ML20211A207
| ML20211A207 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 10/03/1986 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| CON-#486-1175, CON-#486-1176 OL, NUDOCS 8610150027 | |
| Download: ML20211A207 (100) | |
Text
f ORIGINAL UN11ED STATES O
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: 13454 - 13552 DATE: FRIDAY, OCTOBER 3, 1986 I / /0 I Dl ACE-FEDERAL REPORTERS, INC.
O amav-444 North Capitol Street Washington, D.C. 20001 m,10 5- <o (202)347-3700 F Die A:
I '
NATIONWIDE COVERAGE
_ . . _ _ ~ . . _. . . . . _ . . _ _ _. . . _ _ _ .. . _
13454 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY ' COMMISSION 3 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4
_ _ _ _ _ _ _ ; _ _ _ _ _ ; _ _ _ _x 5 :
In the Matter of: :
6 : Docket No. 50-456 OL
, COMMONWEALTH EDISON COMPANY : 50-457 OL 7 :
(Braidwood Station, Units 1 :
- 8 and 2)
_ _ _ _ _ _ _ _ _ _ _ _ ; _ ; _ _ ;x 9
10 Pages 13454 - 13552 11 United States District Courthouse
() 12 -
Courtroom 1919 219 South Dearborn Street Chicago, Illinois 60604 13 Friday, October 3, 1986.
14 15 The hearing in the above-entitled matter reconvened 16 at 8:05 A. M.
17
- BEFORE
18 JUDGE HERBERT GROSSMAN, Chairman I
19 Atomic Safety and Licensing Board O. S. Nuclear Regulatory Commission 20 Washington, D. C.
21 JUDGE RICHARD F. COLE, Member, Atomic Safety and Licensing Board 22 U. S. Nuclear Regulatory Commission Washington, D. C. ,
23 l
JUDGE A. DIXON CALLIH AN, Member, l 24 Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission 25 Washington, D. C.
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_ _, _.- -_ . _ Genevap., Illinois ___60134
13455 iO 1 APPEARANCES:
2 On behalf of the Applicant:
3 MICHAEL I. MILLER, ESQ.
PHILIP P. STEPTOE, ESQ.
4 Isham, Lincoln & Beale Three First National Plaza 5 Chicago, Illinois 60602 6 On behalf of the Nuclear Regulatory Commission Staff:
7 GREGORY ALAN BERRY, ESQ.
8 ELAINE I. CHAN, ESQ.
U. S. Nuclear Regulatory Commission 9 7335 Old Georgetown Road Bethesda, Maryland 20014 10 On behalf of the Intervenors:
11 ROBERT GUILD, ESQ.
)
13 14 15 16 l 17 h
18 l
l 19 20 21 i 22 23 24 C:)
25 l Sonntaq Reporting Service, Ltd.
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-Q 1 EXHIBIT INDEX Marked Received 2 Intervenors' Exhibit No.147 13486 3 Intervenors' Exhibit No.148 13488 4 Intervenors' Exhibit No. 149 13488 5 Intervenors' Exhibit No. 150 13504 13531 6 Intervenors' Exhibit No.151 13534 13552 7 Intervenors' Exhibit No.152 13539 8
TESTIMONY OF 9
NARINDER NATH KAUSHAL 10 EDWARD M. SH EVLIN JOHN R. WOZNIAK 11 NEIL P. SMITH O 12 CROSS EXAMIN ATION (Continued)
BY MR. GUILD: 13459 13 14 15 16 17 18 19 20 21 22 23 -
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1 JUDGE GROSSMAN: The hearing is reconvened.
2 This is the 68th day of hearing.
3 We ended yesterday with the panel being 4 cross-examined by Mr. Guild.
5 Now, do we have preliminary matters?
6 MR. STEPTOE: Just one preliminary matter, 7 Judge Grossman.
8 I asked yesterday that an old chart which we had 9 been discussing two days ago be marked as Applicant's 10 Exhibit No.127 for identification and travel with the 11 record.
() 12 On second thought, that wasn't such a good idea, 13 and I do not ask that that. document be marked.
14 JUDGE GROSSMAN: Okay, fine.
15 So our ruling yesterday that said that it would 16 travel with the record is withdrawn. It was not 17 admitted into evidence in any event, and we had given 18 that -- what number was that?
19 MR. STEPTOE: 127.
20 JUDGE GROSSMAN: 127, okay.
21 So it's clear in the record now that that document 22 will not travel with the record and is not admitted.
23 Why don' t you continue, Mr. Guild?
MR. GUILD: Mr. Chairman, I anticipate that
{} 24 25 I'm going to return to examining f rom the Intervenors' Sonntaa Reporting Service, Ltd.
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~V 1 Exhibit 146, which was Mr. Gardner's inspection report.
2 I'm happy to go forward; but since Mr. Berry or the 3 Staff are not present, I anticipate that it's an area 4 near and dear to their hearts, and perhaps they would --
5 JUDGE GROSSMAN: Okay. We'll then hold off 6 for a few more minutes until Staff can arrive.
7 . MR. GUILD: Perhaps I could, as a preliminary 8 matter, if it suits the Board, raise a couple points.
9 First, I think yesterday or the day before I 10 received another piece of prefiled rebuttal testimony.
11 I apologize. I can't recall the gentleman's name, but O 12 the --
~
13 MR. MILLER: Mr. Kafcas.
14 MR. GUILD: Kafcas?
15 MR. MILLER: Yes.
16 MR. GUILD: Mr. Kafcas, K-A-F-C or -- in any 17 event, while we're awaiting the document, I've not had 18 the time to do anything more than heft it.
19 I expect there's going to be testimony from yet 20 another rebuttal witness, another expert witness -- Dr.
21 Hulin?
22 MR. MILLER: Dr. Hulin.
23 MR. GUILD: -- Dr. Hulin, an industrial
() 24 organizational psychologist, I'm told. I've yet to see 25 that, either.
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1 I'd just like the record to reflect I only got the 2 other one the day before yesterday and haven't had a 3 chance to review it and would inquire about the expected 4
4 availability of whatever else remains of Applicant's 5 prefiled rebuttal case.
, 6 MR. MILLER: In addition to Dr. Hulin's
! 7 testimony, which I hope will be filed today -- it's been 8 beyond my ability to get into contact with him; he's a 9 professor at the University of Illinois -- there will be 10 rebuttal testimony with Mr. Shamblin, and then rebuttal 11 testimony directed to Mr. Archambeault's testimony.
12 Other than that, my expectation -- other than that, 13 I believe that our rebuttal case is essentially 1
j 14 complete.
l 15 I want to check with some of my colleagues. There 16 may be one or two very small pieces of specific factual 17 rebuttal testimony yet to come, but I can advise Mr.
18 Guild af ter the close of the hearing today as to that.
I 19 JUDGE GROSSMAN: Okay. We'll take a recess 4
20 now -- that was a short recess.
4 21 (Laughter.)
22 You may continue, Mr. Guild.
23 MR. GUILD: Thank you, Mr. Chairman. ,
24 Good morning, gentlemen.
- 25 CROSS EXAMINATION Sonntaa' Reporting Service, Ltd.
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1 (Continued) 2 BY MR. GUILD:
3 Q Dr. Kaushal, let me direct some further examination to 4 you, sir.
5 If I could ask you to turn to Intervenors' Exhibit 6 146 -- again, that's Mr. Gardner's Inspection Report 7 8502, bearing a date of February 12, 1985 -- we spoke 8 yesterday about the findings of Mr. Gardner with respect 9 - to problems with the CSR inspection activities, the 10 problems that led to his meeting with you on the 23rd of 11 January and your suspension of those inspection
-()
12 activities and the conduct of the midpoint look.
13 8502, Inspection Report 8502, also raises the 14 question of the adequacy of the CSR checklists that were 15 being employed in the conduct of the CSR reinspection 16 activities.
17 I direct your attention to the third page of the 18 document, Item No. 3.
19 Do you have that before you, sir?
, l 20 A (WITNESS KAUSHAL) Item No. 37 21 Q Yes.
22 A (WITNESS KAUSHAL) Yes.
23 MR. STEPTOE: I object to the relevance of
{} 24 this line of inquiry, Judge Grossman.
I'm sorry?
25 JUDGE GROSSMAN:
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1 MR. STEPTOE: I object to this line of 2 inquiry.
3 Perhaps my objection is premature, but this doesn't 4 seem to have anything -to do with the electrical work.
5 MR. BERRY: What is the exhibit number?
6 MR. GUILD: Mr. Gardner's Inspection Report 7 8502.
8 There is no pending question, Mr. Chairman.
9 JUDGE GROSSMAN: Okay. I think Mr. Steptoe 10 is alerting us to possible future problems.
11 MR. GUILD: May I proceed?
'( ) 12 JUDGE GROSSMAN: - Certainly.
13 BY MR. GUILD: ,
14 Q Do you have it referenced, Dr. Kaushal?
15 A (WITNESS KAUSHAL) I have looked -- I have read 16 Paragraph 3 -- or Item 3.
17 O All right, sir.
18 Now, the pertinent language -- indeed, as 19 apparently Mr. Steptoe is concerned, the issue 20 specifically relates to a checklist not in the 21 electrical area but in the concrete area.
22 But what I want to direct your attention to is a 23 more general statement that appears in that portion of 24 the inspection report.
[}
25 I quote: "The licensee indicated that the Sonntag Reporting Service, Ltd.
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13462 1 checklist was only meant to address major design 2 deficiencies and not individual discrepancies."
3 Then it goes further: "In order for a concrete 4 reinspection program to adequately reflect the quality 5 of concrete, it should include clearly definitive 6 accept-reject criteria for all concrete attributes."
7 Now , sir, do I understand that as a result of that 8 finding, which led to a -- led to the identification of 9 an open item -- that is noted on the next page, 8502-05.
10 A (WITNESS KAUSHAL) I'm sorry. The next page, Page 4 of 11 that?
() 12 O Yes, sir, Page 4.
I see an open item there with respect 13 to the issue of the adequacy of the checklists.
14 Now, I understand that Mr. Gardner's concerns about 15 the adequacy of the checklist prompted a review of the 16 checklists in the concrete area to determine whether or 17 not, as the NRC inspector observed, all of the 18 appropriate attributes were being inspected to under the 19 CSR element.
20 Is that a correct understanding, sir?
21 A (WITNESS KAUSHAL) Are we talking about the concrete 22 checklist now?
23 0 I'm sorry?
24 A (WITNESS KAUSH AL) Are we checking about the checklist
[}
25 for concrete placement?
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13463 ft 1 Q Yes, sir, that you initiated or, in a review of the 2 adequacy of the checklist for concrete, was initiated as 3 a result of the NRC inspector making the observation 4 that I just read to you.
5 That is, that the checklist was only meant to 6 address major design deficiencies, not individual 7 discrepancies, and that in the NRC inspector's view, 8 such a checklist should clearly - "should include 9 clearly definitive accept-reject criteria for. all
! 10 attributes"?
11 A (WITN ESS . KAUSH AL) The characterization here about what
'( 12 the checklist addresses or does not address is not -- is 13 not my understanding of what we reviewed the checklist 14 for.
15 As I have indicated before in response to your 16 questions and otherwise in the testimony, the checklists 17 were designed and included all attributes that had 18 potential for design significance.
19 That's the way all checklists were designed, and 20 that is true of the concrete checklist, also.
, 21 There were discussions with regard to specific 22 attributes in the concrete checklist that were not 23 believed to be -- believed to have potential for design 24 significance.
l (])
25 However, based on that particular inspection and Sonntaa Reportino Service, Ltd.
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13464 1 the concerns expressed by the inspector on the concrete 2 checklist, we did review the concrete checklist again
, 3 and we did make some changes to that checklist.
4 Q All right, sir.
- 5 Let me direct your attention, if I might, to
- 6 Intervenors' Exhibit No.148. That is your January 23rd 7 CSR suspension memo with two further attachments.
8 It's the second of those attachments I want to l 9 direct your attention to. That's the April 15, 1985, 10 memo from a Mr. Sexton to Mr. Clinton, "
Subject:
I 1
11 Evaluation of Attributes for Concrete Placement."
<O 12 A (WITNESS KAUSHAL) Yes.
13 Q Do you have that document, sir?
14 A (WITNESS KAUSHAL) I have it.
I 15 Q All right, sir.
16 Now, I take it that the two gentlemen in that memo i
- 17 are in some fashion responsible for the CSR checklists 18 in the concrete area?
19 A (WITNESS KAUSHAL) They are -- Mr. Sexton was the lead j 20 structural inspector --
21 Q All right, sir.
j 22 A (WITNESS KAUSHAL) -- and Mr. Clinton was the i
23 supervisor of the insp'ection staff.
() 24 Q All right, sir.
25 And does this memo document the review of the ,
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13465 1 concrete placement checklist to which you've just 2 alluded?
3 A (WITNESS KAUSHAL) This memo documents the review by 4 Mr. Sexton of the activities that had transpired 5 vis-a-vis interaction of the inspectors with the 6 engineers, I believe. I have to refresh my memory by 7 reading that.
8 0 Take a moment, if you will. He refers both to the NRC, 9 the ERC, to a checklist review and to a midpoint look in 10 that memo.
11 A (WITNESS KAUSHAL) Now, what was your question with l 12 , respect to this document? -
13 Q This document, in fact, does document the review of the 14 concrete placement CSR checklist pursuant to -- in 15 response to the NRC inspector's concerns that I've 16 directed your attention to?
17 A (WITNESS KAUSHAL) It documents one of the reviews.
18 Let me also remind you that the checklists were 19 prepared by the engineers. The responsibility for 20 preparing the checklist and instructions rested with the 21 engineers, although they consulted many times with the 22 inspectors in order to make them clear and understood.
23 This memorandum is from the inspection staff with 24 respect to their experience and whatever we planned to
[]}
25 do with regard to various attributes on which questions Sonntac Reportino Service, Ltd. )
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2 Q All right, sir. Well, I just want to direct ycur 3 attention to the second page of the document.
4 It appears that two attributes, at least --
5 embedded plates and coatings -- were the subject of
- 6 revisions to the CSR concrete placement inspection 7 checklist as a result of the review initiated --
8 instigated by the NRC inspector's concerns.
9 A (WITNESS KAUSHAL) Apparently the embedded plate 10 attribute was revised and the coating attribute was 11 included, yes.
'{ 12 0 All right, sir.
13 And also as a result of a revision of the 4
14 checklist, again instigated by the NRC inspector's
. 15 concerns, you did a reverification of a number of the 16 attribute inspections in the concrete placement area, 17 again documented by this memo?
, 18 A (WITNESS KAUSHAL) I would not want to agree with your 19 statement that we did that in response to only NRC 20 concerns.
21 0 That wasn't my point, either.
22 A (WITNESS KAUSHAL) Okay.
23 0 You want to be clear that it wasn't only in response to
() 24 their concern?
25 A (WITNESS KAUSHAL) That's correct.
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i 1 0 All right. 1 2 In part, to the NRC's concern?
3 A (WITNESS KAUSHAL) That's correct.
I 4 Q Part to the ERC?
5 A (WITNESS KAUSHAL) Part to the ERC, part to whatever
- 6 other internal information we may have developed.
i 7 Q But, nevertheless, from all those sources you did a 8 revision of the checklist, included new attributes and 9 reverified in part your concrete placement inspections i
10 as a result of the revisions that you had made to that 11 checklist?
(() 12 A (WITNESS KAUSHAL)
That's correct.
13 Q All right, sir.
] 14 Now, what revisions, if any, did you make to the i 15 checklist attributes for the electrical categories --
16 the electrical populations: conduit, conduit hangers,
, 17 cable pan, cable pan hangers, equipment. installation?
18 A (WITNESS KAUSHAL) I don't -- I would not recall l 19 specifically what revisions we made at that time.
20 Whatever we did is documented in the records.
i
- 21 We, as my memoranda here do state -- or at least 22 some of the records that you showed -- we did review 23 whatever we were working on at that time to assure
(} 24 25 ourselves that if there were changes to the checklist that needed to be made, that they would be made.
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1 0 All right, sir.
2 Well, the short and long of it is that as you sit 3 here today, you don't recall whether there were any 4 changes made to the electrical checklist; is that your 5 testimony?
6 A (WITNESS KAUSHAL) Well, I believe -- I've stated that 7 certain revisions were made to the checklist on concrete 8 hangers, but I don' t recall the specifics.
- 9 Q All right, sir.
10 What reverifications of previously-conducted CSR 11 inspections in the electrical area, if any, were made as
) 12 a result of the revision of the electrical checklists?
13 A (WITNESS KAUSHAL) I believe my prefiled testimony 14 states that we went back and looked at the -- all the 15 conduit hanger inspections that we had performed prior 16 to a certain date.
17 I believe -- I'm not sure if it was Mr. Wozniak's
. 18 testimony, also.
19 0 Let me ask Mr. Wozniak, then.
- 20 The first question, sir, is: What revisions, if 21 any, were made to the electrical checklists a result 22 of the NRC item?
23 A (WITNESS WOZNIAK) Mr. Guild, I'd like to point out in 24 my prefiled rebuttal testimony on Page 7 --
l
[}
25 0 Sure. Let me find it.
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13469 1 A (WITNESS WOZNIAK) -- Question and Answer 18.
2 0 All right, sir. That's helpful.
3 What attributes in the electrical populations, if 4 any, were revised as a result of the NRC's concerns?
5 A (WITNESS WOZNIAK) Specifically that would be shown in 6 the NRC Report 8603, I believe.
7 0 86037 ,
8 A (WITNESS WOZNIAK) As I've indicated in my testimony, 9 Question 19.
10 Q Sir, I don't happen to have that report.
i 11 Do you recall what, if any, changes were made to
'0 4
12 the electrical checklist attributes?
13 A (WITNESS WOZNIAK) Again' referring to my testimony, I 14 believe on Page 6, which is the continuation of Answer 15 17, it goes on to say that, "The instructions at that i
16 time required the BCAP task force inspector to verify i
17 that they were the right type of conduits and that they l 18 were properly attached, but did not explicitly require 19 the BCAP task force inspector to verify that the 20 conduits attached were the ones identified in the design 21 drawings.
22 "We were required to verify this information as a f 23 part of the CSR reinspections of the conduit l
l
() 24 cor.struction category.
25 "Therefore, it was not obvious to the BCAP task nnnnean nonnreinn noruico. r+a.
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1 force inspectors that we should also have been verifying 2 conduit identity as part of our inspections of conduit 3 hangers."
4 Now, as my memory serves me, I believe we went back 5 and revised the conduit hanger checklist to prove the 6 identity conduits.
7 0 All right, sir.
8 So conduit identity was then on both checklists:
i 9 the conduit hanger ch'ecklist and the conduit checklist?
I 10 A (WITNESS WOZNIAK) I believe so.
- 11 0 And it's a double-check?
O 12 $ (WITNESS WOZNIAK) Yes, sir. .
13 0 All right, sir. That's one attribute that was'added to 14 the conduit hanger checklist.
15 Were there any other revisions or additions to the 16 electrical checklists?
17 A (WITNESS WOZNIAK) Sir, I'm not able to recall that at 18 this time. There may or may not have been.
19 0 All right, sir.
20 Aside from the review of past inspections in the 21 conduit hanger area again resulting f rom this NRC 22 concern, were there any other reviews or reinspections 23 in the electrical area?
() 24 A (WITNESS WOZNIAK) Mr. Guild, as Dr. Kaushal testifies, 25 we did a midpoint review of all the CSR reinspections.
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1 However, the only reverification program, if you 2 will, that I'm aware of was in the conduit hanger 3 population.
4 Q By " reverification," do you mean a reinspection of the 5 actual field conditions?
6 A (WITNESS WOZNIAK) If so deemed necessary by the 7 reverification program that was approved, yes, sir.
8 0 Well, I take it from your answer, then, that a 9 reinspection -- a complete reinspection was not done?
10 A (WITNESS WOZNIAK) Not in all cases.
11 Q By " reverification" -- why don't you tell me what you
'( ) 12 sean by " reverification," as you -- as distinct f rom 13 " reinspection"?
14 A (WITNESS WOZNIAK)
There was a reverification checklist 15 developed and approved to reverify all conduit hangers 16 inspected, as I've indicated in my testimony, Question 17 and Answer 18 --
18 0 Okay.
19 A (WITNESS WOZNIAK) -- inspected prior to January 24, 20 1985, for the attributes called into question.
21 Now, part of this reverification program determined 22 that if some of the attributes in question were, in 23 fact, questionable, then a reverification per se to the 24 field would take place but not in all cases would have
({}
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1 in the field.
2 Q Let's be clear, then.
3 So the reverification related only to certain 4 attributes --
5 A (WITNESS WOZNIAK) Yes, sir.
6 0 -- of one population, and that's the conduit hangers?
7 A (WITNESS WOZNIAK) Yes, sir.
8 Q And which attributes were those?
9 A (WITNESS WOZNIAK) Those were the attributes, as I've t 10 discussed -- excuse me. If I may refresh my memory here
' 11 a minute - .
12 Q Sure. .
13 A (WITNESS WOZNIAK) Sir, I don't believe I've made that 14 part of my prefiled testimony, but the attributes 15 identified in part by the ERC concerns were reverified 16 on the reverification program.
4 17 I believe the response to that, as I've indicated, 18 is in the NRC Inspection Report 8603.
19 0 All right, sir. That's a helpful reference.
- 20 But you don't recall at this time what those 21 attributes were?
22 A (WITNESS WOZNIAK) Not exactly, no, sir.
23 0 Whatever those attributes were, they were only the
(]) 24 attributes that were the subject of the ERC concern; is 25 that a correct understanding?
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(\ / 7 1 A (WITNESS WOZNIAK) Yes, sir.
1 2 Q All right.
3 Those attributes were the subject of 4 reverification, and I take it from your previous answer 5 that that reverification first included a review of the i 6 checklist?
1 i 7 A (WITNESS WOZNIAK) Yes, sir.
8 O All right.
9 And then and only if then -- then and only if there 10 was a question f rom the. review -of the checklist might 11 the reverifier go to the field to review a field
- O 12 condition; is that a correct understanding? ,
13 A (WITNESS WOZNIAK) Yes, sir.
14 Q All right.
15 And in how many cases were there field i 16 reinspections for the attributes that were the subject 17 of the ERC concern?
18 A (WITNESS WOZNIAK) My memory is not clear on that area.
, 19 But again, sir, I believe that would be documented, 20 as I can recall, in the Inspection Report 8603 or --
21 excuse me -- the BCAP response to that report if it's 22 not a direct attachment.
23 Q Well, sir, let me make it clear that I'm thinking of the l
O 24 same document.
25 Are you speaking of the Commonwealth Edison Company anan&=; c eperting Service; Lt6-
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1 response to the NRC's Inspection Report 8603 --
2 A (WITNESS WOZNIAK) Yes, sir.
3 0 -- or an internal BCAP response?
, 4 A (WITNESS WOZNIAK) Well, sir, I'm not quite sure of the i
5 fundamentals in that area.
6 I would assume it would have to be, you know, the 7 BCAP organization that would respond to it.
8 0 I'm just trying to be able to find the document, lay 9 hands on the document.
10 MR. STEPTOE: I've got the document in front 11 of me, Judge Grossman.
() 12 ,
MR. GUILD: It would be helpful if. counsel 13 would share the document with me. ,
14 MR. STEPTOE: We have another copy. Here.
15 (Indicating.)
16 MR. GUILD: Thanks.
17 If I might, can I just show the document to the 18 witness?
19 MR. STEPTOE: No problem.
20 MR. GUILD: Perhaps the information I sought 21 will be derived.
22 BY MR. GUILD:
23 Q Counsel has made available a document entitled " Conduit Support Reverification Program," Mr. Wozniak.
{} 24 25 Perhaps you could take a moment and review that Sonntag Reporting Service, Ltd.
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13475 1 document and see if you can, f rom that document, 2 identify the information that I was asking about.
3 That is, first, the number of field reinspections 4 that were conducted as a result of the reverification.
5 WITNESS WOZNIAK: Mr. Guild, this is quite a 6 large document. It might take me a few minutes, sir.
7 JUDGE GROSSMAN: Do you wish him to review 8 the entire document now, Mr. Guild?
9 MR. GUILD: Mr. Chairman, if the document --
10 if the witness believes the document has the answer to 11 the preceding several questions, I think it would be
( 12 most convenient if we just allow the witness the time to 13 review it.
14 JUDGE GROSSMAN: Fine. While he's reviewing 15 that, let me clarify the Board's ruling yesterday on 16 admissions.
17 This doesn't concern the witness panel, so you can 18 continue reviewing that, Mr. Wozniak.
19 Where the Staff has stated something that would be 20 considered -- that relates to the Staff's functions, 21 such as the Staff's role in investigations, we will 22 allow the offer of admissions against Staff into the 23 record.
(} 24 I believe we had an example of that yesterday in 25 which there was no objection, actually, so the statement Sonntaq Reporting Service, Ltd.
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1 read by Mr. Guild was properly introduced into the l l
l 2 record.
4 3 The latest statement in which we had some dispute 4 related to Mr. Gardner's opinion as to the propriety of 5 some activities by Applicant.
6 We'll stand by our ruling of not allowing that in 7 as admissions because they would be really adverse to 8 Applicant, and they stand on no different footing than 9 the NRC reports that we would not let in to be used for 10 or against Applicant without having the witness here to 11 support his statement or elaborate on it or clarify it
/( ) 12 or retract it, whatever is necessary.
13 So we stand by what we said, but we want to point 14 out that in the future that is going to be our ruling; 15 and if there is something adverse said by a staff i
16 witness against Applicant, we'll want to have that Staff 17 witness here, unless there's some exceptional reason why 18 we can't have the witness here and we may decide to use 19 hearsay.
I 20 But we will not treat those matters as admissions.
. 21 MR. STEPTOE: Judge Grossman, I'm going to 22 have to read the transcript. I think I understand what 23 you're saying, but I need to read the transcript.
24 JUDGE GROSSMAN: Certainly.
[}
25 MR. STEPTOE: You made a statement there was Sonntac Reportino Service, Ltd.
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'O 1 no objection to the first --
2 JUDGE GROSSMAN: I believe there was some 3 other reference to Mr. Gardner's transcript, and Mr.
4 Guild did read that in and there was no objection made 5 to it. I believe it had to do with the role of Mr.
s 6 Gardner or the Staf f's position.
7 We would have allowed that in anyway as an 8 admission against Staff because it pertains solely to 9 Staf f's role.
10 MR. STEPTOE: I see.
11 JUDGE GROSSMAN: And if Staff wished to, it
/ ,
12 could certainly -- all the admissions do, really, is put 13 the ball in the court of the party against whom the 14 admission is taken, and Staff has the opportunity to 15 then call that person again and clarify his remarks.
16 But it would be unfair to put the ball in 17 Applicant's court for a statement made by another 18 party's witness, an extrajudicial statement, where the 19 Applicant is not on the same footing where it can bring 20 its own employee in to clarify his statement.
21 There's no reason why the ball ought to be in your 22 court, Mr. Steptoe, under those circumstances.
23 MR. STEPTOE: I think I understand that now, 24 Judge Grossman.
[}
25 My only point was I thought I had made an Sonntaq Reporting Service, Ltd.
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a 13478 1 objection, but the transcript will show whether I did or 2 not.
3 JUDGE GROSSMAN: Well, this is to the earlier 4 example?
5 MR. STEPTOE: Yes. I thought we had a bench 6 conference in which I made an objection and then it was 7 resolved by your ruling that Mr. Guild's quotation --
8 JUDGE GROSSMAN: But that objection was not 9 based on its being in admission. That objection was 10 based on Mr. Guild taking it out of context --
11 MR. STEPTOE: I think I also --
-(E) .
12 ' JUDGE GROSSMAN: -- and asking an unfair 13 question.
14 Our ruling was that while the matter was not 15 entirely clear, it could have been construed the way you 16 wanted or the way Mr. Guild wanted. We didn't find 17 anything improper.
18 But that was not related to this matter.
19 Okay. Mr. Wozniak, have you completed your review 20 of that document?
21 WITNESS WOZNIAK: Mr. Chairman, I believe so.
22 Now, if I could have Mr. Guild redirect the 23 questions to me.
() 24 BY MR. GUILD:
25 0 Sure.
nnnneng nonnreing noruin _ r+a.
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Y 13479 i
1 The last question first, Mr. Wozniak,.and the 2 subject was reverification in the area of conduit 3 hangers through the process that you described.
4 How many actual field reinspections were conducted?
5 A (WITNESS WOZNIAK) As attached to this report, a 6 conclusions statement wac made here on Page 3 of 3 from i
7 the BCAP program.
8 The conclusion statement reads, "The conduit j
9 support reverification program contained 357 attributes, 10 of which 53 were identified to be inappropriate entries 11 as follows," and it goes on to break down some t(:) 12 attributes.
13 Q That's as a result of a checklist review, is it not?
~
14 A (WITNESS WOZNIAK) Yes, sir.
15 Q All right. Now, my question was regarding 16 reinspections.
17 How many field reinspections, if any, were 18 conducted as a result of the reverification conduit 19 hanger attributes spawned by the NRC concerns?
20 A (WITNESS WOZNIAK) It appears by this reverification 21 result tabulation I have here as attributes recorded as i 22 acceptable, reverified as rejectable, would be five, if i
23 I understand this document correctly.
() 24 0 Can you direct me to where you're reading from?
I 25 A (WITNESS WOZNIAK) The reverification results.
1 nnnneng nonnreing noruir.. r+a.
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13400 0
1 (Indicating.)
2 0 I see. All right, sir.
3 It's just not clear f rom the table whether the 4 reference is to a result from a field reinspection or 5 simply a document review?
6 A (WITNESS WOZNIAK) Correct, sir.
7 This table might not provide the information you' re 8 looking for, this specific table.
9 0 All right, sir.
10 And the numbers that you read for the record, the 11 attributes reverified -- those also may have been
( /O 12 attributes that were reverified only by a review of the 13 checklists,'a document review and not a field 14 reinspection?
15 A (WITNESS WOZNIAK) It would be my understanding that 16 the statement as read here, " attributes recorded as 17 acceptable, reverified as rejectable" -- it would appear 18 that that would have to come from a field 19 evaluation.
20 0 That's the five; correct?
21 A (WITNESS WOZNIAK) Yes, sir.
22 O All right, but you read the number 356 as attributes 23 reverified.
() 24 Those may or may not have included any actual field 25 reinspections?
I RnnnVan RonnrV4 nn Rornien. T.V A .
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13481 l
1 A (WITNESS WOZNIAK) Sir, I believe the number was 353 --
2 357; excuse me. Those may or may not have been from 3 actual reverifications in the field.
4 0 Your understanding, though, is that the first step was 5 to simply reverify from a checklist review?
6 A (WITNESS WOZNIAK) Yes, sir, as delineated on this 7 reverification checklist that is attached to this 8 report.
9 Q All right, sir.
10 And then only if there was some specific cause 11 arising from a checklist review would there be any
[ 12 second-step field reinspection?
13 A (WITNESS WOZNIAK) Yes, sir.
14 0 We just don't know how many, if any, field reinspections 15 were actually conducted?
16 A (WITNESS WOZNIAK) I believe that number might be 17 obtained f rom actually counting the hanger reinspection 18 checklists themselves.
19 I'm not intimately familiar with every detail of 20 this report, but I'm confident the information is in 21 there.
22 0 Well, are all the checklists in that report?
23 A (WITNESS WOZNIAK) The reverification -- I cannot 24 verify to that. This is a copy. But it would -- it
(])
25 would be prudent to assume so.
Sonntaa Reportino Service, Ltd.
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a 1 MR. GUILD: Perhaps I could ask again, just 2 to try not to burden the record with voluminous 3 documents. I'm looking for a number.
4 If the document does contain the number, perhaps I ;
i 5 could ask Applicant to simply stipulate that there is a 6 number that's derived f rom that document and it 7 represents the number of --
8 JUDGE GROSSMAN: I take it you're not 9 prepared at this point, Mr. Steptoe, to give us a number 10 and stipulate?
11 MR. STEPTOE: No. We'll find out over the 12 weekend, your Honor.
13 JUDGE GROSSMAN: Okay. That's fine.
14 MR. GUILD: That would be helpful. I 15 appreciate it.
16 BY MR. GUILD:
17 Q Now, were there any other electrical population 18 reverifications performed as a consequence of the NRC 19 concerns, aside f rom that in the conduit hanger area to 20 which you've testified?
21 This is directed to anybody on the panel.
22 A (WITNESS WOZNIAK) Not to my knowledge, sir.
23 Q Now, I may have asked this questio.n, but let's make sure 24 the record is clear.
[}
25 One attribute was added to the electrical I
~ ~ ~~"
Sonntaa Reporting Service, Ltd.
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M 13483 1 population checklists, at least so far acknowledged by 2 one or more of you gentlemen, and that was the addition 3 of conduit identity to both -- to the conduit hanger 4 population, when it had been previously only in the 5 conduit population. So that was one additional 6 attribute.
7 Is that a correct understanding?
8 A (WITNESS WOZNIAK) That is not correct.
9 The correct understanding I stated in my testimony 10 here, Page 6. It says, "The instructions at that time 11 required the BCAP task force inspector to verify that 12 they were the qight type of conduits and that they were 13 properly attached, but did not explicitly require the 14 BCAP task force inspector to verify that the conduits 15 attached were the ones identified in the design 16 drawings."
17 Q I see, I see.
18 Now, what's the distinction?
19 Perhaps I'm just missing it. It's not conduit 20 identity.
21 What is it?
22 A (WITNESS WOZNIAK) It would be a conduit presence.
23 0 There was initially a requirement that in conduit
() 24 hangers, the CSR inspector verify conduit presence?
25 A (WITNESS WOZNIAK) The instructions required the nnnneng nennr e ing noruico, r+a-Geneva, Illinois ,60134
13484 nD 1 inspector to verify the right type of conduits and that 2 they were properly attached.
3 0 That was always the instruction?
4 A (WITNESS WOZNIAK) Yes, sir.
5 0 Okay.
6 What was the attribute that was added, then?
7 A (WITNESS WOZNIAK) I believe the correct terminology 8 would be " attribute clarified" to then require the 9 inspector to identify the conduits that were attached.
10 0 Conduit by unique conduit identification number?
11 A (WITNESS WOZNIAK) Yes, sir.
12 0 All right: sir.
13 So, in fact, there was no attribute to be added; it 14 was simply a clarification to the instruction?
15 A (WITNESS WOZNIAK) Yes, sir.
( 16 0 Okay.
17 Now, that one point aside, were there any other l 18 revisions to attributes in any of the electrical 19 populations that resulted f rom the NRC's concern about l 20 the checklist adequacy?
- 21 A (WITNESS WOZNIAK) Mr. Guild, I don't have an accurate j 22 answer for that statement. I'm not aware.
23 0 All right, sir.
l
() 24 And I think, Dr. Kaushal, you weren't aware, either; is that correct?
25 Sonntaa Reportina Service, Ltd.
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1 A (WITNESS KAUSHAL) Well, my understanding, my l l
2 recollection, Mr. Guild, is that we did take a look at j 3 everything that was going on at that time. We certainly 4 focused in on the conduit supports, and the actions 5 regarding that are stated in the -- in the memoranda 6 that you gave me yesterday.
7 I don't have a recollection at this time what other 8 electrical populations were ongoing and whether it was 9 necessary or whether we thought it was appropriate to 10 change anything in those.
11 Given that we didn' t go back and find it -- we
- O 12. didn't find it necessary to go back and reinspect 13 anything else, that would lead me to believe that we 14 didn't find-anything significant that we had to change.
15 JUDGE GROSSMAN: Dr. Kaushal, that is a very 16 elaborate statement for a very simple question.
17 Could you please make your answers a little briefer 18 than that so we can get on with it?
19 WITNESS KAUSHAL: I apologize, Mr. Chairman.
20 A (WITNESS KAUSHAL) (Continuing.) The answer is I don't 21 recall exactly.
i 22 (Laughter.)
23 MR. GUILD: All right, sir.
() 24 Mr. Chairman, I would offer in evidence -- in fact, 25 I've got a couple of documents hanging. I'm not 1
~~~
4 Annnean nonn r ei nn geruica. r+a.
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13486
(
1 offering at this time Intervenors' 146, which is Mr.
2 Gardner's inspection report.
3 I have 147 marked for identification, Dr. Kaushal's 4 January monthly BCAP report that has a March 7th 5 transmittal date on the front of it. I'd offer that at 6 this time.
7 JUDGE GROSSMAN: Any objection?
8 MR. STEPTOE: No objection.
9 JUDGE GROSSMAN: Mr. Berry?
10 MR. BERRY: None f rom the Staff, Mr.
11 . Chairman.
i 12 JUDGE GROSSMAN: Admitted.
13 (The document was thereupon received into 14 evidence as Intervenors' Exhibit No.
15 147.)
16 MR. GUILD: If I can check my notes and make 17 sure I'm up-to-date --
18 JUDGE GROSSMAN: Well, there's 148, which is 19 Dr. Kaushal's memorandum of January 23, 1985 --
20 MR. GUILD: Yes, sir.
21 JUDGE GROSSMAN: -- suspending work in the 22 CSR program.
23 MR. GUILD: Yes, sir, and I would offer that
(} 24 as well.
25 MR. STEPTOE: Judge Grossman, I have no Sonntaa Reportina Service, Ltd.
Geneva, Illinois 60134 Ciut9a_nha9ns0
r 13487 TO 1 objection to the January 23, 1985, memorandum, which is 2 the first page of Intervenors' Exhibit 148, nor do I 3 have any objection to the second memorandum.
4 JUDGE GROSSMAN: Which is the January 24th 5 one?
6 MR. STEPTOE: That's correct.
7 I do have an objection to the last two pages of 8 Intervenors' exhibit, which relate exclusively to the 9 concrete population. I don't believe it's relevant.
10 MR. GUILD: Mr. Chairman, I don't offer it to i ~
11 prove the substance of the matters. I simply offer it
- O 12 as reflecting -- as an aid in cross examination.
13 I'm not interested in getting into the concrete 14 area, but I am interested in establishing that a review 15 -- I take that all back.
16 I do offer it for the substance. It's clear we're 17 not expanding the scope of the contention by asking the 18 Board to look into the area of concrete placement. That 19 is not my purpose.
20 JUDGE GROSSMAN: But this goes to the entire 21 methodology of the BCAP program and the CSR review?
22 MR. GUILD: Indeed it does.
23 JUDGE GROSSMAN: Any objection, Mr. Berry?
() 24 MR. BERRY: No objection from the Staff.
25 JUDGE GROSSMAN: We'll take the whole thing i
snnneng nonnrei ng norui co , r+a_ j Geneva, Illinois 60134 l
13487 (O
1 objection to the January 23, 1985, memorandum, which is 2 the first page of Intervenors' Exhibit 148, nor do I 3 have any objection to the second memorandum.
4 JUDGE GROSSMAN: Which is the January 24th 5
one?
6 MR. STEPTOE: That's correct.
7 I do have an objection to the last two pages of 8 Intervenors' exhibit, which relate exclusively to the 9 concrete population. I don't believe it's relevant.
10 MR. GUILD: Mr. Chairman, I don't offer it to 11 prove the substance of the matters. I simply offer it
- O 12 as reflecting -- as an aid in cross examination. I 13 I'm not interested in getting into the concrete 14 area, but I am interested in establishing that a review 15 -- I take that all back.
16 I do offer it for the substance. It's clear we're 17 not expanding the scope of the contention by asking the 18 Board to look into the area of concrete placement. That 19 is not my purpose.
20 JUDGE GROSSMAN: But this goes to the entire 21 methodology of the BCAP program and the CSR review?
22 MR. GUILD: Indeed it does.
23 JUDGE GROSSMAN: Any objection, Mr. Berry?
() 24 MR. BERRY: No objection from the Staff.
25 JUDGE GROSSMAN: We'll take the whole thing snnneng nonnrH ng servico,_ r+a.
Genevag Illinois 60134
13487 (O
1 objection to the January 23, 1985, memorandum, which is 2 the first page of Intervenors' Exhibit 148, nor do I 3 have any objection to the second memorandum.
4 JUDGE GROSSMAN: Which is the January 24th 5 one?
6 MR. STEPTOE: That's correct.
7 I do have an objection to the last two pages of 8 Intervenors' exhibit, which relate exclusively to the 9 concrete population. I don't believe it's relevant.
10 MR. GUILD: Mr. Chairman, I don't offer it to 11 prove the substance of the matters. I simply offer it
- O 12 as reflecting -- as an aid in cross examination.
13 I'm not interested in getting into the concrete 14 area, but I am interested in establishing that a review 15 -- I take that all back.
16 I do offer it for the substance. It's clear we're 17 not expanding the scope of the contention by asking the 18 Board to look into the area of concrete placement. That 19 is not my purpose.
20 JUDGE GROSSMAN: But this goes to the entire 21 methodology of the BCAP program and the CSR review?
22 MR. GUILD: Indeed it does.
~
23 JUDGE GROSSMAN: Any objection, Mr. Berry?
() 24 MR. BERRY: No objection f rom the Staff.
25 JUDGE GROSSMAN: We'll take the whole thing snnneng nonnreing noruic._ r+a_
Geneva, Illinois 60134
13488
'()
i 1 in. For whatever the last two pages are worth, they i 2 come in, a1so. So that's received.
3 (The document was thereupon received into 4 evidence as Intervenors' Exhibit No.
5 148.)
6 BY MR. GUILD:
7 Q Gentlemen, Dr. Kaushal, I just want to show you another 8 NRC inspection report.
9 (Indicating.)
10 This report bears a date of March 8, 1985. It's 11 Inspection Report 8506.
12 MR. GUILD: M'.
r Chairman, I ask_this be 13 marked as Intervenors' Exhibit 149 for identification.
14 (The document was thereupon marked 15 Intervenors' Exhibit No.149 for 16 identification as of October 3, 1986.)
17 BY MR. GUILD:
18 Q Now, Dr. Kaushal, in the process of processing 19 observations that had been identified by the CSR 20 inspectors in the field, as we discussed yesterday in 21 some detail, there were reviews made by various 22 organizations and individuals for validity.
23 Among them was a review by Sargent & Lundy for O 24 va11dity .
25 Do you recall that testimony?
nnnneng nonnr*4ng noruico. r+a_
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13489 1 A (WITNESS KAUSHAL) Yes. In the beginning of the 2 program, there were reviews by Sargent & Lundy.
3 0 Well, at all stages of the program there were reviews by 4 Sargent & Lundy for validity.
5 It's just that you changed the BCAP-06 procedure 6 and perhaps your practice as well to clarify what, 7 indeed, Sargent & Lundy's role was in reaching 8 conclusions about validity; isn't that the case?
9 A (WITNESS KAUSHAL) That is correct.
10 Q All right.
11 In fact, early on in the program -- strike, that.
12 In fact, the NRC identified an item of 13 noncompliance reflected in Intervenors' Exhibit 149 for 14 identification, Mr. Gardner's report, with ~ respect to 15 the inappropriate invalidation of BCAP CSR observations 16 by the architect-engineer, Sargent & Lundy?
17 A (WITNESS KAUSHAL) What's the question?
18 Q That is a fact, is it not: that the NRC identified an 19 item of noncompliance with respect to the inappropriate 20 invalidation of BCAP observations by Sargent & Lundy?
21 A (WITNESS KAUSHAL) There was a violation, yes --
22 Q All right.
23 A (WITNESS KAUSHAL) -- cited.
24 Now, that also -- that same finding was the subject of
('} Q 25 an adverse finding by the independent expert overview Sonntac Reportino Service, Ltd.
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4 13490 (Q
l group, the ERC?
2 A (WITNESS KAUSBAL) That's correct.
3 Q All right, sir.
4 Now, the reference generally is to 37 BCAP 5 observations involving the use of red-line drawings not 6 in the electrical area but in the mechanical hanger 7 area; correct?
8 A (WITNESS KAUSHAL) Would you -- would you draw my 9 attention to the part of the document that you are 10 referring to?
11 0 Yes. It's Page 4, No. 4 at the bottom, Item 4, entitled 12 , " Review of Invalidated BCAP Discrepancies. " It says, 13 "The inspector reviewed 37 BCAP observations," et 14 cetera.
4 15 A (WITNESS KAUSHAL) Yes.
16 Q All right.
17 A (WITNESS KAUSHAL) What.was your question?
18 I'm sorry.
19 Q The question was: The subject of the noncompliance 20 involved 37 observations invalidated by Sargent & Lundy 21 involving the use of red-line drawings for mechanical 22 hangers?
23 A (WITNESS KAUSHAL) That's correct.
(} 24 0 All right.
Now, it's true, is it not, that Edison's position
, 25 Sonntaq Reportina Service, Ltd.
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13491 1 was that Sargent & Lundy never had the final say-so over 2 the decision to treat an observation as valid or 3 invalid?
4 A (WITNESS KAUSHAL) That's correct, yes.
5 0 That in these cases and others, though, Sargent & Lundy 6 checked the " invalid" box on the observation form?
7 A (WITNESS KAUSHAL) What -- what's the question, Mr.
8 Guild? I'm sorry.
9 JUDGE GROSSMAN: I don' t think you completed 10 your question.
11 MR. GUILD: I meant to make that a complete
'\ / 12 question. ,
13 BY MR. GUILD:
14 0 In these cases and others, Sargent & Lundy checked the 15 " invalid" box on the observation form, did they not?
i 16 A (WITNESS KAUSHAL) Yes, they did.
1 17 Q All right.
18 And the significance of checking the " invalid" box i 19 on the observation form was, in these cases and others, l
20 to treat those observations as invalid?
21 MR. STEPTOE: I object to the form of the l 22 question, "the significance was to treat." I'm not sure i 23 that -- we have two organizations here, and the question 24 is: Who is treating?
{ 25 MR. GUILD: Well, sir, I think the witness is Sonntag Reporting Service, Ltd. Geneva, Illinois 60134
4 13492 1 capable of answering that question, Mr. Chairman. 2 JUDGE GROSSMAN: I think the wording could be 3 improved on that. 4 MR. GUILD: Undoubtedly, Mr. Chairman, but -- 5 JUDGE GROSSMAN: Well, is the question: Did 6 it have the effect of invalidating the -- i 7 MR. GUILD: No, sir, it's not. I asked the 8 question the way I meant to ask the question. I believe 9 it's a proper question. 10 But I'll try to ask it again. 11 JUDGE GROSSMAN: Okay. Please do. (O 12 MR. GUILD: All right, sir. 13 BY MR. GUILD: 14 Q The effect of that action by Sargent & Lundy, checking 15 the " invalid" box, was to cause those observations, and 16 others where Sargent & Lundy had also checked the 17 " invalid" box, to be processed as invalid? 18 A (WITNESS KAUSHAL) No, that's not correct. 19 Q Well, isn't it the case, Dr. Kaushal, that in the
- 20 instance of the 37 observations, no further processing 21 whatsoever took place on those observations for months 22 until Intervenors filed their amended Quality Assurance 23 contention; and then and only then did the BCAP task
() 24 force initiate some document reflecting that indeed, 25 despite the fact these languished for months, they were cnnnean n o nn r
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13493 1 now declared no longer invalid? 2 A (WITNESS KAUSHAL) I don't recall the dates on which 3 the final invalidation on those observations was 4 assigned. The work went on quite late, as you know. We , 5 didn't finish the BCAP effort until October or November 6 of 1985. 7 I don't have any recollection of what time you 8 filed the contention and what time various observations 9 were assigned as invalid. l 10 0 All right, sir. 11 Well, the item of noncompliance that was cited by 0 (\ / 12 Mr. Gardner, the 37 invalid observations -- the item was c 13 cited for an inspection that took place beginning 14 February 4 th through March the 1st, 15 JUDGE GROSSMAN: Of 1985? 16 MR. GUILD: Of 1985, yes, sir. 17 BY MR. GUILD: 18 Q They related to observations made by the independent 19 expert overview group. It took place at least by that 20 date, perhaps earlier; by the date of the end of the 21 inspection report, March 1,1985. 22 A (WITNESS KAUSHAL) What's the question, Mr. Guild? 23 0 The Sarge'nt & Lundy invalidation action was taken at {} 24 least by March 1,1985;-is that correct? 25 A (WITNESS KAUSHAL) That's probably true, yes. Sonntac Reporting Service, Ltd. Geneva, Illinois 60134 Cim9UL5d&Gt9YG _
l 13494 l 1 Q All right, sir. 1 2 I submit to you that Intervenors filed their 3 amended Quality Assurance contention May the 20th of 4 1985. 5 Now, sir, do you know whether or not by May the 6 20th, 1985 -- and that contention, that amended Quality 7 . Assurance contention, raised, as one of the subparts, 6 8 the 37 invalidated BCAP observations. 9 Now, sir, do you know whether or not the BCAP task 10 force had. countermanded Sargent & Lundy's invalidation 11 of those 37 observations before May 20, 19857 e
'/() 12 A (WITNESS KAUSHAL) I don' t exactly recall that, 'but it 13 would not surprise me that it came af ter that.
14 The process of processing the observations to their 15 final conclusion was quite elaborate and proceeded well 16 af ter that time. 17 Q Now, what exactly was the documented form for -- strike 18 that. 19 The 37 observations were in the format that appears 20 as an attachment to BCAP-06, Intervenors' 143. That's 21 the standard BCAP observation record. 22 A (WITNESS KAUSHAL) Are you directing my attention to 23 BCAP-06? () 24 0 Yes, sir. 25 A (WITNESS KAUSHAL) Let me find my copy of it. Annntag nannrei ng servi ca _ r+a_ _ . _ . Geneva, Illinois 60134
13495 l'() 1 I have the document. 2 0 All right, sir. 3 And my question to you, sir, was: The 37 red-line 4 drawing invalid observations utilized this form, did 5 they not? 6 A (WITNESS KAUSHAL) I believe so, yes. 7 Q All right. 8 And in the instances of those 37 red-line drawings 9 and others where Sargent & Lundy invalidated 10 observations, Sargent & Lundy checked the box in 17, 11 " Determination of Validity," and they checked the box i) 12 ,
" invalid," did they not?
13 A (WITNESS KAUSHAL) They checked the box " invalid," 14 right. 15 Q And they wrote in Box 16, " Evaluation," some basis, some 16 explanation, for their action in invalidating the 17 observation? 18 A (WITNESS - KAUSHAL) That's correct. 19 Q All right, sir. 20 A (WITNESS KAUSHAL) I believe that's correct. 21 0 Now, what subsequent action, in the case of the 17 -- or 22 the 37, rather, red-line drawing observations -- what 23 subsequent action, if any, did the BCAP task force take 24 to countermand or reverse the Sargent & Lundy action [} 25 invalidating those observations? Sonntaq Reporting Service, Ltd. Geneva, Illinois 60134 Out91_5mh6t%9
l 1 l 13496 l
'CZ) l 1 A (WITNESS KAUSHAL) I do not have an exact recollection.
2 But there are subsequent steps to processing of the ! 3 observation, and in one of those steps the observation 4 would be reclassified as valid if there was a 5 disagreement with what was stated before. 6 Q All right, sir. Now, that's your general understanding 7 of the process. 8 Is that what happened with the Sargent & Lundy 9 invalidated observations? 10 A (WITNESS.KAUSHAL) I believe that's what happened, yes. 11 Q And what happened to the observation record? O 12 Was there some change made to, the checking of the 13 box " invalid"? 14 A (WITNESS KAUSHAL) I would assume so, yes. I don't 15 have an exact recollection, but I would think so. 16 0 All right. 17 Well, if it's just a matter of checking another box 18 " valid" and perhaps lining through and initialing the 19 " invalid," how long would it take for the BCAP task 20 force reasonably to take that action, the action of 21 simply lining through and correcting the Sargent & Lundy 22 invalidation? 23 A (WITNESS KAUSHAL) The actual action of putting the l () 24 checkmark doesn't take very long, Mr. Guild; but to 25 evaluate the pros and cons of whatever information there l nnnneng nonnreing narric _ r+a. Geneva, Illinois 60134 .
13497 TO 1 is may, in fact, take a while. 2 0 Well, sir, at least as of the time that you had an exit 3 with Mr. Gardner where you discussed the 37 BCAP 4 observations deemed invalid by Sargent & Lundy, did you 5 not? 6 A (WITNESS KAUSHAL) I believe there was some discussion, 7 yes. 8 Q So at least as of the date that Mr. Gardner had his exit 9 with you prior to the publication of the inspection 10 report, you knew what the NRC's position was on this 11 matter. 12 Do you know whether you changed the Box 17 at that 13 time? . 14 A (WITNESS KAUSHAL) No, Mr. Guild. At that time the ' box 15 was not changed. 16 Q And you don't recall how long, if months -- if weeks or 17 even months, it took to get around to countermanding the 18 Sargent & Lundy invalidation? 19 A (WITNESS KAUSHAL) No. There was a significant amount 20 of iteration that took place on that in relationship to 21 -- this does pertain to documentation-review-type work 22 where the documentation was looked at again because -- 23 to develop a better understanding of what the red-line 24 process really means. []} 25 It was a completion of all that effort that was Sonntaq Reportina Service, Ltd. Geneva, Illinois 60134
13498 (0 1 necessary before a decision _could be made. 2 Q How many other instances were there, Dr. Kaushal, where 3 Sargent & Lundy checked the " invalid" boxes on BCAP 4 observation -- strike that. 5 How many instances were there in the electrical 6 area, the electrical populations, where Sargent & Lundy 7 checked the " invalid" box on the BCAP observation 8 records? 9 A (WITNESS KAUSHAL) I would not be able to recall or 10 even -- I'm not even sure I ever compiled that number. 11 But in the end, every observation that was declared 12 - valid or invalid was a task force decision. . 13 0 Well, at some time the task force got around to looking 14 at every piece of paper. 15 My question to you, sir, is more narrow; that is, 16 do you know in how many instances Sargent & Lundy took 17 the action in the electrical area of checking Box 17 18 invalid on observation? 19 A (WITNESS KAUSHAL) No, I do not. 20 JUDGE GROSSMAN: Do you know how many times 21 in the electrical area, Dr. Kaushal, the original 22 Sargent & Lundy invalidation was changed? 23 WITNESS KAUSHAL: Your Honor, I know of these 24 37 instances where it was changed. [{} 25 JUDGE GROSSMAN: We're talking about the Sonntaa Reporting Service, Ltd. Geneva, Illinois 60134 uutstt_sstsv-aurun
13499 l 1 electrical area, now. 2 WITNESS KAUSHAL: Oh, in the electrical area? 3 I don't know that number, your Honor. 4 JUDGE GROSSMAN: Do you know if there are 5 any? 6 WITNESS KAUSHAL: I would think so, that 7 there would be some, yes, sir; but I really don't -- I 8 never compiled that number, your Honor, so -- 9 JUDGE GROSSMAN: So you don' t know? 10 WITNESS KAUSHAL: I don' t know that, no, sir. 11 BY MR. GUILD: - 12 O What was the nature of the concern, as you understand 13 it, Dr. Kaushal, expressed by the independent expert 14 overview group and by the NRC inspector on this issue 15 with regard to Sargent & Lundy invalidating concerns -- 16 or observations? 17 Excuse me. 18 A (WITNESS KAUSHAL) I don't recall the specific nature 19 of concern. 20 What I -- what I recall is that for ERC in the 21 beginning, the basic concern was that just because -- 22 no, I don't really recall. 23 0 All right, sir. () 24 Why did they care? l 25 What difference did it make to ERC, the independent i l Annntag nonnre4ng noruico,_ r+a- ) Geneva, .I1linois 60134 __ _ _ _ _ _ _ _ _ _ _, l
13500 1 expert overview group, or to the NRC that Sargent & 2 Lundy had taken this action on the examples in question, 3 the 37 red-line drawings, or, more generally, that 4 Sargent & Lundy had acted to invalidate BCAP 5 observations? 6 A (WITNESS KAUSHAL) Mr. Guild, my recollection is that 7 the concern was not specifically that Sargent & Lundy 8 per se took that action. The concern was that those 9 observations should not be properly invalid. That was 10 the concern, as I recall it. 11 Q All right, sir. Let's talk about that concern. t<O 12 Now, the NRC and Mr. Gardner, in his inspection 13 report -- he does not cite you for a violation of a BCAP 14 procedure. 15 He cites you for a violation of Appendix B, 16 Criterion 16, which states in part -- and I quote -- 17 * " Measures shall be established to assure that conditions 18 adverse to quality, such as nonconformances, are 19 promptly identified and corrected." 20 Is that a correct understanding? 21 He didn't cite you for violating BCAP-06 or 22 violating a BCAP procedure; he cited you for a violation 23 of Criterion 16, Appendix B? () 24 A (WITNESS KAUSHAL) That's the way it's stated, yes. 25 0 All right, sir. snnneng n.pnreing maruica_ r+a. Geneva, Illinois 60134
13501 [ 1 And do you understand that that reflects the NRC's l 2 concern that in these instances where you invalidated an 3 observation improperly -- where an observation was 4 invalidated improperly, that that represented f ailure to 5 properly provide for the correction of nonconforming 6 conditions? 7 A (WITNESS KAUSHAL) What was the question? 8 I'm sorry. I heard a statement. 9 0 Yes. 10 , The problem was that the invalidation of these 11 observations reflected a failure to properly provide for 12 , the correction of a nonconforming condition. 13 Isn' t that the problem, sir? 14 A (WITNESS KAUSHAL) Well, that's the way the problem was 15 perceived by Sargent & -- by the NRC, if that's what 16 your question is. 17 0 Yes. 18 Well, did you agree that that was, in fact, a 19 problem? 20 A (WITNESS KAUSHAL) No. 21 In fact, there is an elaborate response that I 22 don't have with me that was given to that particular 23 citation and in which we explained exactly the l (} 24 circumstances of what was going on and what the 25 implications were of Sargent & Lundy having invalidated Sonntaa Reportina Service, Ltd. Geneva, Illinois 60134 uuth_smhta9ns
13502 (O 1 them, what the task force position was on that and what 2 further actions were being taken to resolve the thing. 3 0 Well, sir, I'm sure there was an elaborate explanation. 4 My question is really more narrow: 5 Did you agree with the NRC that these instances 6 reflected a problem with the identification and 7 correction of nonconforming conditions? 8 Your answer was no; you didn't agree? 9 A (WITNESS KAUSHAL) That's correct, we did not agree -- 10 I did not agree. 11 Q It is clear, as we understand the general significance
~) 12 of invalidation, that for items that are declared 13 invalid, they're not counted as discrepancies as part of i 14 the CSR program?
! 15 A (WITNESS KAUSHAL) That's correct. 16 Q Now, in your opinion, in the instances of the 37 1
; 17 red-line drawing observations invalidated or deemed 18 invalid by Sargent & Lundy, did BCAP promptly identify i
19 and correct nonconf orming conditions? 20 I emphasize the word "promptly," which is also part r 21 of Criterion 16. I 22 A (WITNESS KAUSHAL) Well, the observations were promptly ( 23 written. The disposition of the observation goes to a (} 24 25 specific process. identified. So in my view, the condition was I Sonntaa Reporting Service, Ltd. { Geneva, Illinois 60134 _ _ _ _ . _ _ _ . _ _ _ _ - . _ _ _ . - . . _ - cB5un_3m%rcvL9
13503
/O V
1 But disposition of the condition can take time, and 2 in this case it was taking time. 3 0 All right, sir. 4 Well, the observation was written, but for -- 5 written and then essentially canceled, deemed invalid. 6 A (WITNESS KAUSHAL) Mr. Guild, I don't agree with that 7 statement. It was never canceled by BCAP task force. 8 Q Just by Sargent & Lundy? 9 - A (WITNESS KAUSHAL) That is correct. 10 0 All right, sir. Understood. 11 MR. GUILD: Mr. Chairman, may counsel suggest - 'O 12 a recess? e 13 JUDGE GROSSMAN: Oh, fine. Why don't we take 14 10 minutes. 15 (WHEREUPON, a recess was had, after which 16 the proceedings were resumed as follows:) 17 JUDGE GROSSMAN: We're back in session. 18 MR. BERRY: You'll recall, Mr. Chairman, that 19 yesterday morning we had a discussion with respect to 20 the recently received allegation received by Region III. ' 21 The Board asked Staff to report back to it on the 22 existence of a memorandum documenting in greater detail 23 the allegations that are reflected in the document that ; () 24 Staff produced to the Board and the parties. I 25 I contacted the regional office yesterday; and l Sonntaa Reportina Service, Ltd. Geneva, Illinois 60134
I l i 13504 () j l I we've been advised that, as of this date, there is no i 2 more-detailed memorandum documenting those allegations. 3 I do understand that the Allegation Review Board 4 has met and the allegation has been assigned to the 5 Division of Reactor Safety. An inspector has been 6 assigned to look into these allegations. 7 We've instructed the Region -- well, we,'ve alerted 8 the Region to particularly at this point emphasize those 9 allegations that the Board indicated appeared to be 10 relevant to this proceeding, so probably early ne::t week 11 we should be in a better position to determine where we h 12 are at this point and may be able to report back to the 13 Board and provide some information to~ determine the 14 relevance and materiality of the allegati.on to this 15 proceeding. 16 JUDGE GROSSMAN: Okay. Thank you, Mr. Berry. 17 Mr. Guild? 18 MR. GUILD: Yes, sir. Thank you, Mr. 19 Chairman. 20 Mr. Chairman, I distributed a document before the 21 recess. It bears on the cover a September 12, 1985, 22 date. I ask that it be marked for identification 23 Intervenors' Exhibit 150, please. () 24 (The document was thereupon marked 25 Intervenors' Exhibit No. 150 for gnnneag n pnreing s rvic . r+a. Geneva, Illinois 60134
i I 13505 ! I k_s) 1 identification as of October 3, 1986.) 2 MR. GUILD: I apologize. The copier gave us 3 some duplicates and didn't put these in the -- I'm not 4 sure that they' re exactly in the proper order. 5 I believe, though, there are three of them. 6 BY MR. GUILD: 7 Q Dr. Kaushal, do you have before you what I've marked as 8 Intervenors' Exhibit 150? 9 A (WITNESS KAUSHAL) I have the document that you gave me 10 earlier. 11 Q All right, sir. 12 Now, some months af ter the NRC expressed concerns 13 about the inappropriate invalidation of CSR 14 observations, we have several other examples of 15 observations that were deemed invalid and where the 16 original inspector, even the original CSR inspector, 17 objected to the actions taken to invalidate their 18 observation. 19 You then, pursuant to BCAP-06, became involved in 20 the process, reviewed the decisions made by a committee 21 and concurred in the action taken to invalidate the 22 observations? 23 A (WITNESS KAUSHAL) That's correct. 24 0 And that's reflected in the series of documents that we []} 25 have before us. Let's look at these in the record in Sonntaa Reporting Service, Ltd. Geneva, Illinois 60134
13506 O 1 which they are stapled together here. 2 The first -- if you would turn to the second page, 3 that is an observation record for an electrical i 4 equipment installation item, is it not? ! 5 A (WITNESS KAUSHAL) That's correct. 6 0 Now, it bears the suffix "902." 7 What does that indicate, the last three digits of 8 the observation number? 9 A (WITNESS KAUSHAL) My recollection is that that would 10 be an inspection performed by inspectors in the BCAP QA 11 group. , 12 O All right, sir. 13 So this wasn't just an inspection performed by. a i i 14 first-line CSR inspector; this was an overview 15 inspection performed by BCAP QA? ! 16 A (WITNESS KAUSHAL) That's correct. I 17 Q All right. 18 Now, you reviewed this observation yourself, and 19 that's indicated by your approval on the cover memo; 20 correct? l 21 A (WITNESS KAUSBAL) That's correct. 22 0 As I read the document, the BCAP QA overinspector 23 identified an observation described in Box 9. l 24 His conclusion reads: "This detail is not (]} 25 interchangeable and is therefore unacceptable." Sonntaa Reporting Service, Ltd. Geneva, Illinois 60134 utsun_sms,asne
13507 (0 v 1 A (WITNESS KAUSHAL) Correct. 2 0 There is a drawing that is attached two pages later. 3 Do you understand that to be a drawing of the 4 detail in question? 5 A (WITNESS KAUSHAL) That's my understanding, yes. 6 Q And that's followed by another drawing. 7 Is the second drawing the actual field-observed 8 condition? 9 Why don't you tell me what the second drawing is. 10 A (WITNESS KAUSHAL) I'm trying to recall. It's not very 11 legible. cO. One is the detail; and the other, I would assume, 12 13 is the actual location where the detail is. 14 Q Well, sir, now, there are two pages of drawings. I'm 15 looking at the second page, j 16 A (WITNESS KAUSHAL) Right. ! 17 0 What is the second page? 18 It has a number on the bottom that says " Drawing i 19 20E-0-3363" and it looks like either "003" or "D03." 20 A (WITNESS KAUSHAL) It's probably "D03." 21 Q What is that page, sir? 22 A (WITNESS KAUSHAL) I can't read the drawing very well, 23 but my understanding i5 that this would be the drawing () 24 that would show the actual installation of the detail. 25 0 All right. On the top left there is a drawing. nnnneng nonnreing s ruic . r+a_ Genevan Illinois 60134
13508
?O 1 Is that a plan view?
2 A (WITNESS KAUSBAL) I see -- it looks that way, yes. 3 Q In other words, looking down on the installation? 4 A (WITNESS KAUSBAL) Correct. . 5 0 And then to the -- in the lower right, a section? 6 A (WITNESS KAUSHAL) That's the way it appears, yes. 7 -Q Looking at the installation f rom the side, in f act -- 8 A (WITNESS KAUSHAL) Yes. 9 Q -- is that correct? 10 A (WITNESS KAUSHAL) I believe so, yes. l 11 Q The top of the plan is at the top of the page with + : 12 , respect to the section view in the lower right-hand 13 corner; is that correct, sir? , 14 A (WITNESS KAUSHAL) I believe that's correct. I would 15 have to take the time to really get myself oriented on 16 the drawing. 17 0 Well, sir, there shows an elevation number, Elevation 18 439. It appears to be at the top of the girder. 19 I take it that you don't do your drawings -- your 20 section drawings upside down, so that would generally 21 suggest that the top is towards the top of the page, 22 would it not? 1 23 A (WITNESS KAUSHAL) Okay. (} 24 0 And that this is a floor-mounted, as-built condition; 25 correct? Sonntaa Reporting Service, Ltd. i Geneva, Illinois 60134
13509 f 1 A (WITNESS KAUSHAL) That's what the description in the 2 memo also states, okay. 3 Q All right. 4 The preceding page, the detail drawing, however, 5 shows a ceiling-mounted -- 6 A (WITNESS KAUSHAL) That's correct. 7 0 -- detail, does it not? 8 A (WITNESS KAUSHAL) That's correct. 9 Q All right, sir. 10 Now, as I read the observation, the CSR -- excuse 11 me -- the BCAP overview inspector concludes that, "The
?
12 connection detail specifies an EC3 connection to an 13 embedded plate at the floor." 14 A (WITNESS KAUSHAL) That's right. 15 Q " Detail for type EC3 shows the attachment elevation as 16 ' ceiling' only. The detail is not interchangeable and i is therefore unacceptable." 17 18 A (WITNESS KAUSHAL) That's what the observation says, 19 yes. 20 Q All right, sir. 21 Now, someone evaluated the observation for validity 22 and completed Box 16 and checked " invalid." 23 Sir, who did that? 24 A (WITNESS KAUSHAL) My expectation would be that would {p 25 be Mr. Patel, who was the lead electrical engineer. 1 Sonntaa Reportino Service, Ltd. Geneva, Illinois 60134 m RE L3 m L &9nF1
h 13510
) 1 I
1 Q All right. 2 Well, that's indicated by Mr. Patel's signature in 3 Box 18, is it not? 4 A (WITNESS KAUSHAL) That's correct. 5 0 All right. 6 Now, that invalidation decision was disagreed with 7 by the overview inspector, was it not? 8 A (WITNESS KAUSHAL) That's my understanding, yes. 9 G And who was the overview inspector? 10 A (WITNESS KAUSHAL) I don't -- I don't recall that name. 11 The signatures are in Box 10 of the observation record (O 12 form. , 13 Q All right, sir. 14 Perhaps you could pass the document down to Mr. 15 Smith, and perhaps Mr. Smith could identify the 16 signature for us, please. 17 A (WITNESS KAUSHAL) (Indicating.) . 18 A (WITNESS SMITH) The signature in Box 10 is Don Groll, 19 G- R L- L . 20 0 And, Mr. Smith, is Mr. Groll an overview inspector? 21 A (WITNESS SMITH) Excuse me? i 22 O What is Mr. Groll's position? 23 A (WITNESS SMITH) He was an overview inspector, (} 24 electrical overview inspector. 25 0 QA, BCAP QA? \ Sonntaa Reportina Service, Ltd. Geneva, Illinois 60134 utstm_senmYO
13511 ( l A (WITNESS SMITH) QA. 2 0 Thank you. 3 Now, Mr. Groll was given this invalidated 4 observation; and I take it he wrote, "I do not agree 5 with invalidation," dated and initialed that statement? 6 A (WITNESS KAUSHAL) I would assume that's correct, yes. 7 It's shown here on the form. 8 O All right, sir. 9 Dr. Kaushal, then, as I understand BCAP-06, the 10 process calls for a committee being organized to review 11 the invalidated observation?
~( ) 12 A (WITNESS KAUSHAL) That's correct. ,
13 Q And it's Mr. Orlov's responsibility to designate the 14 members of that committee, is it not, as the BCAP i 15 assistant director? 16 A (WITNESS KAUSHAL) That's correct. 17 Q And Mr. Orlov appointed himself, Mr. Ryan, Mr. Patel and 18 Mr. Stevens to that committee? 19 They're indicated on the front? 20 A (WITNESS KAUSHAL) That's the way it appears, yes. 21 Q All right, sir. 22 And you then received the committee's 23 recommendation? {} 24 A (WITNESS KAUSHAL) That's correct. 25 0 All right, sir. Sonntaq Reporting Service, Ltd. Geneva, Illinois 60134 UUL91L3A91-R9YU2
13512 to 1 And you approved that recommendation and provided 2 that the subject observation should be designated 3 invalid? 4 A (WITNESS KAUSHAL) Correct. 5 Q And it was, I take it? 6 A (WITNESS KAUSHAL) Yes, it was. 7 Q And that invalidation was -- well, let me ask you this: 8 Af ter the committee's decision, was there then a 9 confirmation of that invalidation? 10 I'm looking on the observation report. 11 Did somebody fill in another box or was there any (O 12 further action taken with the observation form itself 13 after you approved the committee's recommendation, sir? 14 A (WITNESS KAUSHAL) My recollection is that my 15 recommendation makes it final -- my approval makes it 16 final. 17 0 So your signature on the memo is the final step? 18 A (WITNESS KAUSHAL) That would be the case, yes. 19 In some cases I remember signing the form in the 20 " approved" column, but the signature on the memorandum 21 in this case would -- 22 Q In Box 22 in some cases; is that right? 23 A (WITNESS KAUSHAL) I may have very well signed in some () 24 cases in Box 22. 25 Q In this case there is no signature in Box 22?
'~~
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13513 '(C) 1 A (WITNESS KAUSHAL) That's correct. 2 Q Now, what was the basis of your approval of the 3 invalidation of this observation, Dr. Kaushal? 4 A (WITNESS KAUSHAL) Well, the basis in this case was, 5 first, the recommendation of the committee, which , 1 6 included very competent engineers, and, secondly, 7 looking at the -- looking at the observation itself. 8 Given what I saw in the observation and what the ! 9 explanation given to me was, I thought it was 10 appropriate to designate that as invalid. . 11 0 All right, sir. ( 12 Well, let me focus not simply -- I understand your 13 decision was made in part on the basis that you.r 14 subordinates recommended the action to you, but let's 15 focus on the facts, sir. 16 What was the factual basis for approval of the 17 invalidation of this observation? 18 A (WITNESS KAUSHAL) The factual basis, as I understand 19 it, is that there's* a detail that is specified by l 20 Sargent & Lundy on the drawings as being applicable for 21 that particular portion of the construction. 22 However, the detail in it has some wording to the l 23 effect, as it's shown, that it's the ceiling, as opposed 24 to saying it's the floor. [}} 25 But apparently the architect-engineer, in putting l Sonntaq Reporting Service, Ltd. Geneva, Illinois 60134 m
13514 i 1 out the drawing, specified that detail; and my 2 assumption will be with full knowledge that it doesn' t 3 matter whether that detail, even if it's called I 4 " ceiling," is applied to the floor. 5 I talked to a few people on that, and that was my , 6 understanding: that that detail was meant to apply in 7 that particular application. 8 0 So the factual basis for invalidation of this 9 observation was based not just on what appears in the 10 documents before us, which is apparently the basis cited 11 by the committee.
) 12 -
It's on the basis of discussions with others on 13 which you formed an understanding of what Sargent & 14 Lundy, the architect-engineer's, intent was; is that i 15 correct? 16 A (WITNESS KAUSBAL) I would normally be willing to 17 accept the committee's recommendation, and in this case 18 it would have been no exception. I'm just giving you 19 some additional facts that in this case I did talk to 20 others. 21 But I would not consider that to be necessary. 22 0 Well, that's a helpful supplement to your earlier 23 answer, Dr. Kaushal, but in this particular case I am (} 24 25 interested in the fact that you had additional information. Sonntaq Reporting Service, Ltd. Geneva, Illinois 60134
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13515 ( l i 1 But that additional information is not described in 2 either the committee's memorandum, your review of that 3 recommendation, the committee's recommendation or in the 4 referenced evaluation portion of the observation form, 5 is it? 6 A (WITNESS KAUSHAL) The evaluation portion does, in 7 fact, describe what the evaluation by the engineer was. 8 Q Yes, sir. 9 But it doesn't make any reference to Sargent & 10 Lundy's intent nor does it make any reference to your 11 conversations with other persons on which you formed an
'I ) 12 opinion as to that intent?
13 A (WITNESS KAUSHAL) No. Mr. Patel would not have access 14 to or would not be knowledgeable on what I might or 15 might not do in this respect. 16 0 Now, did the committee have a meeting, the committee 17 that passed on this invalid observation? 18 A (WITNESS KAUSHAL) I don't -- I don't know that. 19 0 Well, was it your direction to your subordinates that 20 when they were to consider an objected-to, invalidated 21 observation, that they meet to discuss the matter 22 collegia 11y, that the committee members sit down and 23 discuss the matter? 24 A (WITNESS KAUSHAL) That was not necessarily my 25 instructions that they had to gather in one room at one Sonntaq Reporting Service, Ltd.- Geneva, Illinois 60134 m . _ _ _ _ _ _ _ - - - _ _ 15tRRA - M21h6tMM
13516 f 1 time. 2 It.was -- it was my expectation that the matter 3 will be discussed by a group of people, and -- 4 Q By more than one person? 5 A (WITNESS KAUSHAL) By more than one person, and -- 6 0 And they -- I'm sorry. I didn' t mean to interrupt. 7 A (WITNESS KAUSHAL) -- and the recommendation will be 8 documented to me. 9 0 All right, sir. 10 But those individuals could review the matter 11 individually? I 12 A (WITNESS KAUSHAL) They could. i 13 0 And simply in this -- and simply pass the documents f rom 14 hand to hand and reach a concurrence in the result? 15 A (WITNESS KAUSHAL) That is correct. 16 They may have talked individually with each other 17 one at a time, collectively or in the hall. All those 18 things could transpire, yes. 19 Q All right, sir. 20 Was it your direction that those individuals in the 21 committee meet with the objecting CSR inspector or, in 22 this case, the BCAP overview inspector? 23 A (WITNESS KAUSHAL) It was not a requirement. If there was a need for additional information, (} 24 But again there 25 they may have very well talked to him. Sonntaa Reporting Service, Ltd. Geneva, Illinois 60134
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13517 I l 1(2) i i l I was no requirement that the particular deliberations 2 have to take place in one room at one time. 3 0 Well, that's a different question. 4 Was there a requirement, as you directed your 5 subordinates, that they confer with the objecting 6 inspector in order to understand what the basis was for 7 the lack of concurrence or the objection?
, 8 A (WITNESS KAUSHAL) No, there was no such requirement.
9 Q Did the committee conf er with the objecting inspector in + 10 this case, to your knowledge? 11 A (WITNESS KAUSHAL) I don' t know that.
- O i 12 Q Did you ask the committee, before you approved their 13 recommendation, whether they had conf erred with the 14 objecting inspector?
15 A (WITNESS KAUSHAL) I'm sure I -- well, no, I'm not 16 sure, but I -- no, I don't have an exact recollection. i ! 17 0 The objecting inspector simply writes, "I do not agree 1 18 with invalidation." 19 Do you know whether there was any basis for the 20 objecting inspector's disagreement with the
- 21 invalidation?
22 A (WITNESS KAUSHAL) My knowledge of that will be based 23' on what's documented here. () 24 Q And, of course, that's available to all of us; there l 25 appears to be no elaboration either sought or given by I 4 AnnnVAn ROnnTVSnn ROYU$MD. T.V O . _ _..._Genev,a, Illinois 60134 , _ _ _ _ _ _
13518 i d 1 the objecting inspector -- sought f rom or given by the 2 objecting inspector; correct? 3 A (WITNESS KAUSHAL) What was the question, now? 4 Q There is no elaboration on his objection? 5 A (WITNESS KAUSHAL) No, there is no elaboration on his i 6 objection. 7 0 All right, sir. 8 Now, there's a second document attached -- well, 9 there's another copy of the same observation. Please 10 pass f rom that. 11 Then there's a series of documents. They don't
'() 12 have a'n observation record. attached. I'm looking at a 13 September 5,1985, memo.
14 JUDGE GROSSMAN: Are you off the other one 15 already? 16 MR. GUILD: Yes, I am, Judge. If you have I 17 questions -- 18 JUDGE GROSSMAN: You're not going to ask him 19 anything about Mr. Patel being on the committee, I take 20 it? , 21 MR. GUILD: No, sir. 22 JUDGE GROSSMAN: All right. 23 MR. GUILD: It seems apparent to me. () 24 JUDGE GROSSMAN: All right. I have no 25 questions.
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i 13519 ! l
'O 1 MR. GUILD: Mr. Chairman, perhaps could we 2 stand down for just a moment?
3 I have some documents that I need to get copied. 4 JUDGE GROSSMAN: That's fine. 5 Do you want to take any time now; five minutes? 6 MR. GUILD: That would be fine. 7 JUDGE GROSSMAN: Okay. We'll take five 8 minutes. 9 MR. GUILD: I'm going to talk about this 10 other observation, just to forewarn Dr. Kaushal. 11 (WHEREUPON, a recess was had, after which O 12 the proceedings were resumed as follows:) 13 MR. GUILD: Mr. Chairman -- 14 JUDGE GROSSMAN: Are you ready? 15 MR. GUILD: Yes, sir. i 16 BY MR. GUILD: 17 0 Dr. Kaushal, you have before you Intervenors' Exhibit 18 150, that portion, a memo September 5, 1985, also on the 19 question of the invalidation of CSR observations? 20 A (WITNESS KAUSBAL) Yes, I do. 21 0 All right, sir. 4 22 Now, as I understand, observations were written for 23 observed deficiencies in the configuration of cable pan l () 24 hangers and conduit hangers in the field? 25 A (WITNESS KAUSHAL) That's correct. i RnnnVnq RonnrF4nq Rorvice. T.F A . , Geneva, Illinois 60134
13520
!O V
1 Q All right, sir. 2 And observations were also written for the absence 3 of the appropriate LKC, Comstock, quality control 4 inspection documentation for conduit hanger and cable 5 pan hanger configurations? 6 A (WITNESS KAUSHAL) That's correct. 7 0 All right, sir. Let's take the second of those first. 8 Now, this memorandum reflects the invalidation of a 9 number of observations that were initialed that 10 identified the absence of Comstock documentation on 11 configuration inspections for conduit hangers and cable
<O. 12 pan hangers?
13 A (WITNESS KAUSHAL) That's correct. 14 Q All right, sir. 15 The basis, as I read the memo, for such an 16 invalidation was that, consistent with Comstock's 17 program, no such configuration inspections were done for 18 65 percent of the conduit hangers and cable pan hangers 19 prior to November, 1982? 20 A (WITNESS KAUSHAL) That's correct. 21 Q All right, sir. 22 And that since BCAP was -- since one of the l 23 standards for invalidation of observations'was whether the item was acceptable at the time it was initially (]) 24 25 installed and QC-accepted, in this case the absence of l nnnneng napnrH ng garvic . r.e a . i_ _ _ _ _ _ . , _ _ _ __ Geneva, Illinois 60134 _ _ _ _ ,
. . _ . = . .- . . -.
13521 1 documentation, you presume, reflected an acceptable 2 condition? 3 A (WITNESS KAUSBAL) Yes, that's correct. l 4 Q All right. 5 And that's the rationale for the invalidation of 6 these observations? 7 A (WITNESS KAUSHAL) It was -- yes, right. 8 Q All right, sir. 9 Now, were you aware that Comstock had committed to 10 performing quality control inspections of any of the 11 configurations for~ conduit hangers and cable pan hangers () 12 that had been installed but not inspected due to the 13 sampling inspections up until November of 1982? 14 A (WITNESS KAUSHAL) I'm aware that there is such a 15 commitment, yes. 16 Q Well, sir, were you aware that there was such a 17 commitment at the time that you determined to invalidate ! 18 these observations? I 19 A (WITNESS KAUSHAL) Which observations? 20 Q The observations reflected in the memo that I've 21 directed your attention to, the conduit hanger and cable 22 pan hanger configuration observations relating to 23 do .n enta ti on. () 24 A (WITNESS KAUSHAL) Relating to documentation? Your 25 question was: Was I aware of that commitment? nnnn+nn noner+4nn nerv4ea. s.+ A . Gedeva', I1115ois 60134
l 13522 f 1 O Yes. 2 A (WITNESS KAUSBAL) Yes. 3 0 Well, at the time that you performed these inspections, 4 had Comstock in whole or in part fulfilled that 5 commitment? 6 A (WITNESS KAUSHAL) No. 7 Q They hadn't fulfilled it at all? 8 A (WITNESS KAUSHAL) The walkdowns on both the conduits 9 and the cable pan hanger -- conduit -- conduit hanger 10 configuration and for cable pan hanger configuration to 11 complete that work had not been done. O 12 O Well, sir, that's not exactly the question. 13 First of all, had any action been taken by 14 Comstock, to your knowledge, at the time of the 15 inspection of these items, to inspect for configuration 16 conduit hangers and cable pan hangers? 17 A (WITNESS KAUSHAL) I believe -- I don't know if any 18 action was taken. I don't know that. 19 Q Do you know whether there were any instances in the 20 populations of conduit hangers or cable pan hangers 21 where there should have been a Comstock inspection 22 document reflecting a configuration inspection but there 23 was not? () 24 A (WITNESS KAUSHAL) That would be hard to figure out. I 25 don't know how we would determine that. Annntag Depor&ing Aervice; Ftd. Geneva, Illinois 60134
13523
'O 1 Q All right, sir. Well, that's, I guess, the question.
2 You chose to invalidate all observations for lack 3 of Comstock or Ernst quality documents for configuration 4 inspections of conduit and cable pan hangers prior to 5 November,1982, giving them the benefit of the doubt l 6 that, in each one of those instances, the absence of a 7 quality document was due to the fact that the hanger in 8 question was not one of the sample 35 percent? 9 A (WITNESS KAUSHAL) That's the only way it could be 10 done. 11 My expectation would be that when the walkdowns are ' O 12 done, to complete that commitment that.you earlier 13 mentioned, their basis for redoing the work would also i 14 be based on what documentation exists. 15 0 Wouldn't the more conservative approach have been not to l 16 give them the benefit of the doubt but to identify as a i 17 discrepancy the absence of quality documentation, since 18 you couldn't dcci.de -- you couldn't determine 19 c'onclusively whether the absence of documentation was 20 due to Comstock's failure to properly maintain 21 documentation or properly perform an inspection and 22 document that inspection for an item that should have 23 been inspected or, conversely, whether the absence of (]) 24 documentation was due to the cause you assumed, and that 25 was that the particular item didn't happen to be within annnemg n.pnveing moreiro. r+a_ Geneva, Illinois 60134
13524 I the sample? 2 A (WITNESS KAUSHAL) Your question was -- what was the 3 question? i 4 Q Wouldn't it have been been a more conservative approach 5 not to have invalidated these observations? 6 A (WITNESS KAUSHAL) Not in my mind. It would not have 7 served any purpose. The situation was previously known ) 8 and committed to be reviewed and corrected. 9 Q All right, sir. 10 But you're not aware of whether any of the items 11 that you invalidated reflected instances where an item .o 12 should have been inspected but'the document could not be ! 13 found? 14 MR. STEPTOE: That's been asked and answered, 15 your Honor. 16 JUDGE GROSSMAN: Well, Mr. Guild, I don't
- 17 know what the objection is, but I think we're going far
. 18 afield f rom what was purported to be the purpose for the 19 CSR program. i , 20 If I understand what has been told to us, it was 21 not to validate the original inspections; it was to j 22 determine whether the hardware was acceptable. 23 It really doesn't matter logically whether the () 24 missing documentation was in the 35 percent or the 65 25 percent if the documentation is going to be supplied f
- nnnnean nonnr H nn Amruica. r+d.
Geneva, Illinois 60134
13525 1 later on just because it's missing. 2 If they' re not trying to validate the original 3 inspection, there's no reason to put it in either 4 category. 5 Do you follow what I'm suggesting? 6 MR. GUILD: I understand, Judge, and I think 7 the point is well taken, except that it misses the fact 8 that indeed CSR did perform a documentation inspection. 9 That documentation inspection is not directly part 10 of the company's rebuttal case; but it in this instance, 11 I believe, confirms -- at least raises the question ( 12 about the identification of further documentation 13 deficiencies on the part of the L. K. Comstock Company. 14 I don't mean to belabor the point, but I think the 15 fact remains the CSR did include within its scope a 16 quality documentation review. Part of that review was 17 to establish whether or not indeed an item had been 18 finally -- had been appropriately inspected and that 19 inspection documented on the appropriate form. 20 JUDGE GROSSMAN: Okay. 21 Mr. Guild, I'm not suggesting that, to the extent 22 that the CSR program didn't identify or didn't attempt 23 to identify the missing documentation that might have j (]) 24 been required for the 35 percent, you don't have another 25 area in which the CSR review hasn't, in effect,
~~~
nnnnvnn nonnrv<nn norv4ea. r&a. Gedeva', Illi5ois 60134
13526 A 1 validated the original QC inspection. 2 There may be that additional area, but you can't go 3 much further than that -- 4 MR. GUILD: Understood. 5 JUDGE GROSSMAN: -- is what I'm saying. 6 MR. GUILD: Understood, Judge. 7 JUDGE GROSSMAN: Okay. That's fine. 8 Continue. 1 9 BY MR. GUILD: 10 0 Now, indeed, of the sample of 130 conduit hangers, 41 of 11 them did not have a configuration hanger inspection O 12 form? , ! 13 A (WITNESS KAUSHAL) That's what the memorandum says. i 14 Q All right, sir. 15 However, in the area of cable pan hangers, there 16 were only two instances identified? 17 Again, I'm looking at the memo. l 18 A (WITNESS KAUSHAL) What part are you looking at? l ] 19 0 Just the next sentence there: "For cable pan hangers, 20 only two of 138 CSR sample cable pan hangers had 21 unavailable inspection forms." 4 22 A (WITNESS KAUSHAL) Correct. 23 Q All right, sir. And in each of those cases, the 41 for the conduits (]) 24 25 and the two for the cable pan hangers, those snnntag nopnrti ng servi c. . r+a_
. ~ - - _ _ . - _ . , _ _ _ _ _ _ _ _ _ ,
Geneva, _ Illinois 60134
4 13527 O 1 observations were invalidated?
.2 A (WITNESS KAUSHAL) That's correct.
3 0 All right, sir. > 4 Now, the second page of this memo, the memo of 5 September 5,1985, states, "The-BCAP Level III 6 Inspector, Mr. L. Shea, concurs that these observations
- - 7 identified on the attachment may be appropriately 8 considered invalid.
9 "However, the BCAP Level II Inspector who 10 originally performed the documentation review did not 4 i 11 concur."
- ~O 12 A Correct.
2 (WITNESS KA'USHAL) 13 Q Again, a committee was* formed, pursuant to BCAP-06, to 14 review the invalidation? . 15 A (WITNESS KAUSHAL) That's correct. 16 0 All right. 17 Again, the assistant BCAP director, Mr. Orlov, 18 appointed the committee? 19 A (WITNESS KAUSHAL) Right.
- 20 Q He appointed himself, Mr. Shea and Mr. Patel?
21 A (WITNESS KAUSHAL) That's correct. 22 O You concurred in their recommendation that the matters 23 be treated as invalid? () 24 A (WITNESS KAUSHAL) That's correct. 25 0 And that concurrence is reflected by your note appended i r NAMMFAM D a nn P f 4 M n NDPU$PA. I.f A _ Geneva, Illinois 60134
13528
'O l 1 to the memo?
)
2 A (WITNESS KAUSHAL) That's correct. 3 Q Now, what was the basis for the BCAP Level II 4 Inspector's objection to the invalidation of these
- 5' observations, Dr. Kaushal?
6 A (WITNESS KAUSHAL) As relayed to me, as I recall, he 7 basically felt that he went out there with a checklist 8 to look for documentation and didn't find it; and so as 9 far as he was concerned, the observation -- he made an 10 appropriate observation. 11 Q Now, that was related to you. 3 () 12 Related to you by whom? 13 A (WITNESS KAUSHAL) By the members of the committee. 4 14 0 I see. 15 Did you speak with the original Level II Inspector? 16 A (WITNESS KAUSHAL) No, I did not. t 17 0 Do you know who the Level II Inspector was in this case? 18 A (WITNESS KAUSHAL) I don't recall, no.
- 19 Q Does any member of the panel know the identity of the 20 Level II Inspector in this case?
21 A (WITNESS WOZNIAK) I don't specifically recall, no, 22 sir. l1 i 23 0 Okay. () 24 Do you know whether the committee met as a group to 25 discuss the matter? 4
- _ b a m -
_ _ G_e5_eva',_.I1115ois_60_1_34 _. _ __ _ _ _ __
13529 i 1 This is the same line of questioning as before. 2 A (WITNESS KAUSHAL) I don' t know that. 3 Q Do you know whether they met as a group with the 4 objecting inspector? 5 A (WITNESS KAUSHAL) They probably did not, but I don't 6 know that. 7 Q Do you know whether they documented the basis for the 8 objecting-inspector's objection? 9 A (WITNESS KAUSHAL) The documentation that you see is 10 the documentation there. I doubt that there,'s more i 11 - documentation than that on'that subject. O 12 Q Did you ever review a written documentation of the 13 objecting inspector's basis for objection before you 14 concurred with the invalidation? 15 A (WITNESS KAUSHAL) What was the question again? 16 Q Did you review a written description of the objecting
; 17 inspector's basis for objection before you concurred in 18 the invalidation recommendation of your committee?
19 A (WITNESS KAUSHAL) No, I did not. I based my decision- , 20 on the information described herein. 21 JUDGE GROSSMAN: Mr. Guild, do we know when 22 the walkdowns occurred? 23 MR. GUILD: Yes. We're going to turn to that () 24 question now. 25 Bef ore I do, let me of fer Intervenors' 150, please, i annntag nonnreing coru4c.; r.*a _ Geneva, Illinois 60134 __, _ _ ___ _
4 I i s . 13530
'k ) -
i 1 into evidence. 2 JUDGE GROSSMAN: Any objection? 3 MR. BERRY: None f rom the Staff. ; 4 MR, STEPTOE: Well, with respect to the first 5 part, I have no objection. 1 6 I think we probably have an obligation to the Board 7 to provide some legible copies, if we need to, on 8 redirect. 9 But I have no objection to this portion.
- 10 JUDGE GROSSMAN
- Okay. You're going to 11 supply legible copies for the detail?
f 12 MR. STEPTOE: I'll provide another exhibit at 13 redirect with respect to the detail, that's correct, so 14 it may be easier for everyone to read. 15 JUDGE GROSSMAN: All right. 16 But otherwise there's no objection, and so -- 17 MR. STEPTOE: With respect to the last l 18 memorandum, which is BCAP Memo No. 3240, it deals l 19 exclusively with a documentation-related problem rather l 20 than a reinspection-related matter. 21 It is, as you recognized, as Mr. Guild recognized, 22 outside the scope of our direct testimony, which dealt 23 only with the reinspection portion of the CSR. () 24 I object on that grounds: It's outside the scope 25 of the witnesses' testimony. But since you -- I make i
- nnnne g n.nnr e ing noroir., r.*a -
Geneva, Illinois 60134 ,
13531
.o 1 the objection, for what it's worth.
2 JUDGE GROSSMAN: Okay. The Board didn't 3 agree that it was outside the scope. ! 4 MR. STEPTOE: No. I think -- I 5 JUDGE GROSSMAN: We just -- i 6 MR. STEPTOE: I know you didn't. I'm sorry. 7 JUDGE GROSSMAN: Okay, fine. 8 Any objection f rom Mr. Berry? 9 MR. BERRY: No objection f rom the Staff, Mr. 10 Chairman, 11 JUDGE GROSSMAN: Okay. We'll receive the 12 document. . 13 (The document was thereupon received into 14 evidence as Intervenors' Exhibit No. 15 150.) 16 BY MR. GUILD:
- 17 0 All right, sir. )
l , 18 Now, indeed, as the last memo relating to the i ! 19 documentation issue reflects, in the vast majority of 20 cases in your CSR cable pan hanger sample, there were, 21 in fact, Comstock or Ernst inspection documents for 22 configuration inspections; only two of 138 had them
; 23 missing.
l 1 () 24 It follows, does it not, Dr. Kaushal, that there l 25 were 136 that had the documentation? i Rnnnken Dennrbinn Rarv4re. T.V d . Geneva, Illinois 60134 j
i 13532 6 I i 1 A (WITNESS KAUSBAL) That's what this wculd imply, yes. 2 0 All right, sir. 3 And, in fact, CSR inspectors went out and inspected 4 and identified configuration discrepancies in the area 5 of cable pan hangers? 6 A (WITNESS KAUSHAL) That's correct. 7 0 And those discrepancies, at least in part, were 8 determined to be valid discrepancies, valid discrepant 9 conditions, as compared -- comparing the field-observed 10 condition for configuration with design requirements? 11 A (WITNESS KAUSHAL) You' re calling them " valid. "- 0 12 I don't know if a validity determination was made, 13 but the inspectors did go out and do the inspections. 14 Q Well, sir, let me show you again what I just grabbed off.
- 15 the stack of Attachment 6 of NCR 6145, out-of-scope 16 electrical NCR, the very first observation for cable pan 17 hangers.
18 This observation for cable pan hanger -- for Sample 19 Item CPH-001, observation 2, reflects that the 20 configuration observation was deemed valid, does it not? 21 (Indicating.) 22 A (WITNESS KAUSHAL) At one time it was deemed valid, 23 yes. (]) 24 0 All right, sir. 25 Well, it was checked in the " valid" box, and annneng nannrei ng moruico, r+a. 1 Geneva, Illinois 60134
13533
'O
, 1 there's a valid -- a statement written and then it is 2 marked through? 3 A (WITNESS KAUSBAL) That's what I -- that's why I said 4 4 at one time it was deemed valid. 5 Q All right, sir. 6 And can you tell me whose signature or whose 7 initials and date appear by the mark-through on the 8 evaluation portion? 9 (Indicating.)
- 10 A (WITNESS KAUSHAL) No, I'm afraid I don't recognize 11 those initials.
O 12 Q Could you pass the document along the line of panel 13 members and ask each of them if they can identify the 14 initials? 15 A (WITNESS KAUSHAL) (Indicating.) 16 A (WITNESS WOZNIAK) Mr. Guild, I believe I can identify 17 the initials. l 18 Q Yes, sir? 4 19 A (WITNESS WOZNIAK) He's a member of the BCAP CSR 20 engineering force. He's a discipline engineer. His 21 na'me is Mr. Patel, also. His first name starts with a 22 V. I 23 Q v as in " Victor"? () ~ 24 A (WITNESS WOZNIAK) Yes, sir. i 25 MR. GUILD: All right. RnnnVan nonnrV4 nn noru4ea. T.V A . Geneva, Illinois 60134 1
13534 1 I'd ask that the document be marked. I intend to 3 offer it. I'll make some copies for the Board and 3 pa rties. The portion I showed the witnesses is the 4 third page of the document. 5 (Indicating.) 6 I'd ask this observation record, 7 CSR-I-E-CPH-001-02, be marked as Intervenors' Exhibit 8 151. 9 (The document was thereupon marked 10 Intervenors' Exhibit No.151 for 11 identification as of October 3, 1986.) 12 BY MR. GUILD: - 13 Q Now then, Dr. Kaushal, though determined invalid -- 14 excuse me -- determined to represent a valid discrepant 15 condition, a configuration discrepancy as compared to 16 design requirements, this observation, along with all 17 other cable pan hanger observations, was deemed outside 18 the BCAP scope? 19 A (WITNESS KAUSHAL) That's correct. 20 0 And as a consequence, none of the discrepant conditions 21 were counted in the CSR results? 22 A (WITNESS KAUSHAL) That's correct. 23 Q Now, the observation, Part 3, Block 16, reads, "This (]) 24 observation is covered by future walkdown to be 25 performed as per Sargent & Lundy procedure PI-BB-85," gnnneng nonnr e4 ng servi c. . r.ea _ Geneva, Illinois 60134
13535
/
f 1 paren, "(NCR's 708 and 709) ," and paren. 2 "Therefore, as per BCAP-06, Section 4.3.3 little f, 3- this observation is outside BCAP's scope."
-i 4 And that evaluation was by Mr. D. Patel?
5 (Indicating.) 6 A (WITNESS KAUSHAL) That's correct. 7 0 Now, that observation -- I'm sorry -- that evaluation 8 was made and is dated June 14, 1985; correct? 9 (Indicating.) 10 A (WITNESS KAUSHAL) That's correct. 11 Q Now, that appears to reflect that the walkdown that was
'O /
12 contemplated as the basis for declaring this observation 13 out of scope was not yet -- had not yet been completed; 14 is that true? 15 A (WITNESS KAUSHAL) I don't know whether that signature 16 signifies that, but -- and I don't -- I don't recall 17 when that walkdown was -- in fact, I know the walkdown 18 was not completed at that time. 19 Q It was not? l 20 A (WITNESS KAUSHAL) No. 21 Q Mr. Patel writes that -- he describes it as a " future ! 22 walkdown." l 23 - It was a future walkdown as of June of 19857 () 24 A (WITNESS KAUSHAL) That's correct. 25 Q Now, the walkdown was cited as pursuant to a Sargent & l
- nnnneng nonnretng garvic._ r+a.
L Geneva, Illinois 60134
b 13536 (O 1 Lundy procedure, and the references are to NCR's 708 and 2 709. 3 Dr. Kaushal, are you familiar with NCR's 708 and 4 4 709? 5 A (WITNESS KAUSHAL) I have looked at it, yes. 6 O All right, sir. 7 708 refers to Unit 1; 709 to Unit 27 8 A (WITNESS KAUSHAL) I believe that's correct. 9 Q All rig'ht, sir. 10 And what is the nonconforming condition that is 11 identified in those NCR's?
'O, 12 A (WITNESS KAUSBAL) I would not be,able to recall the. .
13 exact words. It talks about cable pan hangers being not 14 constructed per design detail. i ) 15 0 All right, sir. 16 Well, isn't it a fact that those NCR's for j 17 Braidwood were initiated as a result of lessons learned l 18 through the Byron licensing proceeding? l 19 A (WITNESS KAUSHAL) That was, I believe, one of the 20 reasons, yes. 21 0 Because of identified problems with vendor-supplied 22 Systems Control Corporation cable pan hangers? 23 A (WITNESS KAUSHAL) That's one of the reasons I am aware O 24 of, yes. 25 0 All right, sir. i AnnnFag Donnr F4 ng Rogui en ,_ T.F A - ! . Geneva, Illinois 60134
13537 (D 1 Now, a cable pan hanger as supplied by the vendor 2 by definition already has a configuration, does it not? 3 A (WITNESS KAUSHAL) Yes, in most cases. They may have 4 in part been supplied, but that's correct in general. 5 0 All right, sir. 6 So if only part of the configuration problem with 7 . the field-installed cable pan hangers can possibly be 8 attributed to Systems Control Corporation, it follows, 9 does it not, Dr. Kaushal, that the balance of the 10 configuration attributes are attributable to the L. K. 11 Comstock or E. C. Ernst installation of the cable pan
-() 12 hangers in the field?
13' A (WITNESS KAUSHAL) That's correct, yes. 14 Q In part, L. K. Comstock or E. C. Ernst may 15 field-fabricate cable pan hangers? 16 A (WITNESS KAUSBAL) My understanding is yes, some were 17 field-fabricated, yes. 18 Q And in part L. K. Comstock and E. C. Ernst may 19 field-modify hangers? 20 A (WITNESS KAUSHAL) That's correct, too, from what I 21 understand. 22 Q By that I mean they may modify the hanger from the form 23 in which it was received f rom the vendor; in this case, ! 24 Systems Control Corporation? (]) 25 A (WITNESS KAUSHAL) That's my understanding, yes. nnnneng nopnreing noruico. r+a. Geneva, Illinois 60134 _ _ _
13538 ,
'O.
1 Q All right, sir. 2 So some numbers of attributes, configuration 3 attributes, of these cable pan hangers are really beyond 4 the scope of any deficiencies attributable to the 5 Systems Control Corporation? 6 A (WITNESS KAUSHAL) Yes. I would think there would be 7 some attributes that might be outside of Systems 8 Control. 9 O All right, sir. 10 And, theref ore, some of the field-observed 11 discrepant conditions observed by your CSR inspectors
.O 12 . with regard to configuration of cable pan hangers are 13 attributable not to Systems control Corporation but to 14 the work of E. C. Ernst or the L. K. Comstock Company?
15 A (WITNESS KAUSBAL) That's correct, yes. l 16 Q All right. , 17 How many deficiencies in cable pan hanger 18 configuration are attributable to the work of Ernst or 19 Comstock as contrasted with Systems Control? 20 A (WITNESS KAUSHAL) I would not know that number. 21 Q Does any other member of the panel know the answer to 22 that question? 23 A (WITNESS WOZNIAK) No, sir. - () 24 Q Dr. Kaushal, I'm going to show you another document, an 25 earlier NCR. This is identified as CECO NCR 451. l l sonneng nennrti ng servic . r+a_ i- - _ _ _ _ . _ _ _ _ ______ . Geneva, Illinois,_,60134_ __
13539
.o 1 (Indicating.)
2 This is on the subject of cable pan hanger welding. 3 It reflects an initiation date of December, it looks 4 like, 21,1982. 5 MR. GUILD: Mr. Chairman, I ask that this 6 document be marked as Intervenors' Exhibit 152. 7 (The document was thereupon marked 8 Intervenors' Exhibit No.152 for identification as of October 3,1986.) 9 10 BY MR. GUILD: 11 Q Now, Dr. Kaushal, have you ever seen this NCR before? O 12 A (WITNESS KAUSHAL) No, I don't rec,all seeing it. 13 Q Also, the description of nonconf ormance reads, " System 14 Control hanger welding does not meet AWS D1.1-75." 15 Paren, "(Attached are inspection results for 25 of 131 16 hangers f rom Shipment No. 52 MRR 1144) ," end paren. 17 Now, this is a copy that was given to me in 18 discovery. It appears to reference an attachment 19 showing inspection results. I don't see that attachment 20 in the form of the NCR that I have received. 21 Is it your understanding, Dr. Kaushal, that the 22 results of the inspection, the sampling inspection, of 23 Systems Control Corporation vendor-supplied hangers that () 24 took place in response to NCR 451 led to the conclusion j 25 that the hangers were acceptable? nnnneag nonnreing norvino, r+a. Geneva, Illinois 60134
\
13540
<O 1 A (WITNESS KAUSHAL) What was the question?
2 0 Yes, sir? 3 A (WITNESS KAUSHAL) That it was not -- 4 Q That the inspection led to the conclusion that the 5 hangers were acceptable. 6 A (WITNESS KAUSHAL) I don't have any opinion on that. 7 Q You don't know? , 8 A (WITNESS KAUSHAL) I don't know, yes. 9 MR. GUILD: I apologize to the Board. I 10 thought I had the complete document or, at least, 11 complete in regard to the documented result.
,o i 12 Perhaps I could ask Applicant, if there's an 13 attachment that's missing, whether I could be provided a 14 copy of it, please.
15 MR. STEPTOE: We'll be glad to provide the 16 complete NCR. 17 JUDGE GROSSMAN: Okay. 18 BY MR. GUILD: 19 0 In any event, Dr. Kaushal, if the existence of an NCR 20 originated in December of 1982 appears to reflect that 21 whatever problems existed with cable pan hanger welding 22 that was attributable to Systems Control Corporation had 23 been identified years ago, wouldn' t you presume, sir, () 24 that timely corrective action would have called for 25 having identified and corrected whatever problems there snnneag n.pnreing s.ruic._ r.ea . Geneva, Illinois 60134
l 13541
)
1 were with Systems Control Corporation cable pan hanger 2 welding long before the BCAP CSR reinspections took 3 place? 4 A (WITNESS KAUSHAL) I would not assume that, no. 5 0 All right, sir. 6 What is the relationship between the CECO NCR 451, 7 the document I've just placed before you, and the CECO 8 NCR's 708 and 709 that apparently are the basis for the 9 Sargent & Lundy cable pan hanger walkdown? 10 A (WITNESS KAUSHAL) Do you have a copy of 708 and 709 in 11 front of you? o 12 0 I don't. . 13 A (WITNESS KAUSHAL) I'm sorry? 14 0 I do not. 15 A (WITNESS KAUSHAL) I'll have to recall the words. 16 My understanding is that on 708 and 709, it talks 17 about the hangers not being constructed as per design 18 detail. i 19 0 708 and 709 also refer to Systems Control Corporation? 20 A (WITNESS KAUSHAL) I believe there is a -- there is a 21 mention of Systems Control. 22 0 I see. 23 Why weren't whatever deficiencies existed in () 24 Systems Control Corporation cable pan hangers corrected j 25 before the initiation of the Sargent & Lundy cable pan i snnneng n.pnreing ceruice, r+a-Geneva, Illinois 60134
13542 1 hanger walkdown pursuant to NCR's 708 and 709? 2 A (WITNESS KAUSHAL) I wouldn't know the answer to that. 3 Q Now, that's a long way around getting back to the 4 question that the Chairman asked. 5 What is the status of the Sargent & Lundy cable pan 6 hanger walkdown? 7 A (WITNESS KAUSHAL) My understanding is that walkdowns 8 are complete on cable pan hangers now. 9 0 When were they completed, sir? ' 10 A (WITNESS KAUSHAL) It was sometime in the middle of -- 11 I'm sorry. Just a second. I'm trying to recall. O 12 O Sure. 13 A (WITNESS KAUSHAL) It was a few months ago, but I don't 14 recall the exact time. 15 Q Do any of the other members of the panel know when the 16 cable pan hanger walkdown program was completed? 17 A (WITNESS WOZNIAK) Not specifically. 18 0 Mr. Wozniak, is it your understanding that it was 19 completed several months ago? 20 A (WITNESS WOZNIAK) It's been completed, but again I 21 don't know when it was completed. 22 Q Now, do I understand correctly that the cable pan hanger 23 walkdown program was performed by Sargent & Lundy field I () 24 engineers? 25 A (WITNESS KAUSHAL) It was -- your understanding is Annn&ng popnve4ng coruico, r+a. Geneva,. Illinois 60134 __
13543 (Q 1 incorrect. 2 Q How about straightening me out? 3 A (WITNESS KAUSBAL) Okay. 4 My understanding is that the walkdown was performed 5 by a combination of Sargent & Lundy and Comstock -- 6 Sargent & Lundy engineers and Comstock inspectors and 7 that the configuration inspection was, in f act, done by 8 Comstock inspectors. 9 0 Well, sir, did the -- so in part Sargent & Lundy field 10 engineers performed the walkdown? 11 A (WITNESS KAUSHAL) Sargent & Lundy engineers in part i 12 perf ormed the walkdown, yes. 13 Q All right, sir. 14 And in part L. K. Comstock inspectors participated 15 in that walkdown? 16 A (WITNESS KAUSHAL) That's correct. 17 0 Now, did the L. K. Comstock inspectors perform a 18 configuration inspection of the cable pan hangers to the 19 original design requirements and identify any 20 discrepancies between those design requirements and the 21 as-built condition of the hangers? 22 A (WITNESS KAUSHAL) Mr. Guild, as I understand the 23 walkdown, the purpose of the walkdown was not to () 24 identify the existing deficiencies and to record them. 25 The purpose was to go identify what was there in snnneng nonnreing servic._ r+a. Geneva, Illinois 60l34 j
13544 . -O 1 the field, develop f rom those inspections drawings of 2 as-built conditions and then for Sargent & Lundy, by 3 design -- analysis of the design, to establish whether 4 the condition as it existed in the field was acceptable 5 or not. 6 If there were modifications to be made, they were 7 then released as revisions to the drawings. 8 0 $o the answer to my question is no? 9 A (WITNESS KAUSHAL) What -- I don' t know what I' m 10 answering to now, Mr. Guild. You will have to repeat 11 the~ question. 12 Q The question is: Did the Comstock inspector 6 identify 13 discrepancies between the as-built condition and the 14 original design requirements? 15 The answer to that is no, is it not? 16 A (WITNESS KAUSHAL) That's correct. 17 0 To the extent that such discrepancies exist, Dr. Kaushal i 18 -- by that I mean to the extent the discrepancies in the 19 configuration of these cable pan hangers existed at the 20 time the walkdown was initiated -- those discrepancies 21 would represent f ailures by the original Comstock 22 Quality Control Inspectors to effectively inspect the 23 hangers in the first instance? Ih 24 A (WITNESS KAUSHAL) I can' t answer that question without 25 knowing the specifics. Rnnnf ag Donnrf 4 ng Rorv4 ro. T.f A . Geneva, Illinois 60134
13545 O 1 If you' are assuming that there was a fully 2 QC-accepted record existent on that hanger, then your 3 conclusion would be correct. 4 Q All right, sir. 5 And to the extent that the CSR inspectors 6 identified discrepant conditions in the field-observed 7 condition of the hanger configurations, cable pan hanger 8 configurations, those, too, represented instances where 9 the original Comstock inspector failed to identify 10 discrepant conditions? 11 A (WITNESS KAUSHAL) Again assuming that there was an 12 original fully QC-accepted condition existent, that
~
13 would be correct. 14 0 Well, it wouldn't have been in the CSR sample if it had 15 not been fully QC-accepted? 16 A (WITNESS KAUSHAL) That is not accurate, Mr. Guild. 17 As I pointed out before, they can be partial. 18 Something can be essentially QC-accepted, but there can 19 be portions thereof that are not, on which there is an 20 outstanding rework or other item pending. 21 So there can be a discrepancy on an item that was 22 in the sample that was QC-accepted and completed, but 23 there were specific attributes or specific portions that . () 24 25 were not fully QC-accepted and completed. Yes, sir. 0 snnneag n pnrei ng garvic.. r+a. Geneva, Illinois 60134 _ _ _ _ _ __
13546 ' O 1 If that instance occurred, though, the item would 2 be declared an invalid observation under CSR -- 3 A (WITNESS KAUSHAL) That's correct. 4 Q In these cases they were declared out of scope because 5 of the walkdown? 6 A (WITNESS KAUSBAL) That is correct. 7 0 As least in the case of the observation that was the 8 first one in the stack, the observation of Cable Pan 9 Hanger 001, Observation No. 2, there was a valid 10 discrepancy in the configuration of that hanger? 11 A (WITNESS KAUSHAL) It~would be my expectation that that [( 12 , one would have been valid, yes, if it were not for the 13 walkdown. 14 0 And the validity of that observation indicates that that I 15 particular hanger, for the configuration attributes 16 found rej ectable, had been final QC-accepted? 17 A (WITNESS KAUSHAL) For the deficiencier -- for the 18 discrepancies that were identified and considered valid, 19 that would be the case, yes. 20 0 All right, sir. 21 Was there a walkdown by Sargent & Lundy, an 22 as-built walkdown of the sort you just described for 23 cable pan hangers, for cable pans? I 24 A (WITNESS KAUSHAL) I don't -- I'm not -- I don't recall 25 at this time any walkdown for cable pans. Sonntag Reporting Service, Ltd. Geneva, Illinois bulae i N !
13547' p tL_) 1 Q All right. 2 Are any other members of the panel aware of a 3 walkdown of the cable pans? 4 A (WITNESS WOZNIAK) I don't recall any at this time.
? O All right.
6 There was a walkdown for conduit hanger 7 configuration, was there not -- 8 A (WITNESS KAUSHAL) That's correct. 9 Q -- by Sargent & Lundy under the same general 10 organizational approach you described for cable pan 11 hangers? O 12 A (WITNESS KAUSHAL) No. - 13 In fact, for conduit hangers, the walkdown was done 14 specifically for the purpose of identifying the status 15 of construction in the field. 16 0 This was the question of whether the conduit was 17 attached to the hanger? 18 A (WITNESS KAUSHAL) That was one of the purposes, yes, 19 0 So there's not an -- was it an as-built configuration 20 walkdown as well? 21 A (WITNESS KAUSHAL) There was -- configuration was 22 included in that. i l 23 Q Did they as-built the hangers? l [\ WJ 24 A (WITNESS KAUSHAL) I don't know if it was as-built in l 25 every case. snnn+ng nepnreing servica. r+a_ Geneva, Illinois 60134
13548 1 In some cases or in a large number of cases, they 2 might have gone in the field and found that the as-built 3 condition was in accordance with the design and so the 4 design represented the as-built condition. 5 0 Well, what I'm trying to understand is: For conduit 6 hangers, did Sargent & Lundy prepare as-built drawings 7 and make engineering evaluations of the as-built 8 condition to the extent that that condition differed 9 from the as-designed condition? 10 A (WITNESS KAUSHAL) Yes, in those cases, yes, I believe ( 11 they did.
-b~ 12 0 In cases where they identified differences between the 13 as-built and the design condition?
14 A (WITNESS KAUSHAL) That's correct. 15 0 All right, sir. 16 In those cases where there were differences between 17 the as-built and the design condition, did the L. K. 18 Comstock inspectors perform a prior configuraticr. 19 inspection and document any' discrepant conditions? 20 A (WITNESS KAUSHAL) I would assume so, but I cannot 21 vouch for that in every case. 22 0 Well, did they do it in a way that was different f rom 23 the cable pan hanger walkdown? [ J 24 A (WITNESS KAUSHAL) Oh, excuse me. Maybe I answered the 25 wrong question. I thought you were asking something l gnnneng nopnreing noruica. r+a_ i Geneva, Illinois 60134
13549 0 1 else before. 2 My response before was -- did Comstock QC 3 Inspectors, in their normal first-line QC inspections, 4 perform inspections on those conduit hangers? Was that 5 your question? 6 Q No, but you assume they did? 7 A (WITNESS KAUSHAL) That was my answer, yes. 8 0 Now I'm focusing on the walkdown. 9 Was the role of the Comstock inspector similar for 10 the conduit hanger walkdown as it was for the cable pan 11 hanger walkdown? (~3. 12 A (WITNESS KAUSHAL) No. In fact, I didn't state that. 13 Comstock inspectors were party to the conduit hanger 14 walkdown. 15 0 All right, sir. I presume too much. 16 Were they, to your knowledge, Comstock inspectors? 17 A (WITNESS KAUSHAL) To my knowledge, they were not. 18 0 All richt. 19 To your knowledge, was there any reinspection of 20 the conduit hangers by Quality Control Inspectors, af ter 21 the final QC acceptance but before the Sargent & Lundy 22 walkdown, to identify and document configuration 23 discrepancies? 24 A (WITNESS KAUSHAL) Maybe I'm having some problem, Mr.
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25 Guild. nnnneng nannrei ng moruica _ r+a.
. Geneva, Illinois 60134 __
b 13550
/
1 Would you repeat that question again? 2 0 I'll try. 3 If the Sargent & Lundy engineers in the conduit 4 hanger walkdown performed as-built drawings and made 5 engineering determinations of the acceptability of those 6 as-built conditions where they differed f rom the 7 as-designed condition -- and I understand you to say 8 that they did; correct? 9 A (WITNESS KAUSHAL) In some cases they might have, yes. 10 Q All right. 11 Was that as-built evaluation preceded by a sqF..) . i 12 documentation by Quality Control Inspectors of the 13 discrepincies identified in the as-built condition as 14 compared with the as-designed condition? 15 A (WITNESS KAUSHAL) To my knowledge, no. 16 MR. GUILD: Mr. Chairman, that concludes that 17 line of questioning. 18 I would like to offer Intervenors' 151, which is 19 the BCAP observation record for the cable pan hanger 20 out-of-scope observation, which I'll copy and distribute 21 to the Board and parties; and Intervenors' 152, which is 22 CECO NCR 451 on the Systems Control Corporation.
- 23 JUDGE GROSSMAN
- Okay. Both of these will be 24 supplied by Applicant on Monday, I assume, or they'll be
( 25 completed. 152 is not complete. snnneng papnreing servica_ r.e a .
.__eneva,__
G _ Illinois 60134
13551
-s tJ l Now, are there any objections to the admission of 2 the complete documents when they' re supplied?
3 They'll be admitted now, of course, if there are no 4 objections, and supplied on Monday. 5 MR. STEPTOE: No objection with respect to 6 Intervenors' Exhibit No.151. 7 With respect to Intervenors' Exhibit 152, the full 8 copy of NCR 451, I'm told, is pretty big. 9 JUDGE GROSSMAN: Okay. 10 MR. STEPTOE: I have -- 11 JUDGE GROSSMAN: Judge Cole just pointed out 1 12 to me that we have at least 82 pages in there. ^ 13 MR. STEPTOE: Maybe more. 14 MR. GUILD: It might be helpful, Mr. 15 Chairman, if we had a copy to refer to. 16 JUDGE GROSSMAN: Okay. We'll reserve 17 judgment. Why don't you reserve your offer -- 18 MR. GUILD: All right, sir. 19 JUDGE GROSSMAN: -- for Monday until you have 20 the completed document. 21 Mr. Berry, I take it there's no objection by you? 22 MR. BERRY: No, no. 23 JUDGE GROSSMAN: Okay. So we'll admit 151 () 24 25 now, and no offer having been made on 152, we won't rule on that.
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nnnnvan nennrH nn nervice. u-a . ____Ge5eva',.Illi5ois 6013_4_ _ .___ _ _ _ __ _
13552 1 (The document was thereupon received into 2 evidence as Intervenors' Exhibit No. 3 151.) 4 JUDGE GROSSMAN: Unless there's something 5 further that we ought to hear now, we'll adjourn until 6 Monday at 2:00 o' clock. 7 Is there anything further? 8 MR. GUILD: Not from Intervenors. 9 JUDGE 'GROSSMAN : Okay, fine. Then we're 10 adjourned. 11 (WHEREUPON, at the hour of 11:00 A. M., 12 the hearing of the above-entitled matte,r 13 was continued to the 6th day of October, 14 1986, at the hour of 2:00 o' clock P. M.) 15 16 17 18 19 i 20 21 22 23 25 l snnntag nepnreing snrvice. r.ra _ l Geneva, Illinois 60134 _ _ _ _ _
NO PAGE NUMBER CERTIFICATE OF OFFICIAL REPORTER b;- L This is to certify that the attached proceedings before the UNITED STkTES NUCLEAR REGULATORY COMMISSION in the matter of: NAME OF PROCEEDING: BRAIDWOOD STATION UNITS 1 6 2 COMMONWEALTil EDISON DOCKET NO.: 50-456-457/0L PLACE: CillCAGO, ILLINOIS DATE: , FRIDAY, OCTOBER 3, 1986 were held as herein appears, and that this is the originai transcript thereof for the file of the United States Nuclear Regulatory Commission. (sigt) d/K[Af (TYPED) NancyfJ. Hhph Official Reporter Reporter's Affiliation t3. %
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