ML20203P092
| ML20203P092 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 10/15/1986 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| CON-#486-1251 OL, NUDOCS 8610200255 | |
| Download: ML20203P092 (275) | |
Text
ORG~ NAL c t UNITED STATES NUCLEAR REGULATORY COMMISSION IN THE MATTER OF: DOCKET NO: 50-456 OL 50-457 OL COMMONWEALTH EDISON COMPANY (Braidwood Station, Units 1 and 2) 5 .
LOCATION: CHICAGO, ILLINOIS PAGES: 14472 - 14746 DATE: WEDNESDAY,'DCf0BER 15, 1986
~T8, O / 0 Refuynfo hoe w'/ + Servic e
// J2 /- /-/ 6/.
ACE-FEDERAL REPORTERS, INC.
OfficialReporters 444 North Capitol Street 0610200235 861013 Washington, D.C. 20001 PDR ADOCK OS00 6 (202)347-3700 NATIONWIDE COVERACE
14472 h ( ~) ,
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1 (
l 2 UNITED STATES OF AMERICA I !
I 3 NUCLEAR R EGULATORY COMMISSION !
! i
!' 4 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i :
i 5 !
__________________x .
, 6 i l In the Matter of: :
7 : Docket No. 50-456 l
- COMMONWEALTH EDISON COMPANY
- 50-457 i 8 : :
. (Braidwood Station, Units 1 :
9 and 2) :
- - __________________x 10 l
l 11 Page: 14,472 - 14,746 i O
12 ;
United States District Court House i 13 Courtroom 1743 ,
Chicago, Illinois 60604 Wednesday, October 15, 1986 [
IS i 16 The hearing in the above-entitled matter reconvened !
l 17 at 9:00 A. M.
18 ;
B EFORE: l 19 !
J UDG E H ERB ERT G ROSSMAN, Chairman !
20 Atomic Safety and Licensing Board .
U. S. Nuclear Regulatory Commission 21 Washington, D. C. I i
22 JUDG E RICH ARD F. COLE, Member, j Atomic Safety and Licensing Board ;
23 U. S. Nuclear Regulatory Commission :
Washington, D. C. !
J UDG E A. DIXON CALLIH AN, Member,
)25 Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission I
i Sonntaa Reoortino Se rvice. Ltd. [
- Geneva,~ Illinois 60134 i i (312) 232-0262 [
f 14473 h
1 Washington, D. C.
2 APPEARANCES:
3 On behalf of the Applicant:
i j 4 MICHAEL I. MILLER, E SQ.
[ PHILIP P. STEPTOE, III, ESQ.
i 5 Isham, Lincoln & Beale l Three First National Plaza i
6 Chicago, Illinois 60602 l On behalf of the Nuclear Regulatory ;
8 Commission Staff: -
l 9 GRBGORY ALAN BERRY, ESQ.
ELAINE I. CHAN, E SQ . ?
!. 10 U. S. Nuclear Regulatory Commission !
-7335 Old Georgetown Road !
11 Bethesda, Maryland 20014 {
[ 12 On behalf of the Intervenor-
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/ i 13 ROB ERT GUILD, ESQ . .
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1 EXHIBIT INDEX MARKED R ECE IV ED 2 Applicant's Exhibit No. 149 14516 (
i 3 Applicant's Exhibit No.150 14533-s 4 Intervenors' Exhibit No. 159 14563 l
, 5 Intervenors' Exhibit No.163 145 80 14581 l 6 Applicant's Exhibits Nos. 151 t
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l 1 TESTIMONY OF
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l 2 THOMAS B. THORSELL KENNETH THOMAS KOSTAL t
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! CROSS EXAMINATION (Continued) 4 BY MR. GUILD: 14492 1
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1 JUDGE GROSSMAN: The hearing is reconvened.
2 This is the 74th day of hearing.
3 We ended on Friday with Mr. Guild cross examining, 4 I believe.
S Is that correct?
6 MR. GUILD: Yes, sir.
7 JUDGE GROSSMAN: Okay.
8 Mr. Guild, you can continue.
9 Do we have preliminary matters first?
10 MR. STEPTOE: Yes, Judge Grossman, there are 11 three corrections we need to make.
12 The first one: At some point, the question was 13 raised when the change was made to BCAP-06 with. respect 14 to S&L's role in reviewing the validity versus the 15 invalidity of BCAP observations, and I- stated on the 16 record that it was Revision 8. That's correct.
17 However, the f urther -question is, "When was the box 18 that S & L checked, Box No. 24, removed f rom the form. "
19 That box was 'not removed in Rev 8.
20 There was a change notice in June of .1985 which 21 said, " Consider the box deleted," but the box was not 22 physically removed from the form until Rev 10, which 23 was, I believe, in October of 1985.
() 24 I have no problem providing those documents to Mr.
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1 Guild if he wants to check on that.
2 JUDG E GROSSMAN: Mr. Kostal, do you agree 3 that that is the case?
4 Oh, you haven't checked that out with your 5 witnesses, Mr. Steptoe --
6 A (WITNESS KOSTAL) Well, it was the --
7 JUDGE GROSSMAN: - Mr. Thorsell ?
8 A (WITNESS THORSELL) Yes, I agree that's the case.
9 JUDGE GROSSMAN: Okay, tha t's fine.
10 MR. STEPTOE: The second correction relates
( ') 11 to Transcript Page 14433. It's Mr. Thors ell's R./'
12 correction.
13 There was a discussion with respect to the 14 thickness of the jacket on conductors.
15 Mr. Thorsell, do you recall that discussion?
16 A (WITNESS THORS ELL) Yes, si r.
17 MR. STEPTOE: Would you explain what the 18 nature of the correction is?
19 A (WITNESS THORSELL) Okay. As you recall, we were 20 discussing that there is a jacket on each of the 21 individual conductors as well as, in the case of a 22 multi-conductor cable, there's also an overall jacket; 23 and I had stated that the jacket on individual 24 conductors of a multi-conductor cable is thinner than Sonntag Reporting Service. Ltd.
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1 the jacket would be if that same conductor were just a 2 single-conductor cable.
3 While that's generally true, for the specific cable 4 that we were discussing, which, I believe, is BCAP 5 Observa tion CBL 130, the jacket of the single 6 conductor -- of an individual conductor of the 7 multi-conductor cable is of the same thickness as the 8 jacket would be for a single-conductor cable of that 9 same size.
10 For the large power cables provided at Braidwood, m
(v; 11 the jacket thickness is the same whether it's combined 12 into a multi-conductor cable or whether they are 13 individual single-conductor cables.
14 MR. STEPTOE: Just so we can establish this, 15 Mr. Thorsell, what is the outside diameter of that 16 individual -- I'm sorry -- of the individual conductor 17 within CBL 130 that was the subject of the minimum 18 bending radius violation?
19 A (WITNESS THORS ELL) 1.072 inches.
20 JUDG E GROSSMAN:- Excuse me.
l 21 While we're on that now, are you giving me the 22 outside diameter of the conductor or of the jacket?
23 A (WITNESS THORS ELL) The outside diameter of the 24 conductor with the insulation and j acket. In other Sonntag Repor ting Se rvice. Ltd.
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l 1 words, it's the overall outside diameter.
2 JUDGE GROSSMAN: Well, that's a matter I l 3 wanted to clarify.
t 4 Now, you are telling me, then, thac the standards 5 that were applicable to training radii were based on 6 outsiCe diameters of the jacket now on top of the cable 7 or were they based on the conductor?
- 8. .A (WITNESS THORSELL)' No; on the j acket. Okay. It's on 9 the -- on 'the outside diameter of the entire 10 construction of the cable.
[Jh 'll 12 (Indicating.)
JUDG E GROSSMAN: Okay.
13 Of course, when I say " jacket," I'm talking about 14 the jacket being around the cable, of course -- around 15 the conductor -- I'm - sorry -- not cable.
16 A (WITNESS THORSELL) Correct. But it is.that outside i
17 diameter.
18 JUDG E GROSSMAN: And how is that outside i
19 diameter determined?
20 Are those specifications given by the company that
- 21 are relied on by the QC Inspector?
22 A (WITNESS THORSELL) No. They -- those diameters are l 23 provided by the cable manufacturer, and the cable 24 manuf acturer's quality control program does testing, Sonntag Reporting Se rvice, Ltd.
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G 1 during the manufacturing process of the cable, to 2 confirm that those -- that the diameters provided are 3 accurate.
4- JUDG E GROSSMAN: Well, isn't that somewhat 5 inconsistent with the determination of bend radii for 6 standardized cable, such as using the AWG designations, 7 where there would be a standard bending radius for, 8 let's. say, No. 14 AWG or No. 12 AWG 7 9- A (WITNESS THORSELL) No. The AWG standard establishes 10 the size of the copper.
[\ 11 JUDGE GROSSMAN: Yes, the conductor.
12 I understand that.
13 A (WITNESS THORSELL) All right. And beyond tha t -- all 14 righ t -- for, say -- take, for example, a No. 14 Cable.
15 Tha t No. 14 Cable could have a variety of different 16 insulation thicknesses. Depending on its application l
l 17 and its manufacturer, it could have a variety of f 18 different jacket thicknesses, resulting in a No.14 l
19 Cable - or dif ferent No. 14 Cables having dif ferent l
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20 outside diameters.
l l 21 Now, the bending radius -- allowable bending 22 radius -- is given in terms -- in general, it's given in l 23 terms of a multiple of the outside diameter.
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( 24 In other words --
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l- JUDGE GROSSMAN: Outside diameter 'of the 2 jacket now?
3 A (WITNESS THORSELL) Yes, of the whole -- of the whole 1
4 thing .
5 JUDGE GROSSMAN: Yes.
6 A (WITNESS THORSELL) Okay. And it's also 'a function of 7 what that cable is being used for.
8 For example, if I have a shielded cable, . I may have 9 a different multiplier of outside diameter for allowable 10 bending radius 'ttan for an unshielded cable, but the 11 cables may be the same size, they may have the same l
(
12 outside diameter.
13 JUDGE GROSSMAN: Okay.
14 JUDGE COLE: So for bending . radius 15 applications, the outside jacket diameter is the
! 16 standard measurement?
l 17 A (WITNESS THORSELL) Yes.
l 18 JUDGE COLE: That's general practice, 19 standard practice.
20 J UDG E G ROSSMAN : We' re not only talking about 21 B CA P, we're talking about QC Inspectors --
t 22 A (WITNESS THORSELL) In general, i 23 JUDGE GROSSMAN: -- inspecting as their 24 ordinary inspection requirements have them?
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1 A (WITNESS THORS ELL) Yes.
2 JUDG E GROSSMAN: Mr. Steptoe.
3 MR. STEPTOE: Mr. Thorsell, the third 4 correction relates to Transcript 14466, which had to do 5 with the use of the Bartolucci letter to close out BCAP 6 Observation or CBL 130.
7 Would you describe what the correction is?
8 A' (WITNESS 'IllORSELL) Okay. CBL 130 is a power cable 9 going to the RC/FC fan.
10 The RC/FC f an 'has mounted on it a termination box 11 in which that cable terminates. 'Ihere are actually two 12 power cables that terminate in that box. Both of the 1
13 cables are of. identical construction and both of the
, 14 cables are BCAP sample cables. One of them is CBL 130, l 15 the o th e r is CB L 129. Both of the cables have similar 16 bending radius violations.
17 Mr. Bartolucci looked at both of the cables.
18 However, lat the time that he made his visit, Sargent &
19 Lundy only had the observation for CBL 129 in hand, and 20 so CBL 130 is not documented in Mr. Boj an's letter, l 21 which summarizes those cables that were reviewed by Mr.
22 B artolucci .
23 Now, although Mr. Bartolucci saw both CBL 129 and 24 CBL 130, he would have concentrated on CBL 129, which l
Ronntag Repor t-i ng Ap rvi ce, r.t cL l Geneva, Illinois 60134 (312) 232-0262 l .. . _ - - - _ - . . . _-, ,- . _ _
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. 1 was the subject of the discrepancy report that he had in 2 hand.
3 At the time that I did the evaluation of CBL 130, I 4 thought that Mr. Bartolucci had, indeed, examined both 5 of them with the discrepancies in hand; and my use of 6 the Okonite letter to disposition CBL 130 was in error.
7 It was in error because the understanding that we 8 have with okonite is that we only utilize relaxed 9 criteria on a case-by-case basis where we have brought 10 each of those individual cases to the attention of the Okonite Company.
l \I ,b) 11 ,
12- I should clarify that it's not necessary for an 13 Okonite. representative to physically examine each case 14 that we address to them for relief from their published 15 criteria, but it .is necessary for them to have
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16 sufficient facts to evaluate it and it's necessary for j
17 them to be identified on an individual basis.
18' Cabl'e 130 does meet all of the criteria of the 19 Okonite letter. However, since it was not specifically
. 20 identified to the Okonite Company, my use of that letter 21 was in error.
- 22. I have since contacted Mr. Bartolucci and -- or 23 when I discovered the error, I contacted Mr. Bartolucci 24 and confirmed that the-use of the criteria in the i
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1 okonite letter for CBL 130 is, indeed, acceptable.
2 In addition to that, that cable has been subj ected 3 to a Megger test, as part of the normal construction 4 process at Braidwood, and been found acceptable.
'5 So despite my error in the use of the Okonite 6 letter to disposition the discrepancy at the time, I'm 7 confident that the cable is good and does meet the 8 appropriate criteria.
9 JUDGE GROSSMAN: Excuse me.
10 What exhibit number is that letter?
[ } 11 MR. GUILD: 162, Mr. Ch airman.
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12 MR. STEPTOE: 162.
13 JUDGE GROSSMAN: 162?
14 MR. STEPTOE: Intervenors'- 162.
15 MR. GUILD: It's attached to the observation 16 form letter.
17 JUDG E GROSSMAN: When you said that it meets 18 the. criteria of the letter, you are not talking about 4 19 times the outside diameter; you are talking about 2.5 20 times ?
l~ 21 A (WITNESS . THORSELL) 2.5, with no wrinkling of the jacket 22 and no physical distortion of the cable.
l 23 JUDG E COLE: Mr. Thorsell, you said that you
) 24 subjected Cable 130 to a test l
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1 I didn't get the word that you used to describe the 2 test. . Megger?
3 A (WITNESS THORSELL) Megger.
4- JUDGE COLE: Megger.
5 A (WITNESS THORSELL) M-E-G-G-E-R.
6 It's an insulation resistance test. It's the 7 common method of testing installed cables.
8 J UDG E COLE: All right, sir.
9 Ttiank you.
- 10 JUDGE GROSSMAN: W ell, Mr. Thorsell, I don't 11 want to be argumentative here, but it is somewhat --
12 you'll agree it's somewhat debatable from the letter as 13 to whether a specific instance, not actually reviewed by 14 Mr. Bartolucci, can ever meet the requirements or the 15 criteria of his letter where the bending radius is less
'16 than 4 ? Don' t you agree with that?
17 A (WITNESS THORSELL) I don' t f ollow the question.
18 JUDG E GROSSMAN: Well, it seems to me as I
19 though a logical reading of the letter might be that one
- 20 cannot meet the criteria set forth by the manuf acturer 21 if the cable has a bending radius of less than 4 times l 22 the outside . diameter unless the specific instance is f
23 reviewed by a representative of the manufacturer, and s
l 24 that any instance between 2.5 and 4.0, I guess, would l
l' i
Sonntag Repor ting Se rvice. Ltd.
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14486 I have to be reviewed specifically in order to meet the 2 criteria.
3 Don' t you agree that that's a --
4 A (WITNESS THORSELL) Do you mean -- do you mean that the 5 manuf acturer has to physically examine the ~ cable by i
6 that?
7 JUDGE GROSSMAN: Yes.
- 8 A (WITNESS THORSELL) No, tha t is no t -- tha t is no t th e 9- case.
10 In the normal construction process, in the 11 dispositioning of NCR's, the Okonite Company has only 12 come out to look at individual cases on rare occasions.
13 In general,- our description of the conditions -that 14 exist provide them with sufficient inf ormation --
- 15 JUDGE GROSSMAN
- Yes.-
16 A (WITNESS THORSELL) -- to --
- 17. JUDGE GROSSMAN: Okay.
18 I'm sorry. I realized as soon~ as I spoke the words 19 that I did not mean that' the company has to come out and 20 examine each instance.
21 But the company does have to pass on each instance?
22 A (WITNESS THORSELL) Correct.
j 23 JUDGE GROSSMAN: And so you couldn't just l 24 say, could you, "We have some other cables," unnamed in Ronntag Repor ting Re rvi ce. Y, t d _
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1 a letter to the company, "that have bending radii of 2 over 2.5 times outside diameter but below 4.0, in which 3 we'see there is no visible wrinkling and no apparent 4 physical distortion. Can we take your letter of June 5, 5 1985, to cover those instances"?
6 Now, you do agree --
7 A (WITNESS THORSELL) No.
j 8 JUDGE GROSSMAN: --
don' t you, that from that 9 June 5th letter, you could not -- the company would have 10 to say, "W ell, they are not automatically covered"?
g (d i 11 12 A (WITNESS THORSELL) You are correct.
What I would have to do is identify the specific 13 instance to the company that I wanted to apply that 14 criteria for.
15 In other words, you --
16 JUDG E GROSSMAN: And give a further 17 description?
18 A (WITNESS THORSELL) Right.
19 Your question said -- or in your question, you said 20 additional cables unknown, and that would be --
21 JUDGE GROSSMAN: Unnamed.
22 A (WITNESS THORSELL) Unnamed.
s 23 -- and that would be improper.
)j 24 However, if I had an additional cable that has a Ronntag Repor ting Re rvi ce,. Ltd.
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~1 specific cable number and a specific installed 2 condition, and I describe that specific installed 3 condition and give. the company that particular cable 4 number, then the company will provide -- Okonite, being 5 the . company, will either accept or reject that 6 particular case.-
7 JUDG E GROSSMAN: Now, wouldn' t it .be the 8 usual for you to supply 'a diagram to the company of the 9 installation, a schematic or some pictorial 10 representa tion ?
11 A (WITNESS 'DIORSELL) Not -- not necessarily.
12 It may be _ a verbal description, you know, or a
-13 written -- a written description.
14 JUDGE GROSSMAN: A narrative description?
15 A (WITNESS THORSELL) A narrative description that does 16 not include a diagram.
17 It may include a diagram, it may include --
18- depending on the instances that have come up over the
'19_ course, it's varied all the way from the manuf acturer 20 coming out and physically examining it to us providing 21 the manufacturer with results of various tests, to us 22 physically sending a sample to the manufacturer for 23 further analysis. It depends on the individual 24 conditions.
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O 1 When I talked to Mr. Bartolucci, he did recall the 2 instance, because in order to get to this, you have to 3 crawl over and back around and squat down in a congested 4 area. He recalled seeing the cable, but said that his 5 attention would have been to the cable that was 6 identified -- that had the identified discrepancy that 7 he was attempting to revolve; and he said that the use 8 of the criteria for the other cable was certainly 9 acceptable, i 10 I also have a written letter from Okonite to that L
11 effect for that specific cable.
j 12 JUDGE GROSSMAN: You do have that letter?
13 A (WI'INESS THORSELL) Yes, si r.
14 JUDG E GROSSMAN: Okay.
15 Mr. Steptoe.
16 MR. STEPTOE: That concludes the additional 17 examination I wanted to perform.
l 18 Thank you, Judge Grossman.
l 19 MR. GUILD: Mr. Guild.
i l 20 I take it there are no further preliminary matters, l 21 and so we can continue with the cross examination.
22 MR. GUILD: If I could have just a moment, 23 Mr. Chairman, on this last point.
T
] 24 Mr. Chairman, these subjects are going to be I
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1 visited in cross examination, but I'm trying to, I 2 guess, compromise both absorbing this latest new 3 inf orma tion, including the copies of the letters that 4 were handed me this morning, the rest of the documents 5 given me yesterday, and at the same time not try' to 6 interfere unduly with the progress of cross examination; 7 but I am frankly trying to --
8 JUDGE GROSSMAN: You would like to clarify 9 your understanding with a voir dire of that particular 10 item now and then you'll --
[v }
11 MR. GUILD: No, si r .
12 What I think I prefer to do, frankly, is to be able 13 to pursue this matter a little further off the record 14 before I take the Board's time --
15 JUDGE GROSSMAN: Okay. Tha t's fine.
16 MR. GUILD: -- in the hearing.
17 A matter tha t's, I guess, more or less prelimina ry, 18 let me take up now, eichet in the Thursday or Friday 19 session, you had talked about the process for 20 identifying more highly-stressed sample items or more 21 highly-stressed items in the population of the 22 electrical categories from which BCAP was to select part i 23 of -its engineering judgment sample, j 24 Yesterday counsel provided me with some lists. The l
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, [0 1 lists are, in the present form, of little use to this 2 pa r ty .
3 They are simply lists by component number without 4 any correlation with the CSR sample items, nor .do the 5 items appear to reflect any calculated value for 6 interaction coefficient, which is what I was led to 7 understand was the basis for their selection in the 8 first place.
9 I really would just as soon not take hearing time 10 in trying to extract what is a matter of data from the 4
11 witnesses live on the witness stand.
12 I thought my request was clear at the end of the 13 week; but perhaps if I could simply direct some 14 questions to Mr. Kostal and Mr. Thorsell, so I have a 15 clear understanding of the form in which this data is 16 available and was acquired for purposes of the BCAP 17 sample selection, perhaps my request for further 18 information can be a little more focused; and I may 19 report again to the Board and ask some assistance in 20 acquiring this infotnation.
21 MR. STEPTOE: Judge Grossman, I think there's 22 some misunderstanding.
l 23 I have offered to Mr. Guild Mr. Kostal off the O
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( .24 stand to describe to him -- to explain the list and to Sonntag Reporting Service _. Ltd.
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1 describe the process further, and there's obviously been 2 some miscommunication between me and Mr. Guild.
3 B ut --
4 JUDG E GROSSMAN: Well, fine.
5 You have no objection to proceeding this way?
6 MR. STEPTOE: No, I don't.
Fine.
7 JUDGE GROSSMAN:
8 MR. GUILD: All right sir.
9 CROSS EXAMINATION 10 (Continued)
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11 BY MR. GUILD:
12 Q Mr. Kostal, let's see if I understand now.
13 Let's take -- I understood from your testimony last 14 week that, where available, you provided BCAP Task Force 15 with identification of components that met various I
16 screening criteri a for being more highly stressed, from 17 which you understood they were going to select sample 18 items?
19 A (WITNESS KOSTAL) That's correct.
20 0 All right.
I 21 Now, the numbers are not before me at the present 22 time, but as I understood, there was a screening 7g 23 criteria used depending on the nature of the component.
k 24 For example, you used a screening criteria in the Sonntag Reporting Rervice. T.t d .
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.%J l cable pan hanger population of interaction coefficient 2 of .8 or higher; is that right?
3 A (WITNESS KOSTAL) Tha t's correct.
4 Q And did you identify cable pan hangers at Braidwood that 5 had an interaction coefficient of .8 or higher as 6 designed?
7 A (WITNESS KOSTAL) What we provided them was -- we 8 initially provided them with a list of all. of the 9 hangers -- a l'ist of hangers that had R values exceeding 10 .8.
I 11 Q 'Not R values.
O) 12 A R values.
(WITNESS KOSTAL) 13 Q R values?'
14 A (WITNESS KOSTAL) I'm sorry. Interaction coefficients, 15 IC values.
16 Q Exactly.
17 A (WITNESS KOSTAL) Excuse me.
18 That list was derived at that point in time from 19 the calculations that we had at Byron.
20 The reason for that is the status of. the 21 calculations at Braidwood was still in its evol~ution.
22 We were still providing calculations at Braidwood and 23 assessment of cable pan hangers.
7_
) 24 So in looking at the total population of cable pan Sonntag Reporting Service Ltd.
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V 1 hangers at Braidwood, we could not very easily create a 2 list of highly stressed, by definition, interaction 3 greater than .8, that would be fairly conclusive.
4 We did have the similar hangers that existed at 5 Byron that had been through analysis at that point in 6 time, so we took the analysis that existed at Byron on 7 those same types of hangers and provided a-list of 1,433 8 hangers -- it's about 8, 9 pages -- which represented 9 those hangers that would pass this screening process.
10 0 Let's be clear now.
) 11 That would have an interaction coefficient of less 12 than .8?
13 A (WITNESS KOSTAL) They would have an interaction 14 coefficient of greater than .8.
15 Q Grea'ter than .8. Excuse me.
16 A (WITNESS KOSTAL) Correct.
17 That list, being as large as it was, what BCAP 18 asked us to do was to randomly select.and provide them 19 with a list of 200 hangers f rom this 1,400 hangers.
20 What we did <was then take and generate a set of 21 random numbers. We nu.nbered every single hanger.
22 There are standard methods by which you can es 23 generate a set of random numbers.
k 24 We generated a cet of random numbers, which was 300 Sonntag Reporting Service _. Ltd.
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I 1 random numbers, and from that random numbers, we picked l 2' 200. The first 200 random numbers were the first 200 j
3 hangers we gave to BCAP. From that 200 hangers, BCAP 4 then chose highly stressed additional samples.
5 -Now, in the interim, BCAP had already sampled --
6 through their random methodology and through a certain 7 amount of their engineering judgment sample, -they had I 8 already sampled so many observation packages for the 9 conduit hangers and had assembled --
10 0 Cable pan hangers?
11 A (WITNESS KOSTAL) I'm sorry. Cable pan hangers.
12 -- and they assembled these packages for 13 inspection.
14 They gave us a list of all those they had 15 previously assembled and asked us to check that list to 16 see whether or not any of those hangers were on our list I 17 of the 1,433.
l
- 18 There were a number of those that were on that. We l
19 confirmed which ones were on that list, and then that y 20 told them how many additional samples they would require 21 from this list of 200 that we had provided them.
22 That process evolved into 68, which were defined at 1
23 that point in time as meeting this definition of the OT 24 screening process of more highly stressed.
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l Q All right. j 2 And, again, each of those 68 that were sampled had j 3 an interaction coefficient of greater than .8? !
4 A (WITNESS KOSTAL) Now, that's where the clarification ;
5 has to come. l 6 Because that original sample is based on the ;
7 interaction as it would relate to Byron, at that point 8 in time when we looked at Braidwood -- some of the 9 Braidwood hangers are assembled slightly dif ferently ,
l
! 10 than By ron, so when we were all through with this -- in l
11 terms of review, you will find that in the calculations, ;
12 there are interaction values of certain of those that l l 13 were chosen that are now n'o longer at the .8 criteria.
f 14 Q So they are not more highly stressed by the original 15 definition ?
?
i 16 A (WITNESS KOSTAL) By the original screening process, 17- you would now say that they are not 'more highly 18 stressed. L i
19 O In other words, that there are some of those cable pan !
l 20 hangers selected among the 68 that have an interaction -
21' coefficient of less than .8? i 22 A (WITNESS KOSTAL) As a result of reviewing the actual f
(
23 physical conditions that exist on those hangers at 24 Braidwood and looking at the interaction coefficient on t
f Sonntaa Renortina Service. Ltd. I 4 Geneva, Illinois 60134 l (312) 232-0262 &
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! l 14497 -t i
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i f 'l those particular hangers, some of those do not now meet ;
I !
l 2 that .8 criteria.
{ 3 Q Because they are less than .8?
I !
l 4 A (WITNESS KOSTAL) That's correct.
(
5 Q W ell, si r, do you know what the interaction coefficient l l '6 values were that were derived for the 1,433 cable pan j l 7 hangers that you listed for the BCAP Task Force? !
8 A (WITNESS KOSTAL) Just as.I explained, they were based 9 on the screening of Byron calcs that existed at that l
/
10 point in time.
11' 0 That's how you did it. Now I've got that clear.
l 12 But do you know what the interaction coefficient I
l 13 values were for those listed hangers, the 1,433?
f 14 A (WITNESS KOSTAL) No.
I 15 0 You don't?
16 A (WITNESS KOSTAL) I do not know personally what those 17 1,400 interaction coefficient values are.
18 Q That's not surprising, Mr. Kostal.
19 But does anybody know what they are?
20 A (WITNESS KOSTAL) At the point in time that we did 21 them, we knew what they were, the interaction values I
22 that existed on those 1,433.
23 Today what I would basically have to do is look at 24 the present cales on each one of those hangers and Ronntaa Recor tina Se rvice. Ltd.
l Geneva, Illinois 60134 j
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l 1 define the interaction values that now exist.
[
! -2 At the point in time that we did that, we knew i
l 3 those interaction values.
4 I cannot recreate those original interaction values
! 5 on all those 1,433.
. 6 Q How about any of them?
- 7 A (WITNESS KOSTAL) Sure, I can create them on some; but 3
8 the point is that we do have --
l 9 Q Excuse me.
10 You can create them on- some in which the i ) 11 interaction coefficient happens to be the same as they i
j '12 are now?
I 13 A Well, what it's based on -- if nothing had occurred in l
14 that calculation since that point in time that we
{
! 15 selected it, if there were -- and then -- then we would i 16 have that data.
l 17 If something had occurred in that original
! 18 calculation due to changes in the geometry of the member 19 or whatever have you, whatever typa analysis was 20 performed, we would have the present interaction 21 coefficient.
22 0 All right.
23 All you have is the present interaction 24 coefficient? That's all you can derive because you Sonntag Reporting Service. Ltd.
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I l i
a 1 didn't retain the data for the original. calculated l- -
a 2 interaction coefficient? !
! 3 A (WITNESS KOSTAL) Tha t's correct, tha t's correct.
f 4 JUDGE GROSSMAN: Excuse me.
I 5 How ~ many of the 68 now do not qualify as having .8 6 or greater -- well, .8 or less?
i . .
! 7 A (WITNESS KOSTAL) There's about 20 -- I think there is' j 8 24 or 25 that would now be slightly less than--- some I ,
j 9 are slightly less than .8, and there are a couple as low 10 as .5 based on the physical hangers that exist out at i
11 Braidwood today, L 12 MR. GUILD: Mr. Chairman, that helps clarify; i.
I 13 and now with that clatification, what I would ask is l <
! 14 Applicant identify, from the cable pan hanger i
i 15 popula tion, those cable pan hangers that were sampled in j 16 part of the CSR, and for those sampled, the interaction I
l 17 coefficient as reconstructed.
] 18 JUDGE GROSSMAN: Well, Mr. Guild, I suggest i 19 that it's to your interest to think about this and ask f I 20 for what you want informally, because you may not . cover
{ 21 the area now speaking extemporaneous 1y.
- 1 22 MR. GUILD: I understand that, Judge; and I
, 23 thought I had made the request first or the record and 24 then off the record. I got nothing close to what I was 1 .
Sonntaa Recor tina Se rvice. Ltd.
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1 looking for.
2 I don't want to waste another day of hearing on 3 this; and I would ask, with the assistance of the Board, 4 the company be directed to provide, you know, as close 5 to what I asked for as they can.
6 I appreciate any further explanation that they have 7 that's nelpf ul; but I would like to have the data. so I
$ can get back to work and prepare some cross examination.
9 JUDGE GROSSMAN: Okay.
10 Mr. Steptoe, if that data is --
11 MR. STEPTOE: I have no problem in principle.
12 I just want to understand what Mr. Guild needs, 13 what ' interaction coefficient.
14 Does he mean what the interaction coefficients are 15 today. or back at the time that they were selected?
16 MR. GUILD: Mr. Chairman, I understand from 17 the witness' testimony that that historic information is 18 simply unavailable, and what's available now is the 19 calculated values for the hangers as they exist.
20 MR. STEPTOE: Fine. Then we can provide 21 tha t.
22 My understanding of the witness' testimony was that 23 it's generally unavailable, in some cases it might be, 24 and I wanted to know --
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1 JUDGE GROSSM AN: Of course, if it's available 2 on a historic. basis, you ought to supply that, too, Mr.
3 Steptoe.
4 MR. STEPTOE: All.right.
5 BY MR. GUILD:
6 Q Now, Mr. Kostal, let's see if I can track this for the 7 other populations.
8 Cables: Did you -- just to recap, were there --
9 was there identification of stressed cables or 10 highly-stressed cables?
11 A (WITNESS KOSTAL) No.
12 Q Okay.
-13 Conduits ?
14 A (WITNESS KOSTAL) No.
15 Q Conduit hangers?
16 A (WITNESS KOSTAL) Conduit hangers, yes.
17 Q All right.
18 And can you outline what the process was for 19 identifying those items for the BCAP Task Force?
20 A (WITNESS KOSTAL) The conduit hangers is different than l 21 the cable- pan hangers in the fact that we provide, on a 22 conduit hanger drawing, a listing of loads, for example, 2.3 and it's based on -- maybe it would be best if I 24 illustrated it for you.
l l
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1 0 That would be a help.
2 JUDGE GROSSMAN: By the way, since _ you -all 3 know what you are talking about, it's not important now j 4 that' you define what those interaction coefficients are, j 5 'but I hope you don't let it slip through the cracks, and 6 that when you proceed to question the witness af ter -
7 you've received your discovery request, Mr. . G uild, tha t 8 you will have a full explanation.
9 MR. GUILD: All right, Mr. Chairman.
10 BY MR. GUILD:
11 Q- Just to be clear,. Mr. Kostal, if you would bear with us 12- a second, the interaction coefficient, as you've 13 responded, I take it, is the same thing as defined in i 14 the Sargent & Lundy procedure that we discussed last 15 week?
16 A (WITNESS KOSTAL) That's correct.
- 17 Q It's the reciprocal of the safety margin value?
i 18 A (WITNESS KOSTAL) Design margin value.
l l 19 Q Design margin value, yes.
[ 20 All right, sir.
21 A (WITNESS KOSTAL) What you would find in a typical 22- drawing -- this represents an embedded plate. This 23 represents a conduit, which has conduit attached --
j 24 (Indica ting. )
I
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\s ,/ l 1 Q The conduit hanger with conduit attached? ;
l Yes.
2 A (WITNESS KOSTAL) 3 And this is a -- all right.
4 (Indicating.)
5 What we would provide is a table, and in that table 6 you would have S values, this being -- your definition 7 of S would be 1.0, 1.6, 2.0, rounded off to even 8 half-foot increments.
9 (Indica ting. )
10 What we would also provide is for different types 11 of material -- let's say this is a P1001 versus a IS001.
[Qh 12 These are just different types of _Unistrut membere. . We 13 would also define an Area 1, 2, 3, 4.
14 (Indicating.)
4 15 JUDGE GROSSMAN: I take it S stands for span 16 there?
17 A (WITNESS KOSTAL) No. S stands for the location of 18 the centroid of the load as it relates to the support 19 loca tion.
20 JUDG E GROSSMAN: Oh, okay.
21 A (WITNESS KOSTAL) So this table then would give you 22 values in pounds.
Let's say I'll give you a value for. this of 200 f)'
t s_ 23 24 pounds, and it would go down as this distance got Sonntag Reporting Service. Ltd.
Geneva, Illinois 60134 (312) 232-0262
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1 longer. This would maybe be 150 pounds, this would 2 maybe be 100 pounds, as an example.
3 (In di ca ting . ) .
4 Okay. What areas were defined as -- for example, 5 in the auxiliary building, every ching from the basement, 6 which is arcund 4 -- 346 to and including the roof, 7 which is about 467 -- this is the auxiliary building --
8 that would be defined as an area. Okay. This is an 9 a ea.
10 (Indicating.)
11- There is a note on our drawings wh'ich accurately
(
12 defines it, but, in essence, that's the way we define an 13 area.
( 14 You would find, then, these types of loads.
I 15 What was done is we calculate the dead weight of 16 the conduit.
17 Let's say in this, for example, our S value is 18 going to be 1 foot 1 inch and the load in here is 100 19 pounds. Okay.
20 If -- when we design this, what we do is we 21 calculate this 100-pound load. We look at our S value, 22 and it states -- for an S of 1.1, you immediately go to 23 the 1.6 portion of the table, which says that particular O
k) 24 hanger, and let's give this example P1001 as the hanger.
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1 For this particular member, for this particular 2; conduit hanger, carrying a load of 100 pounds with this 3 dimension, you ' compare it to the allowable load, which.
I 4 is defined in here as 150 pounds. Th eref ore, this is an
- 5. acceptable arrangement.
6 (Indica ting. )
7 The R values that we provided or the screening 8 process that we provided is we looked at our 9 calculations of the weight --
10 BY MR. GUILD:
. 11 Q The interaction coefficient value?
-12 A (WITNESS KOSTAL) W ell, it's not an interaction 13 coefficient in this particular case, 14 I'm sorry. Not R values.
- 15. The ' screening process for the conduit hangers is 16 not based on an interaction coefficient, because this is 17 not a true representation of the state of stress that
- 18 exists within the conduit hanger.
'19- What this provides you is a guidance to assure that
-20 this has already additional built-in conservatisms.
21.. For example, in the auxiliary building, we have the 4 2:2 response spectra that exists at every floor elevation.
H23 For the development of this table for this area, we
( 24- take the response spectra that exists at the extreme Sonntag Reporting Service, Ltd.
I Geneva, Illinois 60134 (312) 232-0262
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l highest elevation and use that value to develop this 2 table for all hangers, no matter where they were at in 3 that building or no matter where they are in the 4 auxiliary building.
5 So, therefore, any place lower in the building, if 6 we used an exact spectra for this elevation, we can show 7 that this l's a very conservative value.
8 That value would go up as you went down in the 9 building;. but we -- for convenience sake, it's just not i
10 economic for us to create that many different matrices
[)
V 11 to. choose from.
12 In addition to that, the table builds in 13 tolerances. All the tolerances that we allow for the 14 installation of a conduit hanger are built into the 15 develo pment of the table.
16 If no tolerance -- if they use none of the-17 tolerances, we can -- again, we have additional 18 conservatisms that exist in the development of the 19 table, because the tolerances basically reduce the value 20 that's given here.
21 (Indica ting. )
22 So those two elements allow -- result in a . very i
23 conservative set of defined loads that we will screen x
) 24 given conduit hanger to.
(.
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Geneva, Illinois 60134 (312) 232-0262
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.V 1 What we did, in providing the list, was to look at 2 the ratio of the actual weight to this defined allowable 3 weight, and whether that actual weight to defined 4 allowable weight, meaning, in this case,100 over 50, 5 since 50 was our -- this would give you a value of .66.
6 JUDGE COLE: You said 100 over 50.
i 7 You meant 100 ove r 15 0 ?
8 A (WITNESS KOSTAL) I'm sorry. 100 over 150. This would 9 give you a valuc of .66.
10 We used a screening process of .7 of.the cales that
/ 11 we had on the conduit hangers that existed at that point k-
-12 in time.
13 That's how we developed the list that we gave to 14 B CA P. Th ey cho se f r om tha t lis t, then, certain items.
15 JUDG E GROSSMAN: Excuse me.
16 I'm not sure I'm focusing on this; but when you 17 have values of less than 1, it would appear as though 18 you've met your criteria without going any further.
l 19 I thought we were talking about cases in which you 20 exceeded the allowable stress.
21 A (WITNESS KOSTAL) No. In none of these populations are 22 they based on exceeding allowable stress.
23 In the cable pan hanger population, an interaction (b) 24 coefficient of .8 means you still have approximately 25 l
l Sonntag Reporting Service ' Ltd.
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1 per cent.
i 2 BY MR. GUILD:
- 3. Q What's the reciprocal of that?
.4 A (WITNESS KOSTAL) 25 percent, it's the reciprocal of 1
5- .8. -It's approximately 1.2.something. I don' t have my
{
6 calculator; but what it's saying, the allowable stress 7 is 1.0, so if you have an interaction value of 1.0, you l
p 8 are exact; your design stress and your allowable stress.
9 are exactly equal.
10 We must stay less than 1.0, so in all cases, you i
/
) 11 will see interaction . coefficients less than -- less than j 12 1.0.
13- JUDG E GROSSMAN: Okay.- I'm sorry. ,
14 Was this taken from the design?
[
l 15 A (WITNESS KOSTAL) This is taken f rom the design. - This 16 is actual weight that exists in the -- in the cable i 17 compared to a table which defines an allowable for given 18 parameters.
19 This -- in ~ terms -- this' would be an allowable, 150 l
20 pounds is the allowable, whereas th j?tual is the 100 21 pounds, so this ratio, by this example, is .66, which 22 says that you have, in this example, additional 33 23 percent design margin by this example if you use it in 24 terms of design margin.
l i
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'l What I am saying is that this allowable is really 2 not the t:ue allowable on a given conduit hanger.
i 3- The true allowable on a .given conduit hanger -
! 4 would -- you would calculate it by doing an exact 5 analysis of the properties, i 6 For example, I chose, even though -- though this 7 dimension is 1.1 and we_ chose the 1.6 -- I mean, the1 i
8~ foot 6 inches, the really allowable, if I just ratio the 9 dif ference of that 1 inch, would be closer to.200 than 4
10 it would be 150, so --
11 JUDGE GROSSMAN: By interpola ting between l
12 those two numbers?
13 A' (WITNESS KOSTAL) Right.
- 14 BY MR. GUILD
1
- 15 0 All right, sir.
i
[ 16 Now, what you -- so this is how you derive- your 17 list of more highly-stressed conduit hangers, i 18 And I take it that once you got back the results of 5
19 the CSR inspections of conduit hanger discrepancies and 20 performed design evaluations on those that met your R 21 value screening criteria, you no longer used this 4
- 22 screening method?
4 23 A (WITNESS KOSTAL) Not R value screening criteria. It 24 wasn't an R value screening criteria.
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J 1 Q Not for conduit hangers?
2 A~ (WITNESS KOSTAL)- lio, R is not the screening criteria.
3 Q Well, R was the screening criteria for structural 4 members and for welds?
J 4
5 A' (WITNESS KOSTAL) Interaction, not R; IC, the screening 6 criteria for choosing the highly stressed or the more i 7 highly stressed.
8 Q No, no, no. You lost me there.
.9 Once you got the discrepancy back, you ~ provided 10 these highly-stressed items on the basis, as you just i
11 described, of the screening criteria; in the case of 12 conduit hangers, the comparison of the allowable load to 13 the actual load at least projected for that condult 14 hanger. Okay.
15 You screened those.- You gave the list to CSR. CSR
-16 went out, did their inspections, identified 17 discrepancies. A list of discrepancies then came back 18 to Sargent & Lundy.
19 Now, you then performed an evaluation for design ,
20 significance of some of those.
21- Now, do I understand correctly that at that stage 22_ you used an R value screening criteria to decide which 23 ones you do detailed calculations on?
24 A (WITNESS KOSTAL) Yes, si r.
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1 Q Okay.
2 Now, did you abandon. the screening device that you 3 used for the selection of the more_ highly-stressed 4 conduit hangers at the point where you were doing a 5 design evaluation and resort to a detailed evaluation of 6 actual conditions?
7 A (WITNESS KOSTAL) We never abandoned. This was never 8 used.
9 Q You didn't use it?
10 A (WITNESS KOSTAL) We just looked at the actual 11 conditions that existed --
12 Q All right sir.
13 A (WITNESS KOSTAL) -- on that particular conduit hanger 14 and used the screening process of .9 --
15 Q Understood.
16 A (WITNESS KOSTAL) -- and if it didn' t meet the 17 screening process of .9, we performed a more detailed 18 analysis.
19 Q All right, sir.
20 Now, how does that screening process for the 21 discrepancies, which used the threshold value of .9, th e 22 R value calculation -- how does that compare with the 23 calculation of the screening measure that you used for (j 24 the sample selection, if it compares at all?
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1 A (WITNESS KOSTAL) I didn't do that comparison.
i
! 2 Q I'm sorry ?
l 3 A (WITNESS KOSTAL) I didn't perform that comparison; but
. 4 it really wouldn't- be a comparison.
i 5 Q_ There is no comparison?
6 A (WITNESS KOSTAL) No.
l 7 Q They are different analytical approaches?-
i 8 A (WITNESS KOSTAL) _ Totally dif ferent.
9 Q All right.
t 10 Now, that gives us.a list of conduit hangers -- -
\
- 11. A (WITNESS KOSTAL) Maybe I can clarify f urther,
- f. 12 The reason that screening process isn't required is I
- 13 because of the number of calculations we did in j 14 developing this - table, and by doing an exact ,
- 15 calculation, we have enough data in-house to show that 16 these values are conservative generally in the order of j 17 40 percent or better.
i.
l 18 (Indica ti ng. ) ,
( 19 Q So you get your list of conduit hangers by this 20 screening process. ;
21 And how -many did you send over to the BCAP Task 22 For ce ?
23 A (WITNESS KOSTAL) We just gave them the entire list, s
24 and then they chose from that list.
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1 Q So you gave them a run of what, all conduit hangers?
2 A (WITNESS KOSTAL) No. We just gave them the list that 3 you have in your hand right now.
, 4 Q Which is those that met the .7 calculation threshold 5 value ?
6 A (WITNESS KOSTAL) That's correct. At that point in 7 time, of the cales that were performed that we had, that 8 was what it met.
9 'O All right.
10 And they selected -- they, the BCAP Task Force, I \ 11 selected from that list that you sent out?
b) 12 A That's correct.
(WITNESS KOSTAL) ,
13 - MR. GUILD : Now, Mr. Chairman, with respect t
14 to conduit hangers, knowing those values, what I would 15 like to do is know what the values were for the conduit 16 hanger items that were sampled for the -- in the CSR 17 por tion of BCAP.
18 I now have a list of conduit hangers identified by 19 component number, but there are no stated values for 20 those, nor are there -- is there a correlation between i
21 those lists and items that got sampled in the CSR.
22 JUDG E GROSSMAN: Any problem with that, Mr.
t 23 Steptoe?
24 MR. STEPTOE: No, Judge Grossman.
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1 JUDGE GROSSMAN: Okay.
2 One thing you haven't clarified to me, and 3 perhaps --
4 A -(WITNESS KOSTAL) Sure.
5- JUDGE GROSSMAN: --
perhaps others to Judge
. 6 Cole, is when you made your actual R value calculation, 2
7 did you utilize the standards 'that you show in this l 8 table where, for that example, you have 150 as the unit?
9 Did you use those?
10 A (WITNESS KOSTAL) Yes.
I Oh, o kay.
') 11 JUDGE GROSSMAN:
.J 12 And you didn' t interpolate between different 13 ca tegories, did you?
14 A (WITNESS KOSTAL) Well, let me go back.
15 R value doesn't relate to these loads. R value i
16 relates to the discrepancy versus the original item.
l 17' I guess I said the wrong thing. It's related to
, 18 the example I gave the other day, which is the weld that l 19 has an inch missing from it.
20 J UDG E G ROSSMAN ; Okay.
4 21 In other words -- well, going back to that table
. 22 you just have on there now, then to relate to the 100
. 23 rather than the 150 on that example you give?
24 A (WITNESS KOSTAL) Well, it would actually relate to --
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O w,
1 f or e xam ple', in the case of a weld, it would relate 2 purely to the detail requirements of the weld, 3 disregarding the discrepancy; and the R value is, again, 4 the area -- in this case, the area of the weld remaining 1
l 5 versus the area of the weld that was originally 6 designed.
7 In a case like this, what we would be looking at is 8 this connection.
9 (Indica ting. )
10 BY MR. GUILD:
, 11 Q When you say "like this," Mr. Kostal --
12 A (WITNESS KOSTAL) W ell, this particular example right 13 here.
14 (Indica ting. )
15 0 The example that you are describing on your chart?
16 A (WITNESS KOSTAL) Right.
17 MR. STE PTOE : Bob, could we mark that as 18 Applicant's Exhibit 148?
19 MR. GUILD: That would be fine.
20 JUDGE GROSSMAN: Okay.
21 Applicant's Exhibit 14 8, which we will follow the 22 same rules for --
23 MR. STEPTOE: 149.
24 MR. GUILD: 149.
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1 JUDGE GROSSMAN: ' -- 149.
2 MR. STEPTOE: And, we will follow the same 3 procedures that we have in the past and make smaller 4 copies.
5 (The document was thereupon marked 6 Applicant's Exhibit No.14 9 f or 7 identification as of October 15, 1986.)
8 A (WITNESS KOSTAL) What we would be -- I'm sorry.
9 In this particular case, what we would be 10 evaluating is there was a weld made to -- let's say this
[ ) 11 is a gusset plate, and this gusset plate is welded here, V
12 here. This is a dotted line, because it's behind the 13 gusset plate --
14 (Indica ting.)
15 BY MR. GUILD:
16 Q To the Unistrut?
17 A (WITNESS KOSTAL) Yes.
18 -- and then it would be welded here. So what you 19 would see is a weld here and you would see a weld here.
20 (Indica ting . )
21 So if I'm looking down in plan, what you would see 22 is two plates in this example with the Unistrut, which 23 is welded, and the discrepancies we would be evaluating 24 would be those that occur within these welds; and the R Ronntag Repor ti ng Ap?vi ce; Tkd _
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\~J l value relates to the -- let's say the design weld versus 2 the actual as-built weld rather than this load.
3 (Indica ting. )
4 JUDGE GROSSMAN: Well, let's assume in this 5 example that that 100 represents the design value for 6 the weld there.
7 Would that be an inappropriate hypothesis for the 3
8 example you give?
9 A (WITNESS KOSTAL) If this is the design value for the 10 w eld, then what we would calculate, then, is the actual
=
j x_/
) 11 value of the weld.
12 So using this example --
13 (Indicating.)
14 JUDGE GROSSMAN: I'm sorry.
15 You pointed to the table now, but the table isn't t 16 the design value of the weld.
17 The table is the design requirement for the weld, 18 if I understand it.
I 19 A (WITNESS KOSTAL) Let me back up.
20 This 100 pounds represents the weight 'that's in the 21 cabl e --
22 BY MR. GUILD:
( 23 Q The conduit?
24 A (WITNESS KOSTAL) -- I mean, it's in the conduit.
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1 JUDGE GROSSMAN: Oh, I'm sorry. Yes.
2 A (WITNESS KOSTAL) It represents the we'.ght within the 3 conduit, and you then compare the weight in the conduit 4 to the allowable weight that this hanger can carry --
5 JUDGE GROSSMAN s Yes.
6 A (WITNESS KOSTAL) -- of conduit.
7 In order to determine the actual stress in this 8 weld, you need to know this weight, you need to know
, 9 these geometries, and you can calculate forces that 10 exist in this weld. Then you can calculate the actual 11 stress that exists in the weld.
[G) 12 (Indi ca ting. )
13 The actual stress that exists in the weld is 14 reviewed, then, against the original stress in the weld, 15 and that will then give you your ratio of your R value,
- 16' or you can compare the actual stress in the weld to the 17 allowable stress in the weld, which gives you, then, l
18 your interaction coefficient.
19 JUDGE C"0SSMAN : Okay, i 20 A (WITNESS KOSTAL) So in this particular example, if
, 21 your :ctual stress is .5 -- let's say 5 KSI, or kips per l
22 square inch, and your allowable stress is 10 kips per 23 square inch, your interaction coefficient would be .5.
) 24 JUDGE G ROSSMAN: Okay. I'm sorry.
J i .
! sonntaa Renortina se rv i ce. Ltd.
G e nev a', Illinois 60134
( (312) 232-0262
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! 1 I shouldn't have used that 100.
2 You were referring to the 150. That is the 3' denominator --
l l 4 A (WITNESS KOSTAL) Right.
i 5 JUDGE GROSSMAN: -- of tha t eq ua tion yo u h avt i 6 up there, yes.
7 Thank you.
- 6 JUDGE COLE
- Mr. Kostal, with respect to 9 Applicant's Exhibit 149 and the values in the table, you i 10 stated that the allowable loads shown ther< by 200, 150
.and 100-pound values are conservative by 40 'pe,rcent or 11 12 more.
13 By that do you mean, sir, that if you had exactly
). 14 an S value of 1.0, that the 200 value would be 15 conservative by 40 percent or on the average would the
- 16 values- be 40 percent?
i 17 A (WITNESS KOSTAL) On.the average..
18 I'm not -- you know, we have a number of examples 19 that we have run to develop these tables, and based on i
i 20 the spectra changes that exist from the -- you know, . th e
- 21 lowest elevation to the top elevation, that's a certain
} 22 . percentage that you would obtain based on doing exact
, 23 analysis.
I 24 The other thing that would enter into the actual j
i
. Sonntag Repor ting Service. Ltd.
Geneva, Illinois 60134 l- - . - . . . . . . . (312) 232-0262
l 14520 i
l' \
i-i 1 true maximum would be the number of tolerances that are f.
2 included. The other thing that would take into account 3 is the actual..S values that would exist.
4 very seldom do you hit it right on the money. In
! 5 ' most cases, you are never -- you are not on the money, f 6 you' are generally in between here; and you are always i
- 7. choosing the more conservative S value, which is the i.
- 8 next value down, which is always less.
l
- 9 JUDGE COLE: All right, si r ,
f 10. The reason why I asked the question is you made the
'll statement they are conservative by 40 percent or more, 12 .and I was wondering if you meant that, okay, right'on l 13 the money it would be 40, and then anything above that, ,
14 for example, between 1 and 1.5, would be more than 40.
j -15 A (WITNESS KOSTAL) What I'm basing the 40.on is when we r ,
l 16 do an exact analysis of a given hanger and compare that
- j. 17 exact analysis to the load t, .e, tha t ra tio is l
18 generally 40 percent conservative.
! 19 JUDGE COLE: So based upon all the 20 calculations you have made, you observed 407 ,
21 A (WITNESS KOSTAL) Tha t's correct.
22 JUDGE COLE: . Okay.
r 23 Thank you.
24 JUDGE GROSSMAN: Excuse me.
Sonntag Repor ting Service. Ltd.
Geneva, Illinois 60134 ,.
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14521.
O 1 Then. do you take that 40 percent into-account in 2 making your final determination as to design 3 significance ?
4 A (WITNESS KOSTAL) In looking at the design 5 significance, i f we ca n -- we m ay if --
6 JUDGE GROSSMAN: I see.
7 A (WITNESS KOSTAL) -- it's available to us.
~
8 Have we done it in each case, I can't say, because 9 I don't have all that data in front of mes, but it's the '
10 normal -- it's -- in the normal process of developing
. 11 these tables, you would go back to the individual 12 analysis on a given hanger, which is a -- it's a 13 computer program, so- it's very easy to put in all these I 14 parameters and do .a little computer run, which only i 15 takes a f ew seconds, because it's all programmed on our
- 16 size hang program, which is called a size hanger l
l 17 program, and that defines and gives you, the n, the l 18 stated -- the actual stress compared to the allowable l
l 19 stress on this particular connection.
20 The connections are all defined within the program, 21' all the member properties are defined within the 22 program. All we have to -- to input is this load and 23 this S dimension, and you can get an actual state of l
24 stress that exists within that given hanger.
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V 1 JUDGE GROSSMAN: Now, I take it also -- I'm 2 sorry -- in arriving at the Y and Z values, you do not 3 take into account that 40 percent?
4 A (WITNESS KOSTAL) That's correct. The Y and Z are 5 purely based on the R value, which is . based on the --
i 6 for example, in the case I explained before, it was the 7 area of the weld provided versus the area of the weld 8 remaining after you took out the discrepancy.
9 JUDGE GROSSMAN: I'm sorry.
10 JUDG E COLE: So this table is used for design
, 11 purposes, but when you are making a check on a design,
\s_-
12 you don' t use that table; you make the actual stress 13 calcula tions ?
14 A (WITNESS KOSTAL) Right.
15 The table is a convenience tool out at the site.
16 These are done at the site. We're putting up hanger.
17 We get exact length of conduit that is attached to 18 hanger with exact locations, and we do a quick check on 19 the weight, we do a quick check on the S and we do a 20 quick review of the matrix to see if we' re okay. Th at' s 21 the main purpose of this table.
22 J UDG E CALLIH AN : Is the 100-pound load, in 23 your right-hand margin, that box -- is tha t a 24 distributed load among many hangers?
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1 A- (WITNESS KOSTAL) No. What that load is is there's --
2 the hangers are generally spaced, let's say, eight feet 3 on center. - You have a conduit -- let's say you have 4 three hangers, so you have a spacing of eight and eight.
5 So what this would be is the conduit length. H al f 6 of that is eight -- eight feet. 16 feet divided by 2 is 7 8 feet. That's the tributary -amount of conduit that 8 would be attached to this particular hanger in the 9 example you gave.
10 (Indica ting. )
11 Did you understand?
(
12 J UDG E CALLIH AN : So in your example, you've 13 got a span of 16 feet with 3 hangers,1 in the middle 14 and 1 on each end?
15 A (WITNESS KOSTAL) Right.
16 JUDGE CALLIHAN: And now, please, again, 17 relate the hundred pounds to that picture that you have 18 drawn.
19 A (WITNESS KOSTAL) Well, I'll just stay on this same 20 sh ee t.
21 This would be a hanger, this would be a hanger and 22 this would be a hanger. Let's say we have a conduit 23 going across all three. It's attached here, here and 24 here. This is the dimension I just gave you, which was Sonntag Reporting Servicef Ltd.
Geneva, Illinois 60134 (312) 232-0262
14524 D\
l eight feet. This is eight feet, also, s
2 (Indicating.)
3 So in this particular example, the tributary weight 4 that would derive this 100 pounds is basically this 5 tributa ry weight. Four feet and four feet, or eight 6 feet, of that conduit would be applied to and deriving 7 the load that would be applied to this hanger.
8 (Indica ting. )
9 J UDG E C ALLIH AN : And so what I called the 10 distributed load of the conduit is like 12-1/2 pounds 11 per lineal foot?
(
12 A (WITNESS KOSTAL) Right, in this case, it would be.
13 12-1/2 pounds, which would be the linear load per foot, 14 times 8 would give you 100 pounds.
15 JUDGE C ALLIH AN : Thank you.
16 A (WITNESS KOSTAL) We don't do any moment contribution 17 to calculate exact weights that would really exist in a 18 multiple span, which you could do, but it's j ust -- it's 19 not something worthwhile to do in this particular type 20 of example.
21 ,
JUDG E GROSSMAN: Mr. Guild.
22 BY MR. GUILD:
23 Q So the screening purpose -- just to return, when you say
( 24 there's conservatism built in and those conservatives on Sonntag Reporting Service Ltd.
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14525 i
1 average are 40 percent- at the margin, those 2 conservatives are less than 40 percent?
3 A (WITNESS KOSTAL) At what margin?
4 Q At the margin where, for example, you are talking about 5 the highest elevation in a particular area before you 6 move to the next area designation.
No. 40 percent even at 7 A (WITNESS KOSTAL) I'm sorry.
8 the highest; and we have much more than that at the 9 lowest.
10 Q All right.
[v ) 11 How about where the tolerances are not -- where the 12 tolerances don't exist in the actual application, .where 13 the tolerances are not used, less conservatism?
14 A (WITNESS KOSTAL) You mean where the tolerances have 15_ been taken advantage of in construction?
16 0 Yes.
17 A (WITNESS KOSTAL) That would reduce part of that 18 conse rva tism.
19 Q All right.
20 And where your -- instead of extrapolating your 21 closest to the lower value, instead of the higher value, 22 the conservatisms are less?
23 A (WITNESS KOSTAL) You never extrapolate to the lower 24 value.
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1 Q You always extrapolate higher.
2 But where the actual value~ is highest to the lower 3_ value --- I'm sor ry.
4 Where the actual value is closest to the highest 5 value and you extrapolate, therefore, less to the higher 6 - value, conservatisms are less than where the . actual 7 value is closest to the lower value?
8 A '(WITNESS KOSTAL) Right.
9 The . bottom line is, based on all the things you 10- have talked about, 'we have taken all those parameters 11 into account, and we get 40 percent.
\
12 Q On average?
13 A - WITNESS KOSTAL) On all the ones we've analyzed.
14 Q On average?
15 A (WITNESS KOSTAL) All the ones we analyzed is not an 16 average.
- 17. The average is the ones that exceeded 40 percent, 18 which are even as h'igh as, let's say, 80, 90 percent.
19 Q What's the average?
20 A What I am saying is --
21 -Q When you explained this the first time, Mr. Kostal, you 22 used a value of 40 percent.
23 What is the average?
24 You didn't use the maximum value, you didn't use Sonntag Reporting Service. Ltd.
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V 1 the minimum value. You gave an average.
2 A (WITNESS KOSTAL) I gave you a rough range of what I --
3 what I believe, based on looking at actual calculations, 4 are ranges of - conservatisms.
5 The actual average value, I don't have that 6 n um be r --
7 Q All right, si r.
8 A (WITNESS KOSTAL) -- but of ever calc I have looked at 9 so far, we have had at least 40 percent.
10 So to answer your question, I would define average
[ ') 11 as- the minimum average -- minimum value that we would C/
12 generally find.
13 J UDG E G ROSSMAN : Do I understand correctly, 14 then, that you have used values greater than 40 percent 15 as allowances in your calculation?
16 A (WITNESS KOSTAL) 40 percent is just the additional 17 design margin that remair.s if you went through this 18 example. 1 19 JUDG E GROSSMAN: I'm sorry.
20 I was groping for words; but you have used ---
21 A (WITNESS KOSTAL) In looking at -- checking a given 22 discrepancy, would we have interaction values with exact 23 analysis that would have design margins less than 40 b
- 24 percent ?
Sonntag Reporting Service. Ltd.
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14528 1 Could be., I'd have to look at each calculation to 2 determine that, but that's something you could check, if 3 you wanted to know that.
.4 JUDG E GROSSMAN: No.
5 'the question I had was that I take it in many 6 cases, you had over 40 percent that you utilized in your 7 calcula tions ?
8 A (WITNESS KOSTAL) Right.
9 JUDGE GROSSMAN: As high as 89 percent; is 10 that what you said?
b 11 A (WITNESS KOSTAL) Well, some were -- for example, the N' 12 loads of a conduit, some of these smaller conduits only 13 weigh a pound, two pounds, a running foot, so the actual 14 load ' that's attached is -- in some cases are 10 pounds,
~
15 where our mimimum load could be 200 pounds.
16 In this case, we would only be at five percent of 17 even the table value, let alone if we did an actual 18 analysis.
19 So there are a number of cables that exist in the 20 plant attached -- that are small cables attached to 21 hangers of this nature which have very small loads 22 applied.
23 BY MR. GUILD:
24 Q Conduits you mean to say?
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v 1 A (WITNESS KOSTAL) Conduits. Excuse me.
2- JUDGE GROSSMAN: Okay.
3 Maybe I've-missed the boat completely; but I 4 understood, in your final calculations of design 5 significance, you did not just utilize the table. You r
6 calculated in the table certain design -- in your value, 7 certain design allowances, or whatever the word is, so 8- that your actual. value -- the values you used were 9- different from the table values by the utilization of 10 certain additional values; is that correct?
I h 11' I'm sure I'm not hitting the right words now.
V 12 A- (WITNESS KOSTAL) What I can' t say right at the moment,-
! 13 Judge Grossman, but I can check, is whether or not in 14 this assessment we went back and did individual 15- calculations; and I think we did a couple of certain 16 conduit hangers that had discrepancies on them.
17 In general, the evaluations were done based on just I
18 comparing the tables.
19 JUDG E GROSSMAN: Without taking into account 20 a 40-percent factor?
l 21 A (WITNESS KOSTAL) Without taking into account the exact 22 analysis, i
i 23 JUDG E GROSSMAN: Okay.
24 But in no case did you use any set amount like 40 r
f' Sonntaa Reportina Service. Ltd.
Geneva', Illinois 60134 (312) 232-0262
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V i
1 per cent?
2 A -(WITNESS KOSTAL) No.
3 JUDGE GROSSMAN: It was either the table 4 value -- as f ar as you recall now, either the table 5 value or an individual calculation which may have 6 resulted in something on the order of a 40-percent 7 dif ference, is that what you are saying now, from the 8 table value?
9 A (WITNESS KOSTAL) Right.
10 JUDGE GROSSMAN: Okay.
11 A (WITNESS KOSTAL) I provided to Mr. Guild a listing of 12 the average -- in my testimony, I gave the average 13 stress that exists -- or the average de~ sign margin that 14 exists and still remains in those hangers that define 15 the values that are in my testimony; and in looking at 16 all .of those, you will see that they are very high 17 design margin on average.
18 There was one particular hanger -- and I can' t 19 remember the exact value -- which was in the 20 neighborhood, I think, of 30 percent, but I could check l
21 that for you.
1 22 The conduit hanger population --
[
23 MR. GUILD: Mr. Chairman, we will revisit l
24 this subject at a later point.
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l Geneva, Illinois 60134
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k 1 I'm, unfortunately, forced to do some discovery 2 from the stand here, by Mr. Kostal maybe being helpf ul 4
- 3 in terms of answering questions, but I'm really trying 4 to acquire. some information at this stage.
4 5 A (WITNESS KOSTAL) W ell, I'm answering the Judge first, 6 and he asked me a question, what.was the. lowest design 7 margin that exists in any hanger in the population, and 8 the lowest value is 1.32, which is on Hanger COH 9 110-101.
j 10 The next lowest value is 1.43, and it gets -- then 11 the range goes up to as high as 38.5.
12 MR. GUILD: May I proceed, Mr. Chairman?
13 JUDGE GROSSMAN: Yes.
i 14 BY MR. GUILD:
l 15 Q All right, sir.
)
i 16 Now, let's j ust -- you explained your screening 17 approach.
! 18' Now, I understand tne design significance i
19 calculations or evaluations don't utilize that screening.
i 20 approach.
21 As we, discussed, with the Sargent & Lundy 22 procedure, you make individual calculations where 23 appropriate, and in those calculations, consistent with
,) 24 that procedure, you are permitted to make various s
a Snaatag Reporting Service Ltd. ____
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1 b: 'l refinements of those calculations, taking into account j 2' . known values and conservatisms as you described them; I
i 3 correct?-
[ .4 A (WITNESS KOSTAL) Yes.
5 -Q All right.
! 6 Now, let's take the R value again; back to that 7 question.
}- 8 Let's talk about a conduit hanger. Let's not talk 9 -about a' welding discrepancy, let'.s talk. about a i 10 discrepancy in-the placement of the conduit on the
[ 11 hanger, a discrepancy that more directly relates to your j 12 screening value, your S value.
13 How would you calculate an R value where the load
. 14 was placed on the hanger at a point different from where i
i 15 .s pecified ?
16 A (WITNESS KOSTAL) R values for physical dimensions are 17 calculated by looking 'at the new properties of the 18 hanger.
i .
j ~19 In this particular example, what we would look at
- l. 20 is actually -- let's' say if we relocated this dimension, i
! 21 we -- then we can't use this criteria of area over area i
22 because the discrepancy is in this dimension, so in that 23' particular case, we would be looking more closely at .
l 24 what this meant in terms of changes in the load.
l
-Sonntag Reporting Service, Ltd. (
j Geneva, Illinois 60134 '
(312) 232-0262 ,
14533 7
U i
1 (Indica ting.)
2 For example, 'if I had -- I could do a moment 3 comparison; and let me give. you an example of what I'm 4
4 talking about..
5 Q Let's drop the conduit down a significant --
7 BY MR. GUILD:
8 Q -- dimension.
9 MR. STEPTOE: Excuse me.
10 Can we go to another sheet?
I 11 JUDG E GROSSMAN: Yes.
's_,)/
12- I think we're going to have trouble getting this 13 all straight.
14 A (WITNESS KOSTAL) Okay.
15 JUDGE GROSSMAN: Why don't we go to a new 16 exhibit, Applicant's Exhibit 150.
17 (The document was thereupon marked 18 Applicant's Exhibit No.150 for
, 19 identification as of October 15, 1986.)
20 BY MR. GUILD:
21 Q Mr. Kostal, how about take an example where your conduit 22 is placed lower down on the conduit hanger than design
) 23 specified.
, 24 A (WITNESS KOSTAL) Okay. What you are asking is this is i
4 _ So n n t a g lep o r_t ing_fitrylce ,3td .
Geneva, Illinois 60134 (312) 232-0262
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14534 O
1 a dimension of 1 foot 6 inches. This is where it's '
2 supposed to be. This is the as-designed as compared to 3 as-built of, let's say, for convenience, 3 feet. Okay.
4 This represents the as-built.
5 (Indica ting. ) okay.
6 One convenient way -- and it would differ 7 depending -- you could look at, le t's say, the moment 8 about this point X, which is some load, W, which would 9 be W times this distance versus -- this is the, le t's 10 say, as-designed versus as-built.
()11 12 (In dica ting. )
In this particular example, if I used this 13 particular logic, my R value would be 1.6 over 3, which 4
14 equals .5. That could be a way that it was done. c 15 (Indica ting. )
16 0 All right, sir.
)
17 Is there a specified procedure for calculating the 18 R value for this particular type of discrepant 19 condition; that is, a conduit misplaced on the conduit 20 hanger beyond -- outside of the design specification?
21 A (WITNESS KOSTAL) I -- there could be a variety. It i
22 all depends on what the problem was.
23 You know, if it's purely this, which exact method 24 th ey used, I would have to go into the calc to look at; Sonntaa Reporting service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14535 O.
l .but I'm giving you an example of how- an objective 2 discrepancy would -- you would develop an R value for an 3 objective discrepancy.
4 Q All right, sir. Well, that's fine. That's helpf ul .
5 Mr. Thorsell, is there a protocol or a specific 6 procedure at Sargent & Lundy for BCAP CSR discrepancy 7 evaluation of objective discrepancies where the 8 discrepancy is of the character that we have just 9 hypo thesiz ed ?
10 A (WITNESS KOSTAL) Yes, it's -- I'm sorry.
11 A (WITNESS 7UORSELL) Okay. I'm not aware of that
(
12 procedure.
13 How ev er, that type of R value calculation was being 14 done by Mr. Kostal's people rather than by my people.
15 Q So obj ective, it's a configuration discrepancy, but, Mr.
16 Kostal, the structural people would have done that?
17 A (WITNESS THORSELL) Right.
18 Q All right, si r.
19 Mr. Kostal.
20 A (WITNESS KOSTAL) It would be contained in the same 21 design control summary, which was -- I forget the --
22 Q It's an exhibit in evidence?
- 23 A (WITNESS KOSTAL) Well, you don't have the whole -- you l
24 have part of it.
l (_
l l
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1 Q Yes.
2 h (WITNESS KOSTAL) There is -- in Exhibit 161, turning 3 to the page on -- okay. You could use the same logic 4 that's applied under Page 14, Section 3.2.
- 5 JUDGE GROSSMAN
- Judge Cole.
6 J UDG E COLE: Mr. Kostal, before we get too
, 7 far with this, your S1 value is 1.5 feet, and I believe 8 you put 1.6 in your moment diagram, didn't you?
9 JUDGE GROSSMAN: One-and-a-h alf fee t.
10 A (WITNESS KOSTAL) Oh, I'm sorry.
11 JUDGE COLE: You have 1.5 up there; right?
[U) 12 A (WITNESS KOSTAL) It's feet, this is inches; and if I i
13 converted, it's actually 1.5, which --
14 JUDG E COLE: Okay.
15 A (WITNESS KOSTAL) -- I apologiz e.
16 I was just trying to give a rough logic.
17 JUDGE COLE: I understand.
18 A (WITNESS KOSTAL) The logic is defined in reporting 19 capacity reduction, and it allows you --
20 BY MR. GUILD:
21 0 Give me the reference again, if you would, sir, please.
l 22 A (WITNESS KOSTAL) In Exhibit -- the Exhibit 161 --
23 Q Intervenors' 161?
24 A -- Page 14, Article 3.2, which talks about t he various So.Dntag RepEr_ ting Service. Ltd.
Geneva, Illinois 60134 (312) 232-0262
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14537 4 !
)
i 1 ways to determine R values. ;
l 2 -Q All right, sir. '
f i 3 A (WITNESS KOSTAL) One of the ways to determine R values i . t
~
1 4 is using tdue as-built component geometry conditions
- 5 governing properties versus the as-built design .
j 6 ' pro per ti es, i 7 _ Another' way to define the R value is the governing 8 interaction coefficient versus the actual interaction 4
9 coefficient as designed versus the interaction 10 coefficient as built, 11 Q All right, sir. ;
- 12 Now , I'm looking at 3.2, reporting of capacity
! 13 reduction. It's half a page there.
?
.14 I don' t see any reference to conduit hangers.
I i
15 'A (WITNESS KOSTAL) It doesn't. It's just referencing i~ '16 the. entire concept of developing an R value.
I 17 It can be used on a'ny population.
l -18 Q It doesn' t - tell you, for example, that you make the i
i 19_ calculation of this you've hypothesized as the 4
20 representative of calculating a capacity reduction for i
i 21- the condition that we've discussed?
l 22 A Yes, it does. It defines that by looking at what's i
I 23 called governing stress IC interaction for as built
- 24 versus governing stress IC interaction for as designed.
Sonntag Reporting Service. Ltd, Geneva, Illinois 60134 (312) 232-0262.
14538-a 1 That literally is the same as doing this type of 2 analysis. It's just a shortcut --
3 Q All right, si r.
4 A (WITNESS KOSTAL) -
for a. quick assessment of where 5 th e R is.
6 Q All right sir.
7 Is there a single fixed calculational method for 8 all discrepant conditions for calculating an R value?
9 A This concept. allows you to develop the R value for the 10 . unique -- all the conditions that exist in all the 11 different populations,
[v) 12- 0 All right.
13 A (WITNESS KOSTAL) What it says, in essence, is you can 14 calculate the R value simply by area comparisons, by 15 stress comparisons. Either way you can calculate the R 16 value. That's, in essence, what the two examples give 17 you.
! 18 The first example is an area comparison. All you
- 19 are looking at is the geometry properties as built 20 versus as designed.
21 In the second example, you calculate -- it's a i~
22 comparison of stress between as built and as designed.
4 23 Either one gives you an R value.
24 0 All right, si r. ,
l l
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V
~
1 A (WITNESS KOSTAL) One is more exacting; but they both 2 can get you in the range.
3 Q All right, si r.
4 And the individual engineer performing the R value 5 calculation has to make a judgment about which 6 particular approach to use among the two; correct?
7 A Tha t's correct, based on --
8 Q Once he chooses -among the two, whether to do it on the 9 basis of the governing properties comparing as built to 10 as designed, or governing stress, comparing as built to h
[b 11 12 as designed, the engineer has to use engineering judgment to make a determination of how to make those 13 computa tions ?
14 A (WITNESS KOSTAL) That's correct.
15 But what it really amounts to is, you look at the 16 discrepancy, and if the discrepancy is very small, you 17 choose the quickest way to develop an R value; and in 18 that particular example, the quickest way would be just 19 an area comparison.
20 If the discrepancy is, let's say, where you can't 21 use very -- let's say it is greater than a very 22 insignificant discrepancy. One would do maybe a stress 23 calcula tion to determine it.
24 In -- you can use either way. It gets you into the
)
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~
14540 l
1
! ' ll range of where.the R value is in terms of insignificant
-2 versus notable.
j 3 That's~ the whole purpose of the screening process.
2 4 Q' All right.
5 And the results of that. calculation of R'value i
6 would vary depending on which particular approach you
^
.7 chose, would it not, for a given discrepant?
i l 8 A (WITNESS KOSTAL) It will vary, but it's very ' close; and j 9 what I mean by " vary," if it came out - . in some of the 1
10 cales that we gave you, as an example, it starts out at l
i
- 11- .85. Af ter you do a stress calc, compared to an area
! 12 calc, it would maybe change to .884; and,. in fact, in i
1 13 the example, - the cale on the cable Pan Hanger 104, you i
l 14 can see that when you had the initial screening versus I 15 the actual n value when you were doing a stress
- 16 analysis --
!- r
- 17 Q All right.
18 A (WITNESS KOSTAL) -- they are very close to one -another.
j 19 Q Might it change from producing an R value of greater j 20 than .90, therefore, being categorized as insignificant, l.
21 to a calculation of an R value less than .90, 22 categorized as notable?
23 A (WITNESS KOSTAL) No.
24 0 It never happened?
l Sonntag_Recorting. service. Ltd.
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-y, 4
1 A (WITNESS KOSTAL) It wouldn' t.
2 What it will' generally do -- when you do the more 3 exact value, you get a slightly lower R value, not a 4 greater R value, because you are doing a very -- the 5 first time around, you are doing a very simplistic R 6 review based on pure area.
7 The second time around, you are doing a more exact, 8' and you get a slightly lower R value.
9 Q And you never worked the other way? You never went ,
10 through more refined calculational techniques in (v 11 calculating the capacity reduction factor, came up with 12 a higher R value -- higher R value, such as to screen 13 out a discrepancy, and categorized it as insignificant, 14 as contrasted with notable, using the less refined 15 calculational technique?
16 A (WITNESS KOSTAL) I can' t recall ever seeing one.
17 0 All right, sir. All right.
18 We've now got the conduit hanger more highly 19 stressed identification.
20 We talked about cable pan hangers. There are no 21 cables that were more highly stressed. There were no
- 22. conduits that were more highly stressed.
23 That leaves us with equipment.
g_s
( 24 And did Sargent & Lundy identify items in the Sonntag_Repor_ ting Se rvice. Ltd.
Geneva, Illinois 60134 (312) 232-0262
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( !
~. ,
1 equipment population for the BCAP Task Force as more 2 highly stressed?
3 A (WITNESS KOSTAL) Yes, sir.
4 Q All right, sir.
5 And, again, would you just briefly recap what the 6 screening process was used by Sargent & Lundy for 7 eq uipment?
8 A (WITNESS KOSTAL) The screening process on equipment is 9 based on an interaction coefficient of .8 or greater, 10 and it's looking at the interaction coefficient at the
[U 11 attachment location, meaning the equipment attached 12 either to concrete or to steel via welding or via anchor 13 bolting or expansion anchoring.
14 So it would be the connection detail that was used 15 as the basis for determining the interaction coefficient 16 of or for screening exceeding .8.
17 0 All right, si r.
18 Now, I take it it's a given that for purposes of 19 calculating the R value, with respect to a piece of 20 eq ui pm ent, electrical equipment, you didn't look at 21 capacity reductions on the equipment itself; say a motor 22 or a terminal block or a switch?
23 Those were outside the scope of BCAP since they ON
( ,
) 24 were vendor-supplied items?
So nn t a g _R e p o r.t ing._S c rylc c ,_L t d .
I Geneva, Illinois 60134 (312) 232-0262
14543 s
(x., '
1 A (WITNESS KOSTAL) Tha t's correct.
2 0 All right.
3 So when you looked at a piece of equipment, you 4 really looked at it as an empty box, a box that had 5 certain loads on it, but a box that was attached either 6 to a beam, for example, if it's hanging in an overhead 7 configuration, mounted to the floor or attached to a 8 concrete wall with concrete expansion anchors?
9 A (WITNESS KOSTAL) That's correct.
10 0 And it's the mounting detail that you reviewed for n
( ) 11 purposes of analyzing capacity reduction?
\.J 12 A (WITNESS KOSTAL) Tha t's correct.
13 0 It's also the mounting detail that you reviewed for 14 purposes of making evaluation of design significance for 15 eq uipment?
16 A (WITNESS KOSTAL) That's correct, because the mounting 17 details are where the discrepancies were documented.
18 0 All right.
19 Decause that's the limit of the scope of what BCAP 20 looked at for cicctrical equipment?
21 A (WITNESS KOSTAL) Well, not in all areas of electrical 22 eq uipmen t.
,s 23 We're talking -- in junction boxes and things like
() 24 tha t, they did look at various other physical attributes So nnta g_Repo r ting _S c tv.ico ,_Ltd.
Geneva, Illinois 60134 (312) 232-0262
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! )
C/
1 of junction boxes, along with attachment locations.
2 0 They didn't look at motors, though, for example?
4 I didn' t hear the word.
5 BY MR. GUILD:
6 0 They didn' t look at motors, for example?
7 A (WITNESS T110RSELL) I don't recall any motors coming up 8 in the BCAP cample.
9 0 Well, that's becauno they are vendor-supplied items and 10 you didn't samplo motors; correct?
[w )/
11 A (WITNESS ill0RSELL) Well, in actuality, the motors --
12 the mounting of the motor -- a motor generally driven a 13 pump or a f an, and the attachment or mounting of the 14 motor la done in conjunction with the mounting of the 15 pump or the f an, and that's done by the contractor that 16 mounts the pump or the fan, so Comatock was not 17 responsible for the motor mounting, either.
18 Q The answer is, nonetholoon, you didn' t look at motora?
19 A (WITNESS T110RSELL) That's correct.
I 20 Q Thoro may be a variety of motors; but that's correct.
l l 21 You didn't look at switchen and you didn' t look at 22 termination blocka, for example?
23 A (WITNESS T110RSELL) You, wo did.
7-i / T
( j 24 0 You did a donign -- an H value calculation for Sonntag Reporting Scryice,_Ltd. . _ _ - - _ -
Genova, Illinoin 60134 (312) 232-0262
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r !
[
l discrepancy in termination blocks?
2 A (WITNESS WORSELL) Yes. 7 3 Q Did you look at the plastic blocks that were supplied by 4 the vendor and evaluate those for discrepancies?
5 A (WINESS WORSELL) %ere were no identified l 6 discrepancies on those blocks.
7 Q Well, did you look at those? !
l 8 That's my question.
9 A (WINESS WORSELL) %at was not work -- no, sir, that 10 ,
was not work that was performed by Comstock.
11 Q Nor was it work that was within the scope of BCAP7 12 A (WITNESS WORSELL) Correct.
13 Q All right; all right, si r 14 Now, using the screening criteria of .8 or higher j 15 interaction coefficient for equipment, gentlemen, either l 16 one of you, how did you derive a list of pieces of l
l 17 electrical equipment that were more highly stressed? h We derived a list for Unit 1 and Unit t
- 18 A (WITNESS KOSTAL) l l 19 2 of -- there were a grand total of 38 pieces of T
l 20 equipment, and that list was derived by reviewing the '
21 calculations on those particular components.
l 22 Q Now, did you do that using Byron or Braidwood data? j l 23 A (WINESS KOSTAL) It's my understanding these are based 24 on B raidwood.
I Sonntag Reporting _Gervice,_Ltd._ i Geneva, Illinois 60134 l l (312) 232-0262 l
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v 1 Q When you say you reviewed the calculations for those, 2 did you review penciled calculations for each of these 3 pieces of equipment?
4 A (WITNESS KOSTAL) Calculations that were prepared, 5 reviewed and approved at that time.
6 Q Were those individual calculations or was it a computer 7 screening?
8 A (WITNESS KOSTAL) It could be -- many of these are 9 computer-generated calculations, some of them are hand 10 calculations, l It just depends on the piece of equipment in terms
( L11 12 of which method is used.
13 We try in general to computerize as many 14 calculations as possible, but there are a number that 15 are done by hand.
16 Q All right.
17 Well, in the case of electrical equipment, is it a 18 mixed bag, some of each? ;
19 A (WITNESS KOSTAL) I would have to check the individual 20 cales. I don't know the distribution of how many were 21 done either via computer or via hand calculations.
22 JUDGE GROSSMAN: Excuse me.
23 It seems as though you are not as familiar with l L
24 this item as the others; is that correct, Mr. Kostal?
( l T
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'l A (WIDIESS KOSTAL) 'Ihe only problem being is I know the 2 cales exist. The cales were performed and they are 3 f iled.
4 These are the original cales that were used to 5 develop these highly stressed screening lists.
6 I have not looked at these calculations to -- in 7 order to say that this .8 screening process was done on ,
8 these cales.
9 The cales I am familiar with are all the cales that 10 Sargent & Lundy performed for the BCAP discrepancies.
11 These are the cales that exist on the given 12 equipment as any other cales that exist within Sargent &
13 Lundy on all the other commodities; so I just have not 14 reviewed these particular cales.
15 JUDG E GROSSMAN: Well, I take it, Mr. Guild, 16 for discovery, you might want to find out more of the 17 details, which Mr. Kostal does not have, with regard to 18 the screening process.
19 MR. GUILD: Fine. .
20 JUDGE GROSSMAN: I'm sure Mr. Kostal will 21 supply someone with that knowledge or Mr. Kostal will 22 refresh his recollection and be able to supply those 23 details to Mr. Guild.
24 Is that okay with you, Mr. Steptoe?
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V) 1 MR. STEPTOE: Yes, Judge Grossman.
2 BY MR. GUILD:
3 Q Mr. Kostal, I recall you telling me, when we talked 4 several weeks ago now, that there was essentially a 5 screening process for electrical equipment, selection of 6 more highly stressed pieces of equipment, that was 2
7 simplified by the fact that equipment installed at 8 higher elevations was subject to greater seismic 9 loadings and, therefore, the more highly stressed pieces f 10 of equipment existed .at higher elevations?
4 11 A (WITNESS KOSTAL) I said that, in general, that's the 12 case.
13 In this particular sample, we looked at all the f
14 equipment we had cales on at that time and used the 4 15 screening process on them.
4 16 Q All right, sir.
17 Well, correct me if I misheard you, but as I 18 recall, it was to the ef fect that they wanted X number, J
i 19 they, BCAP. You started at the top of the plant, and it i 20 was an easy screen to look at the interaction 21 coefficients for pieces of equipment, and you didn' t j 22 have to get very low in the plant before you got the j 23 requisite number of more -- more highly stressed items?
j 24 A (WITNESS KOSTAL) I don't recall exactly saying it in S o n n t a g_Re po r_ ting _S e ry_ic e ,_Lt d .
Geneva, Illinois 60134 i
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14549 v
1 the way you've said it, but I'm telling you --
2 Q I'm sure you didn't.
3 A (UTTNESS KOSTAL) -- I'm telling you exactly what --
2 4 Q So you gave them a list -- you got a list of everything 5 that met that criteria of the .87 6 A (WITNESS KOSTAL) No, I didn't say ,we had everything.
7 I said we looked at the cales that existed at that 8 time and provided a list that were screened based on .8 9 to give them a listing of hangers that would be more 10 highly stressed.
11 Q Equipment now?
12 A (WITNESS KOSTAL) Equipment that was more highly 13 stressed.
14 Q Well, you used the word 38 pieces, and 38 pieces --
15 A (WITNESS KOSTAL) That's how many we defined here.
16 Whether or not that represents 100 percent of all 17 the equipment existing in the plant with that screening 18 process, I can't say that; but this represents at least 19 38 pieces of equipment that have interaction values 20 greater than .8.
21 Q Well, okay. Now, that brings us full circle.
22 How many pieces of equipment are there?
23 A (WITNESS ROSTAL) I don' t -know.
24 Q How many are there --
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\v 1 A (WITNESS KOSTAL) W e --
2 Q Excuse me. Let me get the question out, so the 3 Reporter can put it down, and then -- I know you know 4 the answer, you anticipate it, but you've got to let us 5 take turns here.
6 A (WITNESS KOSTAL) Fine.
7 Q How many are there, with an interaction coefficient of 8 greater than .8, pieces of electrical equipment in the 9 Braidwood Station?
10 A (WITNESS KOSTAL) I don' t know that answer.
11 All right, si r.
( Q 12 It's greater than 38?
13 A (WITNESS KOSTAL) I don' t kn ow tha t an swe r.
14 MR. GUILD: Mr. Chairman, I'd ask that 15 Applicant supply that information.
16 JUDG E GROSSMAN: Okay.
17 Mr. Steptoe, I think, has agreed to that.
18 BY MR. GUILD:
19 Q All right, sir.
20 How many --
21 JUDG E GROSSMAN: Will you agree to that, Mr.
22 Steptoe ?
23 MR. STEPTOE: Well, I'm not sure that it's 24 doable, but if it's doable -- let me confer with my Sonntag_ Reporting service d td-Geneva, Illinois 60134 (312) 232-0262 ;
14551
\x 1 witnesses at' the next break and then I'll get back to 2 you on that.
3 ' J UDG E 8 GROSSM AN : Fine.1 4 BY MR. GUILD:
5 Q How many did the Task Force ask for, Mr. Kostal, pieces 6 of electrical equipment for the more highly stressed 7 sample?
8 A (WITNESS KOSTAL) They didn't ask for 'any given number.
9 They just _ asked us for some that would be considered 10 highly stressed s'o they could choose -- so they could 11 consider it in that engineering judgment portion of the 12 sampl e.
13 Q Why did you give them 38 instead of, you know, 5387 14 A (WITNESS KOSTAL) It happened to be the calcs we 15 reviewed at that point in time where we had the data i
l 16 available that met the screening criteria.
i 17 Q, Okay.
i 18 Now, is that -- did we cover all the population l 19 areas -- I think we did -- for which you supplied --
20 you, Sargent & Lundy, supplied identification of more l
i 21 highly stressed items for the BCAP sample?
i 22 A (WITNESS KOSTAL) Yes, sir.
( 23 JUDGE GROSSMAN: If you are going on to 24 another topic, we might as well take a break, then. ;
f Sonntag Repor ting Service, Ltd.
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i 1 MR. GUILD: That would be fine, Judge.
2 J UDG E G ROSSMAN : Okay, fine.
3 We'll take 10 minutes.
4 (WHEREUPON, a recess was had, af ter which 5 the hearing was resumed as followss) 6 J UDG E G ROSSMAN: We' re back in session.
7 I understand that Staff has a preliminary matter 8 involving Mr. McG rego r.
9 Miss Chan.
10 MS. CH AN : Staff Counsel has been in touch
.11 with the counsel for Mr. McGregor, Mr. Geocaris, and we 12 have been told that Mr. McGregor will not be available 13 tomorrow at 1:00, as tentatively scheduled, because his 14 counsel has not yet received the final report f rom the 15 Office of Inspection and Audit, and he's not received a 16 letter confirming that their investigations on the 17 second incident have been completed, and until he t
- 18 receives that written confirmation, he would keep his 19 witness from appearing.
l 20 He will be able to appear, however, next Wednesday, 21 Thursday afternoon and Friday, at a date convenient to l
l 22 this proceeding, after he receives that letter.
l 23 JUDGE GROSSMAN: That is next week?
24 MS. CH AN : Yes.
l l
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1 JUDGE GROSSMAN: Okay, tha t's fine.
2 Mr. Guild, would you please continue.
3 MR. GUILD: Yes. ,
i 4 MR. STEPTOE Excuse me.
5 Before we go on, Judge Grossman, we do have a 6 problem in granting the request.
7 As I understood it, Mr. Guild's request was for j 8 interaction coefficients for all the items of electrical 9 equipmen t. l 10 There is a total population, according to Dr.
11 Kaushal's testimony, of 1,843 items that were completed l 12 and QC accepted f rom which BCAP chose its sample, and to i 13 provide calculated . numbers for 1,843 would be extremely 14 burdensome, and I don't believe it would serve any 15 usef ul purpose.
16 We have no objection in providing- those numbers for 17 the 38 which were provided -- the short list of 38 which 18 were provided to BCAP f rom which BCAP chose some for the
! 19 engineering judgment sample.
20 I might also add that in the context of this
- 21 testimony, Mr. Kostal's testimony makes it clear that f 22 stress is not a significant design factor for the
( 23 electrical equipment population; and we certainly take 24 no credit in the testimony for having included -- having Sonntac Reportino Service. Ltd.
Geneva, Illinois 60134 (312) 232-0262
. - . .. _ . - _ . . - . , .- .. . = . . - . .. .. - - -
t 14554-I 1 in our engineering judgment population taken high -- l
! 2 highly stressed pieces of equipment into account.
3 The fact that we did, it seems to me, has some -
4 relevance, but marginal relevance to Applicant's 5 tes timony.
6 To provide. the calculations that he's talking about i
I 7 would be unnecessarily burdensome and a time-consuming 8 task.
9 We certainly can provide them for the 38, and 10 explain in more detail ~ either off the record or on the 11 record, af ter Mr. Kostal refreshes his recollection, how 12 those 38 were picked, but 1,843 just seems to us to - be 13 unnecessarily burdensome.
14 MR. GUILD: Mr. Chairman, as I read the 15 1,843, that number is the estimated size of the total 16 ' electrical equipment population that met the BCAP cutof f
- 17 date of June 30, ' 8 4 '.
! 18 'There's even, of course, a larger population out' 19 there that wasn't within the scope 'of BCAP; but the l 20 question I asked was how many of the items in the l 21 electrical- equipment population met the highly-stressed-22 threshold, the screening factor, of .8 or greater l 23 interaction coefficient, the witness didn' t know the i s
)24 answer, and I asked that that identification and list be I Sonntaa ReDortina Service. Ltd.
Geneva, Illinois 60134 (312) 232-0262
( l 4
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1 1 produced.
.2 If Applicant simply will stipulate' that they have i
3 no knowledge of what that number is or of the 4 interaction coefficients for the others in the segment
~
5 of the equipment population that met that screening 6 threshold, that would suit me just fine; but I think 7 inferences can be drawn from that about the
-8 representativeness.or lack of demonstrated 9 representativeness of _ the samples that were made, but I 10 don' t think that it's not relevant.
11 I submit that if Applicant's testimony is to ' stand i 12 defending their sampling regime, that it should be an 4
13 item tha t's discoverable, i -14 JUDG E GROSSMAN: Well, Mr. Steptoe, you must i
- 15 have had some intermediate number between 1,~843 and 38.
i 16 I f ail to . understand how you got down to 38 without 17- any intermediate number; and perhaps Mr. Kostal could 18 tell me that.
19 MR. STEPTOE: And that's what Mr. Kostal has 20 to refresh his recollection on.
l 21 JUDG E GROSSMAN: Okay.
22 W ell, I suspect the whole discussion is futile now, 23 because there may well be some alternate explanation or ,
- 24 some -- the real explanation that we don't know yet ,
t Sonntag Reporting Service. Ltd.
i Geneva, Illinois 60134 (312) 232-0262
14556 U[x 1 until Mr. Kostal refreshes his recollection or consults 2 with .the people, whoever made the actual calculation.
3 So why don't we just defer this until Mr. Kostal 4 has fuller knowledge of the area.
5 MR. GUILD: That would be fine, Mr. Chairman.
6 I have two other matters before we go back to the 7 e xamina tion.
8 I made available to the Staff, and I'll make a copy 9 available to Applicant and one for the Board, a letter 10 from the NRC that I received yesterday. It's a response 11 to a November, 1985, Freedom' of Information Act request N_
12 that was addressed generally to the subject of the 13 - harassment. and in timida tion conten tion; in par ticula r, 14 Mr. Mendez' and Mr. . Neisler's inspectio'n of ' documents 15 that were in the Agency's possession with regard to that 16 inspection.
17 There is a listing of two attachments, which are 18 documents withheld in whole or in part.
i 19 As Mr. Berry confirmed off the record, indeed, a 20 number of these have immediate f amiliarity.
21 They appear to be -- for example, the first j 22 document on Appendix C, a 3/29/85 memo to Warnick and i
i 23 Weil f rom McGregor and Schulz, it's a document in O
24 eviden ce.
Sonntaa ReDortino Service. Ltd.
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h 14557 O
1 Laying aside the question of why the Agency is 2 withholding f rom response, .under the Freedom of 3 Information Act, documents which are in the public t
4 record of this proceeding, I simply ask counsel for the 5 Staff if he could confirm that, indeed, all of the 6- listed documents in these two attachments have been I prov'ided to the parties in discovery, and Mr. Berry has 7
8 said that he would help me do that.
9 I just wanted to state that on the record and ask 10 that the Staff confirm that those documents have been 11 turned over; and if they haven't been turned over, I 12 would request that they be produced.
! '13 MR. BERRY: Mr. Chairman, over the recess, 14 af ter counsel for the Intervenor made this document
( 15 available to me, I perused it briefly, and on first 16 glance, it appears the overwhelming majority of these 17 documents have been produced by the Staf f in the series 18 of productions beginning January the 10th; and as Mr.
19 Guild indicated, the first document listed on the I
20 Appendix C, for example, is what's been introduced into 21 evidence in this proceeding as Intervenors' Exhibit 42.
22 And on Appendix C, for example, Documents 7 through 23 23, for example, are -- a number of those documents have 24 been introduced in evidence into this proceeding and l
l Sonntag Reporting Service. Ltd.
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( N, U
1 were made available to the parties by the Staff in 2 discov ery .
3 Those documents appear to be letters f rom Mr. Weil 4 to each of the allegers attending the meeting with the 5 NRC on March 29th, the letters that you will recall that 6 the Staff counsel had made reference to in his 7 examination of some of the witnesses, asking them if 8 they received correspondence from the NRC, and most of 9 them indicated they had. That is, this is the cover 10 letter transmitting that.
11 Again, going through this, it appears to this
[d}
12 coun sel, just on a preliminary glance, that almost all 13 of the documents, without exception, on Appendix C have 14 been made available to the parties in discovery back in 15 January of this year.
16 Appendix D, if my memory serves correctly, appears 17 to relate to an allegation .that, at .the time the Staf f 18 made its document production, had not been -- the 19 investigation inspection, had not been completed.
20 My recollection is it was a three-part allegation, 21 and two of the parts had been -- you know, had -- the j 22 investigation had been completed and they appeared i
A 23 relevant to this} proceeding.
2 <l The part th t had not been inspected and was not P
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14559 l
1 inspected by Mr. Mendez or Mr. Neisler at the time the 1
2 Staff made its document production had not -- you know, 3 the Staff had not completed its investigation on that.
4 Consequently, when the Staff made its initial 5 document production, we withheld the documents relating j 6 to this particular allegation pending the completion of g 7 that inspection.
J 8 To my knowledge, this matter still has not been 9 closed out by the Region; but I would certainly 10 undertake, over the luncheon recess, to inquire into
) 11 that, you know, to see if I have overlooked something.
.)
12 Maybe it has been completed; and if that's the 13 case, we would produce those documents.
14 As we indicated to the parties back when we made 15 the initial discovery, we would produce those documents 16 and make.them available to the parties under the same 17 ground rules that the other documents were made 18 available to them.
19 As f ar as the question as to -why the Agency -- the 20- FOI- officers may have withheld, in whole or in part, r
21 certain documents that have been offered in evidence in 22 this proceeding, I can only state -- you know, I can 23 only_ speculate as to that, and I would assume' that one
^
24 of the reasons could well be that the officers -- the Sonntag Reporting Service. Ltd.
, Geneva, Illinois 60134 (312) 232-0262
14560 0
1 l 1 Freedom of Information Act officers at the NRC are not 2 in close contact with the Staff lawyers and they just 3 may not have known that some of these documents have 4 been received in open court.
5 I would note, also, that the documents that the 6 Staff has produced to the parties in discovery, we did i
7 not make a public disclosure of that.
8 You will recall that the parties -- we agreed among 9 o urselves, Intervenors, Applicant and the Staf f, that 10 these documents would be made available and they would 11 be treated as confidential within the meaning of the 12 Board's December 6,1985, protective order, so those 13 documents have not been made -- generally disseminated 14 by either the staff, and to my knowledge, either the 15 Applicant or the Intervenors, so there has been no 16 waiver of any privilege that would att'ach to any of 17 these documents by the Agency, you know, though they 18 were produced by' discovery.
19 I can appreciate, though, that to the extent 20 documents have been introduced and received in evidence 21 in this proceeding without restriction, that the reason 22- for withholding documents pursuant _ to the FOIA may well 23 not -- you know, may not be a sustainable isition.
24 Again, a7C and the FOIA of ficers, you know, Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14561 Q
- l. really -- there's not a real direct --
2 J UDG E G ROSSMAN : Mr. Berry, why don' t you 3 review these documents and find out if there really is 4 any problem with any of those documents, and when you 5 discover what the answer is, we'll then discuss it 6 further here.
7 MR. BERRY: Thank you, Mr. Chairman.
8 MR. GUILD: Mr. Chai rman, I also promised 9 last week to, when I got f rom Applicant copies of the 10 population estimating memos for the other CSR electrical 11 populations, reproduce those and distribute them.
.12 They've been identified and received in evidence as 13 Intervenors' Exhibit 159; and let me' distribute those at 14 this time.
15 First, for the cable pan hanger population, Mr.
16 Chairman,114 items were sampled in order to derive an 17 accessible and QC accepted sample of 67.
18 (Indi ca ting. )
l 19 MR. STEPTOE:' Judge G rossman, I'm just not 20 sure that last statement is right, but I don't want to 21 delay us.
I 22 It's not my recollection of the testimony that 67 i
! 23 were accessible and QC accepted.
j 24 MR. GUILD: You are exactly right. I Sonntag Repor ting Se rvice, Ltd.
i Geneva, Illinois 60134 (312) 232-0262
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)
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i r s 1 misspoke.
2 That of that total, the number 114 represents those 3 items that were determined to have -- those items that 4 were reviewed in the field.
5 Of those, 67 were determined to be final QC 6 accepted and installed as of June 30, 1984.
7 JUDGE GROSSMAN: I take it accessibility
, 8 didn' t come into the matter?
9 MR. STE PTOE : To my understanding, tha t 's 10 right, accessibility did not come into the matter in this _ calculation.
. ()11 12 MR. GUILD: -I stand corrected.
13 For conduit, 145 items looked at for a sample of 14 60.
15 (Indica ting. )
16 JUDGE GROSSMAN: I'm sorry.
17 You said this is Intervenors' 158?
18 MR. GUILD: 15 9, Judge, is my n umbe r.
19 JUDG E COLE: 159.
20 MR. BERRY: Is tha t f or bo th of th em ?
21 MR. GUILD: Yes, they are all a Group Exhibit 22 159.
23 For cable pan, 152 items looked at for 'a sample of O
1
( 24 60 QC accepted.
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14563
- (s i
l_ (Indica ting. )
2 JUDG E COLE: This is --
3 MR. GUILD: This is cable pan, the last
! 4 document I j ust handed you.
) 5 For electrical equipment, 208 items looked at for a 6 sample of 61 QC accepted as of June 30, '84.
7 (Indica ting.)
8 And finally, for Category 1 conduit hangers, 369 9 items reviewed ~ for a sample of 61 QC accepted June 30, 10 1984.
11 (Indicating.)
12 Mr. Chairman, this is a group exhibit, Intervenors' 13 159 already received.
14 JUDGE GROSSMAN: Off the record.
i 15 (There followed a discussion outside the i 16 record.)
17 JUDGE GROSSMAN: Back on the record.
18 MR. GUILD: Mr. Chairman, it seems somewhat 19 uncertain whether, in fact, 159 has been received. That
! 20 was my recollection.
21 But we would offer it at this time if it's not been 22 previously received.
{ 23 J UDG E G ROSSMAN : It has been received -- I'm 24 sorry. It has' not been received.
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1 We'll receive it at this time..
-2 (The document was thereupon received into 3 evidence as Intervenors' Exhibit No.
4 159.)
5 MR. GUILD: Thank you.
6 Mr. Chairman, I believe it's been established
- 7. through the testimony of the last panel, at which point 8 these documents were identified, that the same 9 -methodology was employed for estimating the population 10 sizes -- that is, those items in a population final QC
~
11 accepted as of June 30, 1984 -- that the methodology was
(
12 the same for each of the populations and was described 13 by Dr. Kaushal and others with respect to the cable -
, 14 population'which was the subj ect of an Applicant 15 E xhibit.
~
16 Just to make sure that panel hadn't departed and 17 make sure my recollection is correct, perhaps I co uld 18 ask, through the Chair, if Applicant will stipulate to 19 that fact. q I 20 MR. STEPTOE: Yes.
21 MR. GUILD: Thank you.
22 I'm prepared to go ahead.
23 JUDGE GROSSMAN: We'll accept that 24 stipulation.
l l
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l MR. GUILD: I'm prepared to proceed, the n ,
2 with the examination.
3 -
JUDGE GROSSMAN: Please.
4 BY MR. GUILD:
4 5 Q Mr. Thorsell, let's talk about cable 130, observation-6 02.
7 Now, I j ust -- this is a grab sample, Mr. Thorsell'.
8 I just.-- we discussed cables in our meeting. You said, 9 in effect, "Here's how we handle cable evaluations," and 10 were kind enough to provide me' with this particular 11 observation with the Okonite letter attached, but it's i
(
12 just one _ observa tion. 1:t was an objective attribute, 13 non-welding non-structural.
~
I 14_ Now, low and behold we discovered that, in fact, l 15 you _were wrong or in error; that when you relied on the 16 Okonite letter to close out Cable 130, tha t, in fact, 17 the Okonite man had not even looked at cable 130, but i 18 had looked at the adjacent Cable 129. Physically 130
- 19 was there, as you testified, but you didn't have the
. 20 observation available for him to review at that time.
21 Now, was that just inadvertence on your part, .that 22 you misassociated Observation 130 with the Okonite man's i '
23 specific review and approval?
24 A (WITNESS THORS ELL) Yes, si r.
Sonntag Reporting Service, Ltd. l Geneva, Illinois 60134 (312) 232-0262
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1 Q Did you check the cable numbers that he had looked at, 2 the Okonite man?
3 By that I don' t mean the sample number, but the -
4 cable number.
5 Did you check the cable number that he had looked i
i 6 at with the cable number on the observation form before
'7 you signed off Tom Thorsell on the no design 8 significance block on Observation Cable 130-02?
9 A (WITNESS THORSELL) No, sir. That was the nature of my 10 error.
11 It was my recollection that he had looked at that 12 cable, and not checking the correspondence, an error was 13 made.
14 0 Okay.
15 Well, we talked about this cable over in your 16 offices a couple weeks ago and then we talked about this
~17 cable rather extensively on the record Thursday and 18 Friday of last week.
19 When, exactly, did you discovery that you had made 20 this inadvertent error due to failure to match _ up the 21- cable numbers?
22 A (WITNESS THORSELL) When I retrieved the John Boj an --
.23 or the J. J. Bojan letter and its attachment from the 24 file to produce it per your request.
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J ,
^
l Q All right, si r.
. 2 What did you do -- well, at'that time did you look
~
3 at the cable -- excuse me -- the cable numbers on that i 4 attachment to the Boj an letter --
5 A (WITNESS THORS ELL) Yes, si r.
6 Q -- and compare those to the cable number on Cable 7 130-02, observation 02?
{ 8 A (WITNESS THORSELL) Yes, sir.
9 -Q That's when you discovered the mismatch?
a 10 A (WITNESS THORSELL) Yes, sir.
11 JUDGE GROSSMAN: Was that over the weekend 12 that you are talking about, this past weekend?
13 A (WITNESS THORSELL) I believe it was Friday afternoon 14 that I first was aware that the -- that the cable didn't 15 match.
1 16 JUDG E GROSSMAN: Well, when did you then 17 discuss that particular item with the manufacturer?
i 18 A (WITNESS THORSELL) On Monday and Tuesday of this week.
19- JUDGE GROSSMAN: Okay.
20 BY MR. GUILD:
21 ~- Q Now, back in May of -1985, when -- well, Mr. Bartolucci 22 came out to the site and met with somebody May the 7th, 23 1985, to perform his review of the Okonite cable 24 dis cr epancies ?
i i
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- (312) 232-0262
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l A (WITNESS THORS ELL) To review specific Okonite cable 2 discrepancies, yes.
3 Q All right.
4 Indeed, specific, not including the one that's 5 130-02?
6 A (WITNESS THORSELL) Correct.
7 Q Okay.
8 Do you have a copy of Mr. Boj an's May 13, 1985, 9 letter available to you, sir ?
10 A (WITNESS THORSELL) Not in front of me.
ll Q Could you get one in front of you?
12 MR. GUILD: Perhaps counsel could make one 13 ~ available.
14 MR. STEPTOE: What's the Bates Number on that, 15 Bob?
16 MR. GUILD: It's Bates No. AR 006936006936and the 17 f ollowing pages.
f l 18 JUDG E GROSSMAN: Excuse me.
19 While we're waiting for that document --
l 20 A (WITNESS THORSELL) I have the document.
21 JUDGE GROSSMAN: W ell, in any event, were r 22 there other items that you discovered in your review in l
l 23 which the calculations were made which indicated bend l \
) 24 radius between 2.5 times the outside diameter and 4 l
Sonntag Repor ting Se rvice. Ltd.
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1 times the outside diameter which you had calculated 'and
- i. 2 passed originally that you also discussed on Monday or 3 Tuesday with the manufacturer as far as specifics went?
4 A (WITNESS THORSELL) No, sir.
I
- - 5 JUDGE GBOSSMAN
- I take it you didn't search 6 your files to see if there 'were any such items which you 7 had automatically passed between the 2.5 and 4 on the
~
8 basis of that letter, even though Mr. Bartolucci had not 9 specifically reviewed that item?
- 10. A (WITNESS KOSTAL) There are a total of nine cables that 11 were -- that contain bend radius violations in the BCAP i 12 program, and Cable 130 is the only cable upon which I 13 used Mr.. Bartolucci -- or, actually, Mr. Laksey's letter l 14 to disposition. <
15 JUDGE GROSSM AN: Thank you.
j- 16 I'm sorry. Mr. Guild, continue.
17 MR. GUILD: Okay, si r.
l l
18 BY MR. GUILD:
l 19 Q You have the letter before, sir?
20 A (WITNESS THORSELL) Yes, si r ,
i 21 Q Okay, t 22 Now, who is Mr. Boj an?
23 A (WITNESS THORSELL) Mr. Bojan is an electrical engineer 24 that works for me.
Sonntag Reporting Service _. Ltd.
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1 Q He's a Sargent & Lundy employee?
2 A (WITNESS THORSELL) Yes, sir.
3 Q And who is Mr. Bartolucci?
4 A (WITNESS THORSELL) Mr. Bartolucci is an employee of the 4
5 Okonite Company.
6 Q All right, sir.
7 Well, what position does he hold with the Okonite 8 Company ?
9 A (WITNESS THORSELL) I don' t recall his specific title.
' 10 He is a member of Mr. Laksey's staff in the engineering 11 area based in New Jersey.
(
12 Q Do you know what Mr. Bartolucci's specific 13 qualifications are?
14 A (WI TNESS THORS ELL) No, si r.
15 Q Do you- know what Mr. Bartolucci's background and-16 experience is?
17 A (WITNESS THORSELL) No, sir.
18 Q Is Mr. Bartolucci an engineer?
l 19 A (WITNESS THORSELL) I presume so.
20 Q Do you know or are you just speculating?
21 A (WITNESS THORSELL) I do not know.
l 22 0 Well, Mr. Bojan writes Mr. Bartolucci of the Okonite
, 23 Company, but Mr. Bartolucci doesn' t write back.
24 It's not even Mr. Bartolucci's opinion that was the l Sonntag Reporting Service Ltd.
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1 basis for your misreliance on the Okonite letter. It's 2 an opinion by Mr. Laskey?
3 A (WI'INESS THORS ELL) Yes, si r. !
4 Q Do you know what Mr. Laksey's qualifications are?
5 A (WITNESS 'm0RSELL) Mr. Laskey is a vice-president of 6 the Okonite Company.
7 I am f amiliar with his reputation only in the cable 8 industry as a -- as an expert and author of technical 9 papers in the cable industry and --
- 10 Q All right, si r.
11 So you have some competence --
12 MR. STEPTOE: Excuse me.
13 Could he finish?
14 JUDGE GROSSMAN: Yes. Let him finish.
15 A (WITNESS THORSELL) -- and he is Mr. Bartolucci's boss.
16 BY MR. GUILD:
17 0 Well, I'm looking at the same document in f ront of you, 18 and it says, "J. S. Laskey, vice-president-research and l
l 19 engineering."
20 So we know he's a vice-president and we know he's
! 21 over research and engineering, and you have some 22 understanding --
l 23 A Excuse me. I don't have that document in f ront of me.
24 0 Oh, you don't. I'm sorry.
Sonntag Reoorting Service. Ltd.
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/' N 1 I'm looking at Intervenors' Exhibit 162, th e 2 observation for Cable 130-02 with the June 5, '85, 3 letter attached.
4 A (WITNESS THORSELL) Okay.
5 Q That's the letter from Okonite that you relied on 6 mistakenly in closing or determining 130, Cable 130, 7 Observa tion 130-02, is not design significant?
8 A (WITNESS THORSELL) Correct.
9 Q All right.
10 Now, but it's Laskey who responds to Boj an's letter
) 11 to Bartolucci?
(/
12 A (WITNESS THORSELL) Yes, sir.
13 Q All right.
14 Well, but I take it that Mr. Laskey didn't look at 15 the cables, did he?
16 A (WITNESS THORSELL) No, sir.
17 Q He didn't come to Braidwood and look at the cables?
18 A (WITNESS THORSELL) No, sir.
19 As I explained before, in response to questions 20 from Judge Grossman, it isn' t necessary for a cable 21 engineer to physically look at each discrepancy or
.22 discrepant condition.
23 Q Yes, sir. You don't need to repeat yourself, si r. It
) 24 really wasn' t called for by the question.
Sonntag Repor ting Service. Ltd.
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's .
1 1 The fact of the matter is Mr. Laskey did not look 2 at these cables --
l.
i 3 A (WITNESS THORSELL) That is correct.
! 4 Q -- But Mr. Bartolucci did?
- 5 Mr. Bartolucci didn't respond, but Mr. Laskey 6 responded?
7 A (WITNESS THORSELL) That's correct.
{ 8 Q And do you know whether or not Mr. Bartolucci made any 9 diagrams, drawings, took any data, compiled any data,' on 10 the basis of his observation of the cables when he came l,
, 11 to Braidwood?
12 A (WITNESS THORSELL) I have no personal knowledge of I
13 tha t, i
14 Q Well, he hasn' t sent you any, has he?
l i 15 A (WITNESS THORSELL) No, si r.
l 16 0 I mean, have you gotten any data that supported Mr.
l
, 17 Laksey's letter identified as being authored by -- or
! 18 observed by Mr. Bartolucci? Did you get anything 1
19 besides the Laskey letter?
1 20 A (WITNESS THORSELL) No, sir.
21 Q Now, Mr. Bojan anoears to be the one Sargent & Lundy l 22 engineer that works for you.
i 23 He appears *o be the one who provides, ther ef or e, 24 the only documen'.ed description of the discrepant Sonn_ tag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262 .
14574 O
O 1 conditions that were related to the non-CSR bend radius 2 -discrepancies? l 3 A (WITNESS THORSELL) It's true.
4 Q All right.
{
l 5' A (WITNESS THORSELL) It's not uncommon, when more than
-6 one par ty is involved in a meeting of some type, to have 7 one of the parties write notes of the observations of 8 that meeting.
9 Q I take it.it's not uncommon, as part of Sargent &
i 10 Lundy's role in evaluating BCAP discrepancies, for it to
, 11 be the Sargent & Lundy representative who writes up the J
12 description of the condition?
l 4
13 A (WITNESS THORSELL) I believe that all of the 4
14 descriptions of the conditions are contained in the !
15 observations that are written up by BCAP inspectors.
16 Q Well, sir, that's not exactly the case.
l 17 In fact, you wrote the description of the condition 18 you observed with respect to this very cable, Cable 130, j 19 Observation 02.
l 20 We've already established that you relied on your 21 own physical observation of that condition and not the l
r 22- BCAP CSR inspector's observation; correct?
23 A (WITNESS THORSELL) Yes, si r.
24 That was for data that was not provided by the CSR I
1 i i SQDnta9 Reporting Service, Ltd.
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1 inspector.
2 Q Understood.
3 Well, what data was provided for the other bend 4 radius violations that -- or what data wasn't provided l 5 that Mr. Boj an had need of personally acquiring in the 6 . field and documenting in the letter that he wrote to Mr.
7 Bartolucci ?
8 A (WITNESS THORSELL) I don't understand the nature of the
- 9. question.
10 Q Well, I take it that, consistent with your last 11 response, in order for the Okonite Company to evaluate 12 the bend radius v'iolations that are represented by the l
13 attachment to the Bojan letter to Bartolucci, there was i
j' 14 some need in providing the Okonite Company with I
'15 something more than what the CSR inspectors already had 16 acquired by way of observed conditions;' elsewise, you l
l 17 wouldn't have needed to have the Bojan Attachment I?
'18 You simply would have sent Mr. Bartolucci the BCAP CSR 19 obse rva tions ?
20 A (WITNESS THORSELL) The Boj an Attachment A includes 21 information that is not contained in the BCAP 22 observation.
23 Q Indeed, that was my question. It does.
l 24 Okay. All right, si r.
Sonntag Reporting Service,_Ltd.
Geneva, Illinois 60134 (312) 232-0262
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$ 14576 J.
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1 JUDGE GROSSMAN: I'm sorry.. I'm not sure what 4
2 the answer means.
J 3 Is that all that's contained in Attachment A or 4 were there also observations by Mr. Bojan?
5 A (WITNESS THORSELL) I believe that -- well, Attachment A 6 contains a summary of the observations made by .Mr. Bojan j 7 and Mr. Bartolucci. ,
J l j 8 Those observations include information that was
] 9 recorded by the BCAP inspector along with additional 10 information not recorded by the BCAP inspector, such as
\
! 11 wrinkling of the jacket or physical distortion of the 12 ca bl e.
13 The CSR inspector may have just reported the 14' violation of bend radius and given a numerical value for
- 15 the radius that he observed.
16 (Indica ting. )
i 17 BY MR. GUILD: (
.18 Q All right, si r.
, 19 Now, you stated that the Boj an attachment reflects 20 Mr. Bojan and Mr. Bartolucci's observations, but I take t
21- it that you have no personal knowledge that that i
( 22 attachment is a true representation of what Mr. ,
! \
23 Bartolucci saw?
g 24 A (WITNESS THORSELL) Other than -- well, in addition I
i i Sonntaa Recor tina Se rvice. Ltd.
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! Geneva, Illinois 60134 (312) 232-0262 i
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!~
i 1- t o --
2 0 Can you answer that question directly, sir?
3 Please feel free to explain, if you would like.
~
4 A (WITNESS THORSELL) I cannot testify to what Mr.
5 Bartolucci saw --
6 Q All right, sir.
I 7 A (WITNESS THORSELL) --
nor can I testify' to what Mr.
8 Bojan saw.
l 9 Q All right.
j 10 A (WITNESS THORSELL) How ever, in addition to their
, 11 observations, I have seen at least some, if not all, of i
- 12 these cables personally, and I can attest to f acts that
- 13 are contained in this attachment that are not part of l
} .
14 the CSR observation.
15 Q Did you write down your observations, Mr. Thorsell,.as i 16 part of Sargent & Lundy's r eview for design significance 17 of these bend radius violations or did you do that in
- 18 preparation for your testimony here?
i 19 A (WITNESS THORSELL) No, sir. In the case of Cable 130, 20 my observations of no wrinkling in the jacket and no j 21 physical distortion of the cable are recorded in the 22 evaluation of the BCAP discrepancy.
l l '
23 Q Indeed.
How about the rest of them? Did you record your 24 Sonntaa Reporting Service, Ltd.
! Geneva, Illinois 60134
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f 14578 i
1 observations, if you made any, for the other 2 observations?
3 A (WITNESS THORSELL) As required to make my analysis, t 4 yes, si r.
5 Q Well, that really is a bit circular.
6 Did you, in fact, record any personal observations
! 7 for the other- bend radius discrepancies?
8 A (WITNESS THORS ELL) Yes, si r.
9 Q Which ones? Which ones did you personally observe?
10 There were only nine of them, Mr. Thorsell.
11 A (WITNESS THORSELL) I would have to review the nine to
(
12 make sure.
13 I believe that I -- I observed most of'them. I'm 14 not sure whether I observed all of them or not.
15 Q All right, sir.
16 Now, in the Boj an letter to Mr. Bartolucci, he 17 states. that these cable -- let me find the portion --
18 quote, " Sargent & Lundy will recommend that these 19 observa tions be corrected. "
20 Does that -- do I understand correctly that means 21 that you recommend that there be repair or rework made
, 22 to the observed bend radius violation conditions?
l 23 Do you see tha t, sir ?
24 It's in the last full paragraph --
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1 A (WITNESS THORS ELL) Yes, si r.
2 -Q -- of the Boj an letter.
, 3 A (WITNESS THORS ELL) That's what it means.
4 Q Well, did Sargent & Lundy make such a recommendation?
5 A (WITNESS THORSELL) To the best of my knowledge, on the 6 associated BCAP NCR's, that recommendation was made.
7 Q And do you know whether or not, in fact, those bend 8 radius violations were corrected?
9 A (WITNESS THORSELL) No, si r, I do not.
10 0 Well, now, I take it -- then in that same~ paragraph, 11 having said that you are going to recommend that those
[a\ 12 bend radius violations be fixed, be corrected, reworked, 13 you go on to state, the same sentence, "However, we 14 request that during your review, you assume these 15 conditions will be present for the life of the station."
16 All right. Then returning to the first sentence 17 of that paragraph, quote, "Please r eview Attachment A to i
18 determine whether each cable's installation would 19 prevent that cable from performing its function."
20 All right. Well, now, in response to that 21 r eq ues t, Okonite Company, in fact, declined to make that i 22 evaluation and stated that they did not have sufficient 23 data or experience in order to be able to evaluate the 24 design significance of the conditions that were Sonntag Repor ting Se rvice. Ltd.
Geneva, Illinois 60134 (312) 232-0262
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1 observed?
2 A . (WITNESS THORSELL) They stated .that as well as 1
3 providing a relaxed criteria for cable bending radius 4 for which they did have sufficient experience and data 5 to rely on.
6 Q Well, they made two different -- they. stated two 7 dif ferent things, as you just pointed out?
l 8 A (WITNESS THORSELL) Right.
9 Q They did decline -to make any design significance 10 evaluation for any of the cables, didn' t they?
i
'll A ( WITNESS THORSELL) Yes, si r.
12 0 They simply told you that they didn' t have enough
- 13 experience or data to be able to take a position on that
-14 question and they didn' t, although you asked them to?
1 15 A . (WITNESS THORSELL) Tha t's correct.
- 16 MR. GUILD
- Mr. Chairman, I'd like to have i 17 marked as the next -Intervenor exhibit --
i.
18 JUDG E GROSSMAN: 163.
t
! 19 MR. GUILD: Yes, 163. Thank you Mr.' Chairman.
20 The document is a May 13, 1985, letter from'Mr.
i 21 Bojan to Mr. Bartolucci of the Okonite company, with a
! 22 two-page attachment; and I don't have copies, but I'll 23 make them for the Board and the parties.
l 24 (The document was thereupon marked l
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V 1 Intervenors' Exhibit No.163 -for 2 identification as of October 15, 1986.)
3 MR. GUILD: I'd ask that that exhibit be 4 received in evidence, Mr.. Chairman.
I y 5 MR. STEPTOE: No objection.
6 MR. BERRY: Staff hasn' t had an opportunity 7 to r eview the document.
$ - _ . . '8' MR.-GUILD: Please do.
9 (Indica ting. )
10 MR. BERRY: No obj ection, Mr. Chairman.
11 JUDGE GROSSMAN: Received.
s, ;
_ ~ 12 (The document was thereupon received into 13 evidence as Intervenors' Exhibit No.
14 163.)
15 JUDGE GROSSMAN: You don't have a copy now for.
16 the Reporter, I take it?
17 MR. GUILD: I don't, Mr. Chairman; but I 18 can --
l 19 JUDGE GROSSMAN: Okay.
20 We 'll --
21 MR. GUILD: I ask that he mark it, I guess.
i 22- (Indica ting . )
f 23 JUDG E GROSSMAN: Okay. We and the Reporter 24 will get the copies later, the n.
l l
l l
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b 1 MR. GUILD: Yes.
2 Thank you, Mr. Chairman.
3 BY MR. GUILD:
4 4 Q Mr. Thorsell, I want to show you a document that has a 5 Bates Number of AR 006933006933 Counsel gave it to me 6 yesterday. It appears to be a handwritten listing 7 entitled " Bending Radius Observa tions. "
8 (Indica ting. )
9 And, sir, is that a document that you prepared?
10 A (WITNESS THORSELL) .Yes, sir.
ll Q And did you prepare that for this proceeding?
. 12 A (WITNESS THORSELL) Not directly.
, 13 0 Well, why don't you identify what it is?
14 A (WITNESS THORSELL) It is a listing of those bending 15 radius observations that were identified in the BCAP 16 program, nine of which were valid observations, three of 17 which were out of scope observations.
i 18 0 All right, sir, i
19 And what's the relationship, if any, between those 20 listed -- the cables listed on that table and those 21 listed in Attachment A to Mr. Boj an's letter to the 22 Okonite Company?
i 23 A (WITNESS THORSELL) This list contains a total of 12 24 ca ble s. 9 of those 12 cables were reviewed by Mr.
i i Sonntag Repo.rting Service Ltd.
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1 Bartolucci, the documentation of which is sh'own in 2 Attachment A to -- Attachment A of Mr. Boj an's letter.
3 0 Well, my addition is troubling me, the n, because one of 4 those cables, at the very least, was cable 130, the one 5 that you didn't have listed in the Bojan Attachment A.
- 6. Nine and three make twelve, if three were out of 7 s co pe. There must be a tenth there 'somewhere.
8- A (WITNESS THORSELL) No, sir.
-9 Q Let me figure out --
10 A (WITNESS TBORSELL) Mr. Bartolucci reviewed three out of
\ scope violations, al's o.
[J x-
}
11 12 0 Well, then, we have to add three to the Bartolucci --
13 the Bojan Attachment 3, but we still -- I'm still trying 14 to figure out where Cable 130 went to.
15 A (WITNESS THORS ELL) Cable 130 is one of the 12. Cable 16 130 is one of the 9 valid BCAP observations and Cable 17 130 is not one of the 9 that was reviewed by Mr.
18 Bartolucci.
19 0 Okay.
20- Well, you got 9 reviewed by Bartolucci plus 3 out 21 of s cope.
22 That's 12; correct?
23 A (WITNESS THORS ELL) No.
_, ) 24 Q Okay. Help me figure this out now.
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, 1 Bartolucci did not review Cable 130?
2 A (WITNESS THORSELL) That's correct.
3 Q But 130 is on your list of the 9 plus 3 out of scopes?
4 A (WITNESS THORSELL) Yes.
5 And it is also indicated that it was not r eviewed 6 by Okonite.
7 Q Okay.
8 And how many are on Mr. -- let me count, how about?
9 I got 9 on- Mr. Bojan's attachment.
10 A (WITNESS THORSELL) That is correct.
11 Q So there are 10 plus 3 out of scope on that list, on
-12 your-list of observations?
13 A (WITNESS THORSELL) No, sir.
14 Q Where does one drop out?
( 15 I'm just missing you here.
16 MR. STEPTOE: Bob, could he look at the 17 document?
l l 18 MR. GUILD: Sure.
19 A (WITNESS KOSTAL) This is part of it. 1, 2, 3 20 observations by Okonite, 9.
. 21 (Indica ting . )
l l 22 MR. GUILD: Got you.
23 BY MR. GUILD:
24 Q Well, what's the reference in the column to the Okonite i
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i 14585 l
l 1
I letter that's next to Cable 1307 ;
i 2 A (WITNESS THORSELL) That means that that observation was !
3 dispositioned using Mr. Laskey's letter..
4 Q. Though it was not one observed by Mr. --
5 A (WITNESS THORSELL) Correct.
- 6. -Q -- Bartolucci?
7 MR. GUILD: Excuse me.
8 Mr. Chairman, if I could have a moment.
9 BY MR. GUILD:
10 Q All right, sir.
[ 11 So you discovered your error Friday af ternoon last 12 week.
1-13- And I gather from your earlier testimony today you 14 said-you called Mr. Bartolucci?
15 A (WITNESS THORSELL) Yes, sir.
16 Q And you told Mr. Bartolucci that you made the mistake?
17 A (WITNESS THORSELL) Yes, sir, l
18 Q And you reminded Mr. Bartolucci of his trip to Braidwood l 19 and of the rather inaccessible location of this 20 particular piece of equipment --
{- 21 A (WITNESS THORSELL) Yes, sir.
22 0 -- crawling around and over, et cetera, and reminded him 23 of the fact that, as you stated, the cable in question,
.24 130, was right next to another sample item, 129,.which l
l 3
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V 1 h e, in fact, had included in his company's response?
2 A (WITNESS THORSELL) Yes, sir.
3 Q And you told him that you wanted him to sign off on 130 4 on the. basis of your representation that this was a 5 cable in a similar condition to the cable that he had 6 signed off on?
7 A (WITNESS THORSELL) No, sir, I didn' t tell him anything.
8 I asked him about cable 130.
9 Q And he told you that he only evaluated the one he looked 10 a t, which was 129?
11 His statement, to the.best of my
( A (WITNESS THORSELL) 12 recollection, is that he would have seen bo'th cables, 13 but concentrated on the cable that had. the identified 14 discrepancy -- or I think his words were, "The one that 15 was indica ted to me. "
16 (In dica ting . )
17 0 Well, did you ask Mr. Bartolucci to come back and look 18 at the cable that he had not, indeed, looked at?
19 A (WITNESS THORSELL) No, sir.
20 Q All right, si r.
21 Then you -- so you had this conversation with Mr.
- 22. .Bartolucci.
23 And did you ask him whether or not, if you asked (j 24 him to presume that the cable in question,130, was in SQDntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
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l 14587 l 1
/'
'( / s_
i l
1 the same condition as 129, he would vouch for the 2- acceptability of the bend radius condition for 130 as 3 well?
4 A (WITNESS THORSELL) Your words, but it captures the.
5 essence of the conversation, yes, sir.
~
6 Q All right.
7 And then you wrote a letter to Mr. Klein on October 8 13th?
9 A (WITNESS THORSELL) Yes, sir.
4 10 Q And in that letter, you recited your conversation with 11 Mr. Bartolucci?
(
12 A (WITNESS THORSELL) In that -letter, I describe the 13 condition that existed.
14 My contacts with Mr. Klein and Mr. Bartolucci 15 were -- were separate.
l 16 Q- Indeed.
{ 17 Did you talk to Mr. Klein as well?
i j 18 A (WITNESS THORSELL) Yes, sir.
19 0 Oh, you did.
1 20 When did you talk to Mr. Klein ?
i l 21 A (WITNESS THORS ELL) I talked to Mr. Klein on Monday.
l 22 Q All right.
I 23 Af ter you talked to Mr. Bartolucci?
q 24 A (WITNESS THORS ELL) Actually, prior to talking to Mr.
Sonntag Reporting _ Service. Ltd-Geneva, Illinois 60134
.( 312) 232-0262
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\v]
1 Bartolucci.
2 Q Well, did Mr. Klein refer you to Mr. Bartolucci?
3 A (WITNESS THORS ELL) - No, sir. 'I called Mr. Bartolucci 4 independently.
5 Mr. Klein is the local representative of the 6 okonite Company.
7 In general, in order to obtain Okonite's either 8 opinion or information or data relating to cables, we go 9 through the local representative.
10 The local representative may be able to provide 11 that information directly or may have to go back to
[)h
\.
12 their home base in. New Jersey, the engineering group, in 13 order- to get concurrence or additional information f rom 14 th em.
15 I contacted Mr. Klein to determine whether the i
16 condition that existed for Cable 130 was acceptable; and 17 independent of that, I contacted Mr. Bartolucci to 18 determine whether he had a recollection of that specific 19 ca bl e.
20 Q All right, sir.
21 And you got a response back f rom Mr. Klein?
22 You wrote Mr. Klein subsequently and got a response 23 back from Mr. Klein ?
l s 24 A (WITNESS THORS ELL) Correct.
s.
i Sonntag leporting Service.,_Ltd-Geneva, Illinois 60134 (312) 232-0262
i 14589 1
1 Q I take it Mr. Klein did not go to the Braidwood site and
.2 look at the cable in question?
3 .A ~(WITNESS THORSELL) No, si r.
4 Q Nor did Mr. Klein go the preceding year and review the
- 5 nine --
2- No, sir.
6 A (WITNESS THORSELL)~
7 Q -- discrepant conditions ?
8 All right. Then you, Mr. Thorsell, wrote to Mr.
i i
9 Klein of the Okonite Company on October 13th, quote, l 10 "One of the cases reviewed by Mr. Bartolucci was Cable 11 1CP002, which is a 3-conductor 500-MCM 600-volt cable.
12 It has a bend radius violation at the motor termination.
~13 Subsequent to Mr. Bartolucci's visit, Cable ICP004, ,
, 14 which is a 3-conductor 500 MCM 600-volt cable, was l
15 identified as- having a similar bending radius 3
. 16 violation" ?
17 A (WITNESS THORSELL) Yes, si r.
f l
18 Q "Both cables are terminated in the motor termination 19 bo x. There is no visible wrinkling of the jacket and no j 20 apparent visible distortion."
l 21 All right, si r. And it's on the basis of, Mr.
22 Thorsell, your description of the discrepant condit:f on 23 for Cable 130 that then you solicited the Okonite
( 24 Company's confirmation that their original position,
(
I Sqnntag Repor ting Service, Ltd.
Geneva, Illinois 60134
[ ' ( 312) 202-0262
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I which omitted reviewing Cable 130, also extended to that 2 cable as well?
3 A (WITNESS THORSELL) Tha t's correct.
4 Q And, of course, the next day, Mr. Klein writes you back, 5 and all he does is quote the paragraph from the 6 company's June 5, '85, letter?
7 A (WITNESS THORS ELL) And says tha t th e r ely may be 8 applied to Cable 1CP004, 9 By way of clarification, 1CP002 is the cable number 10 of the cable that is associated with the BCAP Sample 11 Item 129 and 1CP004 is the cable number of the cable
(
12 associated with BCAP Sample Item 130.
13 Q Mr. Klein specifically says, though, "Be advised of the 14 following for the above subject cable:," and then he
- 15 simply quotes the paragraph from the company's June 5, 16 '85, letter, "If no visible wrinkling of the jacket and 17 no apparent physical distortion has occurred, and the 18 bending radius of 2.5 times the OD or larger has been 19 maintained, the installa tion is acceptable, the cable 20 should be suitable for its intended use."
21 W ell, I take it back. That's not even a quote 22 from the earlier letter.
23 Where does that language come from?
24 A (WITNESS THORSELL) I believe it comes from the letter SQDDtag Repor ting Se rvice Ltd.
Geneva, Illinois 60134 (312) 232-0262
14591
/3 i (d
1 you just read.
2 Q All right, sir.
3 Was that a formulation that you provided to Okonite 4 Company ?
5 A (WITNESS THORSELL) No, sir. It was Mr. Klein's words.
6 Q Is that the determination you asked him to reach?
7 A (WITNESS THORSELL) I asked him whether it was.
8 acceptable to apply the criteria given in the Laskey 9 letter to Cable 1CP004.
10 Q All right, si r.
11 Again, based on your representations of the
(
j 12 conditions, he confirmed that that was appropriate?
13 A (WITNESS THORSELL) Yes, sir.
14 Q Now, let's try to deal with this question of the 15 conductor diameters.
16 You, in response to questions f rom me and the Board 17 on Friday, pres umed tha t, by observing the actual 18 condition -- the actual diameter of the single conductor 19 of the three that was the subject of Cable 130, tha t the 20 actual diameter of that single conductor of the three 21 would be of a smaller OD than if that conductor had been 22 a single conductor, not a part of a multi-conductor 23 cable, because the jacket would be thinner; correct?
(O) 24 A (WITNESS THORSELL) That would be one rationale for l
SoDDtag Reporting Se rvice, Ltd.-
Geneva, Illinois 60134 (312) 232-0262
14592
%J 1 accepting the bend radius as reported by the BCAP 2 inspector as opposed to the allowable bend radius 3 identified in the Sargent & Lundy drawing.
4 Q Well,-that, in. fact, was your rationale that you relied 5 on on Friday?
6 A (WITNESS THORSELL) Correct.
7 Q And that rational was in error because --
8 A (WITNESS THORSELL) That's correct.
9 Q -- in this case, they were of identical actual 10 di ameters?
[)
v 11 A (WITNESS THORSELL) I believe that I told you on Friday, 12 though, that I did not know the diameter of the cable.
13 Q Well, you did.
) 14 But you told me that you also presumed that the I
15 cable, in the case of one of a multi-conductor cable, 16 had a smaller actual diameter than if that conductor was 17 a single cable -- single-conductor cable with a thicker 18 jacket?
19 A (WITNESS THORSELL) I believe that, at one point in my 20 testimony, I stated that, in general, tha t was true, 21 and --
22 0 Well, in particular in this case --
4 23 A -- and then went on to conclude --
(
7_s}
( j 24 0 -- yo u --
SODntaa Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14593 O
O 1 JUDGE GROSSMAN: W ell, con tin ue.
2 A -- went on to conclude that that would be a rationale 3 for the dif ference in acceptance criteria.
4 BY MR. GUILD:
5 Q -Well, that was the rationale that you relied on on 6 Friday, and you were in error in doing so, weren't you?
7 A (WITNESS THORSELL) I would have to review the testimony 8 to see exactly what I said on Friday as whether I stated 9 that as a factual matter or whether I was talking about 10 this -- the condition in general and speculating as to a 11 reason why the bond radius would be different.
[Jh u-12 0 I see.
13 So you may well have just tsun speculating about 14 this particular case, although to my hearing, perhaps I 15 thought you were making a statement of fact about the 16 particular cable in question.
17 A (WITNESS THORSELL) Yes, sir.
18 Q All right.
19 A (WITNESS THORSELL) As I recall the questioning, you 20 asked me specifically what multiplier was used to derive 21 the 3.2-inch bend radius criteria, and I told you that I 22 did not know because I did not know the outside diameter ,
i l 23 of the cable.
l .
t 24 0 All right, sir.
l i
! So nnta g_Re porti ng_S.errica,_Ltd . I l
Geneva, Illinois 60134 (312) 232-0262
14594 i'
I 1 But you derived the outside diameter of 'the 2 conductor by reference to a specified outside diameter?
3 A (WITNESS T110RS ELL) No, si r .
4 0 Did you measure it?
5 A (WITNESS THORSELL) Well, go back to your -- could you 6 repeat the previous question?
7 0 You derive -- you rely on the actual outside diameter 8 for the conductor in question that exhibited the bend 9 radius violation -- you do that in order to be able to 10 reach your design significance evaluation conclusion?
,m
( ) 11 A (WITNESS THORSELL) Yes, sir, I have to know what the U
12 outside diameter of the cable is --
13 0 All right, sir.
14 A (WITNESS T!!ORSELL) -- in order to apply a criteria 15 that's based on that outside diameter.
16 0 Right, right.
17 Where did you get that outside diameter?
18 I thought we established that last week; but having 19 reconsidered what may be speculation and what may be 20 fact, can you tell me where you got the outside diameter 21 available for Cable 130, the conductor?
22 A (WITNESS T110RSELL) Okay. Let me -- let me answer the 7s 23 question first.
(
( 24 The outside diameter comes f rom information So n nt a g_ Rep or tin g_S c.rvl c e , _L t d .
Geneva, Illinois 60134 (312) 232-0262
14595
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I
- 1 provided by the manufacturer. ,
2 Now, on Friday that outside diameter was not 3 available to me, I had not reviewed it, and I believe my 4 testimony stated that I did not know what that outside 5 diameter was.
6 JUDG E GROSSMAN: Excuse me.
7 I think I hear questions asked with conductor and 8 answers given with cable, and I just think we ought to 9 keep everything straight here.
10 Mr. Guild asked you what you derive the outside 11 diameter of the conductor from and then you gave him an
(
. 12 answer which I thought related to cable.
13 I don't even know what you use an outside diameter 14 of conductor for --
15 A (WITNESS THORSELL) Okay.
16 JUDGE GROSSMAN: -- since you had indicated 17 that you don't use it in these calculations earlier 18 today.
19 Now, please clarify the area for me.
4 20 A (WITNESS THORSELL) Okay. Let me see if I can clarify 21 it.
22 BY MR. GUILD:
23 0 Let me interrupt one second.
24 Let me be just real clear so our reference point is Sonntan_ Reporting _Senice,ltd-Geneva, Illinois 60134 (312) 232-0262
, 14596 i
O 1 the same, Mr. Thorsell. '
i 2 I'm looking at your evaluation of Cable 130 --
3 A . (WITNESS THORS ELL) I understand.
4 Q -- and there is a value for the outside diameter of that
>5 conductor, and that value is stated to be 1.072 inches.
l 6 A. (WITNESS THORSELL) That's right.
i.
7 Q The question is:
i 8 Where did you get that value f rom?
7 9 A '(WITNESS ~ THORS ELL) That value comes from manufacturer's
! 10 information.
11 Now, if I can clarify for Judge Grossman the point.
(
s 12 On Friday we were discussing the allowable bending j 13 radiuses for the three-conductor cable and for a l 14 single-conductor cable.
15 The bending radiuses were based on the outside i
i 16 diameter of the three-conductor cable for all three l 17 conductors, if the overall j acket is in place, and for 18' the single-conductor cable.
l l 19 What I stated on Friday was that I did not know the-20 multiplier that was used for establishing the bend l
21 radius for the single-conductor cable because I did not.
! 22 have that information in front of me.
l 23 I do know the outside diameter of the individual 24 conductor of the three-conductor cable because that l ,
l
! Sonntag Reporting Service, Ltd.
4 Geneva, Illinois 60134 (312) 232-0262
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, 14597
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\s L 1 information is tabulated in the evaluation of 2 Observation 130.
3 Q Well, you wrote it down in that observation?
4 A (WITNESS THORSELL) Yes, si r.
1 5 0 That doesn' t mean it's true --
6 A (WITNESS THORSELL) And the source of the -- my source 7 of information for writing that down in Observation 130 8 is information provided by the cable manufacturer.
9 Q All.right, sir.
10 And that information, does that specify actual.
11 outside diameter of a conductor with jacket of a N-12 three-conductor cable?
13 A (WITNESS THORSELL) The information that is provided by 14 the manuf acturer will provide the outside diameter of a 15 three-conductor cable. There is also information from 16 the manuf acturer that provides the outside diameter of a 17 single-conductor cable.
18 In addition to that information, there is 19 information on the thickness of the insulation and on 20 the thickness of the jacket.
, 21 In the case of the cable associated with 22 Observation 130, the insulation thickness and the jacket 23 thickness for an individual conductor of the
)24 three-conductor cable are the same as they are for a Sqnntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
.]
14598 1 single-conductor cable of the, same size, thus giving the 2 same -outside diameter.
3 JUDGE GROSSMAN: Now, you haven't completed 4 your explanation to me, because it seemed as though you 5- had answered Mr. Guild in some respect with indicating 6 that you used the outside diameter of the conductor for
~7 some calcula tion.
8 Now, if that's the case, it's at variance with what 9 I understood you to say this morning.
10 Now, perhaps I heard it wrong or understood it i
[ h 11 wrong; but did you use the outside diameter of a V
12 conductor for any calculation?
13 A (WITNESS THORSELL) By' " condu cto r, " yo u me a n th e --
14 JUDGE GROSSMAN: The copper.
15 A (WITNESS THORS ELL) Just the copper?
16 JUDGE GROSSMAN: Yes.
17 A (WITNESS THORS ELL) No, sir, I never did that.
18 JUDGE GROSSMAN: So when you talk about 19 outside diameter of conductor, you are talking about
- 20 conductor including insulation and j acket?
21 A (WITNESS THORSELL) Correct.
22 JUDGE GROSSMAN: Okay. ,
23 I just read more into it than you intended to
(
(
24 conv ey .
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V 1 A (WITNESS THORSELL) Right.
2 The copper can be bent at a right angle. It's 3 the -- it's the insulation that you are concerned about 4 the bending radius on, because that bending of the 5 insulation can apply stresses to it.
6 (Indicating.)
7 JUDGE GROSSMAN: Well, aren' t you also 8 concerned about the copper breaking and having less of a 9 diameter conductor than is required for that particular 10 current and voltage?
11 A- (WITNESS THORSELL) This is -- th e coppe r is ve ry 12 malleable. It can be bent without breaking.
13 JUDGE GROSSMAN: Well, now, the testing that 14 I heard you refer to on Friday with regard to voltage 15 testing or current testing -- I forget how you described 16 it --
17 A (WITNESS THORSELL) Insulation resistance testing.
18 JUDGE GROSSMAN: Excuse me.
1 19 Wouldn't that relate only to the metal rather than 20 to the insulation?
21 -A (WITNESS THORSELL) No, it doesn' t relate to the metal 22 a t all. It relates to the insula tion.
23 JUDG E GROSSMAN: Oh, you were testing to see
! 24 if there was any voltage leak there?
i Sonntag Reporting Service. Ltd.
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1 A (WITNESS THORS ELL) Yes, testing to see if there had 2 been any damage to the insulation.
3 JUDGE GROSSMAN: Oh, I assumed that you were 4 testing to see how much current went through it or
- 5 whatever the unit is.
6 A (WITNESS THORSELL) Yes, a violation of bend radius has 7 the potential of damaging the insulation, and so the 8 concern is whether that insulation, indeed, has been 9 damaged, and that can be determined either by applying, 10 I'll say, a rule of thumb established by the cable 11 industry, that if you don't bend it any more than this 1:2 amount, you won' t damage it, or by taking the installed ,
I 13 condition and physically testing it to see whether the 14 insulation resistance is of an acceptable value.
15 (Indica ting. )
i l 16 JUDGE GROSSMAN: And none of your j 17 calculations related to damage of the -- possible damage ;
18 to the conductor itself; is that so?
19 A (WITNESS THORSELL) Correct.
- 20 MR. STEPTOE
- The conductor is defined as --
21 A (WITNESS THORSELL) Conductor, the copper conductor.
I 22 JUDGE GROSSMAN: The copper conductor?
23 A (WITNESS THORSELL) Correct.
24 BY MR. GUILD:
I t :
Sonntag Recortina Service. Ltd.
, Geneva, Illinois 60134 3 (312) 232-0262
14601 O
C/
1 Q Let's try a little f ur ther understanding here, Mr.
2 Thorsell.
3 Two documents were provided me yesterday. Th e 4 first is identified as " Proposal, Technical Data for 5 600-volt Power and Control Cable," Bates No. AR 6934, 6 and the second is a drawing, Sargent & Lundy drawing, 7 " Electrical Installation Cable Information. "
8 Now, do I take it that these two documents are the 9 sources f rom which you derived the outside diameter 10 v al ue s f or yo ur eval ua tion of . Ca ble 13 07 11 A (WITNESS THORSELL) The outside diameter value for Cable
(
i 12 130 was derived from the specification proposal data.
13 0 I'm sorry. The specification --
14 A (WITNESS THORSELL) Proposal data I believe is wha t you
, 15 referred to it as.
16 0 Well, is it in the documents I have?
r 17 I'd be happy to show them to you.
18 A (WITNESS THORSELL) It's the smaller sheet.
19 Q Let's start with the smaller sheet, then.
20 How did you, Mr. Thorsell, derive from this 21 document -- that is, " Proposal Technical Date" -- for 22 that referenced cable the outside diameter of the 23 conductor that is the subject of the bend radius 24 dis cre pancy ?
Sonntag Reporting Service,..Ltd.
Geneva, Illinois 60134 (312) 232-0262
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1 A (WITNESS WORSELL) Okay. By " conductor," if you mean 2 the copper plus the jacket plus the insulation, yes.
3 Q If that's what you evaluated.
4 A (WITNESS WORSELL) Yes, that's what I evaluated.
5 0 All right.
6 A (WITNESS THORSELL) All right.
7 0 Why don't you just identify the line you are going to 8 refer to and then the column.
9 A (WITNESS THORSELL) Okay. '1he critical information 10 appears in the columns entitled, " Item 2" and " Item 3,"
11 and --
12 Q What are those items entitled, sir?
13 A (WINESS WORSELL) Item 2 is "3-conductor 500 MCM" and 14 Item 3 is "1-conductor 500 MCM," and the line items that 15 are necessary are Line 4.5, " Ins ula tion Thickness. "
16 0 What's the insulation thicknesa for both of those items?
17 A (WIWESS WORS ELL) 65 mills.
18 0 All right.
19 So that's the -- is that the jacket thickness or 20 the insulation thickness?
21 A (WITNESS THORSELL) That's the insulation thickness, 22 0 So they both have the same thickness of insulation, 65 23 mills?
24 A (WITNESS WORSELL) Yes, sir.
Bonntag_Repor_ ting Se ry_ica,_Ltd-Geneva, Illinois 60134 (312) 232-0262
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14603
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l Q All right.
i i
2 A (WITNESS THORSELL) And the -- the next line item that 3 is relevant is Line 4.8, Subline A. 4.8 is entitled 4 " Jacket Thickness," Sub A is entitled "Over Insulation,"
5 and the thickness of the jacket over the insulation for 6 the 3-conductor 500-MCM cable is 65 mills and for the 7 single conductor 500-MCM cable is also 65 mills.
8 0 So the jackets in both cases are 65 mills and the 9 insulation in both cases is 65 mills?
10 A (WITNESS THORSELL) Right.
11 And if you go to the -- to the headings of Item 2 12 and Item 3, the copper conductor is the same size in 13 both cases --
14 Q All right.
l 15 A -- 500 MCM.
l 16 0 Let me ask a clarifying question.
l 17 In the case of discrepant bend radius, do we have i 18 either a 3-conductor 500-MCM cable or a 1-conductor l
l 19 500-MCM cable as those items are described in the l
20 specification that you are referring to?
l 21 A (WITNESS THORSELL) You have a 3-conductor 500-McM l
22 ca bl e, but at the location that the bend radius 23 violation occurred, the outer jacket had been stripped
( j 24 off, resulting in the equivalent of 3 single-conductor
}
SonntAq_Reparting_Se h t,_.htd.
Geneva, Illinois 60134
( ' ~
14604
%.]
1 500-MCM cables.
2 To proceed --
3 -Q So you relied -- excuse me.
4 So you relied on the value for the outside diameter 5 of a single conductor of that 3-conductor cable for the 6 data shown for a 1-conductor 500-MCM cable?
7 A (WITNESS THORSELL) Well, if you will let me finish, Mr.
8 Guild.
i 9 The remaining line item that is necessary is Line
$ 10 4.9, "Outside Diameter," and outside diameter for a i[ \ 11 single-conductor 500-MCM cable is 1.072 inches.
12 Now, to answer your question directly, yes, I i
13 relied on the 1.072 inches, because I was able to see 14 that the insulation thickness and the jacket thickness I
15 were the same.
1 16 I could have gone back to another piece of 17 manufacturer's data and found out the outside diameter 18 of the copper and then added the insulation thickness 19 and the jacket thickness to that to be able to derive 20 the outside diameter of a single conductor of the 21 3-conductor 500-MCM cable, but it was unnecessary, since 22 the information was displayed on this table for me.
23 Q All right.
O
( ,) 24 J UDG E G ROSSMAN : Excuse me.
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l 1 You mean twice the diameter -- or twice the 2 thickness?-
i 3 A (WITNESS THORSELL) Well, yes, it would be twice --
4 using the thickness information, I could calculate it.
5 Indeed, it would be the thickness.
- 6 JUDGE GROSSMAN
- All right.
7 It would be one times the outside diameter of the 4
8 copper conductor plus twice the outside diameter -- the 9 outside thicknesses of the insulation and the jacket?
i l 10 .A (WITNESS THORSELL) Yes. t l ( 11 JUDG E GROSSMAN: Okay.
12 BY MR. GUILD:
! 13 Q All right, sir.
- 14 And what's the minimum bending radius specified for 15 a 1-conductor 500-MCM cable by the specification that
{ 16 -you have been reading f rom?
)
- 17 A .(WITNESS THORS ELL) The value that is specified here is 1
18 5.4 inches.
} 19 Q All right, si r.
i 20 J UDG E CALLIH AN : Mr. Thorsell, that's a 21 600-volt conductor --
I 22 A (WITNESS THORSELL) Yes, sir.
l .
23 JUDGE CALLIHAN: -- which is an important i
- 24 factor that was omitted?
Sonntag Regor ting Se rvice. Ltd.
! Geneva, Illinois 60134
) (312) 232-0262
14606 a
(h t V
1 A (WITNESS THORSELL) Yes.
2 BY MR. GUILD:
3 Q And what's the source of the specified minimum bending 4 radius of 5.4 inches for the single-conductor 500-MCM 5 cable?
6 A (WITNESS THORSELL) What's the source?
7 0 Yes.
8 A (WITNESS THORSELL) That document.
9 0 Yes.
10 Well, you wrote the document --
11 A (WITNESS THORSELL) That information is provided by the
(
12 cable manuf acturer.
13 0 Okonite specified, as the minimum bend radius for that
- 14' cable diameter -- that is, for a cable of 1.072 15 inches -- a bending radius of 5.4 inches?
, 16 A (WITNESS THORSELL) Yes, sir.
17 JUDGE GROSSMAN: I'm sorry, what? 5. what?
j 18 MR. GUILD: 4 inches.
j 19 BY MR. GUILD:
20 Q Now, sir, the other document you gave me -- this is the 21 big Sargent & Lundy drawing -- did you rely on this as a 22 source of data for your -- either your minimum bend 23 radius requirements or the outside diameter value for 24 your evaluation of this cable?
l l
Sonntag Repor ting Se rvice. Ltd.
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14607 v
~,
1 ;A (WITNESS THORSELL) No, si r.
4 2 0 Is this the specification that the CSR inspector relied 3 -_ on in inspecting the' as-found condition of the cable in 4 question?
5 A (WITNESS THORSELL) That is the design document that the 3
6 CSR inspector relied on.
7 0 All right, sir.
8 J UDG E G ROSSMAN: Excuse me, but-I still get a
! 9 _ discrepancy here.
10 The outside diameter was 1.072?
b 11 (WITNESS THORSELL) U h-h uh.
(& 12 A
J UDG E G ROSSMAN : And the manufacturer's 13 specified diameter bend radius was 5.47
- 14 A (WITNESS THORSELL) Well, it -- I think Mr. Guild is 15 going to get to that, i i
- 16 If you would like me to leap ahead --
i 17 JUDGE GROSSMAN: Oh, okay.
18 A (WITNESS THORSELL) -- I can.
19 I can --
! '20 JUDG E GROSSMAN: Because offhand --
l 21 A (WITNESS THORSELL) I can shorten this whole thing by 22 explaining all these numbers, if you would like, or it
- 23 can be brought out by Mr. Guild in cross examination.
24 J UDG E G ROSSMAN : Just let me observe that 4 i Sonntaa Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14608 y <
I g-1 times 1.072 does not come out to 5.4.
2 A (WITNESS THORSELL) No, sir, no, sir.
3 JUDGE GROSSMAN: Mr. Guild can handle --
, 4 A (NITNESS THORSELL) I believe that you would find that 5 it's probably 5 times gives you 5.4 after you do some 6 rounding.
7 JUDG E GROSSMAN: That's what it seems to me 8 to be.
9 A (WITNESS THORSELL) Right.
10 Now, cable manufacturers basically apply rules of i [b \ 11 12 thumb; and a standard rule -of thumb for allowable bending radius ~is 5 times the OD of the cable, and this 13 is a value that is -- has existed historically for a 14 long time, and it can be applied over a >1arge number of 15 cable constructions; in other words, cables that use 16 dif ferent insulation systems, _ dif ferent jacketing 17 systems, different materials for insulation and 18 j ac ke ting.
19 The 8-1/2-by-ll sheet of paper, to which Mr. Guild 20 was referring, contained a bend radius of 5' times OD as 21 was supplied by the manuf acturer at the time of his 22 proposal when the specification for cable was released 23 for bid.
(O.s24) This is somewhat of a restrictive bending radius in Sonntag Reporting Se rvice. Ltd.
Geneva, Illinois 60134 J312y 232-0262
14609 y ~l (G i 1 that you encounter many installation situations where 2 you need to bend the cable. tighter than that in 'o rder to 3 physically fit it into the space that's available for 4 the cable.
I 5 Af ter we established Okonite as the cable supplier '
6 for Braidwood Station, we went back to the cable 7 manufacturer and asked for a generic relaxation of the 8 bending radius requirements based on the specific cables 9 that we were going to be using, and the manufacturer 10 then reduced his allowable bending radiuses to lesser
(}11 12 >
values, and those are the values that appear on the drawing that Mr. Guild has.
.13 Now, the value that's shown on the drawing there 14 for- a single-conductor 500-MCM cable, I believe, is 3.2 15 inches, which is 3 times the OD, which is the criteria 16 that Okonite gave to us across the Board on a generic
-17 basis without going' back on an individual-case basis.
18 My analysis of Cable 130 is based on a 2-1/2 times 19 OD with no wrinkling or physical distortion of the cable 20 from the Laskey letter, and then later confiraed to be 21 appropriate by the ,-- by the Klein letter as well as my 22 telephone conversation with Mr. Bartolucci- and also by 23 the Megger test, yb
() 24 JUDGE GROSSMAN: Okay.
Sonfitag Reporting Service. Ltd.
Geneva, Illinois 60134 s (312) 232-0262
14610 fV 1 And I take it the QC Inspectors originally, not for 2 BCAP, inspected to the 3.2?
3 A (WITNESS THORSELL) Correct.
4 J UDG E G ROSSMAN : Okay.
5 MR. GUILD: W ell, tha t's not exactly correct.
6 BY MR. GUILD:
7 0 In fact, the specification -- the Sargent & Lundy 8 specification that is entitled " Electrical Installation 9 Cable Inf ormation, " _provides that, for a cable Type 10 01506, which is the type that was specified in C} 11 12 Observation 130-02, that a minimum bending radius for
-pulling that size cable is still specified at 5.4 13 inches --
14 A (WITNET THORS ELL) Okayo 15 0 -- is that correct? ;
16 A (WITNESS THORSELL) Yes.
17 Q All right.
18 7.nd that's-the value that the CSR inspector 19 inspected to --
20 A (WITNESS THORSELL) No,~ sir.
21 0 -- correct?
22 A (WITNESS THORSELL) No, sir.
23 Let me go back and clarify.
) 24 Q Wait a second. Let me just get this point clear.
i l
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(~'
'\_-)/ '
1 Is that the value that the original Comstock i 2 . quality control inspector utilized as an acceptance 3 criteria?
o -4 A (WITNESS THORSELL) You are asking about 5.4 inches?
5 0 Yes, for a minimum radius, minimum bend radius, pulling.-
6 A' (WITNESS THORSELL) That is correct. For pulling, that 7 is the value that he would have relied on.
.8 Q All right.
k 9 Now, for a training radius, indeed, the CSR only i 10 inspected training radii because they couldn't observe 11 the pull; correct?
( '
i '12 - A (WITNESS THORSELL) No, not correct.
} 13 'Q Well, they didn' t observe the pull? They weren' t there
- 14 when the cable was pulled in the first instance, were
^
15 they ? !
16 A' (WITNESS THORSELL) The cable was not pulled at _ that l 17 point.
18 Q Exa ctly.
19- They observed only the as-constructed condition of 20 the cable, which is the training radii?
21 A (WITNESS THORSELL) No, you don' t -- you have .-- you 22 have a misconception between pulling and training.
l 23 Q If I have a misconception, I think it's a misconception 24 that's been just repeated several times on this record.
'- Sonntag Reporting Service. Ltd.
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- (312) 232-0262
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1 A training radius is the final condition of the 2 cable, .is it not, in its pulled condition?
3 A (WITNESS THORSELL) Yes, it is.
4 How ev er, it is also a radius to which the cable was 5 never subjected to during pulling.
6 (Indica ting. )
7 0 Well, you had to pull it that last little bit to get it 8 into the final training condition that it is in?
9 A (WITNESS THORS ELL) No, no.
10 By " pulling radius," what we' re referring to is the 11- radius around a conduit bend or around a pulling sheave
(
12 where forces are being applied to the side wall of the 13 cable in the pulling process.
14 (Indicating.)
15 Q W ell, Mr. Thorsell, at least from testimony of Quality 16 Control Inspectors who inspect cable pulling, they 17_ include the loop of a cable as it drops out of a pan 11 8 before it goes to a Kellum grip as a pulling or training 19 radius.
20 A (WITNESS THORSELL) Well, you have to be careful in 21 whether you are asking them about training radius or 22 pulling radius or bending radius.
,, 23 Bending radius covers both.
( ) 24 Okay. I need to make one further clarification to Sonntag Repor ting Se rvice. Ltd.
Geneva, Illinois 60134 (312) 232-0262
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1 the description that I gave to Judge Grossman, which is, 2 that when we went back to the Okonite Company for relief 3 across the Board in regard to bending radius, I was 4 referring to training radius.
5 The numbers that were initially provided to us, th e 6 5 times OD, were provided for both bending and training.
7 When we went back and asked them for a separate 8 number for training radius, that's when we got the 3 9 times OD.
10 0 All right.
11 And the 5 times OD remained --
(
12 .A (WITNESS THOR ELL) Tha t's correct.
13 0 -- a specification for pulling radius?
14 A (WITNESS THORSELL) Correct.
15 0 And that's on the Sargent & Lundy specification?
- 16 A (WITNESS THORSELL) Yes, si r.
17 Q That's the acceptance criteria for the quality control 18 acceptance of this particular cable?
19 A (WITNESS THORSELL) For pulling that particular cable --
20 Q For pulling that cable --
21' A (WITNESS THORSELL) -- around bends in conduits or 22 around pulling sheaves or around pulleys that are used
_ 23 in installing the cable.
24 It is not the criteria that's used at the end of Sonntaa Reportina Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
~ . _. ._ = -- ... . _ __ . _ . - - _ . . - . _
14614 O
-1 .the cable when a man -physically turns the cable up to 2 make the termination, because he's not applying any -
3 pressure on the side wall of the cable at the bend when 4- he does that.
5 (Indica ting.
6' Q Well, Mr. Thorsell, how about when a cable puller craf ts 7 person coils the cable on the floor:
8 .Does the pulling -- does the bend radius apply 9 there ?
[ ;10 A (WITNESS THORSELL) The applicable bend radius in that 11 condition is the training radius, not the pulling
~
l 12. radius.
13 Q I see.
}
- 14 Well, perhaps that distinction has not been made 15 apparent to the people that you have inspecting these 16 conditions in the field.
17; Do you know whether or not Quality Control
~18 Inspectors in the field apply _ only the training radius, 19 the smaller value, to the condition that I just l- 20 described in the. coiling of a cable where there was no c
21 tension?
22 JUDG E GROSSMAN: Excuse me.
l 23 'Itat's a larger value.
24 A (WITNESS 'IBORSELL) I don' t know, I don' t know. I don't I
I Sonntag Repor ting Re rvice. Ltd.
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O 4
1 know which value they use.
2 BY MR. GUILD:
3 Q Your understanding is that's the value specified in the ;
4 Sargent & Lundy drawing?
5- 'A (WITNESS THORSELL) My understanding of what?
6 Q. That whatever value the Quality Control Inspector 7 applied is the value that's specified in your drawing i-8 " Electrical Installation Cable Inf orma tion. "
l 9 MR. STEPTOE: There are two values in that 10' drawing.
()11 ~12 A (WITNESS THORSELL) 'There are two values in there.
MR. STEPTOE: I'm confused.
13 A (WITNESS THORSELL) Both of those values are provided to 14 the installer and the inspector.
15 MR. GUILD: Yes.
1 16 A (WITNESS THORSELL) The manner in which he applies -those 17 values I have no personal knowledge of.
18 BY MR. GUILD:
, 19 Q All right.
- 20 You don' t know how L. K. Comstock instructs their 21 Quality Control Inspectors in the application ~of those j 22- values?
23 A (WITNESS THORSELL) I have no personal knowledge in that 24 area.
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Iv) 1 Q But those values -- the only source of those values is 2 the Sargent & Lundy drawing that we've had reference to?.
3 A (WITNESS THORSELL) Yes, si r.
4 Q And it's one of those two values?
3 5 In the case of the particular type. cable in 6 question here, a 01506 type, it is either 5.4 inches or 7 3.2 inches?
8 A (WITNESS THORSELL) That's correct.
9 Could I see the drawing for a moment?
3 10 Q Sure.
11 JUDGE GROSSMAN: By the way, I stand 12 corrected.
13 The training radius is the larger one, not the 14 sm alle r --
15 MR. STEPTOE: No, no, no.
16 A (WITNESS THORSELL) There is a note on the drawing, Mr.
I 17 Guild, under training radius. It says, "See Note 2."
18 Note 2 reads, "This information provides minimum bending 19 radius for training of cables and does not apply to 20 pulling of cables. "
l21 BY MR. GUILD:
22 0 So the larger value, the 5.4, applies in all of the 23 cases except in the training of cables per that note?
24 A (WITNESS THORSELL) It applies to the pulling of cables.
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- 1. JUDGE GROSSMAN: Let's get it' straight on the 2 record, because I messed up twice.
3 The training radius is the smaller radius?
, 4 A (WITNESS THORSELL) Yes, sir.
5 JUDGE GROSSMAN: Tha t's fine.
6 Now, why don' t we take a break f or lunch and we'll 7 return at 1:30.
l 8 (WHEREUPON,- the hearing was 9 continued to the hour of 1:30 10 o' clock P. M.)
11 12 13 14 15 16 17 18 19 20
-21 22 23-24 Sonntaa Recortino service. Ltd.
I -Geneva, Illinois 60134 (312) 232-0262
14618 O
V 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3- BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x 5 :
In the Matter of: :
6 : Docket No. 50-456 OL COMMONWEALTH EDISON COMPANY : 50-457 OL 7 :
(Braidwood Station, Units 1 :
8 and 2) :
_ 1 _ _ _ _ _ _ _ _ _ _ _ _ _ _ ; _x 9
'10 Met pursuant to recess.
4 11 Wednesday, October 15, 1986.
r 1:30 P. M.
( 12 13 14 JUDGE GROSSMAN: We're back in session.
15 Mr. Guild?
16 MR. GUILD: Mr. Chairman, I have a present 17 for the Board and parties. This is the promised 18 Intervenors' 160, the cable population -- I'm sorry --
- 19. cable pan hangers -- excuse me.-- the documents 20 analogous to the company's exhibit for the cable 21 population, including the documents reflecting the 22 sample selection process.
23 JUDGE CALLIHAN: Is it 150?
24 JUDGE GROSSMAN: 160, and it's similar to N
,,) 25 Applicant's Exhibit 131.
Sonntag Reporting Service, Ltd.
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E 14619 1 MR. GUILD: And I've returned to the Reporter 2
2 the marked original.
3 JUDGE COLE:- What is this?
4 JUDGE GROSSMAN: This is Intervonors' 160, 5 which is similar to the cable selection document marked 6 and received as Applicant's Exhibit 131.
7 MR. MILLER: Your Honor, I'd like the record 8 to reflect that I have served on the Board and parties 9 copies of the rebuttal testimony of Mr. Shamblin.
10- MR. GUILD: I believe off the record, Mr.
11 Chairman, Mr. Steptoe proposed to identify the document
() 12 13 that Mr. Kostal -- the drawing Mr. Fostal made as Applicant's Exhibit 150, subject to the provision of the 14 drawing of the size appropriate for inclusion in the 15 record.
16 I believe that drawing has to do with the criteria 17 for screening conduit- hanger populations for more highly 18 stressed items.
- 19 Is that right, Mr. Kostal?
20 WITNESS KOSTAL: No. That is an illustration 21 of, when you have an objective discrepancy, a method to 22 calculate an R value.
23 MR. GUILD: Thank you. I'm sorry.
24 BY MR. GUILD:
25 0 Mr. Thorsell, were there any cable sample items in the Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
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{~'N Ll 1 BCAP population identified with discrepant damage to the 2 cable, aside from the instances involving bend radius 3 violations?
4 A (WITNESS THORSELL) Not that I recall.
5 Q Do I understand correctly that the acceptance criteria 6 for cable damage represented jacket damage that was 7 greater than 50 percent of the thickness of the cable 8 jacket -- such a degree of damage would represent a 9 rejectable or discrepant condition?
10 A (WITNESS THORSELL) . That would represent a condition in 11 the Comstock procedures requiring repair of the jacket.
(
,-~ ) 12 I don't know what. criteria was used by the BCAP L.)
13 inspectors for identifying damage to cable.
14 0 All right.
15 .Mr. Kostal, can you help? Do you know what the CSR 16 acceptance criteria was for cable damage?
17 A (WITNESS KOSTAL) No, sir.
18 0 Mr. Thorsell or Mr. Kostal, do you know whether or not 19 the Okonite Company made any field evaluation of the --
20 of any cables for cable damage, aside from the instance 21 referred to in the nine minimum bend radius 22 discrepancies?
23 A (WITNESS THORSELL) No, sir. The nine -- well, which 24 nine?
25 0 Those referred to --
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14621 l
j/N l
\s_
1- A .(WITNESS THORSELL) The nine that were reviewed by Mr.
2 Bartolucci or the --
3 Q Yes.
4 A (WITNESS THORSELL) To my knowledge, the nine cables 5 that are identified in Attachment A of Mr. Bojan's 6 letter represent those cables that were reviewed or, I 7 should say, inspected in the field by the Okonite 8 Company.
- 9 .O For any purpose under BCAP?
10 A (WITNESS THORSELL) Pardon?
I 11 Q For all purposes and any. purpose under BCAP?
12 A (WITNESS THORSELL) Under BCAP, that is correct.
13 There are cases in there where the word " damage" is 14 used, representing an indentation of the jacket. I 15 believe an example of that would be Cable 1CV077, and I 16 would have to refer to the listing that you showed me 17 earlier to determine whether that was an in-scope or 18 out-of-scope observation.
! 19 Q Does that appear to be an out-of-scope observation?
20 (Indicating.)
21 A (WITNESS THORSELL) Yes, sir.
22 O Now, again, the schedule that you compiled of the BCAP 23 bend radius observations reflect three that Mr. -- the 24 gentleman's name escapes me..
l 25 A -(WITNESS THORSELL) Mr. Bartolucci?
Sonntag Reporting Service, Ltd.
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(b
\,-) J 1 0 -- Mr. Bartolucci -- thank you -- did not observe in the 2 field. The first is cable 034, Observation 02.
3 Why didn't Mr. Bartolucci observe that discrepant 4 condition?
5 A (WITNESS THORSELL) I don't know specifically why he 6 did not observe it.
7 I can only speculate that either it was not 8 . identified at the time or he just did not get to it 9 during his visit. One of those two is a possible 10 answer. I' don't really know.
11 Q All right, sir.
12 Do you know whether it was shown to him?
(
13 A .(WITNESS THORSELL) I do not believe it was shown to 14 him.
15 Q The second one is Cable 13002. We've discussed that.
16 The third item is cable 14602, Sample Item 14602.
17 Do you know why Mr. Bartolucci did not ooserve that 2
18 discrepant condition?
i 19 A (WITNESS THORSELL) No, sir, I do not.
20 Q Your answer would be the same: You could speculate 21 about why, but you don't know?
22 A (WITNESS THORSELL) I don't know.
23 0 Do you know why the three cable bend radius 24 discrepancies were identified as out of scope?
25 A (WITNESS THORSELL) Not specifically.
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i 14623 O
i 1 I do recall looking at one of them, and it was out 2 of scope because it was not a.BCAP sample cable.
3 Q Each one of them has a triple-X designation?
4 .A (WITNESS THORSELL) Correct.
5 Q Does that indicate the reason?
f 6 A (WITNESS THORSELL) Not.necessarily.
) 7 The triple-X designation could identify -- or in i
l 8 general identifies an observation that was made by a 9 BCAP inspector while inspecting some other item. That 10 other item may have been in the same population or may
- 11 have been in a different population.
12 For example, while inspecting conduit, if the 13 inspector came across a cable discrepancy, that cable 14 discrepancy would have been written up as a triple-X 15 observation.
l 16 Q All right, sir.
- 17 Now, accepting for purposes of discussion that the i
l 18 BCAP CSR inspections identified no instances of cable 19 damage, other than the bend radius cases, cable damage l
j 20 defined by the Comstock acceptance criteria -- and that
- 21 is, greater than 50-percent damage to the -- 50-percent 22 thickness damage to the jacket -- do you believe, Mr.
! 23 Thorsell, that it's an appropriate inference to draw 24 f rom the BCAP CSR sample results applied to the j 25 population generally of cables that there would be no 3
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~
14624 s
1 damaged cable with damage exceeding that acceptance
- 2. criteria: more than 50 percent of the thickness of the 3 jacket?
4 A (WITNESS THORSELL) I believe that, given a sample from 5 a population, it is acceptable to draw inferences based 6 on the result of that sample within the limitationc of 7 the sampl'e.
8 0 Well, that's a helpful philosophical observation, but 9 the question was really a little more focused than that, 10 Mr. Thorsell. The question really goes to what you did 11 in BCAP.
12 The question restated is: Given the result that
(
13 you found, that you atested to -- and that is,_there I
14 were no cable discrepancies identified in the BCAP 15 sample -- does that result support the inference that 16 there are no cable damage discrepancies in the 17 population of cables as a whole?
i 18 A No, sir.
(WITNESS THORSELL) l 19 It only supports the inference that the population l 4
20 of damaged cables is less -- well, it depends on the 21 size of the -- you're still in the hypothetical, so it 22 depends upon the size of the sample, the size of the i
23 population.
24 But you can only draw that conclusion -- or make 4 i 25 that inference to the extent to which the accuracy of i
Sonntag Reporting Service, Ltd.
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14625 Os 1 your sample allows you.
2 0 I'm not trying to be hypothetical. My only assumed fact 3 here is that BCAP found no instances of cable 4 discrepancies.
5 I guess that's your testimony, to the best of your 6 recollection or knowledge; correct?
7 A (WITNESS THORSELL) Correct.
8 0 So let's assume that as a fact.- That's the only assumed 9 fact. For the rest I'm asking you to express an opinion 10 about the BCAP results.
11 I'm saying: Given that fact of no cable damage, no O)
( 12 cable discrepancies, as defined and identified in the 13 BCAP cable sample, does that fact support the general 14 inference that in the population of cables as a whole, 15 there are no damaged cables?
16 A (WITNESS THORSELL) No, sir.
17 Q Isn't that the inference that BCAP presumes to make?
18 A (WITNESS THORSELL) The inference that BCAP pr'esumes to 19 make, as I understand it, is that based on the sample, 20 purely the sample, the population of cables as a whole 21 will be at least 95-percent defect-free with a 22 95-percent confidence.
23 0 I see.
24 So that doesn't exclude that in 5 percent of the 25 population as a whole, there may be damaged cables; nor Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134
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1 does it exclude that there's a 5-percent uncertainty as
. 2 to the whole population and the incidence of damaged 3 cable; correct?
4 A (WITNESS THORSELL) Is that a question?
5 0 Yes, that's a. question.
6 A (WITNESS THORSELL) Yes.
7 MR. GUILD: Mr. Chairman, I don't propose to I
8 offer these documents as exhibits. These are the cable 9 diameter and bend radius specifications and Sargent &
10- Lundy design requirements.
11 If Applicant and Staff have no objection, I'd hand 12 them up to the Board in case there's some information 13 that may be of interest to the Board Members.
14 (Indicating.)
15 MR. STEPTOE: Judge Grossman, I was planning 16 on redirect to introduce those as exhibits, so it might 17 be well just to have them marked for identification --
18 MR. GUILD: I have no objection to that.
19 MR. STEPTOE: -- as Applicant's Exhibits Nos.
- 20 151 and 152. 151 would be the smaller document. That's 21 the specification.
22 JUDGE GROSSMAN: That's the proposal 23 technical data for 600-volt power and control cable.
24 MR. STEPTOE: And 152 would be the S & L 25 drawing.
1 Sonntag Reporting Service, Ltd.
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\,j 1 JUDGE GROSSMAN: It's entitled " Electrical 2 Installation Cable Information."
3 (The documents were thereupon marked 4 Applicant's Exhibits Nos. 151 and 152 for 5 identification as of October 15, 1986.)
6 BY MR. GUILD:
~
7 Q Mr. Thorsell, in the latter of those two documents --
8 that is, the Sargent & Lundy drawing, Applicant's 152 9 marked for identification -- you properly noted that 10 there was a note to the drawing that explained the 11 application of the bend radius specifications.
} 12 Now, that note referred to a limited application to
[/
13 -- let me not speculate and try to quote from memory.
14 The Note 2 specifies, quote, "This information 15 provides cable minimum bending radii for training of 16 cables and does not apply to pulling of cables."
17 A (WITNESS THORSELL) Yes, sir.
18 0 Now, is there a Sargent & Lundy specified definition of 19 the material terms in that note: " pulling," " training,"
20 " bending"?
21 A (WITNESS THORSELL) No, sir.
22 0 You leave it to Commonwealth Edison Company and the 23 contractors to interpret those terms?
24 A (WITNESS THORSELL) Yes, sir.
25 Q Has Sargent & Lundy reviewed the L. K. Comstock cable Sonntag Reporting Service, Ltd.
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1 pulling and cable pull inspection procedures?
2 A (WITNESS THORSELL) Yes, sir.
- 3. O Has Sargent & Lundy approved those procedures as 4 revised?
5 A (WITNESS THORSELL) Sargent &-Lundy does not approve 6 contractor procedures.
7 We have indicated that we have reviewed them and 8 found the technical content of those procedures 9 acceptable.
10 0 I take it you had the full procedures available for 11 review, the pulling and the pulling inspection
(') 12 13 procedures?
By that I mean to say: Somebody didn't just supply 14 you -- Edison or Comstock didn't just supply you with an 15 excerpt of what they deemed to be technical information; 16 you reviewed the whole procedure and made your cut as to 17 what you would or would not review?
18 A (WITNESS THORSELL) Yes, sir, that is correct.
19 0 And if there's any definition of " pull," " bend" and 20 " training," therefore, in the Comstock procedures, 21 Sargent & Lundy at least had those definitions available 22 to you for review?
23 A (WITNESS THORSELL) Yes, sir.
24 Q Now, with respect to Cable 130 -- let me see if I can be
) 25 clear about this point -- Intervenors' Exhibit 162, in Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
f 14629 r
(
1 light of your reconsideration of your testimony of last 2 week and your identification of the point of error,.is 3 it your opinion that the CSR inspector correctly applied 4 the design acceptance criteria in identifying the 5 minimum bend radius discrepancies?
6 A (WITNESS THORSELL) Yes, sir.
7 JUDGE GROSSMAN: ' Excuse me. Could you repeat 8 the question and answer?
9 (The record was thereupon read by the 10 Reporter.)
11 JUDGE GROSSMAN: That's fine. Okay.
BY MR. GUILD:
( 12 13 0 Mr. Thorsell or Mr. Kostal, either of you gentlemen, 14 since the weekend, have you been able to identify which 15 L. K. Comstock inspector was -- to which Comstock 16 inspector were the discrepancies attributable in bend
. 17 radius with regard to cable Sample Item 130?
18 A (WITNESS THORSELL) No, sir. I wasn't aware that we 19 were supposed to do that --
20 Q All right, sir. Just checking.
21 A (WITNESS THORSELL) -- or that it's within our scope.
22 Q Just checking, Mr. Thorsell.
l 23 MR. GUILD: Do you have some more 24 information?
25 MR. STEPTOE: If you'll accept -- I checked Sonntag Reporting Service, Ltd.
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i 14630 .
V('N
.1 with Mr. Orlov. If you'll accept my representation, i
2 it's.under " pull."
3 MR. GUILD: It's a pull?
4 MR. STEPTOE: It's a pull.
5 MR. GUILD: We have a JTR, who is a pull 6 inspector.
7 MR. STEPTOE: That's what it looks like to 8 Hme .
9 MR. GUILD: John T. Roman.
10 BY MR. GUILD:.
11 0 Do we know whether Mr. Roman was a Comstock inspector or 12 an Ernst-inspector?
(
13 A (WITNESS THORSELL) I have no idea.
[
14 MR. STEPTOE: The date is January 21, 1983.
15 WITNESS THORSELL: That would indicate that 16 it was a~Comstock inspector.
i i 17 MR. GUILD: It would indicate he's not an 18 Ernst inspector, anyway. All right, sir.
i 19 BY MR. GUILD:
i l
20 0 Now, Mr. Kostal,-let's turn our attention to 21 Intervenors' Exhibit 155-B. This is the Sargent & Lundy l ,
22 calculation package for Cable Pan Hanger 104.
l 23 I take it, from some earlier responses that you had 24 given, that you have had an. opportunity to review this 25 calculation in some detail in preparation for your Sonntag Reporting Service, Ltd.
I Geneva, Illinois 60134 i (312) 232-0262
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1 testimony?
2 A (WITNESS KOSTAL) Yes, sir.
3 0 All right.
4 MR. GUILD: Judge, I got a cleaner copy and a 5 copy in order, which is helpful.
6 Do the Board Members have a replacement copy for 7 155-B?
8 You will recall the pages of my proffered exhibit 9 were misnumbered -- or out of order, out of sequence.
10 JUDGE GROSSMAN: Yes, we have a reordered 11 copy of that.
12 MR. GUILD: Thank you, Judge.
(A}
13 'BY MR. GUILD:
14 Q All right, sir. Now, Mr. Kostal, let's look at the 15 second page of the document, the first page of the 16 calculation.
17 Can you tell me first what the number designation j 18 is in the upper right-hand corner, " Calc No."?
19 There's a multi-digit number.
20 A (WITNESS KOSTAL) It's -- the first portion of the 21 digit, 19.3.1, is the cross-reference to the design 22 control summary, which is part of Exhibit 161. That 23 represents -- in Exhibit 161, under " calculations 24 noted," it's defined'as 19.3.1.
25 The next two digits, 11, represent the population Sonntag Reporting Service, Ltd.
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(-
1 cable pan hanger.
2 The next two -- the number 2 represents the 3 calculation; and the last represents 104, which is the 4 hanger in question.
5 O All right, sir.
6 Now, help me. I've got Intervenors' Exhibit 161, 7 design procedures and assumptions, bearing a calculation 8 number 19.3.1.
9 Is there a particular portion of this document to 10 which this number refers?
11 (Indicating.)
() 12 13 A (WITNESS KOSTAL) document.
No. It just refers to the entire 14 Q All right. I see.
15 Now, the number 2 preceding the identification of 16 104 -- that,'s Calculation 2 of what?
17 A (WITNESS KOSTAL) It just -- it's the second 18 calculation within this body of calculations that are 19 filed together. It would be the second calculation.
20 0 Okay.
21 The body of -- what does the body consist of?
22 A (WITNESS KOSTAL) Well, it's the complete -- each --
23 each individual observation has a set of calculations
,s 24 associated with them, and this is the second set of
( 25 calculations.
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1 So Hanger 104 is the second set of calculations 2 filed within the book of all the calculations.
3 0 I see.
4 So does that indicate that there-are -- there's at 5 least one other calculation for 104 or is it that 104 is 6 the second in a series of multiple calculations?
7 A (WITNESS.KOSTAL) It's the second in a series of 8 multiple calculations, " multiple" being defined as 9 calculations for the other observation packages.
10 Q All right, sir.
11 And I take it this number, the calc number, is the
( 12 unique identifier for this particular calculation for 13 this particular observation?
14 A (WITNESS KOSTAL) That's correct, sir.
15 0 All right.
16 Now, I notice that the block next below this is 17 indicated to be-Rev. 4, and then it has what appears to 18 be a number 2 crossed out.
19 A (WITNESS KOSTAL) Yes, sir.
20 0 What does that information indicate?
21 A (WITNESS KOSTAL) That refers to the revision of the 22 design control summary, which is Exhibit 161.
23 0 Which is your general procedure for --
24 A (WITNESS KOSTAL) Right, this procedure --
25 0 -- for structural?
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(^s 1 A (WITNESS KOSTAL) That's correct.
2 At the time this calculation was made, Rev. 4 of 3 this document was the latest current revision to the 4 document.
5 0 All right.
6 Why was there a 2 in the rev box there marked 7 through on this particular calculation, if that is a 2?
8 At least, that's what it looks like to me.
9 A (WITNESS KOSTAL) What I believe is the reason for the 10 2 is when the calc was originally prepared, Rev. 2 was 11 in force.
() '12 13 If you will notice, when Rev. 4 was applied, if you look further into the calc, you will see under -- this 14 is in the tabulation of metal reduction for undercuts.
15 There is an Item 1. Over there in the right-hand 16 margin, you'll see a dashed line with an R equal -- R-4.
17 That means Rev. 4.
18 0 I've just lost you here.
19 Which page are you referring to, sir?
20 A (WITNESS KOSTAL) I'm still on the same page.
21 Q All right.
22 A (WITNESS KOSTAL) I'm looking towards the bottom of the 23 page --
24 O Sure.
25 A (WITNESS KOSTAL) -- where -- on the right-hand side of Sonntag Reporting Service, Ltd.
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1 the bottora of the page where there are two indications 2 of "Rev. 4."
3 Do you see them?
4 Q Yes.
5 With a cloud to the left of each? i 6 A (WITNESS KOSTAL) Excuse me?
7 -Q with a cloud next to them?-
1 8 A (WITNESS KOSTAL) The cloud is -- yes.
l 9 That'.s basically what I believe'is the 10 cross-referencing of the revision that took place on 11 this calculation relative to that item.
() 12 13 0 All right, sir.
Now, I notice that some of the pages in this 14 exhibit, this cale package for Cable Pan Hanger 104, 15 remain -- they continue to indicate a Rev. 2 in that 16 block at the top of the page?
17 A (WITNESS KOSTAL) That's correct, sir.
18 Q All right.
19 Does that indicate that there was no change from 20 Rev. 2 for that particular aspect of the calculation?
21 A (WITNESS KOSTAL) That's correct, sir.
22 0 All right, sir. Now, there's a " prepared by" box.
23 Can you tell me who is. indicated as having prepared l i
, .24 this calc? !
25 A (WITNESS KOSTAL) His name is S. N. Gupta.
l ,
i !
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\j 1 0 Can you spell his last name?
2 A (WITNESS KOSTAL) G-U-P-T-A.
3 0' All right, sir.
4 And Mr. Gupta -- is it Mr. or Ms.? A man?
5 A (WITNESS KOSTAL) It's a man.
6- 0 And what position does that gentleman hold?
7 A (WITNESS KOSTAL) He is a structural engineer within 8 the Structural Engineering Division, which is a division 9 of the Structural Department of Sargent & Lundy.
10 0 All right, sir.
11 Now, " reviewed by" -- can you tell me who that 12 gentleman is?
13 A (WITNESS KOSTAL) His name is Jeffrey Fazzone, 14 F-A-Z-Z-0-N-E.
15 0 All right.
16 What position does Mr. Fazzone hold?
17 A (WITNESS KOSTAL) He is also a structural engineer 18 within the Structural Engineering Division of the 19 Structural Department of Sargent & Lundy.
~20 0 All right.
21 Is he a peer'of the first gentleman, the preparer, 22 or is he a superior?
23 A (WITNESS KOSTAL) I don't know that.
24 0 Is there a protocol that a superior reviews the work of
) 25 a subordinate, or is it just a peer?
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k 1 A (WITNESS KOSTAL) The general protocol -- a review can 2 take place with a peer. The approval would take place 3 with a supervisor -- the next level.
'4 4 Q And who indeed has approved this calc?
5 A (WITNESS KOSTAL) Bruce Knobloch.
6 0 Can you spell that gentleman's name, please?
7 A (WITNESS KOSTAL) K-N-O-B-L-O-C-H I think is how you.
8 spell it.
9 0 What position does that gentleman hold?
10 A (WITNESS KOSTAL) I'm not quite sure exactly his 11 position, but I know he is a -- I believe him to be a
() 12 13 senior structural engineer, as compared to a structural engineer, which is the next level up --
14 0 All right.
15 A (WITNESS KOSTAL) -- within the department -- within 16 the same division and the same department.
17 Q All right, sir.
i 18 Now, Mr. Kostal, you are presenting the testimony
- 19 on structural issues as far as Sargent & Lundy's role in j 20 BCAP.
21 That's your area of work for Sargent & Lundy, is in l 22 the Structural Department; correct?
23 A (WITNESS KOSTAL) Through July of this year, that's I
24 correct.
) 25 O July of this year, all right.
i l Sonntag Reporting Service, Ltd.
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1 At the time that 'this calculation was made, you l 2 were in the Structural Department at that time?
3 A (WITNESS KOSTAL) That's correct.
4 0 And you held the position of?
5 A (WITNESS KOSTAL) Assistant department manager of the-6 Structural Department.
7 Q Assistant department manager, all right, sir.
8 Now, where did the approval person for this 9 particular calculation fit in the chain of command with 10 respect to you?
11 A (WITNESS KOSTAL) Bruce Knobloch is a senior structural 12 engineer assigned to the Byron /Braidwood Project Team, (a\
13' He is assigned in the Structural Department to that 14 project team.
15 Within the firm there are -- within the Structural 16 Department, there are a number of positions that exist, 17 from an engineer to a Senior Engineer to a supervisor to 18 an assistant division head to a division head and up 19 through the ranks until you reach the assistant manager 20 and the manager of the department.
l 21 So from the point in time relative to where I am, 22 he's -- he's a few levels below me.
l 23 Q Let's just figure out how many ranks below you this 24 gentleman was in the approval position for this l D
( 25 particular calc.
l l
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\v l' What's the next senior position above the position 2 that you believe this gentleman to hold?
3 A (WITNESS KOSTAL) Supervisor for the Byron and 4 Braidwood Project Team.
5 0 All right.
6 And above the supervisor for the team?
7 A' (WITNESS KOSTAL) Within the Structural Engineering 8 Division, to which these gentlemen are assigned, the 9 next position above the supervisor within that division 10 is the assistant division head.
11 O All right.
( 12 And above that gentleman, that person?
13 A (WITNESS KOSTAL) That person is the. division head for 14 the Structural Engineering Division.
15 0 All right.
I 16 And above that person?
~
17 A (WITNESS KOSTAL) That's the highest position within 18 the division.
l 19 Those divisions -- there are design divisions, one 20 of which is the Structural Engineering Division, who 21 report to a design director.
.22 0 All right.
l 23 And above a design director?
j 24 A (WITNESS KOSTAL) The design director reports to me.
25 Q Did you review this calculation in the normal course of l
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I the evaluation of this BCAP observation?
i 2 A (WITNESS KOSTAL) No, sir.
3 Q How many BCAP discrepancies did you personally review, 4 if any, Mr. Kostal, in the normal course of your duties?
5 A (WITNESS KOSTAL) In the normal course of duties, I 6 would review none.
- 7 Since I was providing status of dates at the 8 various NRC presentations, which were held on the 9 f requency of roughly one a month, during those status 10- meetings, I characterized the discrepancies that were 11 being found and the evaluations being conducted by b) 12 13 Sargent & Lundy.
During those periods of time, I had an occasion to
- 14 review selected calculations. ,
15 ~0 All right.
16 As, I take it, you thought they might come.up in 17 the course of such a status conference?
18 A (WITNESS KOSTAL) The purpose of the status meeting was I
i 19 to specifically bring up discrepancies that were being 20 found during the course of the BCAP inspections.
21 0 So for purposes of making your presentation, you would 22 for that reason have reviewed some calculations?
23 A (WITNESS KOSTAL) That's correct.
l 24 0 Now, I take it that -- well, what is the relationship
) 25 between the individuals who had responsibility for Sonntag Reporting Service, Ltd.
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1 preparation, review and approval of this calculation and 2 those who performed the evaluation of this particular 3 observation for design significance?
4 A. (WITNESS KOSTAL) They are one and the same.
5 0 All right, sir.
6 Now, if I go to the observation, BCAP observation 7 form, for Cable Pan Hanger 104, whose name will appear 8 as the Sargent'& Lundy person attesting to the 9 no-design-significance evaluation?
10 A (WITNESS KOSTAL) I don't have in front of me the 11 observation report with the signature of the individual (O
~
12 who, from Sargent & Lundy,. signed that.
V; 13 0 If I could have a moment.
14 All right, sir. Let me show you a copy of 15 Intervenors' Exhibit 155 for CSR Cable Pan Hanger 104,
~
16 Observation 4.
17 (Indicating.)
18 I believe Block 25 is the appropriate portion of 19 the document.
20 A (WITNESS KOSTAL) This was again prepared by Mr. Gupta 21 and signed by Bruce Knobloch.
22 0 All right, sir.
23 So, in turn, the preparer and the approval 24 ' authority for the calculation signed the observation 25 form?
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1 A (WITNESS KOSTAL) In this particular observation, 2 that's correct.
~3 O And is that reflected in the general practice or was 4 there a general practice?
5 A consistent general practice, let's say.
6 A (WITNESS KOSTAL) The general practice -- there were a 7 number of people who could sign. I would -- I believe 8 that the majority of these that were signed were either 9 signed by one of two gentlemen: either Bruce Knobloch 10 or' Steve Bartheau, 11 The reason for saying that is Bruce Knobloch I h 12 coordinated our structural engineers in the office down b in Chicago, where some of these calculations were 13 14 performed;.and Steve Bartheau coordinated the structural 15 engineering group that was at the site.
16 0 All right, sir.
17 So it would have been consistent for either of 18 those gentlemen to have signed the evaluation even if 19 they. hadn' t been in the direct chain of preparation, of 20 review or approval of the calculation itself?
21 A (WITNESS KOSTAL) In signing, they would have reviewed 22 the calculations that would have been performed to 23 assure themselves that the data that was being 24 represented in our sign-off block was accurate and 25 correct.
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V' 1 Q All right.
2 Would they have indicated that review on the 3 calculation sheets?
4 A (WITNESS KOSTAL) No. It would be indicated on the 5 individual BCAP observation where we have a " prepared" 6- statement as well as approval signature.
7 Q All right.
8 So the endorsing of the BCAP observation form 9 carries with it the review of the calculation?
10 A (WITNESS KOSTAL) It carries the review of the 11 calculation to assure that we correctly reflected the
( 12 disposition of the observation and we correctly 13 reflected the calculation that addresses the disposition I 14 of the observation.
15 0 All right, sir. Now, back to the calculation itself, 16 155-B.
17 Now, in this case during the course of the review 18 of this discrepancy, there appeared to have been a 19 number of revisions to the Sargent & Lundy calculation i 20 design procedure and assumptions document, Calc 19.3.1; 21 namely, Bevs. 3 and 4.
22 What were the material constituents of those 23 revisions?
24 A (WITNESS KOSTAL) I don' t know that at this time.
25 0 Mr. Thorsell, do you know?
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(j 1 A (WITNESS THORSELL) No, sir.
2 0 Can you tell me what effect those revisions had on the
~
3 calculations that appear in Intervenors' Exhibit 155-B?
4 A (WITNESS KOSTAL) The only thing I can tell you is that 5 the Rev. 4 of the document and the indication on these 6 cales of the area where the Rev. 4 was applied were 7 consistent.
8 0 Well, th'ey use the same numbers in all the places those 9 numbers were appropriate to use --
10 A (WITNESS KOSTAL) That's correct.
11 0 -- is that what you're saying?
, 12 A (WITNESS KOSTAL) Yes, sir.
%J 13 0 All right. Let's begin with the first page of the 14 calculation.
15 First of all, what's the information that appears
. 16 in the top half of that page?
17 A (WITNESS KOSTAL) It provides you with references to 18 various drawings where you would find the individual 19 components that make up this particular hanger.
20 There are drawings that show the plan layout.
21 There are drawings which also give you your horizontal 22 connections and your vertical connections. That's what 23 basically these reference drawings relate to: the 24 drawings that you would go to to assemble the hanger.
) 25 Then there is a problem statement which says that Sonntag Reporting Service, Ltd.
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14645 x l 1 within this observation package, there were 2 discrepancies noted on undercuts at Unistruts. There 3 were undersized welds, there were underlength welds, and 4 there were some gouges -- gouge areas.
5 0 A11'right, sir. Now, back up to the references at the 6 top.
7 The drawing that's indicated as Rev. I guess it's 8 Roman V -- is that the plan layout drawing, 20E-1, et 9 cetera?
10 A (WITNESS KOSTAL) Yes, 20 -- well, it's 20 E-1-3052H.
i 11 That is the general layout drawing where you would find 12 this hanger in a plan view.
(
13 0 All right, sir.
14 And is that a Rev. Roman V?
15 A (WITNESS KOSTAL) That's a Rev. V.
16 0 Okay. Below that there's a Drawing 3263, Rev. AB.
17 What does that reference?
18 A (WITNESS KOSTAL) 32657 19 0 63.
20 A (WITNESS KOSTAL) Oh, 3263. '
21 3263 refers to various attachment details, and they 22 refer to the detail that was used to attach the vertical 23 elements or vertical members of the hanger to the 24 structural steel member --
25 0 Okay.
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l A (WITNESS KOSTAL) -- primary structural steel member.
2 Q These are at the top of the verticals, which attach the 3 hanger to the beam?
4 A (WITNESS KOSTAL) Right, to the building steel.
5 0 All right, sir.
6 Now, the next line says -- appears to be a 7 misspelling, "Unistrus:" is that right?
8 A (WITNESd KOSTAL) That's correct.
9 0 "Unistrus Gen. Engineering Cat #9."
10 What is that reference?
11 A (WITNESS KOSTAL) That's their catalog.
12 C That's where you find the material specifications?
[OD 13 A (WITNESS KOSTAL) That's where you'll find the material 14 specification, yes, sir. ,
15 0 All right, sir.
16 What does the next line refer to?
17 A (WITNESS KOSTAL) That is another drawing referring to 18 a hanger list where you would find the hanger number.
19 It would define the type of hanger that it is; and 20 it would with define the geometry of the hangers, the 21 number of members that would be entailed and the type of 22 members that were used, as well as the gross weight for 23 this given hanger.
24 0 Okay. All right, sir.
25 I want to show you an excerpt from a series of Sonntag Reporting Service, Ltd.
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1 drawings that were made available with respect to cable 2 Pan Hanger 104, and I'm looking at a small drawing.
3 I can't quite make out the identification of it, 4 but --
5 A (WITNESS KOSTAL) 7218.
6 (Indicating.)
7 0 Is that the reference from the hanger list showing the 8 type of hanger in question?
9 A (WITNESS KOSTAL) Yes, sir.
10 0 It's an attachment to the hanger list?
11 A (WITNESS KOSTAL) That's correct, sir.
12 And that shows you the general configuration of the
( Q 13 hanger in question?
14 A (WITNESS KOSTAL) That's correct, sir.
15 0 Is that the source that the craf t would refer to in the 16 first instance for determining what type of hanger to 17 install at that location?
18 A (WITNESS KOSTAL) Yes, sir. They would use all these 19 drawings to assemble that hanger.
20 0 All right, sir.
21 And, in turn, it's the source that the Quality 22 Control Inspector -- in this case Comstock or Ernst --
23 would refer to to inspect that hanger as built?
24 A (WITNESS KOSTAL) Yec, cir.
25 Q okay.
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1 Now, where in particular in the facility is this 2 hanger located?
3 A (WITNESS KOSTAL) This particular hanger is located in 4 the auxiliary building. It's located in what's known as 5 Area 5, which is an area adjacent to the Unit 1 6 containment.
i
~
7 Q It's referred to as the " wing wall"?
8 A (WITNESS KOSTAL) No. The " wing wall" is referred to l 9 as a concrete wall.that-defines a boundary of -- of Area 10 5, but it's --
11 0 This is the wing wall area or near the wing wall, as
() 12 13 A I've heard the reference made?
(WITNESS KOSTAL) I've never heard of it called the
! 14 " wing wall area."
i 15 We've always used the terminology " Area.5" --
16 0 All right, sir.
17 A (WITNESS KOSTAL) -- to define a certain area within 4
18 the auxiliary building which is --
19 0 This-is adjacent to the concrete wall of the 20 containment?
21 A (WITNESS KOSTAL) Well, it's bounded -- it's near the 22 concrete wall; and it's also near another wall which 23 defines another boundary, which is Area 1 and 2 of the i 24 aux building.
25 0 All right, sir.
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1 At what elevation?
2 A (WITNESS KOSTAL) The elevation of this particular 3 hanger is Elevation 334 foot 10 inches, and that defines 4 the elevation of the lowest horizontal member.
5 0 All right. Now I'm looking at the drawing that 6 indicates Elevation 426.
7 Is that the general level at which the hanger is 8 installed?
9 A (WITNESS KOSTAL) Well, this hanger is actually 10 installed at a higher elevation than that.
11 It's installed at an elevation which would be the
() 12 13 next floor above, which would be -- so it would be installed at 447 foot 10 inches, which would be the 14 bottom of the beam that it's attached to.
15 0 All right.
16 The plan drawing shows it at 426. It shows it on 17 426 elevation.
18 A (WITNESS KOSTAL) That happens to be the plan view at 19 which we show all the cable trays that exist between 426 i
20 and the next elevation.
21 (Indicating.)
22 0 All right, sir.
23 A (WITNESS KOSTAL) You need to go f rom this plan drawing
, 24 to the hanger drawing and, f rom the hanger drawing,
) 25 calculate the exact elevation at which the top support Sonntag Reporting Service, Ltd.
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%d 1 is, which would be the next level of steel.
2 0 All right, sir.
3 MR. GUILD: Mr. Chairman, the record reflects 4 this hanger was inspected at two different times by Mr.
5 DeWald and by Mr. Martin.
6 BY MR. GUILD:
7 0 Now, sir, again the references -- where does one derive 8 the details such as detail DV 162?
9 That's the first one.
10 A (WITNESS KOSTAL) DV 162 is found on Drawing 11 20 E-0-3 992.
[J 12 13 0 All right.
Is that a standard detail?
14 A (WITNESS KOSTAL) This is a standard detail, yes, sir.
15 0 And that reflects a connection of two of the elements of 16 this particular hanger?
17 A (WITNESS KOSTAL) Yes, sir.
18 0 All right.
19 Similarly, for the DV 22, which is the next 20 indicated detail, standard detail?
21 A (WITNESS KOSTAL) That also shows typical connection 22 details.
23 0 All right. Below those two detail references, there is 24 a line that reads " Calc #12.2.126."
k'O) 25 What does that reference?
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14651 1 A (WITNESS KOSTAL) That referenced the calculation that 2 -- that referenced the calculation on this particular 3 hanger prior to BCAP, meaning it's the calculation that 4 exists on the hanger without any evaluations of 5 discrepancies.
6 Q It's the design calculation?
7 A (WITNESS KOSTAL) That's correct, sir.
8 Q All right.
9 And is it a design calculation that you need for 10 this particular hanger or is it a reference calculation?
11 A (WITNESS KOSTAL) No. This is a unique calculation.
12 Q All right.
13 It's the source for the as-designed data that is 14 going to be used as a base for comparison of the 15 as-built condition?
16 A (WITNESS KOSTAL) It referenced where the original calc 17 comes from. The source for the as-designed information 18 comes from a subsequent computer run.
19 It was originally the base for this cale, and then 20 there was a subsequent computer run which was used for 21 modifying this particular calculation.
22 Q For what purpose?
23 A (WITNESS KOSTAL) For the purpose of more accurately
- 24 reflecting the state of stress that exists in thoce 25 members as compared to the load that exists in that Sonntag Reporting Service, Ltd.
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1 hanger.
2 O For purposes of the CSR design evaluation?
3 A (WITNESS KOSTAL) I -- well, let me -- let me try to 4 clarify it.
5 We were in the process -- I'm not sure -- we were 6 in the process of upgrading many of our calculations to 7 take into account the as-designed conditions that 8 existed in the -- in the plant.
9 We were also in the process of reviewing 10 calculations for -- reviewing calculations for a final 11 reconciliation of loads that are given to us for these 12 hangers from what's known as a CIS-4, or Cable (a) 13 Information System, which defines then all the loads 14 that would be associated with this given hanger.
15 That analysis was performed in the calculation 16 that's documented in the. time frame of 7/25/85.
17 0 The reconciliation calculation?
18 A (WITNESS KOSTAL) The reconciliation calculation.
19 0 And was that reconciliation calculation of July of 1985 20 then relied on in whole or in part for the calculation 21 and evaluation documented here?
22 A (WITNESS KOSTAL) That reconciliation calculation was 23 used for upgrading this particular set of calculations 24 to reflect the actual ctate of ctrecc that exicted in 25 the components that were discrepant, yes, sir.
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1 0 All right.
2 Now, I notice that the initial preparation of this 3 calculation is dated May 24, 1985; correct?
4 A (WITNESS-KOSTAL) Yes, sir.
5 0 It went through a review-and-approval chain that led to 6 its approval June 10, 1985, all right.
7 But then I see another block indicating that there 8 was a preparation of another calculation beginning July 9 25, 1985, leading-to an approval September 3, 1985.
10 A (WITNESS KOSTAL) Yes, sir.
11 0 Now, was that second calculation made in light of the
() 12 13 A two subsequent calculations that you've just described?
(WITNESS KOSTAL) Like I said before, we were making a 14 variety -- we were making calculations on cable pan 15 hangers at the same time that the BCAP effort was going 16 on. The origin of why this particular calculation was 17 made could have occurred for a variety of reasons.
18 One is we weto upgrading these calculations to 19 reflect the actual isads that were given to us in the 20 computer print-out for all of those that were on this 21 hanger. That's one reason why we could have done this 22 calculation.
23 The second portion of the reason for the 24 calculation ic we were in the procccc of going through
) 25 the Rev. A walkdown program, which documented all the Sonntag Reporting Service, Ltd.
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14654 L' J 1 objective -- which documented the as-built conditions of 2 the hanger as well as documenting any missing portions 3 of welds.
4 .In addition to that, we may have, in an effort to 5 assure ourselves that the calculation was -- did reflect 6 the present conditions -- it could have been upgraded 7 for that reason, also.
8 So it could have been any one of those three 9 reasons as to why the calc was done again on 7/25/85.-
10 0 I take it that whatever reason it is, it's not evident 11 f rom the calculation documents that we have before us?
12 It's evident that an additional
) A (WITNESS KOSTAL) 13 calculation was made within this period of time and that 14 the --
15 0 The basis for that was not stated, though, the basis for 16 performing that subsequent calculation?
17 A (WITNESS NOSTAL) That's correct.
18 0 You have no personal knowledge of the basis; you' re 19 simply offering --
20 A (WITNESS KOSTAL) I'm offering an opinion as to what 21 are some of the conditions that could have resulted in 22 this analysis being done at that point in time.
23 0 I see.
24 Well, what'c the result of the analysis prepared by b)
( 25 Mr. Gupta and reviewed and approved in the May-June time Sonntag Reporting Service, Ltd.
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1 frame, Mr. Kostal?
2 A (WITNESS KOSTAL) Well, we can look. Tnere are many 3 results.
4 The calculation was prepared over a period of time.
5 It was prepared from 5/24 through 6/5, and the results 6 -- we'd have to go page by page, and I could explain to 7 you the results per connection in terms of what the 8 interaction coefficient was originally in the original 9 calculation versus what the interaction coefficient is 10 with the new calculation and what the design margins 11 were with the original and the design margins with the 12 latter.
(
13 0 All right, sir.
14 Generally, though, are the results of the original 15 calculation contained in these documents?
16 A (WITNESS KOSTAL) Yes, sir.
17 0 And how are they indicated and distinguished f rom the 18 subsequent calculations that were made?
19 A (WITNESS KOSTAL) The subsequent calculations are i
20 marked up in the -- in the circles, the squiggly 21 circles, which define that those were revisions.
22 Therefore, you could look at the original data 23 that's crossed out; and it would tell you, based on the 24 original calculation, what the interaction coefficients
( ) 25 are'as well as the design margins.
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I 14656 1 The squiggly things --
2 Q The clouds?
3 A (WITNESS KOSTAL) The clouded numbers are the numbers 4 . reflective of the later analysis.
5 0 All right, sir. Let's look at the second box for the 6 preparation review and approval of this calc.
7 Who did the preparation July 25, '85?
8 A (WITNESS KOSTAL) Jeffrey Fazzone.
9 Q Who is that gentleman?
10 A (WITNESS KOSTAL) That's the gentleman that's up in the
- 11 review block, who is also within our Structural
() 12 13 Q Engineering Division.
Okay.
14 Who reviewed the second calc?
15 A (WITNESS KOSTAL) I believe it's Mr. Walsh, W-A-L-S-H.
16 He would also be an engineer, structural engineer, 17 within our Structural Engineering Division.
18 0 And who approved the second calc?
19 A (WITNESS KOSTAL) This is also approved by Mr.
20 Knobloch.
21 0 All right. Now, just below that box, there is a cloud 22 that reads " superseded by 19.3.1.11.2 104 Page 21."
23 What does that refer to?
24 A (WITNESS KOSTAL) That refers to the last page that's 25 in this calculation. It's the 21st page of this Sonntag Reporting Service, Ltd.
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14657
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1 /
l' calculation.
2 0 WhatEdoes it supersede?
3 A (WITNESS KOSTAL), It's a clarification of the Unistruts i
4 that~were usedJin terms of area of Unistruts.
5 On Item 1, it wasn't a P-1004; it was actually a 6 .P-5500. The other clarification is -- relates to Item 7 9, which is an exact'-- more exacting cale on the area 8 associated with the metal reduction.
9 0 Item 9 is what; the ninth calc that's performed in here?
10 A (WITNESS KOSTAL) Item 9 refers to a -- you have to use 11 Page 3 of the calculations to locate Item 9.
() 12 13 Item 9 is an undercut -- is a definition -- is an undercut area associated with a particular joint, which 14- is the -- one of the diagonal members.
15 You can find that on Page 3 of the calculations, 16 and you can find it on the lef t-hand side of the 17 diagonal -- the inclined diagonal member at the -- and 18 it's circled up with a 9 with the "U/C."
19 Do you see that location?
20 0 It says "Section C-C"?
'21 A (WITNESS KOSTAL) Yes. That refers to undercut on that 22 location.
23 0 Well, I guess the question I was really asking was: How 24 do you know that the superseded cloud on the first page 25 under the box for the second calc makes those changes?
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14658
/D 1 A (WITNESS KOSTAL) Because it says it. There's a little 2 arrow that refers down to those two locations.
3 If you notice, at the end of the cloud, there are 4 two little lines on the right-hand side. Both of those 5 strows are indicating down to that "Rev. 4."
6 0 I see. All right, sir.
7 Now, the first problem is identified as " undercuts 8 at Unistruts," and that's where I just got you to tell 9 me abcut the cloud.
10 What's the process that the first reviewer or first 11 calculator went through?
12 A Just to clarify, this entire set of
( (WITNESS KOSTAL) 13 21 pages of calculations was all prepared by the --
14 excuse me -- 20 pages of this calculation were all 15 prepared by the same individual and all reviewed by the 16 same individual and all approved by the same individual.
17 0 But then they were changed by different people?
18 A (WITNESS KOSTAL) That's correct.
19 Q All right, sir.
20 I want to try to keep straight what the original 21 preparer did and what was then the subject of the second 22 calculation.
23 A (WITNESS KOSTAL) Okay.
,s 24 0 What did the original preparer set out to do with
( ,) 25 Problem No. 1?
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1 " Undercuts at Unistrut," I take it?
2 A (WITNESS KOSTAL) That's correct.
3 What he was doing -- this is the bottom portion of 4 Page 1 -- was looking at all the various locations where 5 undercut was found in the inspection report.
I 6 The circles on the left-hand side, 1 through 10, 7 relate to Page 3 of the calculations; and that tells you 8 at which joint each of those circles has an undercut.
9 Q All right.
10 A (WITNESS KOSTAL) Now, you have to work this calc map 11 with the observation package, which more accurately
() 12 13 0 reflects the size of each of the underc'uts.
Okay. We've got that. So that's Intervenors' Exhibit
. 14 155. That's the observation.
15 Do you have that available to you, Mr. Kostal?
4 16 A (WITNESS KOSTAL) Yes, sir.
17 0 All right.
18 And where do we have a more particular description 19 of the size of the undercuts?
20 A (WITNESS KOSTAL) Well, if you turn to Page 1 -- Page 21 3, which would be -- I don't know how your package is,
- 22 but it's this map.
23 (Indicating.)
+
24 It says at the top --
i 25 0 "CSR weld map"?
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k 14660 1 A (WITNESS KOSTAL) - "CSR-1-E-CPH-104-4, Attachment 1, 2 Pages 1 through 3." That's on the left-hand side.
3 MR. MILLER: Give us the Bates number, Mr.
4 Kostal.
i 5 WITNESS KOSTAL: I didn't get that. I don't 6 have that package.
- 7 MR. STEPTOE: Is this the one you're 8 referring to?
9 (Indicating.)
10 WITNESS KOSTAL: No.
11 I'm referring to this page right here, which is --
12 (Indicating.)
13 MR. GUILD: Mr. Chairman, Counsel suggests a 14 brief recess so we can get these papers in order here.
15 JUDGE GROSSMAN: Okay, fine. Why don't we 16 take 10 minutes, then.
17 (WHEREUPON, a recess was had, after which 18 the proceedings were resumed as follows:)
19 JUDGE GROSSMAN: Mr. Guild?
20 MR. GUILD: Thank you, Mr. Chairman.
- 21 BY MR. GUILD
22 0 Now, Mr. Kostal, you were helpful to show me the page
! 23 you're referring to. It's the diagram that appears at
, 24 Bates No. 4667 in the package for CPH-104. The whole 25 package is Intervenors' Exhibit 155.
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14661 4
l 1 Now, I think you were explaining that that 2 describes in more detail the size -- the dimensions of
{
3 the undercut in question.
I 4 A (WITNESS KOSTAL) Yes, sir.
- l. 5 What I-was describing was one of the calculations, t
6 and I can start at, if you will -- where is 17 7 A '(WITNESS THORSELL) (Indicating.)
8 A (WITNESS KOSTAL) Okay.
9 I'll just pick any one of them.
10 0 We're doing undercuts, and there are 10 of them that are 11 being evaluated; correct.
i 12 Item No. 1, " check undercuts"?
. \s l 13 A (WITNESS KOSTAL) That's correct.
14 Q And none of those undercuts represent a capacity 15 reduction of in excess of 10 percent?
16 A (WITNESS KOSTAL) In fact, none of them have a capacity 17 reduction of less than 98 percent.
18 0 All right, sir.
19 So the result of the calculation -- the evaluation 20 of undercuts appears at Page 4 of the calc package --
21 A (WITNESS KOSTAL) Yes, sir.
22 0 -- and that is metal reduction R equals .98, which, l 23 being greater than .9, Category Y, is okay?
24 'A (WITNESS KCSTAL) Yes, sir.
i i 25 0 All right.
I J
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1 Now, I take it that, as you've described earlier, 2 given the added -- the additional -- there was a 3 correction made to that calculation with respect to the 4 size of the Unistrut involved?
5 A (WITNESS KOSTAL) That's correct.
6 0 And what significance, if any, did that have on the 7 evaluation of the undercut?
8 A (WITNESS KOSTAL) It had none because it was correcting 9 just the Unistrut used on Page 1.
10 But if you look on Page 4 and you look at the 11 assessment for the diagonal Unistrut, which is the 12
( Unistrut which had the most -- the most undercut on it 13 -- this is Line 4 -- it says the diagonal member was a 14 P-5500.
15 Do you see that on the --
16 0 Yes, sir.
17 A (WITNESS KOSTAL) All right.
18 That P-5500 is the correction that's' associated 19 with -- with Page 1.
20 So in reality, the correct member was indicated in 21 the calculation, and the correct area was used. It was 22 just referenced wrong in the calculation.
23 0 All right, sir.
24 And so there was no need to change the ultimate d
25 analysis of undercut, which was that its capacity Sonntag Reporting Service, Ltd.
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i 14663
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, 1 reducti$n.was negligible?
2 A (WITNESS KOSTAL) That's correct.
3 0 So you 'didn't do any further detailed calculation for 4 the safety margin for undercut defects?
s 5 A .(WITNESS KOSTAL) No, sir.
6 Q All right. So let's move to No. 2, " check undersize 7 welds."' That begins at Page.4 of the calculation.
8 N w, the first reference I see is it says "A & B 9 diagonal brace."
10 What's the symbol that follows the word " brace"?
11 A (WITNESS KOSTAL) Well, if you turn back to Page 3 12 again, at.the top of the -- there is a diagonal member 13 iridicated in- the illustration .--
14 0 Yes. -
15 A (WITNESS,KOSTAL) -- of the hanger, and there are two 16 points. On the left-hand side, you'll see " weld U/S";
. . 17 and there's a circle, meaning Joint B.
18 0 Yes.
19 A (WITNESS KOSTAL) Then if you look at the top-hand 20 , - side, which is now the right-hand-side incline, and you 21 look at the note just below the Section D, there's a 22 note " weld U/S," and it's circled with an A.
23 0 Yes.
24 A (WITNESS KOSTAL) What that refers to is the weld 25 , attaching that diagonal to the vertical tube steel.
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i 1 Q All right, sir. l 2 A (WITNESS KOSTAL) Okay. i 3 Q There are two separate attachment welds in question, one 4 on either side of the diagonal?
5 A (WITNESS KOSTAL) That's correct. t 6 But in this particular case, since the discrepancy 7 on the Attachment B was less than'the discrepancy on [
8 Attachment A, A was used for the analysis.
9 0 Did it make any difference whether it was at the top of 10 the diagonal brace or the bottom of the diagonal brace?
11 A (WITNESS KOSTAL) Well, given it had the greater
( 12 discrepancy, the load on that diagonal brace is 13 literally the same, top and bottcm.
14 We use the greater discrepancy at the top and 15 perform the analysis of the top. Since the results at 16 the bottom would be better, we didn't do an additional 17 analysis on the Connection B.
4 18 Q All right, sir.
19 Now, how did you determine or how did the evaluator 20 determine that the discrepancy at A was more significant 21 than the discrepancy at B and, therefore, the A was to 22 be evaluated? j 23 A (WITNESS KOSTAL) Well, if you read on the Bates stamp 24 Page 4667, which is the observation --
i 25 0 Yes.
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14665 s- 2 1 A (WITNESS KOSTAL) -- it defines that the weld size at 2 the top, which is A, is an undersize on both sides of 3 the weld, both sides of the connection. So both 4 vertical welds are undersized by 1/16 of an inch.
5 If you read on that same diagram the weld which is 6 B, the note says it was undersized on only one side; the 7 south side, not the north side.
8 So, therefore, the discrepancy is only half of what 9 it is as compared to Weld A.
10 0 All right, sir. A portion of the notation on my Page 11 4667 for the upper connection of the diagonal is
[)
V 12 missing.
13 Do you have the full text there?
14 A (WITNESS KOSTAL) It says " Weld size'1/16 under throat 15 size 3-1/4 inch of 3-1/4 inch both sides."
16 0 All right, sir.
17 That means it's undersized for the entire length of 18 the weld?
19 A (WITNESS KOSTAL) That's correct.
20 Q Both sides?
21 A (WITNESS KOSTAL) That's correct.
22 0 All right.
23 Now, on Page 4668 is there a more -- a larger view 24 of that same connection?
I
's ,j 25 A (WITNESS KOSTAL) No, sir. 4668 provides -- it doesn't Sonntag Reporting Service, Ltd.
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1 p'rovide.-- excuse me.
2 On 4668 there are two cross sections, Section C and 3 Section D. Section C relates to Weld B on the lower 4 portion of the diagonal. Section D relates to the 5 connection A, which is on the upper section of the 6 diagonal.
7 What those two sections are showing are 8 discrepancies associated with undercut but on a 9 different location than are shown on Bates Stamp 4667.
10 0 All right, sir.
11 So we determined, from reviewing the diagram
() 12 13 attached to the observation, that for the undersized welds on the diagonal, it's the upper connection that is 14 the more significant, and that's the subject of the 15 evaluation appearing at the calculation packet, Page 4?
16 A (WITNESS KOSTAL) Yes, sir.
17 Q All right.
18 Design weld size was 1/4 inch; the CSR weld 19 inspection establishes that it was 1/16 inch undersized 20 for the length of the weld?
21 A (WITNESS KOSTAL) Yes, sir.
22 0 That's the basis for the 3/16 weld size?
23 A (WITNESS KOSTAL) Yes, sir.
24 Q Now, what are the rest of the numbers that are included 25 in the capacity reduction calculation?
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14667 x
1 A (WITNESS KOSTAL) The next set of numbers relate to an 2 area calculation associated with an R value, and what 3 that is is the as-built area of the weld versus the 4 as-specified area of the weld. That ratio showed that ;
5 -the R value was equal to .69. Therefore, it was less 6 than our. criteria of .9, and it was categorized as a Z 7 discrepancy.
8 Then there is a continuation at the bottom of that 9 same page. It so states that the weld problem is more 10 critical at the top- of the connection on the brace and, 11 therefore, the weld undersize at A will be analyzed.
() 12 13 You go to the next page, which is Page 5, and it illustrates a vertical elevation of the tube steel and 14 the diagonal member and indicates in a cross -- in 15 another view the as-built weld, which is shown on the l 16 top right-hand side of the page --
17 0 All right, sir.
18 A (WITNESS KOSTAL) -- which shows the weld being 3/16 of 19 an inch and a length of 3-1/4; and there are two welds, 20 one on each side of that connection.
21 0 All right, sir.
22 Now, is the connection of the tube steel directly 23 to the Unistrut, the vertical Unistrut, or is there a 24 gusset plate?
) 25 A (WITNESS KOSTAL) There is a -- it's a -- it's a gusset Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14668 rx 1 plate. It's a -- it's a flat plate with two gusset 2 plates, of which then the Unistrut member is attached to 3 those two gusset plates, and that's shown in the Section j 4 D-D on Bates Stamp 4668.
5 If you look at that -- that's a cross section 6 looking down at that diagonal - you'll see a cross 7 section through the tube steel, which is the box. Then 8 you'll see a member immediately to the left of that box 9 -- tube steel, which is a plate.
10 Attached to that plate are two additional members 11 that frame out on a perpendicular direction across the 12 page. Then the Unistrut member is welded to those two
(
13 pieces of plate.
14 So there are, in essence, three different' sets of 15 welds included in this connection.
16 0 Page 5 of your calc package, then?
17 A (WITNESS KOSTAL) What -- 5 -- well, okay. The 18 information contained on 5 are the properties of this 19 particular weld, the as-built weld.
20 You need to- know the area of the weld in doing a 21 stress calculation. You also need to know the moment of 22 inertia, and you also need to know the section 23 properties.
24 First you calculate the moment of inertia, which is 25 the I value indicated.
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14669 em (Ji
'u l 0 Well, first you have the area, the A value?
2 A (WITNESS KOSTAL) First you calculate area so you know 3 what the area is.
4 0 That's the A value?
5 A (WITNESS KOSTAL) 1.218 inches there. That's the 6 quantity of weld that exists at this connection.
7 0 All right.
8 Next, the I value?
9 A (WITNESS KOSTAL) The next value is the I value, which 10 is the moment of inertia. It's in inches to the fourth.
11 Basically what you're doing is calculating I value
() 12 13 around two different axes -- one about the x axis and one about the y axis -- because you want to determine 14 the. stress as a result of load in two directions, 15 whether it exists in the x direction or the y direction.
16 So you have different properties depending on how 17 you apply load to the joint.
18 Section modules, which is S --
19 Q Slow down here a second, Mr. Kostal. Let us folk 20 engineers follow it.
21 Does the moment of inertia --
22 A (WITNESS KOSTAL) It's purely the property of whatever
- 23 configuration you want to create a moment of inertia 24 about. It's basically an area times a distance squared k 25 about some axis.
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i 14670 0
~1 Q What are the two axes?
2 Is one an axis that's vertical that represents 3 consideration _of sideward stresses?
4 A (WITNESS KOSTAL) In this particular example, the y )
5 axis'is the vertical axis, which is load that would act 6 down as if we were looking down at the floor.
7 0 As if you were pushing down on the brace in question?
8 A (WITNESS KOSTAL) That's correct.
l 9 Whereas the x axis can also -- what it would 10 represent in this case is the load that would'act along i
l 11' the perpendicular axis of this member.
( 12 -Q A sideways force on the brace?
13 A (WITNESS KOSTAL) A' sideways force.
l 14 Q All right, sir.
15 How is that calculated?
16 A (WITNESS KOSTAL) That, again, is calculated -- the 17 force?
18 Q The moment of inertia, the force.
19 A (WITNESS KOSTAL) The moment of inertia is calculated 20 by the~ numbers that are indicated here.
21 There is a weld length of 2-1/4 inches. Its width 22 is 1/16 of an inch. You take the distance to, in this 23 case, the y axis, which is 2, and you square that
- 24 distance.
25 There are two welds, and so the equation then would Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14671 1 read 2 times 3-1/4 times 3/16 times 2 squared. That 2 gives you the value of 4.875 inches to the fourth.
3 From there you need to now determine the section 4 properties -- I mean, not "section properties." l 5 You need to determine the section modulus. That is 6 defined as I over C, C being the distance from the axis 7 in question to the extreme point at which you want to 8 analyze the weld to. In this case, C is 2 inches.
9 0 Where is 2 inches in the actual configuration being 10 analyzed?
11 A (WITNESS KOSTAL) Yes, sir. This is the actual 12 as-built condition.
13 0 What is the point that you are analyzing that is 2 14 inches?
15 A (WITNESS KOSTAL) You are analyzing the weld joint.
16 You're analyzing the joint between the vertical member
'l
! 17 and this diagonal member, and there are two welds that 18 attach those two members together. You are' analyzing 19 those two welds.
20 (Indicating.)
I 21 Q All right, sir. Go ahead.
22 A (WITNESS KOSTAL) Okay.
23 You then determine the section modulus.
- 24. In this particular case, you determine the section 25 . modulus around the y axis. Since the distance of the Sonntag Reporting Service, Ltd. )'
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i 14672 l
1 weld from that y axis is 2 inches,_ it's just the moment l 2 of inertia, 4.875, divided by 2, which would then give 3 you section modulus.
4 In a like manner, you do that for the x axis.
5 Q You did it for the x axis, and then you' re doing it for 6 the y axis; correct?
7 A (WITNESS KOSTAL) We did it for the y axis, and then we 8 did it for the x axis.
9 Q Help me follow you here.
10 What's the value 1.072?
11 A (WITNESS KOSTAL) That's the motion of. inertia about 12
( the x-x axis.
13 Q All right.
4 14 You do x first, and then you go to y?
15 A (WITNESS KOSTAL) No. We did y first. Going from-the 16 top of the page down, the first value is Iyy then Ixx.
17 Q All right.
18 A (WITNESS KOSTAL) What you then find is from the 19 computer run, which -- now you have to go back to the 20 model, which is on Page 2 of the calculations.
21 If you look at Joint 6, which is the top joint of 22 the diagonal, for Member 36 -- because you want the 23 forces that are from Member 36, which is the diagonal 24 member, that are being transferred to the' vertical 25 member at the Joint 6 location.
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r 14673 U[h 1 0 Th'e circled number is the member?
2 A (WITNESS KOSTAL) Correct, and the --
3 0 -The uncircled number is the joint?
4 A (WITNESS KOSTAL) That's the joint.
5 0 Okay.
6 So what are you analyzing now for that member?
7 A (WITNESS KOSTAL) Well, what you -- at this particular 8 joint from this particular member, you go into the 9 computer run; and it will give you the forces that. exist 10 at that joint.
11 In this particular case, there are only two forces T 12 at that joint. There are no moments. So you'll find an 13 MA, and you'll find -- excuse me - an FA and an FB, 14 which are at the extreme left bottom of Page 5 of the 15 cales.
15 You will also see noted there is no FC. It's zero,-
17 and MA, MB and MC are zero.
18 0 What are those?
19 A (WITNESS KOSTAL) Those define moments.in various --
20 around various axes.
21 There are no moments about this particular axis.
22 0 Why not?
23 A (WITNESS KOSTAL) ~ Because the analysis assumes that 24 this is a pinned condition because it's a diagonal 25 member.
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1 Therefore, by the definition of " pinned condition,"
2 there is a certain amount of rotation which relieves the 3 moment. Therefore, the moment is zero.
4 0 It is a what condition; a pinned condition?
5 A (WITNESS KOSTAL) A pinned condition. It's just a ;
6 terminology to find the joint that's being analyzed in 7 the computer program.
8 Q P-I-N, pin?
9 A (WITNESS KOSTAL) P-I-N-N-E-D, pinned, versus fixed.
10 " Fixed" defines the fact that a connection can take 11 moment in a certain direction.
() 12 13 Depending upon the direction that you apply the fixi ty , " pinned" means that there is no capability to 14 take moment. It can only take shear loads and tension 15 loads.
16 0 Okay.
17 So you assume that those loads don't exist on this 18 member?
19 A (WITNESS KOSTAL) We assume that the joint is pinned.
- 20 Then what you do, based on this Page 2, is you 21 model the entire hanger, which is what this is. .It's an 22 elevation of a computer model, which provides you all 1
23 the members that went into the model and.all the joints
, 24 that are accounted for in the model.
k, 25 You include in that model'all the properties of l
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14675 1 these joints, meaning if it's fixed or if it's pinned.
2 You include the properties of the horizontal and 3 vertical members.
4 You also include at various node points, meaning.
5 joints -- you include the loads that are going to be 6 applied to this particular hanger.
7 Given that geometry, given all those loads applied, 8 you perform a stress analysis on this hanger.
9 The stress analysis -- what it basically does is.it 10 calculates the stress that exists in every member at 11 every joint and at every node point that you want it to.
C 12 It also gives you, then, the loads either in terms
( ;\
13 of FA, FB, FC or MA, MB, MC.
14 0 All right.
15 Your computer model depicts a hanger that is not of 16 the same configuration as the hanger --
17 A (WITNESS KOSTAL) Yes, it does.
18 Q -- found as built?
19 A (WITNESS KOSTAL) No. It depicts -- yes, it does. It 20 depicts the actual hanger that exists with all the 21 geometry of that hanger, all the' physical geometry.
22 What's not inputed into the computer model is the 23 discrepancy -- the discrepancies that were observed in 24 BCAP. This computer model is based on the assumption b)
(, 25 that all the joints are built correctly.
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v) l 1 All this computer model will give you is the 2 forces. You then take the forces, and you analyze the 3 given joints that have discrepancies for those forces to 4 determine whether or not those particular connections 5 can accommodate the loads that are applied to that 6 connection and sti11 stay within the allowable stress, 7 taking into account the discrepancies that were found.
8 0 All right, sir. Look at your computer model, Page 2; 9 and if you would, look at your sketch of the observed 10 condition of the hanger, Bates No. 4667 in Intervenors' 11 Exhibit 155.
12 Where are the members appearing on the computer (J) model identified as 37 and 38, shown on the as-built 13 14 diagram of the hanger?
15 A (WITNESS KOSTAL) Okay. 37 and 38 are the longitudinal 16 diagonal members, and those members are not shown 17 because this is -- well, they' re kind of partially 18 shown.
19 If you're looking at the vertical elevation of this 20 hanger and you look at that tube steel and you look 21 about, oh, almost halfway up, you'll see Section A and 22 Section B.
23 Do you see that on both sides.of that vertical 24 hanger?
k) 25 0 Yes.
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NJ' 1 A (WITNESS KOSTAL) Okay.
, 2 That Section A and Section B points to what is 3 illustrated as a portion of the longitudinal brace. You 4 only see a cutoff portion of it.
5 Q How many braces are there?
6 A (WITNESS KOSTAL) There's two longitudinal braces: one 7 on the east side and one on the west side.
8 .Where you'll see those -- if you'll turn to the 9 Bates Stamp Page 4668, you will see those two sections, 10 Section A at the top and Section B kind of in the middle 11 of the page on the right-hand side.
(
V) 12 Those define ' the gusset plates which attach the
' diagonal -- longitudinal diagonal member to the vertical 13 14 hanger.
15 0 All right.
16 Do you know whether the BCAP inspector evaluated 17 the attachment welds for those longitudinal braces?
18 A (WITNESS KOSTAL) Yes, sir, because he has indicated 19 discrepancies associated with those gusset plates.
i 20 That's what --
21 Q How about the attachment of the longitudinal braces to 22 whatever else they attached to the other end of the 23 braces?
24 A (WITNESS KOSTAL) The BCAP observation package was 25 drawn up on those connections where discrepancies were l
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14678 fx (v) 1 observed.
2 This entire package, including the welds attaching 3 the two vertical members to the steel above it as well 4 as the two diagonal members to the steel above, were 5 also included in this package for inspection.
6 There were no discrepancies on those welds.
7 0 There are none shown in the package?
8 A (WITNESS KOSTAL) That's correct.
9 Q. It's your understanding that those were the subject of 10 the CSR inspection?
11 A (WITNESS KOSTAL) Yes, sir. This entire package hanger 12 and all welds is part of that package 104.
(A}
13 Q So your evaluation assumes that the attachment welds of 14 the longitudinal braces were without defect?
15 A (WITNESS KOSTAL) That's correct, because no defects 16 were reported and they were part of the inspection.
17 0 All right, sir.
18 Now, what's the nature of the clouding that appears 19 on Page 5 of your calc for the evaluation of the " forces
! 20 from y"?
21 A (WITNESS KOSTAL) The clouding represents the later 22 computer run that was done as part of the run that was 23 performed on 8/30/85.
24 0 What changes were made to the -- what changes were l
( ) 25 caused in the result of that calculation of the later Sonntag Reporting Service, Ltd.
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1 run?
2 A (WITNESS KOSTAL) As a result of that calculation, the 3 forces applied to this particular joint decreased. They 4 decreased from.6,805 pounds in the FA direction to 3,662
, 5 pounds.
6 In the FB direction, they changed f rom 5 pounds to 7 2,847 pounds.
J 8 0 Tell me where Force B is.
9 A (WIT!!ESS KOSTAL) Force B acts in a vertical direction.
- 10 Force A acts in a horizontal direction as you're looking
^
11 at the DV 8 as-built conditions.
12 .So Force B would act downward along the y axis, and
(
13 Force A would act along the x axis.
, 14 Q Sideways, longitudinally along the x axis?
15 A (WITNESS KOSTAL) Well, in reality, it's not acting j 16 sideways; it's acting -- these are two components acting j 17 as -- if you're looking at the joint, one acts 18 vertically -- yes, it's sideways, but in the plane of 19 the hanger.
20 0 All right, sir.
21 Now, what accounts for -- and that's the B force, 22 the sideways force?
23 A (WITNESS KOSTAL) No. That's the A force.
24 0 The B force is the vertical force --
25 A (WITNESS KOSTAL) Yes, sir.
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b
~
1 0 -- on the diagonal member?
2 A (WITNESS KOSTAL) On the joint.
3 Q On the joint of the diagonal member?
4 A (WITNESS KOSTAL) Right.
5 Q All right.
6 What accounts for the calculational refinement that 7 changes that vertical force from a value of 5 pounds to 8 a value of 2,847 pounds?
9 A (WITNESS KOSTAL) The calculation -- I don't know 10 exactly why it changed f rom 5 to 2,847.
11 What I do know that occurred was in this particular
() 12 13 run, we used the Braidwood unique response spectra.
also used the cable pan weights that exist in the CIS-4 We 14 computer print-out, Cable Information System print-out,
, 15 of all loads applied to.this hanger configuration 16 condition.
17 That data was used for input into this particular 18 computer run, which then generated these given loads.
4 19 Q How about the force at A, horizontal force?
20 What changed the result through the refined 21 calculation from 6,805 pounds to 3,662?
22 A (WITNESS KOSTAL) The same analysis with the same i
23 definition I gave you.
24 Q Do you know in particular what assumptions or values 25 were changed to produce that result?
Sonntag Reporting Service, Ltd.
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.1 A (WITNESS KOSTAL) . Exactly what I said: The loads --
~
2 the actual cable pan weights for this particular hanger 3 were inputed into the computer model. Also,-the unique 4 .Braidwood response spectra was inputed into the computer I
5 model.
6 Given those unique loads, you perform an analysis 7 on the entire configuration, on the entire hanger.
8 Q Let me follow the changed inputs that appear on the two 9 lines with the clouds.
10 A (WITNESS KOSTAL) Sure.
11 Q " Forces from" -- I can't quite make it out; I guess it's 12 "1."-
13 .Is that "y"?
14 A (WITNESS KOSTAL) Are you on Page 6?
15 0 I'm still on Page 5.
16 Just above where the FA and FB values are and the 17 changes to those values, there's the line that reads 18 " forces from," and I can't make it out, whether it's a
]
19 "y" or "1."
' ~
20 A (WITNESS KOSTAL) It's " forces from 1," the Computer 21 Run ID S72BH2, which is a unique number that's used to 22 define this particular computer run, which was performed i
23 on 8/22/85 and .is documented in Calculation 12.2.78.2.0.
24 O All right.
25 A (WITNESS KOSTAL) That defines the source of where Sonntag Reporting Service, Ltd.
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1 these forces come from.
2 Q For the revised calculation?
3 A (WITNESS KOSTAL) For the revised calculation.
4- 0 All right.
5 Now, for the original calculation --
6 A (WITNESS KOSTAL) That's a computer run that's SPH002, 7 which was run on 6/1/85. That's where the source of 8 those forces come from.
9 Q Now, what does P-I-P-S-Y-S stand for?
10 A (WITNESS KOSTAL) .It's just a designation for a 11 computer run.
12 Well, I see a line-through and a cloud around that.
( O 13 A (WITNESS KOSTAL) Well -- I'm sorry.
14 Are you talking about " forces from 2"?
15 Q No; " forces from 1." Then there appears to be 16 P-I-P-S-Y-S lined through and clouded as well.
17 A (WITNESS KOSTAL) P-I-P -- oh , that's PIPSYS. That's 18 just the name of the program. It's a PIPSYS program.
19 That's an acronym for a type of program that's used for 20 this analysis.
21 It's nothing -- what PIPSYS is is it's a program 22 that allows you to perform this type of analysis. It l
23 takes into account this particular geometry. It l
l 24 accounts for all the loads. It performs a stress
) 25 analysis and defines then the stresses and forces that l Sonntag Reporting Service, Ltd.
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1 exist in the subject. analysis.
2 0 Well, did you use it or didn't you use it?
3 Is it meant to be deleted or included here with the 4 revised calculation?
5 A (WITNESS KOSTAL) It's - .it's just deleted.
6 0 It's deleted?
7 A (WITNESS KOSTAL) Yes, sir.
8 Q All right.
9 'The " forces from 2," the second line there -- is 10 that clouded and also deleted?
11 A (WITNESS KOSTAL) Right, yes, sir.
\ " Member check run, ID," et cetera -- what does that
[G 12 O 13 reference?
14 A (WITNESS KOSTAL) That represents the same run. That 15 just defines the member properties, the member check, 16 meaning the members -- see, originally -- when you 17 develop -- this program has all the different member 18 sizes and configurations that can be used to select the 19 members, okay.
20 What basically occurs is we input all the units 21 throughout the geometries. We input all the different 22 type of Unistruts that we can use.
23 The program automatically assesses, for a certain 24 member at a certain stress, whether or not it will
) 25 select. The program will select the member that most Sonntag Reporting Service, Ltd.
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1 economically can be used to carry the loads that are 2 generated in a given member. So it's-an automatic 3 selection process.
4 Now, in this particular case,.we already had the 5 members. So in this particular case, we went back and 6 just inputed just the actual members so we didn't need 7 this member check run.
8 0 Okay.
9 At Node Point 6, Member 36 again -- that's the 10 connection and the member in question?
11 A (WITNESS KOSTAL) Yes, sir.
12 0 The next page, Page 6, please.
(
13 What's the equation at the top of Page 6?
14 A (WITNESS KOSTAL) What the equation there is it's an 15 equation determining the resultant stress.
16 It determines the resultant stress by looking at l 17 the force FA, which is'the first portion of the 18 equation, divided by the area. That will give you the 19 stress in the -- let's say, the horizontal direction.
20 The next portion of the equation is the stress in 21 the vertical direction, the 2.847 divided by again the 22 area 1.218.
23 And what you're basic -- what's being done is you 24 -- it's a vector analysis. You get a force in each O
() 25 direction. You square those two forces. You get the Sonntag Reporting Service, Ltd.
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14685 s i C-) l 1 square root of that, and that gets you your resultant 2 force vector.
3 0 Where is the square root shown?
4 A (WITNESS KOSTAL) On the right-hand side of the 5 equation. If you look, there's a double brackets and 6 there's a "1/2" sign.
7 0 Yes?
8 A (WITNESS KOSTAL) That's just a way to designate square 9- root.
10 0 All right.
11 A (WITNESS KOSTAL) The result of that is a stress,
[ 12 resultant stress.
O) You then 13 Originally the stress level was 5.587.
14 compare that stress to the allowable stress, which is 15 the interaction coefficient, which is ICAB. That's.
16 5.587 divided by -- in this old example, it was 14.4 and 17 gave the interaction coefficient of 3.87.
18 That says that that particular joint originally 19 designed was only stressed to 38 percent of its 20 allowable.
21 JUDGE COLE: You mean the interaction of 22 .3 87?
23 You said "3.87."
s 24 WITNESS KOSTAL: Oh, I'm sorry. .3 87, yes, 25 sir.
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U 1 A (WITNESS KOSTAL) (Continuing.) Therefore, that 2 connection was within allowable.
3 The calculation showed that the resultant stress is 4 3.808 kips per square inch. If you go in the clouded 5 area, divided by 19.75, it shows an interaction 6 coefficient at that location of 0.193.
'7 So as a result, that joint now -- or that 8 particular weld is only stressed to 19.3 percent of its 9 allowable.
10 The 19.7' is the allowable for base metal shear, 11 which is in the cloud just above it, which-is 0.95' times
() 12 13 36, divided 'by the square root of 3, equal to 19.75 kips per square inch.
14 That defines what it says just below. It is base 15 metal shear controls. This is an analysis based on a
. 16 seismic run, which includes the safe-shutdown 17 earthquake.
18 In the safe-shutdown earthquake, your allowable is 19 equal to .95 of the yield stress. That's equal to 19.7 5 20 kips per yield strength.
21 BY MR. GUILD: 1 22 0 Yield strength of A36 steel?
! 23 A (WITNESS KOSTAL) That's A36 steel. This plate is made 24 of A36 steel.
l l ( 25 0 So the base metal yield strength controls for this Sonntag Reporting Service, Ltd.
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,g l' particular defect?
2 A (WITNESS KOSTAL) It controls for this particular 3 defect.
4 The next line below that is. the design margin, 5 which is the reciprocal of the interaction coefficient.
6 Initially in the original calc,'the~ design margin 7 was 2.57. If you recall, the design margin that we 8 require is equal to 1. So that means we're at least two 9 and a half times what we need to be.
10 In the revised calculation, the design margin is 11 5.18, which is again the reciprocal of the interaction
() 12 13 0 coefficient.
All right, sir.
1.4 What appears on the rest-of the page, Page 6?
15 A (WITNESS KOSTAL) Okay.
i 16 Now, what we've done for the rest of the page is 17 done a similar' calculation on what would have been the 18 original as designed. The reason for doing this is to 19 determine what the actual R value is.
20 In this particular example, in this particular 21 calculation, if you look further down the page, you'll 22 notice that the interaction -- the R value is -- from
, 23 the original calc, it was .9 - .697, and in the revised 24 calc, it's .6 95.
25 Obviously, it's still less than .9. It's still a Z !
- Sonntag Reporting Service, Ltd. l Geneva, Illinois 60134 (312) 232-0262 _ _ _ . - ___.
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1 discrepancy.
2 That compares with the rough, quick assessment of R 3 value that was found on Page 4, which was purely an area 4 comparison, of .69; literally, the same value. It's 5 just another way of doing it.
6 0 All right, sir.
7 And design margin is shown both on the original and 8 revised version at the bottom of that page, DM7 9 A (WITNESS KOSTAL) That's correct.
10 The design margin at.the original was 2.57, and the 11 revised design margin with the new cale is 5.18.
~ 12 0 All right, sir.
13 Now, let's turn to Page 7, please.
14 A (WITNESS KOSTAL) Yes, sir.
15 0 What is the nature -- what's the defect that's being 16 evaluated beginning on Page 77 17 A (WITNESS KOSTAL) We're still at the -- in this 18 particular calculation, this is the weld size at
! .19 Location H, which is the bottom of -- if you go back to j
20 Page 3, it's the diagonal member again. It's the 21 diagonal member where it's a weld undersize.
22 That is.shown by the arrow with the circled H.
23 It's actually shown twice with an H: once above the i
! 24 diagonal and once below the diagonal.
25 Q All right, sir.
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~ 146 89 x,s' 4 1- Now, that's at the bottom of the diagonal brace --
2 A (WITNESS KOSTAL) That's correct.
3 0 -- the diagonal member?
4 A (WITNESS KOSTAL) But it's at a different weld. It's 5 not the same weld. It's the weld attaching the two 6 gusset plates to the horizontal plate. It's not the 7 horizontal plate attaching to the vertical member.
8 0 All right, sir.
9 A (WITNESS KOSTAL) That's another location for where we 10 do an analysis.
i 11 Q All right.
I rs ,
12 Now, is there a detailed depiction of this
}
13 particular connection?
14 That's the H shown.
15 A (WITNESS KOSTAL) Yes.
16 On Page 7 it points to the weld in question. On 17 Page 7 you'll notice that it shows a 3/16 weld, an inch 18 and a half, which is the as-built condition. The issue 19 here is one of fit-up gap.
20 If you go to the Bates Stamp weld map 4667 and if 21 you look at that diagonal member at the bottom of the 22 diagonal, at the very bottom of that, you'll see fit-up
-23 gap,1/8 of an inch. It's kind of over to the 24 right-hand side next to that weld note.
25 0 Yes.
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1 A (WITNESS KOSTAL) Okay.
2 What that says is that the gusset plates, 3 perpendicular gusset plates, attached to that other 4 plate was slightly cocked, meaning at the bottom it was 5 -- there was a gap of 1/8 of an inch, and at the top it 6 was snug.
7 0 Okay.
8 What significance does that 1/8 inch fit-up gap 9 have for the weld size requirement?
10 A (WITNESS KOSTAL) Since the weld size -- the 11 requirement is when you have a fit-up gap, you have to
() 12 13 increase the weld to compensate for the fit-up gap.
In this particular case, there was no noted 14 increase of a weld increase. So we assumed that the 15 weld would still remain as we specified, which was 3/16.
16 Therefore, we assumed that we effectively lost at 17 the bottom of this weld 1/8 of an inch, so that the weld 18 now is only 1/16 at the bottom and 3/16 at the top.
19 0 Was there any further evaluation of the actual as-built 20 condition of this weld, as-built- dimensions of this 21 weld, beyond the reliance on the diagram that appears 22 attached to the observation?
23 A (WITNESS KOSTAL) Well, it says -- in the note right s
24 over on the side, it says " weld size was not increased 25 for fit-up gap both sides."
Sonntag Reporting Service, Ltd.
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,s
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- 14691 l' So using that note and using the gap, that defined 2 the as-built conditions of that weld. We analyzed for
. 3 that as-built condition.
- . ~4 0 All right, sir.
5 ,. But you say that you assumed that the weld was of a 6 certain dimension, and that assumption was based on this 7 diagram?
8 A (WITNESS KOSTAL) This note, yes, sir.
9 0 Bates No. 4667, prepared in accompaniment with the 10 observation record?
11 A- (WITNESS KOSTAL) That's correct.
12 0 'All right, sir.
13 Aw~ (WITNESS KOSTAL) So given that discrepancy, the first 14 thing we looked at is an as-built area of weld versus l
15 as-designed area of weld for an R value calculation. In i
16 this particular case, the R value was .66; again, less
- 17 than .9, a Category Z discrepancy.
18 Then we go on to evaluate this particular -- with l 19 the remainder of Page 7 and Page 8, as well as a portion 20 of Page 9 -- Page 8, to Page 8. We perform exactly the
, 21 same - type of analysis we just did on the other joint.
22 We determine area. We determine section i
23 properties. We determine moment of inertias. We then-24 apply the same type of equation, which is found on Page 25 8 in kind of the middle of the page, which again is Sonntag Reporting Service, Ltd.
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1 determining the resultant weld stress. There again you 2 look at the loads versus the areas.
3 In that case the initial stress level was 18.3 --
4 18.13 kips per square inch. The allowable is 19.75.
5 The interaction coefficient in the next line is 18.13 6 divided by 19.75, equal to .918, which is less than 1.
7 The revised calculation goes through that same set 8 of calculations'and shows that the revised interaction 9 coefficient is-0.626.
10 0 All right.
11 The original design margin, as calculated for this
() 12 13 A particular joint, would be 1.09?
(WITNESS KOSTAL) Correct, which is still greater than 14 1, which is okay. It's -- we have a margin above the 15 code allowable; and in the revised case, it's 1.60.
16 0 Now, what was the basis for the refinement of this 17 calculation to increase the design margin from 9 percent 18' to 16 percent?
19 A (WITNESS KOSTAL) The br614 is the previous answer I 20 gave, which is the cym e.er run, which includes the 21 actual weights of the cable pan hangers on this -- the 22 cable pans on this hanger as well as the unique 23 Braidwood response spectra.
g,s 24- JUDGE GROSSMAN: Excuse me.
(_ 25 If your design margin had come to, let's say, 0.98, Sonntag Reporting Service, Ltd.
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b 4 1 - would that have meant that the entire item, then, would 2 be considered design-significant?
3 WITNESS KOSTAL: This particular observation 4 package, this particular connection, would have been 5 considered design-significant, yes, sir, because it 6 would have violated our definition of design 7 significance, which is a design margin less than the 8 code allowable.
9 That has nothing to do with whether or not the 10 member would be still able to carry that load. It's 11 just its relationship with the code allowable.
12 JUDGE GROSSMAN: Now, another question: The
(
13 response spectra that you keep referring to -- they are 14 with regard to seismic stresses; is that it?
15 WITNESS KOSTAL: Yes, sir.
16 Response spectra ' are developed for every elevation 17 in the plant. They're developed through a program, and 18 they give you -- there's a different spectra at each 19 ficor elevation. That becomes the input motion for 20 items that are attached at that particular floor 21 elevation. That's a whole series of calculations which 22 were originally prepared to define the response 23 spectras.
24 These response spectras are used by not only ,
25 Sargent & Lundy in doing all our calculations, but Sonntag Reporting Service, Ltd.
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1 they're used by vendors in performing their calculations 2 to qualify their equipment when they are located in a 3 certain elevation within the plant.
4 JUDGE GROSSMAN: Were these design spectra 5 that you used for these calculations previously 6 calculated or did you only calculate them with respect 7 to these particular calculations?
8 WITNESS KOSTAL: The design spectras that 1
9- were used were calculated years ago. They have not been 10 changed.
11 They were calculated at the.beginning of the
.12 I'm -- I don't know the exact date, but they
( project.
13 were at the early stages of the project.
14 They were included in the specifications that were 15 issued for bid in the early stages of the project, 16 meaning in the '70s,1970 time frame, '75 through, let's 17 say, '77, which is the early phases of this project.
18 JUDGE GROSSMAN: Were they based on the REG 19 GUIDE guidelines?
20 WITNESS KOSTAL: Yes, sir.
21 BY MR. GUILD:
22 Q For this particular defect -- that is, the increased 23 weld size for the observed fit-up gap -- you 24 recalculated the capacity reduction f actor?
p_s k,,f 25 Again, at the bottom of Page 8.
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1 A (WITNESS KOSTAL) Yes, sir.
2 In the original one, if you recall, it was .66 on 3 Page 7. In the revised, it's .67, rather than .66.
4 That's at the bottom of Page 8, is the revised R value 5 calc.
6 0 Still less than .9; it's still requiring a detailed 7 calculation?
8 A (WITNESS KOSTAL) Yes, sir.
Now, let me ask you this more generally:
9 Q 10 If you hrd recalculated the R value based on the 11 more detailed evaluation and had determined that the R.
) 12 value was now greater than .90, would you have
(/
13 eliminated the detailed design margin calculation?
14 A (WITNESS KOSTAL) No. The design margin calculation 15 would always exist. We would not void the calculation 16 that was prepared.
17 0 would you reclassify the item?
18 A (WITNESS KOSTAL) We would reclassify the item as being 19 a Y category.
20 0 All right, sir.
21 A (WITNESS KOSTAL) But we would still have the 22 calculation that was performed to reclassify it as a Y 23 category.
l 24 0 All right, sir. You provided me in discovery with a
) 25 listing of the calculated values for notable l
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l' discrepancies, the design margin values.
2 Now, were any of the capacity reduction values for 3 those items recalculated,~ causing those items to be 4 recharacterized from " notable" to " insignificant"?
5 A (WITNESS KOSTAL) Are you referring to the lists that 6 were provided to you on the.four populations that 7 defined my lowest design margin and average design 8 margins in my testimony?
9 0 Well, let me ask the question -- I am, but-let me ask 10 the question a little differently. I thinkfI probably 11 misstated my question.
12 What I mean to say is: As a result of having done 13 more-refined R value calculations for observations that 14 were initially determined to be subject to detailed 15 calculation because they originally were determined to 16 be of an R value of .90 or lower, were any refined i
i 17 calculations made resulting in the reclassification of 18 any observations?
- 19- A (WITNESS KOSTAL) I wouldn't characterize them as l 20 " refined calculations." They were calculations made on 21 the discrepancies noted.
! 22 If, as a result of those calculr.tions, a more l 23 accurate R value was determined and if that R value was
! :24 greater 'than .9, we would have reclassified that as a Y l 25 discrepancy.
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U 1 Q As an insignificant discrepancy?
2 A_ (WITNESS KOSTAL) We characterized Y discrepancies and 3 X discrepancies in the category of " insignificant."
4 0 Yes.
5 And in how many instances did that reclassification 6 take place --
7 A (WITNESS KOSTAL) I don't.--
8 Q- -- in the electrical population?
9 A (WITNESS KOSTAL) I don't know._
10 Q 'Did it take place in any instances?
11 A (WITNESS KOSTAL) .I don't know.
[J 12 13 I would -- I'm saying: If we did this particular calculation and if the value -- and if the exact value 14 of R did exceed .9 after we did an exact value of R, we 15 would have reclassified it.
16 Did we do that? I don't know.
17 Q All right, sir.
18 Now,.is this particular connection, the defect 19 involved in the fit-up gap -- is this the bounding 20 defect for this particular hanger?
21 A (WITNESS KOSTAL). There is another calculation a little 22 further along that -- I just can't remember if it's the 23 bounding or not the bounding.
24 Initially if you turn to Page 15, there was in the
. y ,j 25 original calculation at the very bottom of the page --
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1 this has to do with the calculation of a -- the 2 longitudinal gusset plate.
3 The original calculation at the bottom of Page 15 4 -- the design margin for this particular discrepancy had 5 a 1.03. The revised design margin with the -- was 1.89.
6 So in the first analysis, this discrepancy on Page 7 15 would have been the controllable connection; whereas 8 in the revised calculation, the controllable connection 9 is, in fact ~, the calculation that we were ' talking about 10 on Page 8.
11 Q Yes.
() 12 13 Let's talk about the second calculation, then, the second defect, the defect that in its original -- in the 14 original calculation, represented ~the bounding case of a l
l 15 3-percent design margin.
16 Now, does that calculation begin on Page 13, " weld l
l 17 undersize in Section B-B"?
j 18 A (WITNESS KOSTAL) It's defined on Page 13, and then it l
19 proceeds through 14 and through Page 15.
l 20 Q Let's start at Page 13, Mr. Kostal.
j 21 Now, is this indeed one of the longitudinal braces, i 22 a connection for a longitudinal brace?
23 A (WITNESS KOSTAL) Yes, sir.
24 Q Now, where does this brace go, the brace that's l 25 connected at this gusset point?
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14699 1 A (WITNESS KOSTAL) It goes to the next -- it's a diagonal 2 brace attaching kind of at about the lower portion of 3 this vertical hanger assembly, and it diagonally goes up 4 to the next floor elevation and attaches to structural 5 steel at the next floor elevation.
6 Q All right, sir.
7 And the nature of the defect is in the connection 8 between the gusset plate and the vertical member?
9 A (WITNESS KOSTAL) That's correct.
10 0 All right.
11 Now, who did the welding of the gusset plates to
() 12 13 A the vertical members for these longitudinal braces?
.(WITNESS KOSTAL) It could have been one of two people:
14 It could have either been Systems Control or it could 15 have been L. K. Comstock. I don't know who did this 16 particular weld.
17 Q Both Comstock and Systems Control installed the gusset 18 plates for the longitudinal members on these hangers?
19 A (WITNESS KOSTAL) There are longitudinal -- there are' 20 vertical -- these gusset plates are attached to the 21 vertical member. >
! 22 0 Yes.
23 A (WITNESS KOSTAL) Okay.
t 24. The vertical members were supplied, in some I 25 instances, by Systems Control; in other instances, by l
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() 1 1 Comstock.
- ~2 0 Yes, sir.
3 A (WITNESS KOSTAL) So it could have been either one who 4 made this particular weld.
5 0 'Did Systems Control supply vertical members with gusset
- 6 plates already installed for the purposes of attaching 4
7 longitudinal members -- longitudinal braces?
4 8 A (WITNESS KOSTAL) Yes, sir, yes.
9 0 All right.
! 10 .Now, what's the nature of the defect --
11 A (WITNESS KOSTAL) The nature of this defect --
l
( 12 0 -- appearing on Page 13?
13 A (WITNESS KOSTAL) -- is relating to again undersized 14 welds.
15 This connection detail originally required the weld 16 to be a -- just let me make sure -- 3/16 fillet weld on 17 either side of the gusset plate, and the observation i
18 reports that the gusset plate on the front side is 19 undersized by 1/16.
20 So, therefore, there is only a 1/8 inch weld. On 21 the backside, the undersize is 1/8 of an inch. So that-22 would mean there would only be 1/16 of an inch weld 23 remaining.
. 24 0 All right, sir. Now, help me understand this.
25 I see the diagram at the bottom of Page 13: "1/16 1
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1 undersize NS."
2 A (WITNESS KOSTAL) "NS" is near side. "FS" means far 3 side.
4 Q All right.
5 There's a note that appears to the right of that 6 diagram: "For plate on left' side of Section B-B, no 7 bracing is attached. U. S. weld will not cause
'8 structural deficiency. R equals 1, Category X. "
9 A (WITNESS KOSTAL) Yes, sir.
10 Q You didn't need the weld.on the left side?
11 A (WITNESS KOSTAL) Right.
() 12 13 0 All right.
Now, how would the calculation for this particular 14 defect have changed?
15 How would the R value and the design margin for 16 this defect have changed if the weld that was undersized 17 by 1/8 inch just happened to be on the near side of the 18 hanger, as opposed to the far side?
. 19 In other words, if the side which was critical that 20 was the weld where the -- on the side of the gusset 21 plate to which the longitudinal member ~was attached, if 22 it happened to be 1/8 inch undersized, as opposed to 23 1/16?
24 A (WITNESS KOSTAL) And there were no other 25 discrepancies?
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As- l 1 What's your hypothesis?
2 Q- What would be the effect on this calculation, the 3 evaluation of this discrepancy, if it was a 1/8 inch 4 undersized as opposed to a 1/16?
5 A (WITNESS KOSTAL) It would show a higher stress in the 6 connection.
7 0 What would be the effect on the calculation of capacity 8 reduction for this particular joint?
9 A (WITNESS KOSTAL) Since we do a capacity reduction 10 based on area, it would show an even lower R value.
11 Q Would it cut the area in half?
() 12 13 A (WITNESS KOSTAL) I'd have to do the actual calc, but it would certainly make it less than the .52 that's 14 indicated on Page 14, which was the R value calculation 15 performed on the area of as-built weld versus the area 16 of as-designed weld.
17 Given we would have less as-built weld, it would 18 make the R value even smaller.
19 Q And what would it do, if there was a 1/8 undersized weld 20 at the critical connection, to the calculation of the 21 design margin?
22 A (WITNESS KOSTAL) In this particular example, we would l
23 have to run through this entire calc. What it would 24 show is that our interaction value would -- would j y ,) 25 change. It would go up.
l I
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-(v n) 1 Instead of being -- if you turn to Page 15 and if 2 you look at the third f rom last line, interaction 3 coefficient AB, in the cloud the interaction coefficient 4 is O'.528.
5 If we had a slightly smaller weld like you are 6 defining, that interaction coefficient would become 7 larger.
8 Q Do you know how much larger?
9 A (WITNESS KOSTAL) I'd have to do the calc.
10 0 can you estimate, based on your engineering judgment, 11 what effect the 1/8 inch undersized weld would have on 12 the design margin calculations?
(
13 A (WITNESS KOSTAL) I don't know what the number -- it 14 would be somewhere between -- it would be greater than 15 0.528.
16 0 You just don't know how much greater?
17 A (WITNESS KOSTAL) That's correct.
18 Q Do you think it's, as a matter of probabilities, Mr.
19 Kostal, improbable -- as we' re using the term 20 " probabilities" -- for purposes of drawing inferences 21 about the population of electrical components in the 22 field?
23 Is it improbable that that 1/8 inch undersized weld i
24 might have occurred on the critical side of the gusset 25 plate connection to the vertical member, as opposed to, I
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1 as in this particular case, that undersized weld at the 2 critical connection being only 1/16 inch?
3 A (WITNESS KOSTAL) We didn't find it.
4 0 But that's not my question.
5 My question is --
6 A (WITNESS ' KOSTAL) I can't answer that question.
7 0 Why not?
8 A (WITNESS KOSTAL) Since we didn't have it, I don't know 9 what-the probability is if it could possibly occur.
10 Q Do you think it could probably have occurred?
11 A (WITNESS KOSTAL) We didn't ever observe it.
.12 0 That's not really the question.
13 My question is: Do you, as an engineer who is 14 expressing engineering judgment, viewing the 15 discrepancies we see here -- do you think it's 16 improbable that the 1/8 inch undersized weld might have 17 occurred on the right side of the vertical on the 18 critical connection with the gusset plate, as opposed to 19 the left side, the insignificant, noncritical 20 connection?
21 A (WITNESS KOSTAL) Well, it did occur on the critical I
22 side.
23 The undersize of the 1/16 of an inch and the 24 undersize of 1/8 inch did occur on the same side.
l O
(,,) 25 That's what we're evaluating.
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- O 1- 0 One is on the near side, and one is on the far side?
2 A (WITNESS KOSTAL) The far side is the front undersize, 3 -and there is another discrepancy associated with the 4 same weld which is on the backside.
5 0 If you reversed the near side for the far side and, 6 instead of occurring where it occurred apparently from t
7' this diagram, the 1/8 inch undersize occurred on the 8 side to which the longitudinal member is attached, my
, 9 question to you, sir, is: As an engineer, is.that an 10 improbable occurrence, in your opinion?
l 11 A (WITNESS KOSTAL) I just don't quite understand your 12 question.
13 Since there was an undersize of an 1/8 inch on the l 14 gusset plate in question and there is also an undersize 15 of 1/16 of an inch on the gusset plate in question --
i 16 0 Am I just not speaking.English to you?
! 17 A (WITNESS KOSTAL) I understand --
18 0 I'm telling,you to put that 1/8 inch undersize weld in 19 the area where.you evaluated a 1/16 undersize weld.
20 Is it improbable that that 1/8 inch undersize could 21 have occurred --
- 22 A (WITNESS KOSTAL) If you're asking me if it's
~
23 improbable that no weld was at the gusset plate, I think 24 that's improbable.
( 25 0 1/8 inch undersize?
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1 A (WITNESS KOSTAL) You're basically asking me if I only 2 have 1/16 inch weld on both sides of the gusset plate.
3 MR..STEPTOE: Judge Grossman, I think the 4 witness and the questioner are not communicating. I-5 think Mr. Guild is misreading something, and I --
6 JUDGE-GROSSMAN: That's not my understanding 7 of what's happening, Mr. Steptoe.
8 MR. STEPTOE: All right.
9 BY MR. GUILD:
10 0 You' re looking at the same diagram I am, Mr. Kostal.
11 How about Page 13, the bottom?
() 12 13 Under the heading " weld undersize in Section B-B,"
you determine there's no need to make any calculation 14 for the lef t undersized weld, that which is indicated to 15 be 1/8 inch . undersize, far side, "FS"; correct? No need 16 to make that calculation?
17 A (WITNESS KOSTAL) Yes, sir.
18 0 Why? Because no bracing is attached, as the note 19 states. " Undersize weld will not cause structural 20 deficiency."
21 A (WITNESS KOSTAL) Yes, sir.
22 0 But you do evaluate the near side undersize weld, which 23 is 1/16 inch undersize?
24 A (WITNESS KOSTAL) That's correct.
25 Q Now, my question to you, sir, is: Assume that those --
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1 the locations of the respective undersize welds are 2 reversed and that the 1/8 inch undersize weld occurs 3 where it is significant, where you have evaluated it.
4 I ask you, sir, as an engineer:' Is it improbable 5 that the 1/8 inch undersize weld would have occurred on 6 the side where the longitudinal brace is connected?
7 A (WITNESS KOSTAL) What I'd like to clarify, if we go 8 back to the weld map, which is the Bates Stamp 4668, 9 which is Section B, there are --
10 Q B as in " boy," sir?
'll A (WITNESS KOSTAL) B as in " boy."
12 All right.
( Q 13 A (WITNESS KOSTAL) If you read the note, it says " front 14 side 1/16 inch undersized two plates" - "two places."
15 It also says "back side 1/8 inch undersize two places."
16 What that's telling me is that when I'm looking at 17 the gusset plate, which is attached to support the 18 diagonal member, that gusset plate has two welds. It 19 has a weld as you're looking at this picture, and it has 20 a weld in the back of the picture.
21 (Indicating.)
22 The front side of that weld is undersized 1/16. .
23 The back side is undersized 1/8, which is the example 24 you' re trying to give and the example that's used in the y 25 analysis in this calculation.
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1 Q Assume that they're both 1/8.
2 Is that improbable?
3 I'm simply asking you to move the discrepant 4 condition, Mr. Kostal, a matter of inches from one side 5 of the vertical to the other side.
6 I'm asking you, sir, as an engineer: For purposes 7 of evaluating the BCAP results, is it improbable that 8 the 1/8 inch could f all on the opposite side of the 9 vertical member, regardless of what's on the back side?
10 I'm looking at the diagram that appears at the 11 bottom of Page 13, which is the subject of your
() 12 13 A engineering evaluation.
(WITNESS KOSTAL) Nothing is improbable, nothing is 14 improbable. Anything could occur.
15 Whether or not anything did occur is really the 16 question.
17 In the inspections that were made by BCAP of all of 18 the welds that were made, we didn't have this improbable 19 condition occur.
20 0 Sir, that's not my question.
21 A (WITNESS KOSTAL) It didn't occur, so, therefore --
22 0 My question, sir, is: You looked at a sample of 23 hangers.
24 A (WITNESS KOSTAL) That's correct.
) 25 0 The whole exercise in DCAP is not to simply evaluate Sonntag Reporting Service, Ltd.
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v 1 what you looked at; it's to ask these judges to draw 2 inferences about what you looked at, and that's the rest 3 of the population of cable pan hangers or whatever 4 particular piece of electrical installation we're 5 talking about, sir.
6 A (WITNESS KOSTAL) Yes.
7 Q As a matter of probability, you make the assertions that 8 there are no other defects out there that need be 9 considered. You draw inferences to the whole 10 population.
11 My question to you, sir, is probing the soundness
[d h 12 13 of those inferences, and it asks a very simple question that even a folk engineer can follow.
14 That is, is it improbable that the 1/8 inch weld 15 fell on the opposite side of the vertical member?
16 A (WITNESS KOSTAL) As well as the 1/8 inch falling on 17 the front side?
18 0 Make that permutation the basis of the question if you 19 liker either way you want to consider it, sir.
20 The particular situation that you evaluated on Page 21 13 and the following pages -- reverse the incidence of 22 the discrepancy. Make the 1/8 inch fall where the 1/16 23 fell.
s 24 Could you say it's improbable?
- \ ,) 25 A (WITNESS KOSTAL) It could occur.
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V 1 Q' You didn't evaluate that' condition?
2 A '(WITNESS KOSTAL) I didn't have it to evaluate it.
3 Q And you didn't evaluate it?
4 A (WITNESS KOSTAL) No, sir.
5 JUDGE GROSSMAN: Excuse me.
6 Without going through detailed calculations, could 7 you tell me why, with your recalculation here of the 8 design margins and the R values, that there was such a 9 difference in the design margin but the R values stayed 10 basically the same?
11 WITNESS KOSTAL: Well, the R value is -- is, 12 again, the as-designed quantity of weld versus the v
13 as-built quantity of the weld.
14 That is really independent of the design margins.
15 The design margins are a function of the loads and 16 stresses that exist within the member.
17 JUDGE GROSSMAN: I see, okay.
18 So your using the design spectra to recalculate 19 only affected the design margin; is that right?
20 Your as-built and as-designed elements in your R 21 calculation weren't calculated by using response 22 spectra, were they?
23 WITNESS KOSTAL: Yes, they were.
24 JUDGE GROSSMAN: Oh, they were?
25 WITNESS KOSTAL: That's the section portion Sonntag Reporting Service, Ltd.
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a 1 of the -- in this example, the original R value on Page 2 14 -- the R value purely based on an area comparison was 3 -- this is on about the fourth line on Page 14, kind of 4 in the middle of the page -- R is equal to 1.219 divided 5 by 2.343. There the R value is .5'A.
6 In the -- let's say the R value, as it relates to a 7 stress comparicon -- the value changed to -- this would 8 be found in the clouded area, which is on Page 15, the 9 second from last line. That more exacting -- a 10 different way of doing it came up with the same exact R 11 value. It came out to be .52 again.
So we can use either method, either a quick area
( 12 13 comparison or we can use a stress comparison, to 14 determine an R value.
15 JUDGE GROSSMAN: Okay. I thought there was l 16 just one element that you could isolate that you took 17 into account in your reconstructed design margin that 18 wasn't taken into account in the R value.
19 I thought it might have been the response spectra, 20 but it was not.
21 BY MR. GUILD:
22 0 Mr. Kostal, let's look at Page 14 now.
23 JUDGE GROSSMAN: Excuse me. Wait. There may 24 be an answer.
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1 is that in the R value, which is a function of 2 interaction coefficients, which is found on Page 15, 3 there were two R value calcs made: one with the 4 original computer run, and that value was equal to .538.
5 There was another one, which was the second run, 6 which included the seismic run, and that value then 7 reduced it down to 0.52.
8 That compares exactly to the original R value area 9 calculation.
10 JUDGE GROSSMAN: I understand that, and 11 that's what led me to the observation that there was
( 12 very little change in the R value --
13 WITNESS KOSTAL: That's correct.
14 JUDGE GROSSMAN: -- but a great change in the 15 design margin.
16 WITNESS KOSTAL: That's correct.
17 JUDGE GROSSMAN: I thought it was just one 18 element that wasn't taken into account -- one element of 19 change in the design margin calculation that was not 20 taken into account in the R calculation.
21 But perhaps that's not the case, and I'll just have 22 to go back over the detailed answers that you gave in 23 response to Mr. Guild's questions to see if there is 24 some one element that could be isolated in the design 25 margin calculation that isn't an element of change in Sonntag Reporting Service, Ltd.
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I the R calculation.
2 MR. GUILD: Mr. Chairman, while the point is 3 fresh, what I intended to do during the balance of the 4 ' afternoon was identify the critical changes that have 5 been made in this calculation.
6 On that basis I request of the Chairman that 7 Applicant provide whatever basis there is for the 8 changed calculations, refined calculations, revised 9 calculations, however you want to characterize them.
10 Let me make that request at this time.
11 With respect to this particular example, Cable Pan
() 12 13 Hanger 104 and the engineering calculations, I would request that Applicant supply whatever basis there was 14 for making the revised calculations, including any 15 changes in assumptions and the methodology that was made 16 from the initial calculations that show a lower design 17 margin to the revised calculations showing a higher 18 design margin.
19 JUDGE CALLIHAN: While we're on Page 14, Mr.
20 Kostal, albeit perhaps only an exercise, would you 21 identify the various loadings, upper case F and upper 22 case V and so forth?
23 WITNESS KOSTAL: The loadings are at the 24 bottom of the page. They ' re in the cloud.
( 25 The loadings are Fx equal to zero, Fy equal to Sonntag Reporting Service, Ltd.
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1 12.22 kips, Fz equal to 3.493 kips.
2 The moments Mz, My and Mx are all zero.
3 JUDGE CALLIHAN: Yes, true.
4 But to what are the loadings due and where do the 5 forces act?
6 It was more of a narrative response that I sought.
7 WITNESS KOSTAL: Okay.
8 These loadings come from the computer run. This is 9 the computer run that was made on this particular 10 hanger.
11 They are the loadings that would be found on Node 12 Point -- in this particular case, they would have been
(
13 found on Node Point No. -- it would be Node Point No. 3.
14 Let~me make sure of that.
15 MR. GUILD: I'm looking at Nodes 6 and 11 in 16 the reference of the cloud above, in the middle of the
-l 17 page on Page 14, Mr. Kostal.
18 WITNESS KOSTAL: That's -- that's a different 19 member.
20 The only reason I'm hesitant is there's two 21 diagonal members. They are defined as Members 37 and i
22 38. There's two node points on Page 2: Node Point 3 I
23 and Node Point 10.
- 24 It's my understanding that Node Point 3 for this 25 model represents the west side of the hanger, which is i
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1 the discrepancies noted in Section B-B. So that would 2 be the location of where those particular forces came 3 from.
4 JUDGE CALLIHAN: Then the --
5 WITNESS KOSTAL: Now --
6 JUDGE CALLIH AN : Excuse me. I'm sorry.
7 The V -- upper case V forces are the components, 8 apparently, of the upper case F forces.
9 Along what axis do the V components --
10 WITNESS KOSTAL: This was -- the crossed-out 11 section really was just defining the properties along
() 12 13 the axis of the member.
Since these are resultant forces that are squared 14 and the square root is obtained, it really doesn't make 15 any difference because you're looking for a resultant of 16 the two different forces.
17 When you square them and get the square root, it 18 provides you a resultant force that will act on this 19 weld assembly.
- 20 That's what -- and that's what's shown on 21 Calculation Page 15. It shows the -- this is where we 22 provide the force halfway down the page, where we' re
( 23 showing you -- where it's showing the resultant force i
24 about AB.
j 25 JUDGE CALLIHAN: That's Page --
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LJ 1 WITNESS KOSTAL: 15. ,
i 2 JUDGE CALLIHAN: -- 16?
3 JUDGE COLE: Page 15, 4 JUDGE CALLIHAN: Page 15. Sorry.
5 WITNESS KOSTAL: What that calc would be is 6 the --
7 JUDGE CALLIHAN: Well, somewhere along the 8 line, the coordinate designations were changed, as I 9 understand it, from a, b and c to x, y and z.
10 WITNESS KOSTAL: That may be explained by --
11 JUDGE CALLIHAN: Did that occur before the 12 X-ing out of the loadings or after?
13 WITNESS KOSTAL: It occurred -- if you look 14 at that as-built weld map, you'll see there was 15 originally an axis a, c and b; and then they were 16 clouded out to be x, y and z.
17 JUDGE CALLIHAN: What page is that on?
18 WITNESS KOSTAL: That's on Page 14, on the 19 left-hand side of the page. It's that little weld map.
20 JUDGE CALLIHAN: Yes. I see that.
21 WITNESS KOSTAL: What was originally defined 22 as Axes a, b and c, when the analysis was redone, which 23 was to put it back into the global coordinate system, 24 which is how the computer run is done, we converted 25 those back to x, y, z coordinates. They reflect _the x,
(_
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V 1 y, z terminologies that are in the computer run.
2 JUDGE CALLIHAN: Well, going back to the 3 original designation, you had the -- the F f orces had 4 upper case subscripts to denote the axes, whereas the 5 upper case V forces had lower case a and b.
6 WITNESS KOSTAL: What that would have meant 7 is x-a would have been the axial load along that small 8 axis a, as shown in that sketch.
9 JUDGE CALLIHAN: And what is F sub capital A, 10 then, upper case A?
11 WITNESS KOSTAL: I'm missing you now.
fv 12 FA under " loading" that was crossed out?
13 JUDGE CALLIHAN: Yes.
14 WITNESS KOSTAL: This FA is the force that 15 would have acted in this -- along the axis a in the 16 sketch, along that little axis a, which was crossed out 17 and became z.
18 (Indicating.)
19 JUDGE CALLIHAN: Well, are we -- am I just 20 confused by the use, in one group of forces, of capital 21 -- upper case A and B as axis designation and, in the 22 other cases, the use of a lower case a and b?
23 WITNESS KOSTAL: Yes.
,s 24 Well, what it represents -- the upper case and
( ,) 25 lower case are literally the same.
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1 JUDGE CALLIHAN: Oh, okay.
2 WITNESS KOSTAL: They mean the same thing.
3 One was used for shear. One was used for the axial 4 load.
5 JUDGE CALLIH AN: I guess another way of 6 asking my question is: Where is theta that's 70.88 7 degrees?
8 WITNESS KOSTAL: That would be the angle of 9 inclination of the diagonal, from the horizontal to the 10 angle of in~clination of the diagonal.
11 JUDGE CALLIH AN: And that says, then, that
() 12 13 your reference axes are horizontal and vertical?
WITNESS KOSTAL: Right. It's just converting 14 them to those reference axes.
15 JUDGE CALLIHAN: Thank you.
16 MR. GUILD: Mr. Chairman, I would request 17 that Applicant make available the basis for the changed 18 calculations.
19 JUDGE GROSSMAN: Mr. Steptoe, you've 20 consulted with your people.
21 Is there a problem with that?
22 MR. STEPTOE: Well, Judge Grossman, I suppose i
23 I'm reluctant to do that. What we're doing is in the 24 nature of discovery.
( 25 These calculations have been available to Sonntag Reporting Service, Ltd.
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1 Intervenors for two months now. In fact, Mr. Kostal was 2 available, and there was a day-long interview.
3 I would like some representation of what 4 Intervenors are going to be able to do with it if we 5 bring in two different response spectra here. Mr. Guild 6 -claims to be a folk engineer. I don't know what purpose 7 this is going to serve.
8 If there was a purpose, I guess I wouldn't mind.
9 But I am concerned about the amount of time we're taking 10 here without some representation that there's an error 11 in the calculation.
[)
V 12 MR. GUILD: Mr. Chairman, you know, I've 13 taken a particular calculation, which I have no basis 14 for being able to evaluate but for this witness 15 supplying me with variables, with the assumptions and 16 with the methodology he's applied.
17 I indeed had one day to ask him questions, only one 18 day to prepare for this hearing through interviewing 19 this witness.
20 I believe a good bit of this information is 21 information that simply emerges f rom the witness on the 22 stand.
23 I think it's a reasonable request when, in the 24 course of examining a witness, he tells me that there )
) 25 are changes, the bases of which are not known, that Sonntag Reporting Service, Ltd.
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1 account for having reduced -- increased the design 2 margin conclusions with respect to a particular BCAP 3 discrepancy by significant amounts, that I be able to 4 inquire as to that basis. That seems to me to be, on 5 its face, relevant.
6 I wish I had six months to prepare for this 7 hearing. I wish I had Edison's cadre of engineers to do 8 this evaluation for me. But I'm doing the best I can, 9 Mr. Chairman.
10 JUDGE GROSSMAN: Well, it is a complicated 11 area, Mr. Steptoe, and that 1.03 figure is not such a 12 great margin that the Board is not also curious as to fx.)\
13 how you got f rom there to 1.89.
14 MR. STEPTOE: Okay. Very well, then, Judge 15 Grossman. We'll do our best to provide that.
16 JUDGE GROSSMAN: All right.
17 Now, you did say there were two response spectra.
18 Do you mean for each -- one original and one 19 changed or did you mean --
20 MR. STEPTOE: I assume that there was --
21 maybe I'm speaking out of turn, but I assume that they
~
22 had one -- they had a Braidwood-specific response 23 spectra. Perhaps Mr. Kostal can --
24 JUDGE GROSSMAN: Well, I did ask a question 25 cn this.
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14721 c) 1 Now, did you use the response spectra from REG 2 GUIDE I think it's 1.617 3 WITNESS KOSTAL: The response spectra 4 developed for the plant -- there is a Braidwood and a 5 Byron station. Each had done a seismic analysis.
6 We enveloped the spectras between Byron and 1
7 Braidwood and obtained an enveloped designed spectra.
8 That enveloped designed spectra was used for the initial 9 calculations performed for both stations.
10 In going back and looking at unique conditions that, 11 exist at Braidwood, we have the unique spectra 12 associated with Braidwood, which was also reviewed by 13 the NRC.
14 We have utilized that unique spectra.
15 JUDGE GROSSMAN: So that in the revised 16 calculation, you use the one that's unique to --
17 WITNESS KOSTAL: To Braidwood Station.
18 JUDGE GROSSMAN: -- to Braidwood?
19 WITNESS KOSTAL: Yes, sir, 20 JUDGE GROSSMAN: Okay, fine. You will 21 attempt to make available --
22 MR. STEPTOE: Yes, Judge Grossman.
23 BY MR. GUILD:
24 0 Mr. Kostal, let's proceed to Page 14.
25 hhat is the change that's reflected in the cloud Sonntag Reporting Service, Ltd.
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/~~T i 1 that appears in the middle of the page towards -- on the 2 right-hand side, "Memb. 21 & 22 are braces," et cetera?
3 A (WITNESS KOSTAL) I'm sorry. You're talking about that 4 change in the note on the cloud on the members?
5 0 Well, I want to know: What's the significance of.the 6 change that appears in the cloud, the change beginning 7 "Memb. 21 & 22 are braces," et cetera?
8 Members 21 and 22 are not the longitudinal braces 9 in question -- at least, not according to the 10 designations that appear on Page 2.
11 A (WITNESS KOSTAL) I can't answer that at the moment.
O 12 I'd have to check that out.
(}
13 0 All right.
14 Nodes 6 and 11 -- they aren' t the nodes in issue, 15 either, are they?
16 According to Page 2 there, the connection of the --
17 the upper connection of the diagonal brace we've already 18 talked about and apparently connection of a horizontal 19 member.
.20 A (WITNESS KOSTAL) Well, Node 6 is part of the diagonal.
21 Node 11 is actually part of the horizontal member.
22 0 Right.
l 23 So in what respect are those nodes -- the load for 24 Nodes 6 and 11 enveloping --
N k) 25 A (WITNESS KOSTAL) That's " enveloping."
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1 0 -
" enveloping," if you choose - " enveloping"; how 2 about that?
3 What's the purpose -- what's the meaning of the 4 cloud and the revision?
5 A (WITNESS KOSTAL) I'd have to go back into the -- into
- 6. the actual model.
7 It has to do something with obviously the loads 8 that are applied at that particular joint, and I just 9 don't happen to have that knowledge in front of me.
10 0 All right, sir.
11 Now, we're looking -- this diagram, the weld map
() 12 13 with the a, b, e coordinates changed to x, y, z --
that's, in effect, looking at the weld with the gusset 14 plate -- the two welds with the gusset plate in between, 15 looking at the edge of the gusset plate?
16 A (WITNESS KOSTAL) That's correct.
17 0 All right. There we see one weld that's on the 18 lef t-hand side that's a 1/8 inch weld.
19 Is that what that weld symbol indicates?
20 A (WITNESS KOSTAL) Yes, sir.
21 0 on the right-hand side, we have a 1/16 inch weld?
22 A (WITNESS KOSTAL) Yes, sir.
23 0 The 1/16 inch weld is a designed 3/16 inch weld that's 24 been reduced by 1/8; it's 1/8 inch undersized?
h
( j) 25 A (WITNESS KOSTAL) Yes, sir.
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14724 1 Q All right.
4 2 on the lef t-hand side, it's a 1/8 inch weld that's 3 1/16 undersized?
2 4 A (WITNESS KOSTAL) That's correct.
'5 Q Now, the question I was asking you earlier about this 6 question of probabilities simply asks you whether or not 7 it's probable that the 1/16 inch weld occurs on both 0 sides of that gusset plate.
9 A .(WITNESS KOSTAL) It could possibly occur.
10 0 All right.
11 Now, what's the -- what are the calculations that
() 12 13 A are X'd out that appear below the cloud to the right?
(WITNESS KOSTAL) Those were the original calculations.
14 0 The cloud below that is the reference to the new 15 calculation run?
16 A (WITNESS KOSTAL) It's reference to the computer run 17 and the forces that exist on this joint in the computer 18 run.
19 0 Okay. The loading analysis appears below the X'd-out 20 analy sis.
21 That's the original calculation?
~22 A (WITNESS KOSTAL) Below the loading analysis -- excuse 23 me -- below the X'd-out area, that is, in the cloud, the 24 loads that are from the computer print-out.
25 Now, what are --
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1 0 What are the X'd-out calculations?
2 A (WITNESS KOSTAL) Those came f rom the original 3 analysis.
4 0 All right, sir.
5 The weld properties in the lower left -- are those 6 calculations of the area of the weld?
7 A (WITNESS.KOSTAL) Yes, sir.
8 0 All right..
9 On the next page, the as-desi'gned weld properties, 10 below that a comparison of the two?
11 A (WITNESS KOSTAL) They define the as-designed
() ~12
.13 properties which are contained in the generic calculation for the DV 22 and DV 24 connections, which 14 are the subject of this~particular diagonal gusset 15 plate. They're found in the Calculation 12.2.87.3, 16 which is referenced in the top right-hand corner of the 17 calculation.
18 Q All right, sir.
19 Why do you rely on a generic calculation for weld 20 properties?
21 A (WITNESS KOSTAL) Because the generic calculation 22 assigned unit -- they provided -- we have -- excuse me.
23 I'll back up.
24 When we went in the developing of our standard i
\ 25 details, we developed generic calculations to support Sonntag Reporting Service, Ltd.
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)
1 those standard details.
2 This is a generic calc relative to this particular 3 standard detail; and in that generic calc, you will find
'4 this detail. From that, you can obtain these 5 as-designed weld properties.
6 0 What are the as-designed weld properties which you 7 display from a generic calc?
8 A (WITNESS KOSTAL) They are the properties that are 9 indicated on the lef t-hand side of the calculation under 10 " Area A equal to 2.34 square inches," under "Section 11 Modulus C equal to 2.43 inches to the third," and under
() 12 13 0-
"Section Modulus B equal to 0.58 inches to the third."
All right, sir.
14 And those are for the weld, assuming that the weld 15 was as-designed the full size?
16 A (WITNESS KOSTAL) That's correct.
17 0 Then as-designed you calculate forces.
18 What are the nature of the changes that appear to 19 those calculations?
20 .A (WITNESS KOSTAL) Those are the changes that result 21 f rom the information contained on the previous page.
22 For example, if you're looking at Fz, if you go to 23 the previous page, the Fz force is 3.463 kips; and in 24 the cloud under the equation, you'll see Fz in that
(,) 25 cloud -- you'll see that 3.46 -- 3.493 kips.
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E 14727 1 In the various other clouds, you will find the 2 various other -- the other load that's indicated on Page 3 14, which is the Fy of 12.22 kips. You'll note that 4 under "Fy equal to" -- and it's not in a cloud, but it's 5 12.22-divided by, in this case, the~ area 2.34, which
-6 gives you then a stress level of 2.22 kips per square 7 inch.
8 0 5.22?
9 A (WITNESS KOSTAL) I'm sorry; 5.22.
10 0 Now, why are all of the variables in the first equation 11 crossed out? Why are the variables crossed out?
12 .A They're crossed out because in the
( (WITNESS KOSTAL) 13 revised calculations, you are converting these forces 14 into just two components: a vertical component and a 15 longitudinal component.
16 You don't have to deal with the vector components.
I '
17 If you have already converted the forces into a global 18 coordinate system, you can then just use the global 19 coordinate system components. That's literally what was 20 redone.
21 When we reassigned the FZ, that became a global 22 coordinate system; and the force that exists in the Fz 23 direction is the 3.493 kips.
24 Then when you do the stress in that particular O(_,/ 25 direction, the stress is equal to 3.493 divided by the' Sonntag Reporting Service, Ltd.
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2 Q This is in the as-built section down in the bottom half 3 of the page?
4 A (WITNESS KOSTAL) No. We're still on the top half of 5 the page.
6 0 All right.
7 A (WITNESS KOSTAL) We're still on this line reading 8 stress "Fz," and we're dividing the 3.493 in the cloud 9 by the area 2.34 square inches.
10 If you go down to the next line, it then tells you 11 the stress is equal to 1.49 kips per square inch.
() 12 13 The next line represents the stress in the y direction, and there you take'the force Fy, which is 14 12.22, found on Page 14, and you divide that by the 15 area. You get the stress in the y direction.
16 0 All right, sir. Then -- let me slow you down a second.
17 The original calculation for the stress in the z 18 direction was 8.53 kips?
19 A (WITNESS KOSTAL) Well, it wasn' t z. It was an a 20 orientation, but it was 8.53, yes.
21 0 All right.
22 A (WITNESS KOSTAL) And then the next line represents the 23 vector -- it represents the resultant of those two
- 24 stresses, which is F resultant AD. There it's -- you're 25 squaring the value 1.49, which is the stress in the z Sonntag Reporting Service, Ltd.
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l' direction, and you square the value in the y direction, 2 5.22; and then you get the square root of that.
3 Therefore, the resultant stress on that particular 4 weld is 5.43 kips per square inch. You compare that to 5 the allowable, which is 19.75.
6 The cloud on the right -- left-hand side gives you, 7 then, the interaction coefficient for that weld, which 8 is 5.43 divided by 19.75, the actual stress versus the 9 allowable stress. In that case the interaction 10 coefficient is 0.275.
11 0 What was the original calculation of the interaction
() 12 13 A coefficient for that particular weld?
(WITNESS KOSTAL) I just don't happen to see it at the 14 moment, but it would be 10.29 kips per square inch 15 divided by 19.75, which would be a value of --
16 Q Isn't it IC sub AB towards the bottom of the page there?
17 A (WITNESS KOSTAL) No.
18 You're asking what it would be if it was just for 19 that same resultant, and that -- that particular 20 component was 10.29 kips per square inch, as compared to 21 19.75. That would give you -- that ratio gives you your 22 interaction coefficient.
23 0 All right, sir.
24 What's the value that appears at the bottom for
,) 25 Interaction Coefficient AB?
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\b 1 Do you see that, just above your R at the bottom of 2 the page?
3 A (WITNESS KOSTAL) Right.
4 That was the original combined interaction 5 coefficient; and that was .97, as compared to the 6 revised interaction coefficient in the cloud of .528.
7 0 And that original interaction coefficient of .97 is 8 associated with a design margin of 1.03?
9 A (WITNESS KOSTAL) That's correct.
10 0 You've recalc'u lated that to be a design margin of 1.89?
11 A (WITNESS KOSTAL) That's correct.
~12 0 All right, sir.
13 I take it that if you go to the next page, the 14 underlength welds, your calculation confirms that all of 15 those represent insignificant or Y category 16 discrepancies?
17 A (WITNESS KOSTAL) Starting on Page-16?
18 0 Yes.
19 A (WITNESS KOSTAL) Yes, sir.
20 0 All right.
21 You don't --
22 JUDGE GROSSMAN: Excuse me. If you're off 23 these other calculations, I have another question.
24 With regard to those response spectra, I take it in 25 the original calculation, when ycu eneloped the Sonntag Reporting Service, Ltd.
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t 1 Braidwood and Byron response spectra, what you were 2 doing was using the most conservative case for each 3 frequency?
4 WITNESS KOSTAL: Yes, sir.
5 JUDGE GROSSMAN: And then when you went to 6 the revised calculation, using just Braidwood, you took 7 away that conservatism?
8 WITNESS KOSTAL: We took away that portion of 9 the spectra associated with Byron that was more
. 10 conservative.
11 JUDGE GROSSMAN: Right, okay.
12 Now, why in the first instance had you enveloped 13 both Byron and Braidwood?
14 WITNESS KOSTAL: Because initially these were 15 designed for both plants.
16 See, our original design was to replicate Byron and 17 Braidwood together. So we performed one set of 18 calculations on the building, which represented -- which
)
.j 19 enveloped both the conditions at each plant, and we l 20 built it to accommodate both the conditions at each 21 plant.
22 JUDGE GROSSMAN: But, now, why would you even 23 have a different calculation for Braidwood than for 24 Byron if all you -- I assume all you used were computer 25 models for both of them. l Sonntag Reporting Service, Ltd.
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1 WITNESS KOSTAL: Well, the reason we 2 performed one calculation on the same hanger -- let's 3 say this particular hanger existed at Byron in the exact 4 same fashion. ,
5 We had done one analysis with the enveloped spectra 6 to design this hanger, which was to be built at both 7 stations, taking into account the conditions of each and 8 enveloping those, giving you a more conservative hanger 9 design, okay.
10 In coming back -- that was the original calc.
11 In coming back, in looking at Braidwood, we looked 12 at the unique conditions that' exist at Braidwood to (a) analyze and check for unique hanger conditions at 13 14 Braidwood.
15 In that case we used the unique Braidwood spectra.
16 There was no reason to use nor a need to use the Byron 17 portion of the combined spectra.
18 So we used the exact specific spectra associated 19 with this plant, allowing us then to take advantage of 20 some of those conservatisms in the enveloped portions of 21 the spectra.
22 JUDGE GROSSMAN: Okay.
23 My question was, though -- the follow-up was: Why 24 would you have even -- if you designed the Braidwood
) 25 items identically to Byron, why would you have a Sonntag Reporting Service, Ltd.
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1 different calculation for the two in the first instance?
2 WITNESS KOSTAL: The primary reason is that 3 in the process of building these hangers, different 4 construction conditions existed at Byron and Braidwood, 5 which resulted in modifications to the common hanger.
6 So we ended up, let's say, building it -- let's say 7 for some odd reason there was an interference on one 8 plant and we had to modify the hanger to accommodate 9 that interference.- Then it becomes a unique hanger 10 associated with that plant.
11 In the case of Braidwood, we entered into the 12 walkdown program on all the cable pan hangers. I don't 13 know if it was discussed here yet, but there was a 14 program to document the as-built condition of every 15 single cable pan hanger. That was called the Rev. A 16 program.
- 17 That program was conducted through Comstock f 18 inspectors.with assistance from Sargent & Lundy people.
19 Our portion of that program was done under a 20 project-unique procedure, PIBB-85; and as a result of 21 that program, we got as-built dimensions on every single 22 hanger that existed at Braidwood.
I 23 In addition to that, we --
24 JUDGE GROSSMAN: Are you saying you 25 recalculated your response spectra?
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1 WITN7.SS KOSTAL: No. The response spectra 2 that.we're referring to was initially developed in the 3 1970's. It hasn't changed since those developments.
- 4 We just used -- we inad at that time 5 Braidwood-unique spectra, Byron-unique spectra. We 6 enveloped the two spectra to do -- and we have that 7 enveloped spectra. So we pulled out the unique 8 Braidwood spectra f rom the 1970's and' used those unique 9 Braidwood spectra --
10 JUDGE GROSSMAN: You're answering more than 11 I'm asking.
\
12 Why in the 1970's did you have different response 13 spectra for both plants if you --
14 WITNESS KOSTAL: Oh, okay.
15 The reason that you have different response spectra 16 'is because you have different soil conditions.
17 JUDGE GROSSMAN: Oh, okay. That's fine.
18 JUDGE CALLIH AN : I'm still hung up -- I'm 10 sorry -- on Page 14, in which you have some revised 20 calculations circled. This is Page 14 of Intervenors' 21 Exhibit 155-B.
- 22 In the X'd-out calculation, you have an M sub c and 23 an M sub b, which, if I went a little further than that, 24 would seem to be a moment. But the units bother me a 25 bit.
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1 Is inch-kip correct for the Mc or is Mc really a 2 moment?
3 WITNESS KOSTAL: Generally Mc refers to a 4 moment, "M" meaning it would refer to a moment.
5 .I have not reviewed this portion of the original 6 cales to really answer whether or not it was considered 7 a moment or not.
8 JUDGE CALLIHAN : Well, if it were a moment, 9 then I think you said that in the encircled portions, 10 the M sub z, M sub y, M sub x are moments unequivocally.
11 WITNESS KOSTAL: That's correct.
12 ' JUDGE CALLIHAN: Is there a simple physical 13 condition or change in conditions that drove the finite 14 quantities for moments in the X'd-out portion, if truly 15 they be moments, to zero?
16 WITNESS KOSTAL: What -- what these really 17 are are -- and I'm looking at it -- is they're internal
, 18 moments.to generate the extreme fiber stress on this 19 weld.
- 20 (Indicating.)
21 What you're looking at here is they took the --
22 what would be called VA, which is the vertical force, 23 vertical shear force, in the A direction, and they 24 multiplied that by 2.25. 2.25 on this diagram is the
) 25 location of a point along the weld.
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[V k 1 What he was internally doing -- and I guess I just 2 don't know why at the moment -- he created this internal 3 little moment, which would-be the 2.25 inches times the 4 4.6 8 kips.
5 What I think he was trying -- I'll have to go back 6 and exactly find out why he -- normally we would not 7 perform the calculation in this manner. Normally the 8 computer run would give you a global coordinate reaction 9 and set of forces, and that's what you would use.
10 JUDGE CALLIHAN: Well, assuming the units are 11 correct -- and I-have no reason, really, to doubt them j
() 12 13
-- then my question is moot, because there is no relation, as I understand what you're saying, between 14 upper case M sub x -- and I've replaced the c by an x, 15 just to get us into the same coordinate designation.
16 There's no connection between that and an Mx equals 17 zero in the final line on that page?
18l WITNESS KOSTAL: The -- maybe -- I just 19 noticed, and I'm sorry I failed to notice this before.
20 Under the terminology " loading" in the crossed-out 21 area, there is an M large A equal to M small a equal to 22 M small z equal to zero. Do you -- it's Line 3.
23 Do you see that?
) 24 JUDGE CALLIHAN: All right, okay. I missed 25 it, also.
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1 WITNESS KOSTAL: That basically said the 2 original computer run had these same moments as zero 3 about these same axes.
4 JUDGE CALLIHAN: So that's -- that line 5 refers to honest-to-goodness moments?
6 WITNESS KOSTAL: Yes. The third line under 7 " loading" would refer ~to --
8 JUDGE CALLIHAN: And that's the thing that's 9 comparable to the final line'on that page?
10 WITNESS KOSTAL: That's correct.
11 JUDGE CALLIHAN: I apologize. I missed that, 3
) 12 also, J
13 The other M sub c, whatever it may be, doesn't come i
14 into the argument at the moment.
15 On the other hand, looking on Page 15, the first 16 full equation, which started out to be lower case f sub 17 a and has been changed to lower case f sub z -- I took 18 constance in the dropping of those two terms because the 19 second and third terms on the right of the first 20 equation, first equality -- by saying that somehow in 21 your revision process, the moments went to zero, which 22 we've just now undermined a bit.
23 So I guess I'm confused a bit now by why those two 24 terms drop out. But let's don't pursue it this late in
, 25 the day, unless you' ve got an of f-the-top-of-your-head Sonntag Reporting Service, Ltd.
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(
b 1 answer.
2 WITNESS KOSTAL: Well, the reason -- what he 3 did was reconvert the forces into different axes. As a 4 result of reconverting the forces into different axes, 5 he created internal moments.
6 Literally what you have in the equation fz is V 7 over a, which is a shear area; and Mc over Sc~is 8 literally the extreme fiber stress over the corner of 9 this extreme vertical weld.
I So what he was trying to do is he literally took 10 i 11 the global coordinate system loads and transformed them"
-12 into local ~ coordinate system loads. When you do that,
(
13 you get local moments f or--the transf erring of the loads.
14 That's, in essence, what this is -- what he had 15 done here.
16 JUDGE CALLIHAN: All right. Thank you very 17 much. I think the change in coordinate designation has 18 confused me somewhat as well.
- 19. If you have any further thoughts on it later, we'd 20 be glad to hear it. But for the moment, thank you very l
21 much.
22 BY MR. GUILD:
23 0 I really hesitate to confuse myself any further than I 24 am already, Mr. Kostal, but I frankly just don't 25 understand how the original annotation of M sub c can be
(
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i 1 equated to zero by the same engineer who uses M sub c 2 down below and equates it to 10.53 kips per inch or 3 thousands of inch or thousand inches or kip _ inches.
4 A (WITNESS KOSTAL) Kip inches.
1 5 0 It's either zero or it's 10.53 kip inches.
6 Which is it?
7 A (WITNESS _KOSTAL) Well, it's zero from the loads coming 8 out of the computer.
9 0 So it's zero f rom the loads in the final analysis, the 10 clouded calculations.
11 But the question is: How did the original engineer
() 12 13 A do'his original calculation?
(WITNESS KOSTAL) He converted the axial load which is
, 14 in the brace, which is on the~ diagonal, into two 15 components, which are both vertical and horizontal.
16 In the process of changing that components to 17 vertical and horizontal, he was then calculating what 18 the effect would be of that conversion.
- 19 By drawing a little stress diagram, what he was 20 trying to do was determine the extreme fiber stress --
21 well, the maximum stress that would exist on this 22 particular weld in the top -- in the corners of the
. 23 weld.
24 He was converting this load in an effort to develop b 25 that maximum stress in this corner by looking at the 4
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1 section properties of the weld in two different !
2 directions and' internally applying this vector moment to 3 determine the stress level in the corner.
4 Q My question is simpler: Does Mc at the bottom, where 5 it's equated to 10.53, mean the same thing as Mc at the 6 top, where it's equated to zero?.
7 A (WITNESS KOSTAL) No, it's not the same thing.
8 Q Do you know what it means in each case?
9 A (WITNESS KOSTAL) That's what I was trying to explain.
10 It may be easier if I could bring an illustration 11 tomorrow on a piece of paper so you can'see the 12 difference in how you can get that.
(
13 Q Now, a moment ago you said you were going to have to 14 check.
15 How are you going to check on this thing? ,
16 Are you going to ask the guy who prepared the i
j 17 calculation?
18 JUDGE COLE: No. I think he --
i 19 MR. GUILD: I'm sorry.
20 JUDGE COLE: I thought h'e explained now that 21 he knows how it was done now, and that's what he just 22 explained.
23 A (WITNESS KOSTAL) I know how it was done.
l 24 What I would like to do, to make it simpler for 25 everybody, is to draw a little stress diagram to label l
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b .
1 all these points so there is no misunderstanding as to 2 what this set of numbers really mean.
3 MR. GUILD: All right, sir.
'4 BY MR. GUILD:
5 0 Let me just complete the circle here, if I can.
6 Page 16, underlength welds -- none of those 7 required detailed calculations; they were all determined 8 to reflect a capacity reduction value of less than 10 9 percent?
10 A (WITNESS KOSTAL) That's correct.
11 0 All right.
() 12 13
" Additional undercuts," Page 18, similarly all determined to reflect a capacity. reduction value of less 14 than 10 percent?
15 A' (WITNESS KOSTAL) Yes, sir.
16 O All right. So you get over to Page 20.
17 On the summary I take it that in the original
- 18 calculation, as you testified a few moments ago, this 19 gusset plate with the longitudinal brace attachment and 20 the undersized welds there represented the bounding case 21 originally calculated to reflect a capacity reduction 22 value of .54, an R value of .54, and a design margin of i~
23 3 percent, 1.03, recalculated the bounding case and is 24 represented by the fit-up gap and undersized weld
) 25 previously discussed a capacity reduction f actor of .52 Sonntag Reporting Service, Ltd.
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1 and a design margin of 1.89?
2 A (WITNESS KOSTAL) All this says is it just changed the 3 item that was indicated as the fit-up gap issue -- no, 4 not the " fit-up gap issue" -- of the gusset plate issue; 5 and it just corrected the summary to show that this 6 particular R value changed from .54 to .52, consistent 7 with what is found on Page 15'.
8 0 All right.
9 A (WITNESS KOSTAL) It also --
10 0 Yes?
11 A (WITNESS KOSTAL) And it also -- to be consistent, it (d \ 12 13 showed that the M sign design margin was not 1.03 but 1.89.
14 Q For which particular discrepancy?
15 A (WITNESS KOSTAL) For the same discrepancy. It didn't 16 say " bounding discrepancy." It just corrected the data 17 that was originally presented on Page 20.
18 Q All right, sir.
19 So the summary, Page 20, originally referred to the 20 bounding case, and that was the undersized weld on the 21 gusset plate?
22 A (WITNESS KOSTAL) What the summary' defined was it was 23 the undersized weld on the gusset plate. It was 24 characterized as a Z.
25 It said, " Based on above calculations," meaning the Sonntag Reporting Service, Ltd.
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1 entire 20 pages of calculations, "the cable pan hanger 2 is structurally adequate and as-built condition is 3 acceptable."
4 Q All right, sir.
5 Is there any significance -- you skipped f rom the 6 gusset plate evaluation through the insignificant 7 defects that I just ran th~ rough briefly, all with an R 8 value of -- a capacity reduction of less than 10 9 percent, and then originally there was a summary.
10 But the values shown in the original version of the 11 summary were for the undersized weld involved in the
() 12 13 gusset plate.
Now, why do they list those values in the summary 14 portion of the calculation?
J 15 A (WITNESS KOSTAL) Just to correct the original summary.
16 Q No, sir.
17 Originally why do they list those as the summary 18 for the calculation?
19 Isn't it because it was the bounding case?
20 A (WITNESS KOSTAL) At that time it was the bounding 21 case, yes, sir.
22 0 When you made the revision, you revised not just the 23 bounding case; you revised the evaluation of that 24 particular discrepancies, which was no longer the i
25 bounding case?
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14744 C) 1 A (WITNESS KOSTAL) That's correct.
2 MR. GUILD: Mr. Chairman, I would very much 3 like to round out this line of questioning tomorrow with 4 this panel.
5 I would propose,.though, that in order to do that 6 expeditiously, now having some minimal grasp of the 7 process that led to this calculation, that I be 8 permitted the opportunity to prepare f rom the materials 9 that are now promised by the Applicant with respect to 10 these calculations, 11 JUDGE GROSSMAN : You want to start a little 12 later tomorrow?
)
13 MR. : GUILD: That's what I was going to 14 suggest. By doing that, I think I can complete the l
15 panel tomorrow.
16 JUDGE GROSSMAN: If you agree to come here 17 earlier, we'll let you start later. How is that for a 1
i 18 trade-off?
- 19 Can you all meet at 8
- 00 o' clock tomorrow and we I
20 start at a later time here? Is that agreeable to you, l
21 Mr. Guild?
22 MR. GUILD: I'd be happy to, Judge.
23 I'd prefer, frankly, not doing that, since I'm 24 running pretty late hours as it is right now.
l 25 JUDGE GROSSMAN: Okay. I thought we could .
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Q 4 Nss/'
1 voluntarily get you to make that concession.
2 MR. GUILD: I'll be here at 8:00 o' clock on 3 Friday, Judge.
4 JUDGE GROSSMAN: What time --
5 MR. GUILD: I mean, I'd be happy to extract 6 the information f rom the witness on the stand. It just 7 doesn't seem to be the efficient way of doing it.
8 I don't f rankly think there is any other 9 alternative except to leave this subject, go to another 10 -
and come back to this subject after it's become stale.
11 JUDGE GROSSMAN: Now, what did you have in 12 mind as far as time goes?
(
13 MR. GUILD: Well, I don't know, but I'd 14 assume several hours. It really is dependent on the 15 information.
16 MR. BERRY: What does that mean; 2:00 o' clock 17 tomorrow, 1:00 o' clock, 11:00 o' clock?
18 MR. GUILD: Well, in part it's dependent on 19 what information Applicant has or would anticipate 20 having.
21 There are a number of pieces f rom the witness, 22 aside f rom this calculation, that are promised.
23 MR. STEPTOE: We'll try and get everything 24 that we possibly can get to him as early tomorrow 25 morning as we can.
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1 WITNESS KOSTAL: 'I don't know if we can get 2 it.
3 MR. STEPTOE: But without having consulted 4 with --
5 MR. MILLER: Why don' t you take the time to 6 consult with him?
7 MR. STEPTOE: Can I take five minutes?
8 JUDGE GROSSMAN: All right. Why don't we 9 take five minutes. We'll keep the Reporter here.
10 (WHEREUPON, a recess was had, after which 11 the proceedings were resumed as follows:)
() 12 13 JUDGE GROSSMAN: Back on the record.
We will adjourn until 11:00 o' clock tomorrow.
14 Before that, Mr. Guild will meet with the S & L people 15 and Mr. Steptoe and get briefed on the items that we 16 discussed.
17 We'll.run from 11:00 to probably about a quarter of 18 1:00, and then we'll break for lunch tomorrow.
19 So we're adjourned unti1 tomorrow at 11:00 o' clock.
20 MR. STEPTOE: Thank you, Judge Grossman.
21 (WHEREUPON, at the hour of 5:20 P. M., the 22 hearing of ' the above-entitled matter was 23 continued to the 16th day of October, 24 1986, at the hour of 11:00 o' clock A. M.)
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NO PAGE NUMBER CERTIFICATE OF OFFICIAL REPORTER This 'is to. certify that the attached proceedings before the UNITED ST TES NUCLEAR REGULATORY COMMISSION in the matter of:
NAME OF PROCEEDING: Braidwood Station Units 1 4 2
- DOCKET NO.
- 50-456/457-OL PLACE: Chicago, Illinois DATE: Wednesday, October 15, 1986 were held as herein appears, and that this is the originai transcript thereof for the file of the United States Nuclear Regulatory Comission.
(sigt) $N ' N (TYPED) I
- Official Reporter e Reporter's. Affiliation O
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