ML20206M802
| ML20206M802 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 06/25/1986 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| CON-#386-837 OL, NUDOCS 8607010289 | |
| Download: ML20206M802 (191) | |
Text
OR G N A O
UlN11ED STATES NUCLEAR REGULATORY COMMISSION IN THE MATTER OF:
DOCKET NO: 50-456 OL 50-457 OL COMMONWEALTH EDISON COMPANY (Braidwood Station, Units 1 & 2)
O LOCATION:
JOLIET, ILLINOIS PAGES: 5513 - 5701 DATE:
WEDNESDAY, JUNE 25, 1986
//V ~d/ g
$$N>xssp <fC dey>aeK$n Q y-y yp S
ACE-FEDERAL REPORTERS, INC.
OfficialReporters 444 North Ca itol Street 1
5513 1
UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4
__x In the Matter of:
6
(Braidwood Station, Units 1 8
and 2)
__________________x 9
10 College of St. Francis 3
500 North Wilcox Street 11 Joliet, Illinois 60435 12 Wednesday, June 25, 1986.
13 The hearing in the above-entitled matter reconvened 14 at 9:00 A.
M.
15 16 BEFORE:
17 JUDGE HERBERT GROSSMAN, Chairman Atomic Safety and Licensing Board 18 U.
S. Nuclear Regulatory Commission Washington, D.
C.
19 JUDGE RICH ARD F.
COLE, Member, 20 Atomic Safety and Licensing Board U.
S. Nuclear Regulatory Commission 21 Washington, D.
C.
22 JUDGE A.
DIXON CALLIH AN, Member, Atomic Safety and Licensing Board 23 U.
S.
Nuclear Regulatory Commission Washington, D.
C.
O-25 On behalf of the Applicant:
s Sonntag Reporting Service, Ltd.
Geneva, IlliT1oi s60-174 (312) 232-0262 l
5514 1
4 MICHAEL I.
MILL ER, ESQ.
2 JOSEPH GALLO, ESQ.
EL EN A Z. KEZELIS, ESQ.
3 Isham, Lincoln & Beale I
Three First National Plaza 4
Chicago, Illinois 60602 j
5 On behalf of the Nuclear Regulatory Commission Staff:
6 ELAINE I.
CH AN, ESQ.
7 GREGORY ALAN BERRY, ESQ.
U.
S.
Nuclear Regulatory Commission 8
7335 Old Georgetown Road Bethesda, Maryland 20014 9
on behalf of the Intervenors:
10 ROBERT GUILD, ESQ.
11 2
I 12 13 14 15 l
16 17 l
18 19 i
j 20 21 4
i 22 l
23 I
24 i
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EXHIBIT INDEX Marked Received 2
Applicant's Exhibits Nos. 50 and 52 through 57 5520 3
Applicant's Exhibit No. 58 5532 5605 4
Applicant's Exhibit No. 59 5554 5
Applicant's Group Exhibit No. 60 5559 6
Applicant's Exhibits Nos. 61 7
and 62 5583 5605 8
Applicant's Exhibit No. 63 5595 9
Applicant's Exhibits Nos. 64, 65 and 66 5626 5678 10 1
Applicant's Group Exhibit No. 67 5643 11
~
Applicant's Exhibit No. 68 5678 12 0
13 WITNESS INDEX 14 TESTIMONY OF WORLEY 0.
PUCKETT 15 (Continued) 16 CROSS EXAMINATION (Continued)
BY MR. MILL ER :
5520 17 18 19 20 21 22 23 24
(~)
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JUDGE GROSSMAN :
The hearing is reconvened.
2 This is the 28th day of hearing.
3 Mr. Miller, you can proceed.
4 Mr. Puckett, you remain under oath.
5 THE WITNESS:
Yes, sir.
6 MR. MILLER:
Your ' Honor, before I resume my 7
examination of Mr. Puckett, I'd like to move into 8
evidence Applicant's Exhibits 50 and 52 through 57, 9
inclusive.
10 Exhibit 50 is the reading list that Mr. Puckett 11 signed as he reviewed Comstock procedures.
12 Exhibit 52 is a memorandum that he sent on August O
13 9, 1984.
14 53 is a memorandum he sent on August 13, 1984.
15 Exhibit 54 is the stop-work order of Mr. Rolan, 16 Exhibit 55 is NCR 3099.
17 Exhibit 56 is Mr. Puckett's August 22, 1984, 18 memorandum to Mr. DeWald.
19 Exhibit 57 is Procedure 4.3.14, and we owe 20 everybody copies of that.
21 JUDGE GROSSMAN:
Okay.
22 Let me ask you:
Was there some difference in NCR 23 3099, which is Applicant's Exhibit 55?
24 I thought there was some mention of two versions of
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that yesterday.
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1 MR. MILLER:
Your Honor, I believe I 2
indicated -- perhaps Mr. Guild did -- that the NCR, or 3
at least the first page of it, had been -- is a part of 4
another exhibit.
5 My memory escapes me as to which exhibit that is.
6 If I could have a minute --
7 MR. GUILD:
It's 28, Intervenors' 28, Judge, 8
is my recollection.
9 JUDGE GROSSMAN:
Okay.
10 But there's no problem with Applicant's Exhibit 55 11 for identification as to its completeness, is there?
12 MR. GUILD:
Yes, there is, Judge.
()
13 JUDGE GROSSFEN:
Oh, there is?
14 MR. GUILD:
Yes.
If I may have just a moment 15 to pull out my papers here, I'll bring that to the 16 Board's attention.
17 The first thing, Judge, if you'll note on the front j
18 of 55, Applicant's 55, which is the first page of the 19 NCR, under the block that says " action to preclude 20 repetition," there's the note in handwriting, "See 21 attached speed letter.
Procedure is currently being j
22 revised."
23 There is no attached speed letter to Applicant's 24 55.
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There is apparently some other continuation sheets, 25 Sonntag Reporting Service, Ltd.
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1 but not the referenced speed letter.
2 MR. MILL ER :
Yes.
I agree with Mr. Guild.
3 I think that between the two exhibits, we probably I
4 have a complete set of the -- of the NCR, because 5
Exhibit 55, for example, has hold tags that are signed 6
by John Miner, and Intervenors' Exhibit 28 does not.
7 I am not certain -- you know, the thing that 8
bothers me about Intervenors' Exhibit 28 is that it has 9
attached to it a number of other memoranda:
the 10 stop-work order from Mr. Rolan to Comstock supervision, 11 dated August 17th; Mr. DeWald's memo to Mr. Rolan, dated 12 August 15th; and one of the handwritten documents f rom
(
13 Mr. Puckett to Mr. DeWald.
It's actually the same as 4
14 Applicant's Exhibit 53.
15 JUDGE GROSSMAN :
Okay.
If we have agreement 16 by counsel that the two exhibits together would 17 constitute the complete NCR, then there's no problem.
18 MR. GUILD:
I don't know that to be a fact, 19 Judge.
20 I can say that Intervenors' 28 does, in f act, 21 contain the referenced speed letter from Mr. Gieseker, 22 which is an integral part of the NCR.
It's the second 23 page of Intervenors' Exhibit 28.
24 I don't know for a fact that either one of them
(}
taken together are the full document.
I don' t object to 25 i
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1 the admission.
I'd just like the record to reflect --
2 JUDGE GROSSMAN:
You don't object to the 3
admission as long as we indicate that it's the partial 4
NCR?
5 MR. GUILD:
Or that it has not been 6
established that that's the complete NCR.
7 MR. MILLER:
I think that's a fair statement.
8 JUDGE COLE:
In Intervenors' Exhibit 28, 9
there is an Attachment A with that that is identified as 10 having five pages.
11 I've got four pages with mine.
Page 2 of 5 is 12 missing from mine.
O 13 MR. GUILD:
Okay.
14 JUDGE GROSSMAN:
So we understand that both 15 Intervenors' 28 and Applicant's 55 are partial NCR's as I
16 far as the attachments not being complete.
17 MR. MILLER:
I think what we'll try to do is 18 see if we can't get the NCR file as it exists and make a 19 Xeroxed copy of every piece of paper that is in it for 20 3099 and get with Mr. Guild and then perhaps submit 21 further exhibits so that we're certain that there is a 22 complete document.
23 MR. GUILD:
That would be fine, Judge.
24 JUDGE GROSSMAN:
Okay.
That's fine.
25 Are there any objections to any of the other i
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exhibits that are being offered?
2 MR. GUILD:
No obj ections, Mr. Chai rman.
l 3
JUDGE GROSSMAN:
Mr. Berry?
4 MR. BERRY:
The Staff has no objection, Mr.
5 Chai rman.
6 JUDGE GROSSMAN:
Okay, fine.
7 So we will admit those exhibits, then.
i 8
(Applicant's Exhibits Nos. 50 and 52
~
9 through 57 for identification were 10 thereupon received in evidence as 11 Applicant's Exhibits Nos. 50 and 52 12 through 57 in evidence.)
O
]
13 JUDGE GROSSMAN :
Mr. Miller, you can --
14 MR. MILLER:
Yes.
Thank you.
15 JUDGE GROSSMAN:
-- proceed further.
16 CROSS EXAMINATION 17 (Continued) 18 BY MR. MILLER :
19 Q
Mr. Puckett, I'd like to return just briefly to 20 to Procedure No. 4.3.3.
It was the subject 21 of your testimony yesterday, but I would like to ask 22 just a few further questions on it.
23 I believe that you testified yesterday in substance 24
-- and correct me if I'm wrong -- that when you looked
[}
at Attachment O as it appeared in Revision C to 4.3.3, 25 il Sonntag Reporting Service, Ltd.
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1 you could tell that it was a rejectable procedure 2
because of what the macroetch showed for the effective 3
throat of the flare bevel groove weld that was then 4
being submitted to PTL for approval; correct?
5 A
Yes.
6 0
And that was of concern to you that welders in the fj eld 7
were going to be using that rejected procedure prior to 8
the time it had been resubmitted to Pittsburgh Testing 9
Laboratory as a fillet weld?
10 A
That they could use it.
I didn't know that they would, j
11 but it was in the book and it could have teen used.
12 0
All right.
)
13 And I believe you testified that at was sometime in 14 the month of July,1984, that you obr,erved Attachment 0 15 with the flare bevel groove weld symbol on it; is that 16 right?
17 A
It may have been in the latter part of July, and that's 18 when I started resubmittal of the test coupons and the 19 changing of Attachment O.
20 Q
Can we agree that if we look at Revision D to Procedure 21 4.3.3, which is Applicant's Exhibit 23, that you made --
22 that there was a change made to the weld symbol sign and 23 to the line on the procedure specification sheet -- that 24 is, Attachment 0 -- to show that it was IF, 2F, 3F and
[
4F and that your initials are on there with the date 25 i
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1 July 5, 1984?
2 A
1 don't have the rev date.
3 0
Let me get it for you.
4 (Indicating.)
5 Is that correct?
That is the right date?
6 A
Uh-huh.
7 0
So that as of July 5th, you had observed this rejectable 8
condition in the procedure and had resubmitted the paper 9
to PTL as a fillet weld; correct?
10 A
Yes, I did.
11 Q
All right.
12 Mr. Puckett, this welding was not only rejectable O
13
-- or this procedure was not only rejectable f or welding 14 A446 to A36 material, but it was rejectable for welding 15 A446 to A500B material, too, wasn't it?
16 A
Yes.
17 Q
Did you ever document your concern that welds were being 18 made between A446 and A500B material and urge that work 19 be stopped on that process as well?
20 A
Well, I didn't know that this procedure had been used.
21 I only knew that it could have been used because it was 22 in the book.
23 I did go to the engineer downstairs at Comstock and 24 told him until such time that we get a change made to
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the procedure and make that a fillet weld, that he 25 Sonntag Reporting Service, Ltd.
Geneva, Illinois 601~3 4 (312) 232-0262
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l should not assign that to any of the weld travelers 2
going into the field, the Attachment O.
3 0
Which engineer was this?
4 A
I can't recall the name.
It's -- it's been a long time.
5 0
Right.
6 A
He was the engineer that was responsible for making out 7
these weld travelers and sending them into the field and 8
putting this inf ormation on them.
j 9
0 Ultimately, though, you did recommend a stop-work, but 10 the stop-work was limited to A36 to A446; right?
11 A
At that time, yes.
12 0
And there was no recommendation at that time that the O
13 welding of A446 to A500B be stopped, was there?
14 A
I had not witnessed any welding taking place of A446 to 15 A500.
16 I did, in fact, witness the welding of A446 to A36.
17 That was the majority of the types of materials that was e
18 being used.
19 0
I see.
20 Do you know whether you ever documented the 21 rejectable condition with respect to A446 being welded 22 to A500 on a rejected procedure in any form at all?
23 A
I don't recall that it was done.
24 0
All right.
{)
Now, you sent these documents -- that is, the 25 l
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1 Attachment O documents -- back to Pittsburgh Testing l
2 Laboratory with the fillet weld symbol on them and the f
3 changes made to indicate that it was a fillet weld, f
4 instead of a flare bevel groove weld, in July of 1984.
5 Then I believe your testimony was that the 6
documents got misplaced or lost somehow; is tha,t j
7 correct?
a 8
A Yes.
i i
9 Q
And ultimately they were found, I think you said, a
)
10 couple in Sargent & Lundy's office and a couple in PTL's 1
11 office; is that right?
i j
12 A
No.
O i
13 A Mr. Klevens that worked for Sargent & Lundy j
14 brought two of the papers over to me, and he said, 15 "Somehow these ended up in our office."
t j
16 Q
I see.
17 A
The other two -- I went back to PTL, and they could not l
18 find a good record reflecting where these papers had t
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19 been sent to; that they had sent them out but they l
20 didn' t have a good record as to where tney had been sent 21 to.
i 22 Af ter. doing quite a bit of research and looking i
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23 around and everything, quite by accident when I was in i
I 24 the vault looking for something else -- I had to go into j
l
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the file -- I found the other two copies in -- in the QC 25 Sonntag Reporting Service, Ltd.
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1 vault.
2 0
That was Comstock's QC vault?
3 A
Yes.
4 0
Do you recall when you made this search?
5 A
I don't remember the exact dates.
6 0
Was it around the time that you had recommended that 7
work be stopped on the welding of A446.to A367 8
A It was around that time, I would assume, yes.
9 0
So from July 5th or so until mid August, you were simply 10 assuming that the paperwork was in process for the 11 requalification of Attachment O as a fillet weld; is 12 that right?
O 13 A
Well, during this period of time, I was very busy with a 14 lot of other things, and I didn't check on this every 15 day that I was out there.
16 0
Did you check on it at all, Mr. Puckett?
17 A
I did check on it, yes.
18 0
With whom did you check?
19 A
I checked with PTL.
20 0
And did they tell you that they had the documents and 21 were processing them?
22 A
They said that the documents had been sent back to 23 Comstock.
24 0
And how soon af ter July 5,1984, were you informed of 25 that?
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1 A
I don't recall the dates.
1 j
2 0
But in any event, it wasn' t until af ter the stop-work l
3 order that you instituted your search for these --
1 4
A No.
I had been searching prior to that.
It wasn't I
5 completed until after the stop-work order.
)
6 Q
Thank you.
7 I need to pick up where I was yesterday.
8 I think you just testified that you had gone to the 4
9 weld engineer to urge him not to issue any weld 4
10 travelers that ref erenced Attachment 0; is that correct?
i 11 A
Yeah - 'it was not a weld engineer.
He was the I
i i
12 electrical engineer, but it was his responsibility for CE) j 13 filling out these travelers.
l 14 0
Did you document that instruction to him?
4 15 A
I -- I don't remember whether I did or didn't.
I can't s
j 16 recall having done it.
17 0
Would you agree, Mr. Puckett, that if you had initiated
}
18 a Nonconf ormance Report with respect to Attachment 0 at 1
19 that point of time, that would have been a proper method 20 under the procedures of documenting this nonconforming 1
21 condition?
22 A
Well, at this time it was kind of a company policy with 23 Comstock that a person that hadn't been fully qualified i
24 could not initiate a Nonconformange Report.
i i
25 0
Yes, sir.
J i
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l You were able to initiate ultimately a 2
Nonconformance Report on the welding of A446 to A36 t
3 material, weren't you?
l i
4 A
By going with another person and explaining the i
i 5
conditions that we had.
6 0
Right.
7 And is there any reason that you couldn't have done 8
that with respect to the use of Attachment 0?
)
9 A
I possibly could have, but, in my opinion at that time, 1
i 10 it wasn't necessary.
r l
11 0
Why wasn' t it necessary, sir?
Why wasn' t it necessary 12 to initiate an NCR on this condition?
13 A
As I said, at that time I did not consider it necessary.
4 l
14 Had I had it to do over again, maybe I would have i
15 had a Nonconformance Report initiated.
)
16 0
And at that time, in your opinion, then, was this matter i
17 not something that -- I don't want to ask it in the i
18 negative.
I 19 Am I correct, then, that you did not cause a j
20 Nonconformance Report to be initiated because, in your 21 judgment at the time, it was not a matter of sufficient 22 significance to warrant the initiation --
23 JUDGE GROSSMAN:
Mr. Miller, he's already testified that he didn't believe any work was being done 24 25
[}
that would require that he issue an NCR.
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1 I don't think that we have to pursue it ad 2
infinitum here.
3 MR. MILLER:
Your Honor, I seem to recall 4
examination of Applicant's witnesses, starting with Mr.
5 DeWald and going on to Mr. Seltmann and others, which 6
took off -- by Mr. Guild and yourself -- which took off 7
from the NCR procedure, as to whether or not there was 8
an obligation not only to issue an NCR but to issue a 9
stop-work, as to whether or not there was any 10 di sc r etion.
11 It seems to me that this witness has now testified 12 that he exercised his judgment not just in determining O
13 whether to stop work but as to whether to issue an NCR 14 at all.
15 MR. GUILD:
Mr. Chai rman --
16 MR. MILLER :
I believe that --
17 JUDGE GROSSPEN:
Yes.
I have no problem with 18 your inquiring into that area, Mr. Miller, but it's the 19 repetition that disturbs me here.
s 20 You've already gotten your answer on it.
The 21 question was, "Why wasn't it necessary to do it with the 22 A446 to A500," and his answer was that he didn't believe 23 there was any work being done on it then.
24 MR. MILLER :
All right.
25 JUDGE GROSSMAN:
Now, maybe that's not Sonntag Reporting Service, Ltd.
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1 sufficient reason, but how many times do we need the i
2 same answer?
3 MR. MILLER:
Let me just ask one further 4
question, then, Judge Grossman.
5 BY MR. MILLER :
6 Q
Mr. Puckett, was it your understanding in the summer of l
7 1984 that if you discovered a nonconforming condition in i
8 a procedure but, as f ar as you knew, there was no work i
9 going on to that procedure, that you need not initiate a d
]
10 Nonconformance Report?
11 THE WITN ESS :
Would you repeat the question, I
i 12 please?
(
13 MR. MILL ER :
I'd ask the Reporter to read it j
14 back, please.
l 15 (The question was thereupon read by the i
16 Reporter.)
17 A
I hadn't even thought about this.
18 As I said before, I was in training, and it was
'l 19 company policy that I did not initiate Nonconformance 20 Repo r ts.
I 21 BY MR. MILLER:
22 0
Well, Mr. Puckett, don't hold me too literally to the j
23 word " initiate" in terms of you personally signing a 24 document.
25 You could have caused at that point in time a Sonntag Reporting Service, Ltd.
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1 Nonconformance Report to be initiated; correct?
2 A
I could have talked to other people, but I'm not sure at 3
all that these people may agree with me.
4 It has to be a condition whereas the person that is 5
writing the Nonconformance Report is somewhat 6
responsible for it, and he would have to be in full 7
agreement, you know, that you had a problem before this 8
happened.
9 0
Did you ever -- do you ever recall asking anyone to 10 write a Nonconformance Report on your behalf, 11 documenting the rejectable condition of Attachment O?
12 A
No, I do -- I don' t recall this.
O 13 The Nonconf ormance Report that was written on the 14 A446 to A36 on the dispositioning -- I was thinking that 15 they would have to address those things that may have 16 been done prior to these dates and make some decision on 17 what was to be done with them.
18 0
And when you say "those things that may have been done 19 prior to these dates," that included the welding of A446 20 to A500B in accordance with Attachment 07 21 A
If it had, in fact, been done, yes.
22 0
All right, okay.
23 And you knew that A446 to A36 had been taking place 24 prior to that time?
25 A
I did not say that.
I don' t know that it had.
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1 0
Oh, I see.
2 So you weren' t aware that A446 to A36 --
3 A
Yes, I am aware that it was being done; but on the weld 4
traveler, I do not know what procedure they had assigned 5
to it.
6 0
Since you didn't know which procedure was being assigned 7
to it in July of 1984, in your judgment, it was not i
8 necessary to cause a Nonconformance Report to be 9
initiated?
i 10 MR. GUILD:
Objection.
He stated the basis 11 for that decision several times.
j 12 JUDGE GROSS >mN:
I believe so, Mr. Miller.
- ()
13 Sustained.
14 Please move on.
I 15 BY MR. MILLER:
16 0
Mr. Puckett, let's turn to the stainless steel welding.
17 We were -- I was examining you yesterday with 18 respect to the stop-work that took place with respect to
)
19 stainless steel welding, and the examination left off 20 with my questioning you as to whether or not an NCR had 21 been initiated on that stainless steel welding prior to 22 the time that the stop-work was ordered by Mr. Rolan.
j 23 I think my last question yesterday was probabli 24 inartf ul because it referred you to NCR 3099 and that's 25 the one that deals with the A446 to A36.
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l 1
But let me back up for just a second, if I might.
i 2
Can we agree that NCR 3099 was initiated by Mr.
3 Miner at your request on the same day that the stop-work 4
order with respect to the A446 to A36 welding was -- let i
5 me start over again.
6 Can we agree that NCR 3099 was initiated the same j
7 day that the stop-work order with respect to A446 to A36 8
material was issued?
9 A
It may have been, yes.
1
)
10 0
All right.
]
11 And that date is August 17, 1984.
J 12 Do you recall whether there was an NCR issued with i O 13 respect to stainless steel welding in the 2G position l
14 prior to the time that the stop-work order on that 15 aspect of welding -- of Comstock's welding operation was i
16 issued?
I 17 A
I know that there was a Nonconformance Report issued.
I i
]
18 don't recall the dates.
19 MR. MILLER:
All right.
j 20 I'd like the Reporter to mark as Applicant's l
21 Exhibit 58 for identification L.
K.
Comstock l
1 j
22 Nonconformance Report No. 3145, dated August 24, 1984.
j i
23 (The document was thereupon marked l
24 Applicant's Exhibit No. 58 for 25 identification as of June 25, 1986.)
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1 BY MR. MILLER :
2 0
Mr. Puckett, first of all, I'd ask you whether you've 3
ever seen the document that's been marked as Applicant's 4
Exhibit 58 before today.
5 (Indicating.)
j 6
A Yes, I have.
7 0
All right.
8 And, in fact, the handwriting, except for the 9
signature in the block " description of nonconformance" i
10
-- and it continues over to the second page of the 11 exhibit -- is your handwriting, isn't it?
12 A
Yes, it is.
()
13 0
Now, the first sentence -- first two sentences of the 14 description of the nonconformance relate to the basis on 15 which you recommended that work be stopped for the 16 stainless steel welding; correct?
17 A
Yes.
18 0
All right.
4 19 The next sentence --
20 MR. GUILD:
I guess for clarity, could 21 counsel identify what he means by "the first two 22 sentences"?
23 BY MR. MILLER:
24 0
Why don't you -- can we agree, Mr. Puckett, that there 25 are other nonconformances identified in this document
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Geneva, Illinoir-60174 (312) 232-0262 i
5534 O
1 beyond just the welding of stainless steel in the 2G 2
position?
3 A
I would say that there's other things here that is 4
related to that, the procedure that was being used.
5 0
All right.
6 Could you just read into the record those portions 7
of the description of the nonconf ormance that relate 8
solely to the welding of stainless steel in the 2G i
9 position without the procedure being properly qualified?
10 A
I'm not sure exactly what you' re asking me to do.
11 0
Well, I'd like you to differentiate, if you could, by 12 identifying for us which portions of your description of O
13 the nonconf ormance relate to the nonconf orming condition 14 of welding stainl ess steel in the 2G position when there 15 was no procedure qualified to that position.
16 A
The Nonconformance Report was written to reflect that 17 the procedure, according to the documentation that was j
18 present, had only been qualified in the SG position --
19 which would cover the positions of flat, vertical and j
l 20 overhead -- but not the horizontal position, the 2G 21 position or 2F.
22 0
Well, the sentence that reads why. the description of the 23 nonconformance -- it reads,."The procedure was qualified 24 pipe to pipe SA312 to SA312."
{}
Does that relate to the position issued --
25 Sonntag Reporting Service, Ltd.
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5535 O
1 A
That relates to the types of material that was used.
2 0
All right.
3 The next sentence reads, " Bimetallic welds SA240 to 4
carbon steel are being made in the field."
5 That doesn't relate to the position --
I 6
A No, it does not.
7 0
-- qualification issue?
8 A
It just relates to the procedure itself.
9 0
All right.
10 And then the last sentence of the nonconformance, 11 the one that appears on Page 2 -- that relates to the 12 welder qualification on the thickness of the material Os 13 that the qualification test authorized them to weld; is 14 that correct?
15 A
Yes.
16 Q
Mr. Puckett, your memorandum to Mr. DeWald and 17 ultimately to the stop-work order that Mr. Rolan issued 18 to the field recommended that all stainless steel 19 welding be stopped; correct?
20 A
That they stop all stainless steel welding, yes.
21 0
All right.
22 But as f ar as the qualification position -- of 23 positions was concerned, the only position in which a 24 stop-work was necessary was the horizontal position; 25 isn't that right?
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Sonntag Reporting Service, Ltd.
ueneva, 111rnois 0u1J4 i
(312) 232-0262
4 i
5536
(
1 A
Well, yes and -- and no.
2 If we can look at the procedure --
i 3
MR. MILL ER :
Certainly.
4 I can tell you you' re the only person in the room 5
who has it.
6 MR. GUILD:
Has that been marked as an 1
7 exhibit?
8 MR. MILLER:
Yes.
It's been marked as l
9 Exhibit 57.
10 A
(Continuing. )
My concern with the procedure was the 11 procedure was qualified by Mr. Ron Vilt, whose weld 12 symbol was 93.
He qualified in only the SG position.
()
l 13 In the back of the procedure is his qualification test 14 form.
15 However, on this it reflects that he is qualified 16 vertical, flat, horizontal and overhead, all positions, 17 and the test was run in the SG position only.
18 It further goes on to say that the test that he 19 took was A312 Type 304 and that he took the test on a 20 three-inch Schedule 40 three-eighths-inch coupon, which 21 gave him unlimited thickness.
22 It was my contention at that time, by looking at 23 this and knowing that a three-inch Schedule 40 pipe with 24 a three-eighths wall that does not give unlimited 25 thickness, that the man who qualified the procedures --
[}
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
5537 0
I the qualification would be considered indeterminate.
2 Q
Mr. Puckett, do you know whether that was the initial 3
qualification of the welder, whose name escapes me?
4 A
I do not know if it was the initial qualification.
5 I know it was a qualification in the procedure and 6
that his name appeared in several of these procedures, 7
reflecting that he was the one that was actually 8
qualifying the procedures.
9 I would only assume that if the man qualified the 10 procedure, that he wouldn't then have to turn around and 11 qualify to the procedure.
12 MR. GUILD:
Could I ask the witness to spell O
13 the gentleman's name, for the record, that he just read 14 from the document?
15 THE WITNESS:
- Ron, R-O-N, V-I- L-T.
16 MR. GUILD:
Thanks.
17 THE WITNESS:
His welder's ID symbol was 93.
18 BY MR. MILLER:
19 0
So that it was based on your evaluation of the welder's 20 qualification that you recommended that all stainless 21 steel welding --
22 A
Not entirely.
23 It was the inconsistencies such as this that made 24 me deem that possibly the whole procedure along with tho
{}
positions that it had not been qualified in and the 25 Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
J 5538 2
(:)
I problems we had with the welders, the inconsistencies 2
with the mag particle testing of stainless steel -- that 3
I thought that the procedure itself could be considered 4
as being indeterminate.
5 Q
Mr. Puckett, isn't it true that under the AWS code, that 6
a welder who performs the procedure qualification test 7
is thereby automatically qualified to that procedure?
8 A
I would say yes.
9 Q
So that Mr. --
10 JUDGE GROSSMAN:
Vilt.
11 BY MR. MILLER:
12 0
-- Vilt, by performing the qualification test for the O
13 Procedure 4.3.14, thereby himself became qualified to 14 that procedure; correct?
15 A
He would be qualified to weld to that procedure, yes.
16 My contention was that him qualifying in the SG 17 position did not qualify him in all positions, as the 18 welder's form, the QA 54 form, reflects, and that the 19 thickness that he qualified on would not give him 20 unlimited thickness, as the weld QA 54 reflects.
21 There could be an explanation here.
If a person 22 qualifies on a groove weld, he is qualified also on 23 fillet welds, all sizes of fillet welds, on unlimited 24 thickness of material.
[}
But if he was only going to be qualified for fillet 25 Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
5539 mb 1
welds, there should be some kind of a reflection on his 2
welder's identification card as well as his weld test 3
forms, reflecting that the man can only do fillet welds.
4 0
Is the reason that there is a thickness limitation on 5
groove welds because the qualification record for the 6
welder is on a three-eighths-inch wall pipe?
7 Is that why there is a -- is that the basis for the 8
limitation?
9 A
No.
10 Your -- the test and the thickness of the material 11 that you run the test on determines the maximum 12 thickness that a man can weld doing a groove weld.
13 If he was doing a groove weld, according to this 14 paper, the QA 54 form, he is qualified to do unlimited 15 thickness groove welds in all positions.
16 He had only run the test in the SG position.
He 17 had done it on a thickness that would, in fact, not give 18 him all thicknesses but just twice the thickness of the 19 material that he had welded on.
20 Q
Do you know whether or not there was any groove welds 21 that actually took place within Comstock's scope of work 22 at Braidwood?
23 A
Yes, there was groove welds being done.
24 0
I'm sorry; for stainless steel.
I beg your pardon.
25 A
For stainless steel?
Sonntag Reporting Service, Ltd.
Geneva, 111imois 60134 (312) 232-0262
5540 1
I'm not at all sure.
2 0
Okay.
3 Well, Mr. Puckett, the stop-work for all stainless 4
steel welding was ordered based on your recommendation; 5
correct?
6 A
Something good came out of it.
7 Q
And you then initiated this NCR, which documented the 8
nonconforming condition; correct?
9 A
Yes.
10 0
And do you know what the disposition of the stainless 11 steel welds that were -- that had been made without an 12 approved procedure was?
O 13 A
I never seen the disposition on the Nonconformance 14 Report.
15 This one doesn' t have a disposition.
16 (Indicating.)
17 I knew that the ultimate disposition or a part of 18 it would be that they qualify the procedure in the 2G 19 position, which would give the man all positions.
20 I was in the process of trying to order the 21 material through the Engineering Department to run this 22 other qualification in the 2G position.
23 Q
Do you have Applicant's Exhibit 51, Mr. Schapker's 24 Inspection Report 8509, up there?
25 A
I don't know if I do or not.
Sonntag Reporting Service, Ltd.
l Geneva, Illinois 60134 (312) 232-0262 i
5541 O
1 Q
The cover letter is dated November 21, 1985.
2 Would you turn to Page 5 of the inspection report?
3 The first paragraph there indicates that the 4
corrective action that was taken was "the removal of 5
noncomplying welds and replacement af ter requalification 6
of weld procedures and welders."
7 MR. GUILD:
The first paragraph under "C,"
8 Mr. Miller?
9 MR. MILLER:
No.
It's at the very top of the 10 page.
11 MR. GUILD:
Thank you.
12 JUDGE GROSSMAN:
The first full paragraph.
7sd 13 MR. MILLER:
Yes.
14 BY MR. MILLER :
15 0
Do you see that, Mr. Puckett?
16 A
Yes.
17 0
would you agree that that was the appropriate corrective 18 action for the nonconforming condition that you 19 identified and for which a stop-work was initiated?
20 A
Yes.
I would say that that would be a good disposition.
21 Q
And to that extent, Comstock, after your departure from 22 Braidwood, didn' t slight any of the safety concerns that 23 you had raised, did they?
24 A
It would have been difficult to do so, as a
{}
Nonconformance Report had been initiated.
25 Sonntag Reporting Service, Ltd.
ueneva, 1111nois ou134 (312) 232-0262
5542 O
1 MR. MILLER:
I don't believe you've answered 2
my question.
3 Would you read the question back?
4 A
(Continuing. )
Evidently, if they, in fact, did this, 5
they done what should have been done, yes.
6 BY MR. MILLER: '
7 0
And so they didn't slight the safety concerns that you i
8 raised; correct?
9 A
On this particular item, no.
10 0
Mr. Puckett, if, in fact, only fillet welds for 11 stainless steel welding took place within Comstock's 12 scope of work at Braidwood, would that have altered the
-]
13 recommendation that you made that all stainless steel 14 welding be stopped?
15 A
Probably not.
16 0
Even though the welder who performed the procedure 17 qualification test would have had the proper 18 qualifications for unlimited thickness; isn't that 19 right?
20 A
Yes.
He would have had in all positions except the 2G 21 position.
22 0
And -- but nonetheless, you still would have recommended 23 that all stainless steel welding --
24 A
Because of other inconsistencies, yes.
25 0
What are those, si r?
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Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
5543 f%
V 1
A As we discussed yesterday, I don't remember all of these 2
inconsistencies now because it's been somewhat over two 3
years.
4 But I mentioned that with the welder's 5
qualification test form that is reflected on the back of 6
the procedure, that there was inconsistencies there and 7
that this particular welder -- until I done a further 8
inspection into all of his documentation, I would 9
consider his qualification as being indeterminate.
10 0
Well, in order to do that, you would have had to look in 11 his welder qualification file; correct?
12 A
Yes.
13 0
And check perhaps other weld qualification tests --
14 welder qualification tests that he had taken?
15 A
Yes.
16 Q
And look at the PTL documentation --
17 A
Yes.
18 0
-- attached to it?
19 A
To do a thorough job, you will take it as far as it will 20 go.
21 Q
Did you do that before you recommended the stop-work?
22 A
I did not have time to do this.
23 I was still in Qualification and running a test 24 facility, and these were things I was doing in the short
{}
periods of time that I did manage to be able to be out 25 Sonntag Reporting Service, Ltd.
Geneva, illinois 60134 (312) 232-0262
5544 O
1 of the test f acility and off of the audits.
2 0
So in this case, you just shortcut the whole process and 3
recommended a stop-work?
4 A
Yes.
5 Q
Would you agree, Mr. Puckett, that if you had had the 6
opportunity to do this research, that it would be a 7
matter of judgment on your part as to whether the 8
conditions were suf ficiently nonconf orming, sufficiently 9
serious, so that a stop-work should be recommended?
10 A
Possibly so.
11 That's why I used the term that I would have 12 considered the welder's qualification indeterminate O
13 rather than reject.
14 Further investigation may have proven that the 15 welder was, in fact, qualified.
16 Q
And, therefore, if you had had the time to do all this 17 research, at the end of that process, you would have 18 exercised your judgment, based on your experience as --
19 A
And the code.
20 0
-- and the code and as a welding engineer at Zimmer and 21 as an inspector, to determine whether or not under the l
22 circumstances, all the circumstances as you understood l
23 them, a stop-work order was appropriate?
24 A
Yes.
25 Q
Mr. Puckett, I'd now like to turn to the issue of Sonntag Reporting Service, Ltd.
j Geneva, Illinois 60134 (312) 232-0262
5545 b,-
1 bimetallic welds, and it's referenced in the Exhibit 58 2
that we just marked for identification.
3 First of all, would you describe for the Board what 4
your definition of a " bimetallic weld" is?
5 A
For the purpose that it was used at Comstock, it would 6
have been -- for the types of materials that they were 7
using, it would have been a stainless steel weld -- a 8
stainless steel component welded to a carbon steel 9
component.
10 0
I see.
11 Did you ever personally observe the welding of a 12 stainless steel component to a carbon steel component O,
13 within Comstock's scope of work?
14 A
No, I did not.
15 0
All right.
16 In other words, this was something that an 17 inspector told you about; correct?
18 A
Yes.
19 An inspector come to me -- and I think it was Mr.
20 Miner -- and he had a weld traveler.
He said he had a 21 weld to inspect in the field that was stainless steel to 22 carbon steel and wanted to know what procedure they 23 should have used to make this weld.
24 0
All right.
25 On the weld traveler document itself, was the
}
Sonntag Reporting Service, Ltd.
Geneva, Illirci s 60134 (312) 232-0262
5546 1
nature of the two components that had been welded 2
together identified?
3 A
He -- I did not look at the document myself.
4 He said that he had a bimetallic weld and asked me 5
what procedure they should have used to make this weld.
6 I told him that -- at that time I said, "We do not 7
have a procedure f or making bimetallic welds. "
His 8
answer was to me, "Well, then, I will write a 9
Nonconformance Report."
10 Now, I don't know if he, in fact, wrote the 11 Nonconformance Report or not.
12 0
Well, as the traveler was issued to the inspector, was 0
13 this the weld inspection report form?
14 A
Yes.
15 Q
Did that weld inspection report form reference the 16 specific portion of the weld procedure that the 17 inspector had used when performing the weld?
18 A
It's -- as I say, I never seen the report.
I don't know 19 what it reflected.
20 0
I was being somewhat more general in my question, Mr.
21 Puckett.
22 That is, as a matter of routine, did the weld 23 inspection reports identify that portion of the Comstock 24 welding procedure that had been used in creating the 25 weld that the inspector was to go out and inspect?
i Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262 i
5547 1
1 A
I'm not at all sure if this was a weld that he was doing 2
a postweld inspection on or if this was a weld that was 3
to be done.
4 My impression was the weld had been installed and 5
he was going to do a postweld inspection on it.
I never 6
looked at the forms, but ordinarily it would have told 7
that -- that they used the stainless steel weld 8
procedure to make this weld if stainless steel was 9
involved.
10 What other procedure they could have used I have no 11 idea, because they had no procedure for making a 12 bimetallic weld.
O 13 0
well, they could have used the carbon steel procedure, 14 couldn't they?
15 A
Not very well unless he was violating it, because all 16 your carbon steel procedures require that you use an 17 E7018 or an E7013 filler material.
18 0
So you didn' t look at the -- you didn't go out and look 19 at the installation in the field with Mr. Miner?
20 A
No, I did not.
I was working on an audit.
21 Q
And you didn't look at the documentation that he had to 22 try to determine what the documentation identified as 23 the procedure that the welder had followed in creating i
24 this bimetallic weld?
25 A
No, I did not.
Sonntag Reporting Service, Ltd.
j Ueneva, 1111nois eu144 (312) 232-0262 1
5548 1
Later that af ternoon when I got through with what I 2
was working on at the time, I held an informal 3
discussion with some of the QC Inspectors in the office 4
space.
I said, "Is there, in fact, bimetallic welds 5
being done in the field?"
6 Several of the inspectors related to me that yes, 7
there was.
They couldn't remember off the top of their 8
head where they were, but that, in fact, there was 9
bimetallic welds being made.
i 10 Q
Do you know a QC Inspector named Danny Holley?
11 A
Yes, I know Danny Holley -- I mean, not real well, but I t
12 do remember Danny Holley.
O 13 Q
He was a Level II QC Weld Inspector, was he not?
14 A
Yes.
15 0
nas he one of the inspectors that you asked at the end 16 of the day whether bimetallic welds were being created?
17 A
I don' t recall if Danny was present or not.
18 Q
But you do remember that Mr. Miner was one of the 19 individuals?
20 A
Mr. Miner was the individual that had the weld form and 21 asked me if we had a procedure for making this weld, and 22 I told him no.
He said he was going to initiate a 23 Nonconformance Report.
24 0
All right.
25 At any time af ter this conversation with Mr. Miner, Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
5549 O
1 prior to the time that you lef t Braidwood, did you have 2
the occasion to go out and look at the location where 3
these bimetallic welds had been created?
4 A
No, I had not.
5 0
All right.
6 Did you have occasion to review any documentation 7
which indicated that a bimetallic weld had been created?
8 A
No, I did not.
I was working in the test facility.
9 0
All right.
10 Would you agree that Mr. Holley is a knowledgeable 11 and competent Level II Weld Inspector, as f ar as you 12 knew?
O 13 A
Prom the associations I had with him, I would say yes.
14 0
In this proceeding, Mr. Puckett, Mr. Holley testified 15 that there were no bimetallic welds made within 16 Comstock's scope of work at Braidwood.
17 MR. GUILD:
That's not exactly what he 18 testified.
He said within his knowledge.
19 BY MR. MILL ER :
20 0
Obviously, as far as he knew --
21 A
Basically I think what he was saying was that he hadn' t 22 witnessed any.
23 0
And --
24 A
And as I said, I hadn' t witnessed any.
25 0
And Mr. Schapker, the NRC inspector who investigated Sonntag Reporting Service, Ltd.
Geneva, 1111Ticis 60174 (312) 232-0262
5550 0
1 this, went out in the field and he couldn' t find any, 2
cither, could he?
3 A
Well, I don't know if he went into the field or not.
4 He said that he found no evidence that they had 5
done a bimetallic weld.
However, in another portion of 6
this, he mentioned that he had been reviewing weld rod 7
withdrawal forms and that he had found weld rod 8
withdrawal forms reflecting E309 rod, which, in fact, in 9
most cases -- well, in all cases would be used to do a 10 stainless to carbon steel bimetallic weld.
11 Q
Mr. Puckett, if we could turn to Page 5 of Applicant's 12 Exhibit 51, which is Mr. Schapker's report, after you 13 made the statement to the NRC that bimetallic welds had 14 been made, Mr. Schapker came and interviewed you at your 15 home in Ohio, did he not?
16 A
Yes, he did.
17 0
atl right.
18 Exhibit 51 states that you -- in that interview 19 that you informed the inspector that the welds you were 20 referring to were stainless steel junction boxes within 21 the reactor building being welded to carbon steel j
22 conduit.
23 Is that an accurate reflection of what you told Mr.
24 Schapker?
25 A
It has been a long time since I talked to Mr. Schapker.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
5551
(_)
1 We discussed this, and either he mentioneo...e fact 2
that the junction boxes sometimes was involved in 3
stainless steel or it could have been that I said maybe 4
one of the inspectors had said something about the 5
junction boxes.
6 I don't recall at this time.
It's been a long time 7
since I talked to Mr. Schapker as well.
8 0
And it appears f rom this inspection report Mr. Schapker 9
actually went out and was able to identify the junction 10 boxes f rom your description of them; correct?
11 A
Yes, but that does not necessarily mean that only the 12 junction boxes had relevance to bimetallic welds.
There O
13 could have been other things.
14 I think I told Mr. Schapker at the time that I 15 wasn't sure what components was involved and that what I 16 was -- when I was referring to bimetallic welds, it was 17 f rom the reports that Mr. Miner had given me and the 18 reflection that he was going to write a Nonconformance 19 Re po r t.
20 Q
Now, as you sit here todsy, the only basis that you have 21 for believing that these bimetallic welds were created 22 is that E309 weld rod was used in completing certain 23 stainless steel welds; right?
24 A
No, sir.
25 0
What is your other basis?
Sonntag Reporting Service, Ltd.
Geneva, 111iTTO1 s 00134 (312) 232-0262
5552
!(:)
1 A
The QC Inspectors.
2 JUDGE GROSSMAN:
Mr. Miller, he already 3
indicated that Mr. Miner told him that, that other 4
4 inspectors confirmed that and that there were also i
5 withdrawals of the 309 rods.
l 6
MR. MILLER:
Right.
l
]
7 I did misstate your position, and I apologize.
I 8
BY MR. MILLER:
9 0
You personally knew that E309 weld rod was being 10 withdrawn for stainless steel welding; correct?
11 A
I had, in a review, seen some rod slips in the weld rod 12 withdrawal file, but it was just a glance; the f act that
()
13 E309 rod had been used.
14 N ow, I don't recall on the heading of the rod slip 1
j 15 what component that it may have been used on.
1 16 Q
And it's a fact, is it not, that E309 is a weld rod that I
17 is suitable when joining stainless steel to stainless 1
i 4
18 steel?
1 j
19 A
Yes.
You can use it for either-or.
i 20 0
So that as f ar as you can recall today, the E309 weld 21 rod that you observed on these weld rod withdrawal feras i
]
22 may have, in f act, been used to join stainless steel to i
23 stainless steel; right?
24 A
Possibly so.
25
[}
It's even reflected on the weld procedure that we 1
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262 1
__-.,---,,---y
--,y.---,,.__w,.
y___..
,,_._,,_.,__.._m.,,-.-,,,__.~-,,_..~.,,--,s,mm-,-
,,,,w
,_w.--_%,_.,..
l 5553 l
0 1
have here that they completed that weld procedure 2
stainless to stainless using 309.
It is an acceptable 3
practice.
4 However, going by what Mr. Miner had said and what 5
the other inspectors had said about bimetallic welds 6
being done in the field, I was concerned with it.
t 7
0 Okay.
8 And, in fact, in Applicant's Exhibit 5 8, that was 9
another sentence that you wrote up with respect to the 10 nonconf orming conditions that you observed --
1 11 A
Yes.
12 0
-- with respect to stainless steel?
~
13 Do you know, Mr. Puckett, whether you personally 14 documented this in any other fashion with respect to the 15 issuance of another Nonconformance Report or any other 16 documentation?
17 A
Possibly in personal notes or something of that nature.
18 Otherwise, no.
19 Q
All right.
20 And I think you testified earlier that once you had 21 written it down in a Nonconf ormance Report, it had to be 22 dispositioned; correct?
23 It couldn't be ignored; right?
24 A
I would have hoped that it would have been
{}
dispositioned, yes.
25 1
Sonntag Reporting Service, _ Ltd.
ueneva, 1111nois eulse (312) 232-0262
5554 1
I don' t know that it was.
2 MR. MILL ER :
I'd like the Reporter to mark as 3
Applicant's Exhibit 59 for identification -- it's the 4
same NCR that we've been looking at.
It's a later 5
version.
It's NCR 3145.
6 (The document was thereupon marked 7
Applicant's Exhibit No. 59 for 8
identification as of June 25, 1986.)
9 JUDGE CALLIH AN:
What's the nonconformance 10 number, please, Mr. Miller?
11 MR. MILLER:
It is the same one as the 12 preceding one, Judge Callihan; that is, 3145.
I
(
13 apologize f or this copy.
14 JUDGE CALLIH AN :
Thank you.
15 BY MR. MILL ER :
16 Q
Mr. Puckett, have you ever seen this document before --
17 A
No, sir.
18 0
-- in the f orm that it exists?
19 A
No.
20 0
All right.
21 There's a line drawn through the sentence that 22 ref ers to bimetallic welds, is there not?
23 A
There appears to be, yes.
24 0
And do you recognize the initials in the lef t-hand 25 margin?
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
5555 O
1 A
No, I do not.
2 0
Do you know whether or not Mr. Miner was ever asked to 3
identify the bimetallic welds that he had observed by 4
any other person in Comstock management or supervision?
5 A
No, I do not.
6 0
Mr. Puckett, I'd now like to turn to the subject of weld 7
preheat of components.
8 First of all, could you describe for the record 9
what " weld preheat" is?
10 A
Well, depending on the thickness of the material' that 11 you' re welding on -- it depends on whether this material 12 will require that you use localized heating to preheat O
13 this metal prior to welding.
14 In the AWS, dealing with carbon steel, you preheat 15 up until an inch-and-a-half material requires that you 16 don't have to preheat; that the material be at any 17 temperature 32 or above.
l l
18 After an inch and a half, it requires that you use 19 localized heating to preheat this material before 20 welding.
21 0
All right.
1 22 Now, I'd like you to turn once again to Applicant's 23 Exhibit 51 for identification, which is Mr. Schapker's 24 inspection report, and would you look at Page 9, please, 25
{}
Allegation g.
l l
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
5556 1
Mr. Puckett, first of all, is that an accurate 2
reci ta tion, if you will, of your concerns with respect 3
to the preheat issue?
4 A
Yes.
5 Q
Now, do you still have in f ront of you Applicant's 6
Exhibit 11, which is the -- I'm sorry; I've given you 7
the wrong number -- Applicant's Exhibit 10, which is 8
Revision C to Procedure 4.3.3?
9 A
May I say something about this Item 9 here?
10 Q
Yes.
11 A
The first paragraph up there where it's saying, " Welds 12 were made without the required preheat" -- I don' t O
13 believe that was exactly my words, 14 I said that there was welds that had been made that 15 the preheat could not be verified.
l 16 0
Okay.
17 Other than that change, is this an accurate 18 characterization --
19 A
Yes.
20 0
-- of your concern?
21 Now, Applicant's Exhibit 10 --
22 A
Which is what?
23 0
It's the Revision C to Procedure 4.3.3.
24 (Indicating.)
{}
If you turn to Paragraph 3.8.4, which is f ound on 25 Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
5557 1
Page 7 of 11, that's where the preheat requirements are 2
found, is it not?
3 A
Yes, it is.
4 0
All right.
5 Now, how did you become aware that there were welds 6
that had been made for which the preheat could not be 7
verified?
8 A
During the period of time that I was at Braidwood, they 9
were doing postweld inspections.
They were doing --
10 trying to catch up on the backlog of work.
11 These welds had been done weeks and months prior to 12 the inspection being perf ormed on them.
13 I had an' inspector come to me, and he says, "I have 14 a weld in the field where we have an attachment to a 15 component greater in thickness than an inch and a half, 16 and I cannot verify that this weld was preheated prior 17 to the welding, as we' re doing a postweld inspection on 18 it and no one was there when the actual welding was 19 taking place."
20 0
What was your recommendation, if any, to that inspector?
21 A
My recommendation to him was at the time that he should 22 write something up on this if he didn't feel comfortable 23 with the inspection.
24 I said he could write a memo reflecting that -- his
(~}
25 concerns, or he could document it on a Nonconformance j
s_-
1 Sonntag Reporting Service, Ltd.
Geneva, illincts 60134 (312) 232-0262
)
5558 O
1 Report.
2 0
And to your knowledge, was that done?
3 A
I think that it was.
I'm not -- not at all sure, but it 4
seems to me that he, in fact, did write some type of a 5
document on it.
6 0
Well --
7 A
The reason that I -- yes.
8 In fact, I'm sure now that there was a 9
Nonconformance Report written on it, because later that 10 evening or the next morning, the engineer from Comstock 11 Engineering came to me and said, "We have this problem.
12 We can't verify that we have preheated these welds when 13 they were welded.
How should I disposition this 14 Nonconformance Report?"
15 It was my suggestion to him that they do further 16 inspections on the welds in the field that were 17 installed, such as a mag particle inspection or an 18 ultrasonic inspection, at:d that they qualify a procedure 19 without preheat, reflecting that a sound weld could be 20 made on this thickness without the preheat.
21 MR. MILLER:
Okay.
22 Let me just focus, if I might, on the -- the 23 nonconforming condition that an inspector came to you 24 about.
}
I'd like to mark as Applicant's Group Exhibit 60 a 25
'l Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
5559 1
set of nonconf ormance reports.
2 The first is a Comstock Nonconformance Report No.
3 3 88, dated October 23, 1981.
4 The next is a Comstock Nonconformance Report 2552, 5
dated May 22, 1984.
6 The next is a Comstock Nonconformance Report 2536, 7
dated June 13, 1984.
i 8
The next is a Comstock Nonconformance Report 2571, 9
dated June 19,
'84.
i 10 The next is a Comstock Nonconformance Report 2572, 11 dated June 19, 1984.
12 And the final one is a Comstock Nonconformance 13 Report 3423, dated October 12, 1984.
14 (The documents were thereupon marked 15 Applicant's Group Exhibit No. 60 for 16 identification as of June 25, 1986.)
17 MR. GUILD:
Mr. Chairman, might I suggest 18 that if Mr. Miller anticipates a long line on these 19 documents, that a break might be appropriate?
20 JUDGE GROSSMAN :
I'm sorry.
I didn' t hear.
21 MR. GUILD:
May we take a break at this time 22 if Mr. Miller expects a long line of questioning?
23 MR. MILLER:
I really don't expect a long 24 line of examination on this, Mr. Chairman.
I'd like to 25 persist.
(]}
Sonntag Reporting Service, Ltd.
Geneva, liliMois 60134 (312) 232-0262
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1 If you'd like to take a break, it's satisf actory to 2
me, but we've only been going an hour and a quarter.
3 JUDGE GROSSMAN :
If you are going to ask 4
questions on it, there are a number of documents.
I 5
think the witness ought to be able to read through them 6
and see what they are.
7 MR. MILLER:
Fine.
(
8 JUDGE GROSSMAN:
So why don't we take a 9
ten-minute break at this point.
10
( WHER EU PON, a recess was had, after which i
11 the proceedings were resumed as follows:)
12 JUDGE GROSSMAN :
We're back in session.
O 13 Mr. Miller?
14 MR. MILLER:
Thank you.
i 15 BY MR. MILLER:
16 0
Mr. Puckett, can we agree that f rom the NCR's that are 17 before you that have been marked as Applicant's Exhibit 18 60 for identification, that there was identification of 19 inability to verify that preheat had occurred, as early 20 as October of 1981?
21 A
I never really looked at all the dates on these.
I was 22 just reflecting that, in fact, there had been reports 23 made that preheat had not been identified --
24 0
Well --
25 A
-- or verified.
[}
Sonntag Reporting Service, Ltd.
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5561 1
Q Had not been verified.
2 Now, your concern was not that inspectors were 3
somehow ignoring this requirement, was it?
4 A
No, si r.
5 Q
Because looking at the NCR's that were generated in May 6
and June of 1984 into July, there were, in fact, 7
Nonconf ormance Reports being generated, again during 8
your tenure at Braidwood, that identified this 9
nonconf orming condition; correct?
10 A
Yes.
1 11 Q
So the inspectors were doing what they were supposed to 12 do, and the nonconformance would have to be closed out?
O 13 A
Yes, they would have to be closed out eventually.
14 JUDGE GROSSMAN:
Excuse me, Mr. Miller.
15 There are none that I see in July; just in May and 16 June.
17 MR. MILL ER :
I'm sorry.
That's the one that 18 we took out, which was 2944.
I'm sorry.
19 JUDGE GROSSMAN:
Okay.
20 If you want it in, you' re entitled to have it in.
21 MR. MILLER :
I know I am.
22 No.
23 JUDGE GROSSMAN:
Okay.
24 BY MR. MILL ER :
25 Q
Now, I think you stated that you had recommended that a Sonntag Reporting' Service, Ltd.
Geneva, Illinois 60134 i
(312) 232-0262
5562 0
1 procedure be developed that would qualify these welds 2
without preheat; is that correct?
3 A
Yes, si r.
4 0
That is, regardless of the thickness of the material, 5
there would be no necessity to preheat the material 6
prior to the time the welding operation took place?
7 A
If you qualified a procedure of the required thickness 8
and you done the additional tests, the mag particle test 9
or the ultrasonic test, of the welds that had already 10 been installed where preheat could not be verified, 11 this, I would think, would be a suitable corrective 12 action.
O 13 0
All right.
14 So you took steps to begin the process by which 15 such a procedure could be qualified; correct?
16 A
Yes, I did.
17 0
And those steps included acquiring the material of the 18 proper thickness for a welder to perform a weld 19 qualification procedure test on; right?
20 A
Yes.
21 Q
All right.
22 You, at that point in time, for Comstock at 23 Braidwood, were overseeing the weld test proof, were you 24 not?
25 A
Yes.
I -- I accepted that as part of my
{)
Sonntag Reporting Service, Ltd.
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(312) 232-0262 e
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0-g-
w nm
5563 O
1 responsibilities.
2 0
And the location where these procedure qualification 3
tests would take place?
4 A
That is where they were to take place, yes.
5 0
All right.
6 And af ter you procured the material for this test 7
without preheat, did you assign a welder to perform the 8
test?
9 A
I -- no, I did not.
I did not precure the material, i
10 The engineer did.
He came to me and asked me what 11 types of material would be needed.
12 0
I see.
O 13 And do you remember the name of the engineer?
14 A
No, I do not.
15 0
New, can you recall the approximate date that the 16 engineer made this request of you?
17 A
I can't -- I can't recall the dates.
18 0
What was the next thing that happened with respect to 19 this procedure, as far as you can recall?
20 A
He Pame and asked my opinion and recommendation on 21 diep4 u aioning the Nonconf ormance Report.
22 I told him what I thought would be a suitable 23 disposition, which included the f act that we should 24 qualify the procedure without preheat.
25 He asked me for a list of materials.
I told him Sonntag Reporting Service, Ltd.
Geneva, illinois 60134 (312) 232-0262
5564 (2)-
1 that I would get it for him.
He was to get the material 2
and have the coupons cut f or welding f or qualifying the 3
procedure.
i 4
0 As I -- the next thing that happened, as far as you a
5 knew, was that you were presented with the coupons 6
already welded together by this same engineer; is that 7
correct?
8 A
I don' t know who welded them together, 9
I know that I was called to -- called to the 10 fabrication shop and presented four coupons that were 11 marked 1G, 2 G, 3G and 4G that were completed and told, 12 "This is the procedure.
We done it without preheat, and O
13 now we would like to have them cut and etched and 14 inspected."
15 0
Who -- was this the same engineer that --
16 A
The same engineer.
I 17 0
Okay.
j 18 What did you tell him?
19 A
I told him -- I said, "We can't do it this way.
We have 20 to have verification of all these items when a procedure 1
j 21 is being run, such as the actual preheat," you know, 22 "the welding of the material, the voltage, - the amperage 4
23 and the type of electrode that was used and witness the 24 fact that the man had actually welded in the positions 1
25 that were required. "
j Sonntag Reporting Service, Ltd.
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1 Q
In shor t, it was just like any other weld qualification 2
procedure test:
QC had to be involved; right?
i 3
A QC should have witnessed all of these things and 4
recorded them.
5 0
And so there was --
6 A
No records of anything on these coupons.
7 Q
No documentation and no indication of any --
8 A
None that the engineer could produce for me.
9 0
All right.
10 What did you do then?
11 A
I told him that we didn't qualify procedures that way; 12 that he would have to get new material and that we would O
13 have to rerun this procedure with QC as a witness and 14 document all the essential variables that were being 15 used.
16 Q
All right.
17 And did you then take steps to get additional 18 material that could be used to run a further 19 qualification test?
20 A
The engineer, I assume, did.
I was terminated before 21 this was ever done -- or before I was involved in any 22 more of it.
23 0
Okay.
24 Mr. Puckett, do you know whether there are many
(~
25 welds within Comstock's scope of work that involve v)
Sonntag Reporting Service, Ltd.
Geneva, 111iE5is 60134 (312) 232-0262
5566 O
1 attachments to materials that would require preheat 2
under the provision of --
3 A
I have no idea.
4 I would only think hangers that were attached to 5
heavy beams or to heavy embedments, but I never done any 6
inspection on any myself.
7 0
okay.
8 And based on your experience, would you expect that 9
that would be a relatively small number of the welds 10 that Comstock performed?
11 A
I have no idea how many there would be.
12 In different locations you would probably run into 13 more of these -- in a suppression pool or in the 14 structural steel, the heavy beams and things and 15 anywhere else -- so it would depend on the location.
16 0
That is, the location of the cable pan or conduit 17 hanger?
18 A
Yes.
19 0
Did anyone in Comstock QC -- well, did you report this 20 engineer to anyone in Comstock QC management?
21 A
I mentioned it to Irv that he had called me down to the 22 fabrication shop and had presented me with four 23 completed test coupons and wanted me to have them 24 tested.
(
25 Q
Did Mr. DeWald say, "Well, you should have accepted l
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
I 5567 i
I f"\\
U 1
th em "?
2 A
No, he did not.
3 0
He agreed with you, didn' t he, that it was totally 4
improper?
5 A
Yes.
He got quite a chuckle out of it, too, because he 6
knew that this was the incorrect way of doing things.
7 0
So as f ar as you know, these coupons were never accepted 8
af ter you had said they should be rejected?
9 A
I have no idea.
10 I mean, you know, it was a very short time af ter 11 that that I had no dealings with these particular 12 coupons.
It wasn't too f ar af ter that that I was 13 terminated.
14 Q
I see.
15 Well, I know that the last NCR in this package --
16 that is, NCR 3423 -- is about six weeks -- dated six 17 weeks af ter you lef t Braidwood.
18 (Indica ting. )
19 If you look at the third page of the NCR 3423, 20 there's an identification of certain welds that are to 21 be removed.
22 Do you see that?
23 A
Yes, I see it.
24 Q
All right.
25 By the way, was Mr. Bradf ute, whose name appears at Sonntag Reporting Service, Ltd.
ueneva, Illinois 0u144 (312) 232-0262
5568 O
1 the top of that page -- was he the engineer that you --
2 A
He may have been.
I referred to him -- I can recall now 3
-- as " Dave."
His name is David, so it may have been 4
i 4
him.
5 0
Would you agree that the statements that are found on 6
Page 3 of this NCR 3423 are an appropriate way of j
7 dispositioning welds for which preheat could not be 8
verified?
j 9
MR. GUILD:
The statements at the top of the ii 10 page?
1 11 MR. MILL ER :
Yes, yes.
j i
12 A
Yes, it would be.
(
4 13 However, he is reflecting here that, "The f ollowing 14 supports attached to steel thicker than three inches."
15 Material thicker than an inch and a half requires i
16 the elevated preheat, so I don't see where that has been 17 addressed here.
He is reflecting materials of a greater 18 thickness than three inches.
19 BY MR. MILLER:
20 0
Can you tell, by looking at the weld qualification --
21 welding procedure qualification test records that are 22 also a part of this exhibit, whether they deal with 23 materials up to three inches?
24 A
(No response.)
25 0
That is, Mr. Puckett, if we look at the first diagram,
[}
?
i Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 i
(312) 232-0262 i
..___.--__,,..,..-,-.__.__.._-._-.__,._._,-._m...
5569 O
1 the welding procedure qualification test record, the 2
dimension for the steel that's shown in the joint detail 3
-- the maximum dimension is three inches, isn't it?
4 A
Yes, si r.
5 0
And down in the lower lef t-hand corner, the base metal 6
temperature is shown as 56 degrees Fahrenheit; correct?
7 A
Yes, si r.
8 0
That indicates, does it not, that there was no 9
preheat --
10 A
Yes, si r.
11 0
-- applied?
12 And does that welding procedure qualification test
(:)
13 record, assuming that it was properly performed and 14 accepted by Pittsburgh Testing Laboratory, indicate that 15 materials up to three inches in thickness were qualified 16 without any preheat?
17 A
Yes.
18 0
And this is the procedure -- or the approach to this
]
19 problem that you had originally suggested; correct?
20 A
Yes.
This would have done it if they were only doing 1
21 fillet welds to the procedure.
4 22 However, I would want to check the material that i
23 was used for the procedure, an A588 material.
I think 24 we have a steel there.
I'm sure that it's listed in AWS 25
[}
Dl.1, but I know that it is of a much greater strength Sonntag Reporting Service, Ltd.
Geneva, Illimois 60174 (312) 232-0262
5570 1
than the 50,000 psi that had been mentioned previously.
2 I would want to check into that.
I would be 3
concerned with that type of material used for the 4
procedure qualification at this time.
5 0
That they used A588?
6 A
Yes, because most of the welding that was to be done in 7
the field was going to be done to A36 or A500.
8 MR. GUILD:
Mr. Miller, I notice that the 9
document the witness has just been referring to appends 10 a Commonwealth Edison Company Nonconf ormance Report as 11 well.
12 MR. MILL ER :
Yes, that is correct.
13 I'd like to have just a second, please.
14 BY MR. MILLER :
15 0
Mr. Puckett, let's turn to that portion of the NCR that 16 includes a Commonwealth Edison NCR.
17 A
Which one would that be?
18 0
Well, it is about five pages f rom the back of the NCR, 19 and it's on a Commonwealth Edison form.
20 (Indicating.)
21 A
Is it the one dated October the 17th,1984?
22 0
Well, the one that I'm looking at has the 23 nonconformance --
24 A
Okay.
I think I've got it.
25 0
October lith is the date in the right-hand -- the first
(~}
(-
I Sonntag Reporting Service, Ltd.
Geneva, Illinois 00134 l
(312) 232-0262
5571 (h
U 1
date on the right-hand side of the page.
2 Mr. Puckett, do you know under what circumstances a 3
Commonwealth Edison Company NCR is issued for a 4
nonconf orming condition that's observed within 5
Comstock's scope of work?
6 A
I've never seen this.
7 I have no -- in fact, I' ve never looked at any 8
Nonconformance Reports by Commonwealth Edison during my 9
tenure at Braidwood.
10 Q
Okay.
11 Can we agree that the Commonwealth Edison 12 Nonconformance Report appears to address the same O
13 preheat issue?
14 THE WITNESS:
I haven't read it.
15 MR. MILLER:
Okay.
I'm sorry.
16 TH E WITN ESS :
Can I read it?
17 MR. MILL ER :
Certainly.
18 A
It seems to be addressing the same problems.
19 MR. MILL ER :
Then if you'd look at the last 20
-- the next two pages af ter the Commonwealth Edison NCR, 21 there's a letter from Sargent & Lundy.
If you'd just 22 look that over quickly --
23 TH E WITN ESS :
Now, the question?
24 BY MR. MILLER:
i 25 0
That letter also deals with this --
Sonntag Reporting Service, Ltd.
Geneva, Illinc~is 60134 (312) 232-0262
\\
5572 0
1 A
It addresses the same type of thing, yes.
2 0
Does that indicate to you, Mr. Puckett, that there was 3
appropriate attention paid by Comstock, Edison and 4
Sargent & Lundy to this question of welds being 5
performed on material where the preheat requirements 6
could not be verified?
7 A
It indicated to me that my concerns during the period of 8
time that I was there was finally looked into, yes.
9 Q
Well, your concerns, though, sir, were really only 10 related to the fact that these coupons had been created 11 witnout the proper Quality control involvement?
12 A
And that welding had been done in the field without the
()
13 verification of preheat.
14 Q
Right, and that had been documented properly --
15 A
Yes.
16 0
-- on NCR's, and NCR 3423 indicates that the process was 17 played out in some detail involving both Commonwealth 18 Edison Company and Sargent & Lundy; right?
19 A
Yes.
20 0
All right.
21 Just returning for a second to your concern about 22 the f act that these procedures were qualified on A588 23 material --
l 24 A
Yes.
25 0
-- do you have the AWS D1.1 code?
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
5573 O
1 A
I have it, yes.
2 0
Would you turn to Page 32 of Applicant's Exhibit 12?
3 Can we agree that this table establishes the 4
preheat and interpass temperatures for groups of 5
materials?
6 A
Yes.
7 0
And it's a fact, is it not, that in the second block, 8
under the heading " steel specification," that A36, A500 9
and A588 are all grouped together?
10 A
I see in here, yes, that they have them all in this one 11 block, reflecting the preheat.
12 0
So that qualification of a weld on one type of material O
13 without preheat would qualify all materials within that 14 group; right?
4 15 A
This deals strictly with preheat.
16 I would question the validity of the procedure 17 itself using the A5 88 material until I could do some 18 research.
19 I'm not sure, without doing research into the code, 20 if the qualification on A588 would also qualify a welder 21 to do the welding, the same type of welds, on Grade A500 22 or A36.
I would want to look at this to see.
23 0
At the time that you lef t Braidwood, Mr. Puckett, did 24 you have any reason to believe that Comstock was not 25 properly following up the NCR's that had been written Sonntag Reporting Service, Ltd.
Geneva, 111ino1s-60174 (312) 232-0262
4 5574 O
1 which identified the inability of the QC Inspector to 2
verify tr.at preheat had taken place?
3 A
At the time I left Comstock, I was only aware of the one 4
Nonconf ormance Report that had been written..
5 Q
And as f ar as you knew at the time, it was being 6
followed up properly; right?
7 A
As far as I knew at the time, there was material on 8
order to run a qualification procedure which would be 9
verified by the QC Department.
1 10 Q
And that would be in accordance with what you understood 11 to be the requirements and with your own recommendation; l
12 right?
(2) 13 A
Yes.
14 Q
N ow, let's move on, Mr. Puckett, to another allegation 15 regarding weld procedures.
16 JUDGE GROSSMAN :
Excuse me, Mr. Miller.
17 I do note that the first NCR was dated 10/23/81 and 18 that it wasn't dispositioned until October 17, 1984, or 19 around that time.
20 MR. MILL ER :
I think it's actually -- the 21 corrective action was not completed until May 22nd of 22 1985, when the Commonwealth Edison NCR was closed out.
23 JUDGE GROSSMAN:
Okay.
I just want to note 24 that.
You may want to address that later, but fine.
\\
]
[}
25 MR. MILLER:
I take it that what you're j
Sonntag Reporting Service, Ltd.
Geneva, I111no2s 60134 (312) 232-0262
5575
)
1 suggesting is that we may want to address the interval 2
that took place between the time the nonconf orming 3
condition was identified and the time it was closed out?
4 JUDGE GROSSMAN :
Yes.
5 I mean, you' re making a point of the f act that, you 6
know, the NCR's were dispositioned as a matter of 1
7 course, I believe standard operating procedure; but it 8
does seem to me as though that is a lengthy time.
9 But, you know, that's up to you to determine whether you want to add something to the record on that.
10 3
11 MR. MILL ER :
Thank you.
12 BY MR. MILL ER :
O 13 Q
Mr. Puckett, could you turn now to Page 20 of the 14 Applicant's Exhibit 51, which is Mr. Schapker's report?
15 A
What page again, sir?
16 Q
Page 20.
At the very bottom of the page, it's 17 Allegation t.
18 First of a?.1, is the description of your concern 19 accurately expressed in Allegation t on Page 20 of 20 Exhibit 51?
21 A
It's -- it's pretty close.
22 The allegation that I made was that L.
K.
Comstock 23 was qualifying welders utilizing a General Electric 24 procedure; and that procedure, as the stainless steel 25
}
weld procedure, had only been qualified in the SG Sonntag Reporting Service, Ltd.
GenevaW1-inois 601M (312) 232-0262
5576 O
1 position and was not qualified in the 2G position.
2 0
That doesn' t sound real close to --
3 A
I took care of that while I was there, okay?
4 I qualified --
5 JUDGE GROSSMAN:
Excuse me.
I think we may 6
be looking at the wrong allegation here.
7 MR. MILLER:
I'm not certain, either, your 1
8 Honor.
9 JUDGE GROSSMAN:
Oh, okay.
10 BY MR. MILLER :
11 0
We're talking about the General Electric procedure 12 that's referred to at the bottom of Page 20; correct?
O 13 A
Yes.
That deals with the welding of aluminum.
14 0
All right.
15 You said that the characterization of the 16 allegation wasn't quite correct, and then you started to 17 discuss the qualification in the position --
18 A
Well, I was -- I was trying to explain this particular 19 allegation.
20 If I might explain to you, the way I got involved 21 with this is I was asked to qualify a welder to weld 22 aluminum.
I pulled the procedure out of the book that 23 was going to be used for this qualification and noted 24 first that it was not a Comstock procedure but a General
[
Electric procedure.
25 Sonntag Reporting Service, Ltd.
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1 1
This didn't cause me concern, because you could use 2
another person's procedure, you know, if everybody is 3
agreeable that it's a good procedure.
4 However, in setting the welder up to do the test 5
and looking at the procedure so I would be familiar with 6
it, I noted that this procedure, the General Electric 7
procedure, had only been qualified in the SG position, 4
as had been the stainless steel weld procedure that we 8
i 9
discussed earlier, 10 I reported this to Mr. DeWald, and he asked me what j
J 11 we should do about it.
I said, "Let's go ahead and 12 qualify the 2G position as well and make this procedure O
j 13 okay."
l 14 There was no Nonconf ormance Report written on this t
15 for the simple reason that we found out a little later 16 that everything that was being done with this procedure 17 was nonsaf ety-related.
18 Q
So under Comstock procedures, it was not appropriate to 19 initiate a Nonconformance Report for that condition; 20 correct?
21 A
I would say no.
We just kept it in-house and qualified 22 the welders in the additional position and the 23 procedure, I might say.
24 0
Can we agree that the General Electric procedure that's
/}
referred to in the allegation only relates to 25 Sonntag Reporting Service, Ltd.
ueTieva, 1111Mi870I3 4 (312) 232-0262
l 5578 l ()
1 nonsaf ety-related welding within Comstock's scope of j
2 work?
3 A
It has turned out that that's the way it is, i
.i 4
At the time that I made my report, I was not sure l
l 5
what other components of aluminum may have been welded i
6 on.
i 7
0 All right.
You say when you made your report.
4 8
That is, when you discussed this with Mr. DeWald?
F 9
A To Mr. DeWald to -- and to Mr. Schapker of NRC.
10 0
I see, okay.
.I l
11 So it wasn't until af ter you lef t Braidwood that 12 you learned that this procedure related only to saf ety J O 13
-- nonsaf ety-related equipment?
f 14 A
Yes.
f 15 Ordinarily you would follow up on these things 16 right away; but with the schedules that I had in my 1
l 17 qualification and running the test facility and 18 qualifying the welders and performing audits and l
19 changing procedures and doing document reviews, I never 20 had time to follow up on some of these things as I might 3
21 have liked to.
i 22 0
Well, Mr. Puckett, let me understand.
23 At the time that you were at Braidwood, you didn't l
24 know whether it was safety-related or not, but again you i
25 did not issue a Nonconformance Report; correct?
Sonntag Reporting Service, Ltd.
l Geneva, Illinois 60134 (312) 232-0262
5579 Cl) 1 A
No, I did not.
2 0
Notwithstanding the f act that, as far as you knew, 3
welding was taking place on saf ety-related components?
4 A
Well, I knew the components that they were working on 5
were nonsaf ety-related.
6 I did not know if there possibly were other 7
components using those materials that may have not been.
8 0
I see.
i 9
So because you knew that at least the components 10 that you were aware of were not safety-related, again 11 you exercised your judgment and didn't issue a 12 Nonconformance Report?
-'(
13 A
Well, as I've mentioned before, I was totally the only 14 one that was involved with this particular thing f rom --
i 15 from Comstock.
No other weld inspectors were involved 16 with it or participating in it.
17 It was company policy at that time that until you 18 had received your qualification, you did not initiate 19 Nonconf ormance Reports.
j 20 In talking to Mr. DeWald and explaining the 1
21 situation we had, it was my opinion that if a i
l 22 Nonconformance Report was warranted, that he would have i
23 written it.
24 0
Well, did you discuss specifically with Mr. DeWald
)
}
whether a Nonconformance Report should be initiated?
25 Sonntag Reporting Service, Ltd.
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J 1
i 1
A No, I did not.
2 0
Did Mr. --
i 3
A He was the QC Manager, and I thought that would be his t
4 decision.
5 0
Well, you understood, did you not, under the procedures 6
that it was the responsibility of the individual 7
identifying the nonconforming condition to initiate a
)
8 Nonconformance Report?
4 l
9 A
I think that I have explained that they had company 10 policy that up until such time that you were qualified, i
11 you were not to initiate one.
12 0
In other situations, as we've identified on the record
!(:)
{
13 previously, Mr. Puckett, when that situation occurred, 14 you f ound a QC Inspector who would sign a Nonconf ormance I
l 15 Report?
j 16 A
Yes.
(
I 17 As I mentioned, before when I got the 18 Nonconf ormance Reports initiated, they were involved I
19 with the -- the things that we were working with at that 1
3 t
1 20 time.
21 This aluminum I was working by myself.
I had no 22 other inspectors there that knew exactly what we were l
23 doing and that I was requalifying these welders.
24 0
Mr. Puckett, if you had believed that this was a matter j
25 that involved a nonconf orming condition in saf ety --
l Sonntag Reporting Service, Ltd.
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1 A
I did not say that.
2 0
No, si r.
Let me --
3 JUDGE GROSSMAN:
Well, Mr. Miller, I think 4
we've exhausted this area, too.
5 From what I understand, the witness knew that there l
6 was nonsaf ety-related work being done.
He had no idea 7
whether there was any saf ety-related work.
He was not 8
in a position to initiate the NCR himself.
He discussed 9
it.
10 I would assume if he had instigated an NCR on
)
11 nonsaf ety-related work, we'd be questioning him about i
12 why he did it with nonsaf ety-related work.
)
13 I think we understand what the position is.
14 Everything else now is just argument.
15 MR. MILL ER :
I don' t believe I'm arguing with 16 the witness, Judge Grossman.
17 What I'm trying to determine are the circumstances 18 under which Mr. Puckett was able to initiate
}
19 Nonconf ormance Reports, and we have at least two of them 20 in the record right now.
21 JUDGE GROSSMAN:
And didn't he just explain 22 that he had inspectors working in those areas and they 23 concurred with him on it and were willing to initiate 24 NCR's and the situation wasn't the same here and he 25 discussed it with the only person he thought could make Sonntag Reporting Service, Ltd.
Geneva, IllinciT-~60134 (312) 232-0262
5582 13 V
1 the judgment of issuing an NCR, Mr. DeWald?
2 I think we've explored the whole area.
3 If there's anything f urther that he hasn't 4
answered, you're welcome to try it, but as far as what 5
he's already answered --
6 BY MR. MILL ER :
7 Q
Mr. Puckett, when you had your interview with Mr.
I 8
Schapker, did you tell him about this fact that the 9
procedure hadn't been qualified in the 2G position?
10 A
I don't recall if I told Mr. Schapker that or not.
11 I don' t even recall if -- I think that I told it at 12 Glen Ellyn when I was talking to the NRC Staff there.
O 13 I'm not sure that I discussed it with Mr. Schapker or e
r 14 not.
I 15 MR. MILL ER :
May I have just one second?
16 JUDGE GROSSMAN:
Certainly.
)
17 BY MR. MILLER:
18 0
Well, let's look at the allegation as expressed.
19 Was this also a concern:
that the Comstock Company 20 had qualified a General Electric procedure by only doing 21 a tensile test on the coupons, when it's customary to do 22 a bend test as well?
23 A
Yes, I made that statement.
24 According to the records that I had, the
! {}
qualification of the procedure in the SG position --
25 Sonntag Reporting Service, Ltd.
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1 only tensile tests had been made to qualify this 2
procedure.
The code requires that they have other 3
tests, other than tensile.
4 Again, for nonsaf ety-related items, if that was all 5
that was going to be done with this, maybe that somehow 5
could be justified; but I was concerned that bend tests 7
were not made along with the tensiles.
8 0
Isn' t it a f act, Mr. Puckett, that you were informed 9
while you were still at Braidwood that the aluminum 1
10 welding was taking place on nonsafety-related work only?
11 A
The components that they were working on I knew were 12 nonsafety-related.
O 13 I did not know or no one told me while I was at 14 Braidwood that that was the only aluminum welding that 15 was on the project that Comstock was going to be 16 involved with.
17 MR. MILL ER :
I'd like the Reporter to mark as 18 Applicant's Exhibit 61 a memorandum to Mr. Puckett f rom 19 a gentleman named Tier, T-I-E-R, dated July 12, 1984.
20 And as Applicant's Exhibit -- it has a response 21 from Mr. Puckett on the bottom of the page.
22 A response from Mr. Tier -- well, the only name 23 that's not crossed out is Irv DeWald -- dated July 26, 24 1984.
25
()
(The documents were thereupon marked Sonntag Reporting Service, Ltd.
Geneva, 1111Mcir 60174
5584 O
1 Applicant's Exhibits Nos. 61 and 62 for 2
identification as of June 25, 1986.)
3 JUDGE COLE:
These are two separate exhibits, 4
Mr. Miller?
5 MR. MILLER:
I identified them as two 6
separate exhibits, I believe.
7 JUDGE COLE:
You're going to identify another 8
one as a separate exhibit or you have already done so?
9 MR. MILLER:
I thought on the record I had 10 identified the July 12th memorandum as Applicant's 11 Exhibit 61 and the response dated July 26th as 12 Applicant's Exhibit 62.
2
)
13 JUDGE COLE:
I missed that.
Sorry.
14 BY MR. MILLER:
15 0
okay.
16 Mr. Puckett, looking at Applicant's Exhibit 61, t
17 first of all, did you receive the top half of that i'
18 memorandum f rom Mr. Tier on or about the date it bears?
]
19 A
Yes, I did.
20 Q
Okay.
21 And you turned over the coupons that those two 22 welders had completed for aluminum welding; is that 23 correct?
j 24 A
Yes, I did.
25 Q
Now, there's a ref erence to a cut-and-pull test.
i Sonntag Reporting Service, Ltd.
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5585 1
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1 Is that the tensile test that you --
i 2
A Yes, that would be a tensile test.
3 0
All right.
4 Then you received, did you not, a copy of i
j 5
Applicant's Exhibit 62 on July 7,1984 -- or August 7th?
6 I beg your pardon.
7 A
Yes.
i 8
0 That's your stamp in the lower lef t-hand portion of
)
9 Exhibit 62 and your initials?
10 A
Yes, it is.
11 Q
All right.
12 And this indicates that for these individuals, they
()
1 j
13 are now qualified for aluminum welding on 14 nonsafety-related work only; correct?
i 15 A
This is what this says.
It says, " Paperwork and test i
r 16 results will follow."
t i
l 17 I don't recall ever seeing these paperwork and test j
j 18 results.
However, they may be there.
l 4
19 0
okay.
j i
20 But in any event, these two individuals were going i
i i
j 21 to be working on nonsaf ety-related aluminum welding?
i 22 A
And they would be qualified in all positions now.
i 23 Previously one of the welders had only been 24 qualified in three positions; and the other welder, who 25 had previously been there and qualified and was i
i j
Sonntag Reporting Service, Ltd.
i Geneva, Illinors-60r3'4 l
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5586 i O I
retested, had only been qualified in three positions j
i 2
when he had previously been there.
3 0
How many welders, to your recollection, were involved in l
4 aluminum welding?
3 i
i 5
A Only two, these two particular welders, that I can i
j 6
- recall, l
l 7
I -- I haven't checked the welder qualification 8
test records to reflect if anybody else had been
)
9 qualified or not.
j 10 0
Okay.
11 So can we agree, then, that you knew that no later 1
s 12 than August 7th the aluminum welding that these men were i
,O j
13 qualified for was on nonsaf ety-related work?
)
14 A
I knew that the work that they were working on at the 1
i i
15 time was nonsaf ety-related.
i i
j 16 0
But that's all they were qualified for; isn't that i
17 right?
j 18 A
Before this memo come out, in my opinion, there is l
i 19 nothing on their test records that reflected that they 1
20 could only do nonsaf ety-related work.
l 21 (Indicating.)
1 i
22 According to their welder's qualification test 23 form, they could have welded anything f easibly that was 4
j 24 aluminum.
i 25 0
But af ter August 7th, you understood, did you not --
i l
Sonntag Reporting Service, Ltd.
l Geneva, Illinois 60134 (312) 232-0262 E
5587
)
1 A
Af ter I had requalified this one welder and qualified 2
the other welder in the 2G position, then they would 3
have been qualified to weld on, with these memos, 4
nonsaf ety-related items.
5 Q
And it says "nonsaf ety-related work only"?
6 A
On this it does; but, again, I received this.
7 The individual inspector that is going to be 8
inspecting in the field -- he would have no idea or 9
anything that this even existed.
This doesn' t go to 10 everybody.
11 (Indicating.)
12 As I said before, his qualification test record, I O
13 would say, unicas somebody took it on themselves to add 14 that they could only do nonsaf ety-related work, would, in all instances, give them an opportunity -- if there 15 i
16 was something there that was saf ety-related, they could 17 still work on it and the QC Inspector would not know 18 that they were not qualified to work on work other than 19 nonsaf ety-related.
20 Q
Mr. Puckett, whose responsibility was it to see to it 21 that the welder qualification records reflected any 22 limitations that may have existed?
23 A
Well, prior to myself, this did not seem to have been 24 done in a satisf actory method.
25 After I went to Braidwood, I made sure that any
{}
Sonntag Reporting Service, Ltd.
Geneva, 1111noi s 60174 (312) 232-0262
5588 1
relevant information regarding the welder was, in fact, 2
reflected on his test record.
3 0
So you personally would have seen to it that the 4
limitation to nonsaf ety-related work only was 5
appropriately recorded on these welders' welder 6
qualification records; right?
7 A
If I had been there when this paperwork came back, 8
because at this time it hadn't been received.
It just 9
says, " Paperwork will follow. "
I do not recall ever 10 seeing this paperwork during the time that I was there.
11 This was dated 7/26/84.
I lef t there in August, 12 late August, of '84, and I still had not seen this O
13 paperwork.
14 0
Now, Mr. Puckett, you referred to the 2G and the SG 15 po si tions.
16 Those are the positions that are in the AWS code 17 that we've been looking at; right?
18 A
Yes.
19 0
Is that the code that's applicable to the aluminum 20 welding?
21 A
Well, that would be the code that you could use.
You 22 could weld aluminum using that, but you do have to 23 qualify a procedure.
24 You will not find the materials listed in Dl.l.
25 0
All right.
[}
Sonntag Reporting Service, Ltd.
Geneva, Illinois 6U134 (312) 232-0262
5589 O
1 Mr. Puckett, I'd like to move on to another 2
subject, and that has to do with your concern regarding 3
weld filler material control.
4 JUDGE GROSSMAN :
Do you want to take a --
5 MR. MILL ER :
No.
I'm fine.
6 BY MR. MILLER:
7 Q
Once again, if we turn to Applicant's Exhibit 51, which 8
is Mr. Schapker's 8509 report, the weld filler material 9
allegations --
10 A
What page are you looking at?
i 11 0
-- are set forth in Page 6, right at the very bottom.
12 (Indicating.)
, O 13 First of all, looking at Allegation -- what's 14 identified as Allegation No. 1, is that an accurate 15 characterization of your concern with respect to at 16 least a portion of the weld filler material control 17 issue?
18 A
No, it is not.
That is not what I said.
19 What I said is that L.
K.
Comstock did not have an 20 adequate procedure for the controlling of weld filler 21 material and that at this time they were rewriting it.
22 0
All right.
23 The second allegation with respect to weld filler 24 material control is found on Page 7 under the heading d(
" Allegation 2."
25 Sonntag Reporting Service, Ltd.
Geneva, 1111nci~s 60134 (312) 232-0262
5590 l
1O 1
Is that one an accurate characterization of your l
2 concern?
i l
3 A
Is this Allegation 2 that you' re referring to?
4 Q
Yes, it is.
5 A
Pretty much so, an outline of what I said.
I
{
6 0
All right.
7 And then I've included this.
It's really not i
precisely weld filler material control, but there's also 8
}
9 a control of construction material, an allegation which a
10 is found on Page 8.
1 1
11 I'd ask you to look at that briefly and tell me I
12 whether that's an accurate characterization of your
! (:)
13 concerns about the control of construction materials.
14 A
This is not exactly accurate, either, as to what my f
15 concerns was.
16 Again, my concerns was that, in my opinion, the 17 adequacy of the procedure and the conduct that was i
i 18 taking place in the field in the f abrication shop was 19 inadequate, in my opinion, for the control of filler i
20 material that is governed by 10 CFR 50 Appendix B.
21 Q
Well, Mr. Puckett, let me make certain that --
22 A
They had a certain amount of control of construction 23 materials, but in -- in my opinion and the way I read 10 24 CFR 50 Appendix B, this was not adequate.
i i
25 0
Are you differentiating weld filler material from other s
Sonntag Reporting Service, Ltd.
j Geneva, Illinois 60134 l
(312) 232-0262
5591 0
1 construction materials in this allegation?
2 A
No.
In this allegation I'm talking strictly 3
construction materials.
4 0
Okay.
5 So it's other steel or other materials that are 6
used by Comstock, other than weld filler material?
7 A
Yes.
8 Q
All right.
9 And in what way is the characterization of your 10 allegation not accurate?
11 A
Well, as I said before, this says, "The alleger has 12 found that L.
K. Comstock Company does not have any CE) 13 control of construction materials."
14 0
I see.
15 A
I never made this statement.
16 0
In other wcrds, it was, in your judgment --
17 A
Just inadequate.
18 0
-- not adequate?
19 A
Yes.
20 0
But they did have some controls?
21 A
Yes.
22 0
Okay.
23 A
I might relate that most of the allegations that I have 24 made here to Mr. Schapker were the same type of
~T 25 allegations that were made against us when I was working (Q
Sonntag Reporting Service, Ltd.
GeTreva7 TIT 1TIois 60134 (312) 232-0262
5592 1
at the Zimmer project, and I didn't want a recurrence of 2
this.
This is why these allegations were made.
3 0
You say you didn't want a recurrence of "this."
4 What are you referring to, sir?
5 A
The problems we had at Zimmer that Mr. Schapker was 6
involved in as well.
7 0
So Mr. Schapker had previous experience in evaluating 8
these same sorts of allegations at Zimmer; correct?
9 A
Yes, sir.
10 But after reading this, I would have the impression 11 that Mr. Schapker had two sets of rules:
one for Zimmer 12 and one for Braidwood.
O 13 0
Well, it's also conceivable, isn't it, Mr. Puckett, that 14 Mr. Schapker looked at the Zimmer situation and 15 evaluated it on the same criteria that he evaluated the 16 Braidwood situation?
17 A
No, sir.
18 That's just what I said.
It appears to me that Mr.
19 Schapker had two sets of rules:
one that he applied at 20 Zimmer, where some of these were as serious as a heart 21 attack, and one that he applied at Braidwood that didn't 22 seem quite as serious.
23 Q
And you don't think that, in fact, the situation may not 24 have been as serious at Braidwood as it was at Zimmer?
25 A
That was his opinion.
I --
{}
l Sonntag Reporting Service, Ltd.
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5593 O
1 Q
What's your opinion, sir?
2 Was it as serious at Braidwood as it was at Zimmer?
3 A
Yes, sir.
4 0
Okay.
5 Now, let's go back to the first allegation, which 6
we should now understand to say that Comstock does not 7
have an adequate weld filler material control and the 8
procedure was then being rewritten; correct?
9 A
Yes, sir.
i 10 0
All right.
11 By the way, Mr. Puckett, you met with Mr. Guild on 12 Monday, did you not?
O 13 A
Yes.
That's when I came up here.
14 O
All right.
15 And during that meeting on Monday, did Mr. Guild 16 discuss with you prior testimony that had to do with 17 weld filler metal control?
18 A
I don't recall us discussing anything dealing with weld 19 filler material.
20 Q
He didn' t show you any procedures; right?
21 A
No, sir.
22 0
Okay.
23 Now, the original concern concerning weld filler 24 metal controls originated with the Nuclear Regulatory 25 Commission Staff, did it not?
{}
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5594 O
1 A
The concern by the -- Mr. Schulz of the Nuclear 2
Regulatory Commission was on the filling out of the weld 3
rod withdrawal forms; that they were not being filled 4
out correctly.
5 My concerns was with the control of filler material 6
as a whole on the project where L.
K.
Comstock was 7
concerned.
8 0
I see.
9 But the reason that you were asked to look into 10 this issue of weld filler rod material control was 11 because the NRC had a concern in the area; correct?
12 A
Oh, I had already been witnessing things in the field O
13 that caused me a great concern where filler material was 14 concerned; and when I followed up on Mr. Schulz' 15 inspection of the weld filler material, I could see that 16 the problem was even more serious than I had expected.
17 0
I see.
18 Well, can we agree that at an early point in July, 19 you were informed by Mr. DeWald of Mr. Schulz' concerns 20 with respect to weld filler material control --
21 A
Yes.
22 0
-- snd asked to follow up on it?
23 A
Yes.
24 MR. MILLER:
Now, I'd like the Reporter to
{}
mark as Applicant's Exhibit 63 for identification a 25 Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
5595 O
1 letter -- the f ront two pages are a cover letter f rom 2
Mr. Warnick to Commonwealth Edison Company, dated August 3
7,1984; and attached to that is a notice of violation 4
and Inspection Report 8413, Nuclear Regulatory 5
Commission Staff.
6 (The document was thereupon marked 7
Applicant's Exhibit No. 63 for 8
identification as of June 25, 1986.)
9 MR. GUILD:
Mr. Chairman, I'd like to state 10 that Mr. Miller is getting considerably ahead of himself 11 on offering exhibits in evidence.
12 Again, it's difficult to capture sometimes the next O
13 day or several hours later when they' re of fered only as 14 a group.
15 MR. MILLER:
I'd be happy to off er them at 16 this point.
17 MR. GUILD:
It arises now because I don' t 18 expect you're offering the inspection report for the 19 truth of the matters contained in there.
20 MR. MILLER:
I haven' t offered any of the 21 inspection reports.
22 JUDGE GROSSMAN:
Right.
I' ve noted that you 23 have not, and I think it's wise -- we' ve already had 24 some discussion of that.
25 But I think that it's a reasonable request that you
}
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1 make your of f er when we have those topics up so it's --
2 MR. MILLER :
Okay.
I think that is 3
reasonable.
4 Therefore, I would offer Applicant's Exhibits --
5 JUDGE COLE:
The last one admitted in my 6
records is 57.
7 JUDGE GROSSMAN :
That's correct.
8 MR. MILL ER :
I therefore offer 58, 59, 60, 61 9
and 62.
10 JUDGE GROSSMAN :
Well', with regard to 59, I 11 really don' t think that you have any foundation for 12 offering that.
13 In all respects it's the same as 58, except for 14 matters in which you lack foundation.
15 So I really don' t think that it's admissible f or 16 any reason that 58 doesn't already cover.
17 MR. MILLER :
Well, your Honor, I'd like leave 18 to re-of f er the document if additional testimony or 19 foundation is supplied for those portions that I wish 20 the Board to take note of.
21 JUDGE GROSSMAN :
Right.
That's fine.
I 22 expected that's what you would do.
23 Any objection to the other documents?
24 MR. GUILD:
I hear 58 offered, and I have no
(~T 25 objection to that, Mr. Chairman.
V Sonntag Reporting Service, Ltd.
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1 59 you just spoke to.
2 60 are the group NCR's.
3 Again, if they' re simply offered as -- used as aids 4
in cross examination, I have no problem with them within 5
the scope of the witness' knowledge.
6 Obviously they extend to a period of time prior to 7
the witness' competent knowledge of f acts at Braidwood, 8
the 1981 NCR, and then subsequent to his departure f rom 9
Braidwood, as to which he can have no competent 10 knowledge, 11 I would object to receiving those documents to 12 prove the truth of the matters that were asserted there.
O 13 MR. MILLER:
Your Honor, they' re off ered not 14 for the entire truth of the matters stated but simply to 15 establish that, as of certain dates, certain conditions 16 were identified as nonconforming on the reports.
17 Whether or not the inspector that's identified 18 actually filled out the report on the precise date 19 that's given and so on and the company notations are 20 really not of consequence, but they were used in my 21 cross examination of Mr. Puckett.
22 I believe that they qualify under the business 23 records exception to the hearsay rule, if that's the 24 objection.
r~g 25 JUDG E G ROSS MAN :
If I understand it
(/
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1 correctly, you' re offering it to show the actions that 2
were taken and recommended?
3 MR. MILLER:
Correct.
4 JUDGE GROSSMAN :
Mr. Guild doesn't object to 5
that.
6 Is that correct?
7 MR. GUILD:
Well, sir, I guess maybe I should 8
be more precise.
9 To the extent that Mr. Miller is trying to 10 demonstrate through Mr. Puckett that they did something 11 with respect to the preheat or f ailure to follow preheat 12 requirements -- he can' t do that through Mr. Puckett.
O 13 He just can't do it.
Putting an NCR in front of him 14 that's dated six months or a year af ter he lef t the site 15 doesn't prove that fact.
16 I do object on hearsay grounds to him trying to 17 establish f acts reflected in a piece of paper that the 18 witness is not competent to testify from personal 19 knowledge to.
20 I don't believe it's properly admitted as an 21 exception under the business records exception.
Mr.
22 Puckett is not the custodian of that document.
Mr.
23 Puckett's knowledge has been stated, and it's limited.
24 If Mr. Miller genuinely wants to prove that they 25
")
took care of the preheat problem, the substance of the Sonntag Reporting Service, Ltd.
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5599 O
1 matters contained in those documents, he should offer a 2
competent witness to testify and not do it in cross 3
examination of Mr. Puckett.
4 JUDGE GROSSMAN :
Well, Mr. Guild, do you 5
doubt that the NCR's were dispositioned the way they 6
were -- they seem to have been on their f aces?
7 MR. GUILD:
I don't know, sir, and I don' t 8
think it's a question of what my belief is; it's a 9
question of what I'm going to see in findings from Mr.
10 Miller that are in a stack of paper that's quite 11 voluminous.
12 This witness had a few moments to examine the O
13 documents.
I just don' t know what the scope of evidence 14 is that Applicant would seek to found on documents that 15 are simply not competently offered to prove all of the 16 matters contained therein.
17 MR. MILLER:
Your Honor, some of the NCR's, 18 in fact, were initiated while Mr. Puckett was on-site.
19 That was established -- it's established both through 20 the documents and through his testimony.
21 The final document in the group, NCR 3423, deals 22 with a situation that took place, I admit, after Mr.
23 Puckett was on -- was off the site.
24 But given the testimony not just by Mr. Puckett but 25
)
by the other Comstock and Commonwealth Edison witnesses Sonntag Reporting Service, Ltd.
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5600 O
1 who have appeared here, it seems to me quite clear that 2
these are documents that are created and maintained in a 3
controlled fashion in the ordinary course of business.
4 For Mr. Guild to suggest otherwise is, I think, at 5
this stage in this proceeding kind of silly, frankly.
6 MR. GUILD:
Mr. Chairman, the real point is 7
just what Mr. Miller said.
8 If Mr. Simile was on the stand, for example, and 9
his testimony was to the point that they dealt with 10 issues raised by Mr. Puckett, that's generally what Mr.
11 Simile has to say.
12 Why on earth didn't Applicant off er these NCR's to O
13 be sponsored by a witness who is competent to speak to 14 them?
15 It makes no sense to me to go through the back door 16 to prove a substantive f act when a witness whose tenure 17 extends to the present time, Mr. Simile, is present and 18 is competent to sponsor the document.
19 It seems, to me, highly inappropriate to try to 20 prove these f acts through Mr. Puckett.
21 MR. BERRY:
Mr. Chairman,- this appears to the 22 Staff to be another instance where it really goes to the 23 weight to be accorded to the documents, as opposed to 24 their admissibility.
25 It appears to the Staff that these are records that Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 4
(312) 232-0262 l
5601 O
1 are kept in the ordinary course of business and, 2
consequently, would f all under the business records 3
exception to the hearsay rule.
4 Barring any dispute as to the foundation of the 5
authenticity of the documents, the Staff would not 6
object to the admission of the materials.
7 The question as to whether there's a competent 8
witness or the author of the documents or a witness 9
competent to speak to the matters addressed to the 10 documents is not present and cannot testify just strikes 11 the Staff as something that would go to the weight that 12 the decision-maker would attach to the documents, not O
13 having the benefit of a responsible person or a 14 knowledgeable person in that regard.
15 But in the final analysis, the documents speak f or 16 themselves.
17 JUDGE GROSSMAN:
Well, I don't agree with the 18 fact that lack of foundation for offering a document 19 goes to the weight of the document.
20 Mr. Guild is correct that there really hasn't been 21 a foundation laid f or that.
22 I would think that counsel would be able to agree 23 that these are authentic documents; but in the absence 24 of agreement, I don't think that we really can accept 25 that that the documents prove that on their f aces.
Sonntag Reporting Service, Ltd.
ueneva, Illinois 60134-(312) 232-0262
5602 i
O 1
We certainly would suggest that even if your 2
witnesses who can supply the foundation have already 3
been called, that you'd be entitled to recall them for 4
that purpose of supplying the foundation.
So if that's 5
a concern, we would allow you to do it.
6 But I don't think that we can take it on ourselves, 7
with the lack of foundation, just to accept the 8
documents as purporting to be what they are on their 9
faces.
10 MR. MILLER:
Your Honor, it seems to me to be 11 somewhat unusual in an administrative proceeding to go 12 through what seems to be an unduly elaborate process of O
13 recalling witnesses or finding additional witnesses to 14 simply authenticate a piece of paper.
15 We'll do it if we have to, but I believe that given 16 the state of the record so f ar, that it would be proper 17 to accept these under the business records exception to 18 the hearsay rule.
19 MR. GUILD:
Mr. Chairman, one last point, 20 please.
803(6), records of regularly conducted business j
21 of the Federal Rules of Evidence -- one element of 22 establishing admissibility under the Federal Rules is 23 the opportunity of the adverse party that does go to the 24 question of reliability.
1' 25 The language that I'm looking at specifically Sonntag Reporting Service, Ltd.
Geneva, Illinois cu134 (312) 232-0262
,----._.-e
-_m, 3
1 5603 i
(
1 1
states that, given all the other requirements that the 2
record is admissible, quote, "unless the source of 3
information or the method or circumstances of 4
preparation indicate lack of trustworthiness. "
5 I don't represent to you that on the basis of a 6
30-second review of these documents, that I take a 7
position that I can establish that legal conclusion.
8 But I simply believe I should have the opportunity 9
to do so without having the documents come in 10 unquestioned.
i 11 MR. MILLER:
Mr. Guild is the one who 12 suggested I move them in now.
i 13 JUDGE GROSSMAN:
Mr. Miller, I believe that 14 we have not been f air to Mr. Guild as to the objection 15
-- the suggestion that I made that the objections are a 16 mere f ormality.
17 I think he hasn' t had the opportunity to examine 18 the documents fully, and I think the point is well taken 19 that there may be something in those documents that are 20 going to come back to haunt him for agreeing.
21 I'm not saying that that's the case, but he 22 certainly has a right to be skeptical or suspicious of 23 the documents until he's had an opportunity to examine 24 them.
25 I would urge that once he has examined them, that Sonntag Reporting Service, Ltd.
veneva, Illinois 60134 (312) 232-0262
5604
()
1 if there isn't any such thing, that he come to an 2
agreement with you that the documents can be received i
3 without any further foundation.
4 But I think he ought to be permitted that 5
oppor tuni ty, since we haven't had any foundation laid 6
for receiving those documents.
7 So we'll reserve judgment on admitting that group
~
8 of documents -- we' re now talking about Applicant's 9
Exhibit 60, the group; is that correct?
10 MR. GUILD:
Yes.
11 JUDGE GROSSNmN:
-- until we hear further 12 word f rom counsel as to whether there's an agreement or
()
t 13 di sagreement.
i 14 MR. MILL ER :
Your Honor, just as I was happy l
15 to move the exhibits at this time, I'm happy to def er on 16 Exhibit 60 until Mr. Guild has had an opportunity to 17 look at it.
18 JUDGE GROSSMAN :
Okay.
That's fine.
We 19 still have --
20 MR. MILL ER :
61 and 62.
21 JUDGE GROSSMAN :
61 and 62?
22 MR. MILL ER :
Yes.
23 THE WITNESS:
May I go to the bathroom?
24 JUDGE GROSSMAN:
Okay, fine.
We might as 25 well break for lunch, then.
l Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
5605 LO 1
MR. GUILD:
I have no objections to 61 and 1
2 62.
3 JUDGE GROSSMAN :
Why don' t we excuse the 4
witness for lunch.
5 We'll continue the discussion here and then we'll 6
have a break right af ter that, so you won't have to 7
return until 1:00 o' clock, Mr. Puckett.
8 TH E WITN ESS :
Thank you, sir.
9 JUDGE GROSSMAN :
Is there any objection to 61 l
10 and 62?
11 MR. GUILD:
I have no objection to 61 or 62.'
12 MR. BERRY:
No objection, your Honor.
O 13 JUDGE GROSSMAN:
Okay.
Then we'll a& nit 58, 14 61 and 62.
I 15 We will not admit 59 at this -- 59 or 60 at this 16 point, 59 being the same as 58 except for the matter 17 that no foundation has been laid.
18 (Applicant's Exhibits Nos. 58, 61 and 62 i
19 for identification were thereupon j
20 received in evidence as Applicant's I
21 Exhibits Nos. 58, 61 and 62 in evidence.)
22 JUDGE GROSSMAN:
Then we will' recess for 23 lunch and return at 1:00 o' clock.
24 (WHEREUPON, the hearing was continued to 25 the hour of 1:00 o' clock P.
M.)
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
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1 JUDGE GROSSMAN:
The hearing is reconvened.
2 Mr. Miller.
3 MR. MILLER:
Thank you.
4 BY MR. MILLER:
5 Q
Mr. Puckett, we have just -- we've marked for 6
identification Applicant's Exhibit 63, which is the NRC 7
inspection report with the cover letter dated August 7, 8
1984.
9 Do you have that in front of you, sir?
10 A
Yes, sir.
11 Q
Okay.
If you turn to Page 12 of that inspection report, 12 there is a reference to a review of 300 filler metal 13 withdrawal authorizations.
14 A
Page 12?
15 Q
Yes.
16 A
Yes, sir.
17 0
Well, actually, why don't we go to Page 11.
Would you 18 back up a page, in about the middle of last paragraph, 19 beginning with the word, "However."
20 Do you see that, "However, the inspector 21 discovered," and so on?
22 A
Yes, I see that.
23 Q
All right.
Now, would you read the balance of that to i
24 the next -- or to the end of the paragraph which
(])
25 continues over to the top of Page 12.
Just read it to Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
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1 yourself, please.
2 A
Yes, sir, I've read it.
3 Q
Yes.
4 Mr. Puckett, first of all, did you see a copy of 5
this inspection report on or shortly after the date it 6
bears, which is August 7th?
7 A
No, sir, I did not.
8 Q
The first paragraph of the cover letter indicates that 9
the inspection was conducted during the period June 5th 10 through July 6, 1984.
11 Were you informed by Mr. DeWald or any other 12 employee of Comstock of what the inspectors -- the NRC 0s 13 Inspectors were -- were finding during the course of --
14 of the inspection?
15 A
No, sir.
16 The only thing that I was involved with this was 17 Mr. DeWald called me into his office and he said that 18 the NRC Inspector had been in to our QC vault and had 19 checked a group of weld rods dated for a period of three 20 months -- the dates I can't remember at this time -- and 21 that he had found certain discrepancies, and we talked j
22 there, and it was on a mutual agreement that I should go 23 in and check these same dates and find out what these 24 problems were that he had found with these rods and see
- (])
25 if there was any additional problems --
Sonntaa Reportina Servic_e, Ltd.
Geneva, Illinois 60134 (312) 232-0262
5608 1
Q Okay.
2 A
-- and I did this.
3 The other thing I was unaware of.
4 Q
All right.
5 And, in fact, the -- the NRC Inspectors' review of 6
the weld rod withdrawal authorization forms for May 7
through August of '82 is referred to on Page 12 of 8
Applicant's Exhibit 63, is it not?
9 A
Are you talking about the second paragraph from the 10 bottom.
11 O
Yes, the one that begins, "Over 300 filler metal," and 12 so on.
13 A
This seems to be in the same line of what I was looking 14 at, yes.
15 Q
Okay.
And Mr. DeWald' told you about that aspect of the 16 inspectors' findings prior to the time that this 17 inspection report was dated and received; that is, prior 18 to August 7th?
19 A
I don't recall the dates, but it was --
20 0
Okay.
l 21 A
-- near that time.
22 0
I'd like to show you a document that's previously been l
23 marked as -- well, marked and received as Applicant's 24 Exhibit 20, and that's Procedure 4.3.10 Revision C.
()
25 (Indicating.)
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4 Geneva, Illinois 60134 (312) 232-0262
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1 Yes, they are right here.
Sorry.
2 Mr. Puckett, when was the first time that you saw 3
this -- this procedure?
4 A
I'm still looking at this procedure; and it says it is 5
superseded by Revision D.
6 Is this a -- is this the superseded copy or is 7
there --
8 Q
No, sir.
This is -- this is Revision C; and let me see 9
if I can be of some assistance here.
10 A
Well, what I'm saying is I'm not sure this is the same 11 procedure that was in effect when I was there.
12 I want to make sure that it was, fsd 13 Q
Yes.
14 Do you have Applicant's Exhibit 50 before you, 15 which is the required reading list that you signed, you 16 know, when you --
17 A
I don't think I have a copy of that, but I know what you 18 are referring to.
19 Q
Can we agree, by looking at the third page of 20 Applicant's Exhibit 50, that you reviewed Revision C of 21 Procedure 4.3.10 on June 4, 1984?
22 A
Yes, sir.
Okay.
23 0
Okay.
And that's this procedure; correct?
24 A
Yes --
()
25 0
Okay.
H_onntaa Reportino Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262 i
5610 O
1 A
-- I reviewed it.
2 Q
Now, that review was part of your required reading 3
indoctrination to the site; correct?
j 4
A Yes, sir.
5 Q
Did you have occasion, subsequent to that, to look at i
6 this Revision C, Applicant's Exhibit 20, again?
7 A
It was available to look at at any time.
S Q
Yes, sir.
t 9
But -- but do you recall reviewing it again?
10 A
Well, I recall that I have looked at it from time to
{
l 11 time after that date; you know, maybe a particular point 12 that I was looking for or something of that nature.
13
, O All right.
And is -- is this the procedure -- the 14 version of the procedure on which you base your i
15 conclusion or opinion that Comstock does not have an 16 adequate weld filler material control procedure?
17 A
Well, based on the procedure and based on the way that 18 the rod was being used in the field, yes.
19 Q
- Okay, I'd like you to point out to me which portions of i
20 this procedure were, in your judgment, in the summer of 21 1984, inadequate?
22 THE WITNESS:
Is it all right if I read it?
23 I haven't seen it in two years.
24 MR. MILLER:
Oh, yes, absolutely, Mr. Puckett.
()
25 THE WITNESS:
This will take a few moments.
i Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
5611 O
1 MR. GUILD:
Mr. Chairman, the document that 2
counsel has shown the witness appears to be missing 3
several of the forms or attachments that are referred to 4
in the docutaent.
5 Form 57, Form 63 and Attachment 1 are referred to, 6
and I see only one form.
7 MR. MILLER:
Does your copy not have those, 8
Mr. Guild?
9 MR. GUILD:
Mine does not -- oh, they fell 10 off.
11 Excuse me.
12 BY MR. MILLER:
13 Q
Mr. Puckett, does yours have the Form 57 attached to it, 14 your copy of the procedure?
15 A
Which form is that, sir; Form 577 16 Q
Yes.
17 A
Yes, I have Form 57.
18 Q
All right.
Mr. Puckett, my question to you is:
19 Having looked over Applicant's Exhibit 20, Revision 20 C, could you describe for us the inadequacy in that 21 procedure with respect to control of weld filler 22 material?
23 A
Well, my concern with the procedure and what I 24 considered an inadequacy in it was the fact, at the time
()
25 that I was at Braidwood, the craftsman was not adhering Sonntag_Beportina Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
5612 O
1 to the procedure, and that the procedure _in itself did 2
not require that unused electrode be returned to the 3
weld rod withdrawal shack.
4 At this time the standard policy was that a welder 5
could go and withdraw X number of pound of weld rod to 6
do a job, and once that job was completed, at the end of 7
the day, any unused electrode was to be put in his 8
electrode oven and locked in his kang box overnight.
9 My concern with this was that over a weekend period 10 or for any number of reasons, when the craftsman was not 11 present, that the electrode oven could somehow --
12 comehow become unplugged or there could be a power 13 failure of some kind that would let this rod get below 14 ambient temperature; and the fact that the rod was being 15 issued by craftman to craf tman, with no supervision of 16 the QC Department or weld engineering, I thought was 17 part of the inadequacy of the procedure.
18 Q
All right, sir.
19 I'd like to try and differentiate between 20 inadequacies in the procedure as opposed to inadequacies 21 in the implementation of the procedure; and I think you 22 have identified two inadequacies in the procedure:
23 One, that the craftsman was not required to return 24 the weld rod to the weld rod issue location or crib at
[])
25 the end of his shift; am I correct?.
l Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
5613
,,b 1
A That is one of them.
2 Q
And -- yes.
3 And the other one was that there was no QC 4
involvement in the issuance or return --
5 A
The actual --
6 0
-- of the weld record?
7 A
The actual full-time witnessing of the record being 8
issued to see that it was being done correctly.
9 (Indicating.)
10 And, too, I was concerned with the fact that if a 11 craftsman checked out 10 pound of filler material to do 12 a job with and it only required 2 pound of this rod to 13 complete this job, he was allowed to retain this over 8 14 pound of rod and possibly use it at a later date.
15 How was it to be documented as to what components 16 it was to be used on?
17 Q
I see.
18 In other words, because the craftsman didn't have 19 to turn in his weld filler rod material at the end of 20 the shift, he did -- he would fill out a Form 57 that 21 indicated a specific location that he was going to weld 22 on, but then he might keep the rod that wasn't used and 23 use it at some other location?
24 A
As there was no QC supervisors for that area, that could
()
25 be a very good possibility.
Sonntag Reporting Service. Ltd.
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J i
,I 5614 i
i 1
Q All right.
Now, I think now we've identified three f
f i
i 2
inadequacies in the -- in the procedure itself.
l 1
i 3
Are there any others that you can recall?
i 4
A In the procedure itself -- just at first glance by l
5 looking at it, no, not in the procedure per se itself.
l 6
Q All right.
I take it that you observed these same three 7
procedural inadequacies when you were employed at i
j 8
Comstock in the summer of 19847 i
j 9
A Yes.
10 0
All right.
What, if anything, did you do once you I
11 learned that these procedural inadequacies existed?
12 A
I verbally brought the subject up to management in 13 Comstock, and they said that the procedure is going to i
14 be changed to take in these considerations.
l 15 0
All right.
And do you recall the name of the individual 16 that you brought that up to?
l 17 A
Irv DeWald and Mr. Seese and Mr. Saklak.
4 18 Q
Do you recall whether you ever documented these concerns 1
19 as opposed to --
20 A
I did not document these concerns.
21 Q
All right.
And do you know whether or not, in fact, l
22 there were any changes to the procedure that took place
]
23 while you were employed by Comstock at Braidwood?
24 A
I did not see any changes that had been made to the
(])
25 procedure at that time, no.
i f
Sonntag Reporting Service, Ltd.
l Geneva, Illinois 60134 1
(312) 232-0262
5615 1
Q Okay.
I think you indicated this morning that there was 2
an individual named David Bradfute who may have been the 3
Comstock engineer who you discussed the qualification of 4
the preheat material --
5 A
Yes, sir.
6 0
-- with -- qualification of the preheat procedure, 7
rather.
8 Did you have any other dealings with Mr. Bradfute 9
over the course of your employment at Comstock?
10 A
I can't really recall at this time that I did.
11 Q
Do you know whether or not Mr. Bradfute was working on a 12 revision of -- of this weld rod control procedure?
13 A
It was my understanding that these procedures were to be 14 changed by the QA Department, which would be Mr. Bob 15 Seltmann; but no, I do not know.
16 Maybe Mr. Bradfute was, in fact, working on this 17 procedure.
I don't know.
18 Q
Well, after you raised these concerns with Mr. DeWald, 19 did -- did you ever ask him again as to what the status 20 of the -- of your concerns were?
21 A
I never had the opportunity.
I was working on other 22 things.
23 0
I see.
24 I'd like to show you a document that's been marked
()
25 as Applicant's Exhibit 21 for identification -- I'm Sonntaa Reportina Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
i 5616
(
i i
1 sorry -- in evidence.
I beg your pardon.
2 (Indicating.)
3 Mr. Puckett, would you take a look at -- you are 4
free to peruse the entire document, but I'd like you 5
specifically to look at Paragraph 3.3.4 on Page 4 of 5 t
6 of the procedure.
7 A
What was the number again?
Was that 3.3.4?
l 4
8 Q
Yes, sir.
9 Can we agree, Mr. Puckett, that that revision to 10 the procedure is responsive to one of the inadequacies t
4 11 that you described a little bit earlier to us?
i 12 A
It would be responsive to one of the items, yes.
1 13 Q
All right.
That is, under the procedure now, the welder 14 was required to return the weld rod to the --
15 A
That would alleviate part of my concern.
16 0
-- I think it's called the rod crib?
1 17 A
The rod shack, rod crib, weld rod withdrawal shack.
f 18 Q
Okay.
And then would you look just up at the top of the 19 page at 3.3.2.
20 Would you read that to yourself, please.
21 Would you agree that that provision is responsive 22 to another one of the inadequacies that you described in 23 that at least for each shift, a new Form 57 identifying 24 the location in which the welder did his work was to be
({}
25 filled out?
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60134 Geneva, Ill1nois (312) 232-0262
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1 A
Yes, this would -- if it, in fact, was being done and 2
supervised, I would say that this would take care of one 3
of the concerns that I had.
4 0
All right.
Mr. Puckett, you know, the -- the pages --
5 the revision pages down here for Revision D are dated 6
August 21, 1984, and I realize that you left Braidwood 7
on August 29th.
8 Having looked at this procedure and having had me 9
draw your attention to two specific provisions, do you 10 recall now whether, prior to the time you left 11 Braidwood, you had occasion to look at this?
12 A
I do not remember ever seeing it.
13 On the front cover of this -- it was probably en 14 route, because S & L -- I mean, S & L and CECO's final 15 approval wasn't until 10/4/84.
16 Q
All right.
But you don't recall Mr. DeWald and Mr.
17 Seltmann showing this document to you just by way of 18 informing you of how the concerns -- some of the 19 concerns that you had expressed with the prior procedure 20 had been dealt with?
21 A
No, sir.
22 In fact, I thought that I was going to be involved 23 in the changes to this procedure, but this never come 24 about.
()
25 Q
Now, the --
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
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1 JUDGE GROSSMAN:
Excuse me.
2 I think if you look at.the second page of this 3
document, it doesn't appear as though it came to Mr.
4 DeWald until 9/6/84, and, similarly, to Mr. Rolan, Mr.
5 Seltmann and to the project engineer.
6 MR. MILLER:
Well, those are the dates they 7
signed it.
8 Whether that is the date which it came to them is 9
not clear from the face of the document.
10 BY MR. MILLER:
11 O
Well, in any event, Mr. Puckett, quite apart from 12 whether you saw the document, did Mr. DeWald or any l
13 other employee of Comstock describe to you orally these 14 procedural changes that were being made?
15 A
No, sir, not to this point.
4 16 When I had spoke to Mr. DeWald and Mr. Seese and 17 Mr. Saklak, I told them that I -- at that time that this 18 was the type of changes that would needed to be made to 19 the procedure; and if anything that I might have said 20 prompted these changes, then I feel a lot better about 21 myself.
22 Q
All right.
Well, then, it also shows that Comstock i
23 management was responsive to the suggestions that you 24 made, does it not?
()
25 A
Yes, sir.
Sonntag Reporting Service, Ltd.
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5619 O
1 My only problem was that this procedure had been 2
active for so long without anybody else suggesting these 3
changes.
l 4
0 Well, then, can we agree, having looked at Applicant's 5
Exhibit 63, which is the NRC inspection report that has 6
a cover sheet of August 7, 1984, that Mr. Schulz of the 7
NRC, at the bottom of Page 11 and the top of Page 12, 8
had also identified at least one of the inadequacies in 9
the procedure that you identified?
10 A
Yes.
11 Q
All right.
Now --
12 A
I never had an opportunity to review this latest O
4 13 revision all the way through, and I would be interested 14 in seeing if they put a provision in there where there 15 would be supervision of these activities.
16 Q
Well, let me -- I don't mean to withhold from you.
17 The -- my reading of the document indicates that it 18 is only in Paragraph 3.3.2.3 that there is a reference 19 to the Comstock QC Department.
20 A
It was 3 --
21 0
3.3.2.3.
22 Well, even that's not -- that's not completely 23 accurate.
I beg your pardon.
24 That is one portion, and then Paragraph 3.3.4.1.
()
25 A
Again, sir, I'm not trying to be facetious, but you have Sonntag Reporting Service. Ltd.
Geneva, Illinois 60134 (312) 232-0262
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'()
1 a craftsmai. doing this work without supervision, and to 2
me, that's like having a fox guarding the chickens.
3 0
Why is that, Mr. Puckett?
4 A
The purpose of a Quality control Inspector is to -- to 5
control the quality of these procedures and of the 6
activities that are taking place, and if he's not 7
present during the day to see that the craftsman 8
themselves are adhering to this procedure, if they are 9
just going to take the craftsman's word for everything, 10 why even have a Quality Control Inspector in the field?
I 11 Q
I see.
12 So that of all the inadequacies in the procedure 13 that you described, the absence of a QC Inspector as the 14 weld rod is being issued and returned is most 15 significant?
16 A
I would be very concerned with this.
17 Again, these concerns are based on concerns that 18 derive from the Zimmer project; whereas there in our 19 weld rod withdrawal, we did have full time a weld 20 represent'ative in the rod shack when these filler 21 material was being issued; and, however, this did not 22 seem to be a -- satisfactory with the NRC.
23 I was trying to think of the name of the gentleman 24 that was involved with this at the time; but eventually, i
(])
25 we were required to change our procedures, whereas we i
r Sonntag Reporting'UEdvid% i.td.
i l
Geneva, Illinois 6 ult 4 ~
(312) 232-0262
5621
(
l had full-time coverage by both the Weld Engineering 2
Department and the Quality control Department in our 3
weld rod with -- withdrawal shacks for the issuance of 4
this material.
i 5
Q Mr. Puckett, am I correct that there was a time at i
6 Zimmer when you did not have quality control involvement 7
in the issuance and return of weld rods?
Correct?
8 A
They had the same control that they had in the procedure 9
here.
They would end up with copies of the weld rod 10 withdrawal form; but we also had constant supervision in 11 the shack where this rod was being issued to make sure 12 it was being issued in accordance with the procedures.
13 Q
Constant supervision by whom, sir?
14 A
By weld engineering.
15 Q
That was not a QC function at Zimmer, was it?
16 A
No, it was not.
17 Q
All right.
And at some point in time, the NRC came and i
18 said, "This is inadequate at Zimmer.
You better have QC 19 involvement as well"; right?
20 A
We should have QC involvement as well, and we agreed to 21 that.
j 22.
O All right.
Now, is it apparent from -- to you from your 23 reading of Applicant's Exhibit'63, Pages 11 and 12 of 24 Mr. Schulz' inspection report, that he read the Comstock
()
25 procedure Revision C during the course of his i
Sonntag Reportina Service, Ltd.
Geneva, Illinois 60134 1
(312) 232-0262
5622 0
1 inspection?
2 A
Which -- which item are you talking about now?
3 0
Well, if you look at --
4 A
I'm kind of lost.
5 Q
-- Page 11 -- I'm sorry.
It's this August 7, 1984, 6
cover sheet with --
7 A
What page?
J 8
Q Page 11.
9 And it indicates right on its face, doesn't it, 10 that he looked at Procedure 4.3.10; correct?
11 A
What -- what note does it reflect that at?
12 Q
I'm sorry, sir.
It's about a quarter of the way up the 13 page on Page 11.
It says, " Procedures reviewed 14 included."
15 A
" Documents utilized in the examinations included" --
16 Q
I'm sorry.
That --
17 A
-- is that what we're referring to?
18 Q
I'm sorry.
Let me point it out to you, Mr. Puckett.
19 I realize we're -- it's this sentence here that 20 begins, " Procedures reviewed."
21 (Indicating.)
22 And can we agree that there is nothing in this 23 inspection report that indicates that there should be 24 full time QC involvement as far as Mr. Schulz was
()
25 concerned?
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262 j
5623 1
A No, sir.
2 Q
We can't agree?
3 Where do you find any indication in this report 4
that Mr. Schulz --
5 A
I don't find anything here that says that Mr. Schulz 6
agrees or disagrees with that.
7 JUDGE GROSSMAN:
I believe that that answer 8
should have been yes, sir; that --
9 MR. MILLER:
Okay.
10 JUDGE GROSSMAN:
Yes, that he does not find 11 anything there.
12 MR. MILLER:
Okay.
My question was a little 13 confusing.
14 JUDGE GROSSMAN:
Okay.
15 BY MR. MILLER:
16 Q
Can we agree, then, Mr. Puckett, that there does not 17 appear to be any regulatory requirement that there be 18 quality control involvement in the issuance and return 19 of weld filler material?
20 A
Not here there doesn't seem to be so.
21 Again, I would like to reiterate, at one time at 22 the Zimmer project, it was perfectly okay for our weld 23 rod withdrawal forms to be witnessed by a representative 24 from the weld engineering department full time, and
(])
25 later in the project, it was -- it became mandatory that Sonntao Reportino Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
5624 1
1 we also put a QC representative in there to oversee this 2
full time.
3 And it was my concern, as the Level III at l
4 Braidwood, that we could preclude any of these problems 5
that we had at Zimmer, possibly by, so to speak, cutting 6
them off at the pass.
Let's take care of them now 7
before they really become a problem.
8 (Indicating.)
9 Q
And at Zimmer, this was a problem that was quite a 10 serious one, wasn't it?
11 A
It -- yes, sir.
12 Q
And at Zimmer, the weld rod control was just one aspect 13 of quite serious problems not just -- well, with respect 14 to welding activity?
j 15 A
None that I was involved in.
16 Q
No, no, no, I'm not suggesting that you were.
17 But it was -- it was just one aspect of what the 18 NRC characterized as wide-spread problems with welding 19 at the Zimmer project; correct?
20 A
I really don't know about all those.
21 I know they did, in fact, have problems with the 22 weld rod control and they had problems with the uses of 23 the weld electrode ovens.
24 Q
And wasn't there a. civil penalty assessed at the Zimmer 25 site?
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
i 5625 AU 1
A I really don't know.
2 Q
All right.
Do you know whether there were other NRC 1
regulatory concerns at Zimmer outside of the welding 3
4 area?
5 A
Yes; for intimidation of inspectors, things of this 6
nature.
7 Q
And there were Congressional hearings, were there not?
8 A
Yes, sir.
9 Q
An FBI investigation?
10 A
Yes, sir.
J 11 Q
And -- okay.
12 Now, the second allegation that you made with 13 respect to weld rod control to Mr. Schapker was that the 14 filler material withdrawal forms have inconsistent heat 15 numbers, and you stated that you could not find any 16 paper work to back up heat numbers in the possession of i
17 either Comstock or Phillips Getschow.
l 18 And I think you testified before lunch that that 19 allegation was essentially accurately characterized by 20 Mr. Schapker in his inspection report; correct?
21 A
Yes, sir.
i l
22 MR. MILLER:
All right.
I'd like the 23 Reporter to mark, as Applicant's Exhibit 64, I believe, I
24 a memorandum from Mr. DeWald to Mr. Puckett dated July
()
25 6, 1984; as Puckett Deposition Exhibit -- Puckett I
L l
Sonntaa Reportina Service, Ltd.
i Geneva, Illinois 60134
{
(312) 232-0262~
~
5626 O
1 Exhibit -- excuse me -- Applicant's Exhibit 65, a 2
memorandum from Mr. Puckett to Mr. Saklak, and the date 3
on this is April 15, 1984, but there is a " received" 4
stamp in the lower right-hand corner that has the date 5
of August 17, 1984; and then as Applicant's Exhibit No.
6 66 for identification, a memorandum from Mr. Puckett to 7
Mr. Saklak dated August 17, 1984.
8 (Indicating.)
9 JUDGE GROSSMAN:
Excuse me.
10 Are they in the same order as in the deposition; 11 that is --
12 MR. MILLER:
23, 24 and 25, yes, sir.
\\O 13 JUDGE GROSSMAN:
Okay.
14 MR. MILLER:
Those are the deposition 15 exhibits.
16 JUDGE GROSSMAN:
All right.
17 (The documents were thereupon marked 18 Applicant's Exhibits Nos. 64, 65 and 66 19 for identification as of June 23, 1986.)
20 BY MR. MILLER:
21 Q
Okay.
Mr. Puckett, turning first to Applicant's Exhibit 22 64, did you receive that document from Mr. DeWald in 23 early July, 1984?
24 A
Yes, sir, I did.
()
25 Q
Okay.
The references to the NRC finding on weld rod l
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134-(312) 232-0262
_.7 i
1 5627 t
t
]
1 control -- and:can we agree that that's the same finding 2
that appears on Page 12 of what has been marked as 3
Applicant's Exhibit 63; that is, Mr. Schulz' inspection 4
report?
5 A
It appears to be related to that, yes.
6 0
All right.
Now, Mr. DeWald's description of the problem l
7 to you or the NRC's concern is that weld rod E6013 was l
8 issued but the heat number is for E7018.
{
9 Would you tell us, please, what your understanding i
+
i 10 of that concern was?
I 11 A
Yes, sir.
12 At the heading of the rod slip, it reflected on l
13 there that the welder was to draw E6013 electrode for 1
1 14 the job in which he was to be working on.
However, the 15 rod that was issued to him, based on the heat number, 16 was E7018 electrode, j
17 Q
All right.
And what is the -- the -- well, what are --
i 1
18 the differences between E6013 and E7018 is that E6013 19 has a nominal tensile strength of 60,000 psi; is that 20 correct?
21 A
That is one of the differences.
i 22 Q
And E7018 has a nominal tensile strength of 70,000 psi?
23 A
It is a low hydrogen rod.
24 0
What is the significance of the low -- of the rod being
(])
25 low hydrogen?
I Sonntag Reporting Service, Ltd.
Geneva,-Illinois 60134 (312) 232-0262
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1 A
Well, there is a difference in the way they were kept l
2 and stored and the use they are used for.
3 The -- if you had noticed in the weld rod 4
withdrawal procedure in there, it reflects that the 6013 5
rod has only got to be held in a container that is 6
clean, and that the 7018 rod has got to be stowed in 7
heated ovens and maintained at certain temperatures to 8
prevent the absorption of moisture and oxygen from the 9
air.
I 10 (Indicating.)
l 11 Q
Is there a difference in -- in welder qualification?
12 A
The difference would be, if a welder qualified to weld j
13 with 6013 rod, he would not be qualified to weld the 14 7018 rod.
i
]
15 However, if the welder qualified with the 7018 rod, 16 the higher strength, he would be qualified to weld with i
17 a lower-strength rod.
i 18 Q
All right.
And, to your knowledge, Mr. Puckett, were 19 all the welders at Comstock qualified to weld with E7018 20 rod?
21 A
With the best of my knowledge, they were; but, however, 22 I do not know.
I never checked all the welders' l
23 qualification test records.
4 q
24 (Indicating.)
f Q
25 0
Okay.
Is there any difference in application between 1
{
Sonntag Reporting Service, Ltd.
i Geneva, Illinois 60134 (312) 232-0262 j
4
5629 1
the E6013 and E7018 rod?
2 A
By application, the process is the same.
There's 3
variations in the individual welders and the application 4
on which they are used.
5 The 6013 rod is sometime referred to as a cold 6
freeze rod, and it's used in the industry -- in the 7
nuclear industry mostly for welding your galvanized 8
steels.
9 Q
And why is it used for welding galvanized steel?
10 A
That is usually what is specified by the contractor, 11 because of the -- it would be my opinion -- I've never 12 done an engineering evaluation on it -- that because of 13 the technique that is usually used with the 6013 rod 14 with the oscillation out of the puddle and back to the 15 puddle, that you would be burning off the galvanized 16 ahead of the molded puddle that you are welding.
17 0
And would the welding technique be different if you were 18 using E7018 rod?
19 A
The techniques would be the same but the application 20 would be somewhat different.
21 Usually with a 7018, they usually use a drawing 22 motion without the oscillation in and out of the puddle.
23 Q
Well, Mr. DeWald's memorandum to you says that you would 24 have to get copies of the Form 57's and research back
(])
25 through time sheets and installation reports by welder Sonntaa Reportino Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
5630 O
1 name to determine what component was welded?
2 A
Yes, sir.
3 Q
And, first of all, how were you able to determine --
4 well, was it all Form 57's during the time frame May 25, 5
1982, through July 28, 19847 6
A No, sir; just those forms that seemed to be incorrect, 7
that had either or the -- on the heading, 7018 rod with 8
a 6013 heat number or 6013 rod with a 7018 heat number.
9 (Indicating.)
10 0
Were you able to discern that just from looking at the 11 weld -- the heat number for the weld rod?
12 A
Yes, sir.
13 Q
All right.
That is, there was a -- some distinction 14 that you were able to ascertain between --
15 A
Well, by looking at the majority of the other rod slips.
16 You could tell on there that the majority of the rod 17 slips said 7018, they had the same sequence and heat 18 numbers.
19 0
I see, all right.
20 And you conducted research.
21 And then on Applicant's Exhibit 65, which is the 22 document that has the date stamp of August 17, 1984, you 23 reported back, and the memorandum is addressed to Mr.
24 Saklak; is that correct?
()
25 A
Yes, it's to Mr. Saklak.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
f 5631 (2)
{
l Q
All right.
And Mr. Saklak, at that point in time, was 2
your supervisor; correct?
I 3
A He was the inspection supervisor, yes.
{
4 Q
All right.
Did Mr. Saklak take an active role at all in j
5 your activities at the Braidwood site, sir?
I l
6 A
No, sir, he did not.
1 j
7 Q
All right.
In fact, you sent a copy of this to the 8
Quality Control Manager, Mr. DeWald; right?
i
}
9 A
I don't recall if I did or did not.
i i
10 Q
Well --
11 A
More than likely I did.
It's referenced down here.
12 I might say that I would just hand write these i
j things up and I would give it to a clerk typist to type 13 l
14 up and then I would sign it and give it back to her and i
l 15 she would distribute it to those people that were l
16 supposed to get it.
17 Q
I see.
I
{
18 But your direct dealings on this issue were not i
j 19 with Mr. Saklak, they were with Mr. DeWald, weren't 1
20 they?
21 A
Would you repeat that question, sir?
i
)
22 Q
Yes, sir.
23 Your dealings with individuals in Comstock
.I i
24 management were with Mr. DeWald on this issue rather Y
f ()
25 than Mr. Saklak?
Sonntag Reporting Service. Ltd.
Geneva, Illinois 60134 i
(312) 232-0262
_ _ - - - - - ~, _. - _ _.. -., _ _, _. _ _ _ _,... _ _ _ - - - _
. _, _ _ _..,..,... _ _-,.~.,.__ _ _ _, _ ___,., _ ____ -,._ _ _
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i 5632
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s 1
A Mostly with Mr. DeWald.
2 Q
Now, you identified -- and we agree that the date April i
3 15th is just a misprint by --
1-f 4
A Yes, sir.
5 0
-- the clerk typist and probably should be August; is 6
that right?
7 A
Yes, sir.
1 f,
8 Q
All right.
That -- you say the main concern involves 9
three heat numbers, and two of the heat numbers involved i
10 E7018 rod and one involves E6013 rod?
11 A
Yes.
i l
12 Q
Now, you established to your satisfaction that the i-2at 1
13 numbers were good heat numbers; that on the component 14 that they were used, the strength meets or exceeds the i
15 strength requirements; that the welders were qualified 16 to use either filler material; and then you go on to 17 say, "We have an obvious procedure violation which could 18 be alleviated in the future by a thorough indoctrination i
i 19 of craft tool room weld rod issue clerk."
4 l
20 Now, what was the obvious procedure violation?
21 A
He had issued rod incorrectly on the weld rod withdrawal i
i 22 form.
i 23 He receives the weld rod withdrawal form from the i
l 24 foreman or from the actual welder that is going to do l ()
25 the weld, and it reflects at the top that the welder t
1 l
l Sonntag Reporting Service, Ltd.
I Geneva, Illinois 60134 (312) 232-0262
.----_--..-.-...--.,...,,w_-.-..
5633
()
I wishes to withdraw 6013 rod.
He, instead, issues 7018 2
rod on that weld rod withdrawal form.
3 0
Well, your recommendation was that there be a thorough 4
indoctrination of the craft tool room weld rod issue 5
clerk to avoid this; correct?
6 A
Yes, sir.
7 Q
And it also could have been alleviated, could it have 8
not, by having a full time Quality Control Inspector in 9
the weld rod issue crib?
10 A
It would have helped.
11 Q
But that wasn't one of your recommendations in this 4
12 document, was it?
13 A
Not at that time.
4 14 Q
You go on to say, "A Non-Conformance Report should be 15 initiated listing the heat numbers and types involved 1
16 and the outline of the procedural violation."
17 Do you know whether that was ever done, sir?
18 A
No, sir, I do not.
19 Q
Now, two days later, you again write a memorandum to Mr.
20 Saklak, and it shows a copy to the Quality Control 21 Manager.
22 And this indicates that you just didn't limit 23 yourself in your review to the issue -- or the time 24 period identified by the NRC; is that correct?
(])
25 A
Yes, sir.
Sonntaa Reportina Service, Ltd.
Geneva, Illinois 60134 l
(312) 232-0262
5634 O
1 Q
So you -- you took the initiative and made a further 2
check of the weld rod withdrawal forms; right?
3 A
Yes, sir.
i 4
I felt that that was my job.
5 0
All right.
And you looked in December, 1982; September, 6
1983; and then three months in 1984; correct?
7 A
Yes, sir.
8 Q
All right.
And you pointed out that the same problem 9
persisted, and that was the problem of the weld rod 10 clerk issuing E7018 rod when E6013 rod was called for; 11 correct?
12 A
Yes, sir.
13 0
You say, in about -- after you identify the months that 14 you checked, "However, not as prevalent in the year 15 1984."
16 Does that mean that there were less wrongly-issued 17 rods that you observed?
18 A
Yes, sir.
During that period of time, there didn't seem 19 to be as many mistakes on the weld rod withdrawal forms.
i 20 0
All right.
Now, apparently you looked for a period 21 prior to May, 1982, as well, and established that the 22 heat numbers for E6013 electrodes were not entered on 23 the weld filler material withdrawal form; correct?
24 A
Ask that question again, sir.
I'm not sure I got all of
()
25 it.
i 4
i l
Sonntag Reporting Service, Ltd.
I Geneva, Illinois 60134 (312) 232-0262
N 5635
()
1 Q
I'm sorry.
2 Would you look at the next sentence in your 3
memorandum, the one that begins, "In addition, during 4
the period prior to May, 1982," so forth.
5 A
Excuse me.
6 Yes, I see it.
7 Q
Okay.
Was there -- even though there was no heat number 8
indicated, was there, nonetheless, some identification 9
that an E6013 electrode was, in fact, issued?
10 A
There was no indication of what the electrode was.
11 The heat number that was reflected on the form was 12 traceable back to 6013 rod.
13 However, on the form it did not stipulate what type 14 of rod that was being used.
15 MR. MILLER:
I'm sorry.
16 Could I have the last answer read back, Mr.
17 Reporter.
18 (The answer was thereupon read by the 19 Reporter.)
20 JUDGE GROSSMAN:
Excuse me.
21 Were you trying to say that you don't know which 22 rod was requested; you only know which rod was used from 23 the heat number?
24 THE WITNESS:
Yes, sir.
()
25 MR. MILLER:
I see.
SDDatag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262 i
h 5636
()
1 BY MR. MILLER:
{
2 Q
As far as you could tell, they were valid heat numbers 3
that --
4 A
All but the ones that I have further down here that I l
4 5
could not come up with any validation for.
6 (Indicating.)
l 7
Q Okay.
And -- well, let me -- I'm still trying to 8
understand.
9 JUDGE GROSSMAN:
I'm not sure that -- I hope 10 you understand what I said, i
11 THE WITNESS:
Sure.
)
12 JUDGE GROSSMAN:
And you are sure --
i 13 THE WITNESS:
Sure.
14 JUDGE GROSSMAN:
Okay.
j 15 THE WITNESS:
That's exactly what I was i
i 16 saying.
17 MR. MILLER:
I'm not sure, however, that --
18 okay.
19 BY MR. MILLER:
20 0
If we turn for just a second to the Form 57 -- the i
21 sample Form 57 that's attached to Applicant's Exhibit l
22 20, Revision C of the procedure, the sentence that we i
l 23 were looking at says that prior to May, 1982, heat 24 numbers were not entered on the weld filler material I (])
25 withdrawal form.
i Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 j
(312) 232-0262 i
5637 O
1 I take it, though, that the class of weld filler 2
material was indicated on the forms that you reviewed?
3 A
I think that this is a new revision of the form that was 4
being used in '82.
5 Q
Okay.
6 A
I'm not at all sure that that's the case.
7 Q
No.
You are absolutely right, because the revision date 8
on this form is September 27, 1983.
All right.
9 Do you -- well, on these forms that you looked at 10 in May of 1982, there was a heat number listed; correct?
11 A
There was heat numbers listed on the -- the form, yes.
12 Q
All right.
Now, the NRC had identified some 3 -- they
-}
13 had reviewed some 300 weld -- weld filler material 14 withdrawal forms.
15 And did you look at all of those?
16 A
Yes, I did.
17 0
All right.
Can you give us an estimate as to how many 18 additional forms you looked at beyond the 300 identified 19 by the NRC?
20 A
I would say approximately a hundred.
It was just a 21 random sampling fro: 2eriods of time.
22 The way they have the forms filed in the filing 23 cabinets are by dates and periods for the month of June 24 of 1982 or whatever the case.
(])
25 I would just take out a rambling -- a random Sonntag Reporting service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
5638 o'(
1 sampling of those and look through them and come up with 2
these individual rods.
3 I did not check, for the whole month, of any 4
particular day.
5 (Indicating. )
6 0
I see.
I 7
Well, you then also took a further sample of heat 8
numbers off the rod slips to see if they could be traced 9
back to the documentation that supported the physical 10 properties of -- of those heat numbers; correct?
11 A
Well, in the process of doing this review and loo.:ing at 12 these different numbers, you get pretty familiar with 13 standard heat number types.
14 During this review, there was several numbers that 15 came up that did not, to me, seem to be a standard.
16 That is, you know, a rod that had been drawn the day 17 before and the day after of the same type had different 18 heat numbers.
19 These numbers that looked unfamiliar to me, I 20 copied some of these down.
21 I had a list of approximately 14 or 15 to start 22 with, and I started a review on these to see if I can 23 trace them back to a car *1fication of compliance; and 24 over a period of time and a lot of research, I managed
(])
25 to find that these were, in fact, good heat numbers, Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
5639
(
1 with the exception of the ones that I have listed on 2
this memo that I sent to Irv DeWald dated August 17, 3
1984.
4 Q
Okay.
And as reflected on the memo, the numbers are 5
40lS7441, 401S9011 and 35202061; correct?
6 A
That is what is reflected here.
7 Q
Okay.
Now, Mr. Puckett, it sounds like you spent quite 8
a bit of time on -- on this entire weld rod research 9
- project, 10 Could you give us an estimate of how much time, 11 between early July and mid-August, you spent on this?
12 A
Well, it's reflected here that Irv asked me to start on 13 this and it was 7/6/84, and I was still working on it on 14 August 17th of '84.
15 Well, I had completed it by that time, along with 16 some other projects; but I worked on this for a couple 17 of days and they may put me on welders' qualification or 18 on an audit, and I would get back to this at the 19 earliest convenient time; but total possibly a 20 week-and-a-half or two weeks of research was done on 21 this.
22 A lot of it was done in the CECO MRR books that 23 they had.
They were large books, and I must have went 24 through 80 of these books trying to verify that all the
(])
25 heat numbers that I had found were successful heat i
Sonntag_ Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262 i
_. _ _. = _. _ _ _
f 1,
5640 i
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! (:)
4 l
1 numbers; and the ones that I had problems with, I done a 1
{
2 reverification on a cross-reference that I had received 3
from Phillips Getschow on those heat numbers that they 4
had issued to comstock, and these particular numbers --
5 I tried to cross them by seeing if they had an inverted j
6 letter or inverted number or if possibly a lot number
[
7 was reflected on the weld rod withdrawal form versus the 8
heat number; and -- and the earlier stages of the job --
l 9
I mean, the earlier stages of this review that I was i
10 doing, I had checked the file that was supposed to have 11 been maintained by Comstock on all the weld rod that i
12 they had received from Phillips Getschow, and there was 13 only a total of about four forms in there.
14 So I would say that a total of a week-and-a-half or 15 two weeks I spent trying to trace these three particular t
4 16 numbers as well as the others that have been mentioned, j
17 (Indicating.)
18 0
I see.
l 19 So just on these three specific numbers, you -- you i
l 20 spent about a week, week-and-a-half, two weeks?
I l
21 A
Well, possibly -- well, no, not -- not on these r
i 22 particular ones.
I was doing all of this research at j
23 one time.
24 This was written up after everything was done.
l
()
25 0
I see.
s Sonntag Reporting Servicef. Ltd.
Geneva, Illinolli 60134 i
(312) 232-0262 i
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1 And I think you stated that you checked Phillips 2
Getschow.
3 It's correct, is it not, that Phillips Getschow was 4
the organization on site that procured weld rod for 5
Comstock's use and issued it to Comstock; is that right?
6 A
Well, maybe I should go with the sequence in which I 7
done this.
8 I first checked Comstock's QC vault and was unable 9
to come up with any certification papers for practically 10 any of these heat numbers.
j 11 I then went back to Irv DeWald, which said that i
12 Phillips Getschow was the one that supplied us with the 13 rod.
14 I went to their QC Department, which maintained a 15 log reflecting all of the heat numbers of all types of 16 filler material that they had received.
17 I took the list of numbers that I had with them and 4
1 18 crossed them with their -- their list reflecting the 19 heat numbers that had been received on site and 20 issued, and I excluded those numbers that were, in fact, 21 a good -- good heat numbers and just retained those that 22 didn't reflect on their list.
23 And I went back to Irv again and I said, "I've 24 still got problems here."
He says, "I think we may have
()
25 received some rod from CECO," so I go to the CECO weld Sonntaa ReDortina Service, Ltd.
1 Geneva', Illinois 60134 (312) 232-0262
)
5642 O
1
)
1 engineer, which introduced me to this massive filing i
j 2
system that he had of MRR's in these large books, and he 3
says, "What you are looking for is probably in these 4
books"; and I spent several -- or a couple of days, at i
j 5
least, just setting at a desk going through these books j
6 looking for these particular heat numbers.
I 7
(Indicating.)
i j
8 Now, in these books, they had MRR's on all the 9
structural steel and piping and everything else that had
]
10 been received on the site; but I had to -- to dig out in l
j 11 between all of this these particular numbers, and after i
12 going through it, these three numbers I could not come I
i 13 up with.
14 MR. GUILD:
Could the witness state what an i
15 MRR is for the record?
s l
l 16 THE WITNESS:
That's a Material Receiving i
17 Report.
18 MR. GUILD:
Thank you.
b 1
19 BY MR. MILLER:
3 20 0
That indicates that the quality -- or safety-related i
j 21 material was received on site in a specified condition l
22 and with appropriate documentation; correct?
i*
23 A
That.is what it is supposed to signify, yes.
24 0
Okay.
25 THE WITNESS:
Can we go to the bathroom?
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 s
]
(312) 232-0262 iu
i 5643 J
1 MR. MILLER:
Why certainly.
2 JUDGE GROSSMAN:
Yes, sure.
3 We'll take 10 minutes now.
4 (WHEREUPON, a recess was had, after which 5
the hearing was resumed as follows:)
6 (The document was thereupon marked 1
7 Applicant's Group Exhibit No. 67 for 8
identification as of June 25, 1986.)
I 9
JUDGE GROSSMAN:
We're back in session.
10 Mr. Miller.
(
11 MR. MILLER:
All right.
t
[]
12 BY MR. MILLER:
\\J' 13 Q
Mr. Puckett, I'd like you to look at the inspection 14 report that Mr. Schapker prepared on this -- on your 15 allegations.
It's Applicant's Exhibit 51.
l 16 At Page 7 --
17 A
Is this the one dated November the 21st, 1985?
18 Q
Yes, sir.
j 19 A
Okay.
20 Q
And my question is:
21 If you look at the -- would you just read to 22 yourself the -- the paragraph under "NRC Findings" at 23 the bottom of Page 7.
i 24 A
"The NRC inspector" --
. ()
25 Q
No, no, no.
I'm sorry.
To yourself, sir.
i Sonntaa Reportina Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
5644 O
1 A
Okay.
2 MR. BERRY:
What page was that?
What page?
3 MR. MILLER:
Page 7.
l 4
BY MR. MILLER:
5 Q
Mr. Puckett, when you discussed your allegations with t
6 Mr. Schapker, did you identify the three heat numbers 7
that are found in Applicant's Exhibit 66 -- that is, 8
your memorandum to Mr. Saklak dated August 17, 1984 --
9 to Mr. Schapker?
10 A
Yes, sir, I did.
j 11 Q
All right.
Now, in the inspection report, the -- one of 12 the three heat numbers that you could not locate a -- a 13 certified document for is 401S7441, and in Applicant's 14 Exhibit 51, Mr. Schapker's report, it's typed as j
15 40157441.
16 A
Yes, sir.
17 Q
And did you provide Mr. Schapker with a copy of 18 Applicant's Exhibit 66?
19 A
I do not think that I provided Mr. Schapker with any 20 kind of documentation.
21 Q
All right.
But you told him the heat numbers that you 22 were unable to locate; correct?
23 A
No, sir, I don't think I did.
24 I think that was in the -- I think I told the NRC
(])
25 Inspector at Glen Ellyn this, which may have passed it Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
5645
)
1 to Mr. Schapker.
2 Q
I see.
3 You were --
4 A
I don't recall if I did or did not relate these numbers 5
to Mr. Schapker.
6 Q
All right.
But -- well, you referred to the NRC 7
Inspectors in Glen Ellyn.
8 You were interviewed --
9 A
Yes, sir.
10 0
-- by the inspectors at Glen Ellyn; correct?
11 A
Yes, sir, g$
12 Q
Now, if you turn to Applicant's Exhibit 67.
r
\\~)
13 (Indicating.)
14 Q
Yes, sir.
15 Can you tell us what these documents purport to be?
16 A
It's a -- they call them a CMTR, which is a certified 17 Material Test Report.
18 Q
And it is this type of document that you were 19 researching during July and August of 1984 to find good 20 heat numbers for -- or adequate documentation for the 21 heat numbers that were recorded on the Form 57; is that 22 right?
23 A
This is the type of documents that I was looking at, 24 yes, sir.
(])
25 Q
All right.
Can we agree that the top page of Sonntag Reportina Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
5646 l
C) i 1
Applicant's Exhibit 67 appears to have the Heat No.
2 401S7441 on it?.
3 A
67?
4 Q
Yes, sir.
5 A
It's 402S.
]
6 JUDGE COLE:
They are not in the same order 7
you have.
I 8
MR. MILLER:
Oh, I'm sorry.
i 9
JUDGE GROSSMAN:
Look at the one that says 1
10 Schapker Deposition Exhibit 5.
11 MR. MILLER:
Right, in the upper right-hand 12 corner.
j 13 A
(Continuing.)
Okay.
It's 40lS7441.
i 14 BY MR. MILLER:
15 Q
All right.
And that is the CMTR for one of the three 16 heat numbers that you were unable to locate in the 17 summer of 1984; correct?
18 A
Sir, I'm not really sure.
19 The numbers that Mr. Schapker has down on here 20 versus the numbers that are reflected on these CMTR's 21 are different.
j 22 0
Yec.
23 Well, would you go back to Applicant's Exhibit 66, i
24 your memorandum, Mr. Puckett.
()
25 A
Yes, sir.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
5647
)
1 Q
All right.
And, in fact, you say you were successful in 2
all but three heats, and the first one you identify is 3
40137441; correct?
4 A
Yes, sir.
5 0
All right.
Can we agree that the top sheet of 6
Applicant's Exhibit 67 is, in fact, a CMTR for Heat No.
7 401S7441?
8 JUDGE GROSSMAN:
l' think it may be the last 9
page of that exhibit.
10 They are not in the same order.
11 A
Yes, sir.
12 BY MR. MILLER:
13 0
All right.
And what does the stamp in the lower 14 right-hand corner of that document signify, sir; that 15 is, the " reviewed and approved" stamp; do you know?
16 A
Are you -- okay.
17 QC accepted dated 2/14/85, is that what you are 18 referring to?
19 0
I'm sorry.
I think we stapled them together wrong.
20 It's the stamp on this heat number -- the CMTR for 21 Heat No. 40lS7441, and there is a stamp in the lower 22 right-hand corner.
23 Have you ever seen that stamp on any of the 24 documents that you reviewed carrying out your research?
({)
25 A
I had not looked for that particular stamp anywhere.
I Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262 5
i 4
5648
()
1 was only looking for the heat and/or lot numbers when I 2
was researching these rods.
4 3
0 I see.
Okay.
4 Well, does "PG-QA Department" indicate to you that 5
Phillips Getschow's Quality Assurance Department had 6
reviewed and approved this document?
7 A
Yes, sir.
8 Q
Okay.
Now, I think you said that in conducting your 9
research, that you looked for some obvious 10 transpositions or a mistype of a letter for a number; 11 correct?
12 A
Yes, sir, I did.
13 Q
And you were willing to accept those kinds of 14 differences because they were probably just clerical 15 errors by the typist?
16 A
Yes, sir.
17 MR. MILLER:
Okay.
Excuse me for one second.
18 Do you need to --
19 JUDGE GROSSMAN:
Yes, I think we need a 20 five-minute break now.
21 (WHEREUPON, a recess was had, after which 22 the hearing was resumed as follows:)
23 JUDGE GROSSMAN:
Let's go back on the record.
24 MR. MILLER:
Could I have the last question
(])
25 and answer read -- I'm sorry -- Mr. Reporter.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
i 5649 O
1 (The question and answer were thereupon 2
read by the Reporter.)
3 BY MR. MILLER:
4 Q
Now, looking at what on my page -- in my Exhibit 67 is 5
the second page, but it's -- it's, I believe, t~ne first 6
page of your exhibit, Mr. Puckett.
7 A
(Indicating.)
8 Q
Yes, sir.
9 It's the document that has the Heat No. 402S90ll.
10 Do you see that?
11 A
Yes, sir.
12 0
Is that a Certified Material Test Report that you would 13 accept as being adequate documentation for the heat 14 number that you identified in Applicant's Exhibit 66 as 15 401S9011?
16 A
Yes, sir.
17 0
Okay.
And the -- the final heat number that you were 18 not successful on was a Heat No. 35202061.
19 And I think you said where you couldn't find a heat 20 number, you would accept a lot number; is that correct?
21 A
Yes, sir.
22 0
Is the lot number also a unique identifying number for 23 an individual batch of material?
24 A
Yes, sir.
(])
25 Q
Okay.
And if you look at what in my copy is the last Sonntag Reportina Service, Ltd.
Geneva, Illinois 60134 l
(312) 232-0262 l
5650
(:)
1 page of Applicant's Exhibit 67, you see that there is a 2
Lot No. 3S202061 for Type E6013 weld rod.
3 Given your approach to -- when you were researching 4
this issue, would you have accepted this CMTR as being 5
applicable to the Heat No. 35202061?
6 A
Yes, sir.
7 JUDGE CALLIHAN:
Mr. Miller, in your 8
Applicant's Exhibit 67 --- in particular, Mr. Schapker's 9
Deposition Exhibit No. 5, at any rate, I have 10 highlighting trouble.
11 What type does your copy show --
12 MR. MILLER:
That's a --
13 JUDGE CALLIHAN:
-- or does it?
14 MR. MILLER:
That's a very good question, 15 because I have the identical copy, and it does not show 16 the weld rod type, because that was, in fact --
17 JUDGE CALLIHAN:
Would you presume it was 18 7018?
19 MR. MILLER:
The only way we could tell --
20 let me ask the witness a question.
21 BY MR. MILLER:
22 O
On the trade name of the 7018 rod of -- the rod that's 23 on the Heat No'. 40lS7441 is indicated as Atom Arc 7018.
24 Does that indicate that it was a 7018 weld rod?
()
25 A
I would accept that, yes, sir.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
i l
5651 1
Q Okay.
t 2
JUDGE CALLIHAN:
Thank you.
3 BY MR. MILLER:
I 4
Q Now, it's -- it's a fact, isn't it, Mr. Puckett, that 5
when you began your research into this issue in July of l
l 6
1984, you didn't believe that there was any safety 7
problem involved with tracing these heat numbers down; 8
correct?
9 A
With the numbers with the exception of the three that I 10 said that I could not find the CMTR's for, which is 11 these forms here.
12 (Indicating.)
13 The others I had a question.
That's -- that's what 14 prompted the letter that I wrote to Mr. DeWald, to see 15 what other follow up we might be able to do on these i
16 heats.
i 17 Q
All right.
Well, to the extent that you weren't 18 yourself able to find the CMTR's for these three heat 19 numbers, was there, in your opinion, a non-conforming 20 condition?
I 21 A
Not -- at this point, I would not say that there was a 22 non-conforming condition.
23 I would have been concerned with the fact that this 24 is a quality document, and for at least myself, it was
()
25 not ready retrievable, and that we didn't have this Sonntaa ReDortino Service, Ltd.
Geneva, Illinois 60134
~
(312) 232-0262 L
5652
($)
1 document in our QC vault or in an area where it was 2
ready retrievable at any -- at any point.
3 Q
I may be -- okay, all right.
4 So that on August 17, 1984, when you wrote this A
5 memorandum to Mr. DeWald, you had satisfied yourself 6
about the -- the heat number of the weld rod issued with 7
the exception of the three CMTR's that you were not able 8
to find; correct?
9 A
Yes, sir.
10 0
And at that point in time, even for those three, it was 11 not, in your judgment, a non-conforming condition which 12 required the initiation of an NCR; correct?
13 A
Well, it was my opinion, if this were to be the case, 14 Mr. DeWald would take that responsibility, as-I was not 15 yet qualified.
16 Q
All right.
Well, in fact, you made a suggestion, in the 17 last sentence of this memorandum, as to what Mr. DeWald 18 ought to do, didn't you?
19 A
I'll read it and see exactly what I said.
20 Yes, sir.
21 Q
And what you suggested was a more thorough review and 22 in-house identification of any major problems we may 23 have; correct?
24 A
Yes, sir.
()
25 0
And it was not your suggestion, at least in writing, to Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
5653 i
1 Mr. DeWald that a Non-Conformance Report be initiated?
2 A
Well, you don't write a Non-Conformance Report because 3
you think there might be a problem.
4 If we would have found that there was no MRR's or 5
CMTR's for this rod, then we would have had a 6
non-conformance condition; but at this point, a 7
non-conformance had not been committed.
8 Q
I see.
9 And that's because your research was only partially 10
. completed, and -- and what you were suggesting was, 11 "Let's look further, see if we can find the CMTR's," for 12 the three heats that -- that you were unsuccessful in 13 finding, "and then assess the situation"; correct?
14 A
Yes, sir.
15 Q
So that at this point in time -- that is, August 17th of 16 1984 -- as far as you knew, there was no safety concern 17 with respect to the weld rod slip issued; correct?
18 A
With those -- with the exception of these three, I still 19 had a concern about them, because I hadn't personally 20 seen Certified Material Test Reports or I had no 21 knowledge that these reports even existed.
22 Q
All right.
Was there ever a situation that you 23 uncovered, Mr. Puckett, where E7018 weld rod was called 24 for but the weld filler metal withdrawal slip indicated
(])
25 that E6013 material had been, in fact, withdrawn?
Ronntag Reporting Service Ltd.
Geneva, Illinois 60134 (312) 232-0262
5654 1
A I don't remember the sequence where it was the heat 2
number for E7018 and the filler material was E6013 or 3
vice versa, but they did have rod slips that reflected 4
those things.
5 (Indicating. )
6 Q
All right.
And do you recall specifically any situation 7
in which the heat number indicated that E6013 weld rod 8
had been withdrawn and E7018 was called for?
9 A
I don't remember any specifics.
10 0
Okay, all right.
11 Would that have been an issue that you would have 12 called Mr. DeWald's attention to had you found them?
13 A
Well, I would -- I would call it to his attention unless 14 I was aware that he was already aware of this.
15 Q
The CMTR's, the ones we have marked as Applicant's 16 Exhibit 67, in fact, indicate the tensile strength of 17 each of the heat numbers of rod that are reflected 18 there; is that right?
19 A
Yes, sir, i
20 0
All right.
And just looking at the -- at the one that 21 refers to E6013 rod, that has a tensile strength of 22 82,000 psi, does it not?
23 A
That is reflected here, yes, sir.
24 Q
Which would make it not only as meeting the
()
25 specification for E6013 rod in terms of tensile Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
5655 1
strength, but for E7018 rod as well in terms -- just in 2
terms of tensile strength; correct?
3 A
In terms of tensile strength, it appears to.
4 Q
Okay.
I'm correct, am I not, Mr. Puckett, that at no 5
time on August 17th or prior did you recommend a stop 6
work on welding with respect to any discrepancies that 7
you discovered in the issuance of -- of weld rod 8
material?
9 A
I don't recall recommending a stop work because of weld 10 rod withdrawal.
11 Q
All right.
Now, let's turn to the concern that you r"g 12 expressed with respect to control of construction LJ 13 materials.
14 And I think you stated that the construction 15 materials were -- the control of construction materials 16 was -- was deemed inadequate by you; is that correct?
17 A
In my opinion, it was inadequate.
18 Q
.Now, Mr. Puckett, do you -- do you know the number of 19 the -- well, do you recall reviewing the L. K. Comstock
^
20 procedure for control of --
21 A
I don't recall.
22 I -- more than likely I did read through it, but I 23 don't -- you know, I can't recall it right -ow at this 24 time.
()
25 (Indicating.)
Sonntaa Reportina Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
5656 i
1 0
Do you remember the -- the. title of the procedure at l
i 2
all?
l 3
A Off the top of my head, I don't.
l l
i 4
These varies within -- within the industry.
l o
0 I see.
j
'6 It's correct, is it not, that the only procedure l
j 7
that L.
K..Comstock has with regard to the control of 8
construction materials, other than weld filler rod 9
material, is the receiving inspection procedure?
10 A
It may be so.
i l
11 My concern did not arrive from the procedure I
j 12 itself, but frou 10 CFR, Appendix B, Criteria 8, I think O
13 it is, which requires that you maintain traceability of 14 the material up until time of installation.
15 Again, I might reflect that the problems that I was 16 recognizing at Braidwood was the ve ry type of problems 17 that we had at the Zimmer project; and I wanted to 18 prevent, if possible, the same type of problems that we 19 were having.
20 0
All right.
Let me ask you to describe, if you will, 21 your understanding of what Criterion 8 of Appendix B 22 required in terms of traceability of structural 23 mate rials that were used by Comstock f or safety-related 24 work.
25 A
Well, again, you are asking what I think, how I think Sonntag Reporting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
.)
u
i i
j 5657 i
1 that it should be.
1 i
2 O
Yes, sir.
3 A
Well, how I think it should be is from the time that the 4
material is received within the Comstock organization l
5 from the warehouse, with the material receiving reports j
6 and the material being marked, that those ma rkings and i
j 7
that material should be kept under supervision, so to i
l 8
s pe ak, from time of receipt until time of installation 9
in the power plant and these numbers be maintained on 10 all of these parts at all time.
11 0
So, in other words, if Comstock received some hanger
{
4 i
4 12 steel that was marked with a unique identification
)
l 13 numbe r, such as a lot number, that as that steel was cut l
14 and installed in the plant, the lot number ought to be i
15 marked on each piece of that steel; is that correct?
16 A
The way it is supposed to be done is if they are going i
j 17 to use a piece of steel, they are supposed to mark that j
J e
18 piece of steel before it's cut from the mother piece, so t
1 19 to speak --
i s
1 i
i 20 0
So that each --
i I
i 21 A
-- and then cut it.
I 1
j 22 What I observed at Braidwood was they would cut i
23 this material from pieces in the rack, fabricate it and l
24 then transfe r the numbe rs to it af ter fabrication.
25 O
Mr. Puckett --
}
i l
1 l
Sonntag Reporting Service, Ltd.
j ueneva, Illinois 60134 l
(312) 232-0262
l l
5658 i
d i ([]
l i
1 A
I pe rsonally witnessed this.
l 2
0 So, in fact, the numbe rs, as fa r as you could tell, were 3
being transferred to the steel that was being fabricated i
4 into hangers or --
(
5 A
There was numbers being transferred.
{
l 6
Now, if it was the correct numbers -- because they 7
had several different numbers on several different 8
pieces of steel in the pile -- if the correct numbers i
l 9
were being transferred, I really don't know.
10 0
Mr. Puckett, do you know whether every piece of steel,
(
11 as you say, in the pile had a unique identifying number l
12 that was traceable back to the appropriate quality i
[
13 doc umenta t ion, such as the CMTR?
4 i
i 14 A
I know that the material that I seen in the racks had l
l 15 numbe rs on them.
l i
i 16 I never t ried to trace any of these numbers back.
17 0
Well, was it your understanding, Mr. Puckett, that all 18 of that material was supposed to have the proper 19 pedigree, if you will?
l 20 A
Yes, sir, it was my understanding that it did.
l 21 Q
All right.
Now, Mr. Puckett, at Zimmer when you were a i
l 22 mechanical inspector and a lead mechanical inspector, 23 the scope of your inspection tasks were basically both 24 ASME and ANS work; correct?
25 A
ASME, AUS and ANSI.
Sonntag Reporting Service, Ltd.
7 Geneva, Illinois 60134 l
(312) 232-0262 L.
5659 1
Q And it is correct, is it not, that the ASME Code 2
requires that there be specific traceability by heat 3
number or other unique identifying ma rk for each 4
component that is installed in an ASME Code system?
5 A
Yes, sir.
6 0'
And that is, in fact, a requirement of the ASME Code; 7
correct?
8 A
Yes, sir.
9 O
How, then, is there any compa rable requirement that you 10 can point us to in the AWS Code or any other code --
11 A
I --
12 C
-- that deals with the scope of Comstock's electrical 13 work at Braidwood?
14 A
Again, sir, my concerns did not come from AUS or my 15 conce rns didn't come from the Comstock procedures but 16 from 10 CFR 5 0, Appendix B.
17 Q
Yes, sir; but could you answer my question, please?
18 A
T really never looked in the Code, the AWS Code, for 19 that purpose, no.
20 I couldn't tell you without researching.
21 Q
Mr. Puckett, at Zimmer, while you were there, was the re 22 any requirement for non-ASME work that there be unique 23 traceability of the components by means of transferring 24 heat numbe rs to pieces of steel, as you have described f's 25 ought to be done?
O Sonntag Reporting Service, Ltd.
Geneva, illinois 60134 (312) 232-0262
5660 f~h
()
1 A
Yes, sir.
2 Q
All right.
And was that requirement embodied in a 3
procedure?
4 A
I am not at all sure about that.
5 Zimmer has even been farther back than Braidwood.
6 JUDGE GROSSMAM:
Excuse me.
7 Could you repeat that last answer, Reporter?
8 (The answer was thereupon read by the 1
9 Repor te r. )
i 10 BY MR. MILLER:
11 Q
Mr. Puckett, prior to the time that you left Braidwood, 12 did you raise this conce rn with any person at L.
K.
]
13 Comstock?
14 A
Ve rbally.
15 Q
With whom?
16 A
To Mr. Saklak and Mr. DeWald.
17 Q
Do you recall when you did so?
18 A
It was ea rly.
I would say that it would have been in 19 June that I raised the concern with Mr. Saklak, and his 20 comments were not too receptive.
21 And later I raised the same thing with Mr. DeWald; 22 and, as it turned out, his comments were not too 23 receptive, either.
24 Q
Did --
25 A
In fact, the comment that I received from Mr. Saklak Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
5661 1
was, "Ne are aware of the problem that we have, and 2
Commonwealth Edison has assured us that there will be 3
paper work for eve rything when the project is finished."
4 0
I see.
You unde rstood this to mean that there would be 5
complete traceability from the sheets of steel to the 6
individual hanger by heat number when the project was 7
complete?
8 A
Speaking honestly, sir, I am not really sure what I 9
thought he meant by that.
10 Q
You didn't understand what he was talking about?
11 A
Well, I understood what he was talking about but I 12 didn't understand how he meant it.
13 0
Did you inquire as to what he meant?
14 A
No, sir, I did not.
15 Q
When you raised this with Mr. DeWald, what, if anything, 16 did he say to you?
17 A
He shrugged his shoulders.
18 0
So ho said nothing?
19 A
Nothing that I can recall.
20 Q
And you let the issue drop at that point or did you 21 raise it again?
22 A
I don't recall, other than the fact that I may have 23 mentioned that we maybe should have a procedure that 24 regulated better the use of that material once it was
}
within the Comstock organization.
25 Sonntag Reporting Service, Ltd.
Geneva, Illinois evids (312) 232-0262
5662 O
1 That rega rdless of how CECO handled their 2
materials, that maybe we should cover our own butt, so 3
to speak, by having a better method of having 4
traceability.to this material.
5 Q
And the basis for your conce rn was that the practice, as 6'
' you observed it, was in violation of a regulatory 7
requirement of the NRC?
8 A
Was not adequate.
9 Q
And, therefore, in violation of the regulatory 10 requirement; correct?
i 11 A
I would -- it was my pension -- opinion, pardon me --
12 that it was in violation of 10 CFR 50, Appendix B.
13 O
Mr. Puckett, isn't that the clearest sort of 14 nonconforming condition that requires the initiation of 15 an NCR?
16 A
Sir, I have told you and told you that it was a company 17 policy, until you are qualified, you do not make out a 18 Nonconformance Report.
19 0
Yes, sir.
20 Would you answer my question, please?
21 A
I would not say that it was a nonconforming condition at 22 this point.
23 0
I see.
So, in your opinion, at that point in time a 24 violation of MRC regulatory requirements was not a
{}
25 nonconforming condition that called for the initiation Sonntag Reporting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262 i
l i
5663 O
1 of an NCR?
2 A
Well, that's why I addressed it to Mr. Saklak and Mr.
3 DeWald.
4 I thought that if it had been, they would initiate 5
a Nonconformance Report.
6 Q
But it was your own personal opinion at that point in 7
time that it was not?
8 A
It was my own personal opinion at that time that the way 9
that the material was being used and ma rked was not 10 satisf actory to myself.
11 And, again, as I might say, at the Zimmer project, 12 we had a lot of problems for this ve ry same type of O.
13 thing.
14 I did not wan't it happening at L. K. Comstock.
15 Q
Problems with the NRC; correct?
16 A
Problems with the NRC and with other audit teams.
17 MR. MILLER:
Could I have my last question 18 read back, pl ease, Mr. Peporter?
19 (The record was thereupon read by the 20 Reporter.)
21 BY MR. MILLER:
22 O
Mr. Puckett, I don't think you fully answered my 23 question as to whether or not you believed in June of 24 1984, when you discovered this issue, as to whether or 25 not it was a nonconforming condition.
Sonntag Reporting Service, Ltd.
Geneva, 1111nols bU134 (312) 232-0262
=,
5664 1
A I never thought about it at that time.
2 Q
As you sit here today --
3 A
I mean, I can't sit here now and tell you that I thought 4
about it as being a nonconforming condition, because at 5
this time I don't recall of thinking of it as being a 6
nonconforming condition; but I am thinking that it very 7
well could have developed into that.
8 Q
As you sit here today, Mr. Puckett, do you have an 9
opinion as to whether or not the Comstock control of 10 construction material prdcedure, as you understood it, 11 was a nonconforming condition which should have called 12 for the initiation of an NCR?
13 A
I don't know how to answer your question.
14 It's not something that you answer yes or no, 15 because I don't fully understand it.
16 Q
Well, I don't mean to make the question obscure.
17 You have testified as to what your opinion was in 18 June of 1984.
19 Ne are now in 1986; and I am trying to determine 20 whether you have an opinion right now, as you sit here 21 today, as to whether or not the control of construction 22 materials by Comstock, which you have characterized as a 23 violation of NRC requirements, was a nonconforming 24 condition and should have called for the initiation of a f'T 25 Nonconformance Report.
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MR. GUILD:
Well, you sort of -- objection.
2 The witness's testimony, in fact, was that he 3
thought it was inadequate.
4 Why did he think it was inadequate?
Because the 5
requirements of Appendix B, Criterion 8, suggested a 6
certain standard.
7 It was counsel's conclusion that that equaled a 8
violation of that Appendix B criterion, upon which then 9
the question became:
Does that equal a nonconforming
~
10 condition?
11 JUDGE GROSSMAN:
Actually, I think the 12 witness is having trouble not only because of that but
()
13 because of the NRC action at Zimmer; and I --
14 MR. MILLER:
Well, I intend to explore that.
15 JUDGE GROSSMAN:
-- don't know how much more 16 you can get from the witness on that, because you are 17 asking him to, I believe, agree or disagree with the i
18 URC's position in Zimmer.
19 Is that so?
Is that part of what the problem is?
20 THE WITNESS:
Partially so, yes.
21 It's, as he said, there was no procedure available 22
-- or I don't recall seeing one -- saying how this 23 material should be handled in our own.
24 I know that the practices that I seen taking place 25 at Braidwood, those same type of practices at the Zimmer Sonntag Reporting Service, Ltd.
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1 project were considered inadequate.
2 BY MR. MILLER:
3 Q
When you say " inadequate," Mr. Puckett, do you mean that l
i l
4 they were in violation of 10 CFR 50, Appendix B, j
5 Criterion 8?
i i
6 A
I would say that they would have been.
7 JUDGE GROSSMAN:
Well, I think the problem is
)
8 this:
l
}
9 Is it your understanding that the NRC asserted that I
10 they were inadequate conditions and, therefore, a i
11 nonconforming condition?
{
l 12 THE WITNESS:
I don't recall if there was
)
I 13 Nonconformance Reports initiated either at Zimmer or at i
14 Braidwood; but I am just saying that the same type of j
i 15 handling of material that took place at Zimmer and was 16 of great concern to NRC, I seen these same things i
17 happening at Braidwood.
l 18 And T wanted to take care of these problems at j
I 19 Braidwood before NRC identified them as being problems l
20 there as we13.
j 21 JUDGE GROSSMAN:
Well, Mr. Miller, I think 22 that exhausts --
23 MR. MILLER:
I don't believe it does.
24 JUDGE GROSSMAN:
his understanding of the
{}
25 situation.
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f 1
MR. MILLER:
You know, your Honor, this is --
2 Mr. Puckett is here.
3 He has made allegations which really call into 4
question the entire welding program at Braidwood on the 5
basis of statements that there was a widespread 6
breakdown.
7 As I begin to examine the witness with respect to 8
the specifics, in my judgment, the seriousness of the 9
allegation diminishes as the witness is compelled to 10 deal with specific questions.
11 I think that I have not exhausted the subject 12 matter and I would like leave of the Board to continue.
(
13 MR. GUILD:
Well, I disagree with counsel's 14 characterization.
1 j
15 JUDGE GROSSMAN:
First of all, I am not sure 16 I agree with that characterization, either, Mr. Miller.
17 I will have to reread the transcript to see if it's 18 justified.
19 But we seem to have reached an impasse on this 20 questioning; and I believe the witness's answer was that 21 this was the procedure that was used at Zimmer that was 22 criticized by the NRC as being improper and he didn't 23 want to see the same thing done at Braidwood.
24 Now, you asked him to characterize it as a pg 25 nonconforming condition; and he said he didn't visualize J
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it in those terms at that time.
j l
t i
2 So how nuch further can you go on that?
I don't l
i
)
3 understand.
Nor can he relate to that specific opinion j
l t
4 or area right now.
5 Well, he has given you the ansver.
i 6
MR. MILLER:
Look, your Honor, I think that l
7 what he has told te --
i 8
JUDGE GROSSMAN:
Yes.
l 9
MR. MILLER:
-- is that he regards this as a 10 violation of 10 CFR, Appendix B, a violation of an NRC l
11 regulation.
i 12 JUDGE GROSSMAN; Dased upon the action taken
>(:)
j 13 by the URC ht Zimmer.
)
i
?
14 Now, if you are going to ask him for further j
l I
15 characterization as on attorney or as a writer of 16 regulations, it's just not plausible.
I 17 MR. MILLER:
No, I am not going to'ack him.
l l
18 All I want to discover is and have as a part of i
l 19 this record is as to whether or not this witness c
{
20 believes that a violation of NRC regulations calls for l
I l
l 21 the initiation of a Nonconformance Report.
That is one j
22 of the thrusts of this questioning.
i l
23 I believe that we had gotten to the point where the j
24 witness had indicated that it was not his opinion in the I
25 summe r of 1984 that that was the case; and I was Sonntag Reporting Service, Ltd.
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attempting to --
t 2
MR. GUILD:
He had no opinion.
3 MR. MILLER:
-- explore whether, as he sits l
4 here today, he has any opinion today as to whether or 3
not a violation of MRC requirements calls for the i
I l
6 initiation of a Nonconformance Report.
l l
/
)
7 He can relate it to Zimmer or any other thing in 8
his background and experience; but I believe I am i
9 entitled to an answer to that question, sir.
i 10 MR. BERRY:
Staff feels that question is I
11 p ro pe r, M r. Chairman.
L 12 JUDGE GROSSMAN:
Pardon?
l 13 MR. BERRY:
Staff would agree with Applicant l
I 14 on that.
I 15 Staff thinks that is a proper question, whether the I
16 witness rega rds a violation of NRC regulations as a 17 nonconforming condition or something that should be 18 identified during the course of the construction of a j
l l
19 nuclear power plant; and the Staff -- it strikes un as a 20 purely proper question.
21 If the witness doesn't know, he doesn't know; but 22 the question itself seems proper.
23 MR. GUILD:
Nell, he stated with respect uo 24 the time in question that he had no opinion on the
{}
subject.
25 Sonntag Reporting Service,,
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O 1
Now we have another question, and that is what the 2
witness's opinion is today.
Then that stands on 3
separate footing and, perhaps, independent of anything 4
that counsel has laid as a foundation.
l 5
If he wants to ask that question in the abstract, 6
whether it's relevant or not, I am not sure; but, at i
7 least, we can say that it's not asked and answered.
8 JUDGE GROSSMAN:
I don't see what value that 9
question would have, anyway, as to now whether he would 10 view it as one way or the other.
11 The question is really how he would have viewed it 12 in the past, and he has indicated that.
O 13 MR. MILLER:
Well, your Honor --
14 JUDGE GROSSMAN:
Now, if you want to define 15 it as a nonconforming condition and, apparently, as 16 Staff wants to, state as a hypothesis that there is a 17 nonconforming condition, whether he should report it, 18 well, that's an entirely different question.
19 MR. MILLER:
Well, your Honor, this witness's 20 testimony, as I understand it -- and I think the 21 transcript will reflect when we sift through a lot of 22 the statements here -- is that a violation of NRC l
23 requirements does not necessarily require the initia tion 24 of a Nonconformance Report.
{}
This is a person who has come before this Boa rd as 25 l
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1 someone who was terminated by Comstock for raising 2
quality concerns.
There can't be any more 3
straightforwa rd quality conce rn than a violation of NRC 4
requirements.
5 Yet, it is this witness's testimony that such a 6
condition does not necessarily call for --
7 MR. GUILD:
Mr. Chairman, the witness's 8
testimony --
9 JUDGE GROSSMAN:
First of all, I don't 10 believe you characterize his position properly.
11 He indicated he raised this concern with Mr. DeWald 12 and Mr. Saklak and brought out the possibility that 13 there was an improper procedure and that he himself 14 under the procedures of the company could not have 15 initiated the NCR.
16 Now, I just don't know what else you are going to 17 get from him on this.
18 MR. MILLER:
Well --
19 JUDGE GROSSMAN:
If you phrase another 20 question that appears to me or the witness to be 21 susceptible to answer, you are welcome to it; but it 22 seems to me we reached an impasse here.
23 MR. MILLER:
Your Honor, I find your comments 24 and what I understand to be your ruling really at odds
}
with your rulings when Mr. DeWald and Mr. Seltmann were 25 Sonntag Reporting Service, _
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Geneva, Illinois ou144 (312) 232-0262
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asked -- excuse me, if I may finish -- were asked as to 2
whether or not the initiation of an NCR automatically 3
triggered a stop-work situation, which suggested to me 4
that the Board had an understandable and serious 5
interest in determining the situations in which quality 6
conce rns led to the initiation of appropriate 7
documentation and an actual stop work.
8 There was extensive examination by you, Judge 9
Grossman, of those witnesses as to whether or not they 10 had any discretion when a nonconforming condition was 11 noted and an NCR was written as to whether or not to let 12 work continue.
13 Now, what we have here is a witness who is hostile 14 to the Applicant, who has indicated that, in his 15 judgment, that when there is a violation of NRC 16 regulations, that it does not necessarily call for the 17 initiation of a Nonconformance Report.
j 18 JUDGE GROSSMAN:
Well, I don't recall that 19 answer being given that way, Mr. Miller.
That's your 20 characterization.
21 I don't know that the transcript will reflect that; 22 but if that is the answer that you think you got, my 23 question is:
What more are you after?
j 24 MR. MILLER:
Well, the witness then went on j
25 to qualify it, by saying that, of course, he couldn't i
Sonntag Reporting Service, Ltd.
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1 initiate an NCR, because of the policy on the site.
2 Therefore, I think that I am entitled to ask, as he 3
is sitting here today, as an ex-employee of Comstock, 4
does he believe that a Nonconformance Report should have 5
been issued with respect to the violation of NRC 6
requirements that he observed in the way in which 7
Comstock controlled its construction materials.
8 JUDGE GROSSMAN:
Can you answer the question 9
that was just posed by Mr. Miller?
10 THE WITNESS:
Had I been qualified, I may 11 have initiated a Nonconformance Report based on what I 12 had seen, yes.
~
13 BY MP. MILLER:
14 0
You say you may have.
15 What would have --
16 A
I would have done some further research.
I would have 17 looked at it closer and I would observe things a little 18 closer.
19 As I said before, they had the materials in the 20 racks; and there wou several different types of 21 materials there.
22 They were cutting this material, putting it on the 23 bench and fabricating the component out of it and then 24 they would go back to the rack, get the number off of it 25 and transfer it to the material that they now have
{}
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5674 1
welded.
2 Now, there is a possibility -- thus far, no 3
nonconf orming situa tion has occurred.
However, if I 4
observed them going back and getting what I knew to be a 5
wrong number and tt3noferring it to that material, then 6
that would have been a nonconforming condition.
7 Q
I see.
So you just didn't know, hadn't done enough 8
looking at Braidwood in the summer of 1984 to determine 9
whether there was even a nonconforming condition, did 10 you?
11 A
As I said before, I thought that their control was 12 inadequate.
(
13 0
But you didn't know whether or not there was a 14 nonconforming condition, did you?
15 A
I thought I answered that.
16 O
Answer the question, please.
17 MR. GUILD:
He has answered the question, 18 Counsel; and I object.
It's asked and answered.
19 JUDGE GROSSMAN:
Okay.
My understanding of 20 the answer is that that procedure could have led to a 21 nonconforming condition if they put the wrong number on.
22 Now, is that underctanding correct?
23 THE WITNESS:
Yes, sir.
24 JUDGE GROSSMAU:
Okay.
(~)
25 MR. MILLER:
And he didn't know whether or
\\._/
Sonntag Reporting Se rvice, Ltd.
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5675 1
not he would have to do more research in order to --
2 BY MR. MILLER:
3 0
You would have to do more research?
4 A
I would have done more observation before I wrote a 1
5 nonconforming -- a Nonconformance Report.
6 0
So it was, in fact, how the practice actually took place 7
in the field that determined whether or not there was a l
8 violation of Criterion 8; correct?
9 A
In the field, sir?
10 0
Well, in the fabrication shop.
I am sorry.
Wherever 11 these activities were taking place.
12 A
That is where the practice was that I observed.
O 13 I neve r obse rved these practices in the field.
14 Q
All right.
And it was how these practices took place in 15 the fabrication shop that determined whether or not 16 there was a violation of Criterion 8; correct?
17 A
The way the fabrication was taking place in the shop 18 concerned me.
19 0
But it was that activity rather than any procedure that 20 would determine for you whether or not there was a 21 violation of Criterion 8; correct?
22 A
Yes.
23 JUDGE GROSSMAN:
Are we finished with that 24 topic, Mr. Miller?
r 25 MR. MILLER:
I think so.
Sonntag Reporting Service, Ltd.
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--yr
5676 1
And I probably ought to move some exhibits into 2
evidence at this point in time.
3 JUDGE GROSSMAN:
Okay, fine.
4 THE WITNESS:
Can we go to the bathroom at 5
this point?
6 JUDGE GROSSMAN:
Yes, we are going to take a 7
break.
8 Why don't we move the exhibits in after the break?
9 MR. MILLER:
All right.
10 JUDGE GROSSMAN:
I have to call Washington, 11 anyway.
12 (WHEREUPON, a recess was had, after which O
13 the hearing was resumed as follows:)
14 JUDGE GROSSMAN:
Okay.
Back on the record.
15 Mr. Mille r.
16 MR. MILLER:
Yes.
17 BY MR. MILLER:
i 18 Q
Mr. Puckett, we are now going to turn to the concerns 19 that you identified --
20 MR. GUILD:
Mike, you were going to raise the 21 exhibits.
22 MR. MILLER:
I beg your pardon.
I was, j
23 indeed.
24 I would like to move at this time Exhibits 64
/
25 through 67 into evidence.
Sonntag Reporting Service, Ltd.
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JUDGE GROSSMAN:
Is there any objection?
2 MR.. GUILD:
Mr. Chairman, if I may --
3 MR. BERRY:
I am sorry.
4 Could I have those numbers again?
5 MR. MILLER:
64 through 67.
6 MR. GUILD:
Mr. Chairman, I have no 7
objections with respect to 64, 65 and 66, the memoranda 8
exchange between Mr. Puckett, Mr. Saklak and Mr. DeWald.
9 As to 67, I do object.
The documents -- I have a 10 problem with the mark-throughs on the documents; and the 11 problem is they just are not complete and legible with 12 the highlighting that appears on the face of the O
13 documents.
14 I don't contest their authenticity.
I just can't 15 tell from looking at the documents that there isn't 16 information that appears on those mark-throughs that 17 might be relevant, also.
18 MR. MILLER:
I will endeavor to obtain fully 19 legible copies of the exhibits and consult with Mr.
20 Guild and re-of fe r 67, 21 JUDGE GROSSMAN:
Okay.
We won't take it now e 22 because it would create a problem with the Reporter, so 23 we won't admit the document now; but once that is 24 cleared up, I am sure we will.
25 So we are receiving Exhibits 64, 65 and 66.
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1 (The documents were thereupon received 2
into evidence as Applicant's Exhibits 3
Nos. 64, 65 and 66.)
4 MR. MILLER:
Mr. Puckett, I would now like 5
to, as I said, move to the concerns that you expressed 6
with respect to the welder qualification records.
7 I would like the Reporter to mark as Applicant's 8
Exhibit 68 -- just a second -- a multi-page document, 9
the first three pages of which are in handwriting, the 10 next page of which is typed and the remaining pages are 11 also in handwriting.
12 (The document was thereupon marked as O
13 Applicant's Exhibit No. 68 for 14 identification as of June 25, 1986.)
15 JUDGE COLE:
All written by Mr. Puckett?
16 MR. MILLER:
I believe so; but we will 17 establish that on the record, Judge Cole.
18 BY MR. MILLER:
19 Q
Mr. Puckett, Applicant's Exhibit 68 was, in fact, 20 prepared by you, was it not?
21 A
Yes, sir.
22 0
The document was prepa red in response to a direction 23 from Mr. DeWald that was given to you shortly before you 24 lef t Braidwood, that you complete a review of all
{}
welders qualification records; is that correct?
25 Sonntag Reporting Service, Ltd.
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1 A
Yes, sir, with the exception of the typed portion, which 2
I had done on my own before Mr. DeWald -- well, 3
actually, it was Mr. Seltmann that asked me to do the 4
complete review of all welde rs ' qualifications.
5 Q
The typed page represents your review of the welders who 6
were then on site for Braidwood records?
7 A
It was the current welders' qualification file, yes.
8 0
And had you made a complete review of the current 9
welders' files?
10 A
No, not a complete review.
11 It was just a kind of a spot-type thing that I went 12 through to note the type of problems that we had on the 7,
V 13 welde rs qualification test records; but a thorough 14 review I had not done, no.
15 Q
And you had done this typed page on your own initiative 16 prior to the request from Mr. Seltmann; correct?
17 A
Yes.
18 O
And then the handwritten pages, do those represent 19 welde rs who were currently employed by Comstock or are 20 those welders whose employment was terminated by 21 Comst ock ?
22 A
These were in the dead file or the file that they put 23 the welde rs qualification test records in when they are 24 no longer working there.
U'~s 25 0
I see.
Now, there are,.are there not, repetitive l
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i 1
obse rvations in this document, Applicant's Exhibit 68?
2 That is, you observed the same sort of discrepancy 1
3 in the records for more than one welder?
4 A
Yes, I did.
5 Q
Okay.
And is it also correct that when you were 6
inte rviewed by the NRC, both in Glen Ellyn and by Mr.
7 Schapker,.that you attempted to categorize the types of 8
discrepancies that you observed in these welder 9
qualification records?
10 A
Yes, sir.
11 Q
All right.
Now, I would like you to turn back, if you 12 would, to Applicant's Exhibit 51.
O 13 First of all, Mr. Puckett, do you --
14 A
I want to make sure that I have got the right exhibit.
15 Q
It's the November 21, 1985, inspection report.
i 16 A
Okay.
What page are you on now?
17 0
Well, I am going to turn first to Page 6 of the report
)
18 and just at the top of the page, the first full sentence 19 that starts three lines down, do you see that, "The 1
20 Alleger also made reference," and so forth?
]
21 A
Yes, sir.
J 22 Q
All right.
Now, can you describe to me what the nature 23 of the problem with welder qualification records was j-24 that you observed with respect to SA-312 to SA-312, when 25 SA-240 to SA-312 was being performed in the field?
Sonntag Reporting Service, Ltd.
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5681 1
A Well, I don't remember if this was my exact wording on 2
this.
3 0
I see.
Well, without holding you to this --
4 A
I am t rying to read this and see exactly what is being 5
said here.
6 Q
Okay.
Please, take your time.
7 A
I don't recall saying this, as it's written here on 8
this, the --
9 Q
Well, let me see if I can be of assistance.
10 Would you turn back to Applicant's Exhibit 58, 11 which is Nonconformance Report 3145, that relates to the 12 Stainless Steel Welding Procedure?
O 13 A
That is a Nonconformance Report?
14 Q
Yes, sir.
15 A
Let me look through this stuff up here and find it.
16 I am not sure that I have it yet.
17 0
Well, let me show you my copy.
18 I am showing the witness Applicant's Exhibit 58 in 19 evidence and I am pointing to the sentence that reads, 20 "The procedure was qualified pipe to pipe SA-312 to 21 SA-312.
Bimetallic welds SA-240 to carbon steel are 22 being made in the field."
23 A
Yes, sir.
24 Q
Now --
25 A
But what is reflected --
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1 Q
In Mr. Schapker's --
2 A
-- in Mr. Schapker's up here is saying SA-240 to SA-312 3
is being made in the field and that is not a bimetallic 4
weld.
That is stainless to stainless.
5 That's why I say I don't recall saying this up 6
here.
This is more or less what I said down here.
j l
7 (Indica ting. )
i 8
Q Can we agree that in Applicant's Exhibit 58, the 9
Nonconformance Report 3145, that your reference to 10 SA-312 to SA-312 dealt not with welder qualifications as 11 such but rather with the fact that a stainless procedure 12 was being used, in your opinion, to weld carbon to O
13 stainless?
14 A
That was my concern.
15 Q
Okay.
Now, Page 2 of this NCR does, in fact, deal with 16 a problem with welder qualification tests, does it not?
17 A
Yes, it does.
18 O
All right.
And if we would turn to -- excuse me --
19 Applicant's Exhibit 57, which is Procedure 4.3.14, I 3
20 would ask if you would point to the portion of the 21 welders qualification test record that was of concern to 22 you when you wrote the NCR.
23 A
If everybody has this, it's on the back page.
24 Q
I am the only one who doesn't.
Let me get to that.
/^N 25 Are you also referring to the AWS Code, sir?
%,)
Sonntag Reporting Service, Ltd.
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[v) 1 A
I am just looking in the AWS Code for a ready reference.
2 0
No; I just want the record to reflect that you are and I 3
encourage you to do it, because I know from past 4
experience that working our way through these is not 5
very easy.
6 Mr. Puckett, why don't you take a look at Page 65?
7 A
I am on Page 64.
8 0
64, where the chart is?
9 A
Yes.
10 0
And you are looking at Applicant's Exhibit 12; is that 11 correct?
12 A
(No response.)
0 13 0
All right, all right, sir.
Could you describe for the 14 Board what the nature of the conce rn on the welder 15 qualification test record was, which is the last page of 16 Applicant's Exhibit 57?
17 A
I would assume that this being included in the r
procedure.
Ordinarily it is not.
19 I would assume that this is the welder that also 20 qualified the procedure, Mr. Ron Vilt.
21 My concern here was the joint thickness of the 22 pipe.
If you could follow along with me, it's down in 23 the area where it says, "Three inch Schedule 40, 3/8,"
24 pipe.
)
It's on the right side at the bottom of the first 25 i
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I margin.
2 MR. GUILD:
At the top, Mr. Puckett?
3 THE WITNESS:
You can see where it has his ID 4
symbol of 93.
It's just below that at the bottom there.
5 It says, "Three inch, Schedule 40, 3/8."
j 6
Has eve rybody found that thun far?
7 MR. MILLER:
Yes, sir.
8 A
(Continuing.)
My concern there was that, according to 9
this test record, this welder is qualified, on the next 10 line, to unlimited thickness.
11 However, in the Code, AWS D.l.1 on Page 64, if you 12 check for this type of weld, a groove weld, you will O
13 find that the welder's qualification is 0.063 to 0.674 14 inches in thickness.
15 BY MR. MILLER:
16 O
So, in fact, the welder qualification test record should 17 have indicated that the thickness range was limited to 18 the dimensions that you have just read into the record; i
19 correct?
20 A
The test record should have given these limitations for 21 a groove weld and put down fillet welds, unlimited i
22 thickness.
23 0
And how do you -- from what provision in the Code do you J
24 conclude that he would be qualified for unlimited 25 thickness on fillet welds?
)
i I
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A There is several sections in the D.1 Code that reflects 2
that if you qualify on a groove weld, you are also 3
qualified on all fillet welds of all sizes and 4
thicknesses.
5 0
All right, sir.
Now, do you know, Mr. Puckett, whether 6
or not there was any stainless steel material at 7
Braidwood that had a dimension that was in excess of 8
.674 inches?
9 A
I do not know.
10 0
If one assumes that there was not --
11 A
I am not able to assume those things.
12 Q
No, no, let me finish my question.
O 13 If one assumes there was no stainless steel 14 material that was welded by Comstock at Braidwood in 15 excess of the.674 dimension, would you agree with me 16 that the welder was, in fact, qualified to weld on the 17 material that he actually was welding on in the field?
18 A
In all positions except the 2G position.
19 Q
Right.
That is because that was only qualified in the 20 SG position?
21 A
Yes, sir.
22 0
Okay.
We have been through that.
23 And that while the welder qualification test record 24 was erroneous, that there was no quality or safety 25 significance to the error in the test -- in the velder Sonntag Reporting Service, Ltd.
ueneva, Illinois ou134 (312) 232-0262
5686 O
1 test record; correct?
2 A
If --
3 JUDGE GROSSMAN:
This is still on the 4
assumption that there --
5 MR. MILLER:
Yes, yes.
6 JUDGE GROSSMAN:
This is still on the prior 7
assumption that there is no --
8 MR. MILLER:
You have to accept my 9
assumption.
10 If my assumption --
11 A
(Continuing. )
I was going to say if I assumed there 12 was nothing on the site or if I knew that there was O
13 nothing on the site that was greater in thickness than 14 the 0.674, then I would think, yes, the welder would be 15 qualified.
16 However, I would still want to address this and get 17 it cleared up, as we had problems, again, at the Zimmer 18 project that were not near as severe as this, where the 19 welder's qualification was considered indeterminate; and 20 we had to call the welders back and completely requalify 21 them.
22 BY MR. MILLER:
23 0
And, in fact, you took the appropriate step to, at 24 least, initiate clearing it up by having NCR 3145 signed 25 by Mr. Miner, after you wrote in the description of the Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
}
3687 OV 1
nonconforming condition; right?
2 A
Yes, sir.
3 O
Now, going back for just a second, Mr. Puckett, to Mr.
4 Schapker's report, Exhibit 51 --
5 A
What page are you on again?
6 0
Page 6.
7 A
Page 6?
8 Q
Right.
9
-- can we agree that the reference there to welder 10 qualifications at the top of Page 6 is not an accurate 11 characterization of your concern with respect to 12 stainless steel welding?
O 13 A
Now, which sentence are you looking at?
14 0
Well, it's the one that begins, "The A11eger also made 15 reference to welder qualifications," and so on.
16 A
Again, as I said, I don't recall stating this to Mr.
17 Schapker in this form.
18 What he is talking about here is welding SA-312 to 19 SA-312 or SA-240 to SA-312; and this is stainless to 20 stainless, 21 My reference to him was concerned with stainless 22 being welded to carbon steel.
23 0
So, in fact, if a qualification was made SA-312 to 24 SA-312, that would qualify for SA-240 to SA-312, l's 25 wouldn't it?
U Sonntag Reporting Service, Ltd.
Geneva, 1111n015 OU1J4 (312) 232-0262
l 5688 i
i 1
A I think so, if the SA-312 is the pipe.
2 I don't have all of these figures in my head now.
3 I know that one of them is pipe and that the other is 4
plate.
5 If they had a pipe to pipe weld, that would also 6
qualify the welder to do a pipe to plate weld, yes.
7 Q
If you look at, again, the last page of Applicant's
]
8 Exhibit 57, the weld procedure, Mr. Vilt's, can we agree 9
that he performed his weld on his weld qualification 10 test on three inch Schedule 40 3/8 inch pipe and the 11 material specification is identified as SA-312; correct?
12 A
Yes, sir.
]
13 Q
Okay.
Does that indicate to you that SA-312 is, in j
14 fact, the pipe?
a 15 A
Yes, sir.
16 Q
Okay.
Now, let's turn, Mr. Puckett, to Page 9 of the I
17 inspection report; and there is a reference there 18 Allegation H.
19 Do you see that?
20 A
On Page 9, H?
I.
21 O
Yes, sir.
~
22 Is that an accurate characterization of the concern
]
23 that you expressed to Mr. Schapker?
24 A
Yes, sir.
4 25 0
All right.
And was your conclusion that the welder
}
i j
Sonntag Reporting Se rvice, Ltd.
Geneva, Illinois 60134 i
(312) 232-0262
.--4.-
- - - - - - -.,..-ere.-,
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m-.,.,-_..y_
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.,_..,.__.,__+,.,,,_._,.,,----,_.c.-,m,-.-,-v.--,._--
i 5689 1
qualification records have inconsistencies which make 2
the welder qualifications indeterminate based on 3
Applicant's Exhibit 68, your review of the welder 4
qualification records?
5 A
Yes, sir.
6 I might add that this is just a pa rti al review.
T 7
never got it completed.
8 0
Now, did you describe for Mr. Schapker what the nature 9
of the inco1sistencies were that you believed resulted 10 in the records being indeterminate?
11 A
I don't remember exactly what me and Mr. Schapker 12 discussed; but if this subject was brought up, I am sure O
13 that I may have made an outline to him of the type of 14 inconsistencies I was finding.
15 Q
All right, sir.
Now, you see, do you not, that there is 16 a reference in the portion of Allegation H that is 17 headed up, "NRC review to LKC NCR 3710"?
18 Do you see that?
19 A
Yes, sir.
20 0
Mr. Puckett, I am going to place before you Applicant's 21 Exhibit 13 in evidence.
22 The first NCR in the stack is 3710, and I just ask 23 you to look at the thi rd page of the NCR.
24 You will see there that there are three 25 discrepancies that are listed there.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
5690 (2) 1 MR. GUILD:
Does counsel mean Page 2 of 4 of 2
the document?
3 MR. MILLER:
Yes.
It is the third page of' 4
the NCR as prepared but it is identified as Page 2 of 4.
l 5
BY MR. MILLER:
6 0
First of all, did you observe the inconsistency that is 7
identified and numbered Paragraph 1 on NCR 3710 when you 8
did your review?
9 A
No, sir.
10 0
Did you observe the second -- well, what is identified 11 as numbered Paragraph 27 12 A
Yes, sir.
O 13 Q
All right.
And did you observe the inconsistency that 14 is identified in numbered Paragraph 3?
15 A
No, sir.
16 0
So if I understand, the only inconsistency, the only 17 discrepancy in the welder qualification records that is 18 listed on 3710, that you had identified was that the 19 Form 88, which is the welder qualification test record, 20 shows the wrong base metal specification for the 21 material used; correct?
22 A
On this particular one, yes, sir.
23 0
Yes.
Now, do you agree that the fact that the brand 24 name of the electrode used was not documented is, in 25 fact, an inconsistency in the weld qualification?
}
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
i 5691 r~n d
1 A
I will agree that it ve ry well could be.
2 However, you must understand when I was asked to do 3
this review, I was given this review, along with 4
checking out all the weld rod withdrawal forms and doing i
5 a complete review of all the procedures and changing 6
them and given a week to do this by myself with no help.
7 So the review that I was doing, I was picking up 8
major discrepancies that were very evident.
9 Q
I see.
Well, I don't mean to suggest that you --
10 A'
Yes, sir.
I 11 0
-- delibe rately overlooked any of the discrepancies.
12 I just want to know now whether or not you agree 0
13 that the fact that the brand name of the electrode 14 wasn't documented on the Form 88 was, indeed, a 15 discrepancy in the welde r qualification test record?
16 A
I would really have to look at it and look at the 17 procedure to see if it was a requirement that the brand 18 name of the electrode be listed.
I 19 O
And if it was such a requirement, then not listing it i
20 would be a discrepancy; right?
21 A
I would consider that as a discrepancy as well.
22 0
Then the third one, the third discrepancy that is listed 23 on NCR 3710, is that there is the wrong specification 24 for the electrodes.
25 That is, there was an inconsistency between the j
Sonntag Reporting Service, _ Ltd.
Geneva, 1111nois ou134 (312) 232-0262
5692 iO l
1 type of electrode that was used and the specification 2
for the electrode that was listed on the Form 88.
j 3
Do you agree that that, too, is an inconsistency?
4 A
It is an inconsistency.
i 5
0 Turning to the inconsistency that is shown in numbered 6
Paragraph 2, can you identify for us where that 7
inconsistency would appear on the welder test 8
qualification record?
9 If it's helpful to use the --
i 10 A
Ask the question again.
I was re-reading No. 2 again 11 just to see exactly what it said.
12 0
How would we know that there was an inconsistency, that
'O 13 is that one inch plate was used for the weld test and 14 the material on the Form 86 -- 88, I beg your pardon --
15 was used and, in fact, the material -- I am sorry.
The i
l 16 material was listed as A-106 pipe.
i 17 Perhaps it would be helpful, Mr. Puckett, if you 18 went to the next NCR in the stack, which is NCR 4649.
19 Do you have that one, sir?
20 A
Yes.
21 0
All right.
Can we agree that this is an additional NCR i
22 that was written to document the inconsistency of 23 identifying the wrong base metal specification for the l
24 material used?
25 A
Yes, sir.
I I
I Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 j
(312) 232-0262
,__..I I...
5693 O
1 Q
Okay.
And if we turn to the -- well, there are some 2
weld qualification test records attached to this; and 3
can you point out for the record where, for example, in 4
Mr. James C.
Bucklaew's qualification test record the 5
discrepancy appea rs?
6 A
The discrepancy, as I see it here, would be in the fact 7
that the A.
S.
T.
M. A-106 was changed to A-36, A.
S. T.
8 M. A-106 being pipe, the A-36 being plate.
9 Q
All right.
Well, does it indicate or can you tell from 10 any other entries --
11 A
Right below that, it says, " Schedule 80," which is the 12 method used for determining the thickness of piping.
O 13 It also says, "six inch diameter."
14 Q
I an sorry.
I see that Mr. Bucklaew has two weld 15 qualification test records in this.
16 Are you looking at the one that is dated in the 17 lower right-hand corner August 8, 19797 18 A
Both of the ones that I have are dated 8-8-79 and they 19 both have the same information on them.
20 0
Correct.
The sheet preceding that is also for Mr.
21 Bucklaew and it's dated April 16, 1980; but let's deal 22 with the August 8, 1979.
23 That is probably just a copying error that we have 24 two duplicates there.
['
25 MR. GUILD:
Actually not.
It appears to be V}
Sonntag Reporting Service, _ Ltd.
Geneva, Illinois bu134 (312) 232-0262
5694 O
1 that --
2 THE WITNESS:
It's for two different 3
' positions, I think.
4 BY MR. MILLER:
5 Q
So you can tell from the diameter and wall thickness 6
entry that, in fact, this was done on pipe but the 7
material spec is shown as A-36; correct?
i 8
A Well, my conce rn was that prior to the line-through of 9
the A.
S.
T.
M. A-106 and the addition of A-36 by a 10 cle rk-typist at the Braidwood project, this paper at 11 that time looked satisfactory with just a quick review.
)
12 O
So your conce rn was that somebody had, apparently, made i
13 a change to an otherwise properly filled out test record
-f
[
14 and now created a discrepancy; is that correct?
i 15 A
Yes.
16 I would like to reiterate that we had conditions f
17 that I considered less than this at the Zimmer project 18 and the welder's qualification was considered t
19 indeterminate and we had to call him back to requalify.
20 0
Was that your recommendation that you -- well, do you 21 remember that Mr. Bucklaew's records were among those 22 that you reviewed?
23 A
I don't remembe r.
I would have to go through this to 24 coe.
Evidently, it was.
25 Yes, on Exhibit 68.
j i
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Geneva, Illinois 60134 l
(312) 232-0262
5695 O
1 Q
Right on the first page; right, Mr. Puckett?
2 A
Yes, sir.
3 O
All right, sir.
4 A
This is kind of confusing, because Mr. Bucklaew's ID 5
n umbe r is also changing on the two forms; but, yes, I do 6
have Mr. Bucklacw's here.
7 JUDGE GROSSMAN:
It is apparent that he was 8
reviewing the other qualification test record, the one 9
we were ignoring, not the one we had reference to, the 10 one he had reference to.
i 11 MR. MILLER:
That's right.
You can tell by 12 the welder ID number as indicated.
O 13 JUDGE GROSSMAN:
Right.
14 BY MR. MILLER:
15 0
Well, let's turn back to make sure we are all dealing 16 with the same document.
17 If we look back at the test record for Mr. Bucklaew 18 where his ID numbe r was 555 --
19 JUDGE GROSSMAN:
I am sorry.
That is 535.
20 MR. MILLER:
535, thank you.
21 BY MR. MILLER:
22 0
-- there is the same discrepancy indicated there; 23 correct?
24 A
The same type of discrepancy.
25 If this was his initial qualification, he has a Sonntag Reporting Service, L t'd.
ueneva, 1111n ois 0u134 (312) 232-0262
_)
5696 l
7m
)
<j 1
further problem.
2 O
Well, it's dated subsequent to the later -- the next 3
sheet for Mr. Bucklaew, isn't it?
4 A
Yes, sir.
It's 4-16-80.
5 0
All right.
But just focusing on the discrepancy in the 6
welde r qualification records, on this one, what was the 7
nature of the discrepancy in the material specification?
8 A
Which one are you referring to?
9 0
The one where he has the 535 ID number.
10 A
The only problem that I would find with this, in just 11 glancing at it at this point, is the fact that on the 12 date at the bottom we have got a write-over and at the
, ~,
(
13 top there was a material added.
A-36 was added and 14 initialed by a clerk and not dated.
15 It appearc that prior to this it would have been 16 wrong, too, as it was reflecting -- well, I can't see.
17 It 's ma rked through; but it cculd be 106 again up there.
18 I am not sure.
19 O
All right.
20 A
And the thickness range as being " limited," I would not 21 accept that.
22 I would want the thickness range that the test 23 would qualify and a note that it would qualify on all 24 fillet welds as well.
25 0
Well, let me just ask you th'3, Mr. Puckett:
g Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
5697 1
l 1
If this was a requalification of fir. Bucklaew after j
2 his initial qualification in August of 1979, wouldn't 3
the requalification test on 3/8 inch plate give him l
4 unlimites thickness capability?
5 A
Now, 'if you are asking if thic 4-16-80 qualification J
6 would give him the same thickness range ac the one on
{.
7 the next page, 8-18-79, it rays here " limited."
I could j
8 buy the limited.
{
9 I could not buy " unlimited, because the l
10 qualification on the pipe, if, in fact, it was pipe that.
1 11 he run his qualification test on, has got a lower limit 12 to it.
13 So he would be limited from a fraction to a 4
14
- fraction, f
15 0
f1 r. Puckett, if you lock at Faragraph 5.30 of the AWS 16 Code on Page 67 --
17 A
What page is this, again?
j j
18 0
Page 67, sir.
19 A
Yes, sir.
20 Q
Under Paragraph 5.30, it states, does it not, that where the welder is not engaged in the given process of 21 i
22 welding for which he is qualified for a period exceeding i
l 23 six months, a requalification test need only be made in j
24 the 3/8 inch thickness; correct?
)
25 A
Yes, sir, i
Sonntag Reporting Service, Ltd.
ueneva, illinoic 60134 (312) 232-0262
5690 1
%J
)
O And if the wolder had been qualified for unlimited 7
thicknecc cn his original qualification test, a 3/8 inch 3
requalification test under the provisions of that 4
pa ragraph would continue his qualification for unlimited 5
thickness; correct?
6 A
Yea, 32 r, i f, in fact, on hi7 initial qualification test 7
he had been qualified unlimited thickness; but on his 8
initial qualification test, if the second page is that, 9
he was not qualified for unlimited thickness; but his 10 qualification as shown on Page 64 would have been from 1]
.387 to unlimited.
12 O
And that is because a six-inch Schedule 80 qualification
,c,,
\\
13 test has thone thickness liaitations?
14 A
Yes, sir.
15 0
All right, sir.
16 A
And I might add that most of the welders at Braidwood 17 were welding the 446 steel and the sheet steel, which 18 was helcw thic fraction of.387, 19 Q
That would only be for a limitation on pipe welding, 20 correct, the welding of pipe?
l 21 A
It docen't stipulate here on pipe.
It just says for a 22 groove wcld.
23 Q
Now, I think you stated that your concern here was that 24 much more insignificant discrepancies in the velder 25 qual i f ica ti on records at Zimmer had led to major Sonntag Reporting Se rvice, Ltd.
~ ~ - ~ "
Geneva, Illinoin 60134 (312) 232-0262 t
l 4
4 5699 O
1 problems; is that correct?
2 A
My term for the problems that I found and reported on 3
Exhibit 68, I said, "Without further document research, 4
I would consider these welders' qualifications as being 5
indete rm ina t e. "
6 There is a possibility that these welders could i
7 very well be qualified, that it was just clerical errors 8
on the form, whatever the case might be; but, however, 9
it would take more research for me to be satisfied if 10 they were or were not qualified to weld in the field.
11 Q
So, in fact, without doing that further research, one 12 couldn't really determine whether or not the welders i
p>,,
s j
13 were qualified properly or not; is that correct?
14 A
I could only determine that their welder qualification 15 test records were wrong.
16 0
What other sources would you go to, Mr. Puckett, to make i
17 a detert,iination one way or the other?
4 18 A
More than likely, I would go to any log that might have 19 been maintained on the qualification and the NDE test 20 records.
21 Q
Those NDE test records are reports that are maintained i
22 by Pittsburgh Testing Laboratories; is that correct?
23 A
Yes, si r.
24 Q
You didn't have an opportunity to go and review those, 25 did you?
Sonntag Reporting Service,.
Ltd.
ueneva, 1111nois ou134 (312) 232-0262
5700 (5) 1 A
No, sir.
I yould have.
2 0
Now, you just looked at two of the NCR's in this stack, 3
Mr. Puckett; but is the initiation of an NCR a way to 4
properly track these discrepancies and resolve their 5
significance one way or the other?
6 A
It is one way that it could be done, yes.
7 MR. MILLER:
Mr. Chairman, off the record.
8 (There followed a discussion outside the 9
record.)
10 JUDGE GROSSMAN:
If you are through with this 11 particula r topic, I think we ought to break now so Mr.
12 Puckett can get home.
13 MR. MILLER:
As I understand, Mr. Puckett 14 will be back with us Tuesday morning; is that correct?
15 THE WITNESS:
Is all of this stuff going to 16 be here?
17 MR. MILLER:
I will make sure that it is.
18 Actually, I'would have no objection to you taking 8
19 the documents with you for any reason you wish to.
i 20 THE WITNESS:
I would rather not.
(Laughter.)
21 J
l 22 MR. MILLER:
I can't think of a better way to 23 ruin a weckend.
I speak f rom personal experience.
f 24 THE WITNESS:
I am seeing enough of these
[t 25 documents right now.
U Sonntag Reporting Service, Ltd.
i Geneva, Illinois 60134 j
(312) 232-0262
5701 O
1 JUDGE GROSSMAN:
We will reccas now until 2
9:00 o' clock tomorrow morning.
3 MR. MILLER:
Thank you.
4 JUDGE GROSSMAN:
And the Reporter knows we 5
have a full day tomorrow and probably half a day on 6
Friday.
7 (WHEREUPON, at the hour of 4:50, p.
m.,
8 the hearing of the above-entitled matter 9
was continued to the 26th day of June, 10 1986, at the hour of 9:00 A.
M.)
11 12 13 14 15 16 17 18 19 20 21 22 23 24 Sonntag Reporting Service, Ltd.
Geneva, 111inoin 60134 (312) 232-0262
NO PAGE NUMBER CERTIFICATE OF OFFICIAL REPORTER O
This is to certify that the attached proceedings before the UNITED STATES NUCLEAR REGULATORY COMMISSION in the i
matter of:
NAME OF PROCEEDING:
COMMONWEALTH EDISON COMPANY (Braidwood Station, Units 1 & 2) l i,
I 1
DOCKET NO.:
PLACE:
JOLIET, ILLINOIS DATE:
WEDNESDAY, JUNE 25, 1986 were held as herein appears, and that this is the original i
transcript thereof for the file of the United States Nuclear Regulatory Commission.
(sigt>
NantisiSidrps (TYPED)
Nancy J. Hhp Official Reporter Reporter's Affiliation L,