ML20210V121
| ML20210V121 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 10/06/1986 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| CON-#486-1128 OL, NUDOCS 8610100517 | |
| Download: ML20210V121 (124) | |
Text
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ORIGINAL O
Wim STAHS NUCLEAR REGULATORY COMMISSION IN THE MATTER OF: DOCKET NO: 50-456 OL 50-457 OL COMMONWEALTH EDISON COMPANY (Braidwood Station, Units 1 and 2)
O LOCATION: CHICAGO, ILLINOIS PAGES: 13553 - 13677 f
DATE: MONDAY, OCTOBER 6, 1986 i
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l ACE-FEDERAL REPORTERS, INC.
OfficialReporters 444 North CapitolStreet Washington, D.C. 20001 86IO1oos,- _ (202)347-3700
- ADdde $l)00^
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13553
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1 UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4
5 _ _________________x 6 In the Matter of: :
- Docket No. 50-456 7 COMMONWEALTH EDISON COMPANY : 50-457 8 (Braidwood Station, Units 1 :
and 2) :
9 __________________Z -
10 11 ,
Page: 13,553 - 13677-
/() 12 United States District Court House Courtroom 1919 13 Chica go, Illinois 60604 34 Monday, October 6,1986 15 The hearing in the above-entitled matter reconvened 16 at 2:00 P. M.
17 18 BEFORE:
19 JUDGE HERBERT GROSSMAN, Chairman Atomic Safety and Licensing Board
! 20 U. S. Nuclear Regulatory Commission Wa shington, D. C.
21 JUDG E RICH ARD F. COLE, Member, 22 Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission 23 Wa shin gton, D. C.
p3 24 J UD3 E A. DIXON CALLIH AN, Mem be r,
.\m/ Atomic Safety and Licensing Board 25 U. S. Nuclear Regulatory Commission Washington, D. C.
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i APPEARANCES:
2 On behalf of the Applicant:
3 MICH AEL I. MILLER, ESQ.
4 PHILIP P. STEPTOE, III, E SQ .
Isham, Lincoln &' Beale 5 Three First National Plaza Chicago, Illinois 60602 6
7 On behalf of the Nuclear Regulatory Commission Staf f:
8 GRDGORY ALAN BERRY, ESQ .
9 ELAINE I. CHAN, ESQ.
U. S. Nuclear Regulatory Commission 10 7335 Old Georgetown Road Bethesda, Maryland 20014 11 On behalf of the Intervenor:
ROB ERT GUILD, E90.
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1 CROSS EXAMINATION (Continued) 2 BY MR. GUILD: 13559 3
EXHIBIT INDEX MARKED R ECEIV ED 4
Intervenors' Exhibit No. 153 13568 13585 5
Intervenors' Exhibit No. 154 13603 6
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13556 1 JUDGE GROSSMAN: The hearing is reconvened.
2 This is the 69th day of hearing.
3 We concluded on Friday with Mr. Guild cross 4 examining.
5 I understand now that there are some corrections to 6 some of the testimony, so we'll have that, Mr. Steptoe, 7 first.
8 MR. STEPTOE: Dr. Kaushal, would you identify 9 your first correction?
10 A (WITNESS KAUSH AL) Yes, Mr. Steptoe.
/"
/ (_)/ 11 Mr. Chairman, over the weekend, I had a chance to 12 look at the documentation pertaining to the time when I 13- was appointed or assigned the responsibilities as 14 Director of BCAP, and that date happens to be May 7, 15 1984.
16 In my earlier testimony, I could not recall the 17 exact time, my memory was hazy, and I indicated it was 18 some time around March.
19 It turns out that I was on site in March, but not 20 in that capacity.
21 JUDGE GROSSMAN: Were you working on the CSR i
22 progr ar, or whatever the forerunner name of the program 23 was when you came on site?
{}
24 A (WIINESS KAUSH AL) Your Honor, I had some involvement So.nntag Reporting Service, Ltd.
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13557 1 as in an assisting fashion on an effort that was going 2 on to put together a program at that time.
3 JUDGE GROSSMAN: From the beginning when you 4 first came on site, then, at some time during March? ,
5- A (NITNESS KAUSBAL) Mr. Chairman, the responsibilities 6 kind of gradually went in.
7 I was at that time in the engineering department, 8 proj ect engineering department, and was asked to go to 9 site to participate in some of the meetings, and then 10 gradually I got involved in it. ,
(()
L 11 So there's no well-defined period of time that I 12 can identify at which my responsibilities were described 13 when this program started.
14 JUDG E G ROSSMAN : Okay.
15 So basically you were somewhat involved, but you 16 really didn' t have responsibility up until May?
17 You were somewhat involved beginning some time in 18 March --
19 A (WITNESS KAUSHAL) Yes, sir.
20 JUDGE GROSSMAN: -- until you were formally 21 given the position in May ?
22 A (NITt1ESS KAUSH AL) Yes, si r.
23 JUDGE GROSSMAN: Okay, fine.
24 What's the other correction, then ?
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13558 pd 1 MR. STEPTOE: Judge Grossman, the second 2 correction deals with Intervenors' Exhibit No. 150.
3 I don't think it's something that Dr. Kaushal said, 4 but it's an error in the exhibit.
5 Tha t is, the cover page is a September 12, 1985, 6 memo, BCAP Memo 3368, the subj ect is invalidation of 7 observation, and the correction pertains to the last 8 memo in this document, Page B0011613, a September 5, 9 1985, memo, BCAP Memo 3240.
10 Dr. Kaushal, could you explain what the correction
/() 11 is? .
12 A (WITNESS KAUSH AL) Yes, I will, Mr. Steptoe.
13 Mr. Ch ai rman, the memorandum is from Messrs. Orlov, 14 Shay and Patel to myself.
15 In the last paragraph on the firs ge of tha t 16 memo, the second line, the sentence says, "For cable pan-17 hangers, only 2 of 138 CSR sample hangers had 18 unavailable inspection f orms. " That didn't sound to me 19 right.
20 Over the weekend, I asked Mr. Wozniak to look 21 through the records; and it turns out that there were 13 22 additional CSR sample hangers that did not have 23 unavailable inspection forms, but on which the original 24 preparer inspector had, in fact, acknowledged and Sonntaq Reoor tino Se rvice, Ltd.
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1 agreed.
2 So the 2 -- No. 2 that is represented here is 3 apparently the 2 observations on which his 4 acknowledgement signatures did not exist.
5 MR. STEPTOE: So, Dr. Kaushal, just to nail it 6 down,15 out of 138 CSR sample hangers had BCAP 7 observations which were invalidated for this reason?
8 A (WITNESS KAUSHAL) For this reason, for unavailable 9 inspection forms.
10 Now, there were other configuration inspection --
t /() 11 there were other observations relating to lack of 12 configuration inspection forms which were also valid, so 13 this is not the totality of the observations relating to 14 lack of configuration inspection documentation.
15 JUDGE GROSSMAN: Fine.
16 Mr. Guild, you are still cross examining, so you 17 can explore this area further, if you wish.
-18 MR. GUILD: Thank you, Mr. Chairman.
19 CROSS EXAMINATION 20 (Continued) 21 BY MR. GUILD:
22 Q Dr. Kaushal, let's start with the last clarification 23 first.
24 Let me just see if I can restate what I understood
~-~~
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a 1 from your explanation.
2 There are a total of 15 cable pan hanger sample 3 items for which there were no inspection forms 4 identified?
5 A (WITNESS KAUSHAL) In some form or another, there would 6 be an obsertation relating to lack of configuration 7 documentation.
8 0 And of those,13 of those observations were deemed 9 valid?
10 A (WITNESS KAUSHAL) No, sir, that's not what I said.
((
11 Out of those,13 were invalid, but the original 12 preparer acknowledged the invalidation and did not 13 obj e ct.
14 0 All right, sir.
15 So you had two obj ecti 7ns, and that's the two that 16 you -- or Messrr. Orlov, Shty and Patel listed in this 17 memo to you?
18 A (WITNESS KAUSHAL) Tha t's correct.
19 JUDGE GROSSMAN: Excuse me.
20 Does that mean that, in the prior sentence, 41 of 21 130 were obj ected to, unavailable configuration 22 inspection forms?
23 A (WITNESS KAUSH AL) That is correct, your Honor.
}
24 Mr. Wozniak, also at my request, checked those Sonntaq Reporting Service, Ltd.
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1 ones, and those are the only 41 that we could 2 identify -- namely, there are no others on which he 3 objected -- and there are none on which he did not 4 obj ect on that reason, also, in the --
5 JUDGE GROSSMAN: Oh, Wall, that's what I was 6 asking.
7 So the 41 is the total?
8 A (WITNESS KAUSHAL) Yes, sir, to the best of our 9 knowledge, that's correct.
10 JUDGE GROSSMAN: Okay.
f 11 -
BY MR. GUILD:
12 O Let me be sure.
13 All of the 41 or conduit hanger invalidations were 14 objected to?
15 A (WITNESS KAUSHAL) I believe that's correct, if that's 16 the number.
17 The number should be back in here, and that's the 18 n um be r.
19 Q But to the best of your knowledge, whatever that total 20 is, all of them were objected to, conduit hanger 21 invalida tions ?
22 A (WITNSSS KAUSH AL) That's correct, yes, sir.
23 Q Dr. Kau sh al, did the same CSR inspector r eview all of 24 the 15 cable pan hanger items f or documentation?
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1 A (WITNESS KAUSHAL) Yes, si r.
2 Q So that inspector agreed with the invalidation of 13, 3 but disagreed with the invalidation of 2?
4 A (WITNESS KAUSH AL) Yes, sir.
5 Actually, there is a little more to that story. We 6 thought that he disagreed with those two. By the time 7 those two were to be processed, he had lef t the site; 8 but we wanted to make sure that we don't gloss over 9 that, because we had knowledge that he had objected, so 10 we put that on record, that he had obj ected.
/( ) 11 Q All right, si r.
12 What distinguishes the 2 from the 13 others? What 13 was the basis for his objection to the 2 and not 14 obj ecting to the other 13?
15 A (WITNESS KAUSH AL) I do kn ow know tha t, Mr. G uild.
16 Q Can anybody else on the panel answer that question?
17 A (WITNESS WOZNI AK) No, sir.
18 0 Was the basis for his objection to two documented either 19 on the observation forms or elsewhere?
20 A (WITNESS KAUSHAL) I could not see any specific 21 objection stated on the form.
22 Q Mr. Woz ni ak ? !
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- 23 A (WITNESS WOZNI AK) Excuse me?
24 Q Are you aware of any documentation of the basis for the l l
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1 objection to the invalidation of the two?
2 A (WITNESS WOZ NIAK) There is nothing indicated on the 3 observations, you know, relevant to his, you know, 4 disagreeing with the determination of the invalidity; is 5 that the question?
6 Q Yes.
7 A (WITNESS WOZ NIAK) There was nothing so stated, no, sir.
8 0 What, if anything, distinguishes the circumstances of 9 the invalidation of the 13 from the 2, if anything?
10 A (WITNESS WOZNIAK) I would not have an opinion.
[w ) 11 Q Dr. Kaushal?
12 A (WITNESS KAUSHAL) _ We don' t know the answer to that.
13 The only thing we could do would be speculation, 14 and that wouldn' t be appropriate.
15 0 All right, sir.
16 Now, what exactly was your position, Dr. Kaushal, i
! 17 prior to May 7, 1984, but at a point when you had some l '18 involvement in the design of the BCAP program?
19 A (WITNESS KAUSHAL) Mr. Guild, that will be pretty hard 20 to define.
J 21 We have to put it in context. I had come back f rom 22 my Clinch River assignment. I was assigned to project 23 engineering. In the proj ect engineering, as I indicated 24 before, I had a short-term involvement with the Byron Sonntao Reportina Service, Ltd.
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1 inspector reinspection program.
2 Once that effort had been wrapped up in the form of 3 . a report, I was asked to go down to Braidwood to 4 participate in discussions. .
I 5 There was no -- at least I wasn't aware of any set 6 specific assignment type or otherwise in that respect.
7 Q Who did you work for at the time, Doctor?
8 A (WITNESS KAUSHAL) At that time I was reporting to, I 9 believe, Mr. Deress --
10 Q, can you spell his name, sir?
() 11 A (WITNESS KAUSHAL) D-E-R-E-S-S. -
12 -- who reports to Mr. Shelton; and the reason I ,
13 mention that, because many time I, in this respect, 14 dealt with Mr. Shelton directly.
15 0 What position did Mr. Deress hold?
16 A (WITNESS KAUSB AL) Mr. Deress is the Proj ect 17 Engineering Manager for Byron and Braidwood.
18 0 And that was his position at the time that you were 19 assigned to work down there?
20 A (WITNESS KAUSHAL) That was his position at that time, 21 also.
+
22 0 And what was Mr. Shelton's position?
23 A (WITNESS KAUSHAL) Shelton is -- Mr. Shelton is the
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24 Proj ects, with an s, Engineering Manager, and I believe-l Sonntag Repor ting Service, Ltd.
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1 that's his f ull title.
2 I am not absolutely certain.
3 Q Did anyone precede you as the director or senior person 4 in charge of the -- well, the precursor to the BCAP 5 program, Dr. Kaush al ?
6 A (WITNESS KAUSH AL) For a short time before I took on 7 the directorship, I believe Mr. Shamblin had some 8 responsibility in that respect.
9 Q Well, what position did Mr. Shamblin hold with regard to 10 the precursor to BCAP?
/ ) 11 A (WITNESS KAUSH AL) I believe at that time he was o
\
12 Proj ect Field Engineering Manager.
13 This was a task that he was working on. What his 14 specific task -- responsibility and title with respect 15 to this was, I am not knowledgeable of.
16 0 Okay.
17 This is Mr. Shamblin, who at some point had been 1.8 the Project Construction Superintendent?
19 A (WITNESS KAUSH AL) He is currently Proj ect Construction 20 Superintendent.
21 Q He is currently Prcject Construction Superintendent?
22 A (MITNESS KAUSHAL) Tha t's correct.
23 Q All right.
24 And so this was before he held that position?
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1 A (WITNESS KAUSHAL) In fact, that's just prior to, 2 because my assumption of directorship coincided with his 3 becoming the Construction Superintendent.
4 Q I see.
5 MR. GUILD: Mr. Ch ai rman, before we went in 6 session -- Mr. Ch airman, before we went in session, I 7 distributed to the Board and parties a typed copy of 8 Intervenors' Exhibit 145. That's the tabular 9 representation of the CSR results by item and by weld.
10 I also committed to reproducing BCAP Observation
'( ) 11 Record CSR CPH-001, which was one of the out of -- the 12 first out of scope cable pan hanger observation from the 13 NCR 6145. It was admitted and numbered as Intervenors' 14 Exhibit 151.
15 I'm going to distribute a copy of that at this 16 time.
17 JUDG E GROSSMAN: Okay. You've given the 18 Reporter Intervenors' Exhibit 14 5 ?
19 MR. GUILD: If I haven't, I'll make sure they 20 get one, Judge.
21 BY MR. GUILD:
22 Q Mr. Wozniak, before we recessed on Friday, you had 23 described part of the results of the conduit hanger 24 reverification program.
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1 Do you recall that testimony, sir?
2 A (WITNESS WOZ NIAK) Yes, sir.
3 Q And over the weekend -- this morning I was given a copy 4 of the reverification program report, and that was the 5 document that you had reference to on Friday when you 6 were searching for some answers to questions of mine 7 about the results of that program.
8 Do you recall that testimony?
9 A (WITNESS WOZNI AK) Yes, sir.
10 Q Now, I show you a document that, in part, the
) , 11 reverification program, as I understand Dr. Kaushal's
(
12 testimony Friday, arose f rom concerns by the NRC -- or 13 NRC BCAP Inspector, Mr. Gardner; partly also arose by an 14 observation by the Independent Expert Overview Group, 15 ERC, did they not?
16 , (Indica ting. )
17 A (WITNESS WOZNIAK) That is correct.
18 Q And I want to show you a copy of ERC Observation 11 and 19 ask if you can identify that as the ERC observation that 20 was the basis for the conduit hanger reverification 21 program.
22 (Indica ting. ) .
23 A (NITNESS WOZNIAK) Mr. Guild, this observation here is, 24 in fact, part of the NRC report dated -- I believe it's Sonntaa Reporting Se rvi ce, Ltd.
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1 8603, and this is, in fact, one of the factors 2 contributing to the midpoint look that Dr. Kaushal had 3 directed into the conduit hanger program.
4 MR. GUILD: All right, sir.
5 Mr. Chairman,, I'd ask this document be marked as 6 Intervenors' Exhibit -- I believe it's 153 for 7 identification.
8 JUDGE GROSSMAN: Correct.
9 (The document was thereupon marked 10 Intervenors' Exhibit No.153 for
() 11 ,
identification as of October 6, 1986.)
12 BY MR. GUILD:
13 Q Now, in your reverification plan for conduit hangers, it 14 was specified that the conduit hanger reverification 15 would be limited in scope to the attributes that were 16 the subject of the ERC Observation No.11; is that 17 correct?
'18 A (WITNESS WOZ NIAK) That is correct.
19 Q In particula r, I'm reading from Item 1 in your 20 reverification plan. " Inspection attributes outside the
! 21 scope of the ERC concerns are not addressed in this 22 pl an "
23 And that is a correct understanding of the way 24 that reverification program was implemented as well?
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v 1 It was limited to the ERC-identified attributes; 2 correct?
3 A (WITNESS WOZ NIAK) That is -- to the best of my 4 knowledge, yes.
5 I don' t have a copy of the plan in f ront of me per 6 se.
7 0 All right, sir, let me show you the document.
8 (Indica ting . )
9 Directing your attention to a document entitled, 10 "Reverifica tion Plan, Electrical Conduit Hangers," the (s(_
A) 11 last sentence the first numbered paragraph.
12 (In dica ting.)
13 A (WITNESS WOZ NIAK) That is correct.
14 Q Let's look at some of those attributes, Mr. Wozniak.
15 Those attributes are reflected, are they not, in 16 what's been marked as Intervenors' Exhibit 153; that is, 17 the ERC observation report?
18 The first attribute is identified as Attributes 3d.
19 That's on the f ace of the observation form itself.
20 Do you have that before you?
21 A (WITNESS WOZ NIAK) No, sir, I don't.
22 Q I should have lef t you a copy.
23 You have Intervenors' Exhibit 153 before you?
24 A Oh,, the observa tions ?
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1 Q Yes, sir.
2 A (WITNESS WOZ NIAK) I'm sorry.
3 Q Look at the face of the observation report, the first 4 cover page, not the transmittal letter.
5 You see attribute 3d identified there?
6 A (WITNESS WOZ NIAK) Yes, sir.
7 Q All right, sir.
8 Conduit Hanger 03, Sample Item 03.
9 In this case, the inspector marked the attribute 10 acceptable but the ERC determined that it, the I) 11 attribute, was not applicable to that CSR inspection; 12 correct?
13 A (WITNESS WOZ NIAK) That is what the observation states, 14 yes.
15 Q Did you agree that that was the condition?
16 A (WITNESS WOZNIAK) The results would be documented on ,
17 the reverification plan.
18 I don't have a copy of the results as we reverified 19 it; but that is, in fact, the way the observation 20 states.
21 Q All right, sir.
22 Well, do you generally -- do you know whether or 23 not you confirmed the accuracy of the ERC findings with 24 respect to the specific items that the ERC reported in Sonntaq Reporting Se rvi ce, Ltd, Geneva, Illinois 60134 (nstes sammwa
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U 1 its Observation ll?
2 A (WITNESS WOZ NIAK) Yes, sir.
, 3 Q You did.
4 Generally you confirmed their findings?
5 A (WITNESS WOZNIAK) Well, our Lead Inspector, Mr. Sh ay, i
6 at the time of the occurrence, was involved in doing 7 that validation, if you will, of the ERC concerns; but 8 those results are, again, documented in the response to 9 the ERC observations.
1 i- 10 Q Yes.
{' ) 11 Well, I'd be happy to show you the whole document, 12 if it would help to -- help you answer the question and 13 refresh your recollection.
14 But are you aware, as you sit here today, whether i
! 15 generally you confirmed the accuracy of the ERC findings l 16 on the specific items and attributes that are documented 17 in Observation ll?
18 A (WITNESS WOZNIAK) Yes, we did.
19 0 Okay.
20 The second item is Attributes 2f, and, again -- and 21 there, conversely, the BCAP CSR inspector indicated the
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22 attribute was not applicable when the item, in fact, 23 should have been inspected?
i 24 A (WITNESS WOZ NIAK) That's what the observation states, i
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1 yes.
2 Q All right, sir.
3 For the third attribute, the second sample item, 4 Conduit Hanger 12, again, the CSR inspector indicated 5 the attribute was not applicable; ERC determined that it 6 should have been inspected?
7 A (WITNESS WOZ NIAK) That's what it states, yes.
8 0 All right.
9 The third attribute -- or the -- strike that.
10 Item 2b, Attributes 3 f, the CSR inspector indicated
) 11 that the item or the attribute was acceptable when it 12 should have been not applicable?
13 A (WITNESS WOZ NIAK) That is what the observation states, 14 yes.
15 0 All right.
16 2c, a discrepant condition had not be properly 17 identified by the CSR inspector?
18 A (WITNESS WOZ NIAK) That is correct.
19 Mr. Guild, you will also notice Items 2b and 2c 20 I've addressed in my prefiled testimony, too, I believe.
21 Q Okay.
22 Those are the ones you mention as examples of the r 23 findings --
24 A (WITNESS WOZ NIAK) Yes, sir.
~ ~ ~
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1 0 -- in your testimony?
2 All right, sir.
3 The third item, Conduit Hanger 20, 3a, Attributes 4 2f, and there the CSR inspector improperly indicated the 5 attribute was not applicable; ERC determined that it 6 should have been inspected?
7 A (WITNESS WOZNIAK) Yes.
8 0 3 b, the CSR ' inspector improperly indicated that the item 9 was acceptable when it was not applicable?
10 A (WITNESS WOZNIAK) Correct.
11 Q And finally, for 3c, again, the CSR inspector improperly 12 f ailed to document a discrepant condition?
13 A (WITNESS WOZNIAK) Yes.
14 0 All right.
15 A (WITNESS WOZ NIAK) Mr. Guild, you will note -- or you 16 will recall that item or Attribute 3c of the observation 17 report we had discussed before as being part of my 18 testimony.
19 That was the condition involving the verification 20 of the identity of the conduits not as much as there 21 were conduits installed.
22 (Indica ting . )
23 Q All righ t, sir. Th at's h elpf ul .
[}
24 Now, the reverifica tion plan called f or, first, th e Sonntaq Reporting Service, Ltd.
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U 1 rereview of all of the packages for CSR conduit hangers 2 accepted prior to January 24, 1985; correct?
3 A (WITNESS WOZNIAK) Correct.
4 0 All right.
5 Now, the rereview of the packages is not the same 6 as a reinspection in the field?
7 A (WITNESS WOZ NIAK) That is not, that is correct.
8 Q All right, sir.
9 "The rcreview of the packages shall consist of a 10 comparison of hardware design configuration versus the
() 11 configurati.on indicated by acceptance / rejection or NA of 12 the reinspection checklist attributes."
13 I just read f rom the plan.
14 That's what the reverification consisted of --
15 A (WITNESS WOZNIAK) Correct.
16 0 --
correct?
17 All right. Again, inspection attributes that are 18 outside the scope of the ERC concerns are not addressed 19 in the plan.
20 So you didn' t look at any other attributes beyond 21 what ERC identified in Observation ll?
22 A (WITNESS WOZ NIAK) That is correct.
23 Q All right, okay.
(v-)
24 Now, the first point at which, under the plan, any Sonntao Repor ting Se rvice, Ltd.
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G) 1 actual field reinspection takes place is only in the 2 instances where, upon the rereview of the de cumentation 3 packages -- again I'm quoting from the plan --
4 " Attributes determined to be erroneously recorded as NA 5 shall be reverified by field inspection of the 6 hardware"?
7 A (WITNESS WOZNIAK) Correct.
8 Q And those are the cases where you actually went out to 9 the field?
10 A (WITNESS WOZ NIAK) Correct.
11 Q All right, si r.
12 You, for those instances, would complete another 13 checklist -- or a checklist, correct, a reverification -
14 checklist? $
15 A (WITNESS WOZ NIAK) The checklist that was developed for 16 reverifica tion plans, yes, si r.
17 0 All right.
18 A specific checklist fo. reverifica tion ?
19 A (WITNESS MOZNIAK) Yes.
20 Q Not the same checklist that was used by the CSR 21 inspectors for the original conduit hanger inspections?
22 A (UITNESS N0Z NIAK) Correct.
(} 23 24 0 Okay.
If an observation is made on the basis either of Sonntaa Repor tino Se rvice, Ltd. - --~
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1 the reverification of the packages or through the field 2 reinspection in the instances where there had been an j- 3 improper NA of an attribute, in those instances an 4 observation would be initiated?
5 A (WITNESS WOZNIAK) That would be correct.
6 Q All right.
7 But before an observation was initiated under the
- 8 Level III program -- I'm sorry.-- under the 9 reverification program, there was a requirement that a 10 ,
Level III Inspector review the field condition; correct?
() 11 A (WITNESS WOZ NIAK) ' I'm not aware of that, that the Level 12 III Inspector per se --
13 Q " Attributes determined to be erroneously accepted rather 14 than NA shall be corrected after evaluation by the Level 15 III Inspector."
16 A (WITNESS WOZ NIAK) To me that means that could be 17 accomplished by a review of the reverification results 18 and not necessarily a trip to the field for 19 r einspection.
20 0 All right, sir.
21 So that's a document review by the Level III?
22 A (WITNESS WOZNIAK) A comparison or rereview of the 23 design as stated earlier in your -- in the paragraphs, V(~g 24 review of the design requirements compared to the Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 uuun stR&asv2s
13577 1 documented inspection results.
2 (Indica ting. )
3 Q All right.
4 And not a field reinspection by the Level III?
5 A (WITNESS WOZNIAK) No, si r.
6 Q Okay.
- 7 The observ: tion, though, receives a review by the l 8 . Lead quality control electrical inspector?
9 A (WITNESS WOZ NIAK) Yes; which is the same as a Level 10 III, yes.
G
- (_) 11 Q And if, through that process, the observation is 12 determined valid, then it's processed pursuant to 13 BCAP-06 as a valid observation?
14 A (WITNESS WOZNIAK) Yes.
15 Excuse me. But his review would be for the --
16 suitable for the further processing portion of the 17 observation process.
18 0 I see.
19 And if determined suitable through that review, it 20 then goes into the normal channel for the BCAP-06 21 processing?
22 A (WITNESS WOZNIAK) Yes, si r.
23 Q All right.
24 Now, attached to the reverification results, Sonntaq Reporting Se rvi ce, - Ltd.
Geneva, Illinois 60134
. . - . - - ________ __________R5L2h--- - 11ު
13578 fh U-1 there's a table of the items that were reviewed, and Mr.
2 Woz niak --
3 MR. STEPTOE: Bob --
4 BY MR. GUILD:
5 0 -- the table, again, attached to the results lists 51 6 items; correct?
7 A (WITNESS WOZNIAK) Correct.
8 MR. STEPTOE: Could you identify what you are 9 showing to the witness?
10 MR. GUILD: Yes.
11 This is the document entitled, "Reverifica tion 12 results," part of the reverification program report.
13 MR. STEPTOE: Okay.
14 Thank you.
15 BY MR. GUILD:
16 0 And those 51 items are the total nwnber of items that 17 were reviewed as part of the reverification program for 18 conduit hangers?
19 A (WITNESS WOZ NIAK) The 51 packages that had been 20 completed up to that point where Dr. Kaushal had taken 21 the midpoint look, yes.
22 0 Okay.
23 Now, what's the significance of the column that
[}
24 reads, " Observation initiated and number," and an Sonntaq Reoorting Service, Ltd.
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13579 1 indication by several of those 51 items that there -- of 2 observation numbers?
3 A (WITNESS WOZ NIAK) That appears to be an entry whereby 4 an observation was written as a result of the 5 reverification program.
6 Q All right, sir.
7 Pursuant to the program plan that we were just 8 discussing, the initiation of a new observation as a 9 result of the reverification program?
10 A (WITNESS WOZNIAK) Yes.
11 0 All right.
12 And for how many items were there, then, new 13 observations initiated as a result of the observation 14 program?
15 A (WITNESS WOZ NIAK) I believe there were seven. Yes, 16 seven new observations were initiated.
17 0 All right.
18 Seven new observations, but in only five -- in five 19 items ?
20 A (WITNESS WOZ NIAK) In five item packages, yes.
21 Q All right.
22 And that 5, that number 5, is the number 5 you gave
~T 23 me on Friday when I asked you the question about how (d
24 many field inspections were conducted under the Sonntaq Reporting Se rvi ce, Ltd.
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I 13580 l l
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l 1 reverification program?
l 2 A (WITNESS WOZ NIAK) I believe so.
3 MR. GUILD: Mr. Chairman, I would ask that 4 Intervenors' 153, ERC Observation 011, be received in 5 eviden ce.
6 JUDGE GROSSMAN: Any obj ection?
7 MR. STEPTOE: Yes, Judge Grossman.
8 In the first place, the ERC Observation No. 11 is 9 incomplete, and there's a close-out letter from ERC 10 dated in February, which belongs -- dated February 21,
() 11 ,
1985,, which states that the observation is considered 12 closed.
13 Second, I have potential hearsay problems here.
14 I don't have a problem if the whole document is 15 going in, but if -- but it is hearsay as to Applicant, 16 because ERC was an indepgndent agency; but if the whole 17 document goes in, then I don' t have a problem.
18 What I don't want is to be whipsawed where Mr.
19 Guild puts in the document identifying the problem and 20 then I can't get in the rest of the document identifying 21 that it was closed out.
22 MR. GUILD: Well, Mr. Chairman, this really <
23 is an admission against Applicant.
)
24 The status of ERC as retained by Commonwealth Sonntag Reporting Service, Ltd.
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I I
13581 1 Edison Company to perform the functions it performed 2 under the BCAP program clearly makes them an agent of 3 Commonwealth Edison Company for purposes of performing 4 the functions under the BCAP program.
5 It really, I think -- as I understand the Board's 6 approach to the question of admissions, I think this is 7 highly appropriate as an example of an instance where it 8 is proper and f air that a document of this sort come in 9 through Intervenors as an admission, and prompt the 10 obligation on the part of Applicant, if they deem there
( 11 is something adverse, to respond.
12 It shouldn't be an obligation of Intervenors to 13 call Mr. Hansel as a witness in order to get a document 14 in that really came by way of Applicant as a discovery 15 document; classic admissions.
16 Now, as to the question of completeness, this is 17 the form in which it was given to me as part of the 18 reverification program. .
19 If there is, indeed, a close-out letter -- I don' t, 20 obviously, quarrel with Mr. Steptoe's representation 21 that there is. I haven't seen it. I'd be happy to look 22 at it. It may or may not be appropriate to include by 23 way of an of fer by Applicant.
{}
24 But I really offer the ERC observation itself Sonntaq Repor tina Se rvice, Ltd.
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i 4
13582 )
- (2) i 1 because it was the basis for the reverification program 2 to which this witness has testified -- Mr. Wozniak and 3 the rest of the panel members have testified.
-4 That's my only obligation. It's an admission and 5 it's appropriately admitted that way.
6 J UDG E G ROSSMAN : Mr. Steptoe, why do you 7 think you are going to have trouble getting- the closing 8 letter in?
9 MR. STEPTOE: Well, I don't have a witness 10 from ERC presently s cheduled.
() 11 Now, it is true that Mr. Laney is coming along, and 12 I suppose if I were allowed to use Mr. Laney to get the 13 closing letter in, I could do that, but I think Mr.
14 Guild would object, if I put the ERC conclusions in, as 15 hearsay, and would require me -- it seems to me this 16 situation is exactly analogous to the NRC Inspection i 17 Report -- in f act, NRC Inspection Report -- I think it's l 18 8082 was also the basis for conducting the 19 reverification program, and the Board has already ruled i
l 20 that sposoring witnesses are necessary to put in NCF,'s.
21 The ERC was an independent agency; and I think the 22 ,iss ue was well joined between myself and Mr. Guild.
23 JUDG E G ROSSMAN : It was an independent agency
)
24 retained by Applicant?
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13583 1 Refresh my recollection as to what ERC was.
2 I assume that this is 'in the record, and, of 3 course, what you are telling me is not evidence; but go 4 ahead, Mr. Steptoe.
5 MR. STEPTOE: Tha t's correct.
6 The Independent Expert Overview Group, which 7 functioned primarily through a company called ERC, was a 8 f act -- was an element of the BCAP program.
9 There was a protocol which said that any findings 10 or draft findings of the Independent Expert Overview
) 11 Group should be submitted to the NRC at the same time as -
12 to the Applicant, and, in f act, .I believe the IEOG. or 13 ERC acted as ' essentially a supplement to the NRC in 14 inspecting the BCAP program, and it certainty, as Dr.
15 Kaushal has already testified, was regarded as an
- 16 independent agency.
! 17 Let me just read to you f rom, oh, a description of 18 the group, which appears in -- I guess it's the BCAP --
19 JUDGE GROSSMAN: Well, I don' t think you have 20 to go further on that.
21 As f ar as we' re concerned, it appears as though the 22 SCAP program is a crea tion of Commonwealth Edison, and l
23 anything connected with uit is going to go in.
{}
24 My only problem was with the completeness and the l
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13584 DV 1 fact that you might have a problem getting the closing 2 letter in.
3 I don't think you are going to have that problem; 4 and I think we'll face that when you offer that, which 5 isn' t right now, but when you redirect the witnesses.
6 I just don't see that the conclusions are going to 7 be -- that the fact that certain conclusions were made 8 is going to be excludable, so I just don't see a problem 9 on that.
10 As f ar as admissions go, I think this qualifies as
/( ) 11 an admission; and as you are aware -- well, I don' t kn ow 12 that the closing letter is really part of the document.
13 If it were, you certainly wouldn't have any problem 14 getting it in.
15 With admissions, you can always bring in another 16 part of the document; but I just don't see that the 17 resul ts, even in another document, would be excludable 18 once we have this in, so we are going to -- do you have 19 an obj ection, Mr. Berry?
20 MR. BERRY: No, the Staf f has no objection, 21 Mr. Chairman.
22 JUDGE GROSSMAN: Okay. So we'll admit 23 Intervenors' 153, 24 (The document was thereupon received into Sonntag ReDor ting Se rvi ce, Ltd.
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13585
'O-1 evidence as Intervenors' Exhibit No.
2 153.)
3 BY MR. -GUILD:
4 Q Now, Mr. Wozniak, are you f amiliar with the principles 5 of Appendix B of the Commission's regulations, 10 CFR 6 Part 50, the quality assurance criteria -- the principle 7 of appropriate corrective action for identified 8 non-conforming conditions?
9 A (WITNESS WOZNIAK) Yes.
10 Q Are you f amiliar with the principle that when a
( 11 ,
non-conforming condition is identified that is of 12 significance, that it is re red that a review be made 13 of that non-conforming condition to determine whether or 14 not its existence has generic implications?
l 15 A (WITNESS WOZNIAK) Yes.
16 Q And as part of such a review, are you f amiliar with the
! 17 principle that one is called upon to identify the root 18 cause of such a non-conforming condition?
I 19 A (WITNESS WOZNIAK) Tha t's par t of th e r evi ew, yes.
20 0 In the instance of the identified deficiencies with 21 regard to the CSR electrical inspections, those
. 22 deficiencies identified by the ERC and by Mr. Gardner,,
23 the NRC Inspector, Mr. Woz niak, did you perform any l
[}
l 24 review for generic implications or root cause?
l l
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1 A (WITNESS WOZNIAK) No, I did not.
2 Q All right, sir.
3 It f ollows, therefore, Mr. Wozniak, that you cannot 4 state whether or not the deficiencies that were 5 identified by the ERC in the electrical CSR inspections 6 or by Mr. Gardner, the NRC Inspector.-- whether or not 7 those deficiencies did have generic implications?
8 A (WITNESS WOZNIAK) Mr. Guild, it would be my opinion 9 that, due to the close out of the NRC report, that those 10 -
conditions had been evaluated and that the subject
() 11 concerned was found to be of satisf actory stature.
12 Q Evaluated apparently by Mr. Gardner of the NRC?
13 A (WITNESS WOZ NIAK) Yes.
14 Q All right, sir.
15 Now, Mr. Smith, on behalf of BCAP Q A, what role did 16 BCAP QA have in the identification of the CSR 17 discrepancies that were the basis for the midpoint look?
18 A (WITNESS SMITH) I don't know.
19 Q All right, sir.
20 Did BCAP QA perform any review of the discrepancies 21 identified by CSR -- I'm sorry -- by ERC, the 22 Independent Expert Overview Group, or by Mr. Gardner,
{) 23 24 the NRC Inspector -- did BCAP QA perform any review for root causes or generic implications?
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1 A (WITNESS SMITH) This was very early in the program, so 2 I'm not really sure what you are asking me.
3 MR. GUILD: Well, is that because you don't 4 know the answer or you can't recall or because I've said 5 something that you don't understand?
6 A (WITNESS SMITH) Well, you are asking me, did I check on 7 whether or not the NRC and ERC was doing their job?
8 MR. GUILD: No, sir, that wasn't the question.
9 Would you like the question read back?
10 A (WITNESS SMITH) I'm having a hard time understanding
) 11 your question, si r. -
12 MR. GUILD: Would you like the question read 13 back to you, sir?
Fine.
~
14 A (WITNESS SMITH) 15 MR. GUILD: Could I ask that the last 16 question be read back, Mr. Chairman?
17 JUDGE GROSSMAN: Sure.
18 (The question was thereupon read by the 19 Reporter.)
20 A (WITNESS SMITH) At the time, all we were aware of was 21 what the NRC and ERC was doing.
22 We did not attempt to perform their work for them.
23 BY MR. GUILD:
{)
24 Q All right, sir.
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m l' The answer is no, you did not perform such a 2 review ?
3 A (WITNESS SMITH) We were aware, we discussed it with 4 them, but we did not try to perform any generic 5 evaluations for them, 6 Q You did not perform any such review yourself ?
7 A (WITNESS SMITH) No, sir, we did not.
8 Q Did BCAP QA review the midpoint look, in particular in 9 the electrical area, the reverification program that was 10 conducted, to determine whether the corrective action
) 11 -
taken was of suf ficient scope to fully address the 12 problem and its generic implications?
13 A (WITNESS SMITH) I could not say that I remember.
14- Q Now, Mr. Smith, the BCAP -- QA arm of BCAP and the BCAP 15 Task Force had a futmal process for communication where 16 BCAP QA identified matters of concern.
17 And is it correct that you used a device called an 18 Action Information Request, an AIR, as a means for 19 addressing questions to the BCAP Task Force?
20 A (WITNESS SMITH) That was one of other means, yes.
21 0 Does that fairly describe what an AIR is?
22 or maybe you should tell me what an AIR is.
23 A (WITNESS SMITH) The AIR is -- if we felt that there was
[}
24 a potential problem but there wasn't necessarily one, it Sonntag Reporting Service, Ltd.
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1 was a way of asking questions to get formal responses.
2 0 Okay.
3 In the areas where there may be a potential 4 problem ?
5 A (WITNESS SMITH) Where there was a potential problem.
6 Q All right, sir.
7 I want to ask you about AIR-09, Mr. Sm ith.
8 I show you a package of documents on that subject.
9 (Indica ting.)
10 I apolog,1ze they are somewhat out of order, but
() 11 perhaps you can help us walk through 'them.
12 JUDGE GROSSMAN: Excuse me.
13 Let's go off the record for a second.
14 (There followed a discussion outside the 15 record.)
16 JUDGE GROSSMAN: Let's go back on.
17 MR. STEPTOE: Judge Grossman, he did not 18 receive AIR-09 just recently. He had it in March, and 19 asked Mr. Garnder about it -- he asked Mr. Mr. Gardner 20 about it in March in the deposition.
21 MR. GUILD: Well, that's not true of the 22 document I just examined from, Mr. Chairman.
23 JUDGE GROSSMAN: No, I have no idea what he's 24 going to ask about the March 19, 1985, document, Mr.
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(U 1 Steptoe, so let's proceed.
2 BY MR. GUILD:
3 Q All right, sir.
4 Now --
5 MR. GUILD: Back on the record, Mr. Chairman?
6 JUDGE GROSSMAN: Yes, con tin ue.
7 BY MR. GUILD:
8 0 -- the documents that I've given you are somewhat out of 9 order.
10 If you look at the last page of the document --
() 11 last two pages of the document, there's a form, Mr.
12 Smith, and is that -- well, it says, " Action Item 13 R eq ue s t. "
14 Is this what an AIR is?
I 15 A (WITNESS SMITH) Yes, si r.
i 16 , Q And I take it this is an AIR that you initiated, and you 17 directed it to Mr. Kaushal, the BCAP Director?
18 A (WITNESS SMITH) One of my Q A engineers, Phillip A. Lau, 19 initiated it and I approved it.
20 Q And you approved it?
21 A (WITNESS SMITH) Yes.
22 0 All right, sir. -
{) 23 24 Now, the item is described as follows:
" Provide the basis for below inconsistency and provide quote, t
l l Sonntaq Reporting Service, Ltd.
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13591 1 correction to prevent the recurrence of using outdated 2 revision of the procedure used as a source."
3 Item 2, quote, " Provide justification for not using 4 the revision in use at the time of construction or 5 document completion. (Contractor)"
6 Now, this AIR spawned a debate between BCAP QA and 7 the BCAP Task Force on what the design requirements were 8 that would be applicable to the CSR element of BCAP; 9 correct?
10 A (WITNESS SMITH) Your question?
( 11 ,Q Did you just hear the question? -
12 A (WITNESS SMITH) I -- I -- you said this spawned a 13 deba te ?
14 Q This spawned a debate, did it not, sir, on the 15 appropriate design requirements to apply to the CSR 16 element of BCAP?
17 A (WITNESS SMITH) There was a discussion of design 18 r egirements, yes.
19 0 And that discussion of design requirements arose in 20 response to AIR-009?
21 A (WITNESS SMITH) or the other way around. I mean, 22 our -- our desire to debate the issue was documented in 23 AIR-009.
24 009 did not cause us to want to debate.
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- (_)
1 Q Understood.
2 This documents the debate that you had on that 3 subj ect ?
4 A (WITNESS SMITH) That is correct, this documents it.
5 0 All right, sir, all right.
6 Now, you approved this AIR on the specific subject 7 involving the use of a Comstock -- L. K. Comstock --
8 procedure for purposes of checklist preparation; 9 correct?
10 A (WITNESS SMITH) Which memo specifically are you 11 referring to?
12 Q Again, looking at the text of BCAP AIR-009.
13 The specific case --
14 A (WITNESS SMITH) Correct.
15 0 -- that prompted the AIR was the use of an older 16 Comstock procedure than was in effect at the time of the 17 checklist preparation?
18 A (WITNESS SMITH) That is correct.
19 Q All right.
20 But the question that you were asking was more 21 generic, was it not, and had to do with what the :
22 appropriate design requirements more generally should be l under BCAP?
{} 23 24 A (WITNESS SMITH) That's correct.
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(/
1 Q All right.
2 Now, what was the -- what specifically were you 3 asking the BCAP Task Force to do by way of this AIR?
4 A (WITNESS SMITH) To provide their basis for picking the 5 checklist and requirements that they were picking.
6 Q Okay.
7 Now, the AIR bears a date of February 1, 1985?
8 A (WITNESS SMITE) Correct.
9 Q And what was the required turnaround time for a response 10 to an AIR?
11 A (WITNESS SMITH) Th,ere .was no specific turnaround time.
17 It was whatever .I deemed necessary.
13 I think I put a five-day turnaround on it, a week.
14 0 All right.
15 And can you show us where that appears? Is there 16 a place -- .
17 A (WITNESS SMITH) Box 12, " Response Due Date."
18 Q All right.
19 Did you get a response the 6th of February, as you 20 r equested ?
21 A (WITNESS SMITH) No, sir.
22 Q Okay.
(} 23 24 In fact, you had to write Dr. Kaushal on the 8th of February and tell him that the response was overdue?
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1 A (WITNESS SMITH) Tha t's correct.
2 Q All right.
3 Did you get a response thereaf ter to -- af ter 4 reminding them that it was overdue?
5 A (WITNESS SMITH) The next page forward in your package 6 is a February 15th memo, 686 --
7 Q Asking for an extension of time to respond?
8 A (WITNESS SMITH) That's correct.
9 Q And did you get a response to your AIR by that extended 10 response time of February 22nd?
} 11 A (WITNESS SMITH)- It appears so. ,
12 Q Well, didn't you have to write Dr. Kaushal again on the 13 25th of February?
14 A (WITNESS SMITH) No. We received a response to AIR-009 15 on 2/21/85, and then on 2/22/85 the originator of the 16 document felt that the response he received was 17 unsatisfactory, and on 2/25 an additional memo was 18 forwarded to Dr. Kaushal.
19 0 All right, sir.
20 So you had to seek an additional response.
21 Now, the document that appears to be the initial 22 response, that bears a Bates Stamp Number of Bill 39, j 23 Soos it not? It's entitled, " Response to BCAP QA
[}
24 AIR-009"?
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13595 1 A (WITNESS SMITH) What's the number?
2 Q B00lll39.
3 A (WITNESS SMITH) 37.
4 0 I'm looking at 39; but, yes, indeed, that's another copy 5 of it.
6 That's the first response; correct?
7 A (WITNESS SMITH) Yeah, the first response was 37.
8 Q All right.
9 Now, what about the first response was deemed 10 unsatisfactory by either you or the initiator of the 11 AIR?
12 A (WITNESS SMITH) Well, excuse me.
13 It looks like 37 and 39 are the same.
14 Q Yes, it appears they are the same document.
15 A (WITNESS SMITH) Okay. Do I have a current question?
16 0 Yes, sir.
17 What was it about the initial response that was 18 deemed unsatisfactory by BCAP QA?
19 A (WITNESS SMITH) As stated in the February 25th memo, it 20 dealt with the accept / reject criteria.
21 It says, "Since Item 2 in the ' Description of 22 action requested' of AIR-009 was not responded to, we i i
23 will rephrase the question. l
(}
24 "The BCAP program document discusses construction 1
1
~ ~ "
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~~
J 1 sample in terms of items Construction Sample 2 Reinspection in terms of items inspected prior to 3 6/30/84. Ther ef or e, the use of design documents dated 4 af ter June 30, 1984, seems to be outside the program 5 commi tment s. "
6 Q All right.
7 Then you rephrased the question?
8 A (WITNESS SMITH) It was rephrasing the question to get 9 into, "We would like you to justify' the basis for your 10 CSR engineers not using the specifications, drawings and
() 11 other design documents which were in effect as of June 12 30, 1984."
13 Q All right, sir.
14 And instead, in this case, using a later 15 s pecifica tion ?
16 A (WITNESS SMITH) Using a later.
17 0 All right, sir.
4
- 18 Now, you received a response f rom the BCAP Task 19 Force to that request, and that was a March 5, 1985, i
20 memo f rom Mr. Orlov to you?
j 21 A (WITNESS SMITH) Yes, si r.
22 0 With an attached explication entitled, "BCAP-CSR Element 23 Application of Latest Design Requirements to 24 Previously-Completed Work"?
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1 A (WITNESS SMITH) Uh-huh.
2 Q All right.
3 You reviewed Mr. Orlov's memo, did you not?
4 A (WITNESS SMITH) That is correct.
5 0 And you responded on the lith of March, raising further 6 questions on the issue of the appropriate design 7 requirements to apply to the BCAP CSR efforts?
8 A (WITNESS SMITH) Well, not -- I wouldn't say we were 9 raising further issues.
10 I think at this point we basically were in
() 11 -
agreement with what the task force was saying, but we 12 were toying to put it into some specific examples that 13 we could give to people as, "Here's some concrete 14 examples versus some nice words."
15 (Indica ting. )
16 Q All right.
17 And so you set out a variety of cases that 18 represented your --
19 A (WITNESS SMITH) Interpretation.
20 0 -- interpretation of Mr. Orlov's description of the 21 issue of applicable design requirements?
22 A (WITNESS SMITH) Yeah.
23 And at this point, we were really very close
[}
24 together on what we felt was appropriate.
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1 Q You and Mr. Orlov?
2 A (WITNESS SMITH) Mr. Orlov and BCAP Q A.
3 Q All right.
4 And you set out the cases by way of example, and 5 then asked that both Mr. Orlov, as the Assistant 6 Director, and Dr. Kaushal, as BCAP Director, endorse 7 your recitation of the exemplary cases?
8 A (WITNESS SMITH) That is correct.
9 0 All right, si r.
10 So that those cases could be used as guidance for
() 11 people who were performing the CSR element of BCAP?
12 A (WITNESS SMITH) That is correct.
13 And we had a number of discussions concerning our 14 examples and Mr. Orlov's memo of March 5th, and it was 15 pointed out to us that while our examples were nice 16 exampl es, they were clean cut; that there wer's a number 17 of minor things that had to be considered, and that 18 these would not be an encompassing set of examples.
19 To do so would be a very long and complex document, 20 so we gave up on it.
21 Q So neither Mr. Orlov nor Dr. Kaushal endorsed your 22 proposed examples of the application of the principles
, 23 of design requirements, appropriate design requirements; 24 correct?
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1 A (WITNESS SMITH) They did not endorse it.
2 My understanding of their reason they were not 3 endorsing is it they were not a complete set of 4 exampl es.
5 Q All right, sir.
6 The f act is they didn' t endorse your proposed 7 e xamples ?
8 A (WITNESS SMITH) That is correct.
9 Q Nor did they endorse any examples of the application of
. 10 the design ' requirement principles that Mr. Orlov and you (O_) 11 agreed to?
e 12 A (WITNESS SMITH) They. did not endorse the specific 13 examples, no.
14 0 All right.
15 Now, by the March 19th letter, you asked for 16 further clarification?
17 A (WITNESS SMITH) Basically definitions; and this was a 18 result of our meeting.
19 Q All right, sir.
20 And what response, if any, did you get to your 21 March 19th memo?
22 A (WITNESS SMITH) We received a response that provided 23 inf orma tion upon which we closed out the AIR, if memory
(}
24 serves me correctly.
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1 Q All right, sir.
2 I don't believe that response is in the package 3 that I have here.
4 What does that response consist of ?
5 A (WITNESS SMITH) .I believe it provided specific words 6 for its various definitions.
7 Q All right, 8 And who prepared that response, sir?
9 A (WITNESS SMITH) What?
10 0 Who prepared that response, sir?
() 11 A (WITNESS SMITH) The task force. .
12 Q Was it Mr. Orlov? ,
13 A (WITNESS SMITH) I am not sure if he did.
14 Probably.
15 MR. STEPTOE : Excuse me.
16 I have a copy of that, if you want it.
17 MR. GUILD: Yes, I would appreciate it.
18 BY MR. GUILD:
19 Q When you closed the AIR, Mr. Smith, did you, by that 20 action, agree with Mr. Orlov and Dr. Kaushal's 21 description of the appropriate design requirements for 22 . the .use under the BCAP program?
23 A (WITNESS SMITH) May I see what I -- ref resh my memory 24 on the examples ?
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 UG53 91M-AMR
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~1 Q Sure.
2 I'm showing you an April 2, 85, document counsel 3 made available to me just now, your closure of the AIR.
4 (Indica ting. )
5 A (WITNESS SMITE) And right below it is the March 25th, 6 which provides the specific definitions --
7 Q All right.
8 A -- he asked for.
9 0 And you accepted that explanation?
10 A (WITNESS SMITH) And I believe we closed the AIR on the 11 definitions plus the previous memo; that we had enough 12 words that we could then provide adequate guidance to 13- our QA engineers as to what was and was not acceptable 14 in the performance survellances.
15 0 By the previous memo, you mean Mr. Orlov's memo that's 16 attached?
17 A (WITNESS SMITH) Yes, I believe it's 800. It's the 18 Ma r ch 5, 19 85, B CAP Memo 80 0.
19 Q That's Mr. Orlov's memo to you?
20 A (WITNESS SMITH) Tha t's Mr. Orlov's memo.
21 MR. GUILD: Mr. Chairman, I don't have a 22 complete document of the document I've handed up; and
{) 23 24 what I would like leave to do is to add the additional Orlov response of March 25, 1985, to Mr. Smith and Mr.
Sonntaa Reportino Service, Ltd.
Geneva, Illinois 60134 iLsutu %twr.sys
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' ("1 v
1 Smith's memo closing out the AIR, and ask that the 2 entire set of documents be received in evidence.
3 JUDGE GROSSMAN: Okay.
4 We'll mark the entire document Intervenors' 154.
5 Do we have a f ull package for everyone, Mr.
6 Steptoe?
7 MR. STEPTOE: I believe so.
8 We can take the top three pages off the document I 9 gave him and give it to you, and then you will have the 10 complete -- I believe you will have the complete set.
) 11 MR. GUILD: I only have three copies, and I 12 appreciate Mr. Steptoe even having three; but what I 13 would like to do is make copies for the Board and 14 pa r tie s.
15 J UDG E G ROSSMAN : Okay. We will take that 16 t omor r ow, then. Fine.
17 I take it there's no objection to the admission of 18 the document?
19 MR. STEPTOE: No obj ection.
20 I'd like the opportunity to make sure it's the f ull 21 package; but no obj ection.
22 MR. BERRY: Non e f r om th e Staf f, Mr.
23 Chairman.
24 JUDG E GROSSMAN: Okay.
Sonntaq Reporting Se rvice, Ltd. !
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1 So we'll admit Intervenors' 154, and we'll receive 2 it for inclusion in the record tomorrow, though it's 3 received now.
4 (The document was thereupon received into 5 evidence as Intervenors' Exhibit No.
6 154.)
7 JUDG E GROSSMAN: Do you wish to take a recess 8 now, Mr. Guild?
9 MR. GUILD: No, sir, Mr. Chairman, that's 10 fine.
) ,
1 1, BY MR. GUILD:
12 Q Now, the policy that is reflected in the series of 13 documents relating to AIR-009 on the application of 14 design requirements to BCAP CSR, was that policy used in 15 passing on the validity of CSR observations?
16 A (WITNESS SMITH) Yes.
17 Q All right, si r.
18 And on the basis of the application of that policy, 19 certain CSR observations were deemed invalid?
20 A (WITNESS SMITH) Yes.
21 MR. GUILD: Mr. Chairman, I am going to begin 22 a new line, and if this is an appropriate time to take a 23 break, that's fine.
24 JUDGE GROSSMAN: Okay, fine.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 tiutu %t% rare
13604 1 We'll take 10 minutes.
2 (Whereupon, a recess was had, af ter the 3 hearing was resumed, as follows:)
4 JUDGE GROSSMAN: We' re back in session.
5 MR. BERRY: Mr. Chairman, could I just state, 6 for the record, that it's my understanding that DIA has 7 done what they were requested -- that they represented 8 that -- what I had represented that they were going to 9 do in relation to the McGregor matter, and that's all 10 I'll say. That's all I'll say at this point; but it's
() 11 my understanding that they have fulfilled their 12 obligations that the Staff informed you on.
13 JUDGE GROSSMAN: Well, we have a letter dated 14 October 1st from the director of OIA in which it 15 suggests that there will be a final disposition of both 16 inspections -- of both investigations which have been 17 discussed; but we see that one report is expected to be 18 completed by October 10th and the other one will be 19 completed in approximately one week. One week from 20 October lot is approximately October 8th or 10th, also.
21 I see that -- well, let me read the last paragraph.
22 "We are providing this letter only to the Licensing 23 Board and as a courtesy to Mr. !!cGregor and his
[} i 24 attorney, Mr. Geoca ris. He do not obj ect to the Board Sonntao Repor tino Se rvice, Ltd.
Geneva, Illinois 60134
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('v) 1 itself providing the letter to the proceeding if the 2 Board thinks it would be necessary for the proper 3 conduct of the proceeding, but unless Mr. McGregor makes 4 the letter public, we believe that disclosure to the 5 parties should only be on an in-camera basis."
6 I hesitated to mention the letter because of that; 7 but I really don't even understand, from what's 8 contained in the letter, why it should be in camera.
9 I would hope that we would get the final report on 10 or about October 10th, anyway, and I guess that should
( 11 resolve the entire issue, and we ought to be able to 12 have Mr. McGregor back perhaps next week.
13 MR. BERRY: Mr. Chairman, I did see the 14 letter, you know. I read it along with you this 15 afternoon.
16 It's my understanding -- it's not even my 17 understanding. I guess my assumption is that actually 18 there were two investigations referred to.
19 I believe the first investigation is the one that 20 Mr. McGregor himself alluded to.
21 The fieldwork is complete; I believe the draf t 22 report is written.
, 23 The report is probably just going through final
)
24 review; and I think it should be issued -- I think the Sonntaa Reportino Service, Ltd.
Geneva, Illinois 60134 onsu;to ctsuw.wvw
1 13606 O
V 1 letter refers to October the 10th.
2 The second one -- the second matter I'm not certain 3 what the status is.
4 I would assume that what that refers to is the 5 fieldwork has been completed or is about to be completed 6 and a report will have to be issued on the -- a draf t 7 report will have to be written on that, and that will 8 have to go through the reviewer.
9 So I'm not certain if the second report that's 10 referred to in that letter will be available for n)
(_ 11 issuance by October 10th or when the first one is. It 12 may well be, 13 But I would just want to point out to the Board and 14 the parties, with respect to the second one, there may 15 be a time lag built into that, if what they are . talking 16 about is correct.
17 JUDGE GROSSMAN: Okay.
18 The reason I'm a little surprised that they wish 19 this to be in camera is that apparently there has been 20 nothing in here derogatory towards Mr. McGregor, and 21 considering the cloud that appeared over him from what 22 we heard previously, I think it would only be fair to 1
23 discloco the entire matter; but we'll just hold off for
)
24 a few days until we decide what we ought to do with Sonntaa Reporting Service, Ltd.
Geneva, Illinois 60134 LaRm su191-A5uw 1
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1 tha t.
2 MR. BERRY: You know, if I might remark just 3 briefly, Mr. Chairman, I believe that the reason for 4 that is ordinarily matters of this type would not be the 5 subject of an inquiry into an operating license 6 proceeding.
7 Matters of this type really are really not 8 necessary to be disclosed to the public, and it's a 9 privacy matter, really, and I think that's the caution 10 for the subject of the investigation. That would be the
() 11 reason for that.
12 I don' t have any particular obj ection to it being 13 made public, but before I give that final assurance, I 14 would just take the opportunity to consult, you know, 15 with my colleagues; but I think that the reason for that 16 last paragraph in that letter is just generally 17 consistent with the NRC's procedures, and it's way of 18 operating, that a personnel or an internal 19 grievance-type matter -- we generally don't make matters 20 like that public.
21 JUDGE GROSSMAN: Okay, fine.
22 I would hope that you would be in touch with Mr.
23 McGregor and find out, since he has received a copy of 24 this, whether he'd be available next week for completing Sonntaq Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 L9ute est% a9vte
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1 his testimony.
2 MR. BERRY: We will do that, your Honor.
3 MR. GUILD: Mr. Chairman, we would request a 4 copy of whatever communication OIA has made on the 5 subject to the Licensing Board.
6 With respect to an in-camera restriction on it or a 7 protective order on it, if that's the pending position 8 of the Board or the Staff, that I have the same doubts 9 about the appropriateness of treating it as secret, 10 since, in fact, Mr. McGregor mentioned matters very
) 11 prominent on the record; and I believe the fairness to 12 him calls for closing the matter on the public record.
13 But for the time, I would ask that the parties 14 receive copies of whatever OIA has communicated to the 15 Licensing Board.
16 JUDG E G ROSSMAN : Okay.
17 Mr. Miller, I take it you are agreeable to 18 receiving this under protective order, at least reading 19 i t, because all we have is one copy here?
20 MR. MILLER: Yes, sir.
21 JUDGE GROSSMAN: And you, too, Mr. G uild ?
22 You would agree to that?
23 MR. GUILD: Yes, si r.
24 JUDG E G ROSSMAN: And I would expect that as
--"Sonntaq Reporting Service, Ltd.
Geneva, Illinois 60134 L gju ga _ _,sjuq_ gs gs
13609 1 soon as Mr. McGregor gives his okay, we can make it 2 public.
3 So at the close of today's session, we'll just let 4 you read the copy of the letter.
5 MR. GUILD: Thank you, Mr. Ch airman.
6 May I proceed?
7 JUDG E G ROSSMAN : Continue, please.
8 BY MR. GUILD:
9 Q Mr. Wozniak, turn, if you would, please, sir, to Page 7 10 of your prefiled testimony.
( 11 There in Answer 18, you state, quote, "W e 12 reinspected all conduit support hangers inspected prior 13 to January 24, 1985, for the attributes called in 14 question."
15 Shouldn' t that testimony actually read, "We 16 r everified all," instead of, " reinspected all" ?
17 A (WITNESS WOZ NIAK) Reinspection per se of the design 18 requirements versus the attributes that had been 19 documented; but quite possibly for the purpose of this 20 text, reverification would be the proper terminology, 21 yes, sir.
22 Q All right, si r.
{} 23 24 You didn't actually go out and do a field reinspection, as we've used the term " inspection" in our Sonntaq Reoorting Service, Ltd.
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(d 1 conte xt, to look at the physical characteristics of the 2 item?
3 A (WITNESS WOZ NIAK) We did not go out and inspect in the 4 field all 51 packages, no, si r.
l 5 0 All right, sir.
6 Mr. Smith, if you would turn to Page 9 of your 7 prefiled testimony, sir, there you speak about the BCAP 8 QA overinspection of CSR inspectors' work, and you 9 state, in pa r t, that you employed a 95 percent 10 acceptance rate for obj ective attributes and a 90
() 11 percent agreement rate for subjective attributes; 12 namely, welding; correct? .
13 A (WITNESS SMITH) Yes, sir.
14 Q All right.
15 Now, you state that the basis for using those 16 acceptance criteria of 95-90 was the Byron QC IRP and 17 the supplemental initial decision of the Licensing Board 18 in the Byron proceeding that you cite to?
19 A (WITNESS SMITH) Yes, sir.
20 0 What was the empirical basis for the use of a 95 per cent 21 acceptance criteria for objective attributes and a 90 22 percent acceptance criteria for welds?
23 A (WITNESS SMITH) When you say " empirical," could you --
24 0 Yes.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 UDUG 219-R9BJ2
13611 1 What basis in fact, aside from citation to the 2 Byron Licensing Board decision and the Byron Quality 3 Control Inspector Reinspection Program, did you have as 4 a basis in fact, sir?
5 A (WIINESS SMITH) I'm having a hard time -- excuse me.
6 I'm having a hard time hearing you and understanding 7 what you mean.
8 0 I'll be happy to repeat.
9 Am I speaking loud enough?
10 A (WITNESS SMITH) I have ear problems.
() 11 Q Tell me if you can't hear me; and we can make sure I 12 read it back or read it loud enough.
13 Would you like me to repeat the last question?
14 A (WITNESS SMITH) Yes.
15 It dealt with empirical?
16 0 Yes.
17 What was the empirical basis for the use of the 18 95-90 acceptance criteria that you employed in your 19 overinspections?
20 A (WITNESS SMITH) The Byron licensing decisions.
21 Q That's your basis.
22 Now, what was the basis in f act -- aside from 23 relying on or citing to the Byron decision, what facts
)
24 support the use of a 95 percent acceptance criteria for Sonntaa Reporting Se rvi ce, Ltd. -- -
Geneva, Illinois 60134 CEQUD 9LW-fU6*S
i 13612 l (3
u) 1 objective attributes?
2 A (WITNESS SMITH) I guess I don't know what you are 3 asking, si r.
4 Q Do you know the answer to the question of whether there 5 is a factual basis for the use of a 95 percent 6 acceptance criteria?
7 A (WITNESS SMITH) No.
8 My only basis for using it was the Byron Licensing 9 Board decision.
10 0 , All right, sir.
("T -
-(/ 11 The same answer for the 90 percent acceptance 12 criteria?
13 A (WITNESS SMITH) Correct, that's correct.
14 Q Okay.
15 Do you know whether or not there is an empirical 16 basis, a basis in fact, for using those acceptance 17 criteria?
18 A (WITNESS SMITH) Other than people telling me that they 19 are generally-accepted numbers, no, si r.
20 (Indica ting. )
21 Q All right.
22 Now, gentlemen, I want to show you a sample item
(} 23 from the CSR sampling and ask you to help me identify 24 the constituent parts of the package.
Sonntag Repor ting Se rvice, Ltd.
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13613 1 (Indica ting. )
2 First let's turn, if we would, please, to Dr.
3 Kaushal's Attachment 4.
4 I'm looking at Line Items 919 and 920. They are 5 the results -- the data base results for Cable Pan 6 Hanger 104.
7 Do you have that before you, gentlemen?
8 A (WITNESS KAUSH AL) I do.
9 Q Cable Pan Hanger 104?
10 A (WITNESS KAUSHAL) I'm seeing it.
() 11 Q You have it, Dr. Kaushal?
12 A (WITNESS KAUSHAL) I have it in front of me, yes.
13 Q All right, sir.
14 Now, for that particular CSR item, as I understand 15 it, two weld inspection documents -- Comstock weld 16 inspection documents -- were identified; is that 17 correct, Dr. Kau sh al ?
18 A (WITNESS KAUSB AL) That would be correct based on these 19 entries.
20 Q All right.
21 And they reflect an inspection on May 15, '81, by 22 IFD, and tha t is Mr. DeMald, the present Comstock 23 Quality Control Manager; correct?
t 24 A (NITNESS KAUSH AL) That would be correct, yes.
i I
Sonntaq Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262 _
13614 1 Q All right.
2 And a second weld inspection performed -- or dated 3 February 8, 1982, by R. L. M., and that's Richard L.
4 Martin, is it not?
5 A (WITNESS KAUSHAL) I believe that's correct.
6 O All right, sir.
7 Now, in that particular item --
8 MR. GUILD: Is the reference clear to the 9 Board members? It's CPB 104.
10 JUDG E CALLIH AN : Revision 2, Mr. Guild?
() 11 IR. GUILD: I don't think it's the subject of 12 any revisi6n, Judge Callihan, but, yes, Revision 2 is 13 the current one.
14 JUDGE COLE: It's Page 17, I believe --
15 MR. GUILD: All right, si r. Thank you.
16 JUDG E COLE: -- AR 006866006866 17 NY MR. GUILD:
18 Q Now, that particular item, gentlemen of the panel, was 19 counted to have 1,923 inspection points; correct?
20 A (WITNESS KAUSH AL) That's correct. That's what it 21 says.
22 Q All right.
23 An6 those consisted of 128 welds?
24 A (WITNESS KAUSH AL) Right.
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13615 1 Q All right.
2 of the 1,923 inspection points, there were 37 3 discrepancies identified?
4 A (WITNESS KAUSHAL) Yes, yes, discrepancy points.
5 Q Discrepancy points?
6 A (WITNESS KAUSHAL) Right.
7 Q All right, si r.
8 Of the 128 welds, 24 of them were discrepant?
9 A (WITNESS KAUSHAL) That's correct.
10 Q All right, sir.
I) 11 Now, the data points are identical for both Mr.
- 12 DeWald and Mr. Martin.
13 And does that mean that, for data -- for the data i- 14 base purposes, you assumed that both of those inspectors I
- 15 inspected all of those welds?
! 16 A (WITNESS KAUSHAL) 'S&iat would be the understanding, 17 yes.
18 Q And both of those inspectors inspected all of those 19 in spection points?
20 A (WITNESS KAUSH AL) That would be, yes.
21 Q And both of those inspectors failed to identify each of 22 the discrepancy points?
23 A (WITNESS KAUSHAL) That would be the implication, yes.
24 Q Again, finally, both of those inspectors failed to
(
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U 1 identify each of those discrepant welds?
2 A (WITNESS KAUSHAL) That's correct.
3 Q All right, sir.
4 A At least that's the implication f rom here.
5 0 W ell, that's the way the data is presented --
6 A (WITNESS KAUSHAL) That's correct.
- 7. Q --
and described, is it not?
8 A (WITNESS KAUSHAL) Right.
9 Q Let's see if we can walk through a package reflecting 10 this inspection.
() 11 First I show you a package. that begins with the 12~ ' observation -- the first observation for this item.
13 (Indica ting. )
14 Now, Dr. Kaush al, if you would help me flip through 15 this package, we have an observation record for CPH 16 104-0l?
17 A (WITNESS KAUSHAL) Correct.
18 Q All right.
19 And flipping through, we then have an Observation 20 02 for the same item, do we not?
21 A (WITNESS KAUSH AL) Yes, there is.
22 Q And there's an 03 and also a 4? l 1
23 There are four observations for this particular j 24 item, Cable Pan Hange r 104 ? i l
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V 1 A (WITNESS KAUSHAL) Yes, I see four of them.
2 O All right, sir.
3 Now, your data points in your Attachment 4 to your 4 testimony only reflect the existence of one observation; 5 correct?
6 A (WITNESS KAUSHAL) No; that isn' t necessarily true, no.
7 0 W ell, do you know whether it reflects more than one?
8 A (WITNESS KAUSHAL) It reflects all the discrepancies on 9 that particular item.
10 , Q Well, all the discrepancies that were determined to be
() 11 valid for that particular item?
12 A (WITNESS KAUSHAL) All the discrepancies that were 13 determined to be valid, which are the only things that 14 we call discrepancies.
15 Q All right, sir.
16 A (WITNESS KAUSHAL) The rest are not called 17 dis crepancies.
18 Q Yes, sir.
19 And, in fact, Observation -- Cable Pan Hanger ;
20 104-01 is determined out of scope; correct?
21 A (WITNESS KAUSHAL) Yes, that's correct.
22 Q It was deemed -- it was previously deemed valid, but 23 then determined out of scope on the basis of the Sargent
)
24 & Lundy cable pan hanger configuration walkdown program?
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1 A (WITNESS KAUSHAL) It was not just the Sargent & Lundy 2 cable pan hanger walkdown. It included Comstock's, yes.
3 0 All right, si r.
4 But it was on the basis of that walkdown program 5 that this observation was deemed out of scope?
6 A (WITNESS KAUSHAL) That's correct.
7 0 But it previously had been deemed a valid discrepancy?
8 That's the preceding page.
9 A (WITNESS KAUSHAL) The initial assessment by the 10 engineer was marked valid, yes.
() 11 Q All right, si r. -
12 On the basis that it reflected discrepancies from 13 the original design configuration?
14 A (WITNESS KAUSH AL) I'm sorry ?
15 0 It reflected discrepancies from the design 16 configuration?
17 A (WITNESS KAUSHAL) Well, that's a statement, Mr. Guild.
18 May I know what the question is?
i 19 Q Well, that is a question.
20 Is that accurate, sir, that the 01 observation 21 indeed reflected valid discrepancies in the 22 field-observed configura tion from design r equirements ?
23 A (WITNESS KAUSH AL) Mr. Guild, I would not be able to
}
24 state to tha t, because the -- it did go through some l
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-1 process.
2 I guess, in this case, I would have to say that's 3 correct, yes.
4 0 All right, sir.
5 Now, 02 similarly -- also similarly reflected 6 discrepancies in the cable pan hanger that were deemed 7 valid discrepancies f rom design requirements, but, 8 none th eless, the observation was deemed out of scope of 9 BCAP and, therefore, the discrepancies were not counted 10 as discrepancies?
() 11 A (WITNESS KAUSHAL) That's what the paper would signify, 12 yes.
13 Q All right.
14 And the same for 03, also valid discrepant 15 configuration conditions deemed out of scope on the 16 basis of the Sargent & Lundy walkdown?
17 A (WITNESS KAUSHAL) Tha t's correct.
18 Q Leaving BCAP CSR Cable Pan Hanger Item 104, Observation 19 4, as the only valid in scope observation discrepancy 20 that required further evaluation?
21 A (WITNESS KAUSH AL) That's the one that pertains to 22 w eld s. I believe that's correct, yes.
23 0 You find that in the document that follows 1, 2 and 3?
24 A (WITNESS KAUSH AL) I'm sorry ?
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v 1 Q Do you find that in the documents?
2 A (WITNESS KAUSH AL) Yes, I found it.
3 Q All right, si r.
4 Now, Dr. Kaushal, attached to BCAP -- to the 5 Observation 04 for Cable Pan Hanger, the second page of 6 the document as well as the third and the fourth page 7 are drawings, are sketchs?
8 A (WITNESS KAUSHAL) Sketchs, yes.
9 Q All right.
10 Are they sketchs as you used the term ",sketchs"
() 11 earlier in your examination --
12 A (WITNESS KAUSHAL) Yes.
13 0 -- as opposed to weld maps?
14 A (WITNESS KAUSH AL) These are sketchs, yes.
15 Q All right, si r.
16 Now, the first sketch -- and that is Attachment 1, 17 Page 1 of 3 -- does that appear to reflect a section 18 view of the hanger?
19 A (WITNESS KAUSHAL) That's what it appears to reflect, 20 yes.
21 Q All right, sir.
22 How many welds are on that -- are shown on that 23 section view of the drawing of the cable pan hanger?
24 MR. STEPTOE: Nell, I'll obj ect to this Sonntaq Reporting Service, Ltd.
Geneva, Illinois 60134 CDUD Ul#-f@$#2
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'a 1 question.
2 He's asking the wrong witness, Judge Grossman.
3 It's already in the record that Sargent & Lundy did 4 the counting of the inspection points and the counting 5 of the welds.
6 MR. GUILD: All right, sir.
7 MR. STEPTOE: If the only purpose is to 8 embarrass Dr. Kaushal by making him go through an 9 exercise on the stand -- you know, I'd be hard pressed 10 to do this, especially if I were under oath.
() 11 JUDGE GROSSMAN: Well, I'm not sure it will 12 embarrass Dr. Kaushal.
13 MR. STEPTOE: W ell, I do n ' t kn ow.
14 JUDGE GROSSMAN: He probably has the answers 15 to these.
16 If it gets to that point, we'll take the obj ection 17 into account.
18 MR. STEPTOE: Thank you.
19 BY MR. GUILD:
20 Q Dr. Kaushal, f rom the sketch attached to the observation 21 for 4, 04, how many welds are indicated for that cable 22 pan hanger? .
g 23 A (NITNESS KAUSH AL) Mr. Guild, I would not be able to
(~/
\_
24 count th em.
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1 Q All right, si r.
2 It's a complex hanger; but are all the welds on 3 that hanger shown on that sketch?
4 A (WITNESS KAUSH AL) My general expectation will be that 5 the discrepant welds would be shown. All the good welds 6 may or may not be shown.
7 Q All right.
8 Well, how many discrepant welds are there, sir?
9 A (WITNESS KAUSHAL) Again, I would have difficulty 10 counting this.
I 11 Q All right. ,
12 It's a very complex drawing or sketch, is it not?
13 A (WITNESS KAUSH AL) That is correct.
14 Q And contains a large amount of information, a lot of 15 data?
16 A (WITNESS KAUSH AL) That's correct.
17 Q All right, sir.
18 Would you agree that it's a difficult task, from a 19 review of this sketch, to identify the number of 20 discrepant welds?
21 A (WITNESS KAUSH AL) As I said, I would have difficulty; 22 but for a person who's been doing this all the time, it 23 should not be that difficult.
24 Q All right, si r .
t Sonntag Reporting Service, Ltd.
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'O 1 Well, I haven't been doing it all this time, and I 2 tried and I couldn' t do it.
3- You can't do it, can you, sir, determine how many 4 welds -- discrepant welds there are?
5 A (WITNESS KAUSHAL) If I did it for a living, I could ;
6 but no, I cannot at this time.
7 0 All right, si r.
8 Now, then, following the section view of the hanger 9 in question and the indication of where certain i 10 discrepant welds are anticipated on that hanger, there
()
11 are two pages of detail.
- 12 And can you tell me what those details are, sir?
~
13 A (WITNESS KAUSHAL) Those details point to certain weld 14 discrepancies in the more detailed form.
e 15 0 All right.
16 They clearly don't reflect all of the discrepant 17 welds ? They are not detailed -- there are no detail
-18 drawings for many of the discrepant welds indicated on
- 19 the first sheet; correct ?
' 20 A (WITNESS KAUSHAL) Mr. Guild, just so I don't create a 21 misunderstanding, I have not taken the time, and I'm not 22 sure I can do it quickly, reviewing what's on thezfirst 23 attachment.
24 I am looking at the second attachment, and I I Sonntaq Reporting Se rvi ce, Ltd.
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1 understand it to be detailed views of certain discrepant 2 w elds.
3 Q All right, sir.
4 A (WITNESS KAUSH AL) You know, whether or not it reflects 5 all the discrepant welds, I really couldn't testify to 6 that at this time.
7 Q Well, sir, just looking at the first -- the second page, 8 I see there are four details shown, AA through DD; 9 correct?
10 A (WITNESS KAUSHAL) Yes, that's correct.
() 11 Q And there are two additional details shown on the third, 12 sheet?
13 A (WITNESS KAUSH AL) That's correct.
14 Q Now, if we took each of those as separate weld details, 15 that would be six.
16 And there are clearly more than six discrepant weld 17 details depicted on Sheet 1, are there not?
18 A (WITNESS KAUSHAL) Many of those details may be 19 iden tical, Mr. G uild.
20 0 There are, indeed, though, more than six discrepant weld 21 details shown on the first sh e e t, though, aren' t there ?
22 A (WITNESS KAUSH AL) I would not know that.
23 See, the first sheet is supposed to show, as you 24 indica ted, the section view of the hanger identifying Sonntaq Reporting S e rvi ce, Ltd.
Geneva, Illinois 60134 L CiULD 21bfdSJ2 _-
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I where the discrepancies were seen.
2 A number of those connections appear to me, on 3 cursory review, to be similar, and they may be amenable 4 to sketchs than the details that are more generally 5 applicable.
6 Q All right, sir.
7 Mr. Shevlin, do you have the document available to 8 you, sir?
9 Can you help clarify what the sketchs represent, 10 sir?
() 11 A (WITNESS SHEVLIN) Yes, sir.
, 12 On the first page of the attachment, there's an 13 elevation view of a support.
14 By definition, it represents a side view of the 15 entire support.
16 0 All ri~ght, sir. Thank you.
17 A (WITNESS SHEVLIN) The only thing that's excluded is the 18 connection to the building steel, 19 Q Which would be to the top of the page?
20 A (WITNESS SHEVLIN) Yes.
21 Q All right.
22 A (WITNESS SHEVLIN) Now, it can be seen, by looking at 23 this elevation view, that the section shown on Pages 2 24 and 3 have been cut from various areas on the elevation.
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1 2 A (WITNESS SHEVLIN) Yes, exa ctly.
3 Q All right, sir.
4 A (WITNESS SHEVLIN) That would put the sections shown on 1 5 Pages 2 and 3 of the attachment in perspective with the 6 hanger.
7 Q All right, si r.
8 A (WITNESS SHEVLIN) At that point, the engineer who will 9 evaluate these discrepancies will know exactly where on 10 the hanger he is looking, be able to relate the
() 11 ,
discrepancies to the hanger, and perform whatever 12 analysis he needs to perform.
13 (Indica ting. )
14 With regards to the counting of welds, it cannot be 15 done purely from this document.
16 Q All right, sir.
17 A (WITNESS SHEVLIN) One would need the design documents
, 18 to go with it.
l 19 Then the counting of welds would not be a very 20 difficult task.
21 Q All right, sir.
22 A (WITNESS SHEVLIN) From this document, it's impossible.
23 Q Now, can we agree, Mr. Sh evlin, that what you have 24 denominated as the section views of the Details AA, BB, l
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1 CC and DD, do not reflect all of the details where there 2 are indicated discrepant welds on the first sheet on the
- 3 elevation view.
4 A (WITNESS SHE7LIN) That's true. They supplement the 5 first sheet.
6 Q All right.
7 There are other discrepant connections that are not J
8 shown in detail by the attached section views?
9 A (WITNESS SHE7LIN) No, sir. All discrepant welds on 10- this support should be shown somewhere in the attachment
/~'s
'() 11 to the observation, e
12 (Indica ting . )
13 0 Well, maybe I'm just not following you.
14 I see six details shown on the attached two pages 15 to the elevation drawing that shows the whole hanger.
16 Can we agree that there are more than six 17 connections on that?
18 A (WITNESS SHE7LIN) Sir, you see six section views on 19 Pages 2 and 3.
20 Q Yes.
21 A (WITNESS SHE7LIN) You also see, on Page 1, f ur ther
- 22 identified discrepancies. These are not repeated on 23 Pages 2 and 3.
{
j 24 Q I see. Thank you.
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13628 1 JUDGE GROSSMAN: When you say " supplemental,"
2 2 and 3 are additional?
3 A (WITNESS SHEVLIN) Yes, sir, they expand upon the 4 information shown on the first page, simply because 5 there wasn't enough room on the piece of paper to 6 present all the information that the inspector wanted to 7 present.
8 MR. GUILD: Understood.
9 BY MR. GUILD:
10 0 So if one identified all of the discrepant weld
( 11 conditions, one would have to consider taking together 12 all three of the sketchs? -
13 A (WITNESS SHEVLIN) Tha t's correct.
14 Q Now, can we agree, gentlemen, that the Observation 04 15 nowhere specifies the number of discrepant welds by a 16 numerical count? There's simply the sketchs shown?
17 A (NITNESS SHEVLIN) Sir, it's specified by the f act that 18 they are all pictorially represented and described.
19 0 Well, si r, tha t may be.
20 But the answer to my question is there is no 21 numerical count reflected in the description of the 22 discrepancy of the number of discrepant welds?
23 A (WITNESS SH EVLIN) Nor was there any requirement for
(}
24 there to be.
Sonntaq Reporting Service, Ltd.
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w 13629 1 Q Understood.
2 The description of the discrepancy appears at Page 3 2 of 3 of the observation record, does it not, under the 4 evaluation section, quote, " Welds are undersized, 5 underlength and undercut at Unistrut" ?
6 On that basis, it's a valid observation? That's 7 the only narrative description of the nature of the 8 discrepant conditions aside from what's depicted in the 9 sketchs?
10 A (WITNESS SHEVLIN) No, sir, that's accurate, d ) 11 Q There was no requirement under the CSR element that the 12 CSR inspector count the discrepant welds and describe 13 the number of discrepant welds in a narrative in the 14 observation record?
15 A (WITNESS SHEVLIN) Not in narrative form, no, sir. l 16 The requirement was they -- all the inf ormation i
17 needed by any or all of the associated engineers -- and I 1
18 that includes the Sargent & Lundy people who ultimately I l
19 did the counting -- all this information must be 20 presented in the observation record.
21 Q All right, si r.
22 But in order to know how many welds there are, you 23 have to go beyond the observation record to the design 24 documents?
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1 A (WITNESS SHE7LIN) That is correct, sir.
2 Q Now, this particular Observation CPH 104-4, was it 3 r eviewed for completeness, clarity and accuracy; anybody 4 on the panel?
5 A (WITHESS SHE7LIN) Yes, sir, it was.
6 0 All right, sir.
7 And was it approved for that purpose? Was it 8 proved for completeness, clarity and accuracy ?,
9 A (WITNESS SHE7LIN) Yes, sir, it was.
10 Q Okay. ,
() 11 And who made that approval, sir?
12 'A (WITNESS SHE7LIN) Howard M. Seigers.
13 Q Is that indicated in Box 14?
14 A (WITNESS SHE7LIN) Yes, sir.
15 Q Okay.
16 The observation was reviewed for validity, and it 17 was determined to be valid, was it not?
18 A (WITNESS SHE7LIN) Ye's, sir.
19 Q By Mr. Pa tel ?
20 A (WITNESS SHE7LIN) It was evaluated by Mr. Patel and 21 approved by Mr. Thompson.
22 Q Who is Mr. Thompson; anybody ?
23 Dr. Kau sh al ?
{}
24 A (WITNESS SHE7LIN) I think Dr. Kaushal can answer. i l
Sonntag Repor ting Se rvice, Ltd. l Geneva, Illinois 60134 '
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1 A (WITNESS KAUSHAL) I believe he was assistant j 2 supervisor for CSR.
3 Q All right, sir.
4 A (WITNESS KAUSHAL) I am not fully recalling that right 5 now, Mr. Guild, but that's my recollection.
6 Q All right.
7 Now, the second -- the next page of the record, 8 Page 3 of 3, reflects Sargent & Lundy's evaluation of 4
9 the discrepancy, does it not?
10 A (WITNESS SHEVLIN) Yes, sir, 11 Q All right.
12 We'll speak to Sargent & Lundy about what they did 13 on this one.
14 But it is the Box 25 that Sargent & Lundy 15 completed, and the BCAP Task Force review of Sargent &
16 Lundy's evaluation is contained in Box 29; correct?
17 A (WITNESS KAUSHAL) Excuse me, Mr. G uild. I had to give 18 my document to Mr. Shevlin --
19 Q Sure.
20 A (WITNESS KAUSHAL) -- and I wasn' t quite following.
21 Your question is on Part 4 now?
22 Q Yes, sir. -
23 Box 25 is the Sargent & Lundy evaluation, Box 29 is 24 the BCAP Task Force review of that evaluation.
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13632 As 1 A (WITNESS KAUSHAL) That is correct.
2 Q All right, sir.
3 And the Sargent & Lundy evaluation was an 4 evaluation of the discrepancy for significance?
5 A (WITNESS KAUSHAL) Design significance.
6 0 All right, sir.
7 They concluded, on the basis of their evaluation, 8 that the item was not design significant as that term is 9 used in the BCAP program?
10 A (WITNESS KAUSH AL) Tha t's correct.
/'T
'(,) 11 ,
Q And you, the BCAP Task Force, accepted that evaluation? ,
12 A (WITNESS KAUSHAL) That's correct.
13 0 All right, sir.
14 Now, who did that evaluation of that review --
15 e xcus e m e -- th e r evi ew of th e S & L ev al ua tio n f or th e 16 BCAP Task Force?
17 A (WITNESS KAUSHAL) It would normally be done by the 18 BCAP engineers.
19 I don' t recall whose initials those are at the end 20 of that evaluation; but the evaluation would be done by 21 the appropriate engineering staff.
22 0 W ell, tha t's not Mr. Pa tel ?
23 A (WITNESS KAUSH AL) That one is not Mr. Davey Patel that 24 I talked to you the other day about.
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V 1 Those initials do not look like Mr. Davey Patel's.
2 JUDG E G ROSSMAN : Weren' t there two Patels we 3 hea r'd ?
4 A (WITNESS KAUSHAL) Oh, excuse me.
5 It does say, " Reviewed by Davey Patel. "
6 BY MR. GUILD:
7 0 Under Box 30?
8 A (WITNESS KAUSBAL) Under Box 30.
9 Q Wouldn't that signify that Mr. Patel was the Box 29 10 reviewer ?
( 11 A (WITNESS KAUSH AL) That would be -- that would signify 12 tha t, yes.
13 Q All right, sir.
14 And then Box 31 -- what's the significance of the 15 Box 31 signature, Dr. Kaushal?
16 A (WITNESS KAUSH AL) I believe the Box 31 -- I'll have to 17 look a t th e B CAP-06, Mr. G uild.
18 I don't really recall what specific step was 19 involved in signing the Box 31.
20 0 All right.
21 A (WITNESS KAUSH AL) It may very well be the final review 22 by the CSR supervisor.
{} 23 24 0 Can others on the panel respond?
Wha t was th e Box 31 r eview f or ?
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13634 V(~\
1 A (WITNESS SHEVLIN) I have no idea.
2 Q Mr. Shevlin, you don' t know ?
3 A (WITNESS SHEVLIN) This form is well past my involvement 4 with an observation.
5 Q All right, sir.
6 Mr. Smith? Mr. Smith, do you know the answer?
7 A (WITNESS SMITH) You are just asking what does that 8 signature signify?
9 Q Yes, sir, what does that signature in Box 31 signify?
10 A (WITNESS SMITH) Basically final acceptance by BCAP of S
/"')
(m/ 11 and L's disposition -- or design significance 12 evalua tion.
13 0 All righ t, sir.
14 And can you tell who performed it in this case?
15 A (WITNESS SMITH) Was that Willoughby?
16 A (WITNESS KAUSHAL) Yes. ,
17 Q What position -- Mr. Willoughby?
18 A (WITNESS SMITH) Mr. Willoughby.
19 0 What position does Mr. Willoughby hold?
20 A (WITNESS KAUSH AL) Mr. Willoughby -- are you asking --
21 Q Anybody on the panel.
22 Dr. Kaushal would be fine, if you can answer.
23 A (WITNESS KAUSH AL) Mr. Willoughby a t that time, I
)
24 believe, was CSR supervisor.
Sonntaq Reporting Service, Ltd.
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1 Q All right, si r.
2 Now, the BCAP Task Force review of Sargent &
3 Lundy's evaluation makes a reference to another 4 observation as the basis for accepting this review, and 5 I know -- I don't expect you to know what CPH 150-5 was.
6 Anybody on the panel?
7 A (WITNESS KAUSHAL) 150-5?
8 Q 150-5.
9 Per chance, does anybody know what 150-5 was?
10 A (WITNESS KAUSHAL) No, I would not know.
11 A (WITNESS SHEVLIN) No. ,
12 0 What was the practice for the BCAP Task Force by way of 13 evaluating Sargent & Lundy's evaluation with regard to 14 referencing a previous observation?
15 Why is there a reference to 150-5 for CPH 104-4?
16 A (WITNESS KAUSHAL) Mr. Guild, I'm sur e -- I'm almost 17 positive, if we look at BCAP-06, we would see that the 18 BCAP evaluation of the discrepancy was based --
19 discrepancy evaluation for design significance was of a 20 nature of looking at the general methodology used and 21 the assumptions and criteria employed rather than a 22 detailed run through of the actual count.
() 23 Q All right, sir.
24 A (WITNESS KAUSH AL) That was Sargent & Lundy's role.
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13636 1 So if there was a similar discrepancy or the kind 2 of calculation that applied to this discrepancy, as it 3 was in the previous one, then that's what this kind of 4 comment would imply to me.
5 0 All right, si r.
6 What's the significance of the referenced 7 Observation 150-5 7 Was there a BCAP Task Force 8 detailed review of that evaluation,150-5 7 9 A (WITNESS KAUSHAL) I would have to look at the record 10 on 150-5; but it probably is going back to a certain set
-q
('_/ 11 of discussions that they had on that discrepancy and 12 referring that -- just like in that case, it's okay 13 here.
14 0 Well --
15 A (WITNESS KAUSB AL) That's my expectation; but --
16 Q Is it your expectation -- I'm sorry. I didn't mean to 17 interrupt.
18 A (WITNESS KAUSHAL) -- but I don' t have an exact 19 recollection of what 150-5 was.
l 20 Q All right.
l 21 Would there have been a detailed task force l
22 evaluation of any of the Sargent & Lundy calculations 23 for purposes of reviewing Sargent & Lundy's design
! 24 significance evaluation?
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V 1 A (WITNESS KAUSHAL) The only review was of the nature 2 that I indicated to you.
3 If you consider that detailed, then it was 4 detailed. If you don't, then it wasn' t.
5 Q Well, you didn't consider it detailed?
6 A (WITNESS KAUSHAL) In that view, that would not be a 7 detailed review of the count, yes.
8 Q All right, sir.
9 And would it be appropriate for -- is it consistent 10 with your understanding, Dr. Kaushal, of the way the
()
11 task force reviewed the Sargent & Lundy evaluations, 12 tha t 15 0-5, the referenced observations, would also not 13 reflect the detailed review?-
14 A (WITNESS KAUSHAL) Of the item by item, that's probably 15 correct; although, you know, each engineer decided for 16 himself the depth to which he felt he needed to go to 17 make himself comfortable with that.
18 So to what extent this particular engineer or group 19 of engineers went, I would not know.
20 Q All right, sir.
21 Now, proceeding through the observation package, 22 there is another drawing -- or a drawing that bears the legend "CSR weld map. "
{} 23 24 Do you see that, the next page, sir?
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1 A (WITNESS KAUSHAL) Give me the page stamp number.
2 Q Mine has AR 004672004672
3 A (WITNESS KAUSHAL) All right.
4 Q Is that a weld map there?
5 A (WITNESS KAUSHAL) That's what the piece of paper says, 6 yes. That is weld map.
7 Q Mr. Shevlin, do you agree with that, that's a weld map?
8 A (WITNESS SHE7LIN) It's part of a weld map.
9 Q It's part of a weld map.
10 Where is the rest of the weld map, the succeeding
.- 11 -
pages ?
12 A (WITNESS SHE7LIN) I don't know, sir; but this form is 13 entitled " Weld Map Continua tion. "
14 Q Indeed it is.
15 This was the form in which the document was given 16 to me.
17 What would this -- what would have preceded the 18 continuation for this to represent a complete weld map, 1
19 Mr. Shevlin?
20 A (WITNESS SHE7LIN) The second -- the second -- the next 21 f ollowing page.
22 Q Okay.
23 4673 at the bottom?
[}
24 A (NITNCSS SH E7LIN) Yes, tha t's th e -- tha t's generally Sonntaq Reporting Service, Ltd.
Geneva, Illinois 60134 CiULM RRhldK9
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1 a -- tha t's the first page of the weld map.
2 Q That should be the first page?
3 A (WITNESS SHE7LIN) Yes.
4 Q All right, sir.
5 A (WITNESS SHE7LIN) And the first page, numbered 4672, 6 is the second panel.
7 Okay. \*
0 8 How about 4674?
9 A (WITNESS SHE7LIN) That indicates that this weld map was 10 later supplemented by a Level III Welding Inspector; in
() 11 all probability, at the Sargent & Lundy's request for 12 additional information.
13 0 Okay.
14 How can you tell from that 4674 that it represer.ts 15 a Level III supplement?
j 16 A (WITNESS SHE7LIN) Because I caused him to be certified 17 to a Level III.
18 0 So you know the identity of the gentleman; you know he's
, 19 a Level III rank?
20 A (WITNESS SHE7LIN) Absolutely, yes.
21 Q I'm not questioning you on that score, si r.
22 Nothing f rom the page indicates a Level III review.
23 You just happen to know that that gentleman is a Level 24 III?
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O 1 A (WITNESS SHEVLIN) Right.
2 It wasn' t required that he be a Level III.
3 0 Understood.
4 All right, sir.
5 Now, looking at 4672, the elevation view of the 6 hanger -- that is an elevation view, is it not?
7 A (WITNESS SHEVLIN) Yes, sir.
8 Q All right. .
9 Now, that, in fact, is the identical drawing to the 10 sketch that was the first attachment page to' the
( 11 Observation 04, was it not?
12 A (WITNESS SHEVLIN) Without a detailed study, it appears 13 to be, yes, sir.
14 Q Well, compare that to Bates No. 4667.
15 And doesn' t it immediately -- isn' t it immediately 16 clear it's the same drawing?
17 A (WITNESS SHEVLIN) There's a possibility of some minor 18 variances in there, but probably -- it's probably a 19 copy.
20 0 All right, si r .
21 A (WITNESS SHEVLIN) Probably Xeroxed.
22 !!R. STEPTOE: Can I ask the witness to study 23 it, pl ease.
24 MR. GUILD: I'd be happy if he would; and I Sonntaq Repor ting Service, Ltd.
Geneva, Illinois 60134 Citstm th/aac _ _ ,_. __._.___n--- _ _ _ _ _
13641 1 don't know the anser to the question, so I'm asking.
2 If there are differences --
3 MR. STEPTOE: There appear to be obvious 4 differences to me, so that's why I asked the question.
5 MR. GUILD: All right.
6 JUDGE GROSSMAN: Well --
7 MR. STEPTOE: And I don't know whether this 8 is significant or not.
9 We just have an answer --
1C JUDG E G ROSSMAN: Well, I don' t see what's 11 objectionable about the witness confirming that these 12 are identical drawings. ,
13 JUDGE COLE: Yes. There seems to be a lot 14 more detail on what's identified as the weld map, for 15 e xam ple, than in the cable pan trays themselves.
16 There's a lot of additional detail.
17 Do you see that, sir?
18 JUDG E GROSSMAN: Well, why don't we all agree 19 it .seems as though everything that's included on AR 20 004674, except for that number, is also included on AR 21 004672, but there are additional items shown on that 22 - latter page; is that correct?
i 23 A (WITt1ESS SHE7LIN) Judge Grossman, that would not be
[}
24 uncommon or unexpected.
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- f'\V 1 BY MR. GUILD:
2 Q But that is correct, is it not, that they took the 3 original sketch and added some detail to it to make it 4 the weld map?
5 JUDGE GROSSMAN: Was that basically it?
6 A (WITNESS SHEVLIN) Yes, that's basically correct.
7 BY MR. GUILD:
8 Q All right, si r.
9 Can you characteri=e, Mr. Shevlin, the nature of 10 the detail that was added to the sketch to make it the
( 11 weld map?
12 A (WITNESS SHE7LIN) With some study.
13 As a general rule, we might add information about 14 good welds.
15 The obj ect of the one report is to report a 16 discrepancy in sufficient detail that the CSR engineer 17 had the full understanding of what the problem is.
18 The object of the weld map is to furnish that i
19 detail and any other desired or requested detail to the 20 Sargent & Lundy engineer.
21 It's not unexpected that a weld map will be, in 22 some cases, significantly more detailed than the 23 observation.
24 Q All righ t, sir.
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1 A (WITNESS SHEVLIN) In other cases, they would be 2 identical.
3 0 Mr. Shevlin, would you take a moment, please, sir, or 4 whatever -time is required, and review the weld map, 5 please, sir, and describe for me generally the character 6 of the detail that was added.
i 7 A (WITNESS SHEVLIN) You want a detailed description of 8 every dif ference on these forms?'
a 9 Q No, sir.
10 Can you characterize wha,t the nature is of the -
() 11 detail that was added to the weld map?
12 What are~ the types of details that are shown on the 13 weld map that are not on the original sketch?
14 A (WITNESS SHEVLIN) An example would be in the upper 15 lef t-hand connection, weld symbols, showing both the 16 size and the length' of the weld on two opposite sides of 17 the piece were added on the weld map. They were not put 18 on the observation.
19 Q That's on the diagonal brace there?
20 A (WITNESS SHEVLIN) Yes, under where the -- under where 21 the cut lines for Section C are shown.
i 22 0 Yes, sir.
23 What's the nature of the detail that appears on the
(
24 horizontal members of the hanger on the weld map?
l Sonntag Reporting Service, Ltd.
Geneva, Illinoin 60134 use st%Ava e
13644 1 A (WITNESS SHEVLIN) He, again, added weld symbols.
2 Q Does it show the size of those welds?
3 A (WITNESS SHEVLIN) Yes.
I 4 Apparently.what he's doing here is picking up on 5 good welds and adding it to the weld map for the benefit 6 of the engineer who has to do the calculations.
7 Q All right, si r.
8 Not all the good welds, but just the good welds and 9 on selected connections where there had been discrepant i 10 welds?
I) 11 A (WITNESS SHEVLIN) I couldn't answer that without seeing 12 the design drawings, sir, i
13 0 Okay.
14 You can't tell whether they are all the good welds 15 or not?
16 A (WITNESS SHEVLIN) No, I can't.
17 Q All right, si r.
18 Now, let's turn further through the document, if 19 you would, please.
i
- 20 Af ter the final page of weld map, there is an L. K.
21 Comstock -- a series of L. K. Comstock and PTL 22 docum ents. -
23 Do you see a 2/8/82 transmittal form from Comstock 24 to PTL7 Sonntaq Reporting Service, Ltd.
Geneva, Illinois 60134 UULU 9Lt % f6LE49
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(
l A (WITNESS SHEVLIN) Yes.
2 Q Okay.
3 Reflecting 152 welds, 35 hangers; correct?
4 A (WITNESS KAUSHAL) Yes.
5 Q Done by four different welders?
6 A (WITNESS KAUSHAL) Tha t's correct.
7 Q And this transmits a Form 19 Comstock weld inspection 8 checklist that bears Mr. Rick Martin's signature with a 9 date of February 8, 19827 10 A (WITNESS KAUSHAL) That is correct.
11 Q Now, Mr. Martin's Form 19 uses a grid reference, does it .
12 not, to indicate the components' location?
13 A (WITNESS KAUSHAL) I believe it does, yes.
14 0 112 to 113 0 to -- I'm not sure that's S7 or -- do you 15 see the grid reference, Dr. Kaushal?
16 A (WITNESS KAUSHAL) That is a grid reference, yes.
17 Q All right, sir.
18 How do you know that the hanger that .is the subj ect 19 of the CSR Observation 104-4 is contained -- was the 20 subj ect of Mr. Martin's weld inspection?
21 A (WITNESS KAUSH AL) The hanger numbers are identified in 22 that previous transmittal letter that you just 23 indi ca ted.
(])
24 Q All righ t, sir.
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- 1 They are not identified on the Comstock Form 19 2 Weld Inspection Report, are they?
3 A (WITNESS KAUSHAL) No; not on the -- not on the Form 4 19, no.
5 0 All right, sir.
6 A (WITNESS KAUSHAL) I don't see it.
7 Q Did --
8 A (WITNESS KAUSHAL) This letter is attached to that form.
9 Tha t's the way it's h eld.
10 0 And it's the PTL transmittal letter that you relied on 11 and not the inspection checklist in this case to 12 determine that this inspection by Mr. Martin included 13 the hanger that was the subject of the CSR sampling?
. 14 A (WITNESS SHEVLIN) The transmittal is filed with the 15 other inspection reports, and it also lists the hanger 16 n um be rs.
17 A (WITNESS KAUSHAL) Excuse me. I don' t want to butt in.
18 Who are you directing your questions to?
19 0 Anybody on the panel.
20 Dr. Kaushal, I believe you are the one who sponsors 21 the testimony about how the CSR results were apportioned 22 to or associated with Comstock inspectors.
{) 23 24 A (WITNESS KAUSH AL)
Comstock to PTL --
This letter of transmittal is from Sonntaq Recortina Service, Ltd.
Geneva, Illinois 60134 CiULU n %ft9/G
13647 1 Q Yes.
2 A (WITNESS KAUSH AL) -- and it lists the hangers.
3 Q It's the PTL transmittal that you rely on to associate 4 Mr. Martin's inspection with the CSR Observation CPH 5 1047 6 A (WITNESS KAUSHAL) When you say "PTL transmittal," you 7 mean transmittal to PTL --
8 Q Yes, sir.
9 A (WITNESS KAUSHAL) -- or transmittal from PTL7 10 Q It's the document AR 00089 that you rely on to connect 11 Mr. Martin to the CSR --
12 A That's correct.
13 0 -- item?
14 A (WITNESS KAUSH AL) And it's the transmittal from 15 Comstock to PTL.
16 0 All right, sir ,
17 Now, which hanger was tne subject of the CSR 18 obse rva tion ?
19 A (WITNESS KAUSHAL) That will be indicated on the 20 package number, and I'm not sure I can tell you that at 21 this time.
22 0 Well, sir, I'm looking at the description of the
{} 23 24 obse rva tion, Cable Pan Hanger B-002-1-3052, Is that not the hanger that's the subj ect of the Sonntaq Reporting Se rvi ce, Ltd.
Geneva, Illinois 60134 CR5LB 915&a9m
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1 CSR observation?
2 MR. STEPTOE: What document are you reading
^
3 from, counsel?
4 MR. GUILD: The observation record.
5 MR. STEPTOE: Which one?
6 I mean, 104?
7 MR. GUILD: I'm reading from -- 104-01 just 8 heppens to be at the top of the stack.
9 It should all be the same component, I take it.
10 MR. STEPTOE : Should be.
11 A (WITNESS KAUSB AL) Is the same item number shown on --
12 it says H02-1-3052, 13 BY MR. GUILD:
14 0 All right.
15 Now, what is the hanger number? Is that whole 16 number the hanger number?
17 A (WITNESS KAUSHAL) At this time I cannot recall what -
18 the correlation between that number and the hanger 19 number identified here on this transmittal is, Mr.
- 20 G uild.
21 0 Can you tell me which one of the hangers shown on the 22 PTL transmittal letter is the hanger that's the subject 23 of the CSR observation?
24 A (WITNESS KAUSHAL) A couple of these ones are Sonntag Reporting Service, Ltd.
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v 1 overwritten. I cannot read them.
2 Q Is it any of the ones that are not obliterated?
3 I'm looking at the same copy that you got, Dr.
4 Ka ush al, and mine apparently -- it apparently had a 5 highlighter on it at one time. It's obliterated one of 6 the hanger numbers.
7 Is it any of the other hanger numbers?
8 A (WITNESS KAUSHAL) Mr. Guild, I don' t recall that right 9 now.
10 Q Mr. Shevlin, can you tell which hanger it is?
() 11 A (WITNESS SHEVLIN) I think Mr. Wozniak would be the best 12 one to answer that, sir.
13 0 All right.
14 Mr. Wozniak, if you would help.
15 A (WITNESS WOZNIAK) It's my understanding that part of L.
16 K. Comstock's document review program ascigt.ed this 17 little stamp on the bottom right-hand corner of the 18 Pittsburgh Testing Laboratory transmittal form, a.7d if 19 you will read that, it says, "QC Tracking Form ID is 20 H2," meaning Hanger 2, "on drawing 20E-1-3052H."
21 Q All right, sir.
22 And is that the reference you rely on to track --
23 to tie Mr. Martin's Form 19 checklist to this CSR cable
)
24 pan hanger item?
Sonntaq Reporting Service, Ltd, L Geneva, Illinois 60134 i CiUUU ti& A2A2
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1 A (WITNESS WOZNIAK) As per r eview of this . co py, yes.
2 Like you had indicated, a lot of times a 3 highlighter would not show up on a oopy, but on the 4 original documentation, quite possibly underneath that 5 what appears to be the obliterated entry there is, in 6 fact, the H2 designator.
7 Q All right, si r.
8 So do I understand correctly, then, that whoever 9 did the data evaluation and compilation, for purposes of 10 Dr. Kaushal's Attachment 4, relied on the L. K. Comstock
() 11 document review for this particular package where the 12 Comstock document review stamped the information that 13 appears on the lower right-hand corner of the PTL 14 transmittal letter indicating Hanger H2 for that 15 drawing ?
16 A (WITNESS WOZ NIAK) I would say that the QC tracking 17 stamp that is on the right-hand side of the document 18 there enhances any other inf ormation that might be so 19 listed; but, yes, that would be a method -- that would 20 be the identification of this document.
21 Q Well, assuming that the person who did the data 22 compilation f or Dr. Kaushal's Attachment 4 had the same 23 document that we have before us with an obliterated 24 entry, the only connection between the PTL transmittal Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 LUUU R%L9t-51M9
13651 13 V
1 form and the hanger in question is the H2 reference on 2 the Comstock document review stamp?
3 A (WITNESS WOZNIAK) That would be a correct assumption, 4 yes.
5 Q Now, which 152 welds did Mr. Martin inspect in that grid 6 r eferen ce ?
7 A (WITNESS WOZ NIAK) Well, sir, one must take a look at 8 the hanger installation report that is also attached as 9 part of this document. It bears a document stamp of 10 3993.
) 11 0 Okay. -
12 Several pages following the package ?
13 A (WITNESS WOZNIAK) Yes, sir.
14 Q Okay.
15 A (WITNESS WOZ NIAK) Whereby on the Drawing Number 16 1-3 0-52H, Hanger No. H02, the foreman signifies that the 17 hanger was completed installed.
18 That form is a production form that, you know, is 19 presented -- in other words, a notification form 20 inspection --
21 Q All right.
22 A (WITNESS WOZ NIAK) -- and that the hanger itself would 23 be totally installed as per the Rev drawings referenced 24 on the hanger installation report and that he inspected Sonntaq Reporting Service, Ltd.
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1 the welds as requested. ,
2 0 Who inspected the welds as requested?
3 A (WITNESS WOZNIAK) Well, it appears Mr. -Martin on the 4 referenced document of 2/8/82. -
5 Q What's the 2/8/82 reference to?
6 A (WITNESS WOZ NIAK) Well, that's the date at the top of 7 the PTL transmittal form.
8 Q Yes, sir.
9 But how does that correlate with the hanger 10 installation, if that's your point?
() 11 A (WITNESS WOZ NIAK) Well the hanger installation record 12 has got a foreman's signature date of April 15, 1981.
13 Okay?
14 0 Yes, sir.
15 A (WITNESS WOZ NIAK) I notice also farther in this package 16 that there's an inspection record dated May 15, '81 --
17 Q Yes, sir.
18 A (WITNESS WOZ NIAK) -- by Mr. DeWald.
19 Q That's another Form 19 we',re going to get to in a 20 moment, but --
21 A (WITNESS WOZ NIAK) Well, it would appear that Mr. DeWald 22 inspected prior to Mr. Mar tin.
23 Q Sure.
24 The f orm is dated 5/15/81, Mr. DeWald's?
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1 A (WITNESS WOZNIAK) And the hanger installation report is 2 dated a month prior to that, the one that is attached in 3 the package to Mr. -- or the way it's attached now would 4 be behind Mr. Martin's inspection record.
5 Q All right.
6 A (WITNESS WOZ NIAK) You must understand that, you know, 7 you can assemble these documents any way you want.
8 For me to sit here on the stand and try to piece 9 this together is not easy, you know.
10 ,Q I agree with that, sir.
() 11 They are assembled in the same form they were 12 presented to me. The Bates numbers are sequential.
13 A (WITNESS WOZNIAK) That may be true.
14 So, then, in front of the inspection record by Mr.
15 DeWald dated May 15, '81, there's a PTL transmittal f orm 16 dated May 15, '81, with a QC tracking stamp on it 17 referencing Hanger 2 on Drawing 1-3052H.
18 Q All right.
19 Now, the date on the transmittal is the date in the 20 upper right-hand corner?
21 A (WITNESS WOZ NIAK) Upper left-hand corner.
22 0 Oh, correct.
23 Also in the upper right-hand corner, S/15/817
)
24 A (WITNESS WOZNI AK) Oh, okay.
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1 l
1 Q Okay.
2 A (WITNESS WOZ NIAK) That, also, I believe, is how they 3 code on the document, the document being the Form 19, as 4 to which inspection record belongs to which PTL 5 tran smitt al.
6 If you will note, the Form 19's carry that same 7 coded number in the upper right-hand corner as does the 8 PTL transmittal form.
9 (Indica ting . )
10 Q All right, sir.
/
(_) 11 So the correlation is made on the basis of the date 12 of the transmittal form?
13 A (WITNESS WOZ NIAK) Uh-huh.
14 Q You have to answer yes or no so that the Court Reporter 15 can take it down.
16 A (WITNESS WOZNIAK) Yes.
17 0 All right, sir.
18 A (WITNESS WOZ NIAK) But, again, in the Comstock vault, 19 these PTL transmittal records are attached to the Form 20 19's with that QC tracking record on it; and also a 21 further means would be to use that request number, which 22 is, in fact, a date -- ,
23 (Indi ca ting . )
)
24 Q All right, sir.
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4 1 A (WITNESS WOZNIAK) -- in the upper right-hand corner, j 2 Q A QC tracking record is simply a rubber stamp that's put 3 on a Xerox copy of the original checklist when the t
4 Comstock document people attempted to assemble document 5 packages for each hanger where the original inspections y 6 had been on the basis of grid or multiple hangers?
- 7 A (WITNESS WOZNIAK) Okay.
i 8 Q. Do you agree with that, sir? -
9 A (WITNESS WOGNIAK) I was not involved intimately in 1
10 their document preview program, but that sounds like; a
() 11 logical explanation.
12 0 All right, sir.
l 13 You are being helpf ul, Mr. Wozniak.
14 What is your involvement with the data compilation, j 15 if any, that you are going through here?
l 16 A (WITNESS WOZ NIAK) The data compilation?
17 Q Yes.
! 18 The data compilation, the effort to associate CSR 19 data with Comstock inspections.
20 Have you had any involvement in this task?
21 A (WITNESS WOZNIAK) Well, as Dr. Kaushal, I believe, 22 wrote in some of his revised testimony, at his request I 23 had done some tasks for him, but I was not involved in
)
j 24 the total data compilation as per se. You know, I did Sonntag Repor ting Se rvice, Ltd.
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13656 1 not formulate all the data that we're using as the 2 Kaushal Attachment 4.
3 Q All right, sir.
! 4 You didn' t do the data compilation, but you had 5 some handling of the documents, I take it, involved in 6 reviewing that compilation?
7 A (WITNESS WOGNIAK) Yes; just recently, yes.
8 Q All right, sir.
9 Now, again, which welds did Mr. Martin inspect?
10 What are the -- what are the 152 welds that Mr. Martin
( 11 inspected? -
12 A (WITNESS WOZ NIAK) As I've said, on the hanger 13 installation record that would have been submitted for 14 his inspection, he would have inspected the welds th t i
15 were installed. Okay.
4 16 One has to assume, from this document, that he 17 inspected all the welds that were required by the rev of 18 tht drawing referenced on the hanger installation 19 record.
20 0 All right, sir.
21 The CSR item has 128 welds according to Dr.
22 Kaushal's Attachment 4.
{} 23 A (WITNESS WOZ NIAK) Okay.
24 Q And you assume that Mr. Martin inspected all of those Sonntaq Reporting Service, Ltd.
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G 1 128 welds ? That's the assumption made by associating 2 the entire results of the CSR Weld inspection with Mr.
3 Martin; correct?
4 A (WITNESS WOZ NIAK) That may be true.
5 I'd like to, at this point in time, point something 6 out.
7 Some of the other proj ects I've been on count welds 8 in a dif ferent manner.
9 Now, Mr. Shevlin might be able to answer this 10 question a little farther with respect to a given 11 structural member that has two weldments on it. Is that 12 one weld or two?
13 Q Sure.
14 A (WITNESS WOZ NIAK) How Comstock counted that as a weld, 15 how BCAP counted it as a weld, I'm not a Welding 16 Inspector on this proj ect.
17 0 I see.
18 Can you clear that up for us, Mr. Shevlin?
19 We've got 128 welds counted on this CSR item. Mr.
20 Martin says he did 152 welds on this grid.
21 How do we know that he inspected the 128 that were 22 on the CSR Capable Pan Hanger 104?
(~T 23 A (WITNESS SH E7LIN) I don't think I can prove that from V
24 the documentation.
Sonntag Reporting Service, Ltd.
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I 13658 i3 NJ 1 Q All right, si r.
2 Dr. Kaushal, do you have anything to add to that, l
3 sir?
4 A (WITNESS KAUSHAL) Mr. Guild, the assumption here is 5 that the 152 welds represent all the welds there were on 6 the hanger. That was a complete inspection.
7 Q All right, sir.
8 That's an assumption -- I'm sorry, sir. Did y.ou 9 complete your answer ?
10 A (WITNESS KAUSHAL) Excuse me.
11 Now, in terms of whether those 152 welds would i
12 correlate with our 128 welds, one would have to figure 13 out how exactly they counted the welds at that time.
14 Sargent & Lundy had a well-defined systematic way 15 of counting the welds so that they will all be 16 consistent.
17 Whether that was exactly identical to the way 18 Comstock counted those 152 welds we have no way of 19 nothing.
20 0 You simply don't know which welds Mr. Martin inspected 21 of the 128 that are shown on your CSR Cable Pan Hanger 22 104?
23 A (WITNESS KAUSHAL) Well, what we do know is that the
{)
24 documentation indicates that the hanger was completely Sonntaa Reporting Service, Ltd.
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1 inspected -- that's what the documentation implies --
2 and 128 is simply our count of what complete inspection 3 is.
4 0 Yes, sir.
5 Could you answer the question more directly.
6 Do you know whether Mr. Martin inspected all 128 7 welds on your CSR item?
8 A (WITNESS KAUSHAL) Mr. Guild, the only way I have to go 9 at it is f rom the documentation.
10 I would not know, no, exactly what he inspected.
() 11 Q All right, sir.
12 Mr. Martin's transmittal to PTL says he inspected 5 13 hangers that contained a total of 152 welds.
14 Your cable pan hanger is one item. It had a 128 15 w elds ?
16 . A (WITNESS KAUSH AL) That is correct.
17 Q If you assume Mr. Martin inspected all your 128, tha t 18 leaves 24 welds that Mr. Martin inspected on the 4 other 19 hangers in toto?
20 A (WITNESS KAUSH AL) And what I indicated to you in my 21 last response is that the consistency in counting the 22 wolds, speaking of Sargent & Lundy and the manner in 23 which Comstock counted at this time, we cannot 24 recreate --
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L) 1 Q All right, sir.
2 A (WITNESS KAUSH AL) --
but our expectation is that that 3 was a complete inspection.
4 Q That's your assumption?
5 A (WITNESS KAUSHAL) Tha t's what the documentation would 6 indicate.
7 Q That's your assumption, is it not, sir?
8 A (WITNESS KAUSHAL) Mr. Guild, that's a fairly firm 9 assumption in the following sense:
10 That's the documentation that exists to imply QC
( 11 ,
acceptance of that particular hanger, so it has to be a 12 complete inspection.
13 0 Well, assuming the accuracy and completeness of the 14 Comstock QC documentation?
15 A (WITNESS KAUSH AL) That's correct.
16 Q All right, si r.
17 Now, let's turn through quickly -- Mr. DeWald, 18 then, is also associated wi.th this CSR item.
19 Mr. DeWald's transmittal form to PTL shows that he 20 inspected 238 welds on that checklist. That appears to 21 be associated with -- I count 19 hangers.
22 Now, do you know whether or not Mr. DeWald's 238
{} 23 24 welds inspected on 19 hangers represents that he incpected the 128 Welds on Cable Pan Hanger 104, Sonntaq Reporting Service, Ltd.
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1 Observation 4?
2 A (WITNESS KAUSB AL) Excuse me. I don' t have the piece 3 of paper.
4 Now, what was the question, Mr. Guild, and what 5- piece of paper are we on?
6 0 Okay.
7 You've got Mr. DeWald's checklist, Form 197 8 A (WITNESS KAUSH AL) Yes, yes.
-9 Q Following the logic that Mr. Wozniak was explaining, 10 we've got a PTL transmittal form that precedes it?
11 A (WITNESS KAUSHAL) Yes.
1:2 0 It shows 238 total welds inspected and I counted 19 -
13 entries of hanger numbers.
14 A (WITNESS KAUSHAL) Yes.
15 Q Now, sir, I want to ask the same question I asked of Mr.
16 Mar tin.
17 Do you know with certainty that Mr. DeWald l
18 inspected the 128 welds on the hanger that is identified 19 as CPH 104?
20 A (WITNESS KAUSHAL) I guecs the answer is the same as 21 before.
22 0 All right, sir.
23 Now, PTL performed a sampling overincpection of Mr.
{}
24 !!ar tin's weld inspection, did they not?
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1 A (WITNESS KAUSH AL) I'm sorry?
2 Q PTL, Pittsburgh Testing Laboratories, performed a sample 3 overinspection of Mr. Martin's quality control 4 inspection?
5 A (WITNESS KAUSHAL) I believe that's correct, yes.
6 Q And that report, the report of that overinspection, is 7 contained in a two-page document reflecting inspection 8 date of 2/25/82; correct?
9 A (WITNESS KAUSHAL) I'm not on that page.
10 What page number is that?
( ll Q Yes. It's AR 00981 and 82.
12 . JUDGE GROSSMAN: I think tha t's 91.
13 MR. GUILD: 91.
14 JUDGE GROSSMAN: 91 and 92.
15 MR. GUILD: 91 and 92, yes.
16 Excuse me, ,
17 A (WITNESS KAUSH AL) 91 and 927 18 MR. GUILD: Yes, sir.
19 A (WITNESS KAUSH AL) Yes, sir.
20 BY MR. GUILD:
21 Q PTL found all of their sampled overinspection --
22 overinspected welds acceptable?
{} 23 24 A (WITNESS KAUSHAL)
All right, si r.
Yes; I see that, yes.
2 Sonntaa Reportina Service, Ltd.
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1 Their sampling inspection of Mr. Martin's cable pan 2 hanger weld ' inspection identified no discrepant 3 inspection items?
4 A (WITNESS KAUSH AL) That's what the paper says, yes.
5 Q Now, let me ask you a general question, Dr. Kaushal.
6 Assuming PTL had identified discrepant items in Mr.
7 Martin's weld inspection, would that item, that cable 8 pan hanger, have been subj ect to the CSR sampling?
9 A (WITNESS KAUSHAL) That -- that depends on what was 10 found.
G
(_) 11 If it was found and found to be wholly deficient, 12 it might have been dropped, but if there was -- might 13 have been. Again, that depends on whether that 14 knowledge is there up front; but if there are one or two 15 welds defective and there is an outstanding NCR on that, 16 that would not preclude that item from being included in 17 the sampling.
18 0 Well, let's be more precise.
19 Of the 128 welds -- assume hypothetically of the 20 128 welds on this particular capable pan hanger, le t's l l
21 say PTL did their 10 percent overinspection and happened 22 to catch 13 wolds, and of the 13, they found 1 23 discrepant weld.
[}
24 Now, assuming those results of the PTL Sonntag Repor ting Service, Ltd.
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1 overinspection, would that hanger, with those welds, 2 have been included in the CSR sampling?
3 A (WITNESS KAUSHAL) That would not be a reason for 4 exclusion that I can think of.
5 0 All right, si r.
6 If an NCR was initiated as a result of finding one 7 discrepant weld on that hanger, would that item have 8 been included in the CSR sampling?
9 A (WITNESS KAUSHAL) Again, I would not consider that an 10 automatic reason for exclusion of the sample.
11 Q How many weld discrepancies would dictate exclusion of 12 the item from the CSR sample?
13 A (WITNESS KAUSHAL) I don' t kn ow tha t. I do n' t r e call.
14 It's a matter of judgment that the numbers applied.
15 I was not personally involved in that.
16 It's a questien of whether the item is 17 substantially complete or the item is not substantially 18 com pl ete.
19 Q All right, sir.
20 Well, what if PTL did an overinspection, found 21 adverse results -- I mean, found discrepant weld 22 conditions that hasn,' t been identified by the Comstock 23 ins pe ctor, but no action was taken; in other words, no u
24 NCR was initiatsd, no additional rework was called f or.
" ~ ~ ~
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13665 1 Would that item then have been included in the CSR 2 sampl e?
3 MR. STEPTOE: I'm sorry.
4 Could I have the question repeated? I lost it.
5 JUDG E GROSSMAN: Sure.
6 (The question was thereupon read by the 7 Repor te r. )
8 MR. STEPTOE: Is there a representation by 9 counsel that that occurred?
10 JUDGE GROSSMAN: Well, it's a hypothe tical.
11 Is there a problem with that hypothetical?
- e 12 MR. STEPTOE: Ass uming tha t -- yes, it 13 assumes that a non-conf orming condition was identified 14 and the appropriate corrective action was not taken.
15 JUDG E GROSSMAN: Are you saying that's an 16 impossibili ty ?
17 MR. STEPTOE: I'm not saying it's impossible, 18 no, of course not; but I'm -- if it's just in a 19 hypothetical -- posed in a hypothetical way, the 20 impression is lef t on the record that it happened all 21 the time, and I don' t know how I can respond to that.
22 JUDGE GROSSMAN: Well, when I said 23 impossibility , is that an extraordinary situation?
{}
24 MR. STEPTOE: I would assume so.
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1 I mean, under Appendix B, if you find a 2 discrepancy, you are supposed to document it.
3 Isn't that what the regular practice is?
4 JUDG E GROSSMAN: Mr. Guild, is there any 5 reason to believe that something like that could happen?
6 MR. GUILD: It probably could happen.
7 It is asked as a hypothetical, Mr. Chairman.
8 What I'm trying to establish is what possible PTL 9 outcomes would influence the inclusion or exclusion of ,
10 an item that was subj ect to a PTL overinspection from 11 -
CSR sample, and I posed a case. It's not a case that I 12 can repsesent occurred. I can' t say that it's not 13 possibir 14 We'll talk about the PTL aspects of this rebuttal 15 case later, and I submit that the possibility will 16 become more evident when we talk about PTL; but for this 17 point, I'm only asking hypothetically, assuming the l
l 18 f acts that I posed, what would be the treatment of the l
l 19 item for CSR sampling purposes.
20 JUDG E GROSSMAN: Well, let me first ask the l 21 witness:
22 In your opinion, could that have occurred?
l
{} 23 A' (win 1ESS KAUSH AL) Mr. Chairman, that will be highly 24 irregular if it did occur. I mean, that's a violation l
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tJ 1 of the very fundamental principle on how things are run.
2 If a non-conforming condition is validly 3 identified, it is absolutely imperative that it be 4 identified, that it be recorded.
5 You know, if, in the course of a regular 6 inspection, a PTL inspector finds something, it really 7 has to be recorded; so I'm kind of at a loss to presume 8 that that would ever happen.
9 Now, obviously, somebody can violate some rules and 10 do it; but I have no reason to believe that that O 11 h appened.
12 MR. GUILD: Mr. Chairman, I don' t mean to 13 represent that it did.
14 We will see an item of non-compliance, though, when 15 we talk about PTL that I will -- my recollection 16 reflects showed a circumstance where deficient welds are 17 identified and PTL -- and Comstock could not document 18 that any corrective action had been taken; that neither 19 an expansion of the sample to include other welds 20 performed by that inspector, given the f act that the 21 rejection rate was above the threshold, nor 22 documentation reflecting that the actual discrepant 23 welds had ever been corrected, existed.
24 How, that was a case that I am recounting on the Sonntaq Reportina Se rvice, Ltd. ---
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13668 1 basis of memory, which may well be faulty, but was an 2 item of non-compliance or was an open or unresolved item 3 identified by the NRC.
4 JUDGE GROSSMAN: Mr. Berry, I seem to have 5 some recollection of something like that, too.
6 MR. BERRY: I believe Mr. Guild's 7 recollection is correct.
8 I believe Mr. Mendez, in Inspection Report 8521, 9 22, documented this very fact.
10 It was either an item of non-compliance or 11 unresolved item; but' the general matter that -- example i 12 that Mr. Guild just alluded to is, to my recollection, 13 pretty accurate.
14 JUDGE GROSSMAN: Okay. We'll allow the 15 question with the understanding that it's just a 16- hypothesis and it's just really designed to determine 17 what the parameters are that the CSR BCAP program would 18 utilize to determine what action would be taken or not 19 taken there.
20 MR. GUILD: Okay.
21 JUDGE GROSSMAN: Maybe you want to repeat the 22 question.
23 MR. GUILD: I' d be happy to.
(
24 SY HR. GUILD:
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13669 lb 1 Q Dr. Kaushal, let's just assume -- and this is just a 2 hypothetical now -- just assume these f acts are true:
3 The PTL overinspection finds these discrepant weld 4 conditions and no action is taken by way of a 5 Non-Conformance Report or an ICR.
6 You get -- you get the package -- strike that.
7 What action, if any, would be taken by way of 8 including or excluding that component that was the 9 subject of the PTL overinspection from the CSR sample?
10 A (WITNESS KAUSH AL) Mr. Guild, if an inspection was 11 performed and BCAP had no knowledge of it via an NCR or 12 anything else, then, obviously, for BCAP that 13 information doesn't exist and cannot be factored in.
l 14 Q All right, sir 1
15 So you wouldn't have included it?
l I
16 A (WITNESS KAUSHAL) That would be the presumption, yes.
17 Q Now, let's take the other case. PTL identifies 18 discrepant weld conditions. They send the hanger back 19 to be reworked.
20 Would the original Comstock inspection of that 21 hanger be included in your CSR results?
22 -
A (PITNESS KAUSH AL) Are we talking about the original 23 CSR results ?
g 24 I'm afraid I'm not sure I --
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E 13670 1 Q We're talking about your Attachment 4 --
2 A (WITNESS KAUSHAL) --
understand.
3 0 -- your Attachment 4 first. -
4 A (WITNESS KAUSH AL) Attachment 47 4
5 Q Yes.
6 A (WITNESS KAUSHAL) If the item -- if the item was 7 identified to be discrepant to the point where it now 8 has to be reworked, then the item is no longer complete 9 and QC accepted.
10 That would be -- Mr. Guild, I -- I don' t know if 11 there is a specific case. No such specific case was 12 brought to my attention.
13 How that was handled in reality, I would not know.
14 (Indicating.)
15 0 Well, isn' t it apparent, though, Dr. Kaushal, if there 16 was a Comstock inspector that did weld inspections on a 17 cable pan hanger, f or example, there was a PTL 18 overinspection, and it found a discrepant weld or more 19 than one discrepant weld, an -NCR was originated for 20 those discrepant welds that called for reworking that 21 hanger, you would have excluded that item from the CSR 22 sample because it had been the subj ect of a rework?
gr 23 MR. STEPTOE: May I -- m ay I ask --
24 JUDG E G ROSSMAN: Excuse me.
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1 Are we talking now about the NCR still being open 2 or the rework having been done?
3 MR. GUILD: That's a good question, Mr.
4 Chairman.
5 JUDG E G ROSSMAN: I thought we had the rules 6 if the NCR is still open, then it would not have been --
7 the. observation would have not been valid, according to 8 what we heard the other day and what we read.
9 MR. GUILD: All right.
10 JUDGE GROSSMAN: If the rework had been done, I
$_/ 11 then the observation would be valid.
12 The question I thought you had originally was what 13 would be done with the original Inspection Report as f ar, 14 as inclusion in Document 4.
15 MR. GUILD: Exactly that is the question, 16 Judge.
17 A (WITNESS KAUSH AL) I'm afraid I'm --
18 JUDGE GROSSMAN: Have you forgotten that 19 question?
20 Assume that there was an NCR and that rework had to 21 be done and rework was done, and there was a second 22 inspection then which accepted that item, pr5 23 When BCAP went back and inspected that item, I 24 would assume certainly the second Inspection Report Sonntag Repor ting Se rvi ce, Ltd.
Geneva, Illinois 60134 GSL%n -
l 13672 1 would be included --
2 A (WITNESS KAUSHAL) Yes, sir.
3 JUDGE GROSSMAN: --
in your observation 4 report or whatever the nomenclature is.
5 Now, the question is:
6 What would be done with the first Inspection 7 Report?
8 A (WITNESS KAUSHAL) Your Honor, in this case, inasmuch
. 9 as the item has been since then reworked, the B CAP 10 reinspections can no. longer be compared to the
\ ,11 inspection that was done prior to the rework, so it 12 would not be appropriate to include it.
13 JUDGE GROSSMAN: Okay. \
14 MR. GUILD: Fine.
15 BY MR. GUILD:
16 Q Do you know in how many cases, Dr. Kaushal, those 17 circumstances occurred?
18 A (WITNESS KAUSH AL) I would not know that, Mr. Guild.
l l
19 MR. GUILD: Mr. Chairman, we're at the 20 quitting time.
21 What I would like to do is have the rest of this 22 document simply identified before we adjourn. -
Amq 23 JUDG E G ROSSMAN: Well, something that puzzles kI '
24 me, because I thought that these two inspections -- oh, Sonntaq Reporting Service, Ltd.
l Geneva, Illinois 60134 LTd15s 91R h td 2 L9
13673 rn
( l uJ l I'm sorry.
2 The document we' re talking about now, Intervenors' 3 155, I take it there was no rework on the original l 4 DeWald inspection, but it was reinspected by Mr. Martin 5 because of -- no, I'm not sure.
6 Now, were there two inspections on this document?
7 A (WITNESS KAUSH AL) Mr. Chairman, I could not give you 8 an answer on that.
9 For the purpose of the data that was compiled, 13 there were two f nspection reports without any indication f) 11 of rework in be, tween, so they were both included in the 12 data base.
13 (Indi ca ting. )
14 The presumption in this case is that for some 15 reason or another, one inspector inspected it and 16 another inspector inspected it, again without really 17 needing to do it. That's the only presumption -- that's 18 the only assumption we could make in this case 19 (Indi ca ting. )
20 JUDGE GROSSMAN: Okay, fine.
21 That's a complete answer.
22 Mr. G uild, now, did you want to of fer Intervenors' g 23 155?
l f- T 24 MR. GUILD: Yes, i
l l
i Sonntaq Recor ting Se rvi ce, Ltd.
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1 Let me just simply get the rest of it identified.
2 There are some extra portions, and I won' t go into 3 details, but I would just like the witnesses to identify 4 for the record what's in the package.
5 BY MR. GUILD:
6 0 If you turn, gentlemen, past Mr. DeWald's Inspection 7 Report, there appears to be a document of two pages from 8 Phillips to DeWald that is --
9 A (WITNESS KAUSH AL) Would you identify the Bates Number, 10 pl ease ?
) 11 Q Yes, sir. It is AR 3996 and 97.
12 A (WITNESS KAUSHAL) Yes.
13 0 It appears to be part of a document review program.
14 A (WITNESS KAUSHAL) I read the letter, yes.
15 0 Okay.
16 Is that what it is? Does it document the review 17 of documents associated with these components ?
18 A (WITNESS KAUSHAL) I believe that's true; but it says, 19 "See attached sheets," and I don't whether the following 20 pages are attachments to that or something else.
21 0 W ell, tha t's correct, it's simply un clea r.
! ,22 The following sheets af ter the two page document 23 r eview results is a QC installation inspection checklist i
24 signed by Mr. Chuck Taylor, December 14, '82.
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1 13675 g
1 Does that relate to the component that's identified 2 as CSR 104 -- CPH 104?
3 A (WITNESS KAUSHAL) That seems to be something else.
4 JUDG E GROSSMAN: We seem to be at an impasse 5 here, Mr. G uild.
6 Do you wish to get this information so you can 7 prepare your testimony for tomorrow --
8 MR. GUILD: Yes, sir, I do.
9 JUDGE GROSSMAN: -- or your examination?
10 MR. GUILD: I'm looking f or an explanation if 11 the witnesses know it.
12 If they don' t, I'll understand..
13 A (WITNESS KAUSH AL) Was there a question still pending?
14 BY MR. GUILD:
15 Q Yes.
16 I was trying to get you to identify what the 17 documents were tha t follow Mr. DeWald's Inspection 18 Report and whether they bear any relation to the CSR 19 sample item.
20 A (WITNESS KAUSH AL) You see, this one here talks about 21 document r eview and then refers to Hangers H110, H107 22 under Item 16, which are not -- which is not the iranger 23 that we've been talking about.
24 MR. GUILD: Mr. Chairman, there may be no Sonntag Recorting Se rvi ce, Ltd.
Geneva, Illinois 60134 rcastsm utst,asvas
4 13676 1 e xplana tio n.
It was simply given to me as a package for 2 104.
3 I don't know whether there is any relationship at 4 all.
5 I'm somewhat in the dark as well and simply trying 6
. to understand.
7 JUDG E G ROSSMAN: Well, no.
8 My question was maybe the panel ought to look at 9
the document overnight so they can tell you what they 10 know about it in the morning, unless you need it in 11 order to prepare your examination.
12 MR. GUILD: Yes, I was hoping to have an-13 explanation so that I could prepare based on that 14 explanation; and it seems to simply be beyond the 15 knowledge of the witnesses.
16 JUDGE GROSSMAN: Okay. So you won't get 17 that, but at least we might get something in the 18 morning, the n.
l 19 MR. GUILD: Yes, sir.
20 JUDGE GROSSMAN: Okay. W hy do n ' t w e, then, i 21 adjourn, and we will show Mr. Miller and Mr. Guild the 22 in-camera document.
l 23 So we'll adjourn until 9:00 o' clock tomorrow 24 morning.
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L Geneva, Illinois 60134 tn 211.- a@jre . - - - --
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I 13676 l L-J l e xplana tion. It was simply given to me as a package for 2 104.
3 I don't know whether there is any relationship at 4 all.
5 I'm somewhat in the dark as well and simply trying 6 to understand.
7 JUDG E G ROSSMAN : Well, no.
8 My question was maybe the panel ought to look at 9 the document overnight so they can tell you what they 10 know about it in the morning, unless you need it in 11 order to prepare your examination.
12 MR. GUILD: Yes, I was hoping to have an 13 explanation so that I could prepare based on that 14 explanation; and it seems to simply be beyond the 15 knowledge of the witnesses.
16 JUDGE GROSSMAN: Okay. So you won't get 17 that, but at least we might get something in the 18 morning, then.
19 MR. G UILD: Yes, sir.
20 JUDGE GROSSMAN: Okay. W hy do n ' t w e, then, 21 adj ourn, and we will show Mr. Miller and Mr. Guild the 22 in-camera document. I r; 23 So we'll adj ourn until 9:00 o' clock tomorrow
('~' )
24 morning.
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_ _ _ __________________________ __1 st1 9 1- asthasse
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1 (WHEREUPON, at 5:10 P. M., the hearing of 2 the above-entitled matter was continued 3 to the 7th day of October, 19 86, a t th e 4 hour of 9:00 o' clock A. M.)
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NO PAGE NUMBER CERTIFICATE OF OFFICIAL REPORTER This is to certify that the attached proceedings before the UNITED ST TES NUCLEAR REGULATORY COteiISSION in the matter of:
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NAME OF PROCEEDING: Braidwood Station Units 1fi 2 1
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DOCKET NO.: 50-456/457-OL PLACE: Chicago, Illinois DATE: Monday, October 6, 1986
. . 1 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) N (TYPED) Nancy /J. Ho%$
Official Reporter Reporter's Affiliation
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