ML20211A434
| ML20211A434 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 10/08/1986 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| CON-#486-1214 OL, NUDOCS 8610150129 | |
| Download: ML20211A434 (174) | |
Text
ORlG N AL
-- 4 UN11ED STATES .
NUCLEAR REGULATORY COMMISSION IN THE MATTER OF: DOCKET NO: 50-456 OL 50-457 OL COMMONWEALTH EDISON COMPANY (Braidwood Station, Units 1 and 2)
Oy LOCATION: CHICAGO, ILLINOIS PAGES: 13859 - 14131 DATE: WEDNESDAY, OCTOBER 8, 1986 O
\
ACE-FEDERAL REPORTERS, INC.
q2 OfficialReporters 444 North CapitolStreet Washington, D.C. 20001 S t.101 y.1 ;> (202) 347-3700 n ot: Anec ,
NATIONWIDE COVERAGE L
13859
\
n ,'
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 13 859 - 14131 11 United States District Courthouse x Courtroom 1919
/ h 12 219 South Dearborn Street
't / Chicago, Illinois 60604 13 Wednesday, October 8, 1986.
14 15 The hearing in the above-entitled matter reconvened 16 at 9:00 A. M.
17 BEFORE:
18 JUDGE HERBERT GROSSMAN, Chairman 19 Atomic Safety and Licensing Board U. 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 JUDGE A. DIXON CALLIHAN, Member, 24 Atomic Safety and Licensing Board 4 25 U. S. Nuclear Regulatory Commission Washington, D. C.
g_ Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13860
/
/ ,
w/
1 APPEARANCES:
2 On behalf of the Applicant:
3 MICHAEL I. MILLER, ESO.
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. CH AN , ESQ.
U. S. Nuclear Regulatory Commission 9 7335 Old Georgetown Road Bethesda, Maryland 20014 10 On behalf of the Intervenors:
11 ROBERT GUILD, ESQ.
12
('
'v 13 14 15 16 17 18 19 20 21 22 23 24 25 Sonntag Reporting Service, Ltd.
Geneva, Illinois 60144 f (312) 232-0262 ;
13861
~
U 1 EXHIBIT INDEX Marked Received 2 Intervenors' Exhibit No. 146 13940 3 Applicant's Exhibit No. 133 13907 4 Applicant's Exhibit No. 134 13908 13916 5 Applicant's Exhibit No. 135 13927 13940 6 Applicant's Exhibit No. 136 13948 13968 7 Applicant's Exhibit No. 137 13967 13967 8 Applicant's Exhibit No. 138 13973 9 Applicar.t 's Exhibit No.13 9 13979 13981 10 Applicant's Exhibit No. 140 13988 11 Applicant's Exhibit No. 141 13995 13995
[ ) 12 Applicant's Exhibit No.142 14d35
\d 13 14 15 16 17 18 19 20 21 22 23 24 dlll 2, Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13862 f%
s-1 TESTIMONY OF 2 NARINDER NATH KAUSHAL EDWARD M. SHEVLIN 3 JOHN R. WOZNIAK NEIL P. SMITH 4 GEORGE MICHAEL ORLOV 5
REDIRECT EXAMINATION (Continued) 6 BY MR. STEPTOE: 13866 7 VOIR DIRE EXAMINATION BY MR. GUILD: 13959 8
REDIRECT EXAMINATION (Continued) 9 BY MR. STEPTOE: 13960 10 TESTIMONY OF GEORGE MICHAEL ORLOV 11 DIRECT EXAMINATION
-s BY MR. STEPTOE: 13982 i 12 CROSS EXAMINATION 13 BY MR. GUILD: 14035 14 15 16 17 18 19 l 20
< 21 22 l 23 l 24 25 i
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262 _
13863 C\
t i V
1 JUDGE GROSSMAN: The hearing is reconvened.
2 This is the 71st day of hearing.
3 We ended with Mr. Steptoe on redirect.
4 Is there any preliminary matter before we go on to 5 the witnesses?
6 MR. STEPTOE: Just one, Judge Grossman.
7 Mr. Guild asked me to check yesterday to determine 8 whether Revision H to BCAP Procedure 06, which is 9 Intervenors' Exhibit 143, was made in response to the 10 NRC item of noncompliance regarding the 37 red-line 11 observations and deleted the S & L's checklist box for
( f) 12 " invalid" versus " valid."
O' 13 The answer to that is yes.
14 JUDGE GROSSMAN: Okay. That's fine.
15 MR. STEPTOE: Judge Grossman, with the 16 Board's permission, I thought we'd start by having Mr.
17 -- begin with the discussion of cable inspections by 18 having Mr. Wozniak explain, using a demonstrative 19 exhibit, what BCAP inspectors .4.nspected.
20 JUDGE GROSSMAN : Okay. That's fine.
21 MR. STEPTOE: I have it here, and it's not 22 easy to see. You won't be able to see it from where he 23 is.
24 May I ask that he approach the bench?
\t 25 JUDGE GROSSMAN: Certainly.
t.V Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13864 1 I hope you're not going to offer that exhibit.
2 (Laughter.)
3 MR. STEPTOE: I'll make appropriate copies.
4 (Laughter.)
5 No. I'm not planning to offer the exhibit.
6 If any party believes it should travel with the 7 record, we will arrange for it to be taken to Washington 8 as a demonstrative exhibit.
9 I believe there are provisions in the federal rules 10 for those things, but I don't know whether it will be 11 necessary.
12 I think the parties will just have to gather around
(
13 to see this.
14 JUDGE GROSSMAN: Okay. But, now, I would 15 hope the witness will verbalize whatever he's discussing 16 with regard to that exhibit --
, 17 MR. STEPTOE: Okay.
18 JUDGE GROSSMAN: -- because "this" and "that" 19 isn't going to do too much for our transcript here.
20 MR. STEPTOE: Yes. Mr. Wozniak, do you 21 understand --
22 WITNESS WOZNIAK: I do.
23 MR. STEPTOE: -- Judge Grossman's concern?
24 WITNESS WOZNIAK: Yes.
7_
25 MR. STEPTOE: If you want to follow along Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
i
- 13865
's ,
)
I with the BCAP checklist for the cable population, it's 2 in Mr. Wozniak's testimony, attached to his prefiled
- 3 testimony. It's also in the cable package which we 4 still owe you.
5 JUDGE GROSSMAN: Oh, okay.
6 I thought you meant that big --
7 MR. STEPTOE: There are two of them.
8 JUDGE GROSSMAN: Oh, there are, okay. This 9 isn't that big a problem.
10 MR. GUILD: Mr. Steptoe, I've got the cable 11 package that you --
12 MR. STEPTOE: That has the same checklist.
(
13 MR. GUILD: Applicant's 131.
14 MR. STEPTOE: But I don't think the Board has 15 it. Attached to Mr. Wozniak's testimony, one of the 16 checklists is for cables, too.
17 WITNESS WOZNIAK: Mr. Steptoe, in my 18 testimony I do not have the cable instructions.
19 MR. STEPTOE: That's all right. We're just 20 going to go through the checklist.
21 WITNESS WOZNIAK: Okay.
22 JUDGE COLE: Is this the checklist he's going l
! 23 to use?
24 (Indicating.)
) 25 MR. STEPTOE: Yes, sir.
l Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
M 13866
(
(
1 REDIRECT-EXAMINATION 2 (Continued) 3 BY MR. STEPTOE:
j 4 0 Could you identify the first demonstrative exhibit, the 5 small one?
. 6 What are you holding in your hand, sir?
7 A (WITNESS WOZNIAK) I'm holding a four-conductor
, 8 600-volt No.14 wire example attached to a terminal 9 block.
f 10 MR. GUILD: Say that again. A 11 four-conductor --
12 WITNESS WOZNIAK: A four-conductor No. 14 AWG, 13 which is American Wire Gauge, 600-volt control cable, 14 along with a terminal block.
15 BY MR. STEPTOE:
16 0 Now, Mr. Wozniak, the first attribute on the BCAP 17 inspection checklist is cable identification markers.
18 Would you explain how you would do the inspection 19 for cable identification markers?
20 A (WITNESS WOZNIAK) Yes, sir, I would.
21 When we would go and inspect this cable, we would
- 22 find a cellophane adhesive-type marker attached near the 23 point of where the individual conductors would break 25 This cable identification marker would have the
! Sonntag Reporting Service, Ltd.
Geneva, Illinois eU134 (312) 232-0262
13867
,/'N 1 unique cable number along with the segregation code in a 2 color-coded format.
3 0 What would the segregation code be?
4 A (WITNESS WOZNIAK) The segregation code is a unique 5 application of the design service level of the cable.
6 In this case, it would be a C1E with black on green 7 background.
8 The segregation code denotes that the C would be a 9 control cable, that the 1 would be the No.1 reactor 10 protection division, and the E would be the service 11 level of the cable.
\
[d 12 13 Q Now, the second attribute is cable type and size.
JUDGE COLE: Just a minute.
14 MR. STEPTOE: Sure.
15 JUDGE COLE: How does that identification get 16 on the cable?
17 Is it put on by the manuf acturer or at some other 18 time?
19 WITNESS WOZNIAK: It is put on by the 20 electrician doing the identification process.
- 21 MR. GUILD
- There is no such identification 22 on the cable that you're using as an example?
23 WITNESS WOZNIAK: That's correct.
l 24 BY MR. STEPTOE:
7-( 25 0 The second attribute is cable type and size.
l Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13868 V
1 How would you verify that attribute, sir?
2 A (WITNESS WOZNIAK) Imprinted on the jacket of the 3 cable --
4 Q Hold it up closer to the judges.
5 A (WITNESS WOZNIAK) -- we would verify that this cable, 6 as indicated there, is a 4-C, which stands for 7 "four-conductor," No. 14 AWG 600-volt cable.
8 (Indicating.)
9 That corresponds to a termination card that would 10 be at the point of inspection in the field.
11 Q The third attribute is cable routing, sir.
12 A (WITNESS WOZNIAK) Cable routing would be verified
}
13 through the actual cable pans and conduits in the field.
14 We would physically trace the routing that the cable was 15 installed as per the design requirements.
16 There were provisions within the checklist that if 17 the cable was a long complex route, that we could 18 de-terminate both ends of the table, attach a signal 19 generator to the cable and track it with a wand-type 20 mechanism where we would pick up an audible signal.
21 Q All right.
22 The fourth attribute is cable bending training 23 radius.
24 A (WITNESS WOZNIAK) In the cable bending training 25 radius, there are provisions within the checklist l
Sonntag Reporting Service, Ltd.
-Geneva, Illinois 60134 (312) 232-0262
13869
/' i (j
1 instructions to assure that the cable is not bent in too r
2 tight of a configuration, such as this.
3 (Indicating.)
4 There were provisions for the cable itself to 5 maintain a specific training radius, as well as the 6 individual conductors of the cable to not be bent in too 7 tight of a configuration.
8 0 Mr. Wozniak, you're referring to individual conductors.
9 What are you holding in your hand there?
10 A (WITNESS WOZNIAK) This is an individual conductor of 11 the four-conductor cable.
12 (Indicating.)
(
13 0 There are four individual conductors coming off that 14 cable, are there not?
15 A (WITNESS WOZNIAK) This is true.
16 JUDGE GROSSMAN: Of course, as has been 17 pointed out before, your bend radius test is only with 18 the finished product and doesn't at all -- and can't --
19 take into account the bend radii when the cable was 20 pulled or before the final connections were made.
21 WITNESS WOZNIAK: This is true. That would 22 be an example of nonrecreatable.
- 23 JUDGE GROSSMAN
- Right.
24 WITNESS WOZNIAK: In this case we're going to l
25 verify cable training radius as installed in the field.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13870 m
1 JUDGE GROSSMAN: I notice that on this 2 example here, you have only black cable.
3 Were they actually color-coded or was that -- I 4 guess that may not have been possible, because you have 5 so many different conductors in each cable.
6 WITNESS WOZNIAK: Sir, if I may, you'll note 7 that on the individual conductors, they are identified 8 as to their color coordination.
9 This is No. 4, green; this one being No. 3, red; 10 No. 2, white; No. 1, black.
11 (Indicating.)
12 JUDGE GROSSMAN: I see, okay.
13 WITNESS WOZNIAK: So they are imprinted on 14 the individual conductors.
15 JUDGE GROSSMAN: In other words, the 16 insulation isn't colored, but on the insulation it says 17 that it's a certain color even though it isn't.
18 WITNESS WOZNIAK: Exactly.
19 JUDGE COLE: That black wire is green; right?
20 WITNESS WOZNIAK: Yes, sir.
21 (Laughter.)
22 BY MR. STEPTOE:
23 0 The next attribute is separation of cable in air and 24 inside electrical equipment.
25 A (WITNESS WOZNIAK) What that applies to is a physical l
Sonntag Reporting Service, Ltd.
Geneva, Illinois 6U134 (312) 232-0262.
13871 4
1 separation of a classification of cable with respect to
'2 another classification of cable inasmuch as we would
, 3 want to keep the safety-related cables separated from a 4 nonsafety-related cable.'
5 The instructions provided that we would maintain 6 six inches of separation from a safety-related cable to 7 a nonsaf ety-related cable while inside _the equipment, 8 and 12 inches in the free-air condition, outside of the 9 equipment.
10 (Indicating.-)
11 Q Now, cable supports is the sixth attribute on your
_12 checklist, sir.
i 13 A (WITNESS WOZNIAK) Cable supports would be such like --
14 excuse the phrase -- the Chinese-type handcuff 15 configurations.
16 (Indicating.)
17 I believe those were, if my memory serves me 18 correct, not an inspectable attribute at the time of the 19 reinspection process.
20 MR. STEPTOE: We'll go on to that later, and 21 I'll explain that.
5 22 MR. GUILD: That's the Kellum grip?
23 WITNESS WOZNIAK: Yes, sir..
, 24 BY MR. STEPTOE:
) 25 0 The seventh item is cable termination.
3 Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
1 13872 1
'O 1 Would you explain what was involved in doing a 2 cable termination inspection?
3 A (WITNESS WOZNIAK) Okay.
- 4 As found in the field, we would have the cables --
5 all individual conductors terminated to the respective 6 points on a terminal block.
7 We would take the termination card and verify at 8 that point in time that, for example, No. 2 conductor, 9 white, was landed on Point 2 of the terminal block. We 10 would do that for all the conductors involved in the 11 multi-conductor cable.
12 (Indicating.)
13 No. 4, green, would have been indicated to be on 14 Terminal Point 4. We would verify that it would be 15 terminated, in fact, on Point 4 of the terminal block.
16 JUDGE COLE: How do you know that's Point 4 17 on the terminal block?
18 WITNESS WOZNIAK: Sir, the terminal block was 19 numbered in the field: 1, 2, 3, 4 and so forth.
20 JUDGE COLE: Your example is not numbered, 21 but it is numbered in the field?
22 WITNESS WOZNIAK: Yes, sir.
23 A (WITNESS WOZNIAK) (Continuing.) At that point in 24 time, having verified that the conductors were landed at 25 their proper termination points, we were accompanied by Sonntag Reporting Service, Ltd.
Geneva, Illinois eu134 (312) 232-0262
13873 1 an electrician who then had authorization to lift the 2 leads from the termination point.
3 We would then inspect the as-found condition of the 4 terminated conductor, and we would verify that the 5 insulation of the wire was properly inserted into the 6 ferrule of the lug.
7 BY MR. STEPTOE:
8 0 Could you explain what a ferrule is?
9 A (WITNESS WOZNIAK) It's this portion of the barrel of 10 the lug.
11 (Indicating.)
/' 12 JUDGE COLE: The outside cover?
13 WITNESS WOZNIAK: Yes, sir.
14 A (WITNESS WOZNIAK) (Continuing.) There's a portion in 15 there that is a continuance of the ring portion of the 16 lug; and that is what physically gets crimped onto the 17 conductor, this being the insulative portion of the lug.
18 We would give it a little pull test to make sure that it 19 was, in fact, tight.
20 (Indicating.)
21 We would verify that for a No.14 wire -- in real 22 fine print on the back of this lug, we were required to 23 verify that this was, in fact, an Amp Special Industries 24 lug, that it was the proper size for the cable specified 7-( 25 and that the screw hole coincided with the screw size Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
o 13874 1 being utilized.
2 If you had a magnifying glass, you could see that 3 it says " Amp 16-14 HD."
4 (Indicating.)
5 JUDGE GROSSMAN: Which means that that's 6 usable for either 16-gauge or 14-gauge cable --
7 WITNESS ~WOZNIAK: This is correct.
8 JUDGE GROSSMAN: -- conductor?
9 A (WITNESS WOZNIAK) (Continuing.) We would also do a 10 physical examination for both apparent cable jacket 11 damage and individual conductor damage.
'12 (Indicating.)
(
13 For example, when the electrician performing the 14 original termination -- when he removed the jacket, he 15 may or may not, you know, as an accident could happen, 16 have cut the individual conductor. We would inspect-for 17 that, for insulation damage.
18 (Indicating.)
19 We would then inspect for proper insertion of the 20 conductor into the barrel portion of the lug. The 21 crimping tool that is utilized in this type of 22 application leaves a little indentation. You could pick 23 that with your fingernail.
24 (Indicating.)
25 That is indicative of an amp tool used on an amp Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13875
[ \
V 1 lug, and that would assure that the proper tool was 2 utilized in the compression.
3 BY MR. STEPTOE:
4 Q Now, Mr. Wozniak, the next attribute is cable splice.
5 Would you identify what you did to verify cable 6 splice?
7 MR. GUILD: Mr. Chairman, before he goes 8 further, do you mind if I ask a clarification question 9 if it doesn't interfere with the examination?
10 MR. STEPTOE: Not at all.
11 MR. GUILD: Do you de-land all four 12 conductors, as you've been describing it, if it's a O- 13 four-cable --
14 WITNESS WOZNIAK: Under the control cable 15 population, yes, sir.
16 In the case like our other show-and-tell exhibit, 17 if you will, the other examples, we were required to 18 only determine one phase of a power conductor.
19 In the case of a control cable, we would actually 20 inspect every conductor.
21 MR. GUILD: How did instrumentation --
22 JUDGE GROSSMAN: Mr. Guild, even though 23 you're speaking very close to the witness, you have to 24 speak so the Reporter can take it down and everyone else 25 can hear.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13876 I
'v'I 1 WITNESS WOZNIAK: In instrumentation we would 2 verify that, also.
3 MR. GUILD: For all conductors?
4 WITNESS WOZNIAK: Of the conductors that are 5 landed.
6 JUDGE CALLIHAN: Where and when do you check 7 insulation type?
8 WITNESS WOZNIAK: Insulation type is 9 delineated, in the type of cable that is being used, for 10 the proper cable as specified on the termination card.
11 Sargent & Lundy has a breakdown of the cabling type
[, } 12 and code. In this case they've specified through the
\_/
13 code number that it is, in fact, Okonite Corporation 14 cable and it is, in fact, four-conductor No. 14 600-volt 15 wire.
16 So far as verifying the type of insulation, that is 17 inherent in this type of cable for this application.
18 MR. BERRY: So it would be Attribute 2, sir?
19 WITNESS WOZNIAK: Cable type and size, that 20 is correct.
21 JUDGE GROSSMAN: If I understand it, you 22 can't field-verify that the manuf acturer has put in the l 23 right insulation; you just have to depend on his marking 24 of the cable?
25 WITNESS WOZNIAK: That would be correct.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13877 p) t U
1 BY MR. STEPTOE:
2 Q Cable splices, the eighth attribute?
3 A (WITNESS WOZNIAK) Under cable splices, there was a 4 provision, the provision that we would not field-verify 5 in-line conductor butt splices. ,
6 But under Attribute 8, under cable splices, we were 7 to document any cable splices we found in the field on 8 the checklist.
9 What I believe the intent was there for was to find 10 an unauthorized splice, if you will, 11 0 So what would you do when you saw a splice?
12 A (WITNESS WOZNIAK) We would so note it on the 13 checklist.
14 0 Would you write an observation?
15 A (WITNESS WOZNIAK) I don't think so. If my memory 16 serves me, we would not at that point in time.
17 We would note it on the checklist that a splice was 18 located, for example, in Routing Point No. 123 of the 19 cable pan.
20 JUDGE COLE: Where would you write this on 21 this Form 221?
22 WITNESS WOZNIAK: In the remarks section, 23 sir, of the checklist.
- 24 JUDGE COLE: Okay.
( 25 MR. GUILD: Is that because there was a butt Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13878
.p V
1 splice correction action program that that butt splice 2 was not specifically inspected?
3 WITNESS WOZNIAK: I'm not sure if that was or 4 was not as a result of that.
5 There are provisions within the jobsite procedures 6 that conductor butt splices are allowed.
7 Whether or not it was a result of the fact that 8 they' re allowable and that they are normally covered by 9 heat-shrink and we couldn't inspect them anyway or 10 because there was a butt splice confirmation program in 11 progress, I don't know.
/m b) 12 13 later.
MR. STEPTOE: We'll go into that a little 14 BY MR. STEPTOE:
15 0 The last attribute on your checklist, Mr. Wozniak, is 16 cable damage.
17 A (WITNESS WOZNIAK) That again, as I explained during 18 the termination process, would be an overall look at the 19 cable and individual conductors for any apparent damage 20 to the individual conductors or the cable jacket itself.
21 (Indicating.)
22 MR. STEPTOE: Again, I'm going to have to 23 share my copy of the document marked " cables." This is 24 Applicant's Exhibit No. 131.
7_
() 25 JUDGE COLE: We don't have a copy of it yet.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262 . .
13879 r
w' 1 MR. STEPTOE: LI know. I'll share it with the 2 Board.
3 (Indicating.)
4 My troops are putting together copies even as we 5 speak.
6 BY MR. STEPTOE:
7 0 Could you go through this list of attributes not 8 included in the checklist or justification for alternate 9 criteria for the cabling population and, using the 10 demonstrative exhibit, explain what you couldn't or did 11 not verify?
12 MR. GUILD: Tell me what you're referring to.
13 MR. STEPTOE: It is the second tab of the 14 cable --
15 MR. GUILD: " Checklist instructions"?
16 JUDGE COLE: " List of attributes," okay.
17 BY MR. STEPTOE:
18 0 The first item there is cable pulling tension.
19 The statement there is that this attribute is not' 20 recreatable, Mr. Wozniak.
21 A (WITNESS WOZNIAK) Obviously, that's true. As the 22 cable is installed, we could not verify something that 23 had taken place prior.
24 Q The second attribute is cable pulling radius.
25 A (WITNESS WOZNIAK) As we also discussed earlier, we Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13880
- 1- - could not verify the pulling radius as would have been 2 installed.
j 3 The training radius in an as-found condition is the 4 attribute we verified.
5 0 The third attribute is terminations of coaxial and 6 triaxial cables to connectors.
7 A (WITNESS WOZNIAK) That would be considered part of a 8 destructive-type examination; and due to the type of 9 connectors used, that was not an attribute that we 10 verified.
11 0' The fourth attribute that you didn't verify is stress 12 cone installation detail.
(}
13 Can you explain what a stress cone is?
i 14 A (WITNESS WOZNIAK) A stress cone primarily -- this is a i
15 very weak example of what a stress cone would be. But 16 as the' term indicates, it would relieve some of the 4
17 stress of the conductors coming out of the -- being i 18 broken out of a jacket assembly, i 19 (Indicating.)
- 20 Q Now,-what are you referring to when you say "this"?
21 A (WITNESS WOZNIAK) This area of the cable right here, 22 this taped --
23 (Indicating.)
,- 24 0 A taped portion of the cable where the four conductors l
f( 25 come out; is that correct?
l l
l Sonntag Reporting Service, Ltd.
l L Geneva, Illinois 60134 (312) 232-0262
13881 1 A (WITNESS WOZNIAK) That is correct.
2 The stress cone itself would be hidden by .the tape,-
3 which is the visible portion in the field. Therefore, 4 it was not considered an attribute for reinspection.
5 MR. GUILD: What is a stress cone?
6 WITNESS WOZNIAK: A stress cone, primarily in
- 7. a larger cable, would support and prevent stress from 8 being added to the individual conductors being broken 9 out of a larger cable.
10 JUDGE GROSSMAN: That's put on in the field ;
11- when the cable is stripped?
12 WITNESS WOZNIAK: And terminated, yes, sir.
(
13 MR. GUILD: What is it made of, Mr. Wozniak?
14 WITNESS WOZNIAK: There's various 15 manufacturers who make stress cones of various 16 materials. Mostly the components are a dielectric or an 17 insulative-type application.
18 MR. GUILD: All right.
, 19 JUDGE CALLIHAN: Sealing?
20 WITNESS WOZNIAK: Exactly.
21 JUDGE GROSSMAN: And you' re dealing only with 22 Romex cable here;-you didn't have any armored cable at 23 all; is that right?
- 24 WITNESS WOZNIAK: There were some -- the
( ). 25 armored cable per se would be like a shielded power Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
- . _ . . _ _ _ _ . . _ . _ . _ _ _ _ _ _ _ _ - . _ ~ . ._ __ - . - , _ - . _ _ . _.. _ . _ _ _ _
13882 l )
Q) 1 cable, and there were cable packages I believe that had 2 the armored -- excuse me.
3 Armored cable in the sense -- I know what you' re 4 speaking about. That would be the metallic-type 5 insulation.
6 JUDGE GROSSMAN: Yes.
7 WITNESS WOZNIAK: Sir, we did not have that 8 in our population.
9 JUDGE GROSSMAN: Okay.
10 BY MR. STEPTOE:
11 0 The fifth attribute on this list of attributes not
[v ') 12 included in the checklist is cable grips.
13 Would you explain why that was not included?
14 A (WITNESS WOZNIAK) The page here indicates, "The 15 Nonconformance Reports Nos. 429 and 595 are issued 16 against cable grips in the auxiliary building and 17 containment. All cable grips are required to be 18 reinspected. There is no QC-inspected cable grips as of 19 the cutoff date of the BCAP program, June 30, 1984."
20 0 So did you not inspect any cable grips?
21 A (WITNESS WOZNIAK) No, sir, we did not.
22 O Cable ties -- can you identify what that is?
23 A (WITNESS WOZNIAK) Sir, this is referred to as a cable 24 tie or in some cases an actual cable tie wrap.
25 (Indicating.)
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13883 U
1 0 Can you explain what you' re pointing to?
2 A (WITNESS WOZNIAK) This would be the nylon little tie 3 here that secures the bundle of cables together.
4 (Indicating.)
5 These would be used to train the cable within the 6 routing portions of the cabinet, and it uses in some
, 7 cases a limited application of a cable support.
8 You would physically bundle the cables together for 4
9 protection against damage, routing, et cetera.
10 0' So that's the white nylon ring that encircles the four 11 conductors there?
12 A (WITNESS WOZNIAK) This is correct.
(
13 JUDGE COLE: Why would they do it that way, 14 as contrasted with just extending the jacket up to that 15 point, since all four cables are still maintained in 16 their same relative position?
i 17 WITNESS WOZNIAK: Judge, it might be that 18 during the cable termination process, the terminator 19 needed to remove that much jacket to accurately get his 20 tools involved.
21 For example, this conductor here is very small.
22 For him to be able to work on the cable, he stripped off 23 that much jacket.
II 24 (Indicating.)
25 This Conductor No. 4 may be required to terminate Sonntag Reporting Service,.Ltd.
Geneva, Illinois 60134 (312) 232-0262
13884 A '
(J l farther down on a lower point on the terminal block.
2 (Indicating.)
3 JUDGE COLE: He needed it for working room, 4 then.
5 WITNESS WOZNIAK: Exactly.
6 JUDGE COLE: Okay. Thank you.
7 BY MR. STEPTOE:
8 0 Then the last -- Item No. 7 is torquing of bolts for 9 cable connections.
10 A (WITNESS WOZNIAK) We did not verify the torquing of 11 bolts for. cable connections. They were determined to 12 not be a design-significant consideration.
(
13 0 And that decision was made by the BCAP engineers?
14 A (WITNESS WOZNIAK) Yes, sir.
15 MR. GUILD: What is a cable connection; the 16 termination of the cable?
17 WITNESS WOZNIAK: Yes, sir.
18 MR. GUILD: In this case, the screw 19 connection is on the terminal block?
l 20 WITNESS WOZNIAK: Exactly.
21 BY MR. STEPTOE:
22 0 So you didn't verify that the conductor was screwed in 23 tightly to the cable block?
, 24 A (WITNESS WOZNIAK) No, sir.
25 0 Okay.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13885 O
1 A (WITNESS WOZNIAK) Excuse me.
2 -I might point out that if, during our inspection, 3 the electrician that accompanied our BCAP inspectors 4 found that the screw was loose, we would, I believe, 5 write I believe it was an out-of-scope-type observation 6 indicating that the screw was found loose.
7 But it was not an attribute that we would --
8 0 Looking at the lug, sir, the lug is- circular; is that 9 correct?
10 A (WITNESS WOZNIAK) Yes, sir.
11 0 Did you have any lugs like I have on my stereo, which
.b v
12 are open-pronged?
13 A (WITNESS WOZNIAK) No, sir. That would be considered a 14 forked-tongue-type lug, and those were not approved for 15 the jobsite.
16 This is ref erred to as a ring-tongue-type lug, and 17 these were the type used on the jobsite.
18 (Indicating.)
19 JUDGE COLE: I guess I have a minor problem 20 with the decision that a loose bolt would not be i
21 design-significant.
22 How would you make an electrical connection if it's 23 not fastened down?
24 That certainly could possibly be responsible for no 25 electrical current passing and possible malfunctions.
t Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13886 m
ss 1 WITNESS WOZNIAK: Judge Cole, oat the time in 2 my tenure as a BCAP inspector, I had no involvement in 3 the determination of the checklist attributes.
4 Perhaps someone else within Mr. Steptoe's --
5 MR. STEPTOE: Mr. Thorsell probably would be 6 able to address that.
7 JUDGE CALLIHAN: Where were these bolts?
8 WITNESS WOZNIAK: The bolts in this case 9 primarily would be more applicable to a power-type 10 current connection, where you have two lugs bolted back 11 to back with a bolt going through them.
[
V
) 12 JUDGE CALLIHAN: With a bolt connecting lugs, 13 not the termini?
14 WITNESS WOZNIAK: That's correct.
15 MR. GUILD: In this case it was screws 16 terminating to the terminal block, the same thing?
17 WITNESS WOZNIAK: Yes.
18 BY MR. STEPTOE:
19 0 You did not verify that the screws were tight; it's the 20 same thing?
21 A (WITNESS WOZNIAK) As I indicated, if we found one 22 loose, we would indicate that.
23 But it was not a requirement. It was something 24 that the task force inspectors did beyond the checklist.
7s
() 25 JUDGE GROSSMAN: I would expect that screws 1 Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 f (312) 232-0262
i 13887 O
1 come loose and that it probably wouldn't be a good 2 indication of whether the item was properly inspected in 3 the first instance.
4 WITNESS WOZNIAK: Sir, that would be correct.
5 It would be, in my opinion, classified along with 6 construction damage.
7 I could not see how an inspector could be held 8 responsible for something like that when he walked away 9 f rom the finished product, t
10 JUDGE CALLIHAN: Did your electrician 1
11 disconnect each terminus so you could feel and so forth?
12 WITNESS WOZNIAK: Yes, Judge Callihan.
(
13 JUDGE CALLIHAN: So it's not a 14 nonreconstructible attribute, then?
15 WITNESS WOZNIAK: On the control-type - cables, -
i 16 we had the electrician lift each lug that would be 1
- 17 landed in the as-found condition.
l 18 On a power cable termination, we were required to
- 19 do only one phase; in other words, one of the three.
20 JUDGE CALLIHAN: But at any rate, the 21 tightness of the screw is nonreproducible?
22 WITNESS WOZNIAK: Exactly, because the 23 electrician would return it back to a, quote, " tight" 24 condition.
25 JUDGE CALLIHAN: What's the "Cu" on the J
? Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
s 13888
/^% .
1 cabling marking there? ,
2 WITNESS WOZNIAK: My interpretation would be 3 that the conductor was-made out of -- that is the atomic i 4 indication of copper. "Cu" is the --
5 JUDGE GROSSMAN: What do.you mean by 6 " phases," now?
7 MR. STEPTOE: We'll get to that. That's our 8- next exhibit, Judge Grossman.
9 JUDGE GROSSMAN: Okay.
10 MR. STEPTOE: It's for power cable, and this 11 is instrumentation.
12 WITNESS WOZNIAK: Control, p
13 MR. STEPTOE: Control cable; excuse me.
i 14 JUDGE GROSSMAN: Okay.
15 You're talking about neutral, hot and grounded, via i 16 phases?
17 WITNESS WOZNIAK: In a 240-volt application, 18 yes, sir. ,
19 In a 480-volt, there's three phases required to
. 20 make a 4 80-volt circuit. You've got two hot and a f
21 neutral.
22 JUDGE GROSSMAN: Well, if you're talking i 23 about 220 or 240, you don' t mean " neutral" and " hot";
i l 24 you mean two hots and a grounded?
25 WITNESS WOZNIAK: Correct, and that would be i
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13889
\
! v 1 the three phases of the cable.
2 JUDGE GROSSMAN: All right, okay.
3 BY MR. STEPTOE:
4 0 The next-item on the list of attributes not included in 5 the checklist is insulated copper lugs for control and 6 instrumentation, cable sizes 22 AWG through 14 AWG.
7 A (WITNESS WOZNIAK) Sir, the document reads that, "The 8 Nonconformance Report Commonwealth Edison NCR No. 453 is 9 issued against Amp Special Industries insulated copper 10 lugs for control and instrumentation, cable sizes No. 22 11 through 14.
12 "All Amp Special Industries insulated copper lugs
(
13 for wire sizes No. 22 through No. 14 are. required to be 14 reinspected. Therefore, inspection of these lugs is not 15 included."
16 Q Are insulated copper lugs -- are there any insulated 17 copper lugs on this demonstrative exhibit that you're 18 holding in your hand?
19 A (WITNESS WOZNIAK) Sir, this is an insulated tin-plated l
20 copper lug.
21 (Indicating.i 22 0 Is it a copper lug?
23 A (WITNESS WOZNIAK) Yes, sir.
24 0 So what was it that you did not inspect as a result of 25 this item?
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
l-13890
-~
a 1 A' (WITNESS WOZNIAK) I would have to refer specifically 2 to the checklist instructions, but we would just 3 document the fact that the lug was utilized.
4 Q Okay.
5 Would you refer to the instructions, which are in 6 the next portion of the cable package?
7 That's Applicant's Exhibit 131.
8 A (WITNESS WOZNIAK) Under the cable termination 9 attribute, No. 7, cable termination, on Page 6 of 7 of 10 the cable instructions, Item G, it states, " Insulated 11' copper lugs for cable sizes No. 10 AWG and smaller.
I h 12 Subitem 1:. Verify that the insulated sleeve has the b 13 following colors."
14 Size No. 22 through 18 is red. Size No. 16 through 15 14 is yellow with a black stripe.
16 0 Is that the type that you have there on the example?
17 A (WITNESS WOZNIAK) This is correct. It's yellow with a 18 black stripe.
19 MR. BERRY: Where is the black stripe?
20 WITNESS WOZNIAK: Right here.
21 (Indicating.)
22~ A (WITNESS WOZNIAK) (Continuing.) Size 12 through 10 is 23 just plain yellow.
24 " Note: The Amp Special Industries insulated lugs 25 No. 22 through 14 are excluded from inspection of this 4
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
1 13891 A
IV) 1 attribute."
2 This is an amp lug, but I believe this is 3 classified as an amp heavy-duty-type lug. The only 4 requirement for us in the BCAP was to verify that this 5 was, in fact, yellow with a black stripe.
6 (Indicating.)
7 MR. STEPTOE: Okay.
8 BY MR. STEPTOE:
9 0 For this type of application?
10 A (WITNESS WOZNIAK) Yes.
11 MR. GUILD: If it falls within the exclusion 12 because it's covered by that NCR, what wouldn't you 13 inspect for that lug?
14 WITNESS WOZNIAK: Well, this is, turning back 15 to Page 5 -- Page 4, these are the wires included for 16 the inspection, and these are the subattributes.
17 (Indicating.)
18 When we come down to this size conductor, the 19 instructions were that we would verify only, in this 20 case, the color referenced to the size of the lug.
21 MR. GUILD: What would you do otherwise if it 22 wasn't excluded, then?
23 WITNESS WOZNIAK: There was no -- we had not 24 found any that were not of this condition. The ones
) 25 that we verified in the field were these type of Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 f (312) 232-0262
13892 (3 )
\
v 1 insulations.
2 (Indicating.)
3 I'm only assuming at this point that, because of 4 the ongoing NCR program, there may or may not have been, 5 I understand, some nonamp lugs or the nonamps, HD-type 6 lugs.
7 That I don't have an opinion to. When we came to 8 this type of lug, we verified just as stated in the 9 checklist instructions.
10 MR. GUILD: Mr. Steptoe, Mr. Chairman, I 11 guess my problem is I don't understand what the nature
( 12 of the excluded attribute is.
\
13 BY MR. STEPTOE:
14 0 Did you verify, Mr. Wozniak, that the conductors were 15 inserted up to the end of the insulated barrel for an 16 insulated copper lug, cable sizes 22 AWG through 14 AWG7 17 A (WITNESS WOZNIAK) Yes, I did.
18 Q Did you verify that the vendor's trademark was stamped 19 on the lug and had the Commonwealth Edison stamp 20 EM-40276-B/B?
21 A (WITNESS WOZNIAK) Yes, we did. That would be the 22 writing stamped on the back of the lug.
23 0 Did you verify that the crimp connection was tight?
24 A (WITNESS WOZNIAK) That was verified, yes, sir, by 25 actually pulling on the lug from the conductor.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 i
f (312) 232-0262
13893
'm J l 0 Even as to these Amp Special Industries insulated lugs 2 No. 22 AWG through No.14 AWG, you would verify those 3 attributes?
4 A (WITNESS WOZNIAK) Yes, sir, we did.
5 MR. GUILD: So what's excluded per the 6 excluded attribute?
7 WITNESS WOZNIAK: It would be my 8 interpretation of the instructions that if we were to 9 find an Amp Special Industries insulated lug, that we 10 would not do any of the aforementioned cable 11 inspections, because they were required to be inspected 12 under the provisions of the CECO NCR 453.
Ov You just never found any of 13 MR. GUILD:
14 those?
15 WITNESS WOZNIAK: No, sir.
16 MR. GUILD: I see.
+ 17 BY MR. STEPTOE:
18 0 The next item on this list of attributes not included in 19 the checklist is conductor extension splices inside 20 equipment.
21 Now, you did not inspect conductor extension 22 splices inside equipment, did you?
23 A (WITNESS WOZNIAK) No, sir, we did not.
24 0 And the reason for that is as stated in the list: that f_
25 there was an NCR issued?
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13894
(h v
1 A (WITNESS WOZNIAK) Yes, sir, that is correct.
2 O All right.
3 Item No. 310, terminations and metal shielding braid 4 and tape-shielded drain wire.
5 A (WITNESS WOZNIAK) Those were -- as stated in the 6 exclusions, this attribute is inaccessible because the 7 terminations are covered either with heat shrinkable 8 tubing or a crimp connection.
9 0 Why would that make it inaccessible?
10 A .
(WITNESS WOZNIAK) The heat-shrinkable tubing is 11 totally shrunk down around the termination of the metal
[m t}
12 shielding. Therefore, that would be considered a 13 destructive examination.
14 We did not disassemble any heat-shrink.
15 0 What about the crimp connection?
16 A (WITNESS WOZNIAK) By virtue of the crimp, you would 17 not be able to tell whether or not the crimp was good in 18 this type application.
19 0 Without destroying the connection?
20 A (WITNESS WOZNIAK) That is correct.
21 Q Finally, the verification of cable terminations at 22 proper terminal points for a three-phase motor.
23 Would you explain why that was not --
24 A (WITNESS WOZNIAK) Primarily, sir, that has to do with 25 the phasing of a three-phase cable inasmuch that Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 f (312) 232-0262
13895
,G b
.1 rotation of any two leads of a three-phase power feed 2 would change the rotation.
3 We were_not required to verify that the proper 4 phasing had been accomplished. That would be done 5 through the start-up phases of the project.
6 0 To your knowledge, is there a procedure for doing that?
7 A (WITNESS WOZNIAK) There is within the Commonwealth >
8 Edison start-up procedures, yes, sir.
9 MR. GUILD: Mr. Chairman, let me jump back to 10 No. 9, butt splices, again.
11 Did you note the presence of a butt splice inside
, 12 the equipment?
13 WITNESS WOZNIAK: No, sir, we did not.
14 MR. STEPTOE: All right.
15 The next demonstrative exhibit is a little bigger, i
16 but it will go faster, I think, Judge Grossman.
17 BY MR. STEPTOE:
18 0 What we have here is a big cable. It looks like a i
19 trident attached to a board.
20 (Indicating.)
21 Would you explain what it is?
22 (Indicating.)
l 23 A (WITNESS WOZNIAK) This is a three-conductor No. 2 5-kV 24 cable -- the "5-kV" stands f or it's a 5,000-volt-rated 25 cable -- three individual conductors encompassed in one Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13896 O
d 1 jacket.
2 (Indicating.)
t 3 MR. GUILD: Say that designation again, 4 please.
5 WITNESS WOZNIAK: Three-conductor /2 ---that 6 would be the AWG size.
7 MR. GUILD: 2-gauge?
8 WITNESS WOZNIAK: Correct.
9 -- 5-kV power cable.
10 JUDGE COLE: Now, you're reading from the 11 marker that's put on by the electrician that made the 12 installation?
s 13 WITNESS WOZNIAK: Yes, sir.
14 Also, on the cable jacket again it would be stamped 15 with this information. In this case it's obscured by 16 the label.
17 (Indicating.)
18 MR. STEPTOE: Judge Cole, it's my information 19 that this was a training device used by Comstock.
20 BY MR. STEPTOE:
21 0 would you see this kind of label in the field?
22 (Indicating.)
23 A (WITNESS WOZNIAK) This is similar to the segregation 24 label that I had described earlier. It would contain in 25 this case, though, the cable number and the segregation Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 f (312) 232-0262
1389.7 V
1 code.
2' Q And'would the seg code label be colored?
3 A (WITNESS WOZNIAK) It would be color-coded 4 corresponding to the design drawings.
5 0 Could you explain what this tape wrapping is at the 6 junction of the three prongs of the cable?
7 (Indicating.)
8 A (WITNESS WOZNIAK) This is the taping that is in the 9 form of a stress-cone-type condition.
10 This would -- in this area here, the jacket is 11 penciled down evenly to meet the three individual i
- 12 conductors; and the taping process is involved in this, 13 being the outer jacket of that taping process.
14 (Indicating.)
15 0 Now, the three cables that lead out f rom that look 16 different.
17 Would you explain why they' re different?
18 A (WITNESS WOZNIAK) Okay.
19 These are in various phases of the termination 20 process. Again, the three conductors are denoted with 21 their color: red, white and black.
22 MR. GUILD: Not " color" but --
! 23 WITNESS WOZNIAK: Annotation.
( 24 MR. GUILD: All right.
t
/
) 25 BY MR. STEPTOE:
i Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13898 iA)
\v/
1 0 This is the left-hand fork of the tines of the fork; is 2 that right?
3 A (WITNESS WOZNIAK) Yes, sir, 4 The cable insulation had been penciled down 5 uniformly to meet the conductor.
6 The conductor is barely visible between the lug and 7 the penciled-down portion of the insulation. That is 8 achieved by the electrician in preparation for his 9 termination.
~ '
10 MR. GUILD: What type of conductor is it?
i 11 WITNESS WOZNIAK: This is a power cable
') 12 conductor.
13 MR. GUILD: What's the material of the 14 conductor itself?
15 WITNESS WOZNIAK: That would be copper.
16 MR. GUILD: Is it braided or solid?
17 NITNESS WOZNIAK: That would be stranded.
18 This is a No. 2 Homac lug that had been compressed 19 onto the conductors, "No. 2" again corresponding to the l
j 20 AWG size of the cable.
21 (Indicating.)
22 BY MR. STEPTOE:
23 0 There's a bolt hole or something at the top.
24 Could you explain what that is?
l
,) 25 A (WITNESS WOZNIAK) This hole is used for making up the Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13899 V
1 connection. This would either be bolted to the pigtails 2 within the motor leads or the other feeds coming f rom 3- the driven end of the equipment.
4 Q Okay.
5 And how would the connection be made?
6 A (WITNESS WOZNIAK) The connection in the field, for 7 example, to motor pigtails would be bolted back to back i
I 8 with another lug with a bolt, nut and washer. Then the 9 connection would then be taped.
10 JUDGE GROSSMAN: I notice you don't have any 11 grounding lead in there.
12 WITNESS WOZNIAK: This is a nongrounded
(
13 cable. It's a three-phase power cable.
14 JUDGE GROSSMAN: Oh, okay. ,
15 None of them had grounding leads in them, then?
16 This is for a 480-volt --
17 WITNESS WOZNIAK: No, sir. This is for a 18 4,160-volt application.
19 JUDGE GROSSMAN: Oh, okay.
20 WITNESS WOZNIAK: The cable itself is rated 21 at 5,000 volts.
22 JUDGE GROSSMAN: Oh, okay.
23 MR. GUILD: What's a typical application for 24 a power cable of that size?
25 WITNESS WOZNIAK: For example, this would be Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 '
I (312) 232-0262
13900 h
\_ /
1 coming f rom the 4-kV switch gear going down to the 2 substation, which would break the 4-kV voltage rating 3 down to 480 volts.
4 MR. GUILD: I thought you were talking about 5 a motor being the termination of this.
6 WITNESS WOZNIAK: This may also be used for a 1
7 power feed to a 4,000-volt motor. This cable has 8 several applications, I'm sure.
9 MR. GUILD: Okay.
10 BY MR. STEPTOE:
11 Q Could you go on to the center tine?
12 A (WITNESS WOZNIAK) In the center tine, you'll note that 13 the taping process had begun and the homogenous-type 14 tape had been applied to the penciled area of the 15 insulation uniformly down onto the barrel portion of the 16 lug.
17 (Indicating.)
18 Q The right-hand tine, sir?
19 A (WITNESS WOZNIAK) That is the completed taping process i'
20 of the lugged connection, the final tape having been i
21 applied.
22 At this point another cable identical to it would 23 be the as-found condition. Had we de-terminated one of 24 the power phases of the cables and unbolted it, this is
( 25 what we would find: another one on the right-hand side.
Sonntag Reporting Service, Ltd.
. Geneva, Illinois 60134 (312) 232-0262 - . .
13901
> 1 (Indicating.)
, 2 Q Briefly, when you found it in the field, would all three 3 tines of the power cable be like this one on the - right?
! 4 A (WITNESS WOZNIAK) They would be as I have described-5 earlier and then, af ter they had been bolted, completely
, 6 covered in either heat-shrink or another taping process.
7 Q Now, how, if at all, did you inspect that configuration?
8 A (WITNESS WOZNIAK) We chose randomly one phase of the 9 three-phase power cable, took the jacketing tape off. --
10 took.this tape cff with the aid of our electrician --
i 11 and inspected for any visible cable damage, correct type 12 lug, the presence of the high-press cable tool that was
(
! 13 used to compress the lug onto the conductor.
1 14 (Indicating.)
15 Q Okay.
f 16 So by cutting it apart, you got it back to-the i
l 17 condition of the lef t tine, the lef t-hand tine?
i 18 A (WITNESS WOZNIAK) Yes, that's correct.
19 0 All right.
20 Now, you were unable to verify that the crimping 21 tool that had been used was properly calibrated; is that 22 correct?
23 A (WITNESS WOZNIAK) That is correct.
~
24 Q What could you tell about the crimping tool that had 25 been used?
4 I Sonntag Reporting Service, Ltd.
! Geneva, Illinois 60134 (312) 232-0262
4 13902 O
1 A (WITNESS WOZNIAK) The crimping tool within the dies 2 leaves a trademark relative to the die size utilized.
3 There is a code that in this case is not purely 4 visible in this training exhibit here, but the dies of 5 the tool leave an indentation onto the lug itself, 6 indicating that the proper tool was used in achieving 7 the crimp.
8 (Indicating.)
9 MR. STEPTOE: That's all the questions I have 10 of you, Mr. Wozniak.
11 If any of the other parties or Board have 12 questions, please feel free.
13 MR. BERRY: Would that, in essence, be a 14 destructive examination?
15 JUDGE GROSSMAN: You have to. speak up, by the 16 way, Mr. Berry.
17 WITNESS WOZNIAK: Excuse me?
18 MR. BERRY: Would that, in essence, be a 19 destructive examination?
20 WITNESS WOZNIAK: Inasmuch as the insulation 21 that was insulating the power connection.
22 A further destructive examination would be to 23 thoroughly cut that off and examine it.
24 We had no requirement to do that.
) 25 BY MR. STEPTOE:
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 l- (312) 232-0262
. . - =. - - .
4 13903 p .
1 Q One further question, Mr. Wozniak:- Inside this --'what 2 is this; the metal jacket?
3 (Indicating.)
4 A (WITNESS WOZNIAK) This is the chinned copper lug 5 itself.
6 (Indicating.)
7 Q Were you able to verify the presence of the conductor 8 inside the copper lug?
9 A (WITNESS WOZNIAK) Mr. Steptoe, in this type of lug, 10 there is not the presence of a weep hole.
11 Would there have been the presence of a weep hole, 12 which is a hole drilled into this portion of the lug, we
(
13 would look in there with a flashlight to see if we could 14 see the end of the conductor, thereby verifying 15 conductor insertion.
16 (Indicating.)
f 17 0 What was the condition of the power cables of this sort 18 that you found in the field? Were there generally weep holes?
19 20 A (WITNESS WOZNIAK) It was -- both conditions were found 21 in the field.
22 JUDGE COLE: After you completed your i 23 inspection, did the electrician that accompanied you on 24 this then redo the connection?
25 WITNESS WOZNIAK: Yes, sir.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134
[ . .. _
(312) 232-0262
13904 O 1 1 At that point in time,-we called out -- in the case 2 of saf ety-related, we were required to call out an L. K.
3 -Comstock QC Inspector, and he verified our electrician 4 reterminating the cable back to its as-found condition.
5 JUDGE ~ COLE:- Okay. Thank you.
6 JUDGE GROSSMAN: Excuse me.
7 You didn't talk about butt splicing.
8 I assume you're talking about splicing within a 9 piece of equipment, not along the cable that's outside 10 of any equipment; is that correct?
11 WITNESS WOZNIAK: The attribute for cable 12 splices required us to record any observable cable
[Vh 13 splices wherever they may be, and that was termed to 14 include a splice, your Honor, within the cable pan 15 routing anywhere located in the field.
16 An individual conductor butt splice would be noted 17 primarily inside the equipment on an individual 18 conductor.
19 JUDGE GROSSMAN: Well, were craf t permitted 20 to butt-splice outside of equipment?
21 WITNESS WOZNIAK: No, sir.
22 JUDGE GROSSMAN: Okay.
23 If anyone did find a butt splice, then, they would 24 have to insert a junction box, I would assume, and put 25 the splice in there.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 f (312) 232-0262
13905
[%J 1 It wouldn't be permissible, would it, to have a 2 butt splice that was in an exposed cable?
3 WITNESS WOZNIAK: The procedures that exist 4 allow for conductor butt splices within equipment. The
- 5. instructions for the BCAP checklist were to record any 6 observable cable splices.
7 BY MR. STEPTOE:
8 0 Is there difference between a cable splice and a butt 1 9 splice, sir?
10 A (WITNESS WOZNIAK) Mr. Steptoe, this would be 11 considered a cable containing many conductors.
12 The provisions are -- assuming the meaning for us
( in trying to locate any observable cable splices, it 13 l 14 would be the presence of an unauthorized splice outside l
15 of the equipment.
16 Q All right.
17 And if there was a cable splice outside of the 18 equipment, you wrote it down; isn't that correct?
19 A (WITNESS WOZNIAK) That is correct.
20 0 Now, was there any -- did you ever see any butt splices 21 outside of equipment?
22 A (WITNESS WOZNIAK) No, sir, I did not.
23 0 Okay.
24 A butt splice -- would you define what a butt 25 splice is?
l Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 l
(312) 232-0262
13906 (DI 1 A (WITNESS WOZNIAK) A butt splice is an extension of the 2 individual conductor itself. It's a butt splice 3 connector where you take the two -- excuse me -- butts 4 of the cable, insert them into a butt-splice connector, 5 crimp it down and then heat-shrink it.
6 (Indicating.)
7 MR. GUILD: So they never occur outside 8 equipment?
9 WITNESS WOZNIAK: I cannot state that they 10 never do, sir, but I've not found any.
11 MR. GUILD: But if they occurred inside 12 equipment, you wouldn' t have noted those?
(x.-
13 WITNESS WOZNIAK: No, sir. A conductor butt 14 splice is quite obviously different than a cable splice 15 itself.
16 BY MR. STEPTOE:
17 0 Dr. Kaushal --
18 A (WITNESS KAUSHAL) Yes, sir.
19 0 -- in your testimony, Attachment No. 2C-2, there is a 20 number given for the population f rom which you drew your 21 sample.
22 A (WITNESS KAUSHAL) That's correct.
23 0 Can you identify what that number represents?
24 A (WITNESS KAUSHAL) I believe I responded to that
) 25 question earlier.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 f (312) 232-0262
i l
13907
<w l
( ) -
\s / ,
i 1 It is an estimate of the total number of items that 2 were QC-accepted and completed as of June 30,1984, and 3 it was estimated based on the number of QC-accepted and 4 completed items that were found in a random sample of 5 items that were picked from a design population.
6 Q Okay.
7 I'll hand you an exhibit, which I'd like marked as 8 Applicant's Exhibit No.133.
9 (The document was thereupon marked 10 Applicant's Exhibit No. 133 for 4
11 identification as of October 8, 1986.)
I 12 BY MR. STEPTOE:
N~-
13 Q Would you identify what this is, Dr. Kaushal?
14 (Indicating.)
15 A (WITNESS KAUSHAL) Yes. This looks like a memorandum 16 out of BCAP records. This pertains to estimation of 17 population size for cables, and it goes to the process 18 that I just talked about.
19 There were 8,575 entries. Based on the population 20 from the total list arrived at from the design 21 documents, they looked at random at 189 items, out of 22 which 60 turned out to be QC-accepted and completed.
23 Based on that number, the estimate of the 24 population size, which is the QC-accepted and completed 25 number of items, was arrived at as 2,722.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13908 1 Q Dr. Kaushal, I'll hand you another document, which I 2 would like marked as Applicant's Exhibit 134.
3 (The document was thereupon marked 4 Applicant's Exhibit.No. 134 for 5 identification as of October 8, 1986.)
6 BY MR. STEPTOE:
7 Q Please identify what this is.
8 (Indicating.)
9 A (WITNESS KAUSHAL) These are again memoranda or
- 10 documents created in the course of BCAP work; and as I 11 see it, there's one such document for each population.
12 I haven' t counted them all, but I believe they' re there.
( ,
13 These documents record the list of attributes that 14 are excluded or-justification for alternate criteria for 15 each of the electrical populations.
16 0 Okay.
17 And this is similar to a list which appears for 18 cables in Applicant's Exhibit No.,131, is it not, which 19 is the package for cables?
20 A (WITNESS KAUSHAL) I thought cable was in here, Mr.
21 Steptoe.
I 22 0 Is it?
23 A (WITNESS KAUSHAL) No, it isn't, it isn't.
- 24 Yes, this is the equivalent for the other five 1 25 populations, what you, in fact, just went through for Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134
- (312) 232-0262
L 13909 i
1 the cable-population.
2 MR. GUILD: Mr. Chairman, excuse me.
3 Before we go any further, Applicant's Exhibit 133 4 appears to reflect the first time that Applicants are 5 informing us that, in fact, Dr. Kaushal's Attachment 3, 6 where it identifies the entries as " number of population 7 items," in. fact, is not the number of population items;-
l 8 it's simply an estimate derived apparently through the i.
9 seat-of-the-pants process that's reflected in this 10 memorandum, i 11 Now, I just checked back to Dr. Kaushal's prefiled 12 testimony, Page 11; and I note on my copy that when he f
! 13 took the stand, he made a correction to his testimony.
14 There he said he deleted a word, and he changed the 15 sentence at the bottom of the page to read, "For each 16 construction category, the CSR sample was selected" --
! 17 well, my notes are not complete, but the original l 18 reading was, "For each construction category, the i 19 population of all safety-related items that were i 20 completed and QC-accepted as of June 30, 1984, was t
-21 identified."
22 The word " identified" was stricken and words were 23 inserted, but no change was made to indicate in the 24 testimony that this was only an estimate of the size of 25 the population. We only learn that now on redirect.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 0U134
( (312) 232-0262 .
O l l
13910 l O
hss/ l 1 I think it's absolutely inexcusable that a 2 correction was made to the testimony but that Applicant 3 did not give the explanation, at the time they tendered 4 the witness, that only now we are confronted with on 5 redirect examination.
6 I frankly have proceeded in my preparation on the
- 7 assumption that, given Dr. Kaushal's testimony, someone 8 gave him a list of the items that were QC-accepted as of 9 June 30, 1984, and that when he says " population items,"
10 that that is a definitive identification of items and 11 not simply an estimate.
I 12 MR. STEPTOE: Judge Grossman, first of all,
( it didn't occur to me, at the time that Dr. Kaushal took 13
, 14 the stand, that this clarification was necessary.
i 15 But certainly the clarification that Dr. Kaushal 16 made when he took the stand was that they did not i 17 identify all the OC-accepted items that Comstock had
- 18 completed and OC-accepted as of June 30, 1984.
19 Instead, what he said was that they went through
(
20 the S & L drawings, identified all the possible items 21 and then did a check to see which ones had been -- then 22 drew ran a random sample from that population and then i 23 went to see whether the items they came up with had been i
- 24 QC-accepted.
Indeed, that's clearly shown in Applicant's Exhibit
) 25 Sonntag Reporting Service, Ltd.
- Geneva, Illinois 60134 -
l (312) 232-0262
l l
l 13911 O
O 1 No. 131, which shows that random picking process at 2 work.
3 If counsel was surprised by this, I really have to 4 say I'm sorry. I didn't think of this further 5 clarification, but it seems to flow obviously from the 6 first clarification.
7 MR. GUILD: Mr. Chairman, I understand --
8 JUDGE GROSSMAN: Well, okay. I don't think 9 it is obvious, and I thought the explanation for the 10 change was not really that instructive, for the change 11 in the testimony.
12 I think in the future when you do have a
(
13 significant change, rather than just making the words 14 precise, you ought to give a full explanation of why it 15 was imprecise before and is now correct.
16 But we'll just have to accept this as an anomalous 17 situation.
18 Mr. Guild, you'll be able to prepare on recross for 19 this particular item.
20 MR. STEPTOE: I apologize, Judge Grossman, 21 both to you and to counsel.
22 JUDGE COLE: Will your statistician be 23 addressing the contents of this Applicant's Exhibit 133, i Mr. Steptoe?
24 25 MR. STEPTOE: He certainly can, but he was
- Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13912 v
basically -- his testimony basically only says that the 1
2 . random portion of the sample was, in fact, random.
3 But he certainly would be available for questions 1
4 on this. It's a straight -- I'd better not say that.
! 5 JUDGE COLE: I guess I have one or two 6 questions about this. Maybe the panel might know the 7 answer to it.
8 The 189 items, randomly-selected items, that were 1
9 initially selected were selected f rom the population of a
10 8,575 on a random basis, were they not?
11 WITNESS KAUSHAL: That's correct, your Honor.
12 JUDGE COLE: So apparently what they've done 13 here is, since they used only 60 of the 189, which is 14 only one-third of the entire number of random samples 15 that they originally selected, they just assumed that 16 that proportion should be the proportion of the entire i
17 population size that they used?
I 18 I guess I don't see the basis for that calculation, 19 myself. The original population was selected from the
! 20 entire population -- the original sample was selected 21 from the entire population, but they didn't use all of 22 those that they sampled.
23 So they then reduced the estimated population size i 24 because of that?
25 WITNESS KAUSHAL: Your Honor, I can explain 1
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 i
(312) 232-0262
13913 2 .
A 1 that very easily.
2 JUDGE COLE: All right.
I 3 WITNESS KAUSHAL: In fact,-I thought I 4 explained that, and there were several questions and 5 answers on that in cross examination.
6 In the electrical. categories, we did not.have a 7 good handle on the precompiled list of QC-accepted and 8 completed items; but for the purpose of sampling, we 9 were supposed to take only QC-accepted and completed i
j 10 items.
11 So instead what we did was we identified everything
[h 12 that was designed, without any attention to whether or
'V 13 not it was QC-accepted or completed.
4 14 We then picked an item out of that at random and 15 then applied a test to it to determine whether or not it
. 16 was QC-accepted and completed. If it was, then it was I 17 an acceptable sample. If it was not, it was not.
i 18 We had to go through 189 items in order to come up 19 with 60 items that were QC-accepted and completed.
20 Now, purely from a statistical ratio point of view, 21 all we are now doing is making an estimate that, given
- 22. that the total population of designed items was 8,575
)i 23 and given that out of 189 of such items we found 60 that 24 were QC-accepted and completed, it stands to reason then
) 25 by the simple ratio that 2,722 items were QC-accepted i Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13914 t
o 1 and completed.
2 Now, I also go on to say that this number of 2,722-3 plays only a role in the size of the sample that we 4 select, and it's a very minor,. weak role; namely, if
, 5 this population number is beyond a certain-point, then 6 the random sample is always 60.
7 So it really does not play that big a role, except 8 as an estimate of what the QC-accepted items were at 9 that time.
10 JUDGE COLE: Your response is very helpful, 11 and it answers my question. Thank you, sir.
[ \ 12 WITNESS KAUSHAL: Thank you, sir.
13 JUDGE GROSSMAN: By the way, are you sure now 14 that the 8,575 represents the total number of items in
) 15 that category?
16 I assume you got that, I believe you said, from the 17 S & L drawings.
18 WITNESS KAUSHAL: Yes, sir. That is a --
19 that number comes out of the design by going through all 20 the drawings and documents there are.
21 JUDGE GROSSMAN: Okay.
22 MR. STEPTOE: Judge Grossman, I move for the 23 admission into evidence of Applicant's Exhibit No. 133.
24 JUDGE GROSSMAN: Any objection?
l
- 25 MR. GUILD
- I'm considering, Mr. Chairman.
i l
Sonntag Reporting Service, Ltd.
? ueneva, Illinois 6u144 (312) 232-0262
13915 O
O 1 Just a moment.
2 MR. BERRY: No objection f rom the Staf f, Mr.
3 Chairman.
4 MR. STEPTOE: Judge Grossman, I move -- well, 5 first of all, Mr. Grossman, with respect to Applicant's 6 Exhibit No. 134, is this list of -- did I say "Mr.
7 Grossman"? I'm sorry.
8 BY MR. STEPTOE:
9 Q Dr. Kaushal, with respect to Applicant's Exhibit No.
10 134, is this list of attributes excluded or 11 justification for alternate criteria for the five 12 additional electrical construction categories correct?
( )
13 A (WITNESS KAUSHAL) Is it --
14 Q Is it correct?
15 A (WITNESS KAUSHAL) Yes, sir.
16 0 Is it from the official BCAP records?
17 A (WITNESS KAUSHAL) It's f rom the of ficial BCAP records.
18 MR. STEPTOE: I move for the admission of 19 Applicant's Exhibit No.134.
I 20 JUDGE GROSSMAN: By the way, did we hear if l
i 21 there were objections to 133?
- 22 Do you object, Mr. Guild?
l
! 23 MR. GUILD: May I reserve on that, Mr.
24 Chairman?
25 I'd like to consider the matter more carefully.
j Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
- , - _ - - . . . _ -- . - - - = _ _ - - -.- - _ _ . .
13916 0
1 1 JUDGE GROSSMAN: You may wish to voir dire?
2 MR. GUILD: I may, but I wish to consider the t
3 matter.
4 JUDGE GROSSMAN: How about 134?
5 MR. GUILD: 134 is fine. I have no objection 6 to it.
7 JUDGE GROSSMAN: Mr. Berry?
8 MR. BERRY: No objection, Mr. Chairman.
9 JUDGE GROSSMAN: Okay. We'll admit 134 and 10 reserve ruling on 133.
11 (The document was thereupon received into 12 evidence as Applicant's Exhibit.No. 134.)
i 13 JUDGE GROSSMAN: Now, my recollection is that 14 you didn't offer 132.
15 MR. STEPTOE: Oh, well, I certainly meant to 16 offer Applicant's Exhibit 132, and I do so now, Judge 1
17 Grossman.
18 JUDGE GROSSMAN: Okay. The reason is because 19 we didn't have copies.
' 20 Is this 132?
l 21 (Indicating.)
l
! 22 MR. STEPTOE: It's the history of CBL-001.
l 23 JUDGE GROSSMAN: Okay. I guess we still 24 don't have copies.
25 MR. STEPTOE: We haven' t got copies yet.
f Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262 _ _ _ . _ _ _ _ _ _ _
13917
/O 1 Perhaps we should reserve until then.
2 JUDGE GROSSMAN: Okay. We will reserve on 3 132, and we'll let the record show -- this is 131?
4 (Indicating.)
5 MR. STEPTOE: The cable package, yes.
6 JUDGE GROSSMAN: Okay. I believe we 7 admittted 131, and we'll just let the record note that 8 we are now receiving our copies of that.
9 BY MR. STEPTOE:
10 0 Mr. Shevlin, at some point during his cross examination, 11 Mr. Guild asked Dr. Kaushal how many items were h 12 excluded, during the sample-picking process, on the
[V 13 basis that they were inaccessible.
14 Do you recall that question?
15 A (WITNESS SHEVLIN) Yes, sir.
16 Q Do you know what the answer to that question is?
17 A (WITNESS SHEVLIN) 19 items in the electrical area, sir.
18 Q And how did you find out that answer, sir?
19 A (WITNESS SHEVLIN) By a review of the BCAP Forms 21-8 20 for all the electrical population, sir.
21 0 And those Forms 21-8 are in the sample-selection 22 packages, sir?
23 A (WITNESS SHEVLIN) Yes, sir.
24 MR. STEPTOE: We have those sample-selection y ) 25 packages, and we have had them for several days in the Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262 .. - - - _ _ -
13918
\
)
1 room. We'll make them available to Mr. Guild if he 2 wants to check that.
3 Judge Grossman, my next series of questions relates 4 to the conduit support reverification plan. I'd like to 5 get some of those documents into evidence.
6 MR. GUILD: Just for clarity, Mr. Chairman, 1
7 Mr. Shevlin's last response -- does that apply to items I l
8 that have been designated as items and, therefore, were l l 9 excluded or is that before a population -- a member of 10 the electrical population was designated a sample?
11 MR. STEPTOE:. That's a good question.
12 Perhaps I should go through that.
13 BY MR. STEPTOE:
, 14 Q Dr. Kaushal, would you explain the sample-selection l
l 15 sequence?
l 16 A (WITNESS KAUSHAL) Yes, sir.
17 As I was just talking about, in fact, on an earlier 18 exhibit, the basic process was that we had the number of 19 design items first identified. An item was selected at 20 random out of this population.
21 The next test that was applied was whether or not I 22 it was QC-accepted and completed as of June 30, 1984.
23 Once that test was passed, then the next test that 24 was applied was whether or not it was accessible for
! 25 inspection.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 f (312) 232-0262
13919
'(
V 1 If the item was accessible, then it was part of the 2 sample. If the item was not accessible, then that item 3 was dropped f rom the sample and the sample-selection 4 process continued with the next item.
5 What Mr. Shevlin is referring to is a count from 6 the record of this process that is maintained -- has 7 been maintained for each of the construction categories' 8 populations.
9 A- count f rom that indicates I believe the number 19 10 that Mr. Shevlin talked about as the total number of 11 items that were considered inaccessible.
Ih 12 MR. GUILD: Just for clarity, with respect to U the cable population in Applicant's Exhibit 131, it's 13 14 the table that's " random sample identification" and the 15 column that reads " accessible."
16 That's the data source for Mr. Shevlin's response?
17 WITNESS KAUSHAL: If the question is directed 18 to me, for cable, my recollection is everything is 19 accessible -- or was.
20 But there is an equivalent form for other 21 populations.
22 MR. GUILD: That would be the data source for 23 Mr. Shevlin?
_s 24 WITNESS KAUSHAL: That would be the data
( 25 source.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262 ._. _-_.
.. _ ~
i 13920
' h(~'N 1 MR. GUILD: Okay. l l
2 JUDGE GROSSMAN: Excuse me.
3 Maybe I'm dense here, but looking at Applicant's 4 Exhibit 133, I take it -- and maybe I'm wrong on this --
5 were the inaccessible cables part of the -- the 19 6 inaccessible cables part of the 129 items that were not 7 used, Dr. Kaushal?
8 WITNESS KAUSHAL: Your Honor, for cable it 9 was very simple. There were no inaccessible items.
10 JUDGE GROSSMAN: Oh, there were not. Oh, I 11 see, okay. I thought you were talking about cables.
12 Now, what were the inaccessible items?
(J) 13 WITNESS SHEVLIN: Sir, in all electrical 14 populations, there were a total of 19.
15 JUDGE GROSSMAN: Oh, okay.
16 If there had been -- well, I don't want to 17 complicate the matter. That's fine.
18 Well, maybe it isn't complicating the matter, 19 because I assume you have a similar memo, similar to 20 Applicant's Exhibit 133, with regard to the other five 21 types of inspections; is that correct?
l 22 WITNESS KAUSHAL: Yes, your Honor. l 23 JUDGE GROSSMAN: And I take it that wherever 24 those inaccessible items are, they would have been 25 thrown out as part of the nonusable sample items?
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
I l
I 13921 4
I l (
l l WITNESS KAUSHAL: Your Honor, if my logic is 2 correct, I assume this will be what will be on the other 3 forms.
4 Where on the exhibit it says " estimated population 5 size," it says "60 over 189." 60 is the total number of 6 items found to be QC-accepted and completed, regardless 7 of whether or not they were accessible.
8 JUDGE GROSSMAN: Oh, okay.
9 So they wouldn' t be part of the 19? If they had 10 occurred with cables, they wouldn't be part of the 19; 11 they'd be part of the 60?
12 WITNESS KAUSHAL: They'd be part of the 60, 13 and the denominator will be the total number that we had 14 to go through to come up with the 60 QC-accepted and 15 completed items.
16 JUDGE GROSSMAN: Okay.
17 In other words, they'd be thrown out after you got 18 to the 60?
19 But then you would have to get other samples to i
20 take their place.
21 WITNESS KAUSHAL: Yes, sir. I understand j
22 where your concern may be coming up.
23 The item 60 in this case happens to be the random 24 sample size, but for other populations the calculation 25 should include not only the sample but also those that 4
j Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
-. _~ . -_. .-
1 13922
(
1 were found inaccessible but QC-accepted and completed.
2 MR. GUILD: Well, if I can jump in, Applicant 3 made available, Mr. Chairman, that comparable document 4 for cable pan hangers.
5 I'm looking at it, and it appears that only if the 6 item passed the test of being accessible did it receive 7 a CSR sample number designation. That would seem to 8 suggest that inaccessibles fell in the --
9 JUDGE GROSSMAN: 129, rather than the 60.
10 That's what it suggests to me.
11 MR. STEPTOE: Judge Grossman, if we could
( 12 take a brief break, I think we can clear this up.
13 JUDGE GROSSMAN: Okay, fine. Why don't we 14 take our recess now for 10 minutes.
15 (WHEREUPON, a recess was had, after which 16 the proceedings were resumed as follows:)
17 JUDGE GROSSMAN: Mr. Steptoe, please 18 continue.
19 BY MR. STEPTOE:
20 Q Dr. Kaushal, do you have an answer to Judge Grossman's 21 question as to whether inaccessible items are included 22 or excluded f rom the calculations of the type shown in 23 Applicant's Exhibits No. 133?
24 A (WITNESS KAUSHAL) Yes, I do.
( ) 25 Let me explain, your Honor.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 f (312) 232-0262
4 13923 1 During the recess, I went through another 2 population, cable pan hangers. As an example, in that 3 one we looked at 114 items at random f rom the designed 4 total population. Out of that, 67 items were found to 5 be QC-accepted and completed. Out of those 67, seven 6 were found to be inaccessible.
7 To estimate the population of QC-accepted and 8 completed items, we used 67 in the numerator and 114 in 9 the denominator and then multiplied that by 6,413, which 10 is the total number of designed -- items out of the 11 design.
12 So to answer your question directly, your Honor,
(
13 the inaccessible items are included both in the
- 14 numerator and in the denominator.
15 JUDGE GROSSMAN: Okay.
16 But subsequently they' re not inspected by BCAP;
- 17 they're thrown out as part of the samples inspected?
18 WITNESS KAUSHAL: That is correct, your 19 Honor. Inasmuch as they were found to be inaccessible, 20 they were not included in the sample to be inspected. ,
21 JUDGE GROSSMAN: Now, let me ask you, by the 22 way -- I hate to interrupt, Mr. Steptoe.
23 You' re indicating now that only a third of the 24 cables, approximately, and only about half of whatever 25 other population you' re talking about was QC-inspected Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13924 O ,
1 and accepted. That suggests that there was a very large 2 population that hadn' t yet been QC-inspected.
3 Is that so?
l 4 WITNESS KAUSHAL: QC-inspected and accepted, 5 yes, sir, your Honor. That's what it means.
4 6 JUDGE GROSSMAN: Well, now, how valid would 7 your projections be from the samples that were inspected 4 8 under BCAP to the items that were not yet QC-inspected
- j. 9 and. accepted, considering that the circumstances of QC 10 inspection are considerably different with items that 11 are yet. to be inspected than they are with regard to 12 items already inspected?
13 That's a long question, but I think you can
, 14 understand it. <
15 WITNESS KAUSHAL: I understand your question, 16 your Honor.
17 The results f rom the BCAP reinspection program, at 18 least on mathematical terms, apply only to the universe 19 that was available for inspection at that time, which is 20 that portion of-the total work that was QC-accepted and 21 completed at that time.
L -22 Any other extension of that result will have to be 23 then considered in light of what it means vis-a-vis the
[.
24 system that existed at that point versus the system that 25 existed thereafter.
I Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13925 1 JUDGE GROSSMAN: Okay.
2 But you do, I would expect, recognize that there's 3 a big difference between -- well, not just in-process --
4 well, perhaps that's a word -- that is not a correct 5 differentiation, but between inspections performed 6 basically contemporaneous with the work being done and 7 those inspections that are being done on a backlog 2 8 basis? r 9 You do recognize that there might well be a 10 difference in kind, don' t you?
11 WITNESS KAUSHAL: Your Honor, I' don't -- I'm 12 not sure I agree with your characterization that one is 13 a backlog versus one being in-process.
14 In fact, the things that were not reinspected -- I 15 mean, inspected and OC-accepted at that time --
16 basically you're presented ongoing work in some form or 17 another. A lot of that work was completed soon 18 thereafter, and much more was completed much later in l 19 time.
20 But the work goes on all the time. We just had to 21 cut off the date at a particular point in order for the 22 work to be done --
23 JUDGE GROSSMAN: Okay.
24 WITNESS KAUSHAL: -- by us.
) 25 JUDGE GROSSMAN: I understand that.
- Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
1 13926 d
1- Mr. Steptoe?
2 MR. STEPTOE: Over the break, I think Mr.
3 Wozniak spoke to Mr. Thorsell about the subject of 4 stress cones, and he'd like to correct his testimony.
5 Mr. Wozniak?
6 WITNESS WOZNIAK: Yes, sir, Mr. Steptoe.
7 In the exhibit there of the power cable 8 termination, that is not, in fact, a stress-cone-type 9 condition.
10 BY MR. STEPTOE:
11 0 You' re referring to the wrapping of the tape at the 12 juncture of the three cables?
13 (Indicating.)
14 A (WITNESS WOZNIAK) Yes, sir. That stress cone applies 15 to the application of a power cable that would be 16 shielded.
17 In this case this cable is not shielded. that 18 primarily is a cosmetic dressing.
19 MR. STEPTOE: Mr. Thorsell will be able to 20 talk more about stress cones and their use in the plan, 21- Judge Grossman.
22 Judge Grossman, the next step in my redirect is 23 essentially to introduce records relating to the conduit 24 support reverification program.
25 What I'm seeking to introduce into evidence is Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134
[ (312) 232-0262
13927 )
f}
\~s) 1 l
1 incomplete in that it includes Sections 1, 2, 3, 4 and 5 1 2 and Exhibits A through G.
3 But the last three exhibits in the package I have 4 not given to you simply because I didn't want -- it was.
, 5 unnecessary for my purposes. Those exhibits are 6 available here in the courtroom.
7 I'd like to walk Dr. Kaushal through this package 8 and have him identify the documents that we' re looking 9 at.
10 I'd like this conduit support reverification 11 program package to be marked as Applicant's Exhibit 135.
12 (The document was thereupon marked 13 Applicant's Exhibit No.135 for 14 identification as of October 8, 1986.)
'15 BY MR. STEPTOE:
l 16 Q Dr. Kaushal, the first page is marked " table of 17- contents." l 18 When was this created?
i 19 A (WITNESS KAUSHAL) Mr. Steptoe, my recollection is that 20 this document was prepared soon af ter thisiprogram that 21 was called " conduit support reverification program" was 22 completed.
23 Q Referring to Section 1, entitled " introduction," would 24 you identify this, please?
l
, g 25 Who is the author?
i Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262 - - . - . . . .
13928 V
1 A (WITNESS KAUSHAL) Most of this document .as prepared 2 by Mr. Byers, who was the assistant director -- one of 3 the two assistant directors under me.
4 Q Okay.
5 Referring down to the next to the last sentence on 6 Page 1 of 1 under " introduction," the statement is that, 7 "All 51 conduit support reinspection packages completed 8 prior to January 24, 1985, were reinspected in 9 accordance with the approved reverification plan."
10 Would you agree with the statement made by Mr.
11 Wozniak yesterday, in response to Mr. Guild, that the
[ ), 12 word " reverification" would probably be a better word to
\~/
13 use than " reinspection"?
14 A (WITNESS KAUSHAL) That would be correct, yes.
15 Q Could you go on to Section 2, Dr. Kaushal? Would you 16 explain what Section 2 is?
17 A (WITNESS KAUSHAL) Section 2 are I believe documents, 18 NRC documents, that are the background -- these are 19' inspection reports, Mr. Steptoe.
20 0 I'm sorry. I can't hear you, Dr. Kaushal.
21 A (WITNESS KAUSHAL) These are the inspection reports 22 that relate to this particular program.
23 0 okay.
_ 24 Section 3, Dr. Kaushal -- could you identify that,
_25 please?
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13929 1 A (WITNESS KAUSHAL) Just a second.
2 Section 3 is ERC observation. I'm trying to get to 3 it.
. 4 0 This is the same as Intervenors' Exhibit 153, which was 5 admitted into evidence previous 3y. I'll just say that 6 for the record.
, 7 A (WITNESS KAUSHAL) Mr. Steptoe, Section 3 is not in the 8 section I have here.
9 0 Okay.
10 A (WITNESS KAUSHAL) I see it in the index, but I don't 11 have it here.
4 I ) 12 MR. STEPTOE: As for that, we'll provide a 13 Section 3. I will just represent to the Board that 14 aside from a cover page, it is the same as Intervenors' 15 Exhibit 153, which is the ERC observation report.
16 BY MR. STEPTOE:
I 17 Q Can you identify Section 4, please?
18 A (WITNESS KAUSHAL) Yes. Section 4 is the response f rom 19 BCAP CSR and the corrective action in response to ERC 20 Observation 11.
21 Q I note the first page of that, Dr. Kaushal, is a letter 22 dated February 21, 1985, to you, from Mr. Hansel, 23 closing out ERC Observation 011; is that correct?
24 A (WITNESS KAUSHAL) That's correct.
25 0 And the last page of this Section No. 4 represents a Sonntag Reporting Service, Ltd.
( Geneva, Illinois 60134 l (312) 232-0262
13930 f) 1 response to the ERC Observation No.11?
2 A (WITNESS KAUSHAL) That is correct.
3 0 And that response -- whose initials are there down at 4 the bottom?
5 A (WITNESS KAUSHAL) That is also Mr. Byer's response --
6 Mr. Byer's initials; I'm sorry.
7 0 Okay.
8 Can you identify Section 5 of this document, sir, 9 entitled " summation"?
10 A (WITNESS KAUSHAL) That's a summary description of the 11 work, yes.
12 That's a summary description of what work, sir?
( Q 13 A (WITNESS KAUSHAL) Of the conduit support 14 reverification program and the conclusions.
15 0 Was that prepared by Mr. Byers or by you?
16 A (WITNESS KAUSHAL) That was also prepared by Mr. Byers.
17 Q Does that reflect the work that was done in response to 18 BCAP Observation ll? '
19 A (WITNESS KAUSHAL) Yes, it does.
20 0 The next page is a BCAP memo, No. 546. It's actually 21 Exhibit-A to this package, although it's not marked as 22 such. It's dated January 23, 1985.
23 It's a memo that you wrote, is it not?
l 24 A (WITNESS KAUSHAL) That is correct.
25 0 And it describes your decision that it would be a good Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13931 V
1 idea to do a midpoint look; is that correct?
2 A (WITNESS KAUSHAL) That's correct.
3 0 Could you describe the following two pages, which is a 4 January 24, 1985, BCAP Memo No. 551, authored by you?
5 A (WITNESS KAUSHAL) That is correct.
6 That's a memorandum in which, subsequent to 7 discussions with my staff, I identified areas in which 8 we would like to -- we would do more work and 9 identifying at the same time that in areas other than 10 those that are specifically identified in this 11 memorandum, we could proceed with the work.
12 0 The following page, Dr. Kaushal, appears to be an
(
13 attendance roster for a training session, dated January 14 30, 1985.
15 A (WITNESS KAUSHAL) That's correct.
16 0 Mr. Wozniak, I note that your signature is on that 17 document, isn't it?
i 18 A (WITNESS WOZNIAK) That is correct.
19 0 That indicates that you attended that training session?
20 A (WITNESS WOZNIAK) That's also correct.
21 0 The following page, Dr. Kaushal, is BCAP Memo 616, a 22 three-page memo entitled " reverification plan for 23 electrical conduit hangers."
24 Could you describe what this is, sir?
l (O) 25 A (WITNESS KAUSHAL) This describes the work that was Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13932 O
1 done in response to the ERC Observation 11 and any other 2 areas that might have been identified by virtue of the 3 training session and other discussions between the 4 inspectors and engineers.
5 O Mr. Wozniak, could you identify the last page of this 6 reverification plan, which looks like a checklist?
7 A (WITNESS WOZNIAK) Mr. Steptoe, this is a sample copy 8 of the reverification checklist used for the conduit 9 hanger population.
10 0 Okay.
11 Under "special instructions," the phraseology is a 12 little confusing to me. There's a sentence that reads (J) 13 -- the second sentence under "special instructions" 14 reads, " Record documented as status."
15 Could you explain what that meanc?
16 A (WITNESS WOZNIAK) That should read " record documented 17 as."
18 In other words, under the first column there where 19 it says " inspection by/date," that would be the initials 20 identifying who the original inspector was of the 21 conduit hanger. The second column would be the 22 reverification inspector.
23 That " record documented as status" pertains to the
, 24 third column in that it would record the status as it 25 was documented: either " accept," " reject" or "not Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
l 1
I 13933 i r.
s_/ i 1 applicable."
2 Q By the initial BCAP inspector?
3 A (WITNESS WOZNIAK) Yes, sir.
4 Q And then the fourth column, " reverified as"?
5 A (WITNESS WOZNIAK) That would be the results that would 6 be reverified as by the reverification inspector.
7 Q The following page is a memo from Mr. Shea to Mr.
8 Clinton, which also appears to be an attendance roster.
9 A (WITNESS KAUSHAL) That's correct.
10 0 Mr. Wozniak, is that your signature on that page?
11 A (WITNESS WOZNIAK) Yes, it is, second from the top.
12 Q All right.
13 Then the next part of this Applicant's Exhibit 135 14 is a four-page document entitled " reverification 15 results."
16 Dr. Kaushal, are these, in fact, the results of the 17 conduit support reverification?
)
18 A (WITNESS KAUSHAL) That's my recollection, yes.
19 Q And the next package, which is a rather lengthy package i 20 -- Mr. Wozniak, would you just -- are these, in fact,,
21 the completed reinspection checklists?
22 A (WITNESS WOZNIAK) These are copies of the reinspection 23 checklists pertaining to the 51 packages in
,, 24 question.
- ) 25 0 And, in fact, Mr. Wozniak, is this package what you l
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262 _
l l
13934
/N )
m/ j 1 referred to the other day in attempting to respond to 2 Mr. Guild's questions about the conduit support 3 reverification program?
4 A (WITNESS WOZNIAK) Yes, sir.
5 MR. STEPTCE: Judge Grossman, I move that 6 Applicant's Exhibit No. 135 be admitted into the record.
7 JUDGE GROSSMAN: Well, when did you make up 8 this package, Mr. Steptoe?
9 MR. STEPTOE: This came right out of the BCAP 10 files, Judge Grossman. It was created a long time ago.
11 JUDGE GROSSMAN: Okay.
12 Apparently some of these items are admissible, 13 assuming --
14 MR. STEPTOE: Oh -- I'm sorry.
15 JUDGE GROSSMAN: -- assuming that they're 16 part of proper redirect, provided they're within the 17 scope of the direct and within the scope of the cross i
18 examina tion.
19 Other parts, even if they' re part of a package that i.
L 20 were put together contemporaneous 1y in the past, don't 1
21 become admissible because they' re part of a package if 22 they're not admissible on their own.
23 Now, if Mr. Guild has no objection to any of this I
24 nor has Mr. Berry, we'll admit the package.
25 Mr. Guild? ,
Sonntag Reporting Service, Ltd.
i Geneva, Illinois 60134 (312) 232-0262
13935 ,
1 MR. STEPTOE: Judge Grossman, you pointed.out 2 a mistake by me, which is that there is an NRC 3 inspection report in here.
4 I didn't offer that to prove the truth of the 5 matters assserted but for the context; that is, the 6 thing to which BCAP was responding.
7 JUDGE GROSSMAN: Okay.
8 MR. GUILD: Mr. Chairman, I. don't object to 9 the admission of the entire document, but I want the 10 entire document in.
11 Let me, if I can, by way of reference -- indeed, 4
\ 12 the inspection report that's included in-this document
.13 has been previously offered as Intervenors' Exhibit 146
~
14 and was excluded on the grounds of hearsay.
15 Let me direct the Board's attention to Federal Rule 16 of Evidence 801-D-2, " admission by a party opponent."
17 In particular, Judge, I believe that the 18 Applicant's offer of this-package now demonstrates that I
19 the inspection report, either in its original form as an 20 Intervenors' exhibit or as a portion of this report, is 21 now admissible for proof of the matters asserted on the 22 grounds that this represents not only either a statement
. 23 by a party or a statement - "B, a statement of which he
! 24 has manifested his adoption or belief in its truth."
\
25 Now, the reliance on the NRC inspection report --
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13936 O
1 its adoption by BCAP for purposes of performing the 2 conduit support reverification program demonstrates --
3 JUDGE GROSSMAN: Wait.
4 Before you go any further, Mr. Guild, do you wish 5 to have that NRC report in?
6 MR. GUILD: I do.
7 JUDGE GROSSMAN: I take it you have no 8 objection to the report going in, Mr. Steptoe?
9 MR. STEPTOE: No, Judge Grossman.
10 JUDGE GROSSMAN: Okay.
11 Is there anything in this document, Applicant's ex (d ) 12 13 Exhibit 135, that you do object to going in?
MR. GUILD: The only question -- I don't 14 object to anything I see so far; but as Mr. Steptoe 15 observed, it's not a complete document.
16 I simply would ask that there be, for the record, 17 an identification of those portions that are not 18 included, beyond simply the reference on the cover page.
19 Perhaps either by voir dire or through Mr. Steptoe 20- the witness could simply explain what the portions are 21 that are being omitted, just for clarity.
22 JUDGE GROSSMAN: Okay. That's fine.
23 Now, with regard to the portion that had previously
- 24 been admitted as Intervenors' Exhibit 153, there's a
() 25 notation on my cover page that that's included here.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13937 o
Y l l
1 There's no point to having it included in the package if 2 it's already admitted into evidence.
3 So I think it's sufficient that we have a 4 cross-reference to Intervenors' Exhibit 153.
5 MR. STEPTOE: I have no problem with that.
~
6 JUDGE GROSSMAN: I just want to point that 7 out before you go over the other parts that are not 8 included in this package.
9 MR. BERRY: Mr. Chairman, Staff has no 10 objection to Applicant's Exhibit 135, either.
11 I would inquire through the Chair, though, whether 12 the inspection report that's included in Applicant's 13 Exhibit 135 has been admitted into evidence.
14 Would it not be easier also just to admit 15 Intervenors' Exhibit 146?
16 JUDGE GROSSMAN: I'm sorry. You'll have to i 17 speak up.
j 18 MR. BERRY: Again, Staff has no objection to 19 Applicant's Exhibit 135.
20 But I would inquire through the Chair, now that the 21 inspection report that's included in Applicant's Exhibit 22 135 has been received, would it not just make it easier 23 as far as the record to receive Intervenors' Exhibi t 24 146?
j 25 JUDGE GROSSMAN: Yes. We were going to do l
l l
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262 _ . . _ _ , _
13938 G
1 that. But we'll wait for the further questioning of the 2 witn' esses as to what is excluded, and then we'll admit 3 both documents.
4 Continue, Mr. Steptoe.
5 BY MR. STEPTOE:
6 0 Dr. Kaushal, do you have in front of you a document 7 entitled " observations initiated during reverification 8 program"?
9 A (WITNESS KAUSHAL) Yes, I do.
10 Q Does that include seven observations?
11 A (WITNESS KAUSHAL) Yes, it does.
[ 12 0 And are these observations the observations that were V) 13 written during the reverification program?
14 A (WITNESS KAUSHAL) I believe so.
15 0 That is, this document corresponds to Exhibit H on the 16 cover page of Applicant's Exhibit 135?
17 A (WITNESS KAUSHAL) That would be correct, yes.
18 0 Exhibit I on the cover page of Applicant's Exhibit 135 19 refers to " feedback training." That is not included in 20 Applicant's Exhibit 135.
21 Do you-have in front of you a one-page document 22 entitled
- training session," dated February 8, 1985?
23 A (WITNESS KAUSHAL) Yes, I do.
- 24 0 Is that essentially a roster of individuals who attended 25 the training sessions?
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13939
,m
~
l A (WITNESS KAUSHAL) That would be my expectation, yes.
2 Q Again, it has Mr. Wozniak's signature on it, does it 3 not?
4 A (WITNESS KAUSHAL) Yes, it does.
5 Q Finally, Exhibit J on the cover page is "CSR-I-E-COH 6 Rev. 4 conduit hanger checklist instruction."
7 'Do you have that document before you?
8 A (WITNESS KAUSHAL) Yes, I do.
9 Q Revision 4 of checklist instructions is a rather lengthy 10 document, is it not?
- 11. A (WITNESS KAUSHAL) Yes, it is lengthy.
12 0 And does that checklist instruction indicate, by means-(
13 of a bar on the side of the instruction source document, 14 what changes were made in Revision 47
'15 A (WITNESS KAUSHAL) Yes, it does.
16 0 Okay.
17 I believe by " inspection" it indicates that a l 18 change was made in Attribute for Inspection No. 7, i 19 " wireway / conduit installation"?
20 A (WITNESS KAUSHAL) That's correct.
21 JUDGE GROSSMAN: Okay.
22 Mr. Guild, is there any part that has just been 23 described by Dr. Kaushal that you wish to have included 24 in Applicant's Exhibit 135?
)- 25 MR. GUILD: Yes. I would ask that the i
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134
- j. (312) 232-0262
'13940 O
V 1 observations initiated during reverification program be 2 included.
3 I don't think the training roster is particularly 1
4 material. Perhaps, for clarity,- the page where the 5 instructions were revised, which appears to be only a 6 small portion of the document, might also be included.
7 But I believe that the observations that were 8 initiated as a result of the reverification program are 9 material and are necessary for the document to be 10 complete.
11 MR. STEPTOE: Judge Grossman --
12 JUDGE GROSSMAN: No problem with that, Mr.
13 Steptoe?
14 MR. STEPTOE: Why don't we just put the whole 15 document in at this time -- that's fine by me -- with 4
16 all the exhibits?
17 JUDGE GROSSMAN: All the exhibits?
18 MR. STEPTOE: Yes.
19 MR. GUILD: No objection, Judge.
20 JUDGE GROSSMAN: Okay. So we'll admit both 21 Intervenors' 146 and Applicant's 135, the complete 135 22 that will be reassembled by Mr. Steptoe later in the 23 day.
24 (The documents were thereupon received 25 into evidence as Applicant's Exhibit No.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 f (312) 232-0262
13941 0
1 135 and Intervenors' Exhibit No.146.)
2 JUDGE GROSSMAN: We wish to point out for the 3 record that Intervenors' 146 was not the complete NRC 4 report, but we now have the complete report in as part 5 of Applicant's 135.
6 BY MR. STEPTOE:
7 0 Moving on, Dr. Kaushal, there was a line of questions
, 8 asked to other members of the panel with respect to, at i
. 9 the time of Mr. Gardner's and the ERC Observation No.
10 11, Mr. Gardner's concerns whether there was any_ review 11_ of their concerns for the possible generic implications 12 or root cause.
(
13 Do you recall that line of questioning?
14 A (WITNESS KAUSHAL) Yes, I do.
- 15 Q Do you believe any such review was conducted by any 16 portion of the BCAP effort?
17 A (WITNESS KAUSHAL) Yes, I do. I believe there was a 18 review conducted in that respect.
19 0 would you describe that review, sir?
20 A (WITNESS KAUSHAL) Well, the review included, as I 21 indicated earlier, detailed discussions between i 22 engineers and inspectors in terms of what the source of 23 misunderstanding might be between the inspectors and the 24 engineers with regard to attributes on which errors have i
25 been discovered.
i Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
.~ .-.. . . . . . ._ - . _ - -
l 13942 (vh i'
1 At.the same time, it's my recollection that I asked 2 Mr. Shea to take a look at not just what ERC identified 3 but if there are any other areas in the checklist and 4 instructions that the inspectors might be having some 5 difficulty with.
6 Based on those discussions, that's how areas were 7 identified where changes needed to be made in the 8 instructions.
9 It turned out that part of the reason was basically 10 a misunderstanding which could be taken care of by 11 communication, and the other one where a specific change 12 in the checkliLt was deemed appropriate.
( Subsequent to this particular point in time, we 13 14 made it a general practice that when the checklist and 15 instructions were developed, there was a session between 16 the engineers and the inspectors where the engineers b
17 could explain and answer questions on the checklist and 18 instructions.
19 Q Dr. Kaushal, there was some discussion several days ago 20 with respect to the time it took for BCAP to close out 21 and make a final determination with respect to the 37 22 red-line observations which were the cubject of an NRC 23 item of noncompliance.
24 Do you recall that issue?
25 A (WITNESS KAUSHAL) Yes, I do.
l Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 i
L (312) 232-0262
13943 O
1 Q And you were asked whether that occurred after --
2 whether that final determination of' validity occurred 3 after May 20, 1985, the date that Intervenors filed
- 4 their Quality Assurance contention.
t 5 Do you recall that question?
6 A (WITNESS KAUSHAL) I recall the question.
7 Q Was there any relationship, any causal relationship, 8 between the filing of Intervenors' Quality Assurance 9 contention and the final action that BCAP took with i 10 respect to those 37 red-line observations?
11 A (WITNESS KAUSHAL) No, there was not.
12 0 Was there any relationship in the timing of those two 13 events?
14 A (WITNESS KAUSHAL) There was no deliberate 15 relationship. If there was any, it was coincidental.
- 16. Q Dr. Kaushal, I'm going to move on to Intervenors' 17 Exhibit No.150, which consists of three memoranda to 18 you relating to the invalidation of CSR observations.
19 Let's start with the --
20 WITNESS KAUSHAL: I'm sure I have a copy of 21 that, Mr. Steptoe. Let me check my package here.
22 MR. STEPTOE: I can get you a copy, sir.
23 WITNESS KAUSHAL: No, I don't have it.
24 MR. STEPTOE: (Indicating.)
-25 WITNESS KAUSHAL: Yes, sir?
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13944 s.
1 BY MR. STEPTOE:
2 0 Let's start with the first observation which you 3 approved the invalidation of -- that's a terrible 4 sentence.
5 The first observation is CSR-I-E-EIN-078-902 --
6 actually, it's the first in this package.
7 A (WITNESS KAUSHAL) That's correct.
8 0 Could you please explain the nature of the observation?
9 A (WITNESS KAUSHAL) The nature of the observation 10 pertains to the interpretation of the drawing.
11 Actually, it more pertains to whether it was appropriate 12 for a certain detail to be specified for a particular
(
13 application, rather than what the condition in the field 14 was.
15 It was clear from the observation that a certain 16 detail had been specified, and it was the inspector's 17 belief that that detail should not have been specified 18 for that particular application.
19 0 Well, does this relate to a junction box being installed 20 in one location in the field versus another location in l 21 the field?
22 A (WITNESS KAUSHAL) Well, what it involved is that the l
23 junction box was located on the floor, while the j 24 inspector believed that the detail that was provided was l[
25 for an installation on the ceiling.
l Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13945 n\_- l 1 0 Where was the junction box supposed to be installed; on 2 the floor or on the ceiling?
3 A ~ (WITNESS KAUSHAL) The junction was shown to be 4 installed on the -- on the floor.
5 Q And that's where it was installed in the field?
6 A (WITNESS KAUSHAL) That's the way it was installed.
l 7 Q So what was the inspector's concern, as identified in 8 this observation?
9 A (WITNESS KAUSHAL) The inspector's concern or 10 observation identified that the detail that was shown to 11 go with that installation had shown the word " ceiling"
[}
%J 12 in it, and he felt that that detail was not applicable 13 or should not be applicable in that particular location 14 on the floor.
15 0 I believe there was testimony that you did not go back 16 to the Level II Inspector who wrote the observation, 17 when you decided that the observation was invalid.
18 Do you recall that testimony?
19 A (WITNESS KAUSHAL) Yes, I do.
20 0 Why didn't you go back to the Level II Inspector and 21 talk with him?
22 A (WITNESS KAUSHAL) In this particular case, based on 23 the information that I had in front of me, I concluded 24 that the matter pertained -- the matter was more in the q j 25 domain of Engineering in terms of determining as to what l
l Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13946
'fD V
1 detail was applicable in that place, rather than a 2 matter of dispute over what was really in the field.
3 There was no dispute on what was really out there 4 in the field and how it was installed.
5 Secondly, this one, as I indicated also earlier in 6 the testimony, was f rom an inspector in the BCAP QA 7 group. As was our normal practice, the invalidation of 8 this observation would have to be concurred in by QA.
9 I figured that if there was any concern in that 10 respect, I'd hear about it.
11 Q Mr. Smith, did BCAP QA concur in this invalidation?
12 A (WITNESS SMITH) Yes, sir.
13 Q Dr. Kaushal, moving on to the next memo in this package, 14 dated September 5,1985, BCAP Memo No. 3269 --
l 15 MR. STEPTOE: Can I just inquire whether this 16 was admitted as part of Intervenors' Exhibit 1507 17 It wasn't discussed directly in the cross 18 examination.
19 MR. GUILD: I'm sorry. Which document is 20 that, now?
21 MR. STEPTOE: It's got B00ll612 Bates-stamped 22 on the bottom. It's a cover memo. It's a memo from Mr.
23 Orlov, Mr. Shea and Mr. Patel to Mr. Kaushal. It's part 24 of the package that we received.
j-s I (v) 25 JUDGE COLE: It's part of my package, also.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 f (312) 232-02b2
13947
'd 1 I assume it was part of Intervenors' Exhibit 150, 2 MR. GUILD: Yes.
3 BY MR. STEPTOE:
4 Q Now, Dr. Kaushal, referring to the first observation 5 which appears here -- it's CSR-I-E-EIN-112-02.
6 A (WITNESS KAUSHAL) Yes.
7 0 -- are you familiar with that observation?
8 A (WITNESS KAUSHAL) Yes, I am.
9 0 Is that the observation which is described in your 10 direct testimony?
11 A (WITNESS KAUSHAL) That's the observation that I 12 referred to in my direct testimony, and I believe it was 13 also talked about in Mr. Wozniak's testimony.
14 0 Is that true, Mr. Wozniak?
15 A (WITNESS WOZNIAK) That's-true.
16 0 Going on to the next --
17 MR. GUILD: Could I 1. ave a more particular 18 reference?
i 19 MR. STEPTOE: Sure. It's Page 24 of Dr.
20 Kaushal's testimony, prefiled testimony, and Page 9 of 21 Mr. Wozniak's prefiled testimony.
( 22 MR. GUILD: Thank you.
I 23 BY MR. STEPTOE:
- 24 0 All right, Dr. Kaushal.
25 I'm handing you something which has been marked for I
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262 . _. _- .
I 13948 v
1 identification -- which I'd like to have marked for 2 identification, rather, as Applicant's Exhibit No. 136.
3 (The document was thereupon marked 4 Applicant's Exhibit No. 136 for 5 identification as of October 8, 1986.)
6 BY MR. STEPTOE:
7 Q Referring to the first four pages of that document, Dr.
8 Kaushal, is that Observation CSR-R-E-CND-110-01?
9 A (WITNESS KAUSHAL) That's correct.
10 Q And that's the observation that's referred to in BCAP 11 Memo 3269, which is the page of Intervenors' Exhibit 150 12 that we' re talking about; is that correct?
(
13 A (WITNESS KAUSHAL) That is correct.
14 0 And you approved the invalidation of this observation; 15 is that correct?
16 A (WITNESS KAUSHAL) That's correct.
17 0 Is this an inspection observation or a documentation 18 cbservation?
19 A (WITNESS KAUSHAL) It's a documentation review 20 observation.
21 0 Can you explain why you approved the invalidation of 22 this observation?
23 A (WITNESS KAUSHAL) The third and fourth pages of the cs 24 observation record that you gave me show a memo from Mr.
() 25 Corcoran to Sommerfield which identifies their policy Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 f (312) 232-0262
13949
/
.t
., 1 with regard to -- or their policy and procedure with 2 regard to the qualifications of the Level II reviewer, 3 and it .was clear f rom that memorandum that the 4 observation was not valid.
5 HR. GUILD: I take it that the date on that 6 memorandum is 1982?
7 MR. STEPTOE: Yes. My copy is obliterated.
8 We can find that out for the record, but I believe 9 that's correct, Bob.
10 BY MR. STEPTOE:
11 Q Moving on to the remaining pages of Applicant's Exhibit g
12 136, we have another copy of a September 5, 1985, BCAP 13 memo, No. 3269. But then we have BCAP Observation 14 Record No. CSR-R-E-CND-XXX-84.
15 A (WITNESS KAUSHAL) That's correct.
16 0 Are you familiar with that observation, sir?
j 17 A (WITNESS KAUSHAL) Yes, I am.
18 Q Did you approve the invalidation of that observation?
19 A (WITNESS KAUSHAL) Yes, I did.
20 0 Is that a documentation --
l 21 A (WITNESS KAUSHAL) Yes, it is.
l 22 0 -- observation?
l 23 A (WITNESS KAUSHAL) It is a documentation review 1
24 observation.
l 25 0 Who was the inspector that refused to concur in the Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13950
/~'N 1 invalidation of that inspection?
2 A (WITNESS KAUSHAL) Mr. Wozniak.
3 0 Mr. Wozniak, can you explain what your concern was with 4 respect to this observation?
5 A (WITNESS WOZNIAK) Mr. Steptoe, I was reviewing the 6 documentation in the Comstock vault; and I had written 7 the triple-X observation, indicating that there was a 8 line-through on the Comstock document that had not been 9 initialed and dated.
10 0 Can you show us where that line-through occurs in this 11 observation in this package?
m 12 A (WITNESS WOZNIAK) Okay. If you'll turn to the Form (J) 13 60A, which is the conduit inspection report --
14 0 That's the next to the last page of this Applicant's 15 Exhibit 136, is it not?
16 A (WITNESS WOZNIAK) That is true.
17 It's dealing with the second and third entries on 18 the top of the inspection form that contains the basic 19 information relative to the inspection.
20 You'll note that there's a line-through on the 21 conduit size and a line-through through an entry that's 22 indicated as "PlE."
23 0 Is "PlE" a conduit size, sir?
,s 24 A (WITNESS WOZNIAK) No, sir. "PlE" is a conduit
( 25 segregation code, okay.
l Sonntag Reporting Service, Ltd. )
Geneva, Illinois 60134 '
f (312) 232-0262
1 13951 (v.b 1 In the block marked " segregation code," there's a 2 line-through through an entry of a three-inch 3 designation.
4 0 And three-inch is a conduit size, I take it?
5 A (WITNESS WOZNIAK) Yes, sir.
6 0 And the correction is -- well, would you explain what 7 the correction was that appears on this document?
8 A (WITNESS WOZNIAK) Okay.
9 What appears in reviewing this document is that the 10 originating inspector had inappropriately indicated the 11 conduit size and seg codes on the wrong lines of the 12 checklist, and he had lined through both entries and
(} elected only to initial and date one of the entries.
13 14 So I, as an inspector, had indicated that I felt an 15 observation was appropriate and wrote an observation to 16 the effect that there was a line-through lacking an 17 initial and date.
18 Q And the BCAP engineers who reviewed your observation 19 invalidated it; isn' t that correct?
2:0 A (WITNESS WOZNIAK) Yes, they did.
21 Q And you refused to acknowledge?
22 A (WITNESS WOZNIAK) I declined the acknowledgment of the 23 observation, yes, sir.
24 0 Why not? Why did you refuse to -- why did you decline 25 to acknowledge that decision?
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13952
,e- .
(
1 A (WITNESS WOZNIAK) On a sheer hardheaded technical 2 interpretation of an ANSI standard, I had felt that the 3 segregation code line-through was, in fact, lacking an 4 initial and date.
5 Although it is quite obvious that it's an error in 6 the transposition of the information contained and no 7 information had been obliterated, that was my 8 interpretation at the time as an inspector.
9 Q Now, Dr. Kaushal, we have here -- in Intervenors' 10 Exhibit 150, we have one observation which the inspector 11 declined to acknowledge in BCAP Memo No. 3368, which is 12 the first one in this package.
[J) 13 We have three more such observations listed on Page 14 B0011612, which is a September 5, 1985, BCAP Memo 3269.
15 Then we have -- I don' t have the number -- in the -
16 last package BCAP No. 3240, a larger number of 17 invalidations where the inspector refused to tacknowledge 18 the invalidation; isn' t that correct?
19 A (WITNESS KAUSHAL) That's correct.
20 0 Now, on how many other occasions for the electrical 21 population were there invalid -- were there observations 22 which were invalidated and the BCAP inspector refused to 23 concur?
24 A (WITNESS KAUSHAL) To my knowledge, none.
(O) 25 Q How many of these observations relate to inspections, as Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
L 13953 p
1 opposed to documentation reviews?
2 A (WITNESS KAUSHAL) A total of two.
3 Q Mr. Shevlin, who inspected concrete expansion anchors 4 for the electrical -- for the electrical construction -
5 categories?
6 A (WITNESS SHEVLIN) We had a civil structural group that 7 did the concrete expansion anchors for all populations.
8 Q And that was not your group, sir?
9 A (WITNESS SHEVLIN) That was not my group.
10 0 Mr. Wozniak, that was not your group, either?
11 A (WITNESS WOZNIAK) No, sir, that was not my group, 12 either.
13 Q Dr. Kaushal, do your results in Attachments 2C Kaushal-2 14 and Kaushal-3 for the BCAP program as a whole for the 15 electrical population -- do they include the results of 16 CEA inspections?
17 A (WITNESS KAUSHAL) Yes, they do.
18 Q Now, do your results for the CSR data base, Attachment 19 No. 4 -- do they include any results for the CEA 20 inspections?
21 A (WITNESS KAUSHAL) They do not.
22 Q Why not?
23 A (WITNESS KAUSHAL) The Comstock inspectors -- the CEA 4
24 inspections were actually done by PTL, not by Comstock R
) 25 inspectors.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13954 O
1 Comstock inspectors did do some sampling-type 2; inspections in order to assure that the process was 3 working okay, but the QC acceptance of the CEA's is 4 based on PTL inspections.
5- Q Now, you will recall a few days ago there was cross 6 examination with respect to cable pan hanger package No.
7 104.
8 I believe there was some discussion of .whether the 9 number of welds indicated on the PTL transmittal forms, 10 which were filled out by Comstock at the time of'their
~
11 weld inspections, could be correlated with the number of 12 welds shown in Attachment No. 4, which is a weld count
'[V) 13 performed by.Sargent & Lundy.
14 Do you recall that cross examination?
15 A - (WITNESS KAUSHAL)- Yes, I do.
16 0 Okay.
17 Have you, since the time of that cross examination, 18 thought of any reason why those numbers might not 19 correlate?
20 MR. GUILD: Objection. The question clearly 21 calls for speculation. I could think of some reasons, 22 too, but I'm not competent to testify.
23 Just because Dr. Kaushal can think of some reasons 24 doesn' t establish that what answers to be elicited f rom
) 25 that question are evidence.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13955 G
U.
1 JUDGE GROSSMAN: We'll overrule that. We'll 2 allow the answer, but I hope he would give his basis for 3 believing that. ;
4 So you may answer.
i- 5 A (WITNESS KAUSHAL) I.did not make it clear. In fact, 6 it was implicit in the answer that I gave, which was 7 that for the purpose of Kaushal-4, a complete inspection j 8 was assumed.
9 A complete inspection in this case -- what I meant 10 was -- but I did not recall it at that time; I did not 4
. 11 explicitly state it -- but it included all the welds on
-12 that hanger.
(
13 It occurred to me later that part of those welds i 14 may be Systems Control welds. They are vendor-supplied 15 or shop-fabricated welds.
16 The BCAP inspection of cable pan hangers was l
17 complete in terms of the welds. It did not distinguish
! 18 between Systems Control or Comstock welds.
l 19 But the Comstock inspectors performed a certain 20 subset of those welds, and that subset is not clearly
- 21 identified.
i 22 JUDGE GROSSMAN: I'm not sure I understand 23 that answer.
l 24 We are talking about the figure 24, aren't we, for l
l (b) 25 the number of welds that were not properly -- for which i
Sonntag Reporting Service, Ltd.
, Geneva, Illinois 60134 (312) 232-0262 .
13956
[ -
Q l there were observations?
2 MR. STEPTOE: No, Judge Grossman. We're --
3 WITNESS KAUSHAL: I -- excuse me.
4 MR. STEPTOE: Go ahead.
5 WITNESS KAUSHAL: I was talking about the 6 total number of welds as well as the discrepant welds.
7 What you are remembering, I believe, are 24 8 discrepant welds.
9 JUDGE GROSSMAN: Yes. That's what I meant.
10 WITNESS KAUSHAL: The 24 discrepant welds are 11 out of the total number of welds that BCAP inspected.
12 BCAP inspected all the welds that were there on that 13 hanger, which included both those welds made by Systems 14 Control and those welds that were made by Comstock.
15 BY MR. STEPTOE:
16 0 And what was that number, Dr. Kaushal, do you recall?
17 A (WITNESS KAUSHAL) My recollection is 128 welds per 18 hanger. That's my recollection, and that includes the 19 Comstock welds as well as the --
20 JUDGE GROSSMAN: Yes, but my understanding --
21 and maybe I'm wrong on that -- was that we couldn't 22 correlate the discrepant welds with the ones shown on 23 the drawing.
24 MR. STEPTOE: That wasn't the purpose of my 0
! 25 question. You're right: That was another portion of Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13957
[ \
U 1 the cross examination.
2 I'm talking about the correlation between the total 3 number of welds, 128, and the total number of welds 4 shown on those PTL transmittal sheets which are in the 5 package for Cable Pan Hanger 104 that showed that for 6 five hangers, there were 152 welds.
7 JUDGE GROSSMAN: I see, yes, okay. I recall 8 that, okay. Thank you.
9 MR. GUILD: Mr. Chairman, may I voir dire on 10 this point?
11 MR. STEPTOE: I'd like to continue with a few 12 more questions, and then --
13 JUDGE GROSSMAN: That would complete your 14 redirect?
15 MR. STEPTOE: Oh, no.
16 JUDGE GROSSMAN: But you just want -- okay.
17 That's fine.
18 MR. STEPTOE: I don't think the explanation 19 is complete yet.
20 BY MR. STEPTOE:
21 0 Dr. Kaushal, in general did BCAP inspect vendor :
22 equipment or vendor welds?
23 A (WITNESS KAUSHAL) In general BCAP did not.
I 24 0 Why was it that BCAP decided to inspect Systems Control
, 25 welds in the cable pan hanger population?
l l
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 l (312) 232-0262 - -.- - -___.-,-.-.- ,.- . -
13958 O
1 A (WITNESS KAUSHAL) My recollection is that the BCAP 2 engineers did not have a good way of identifying or 3 separating Comstock welds from Systems Control welds.
4 There were several complicating factors. One was 5 that part of the -- a certain number of hangers were, in 6 fact, fabricated on-site by Comstock. Out of those 7 hangers that were supplied by Systems Control, some 8 hangers had been reworked on-site.
9 The exact knowledge of which welds had been 10 - reworked or which hangers had been field-fabricated was 11 not available.
12 O Dr. Kaushal, I believe there's been testimony that there
[ )
N./ was, in preparing Attachment No. 4, an apportionment of 13 t 14 CSR results among Comstock inspectors.
15 What apportionment, if any, was made of the Systems 16 Control welds in preparing Attachment No. 4?
17 A (WITNESS KAUSHAL) My recollection is there wasn' t any.
18 We assigned the full number of welds to the Comstock 19 inspectors.
20 0 Why did you do that, si r?
21 A (WITNESS KAUSHAL) Firstly, there wasn't a way of 22 apportioning because we didn't have the information. We 23 thought that was a conservative approach.
24 JUDGE GROSSMAN: Okay. Mr. Guild, you may
) 25 voir dire on that.
l Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
M 13959 w ./
1 VOIR DIRE EXAMINATION 2 BY MR. GUILD: ,
3 Q Dr. Kaushal, do you know if there were any Systems 4 Control welds on CPH-104?
a 5 A (WITNESS KAUSHAL) Specifically on that hanger, no, I 6 do not.
7 0 So when you say that some number of the 128 welds were 8 Comstock and some number were Systems Control
- - 9 Corporation, you don' t, in fact, know whether or not any 10 of those were Systems Control Corporation welds?
11 A (WITNESS KAUSHAL) For that specific hanger, I don't
- 12 know.
13- My statement is for the general Kaushal-4 14 attachment. ,
15 MR. GUILD: All right, sir.
16 Mr. Chairman, I would move to strike the witness' f 17 speculation about 104 to the extent that he testified 18 beyond his competence and stated as fact that there were 19 certain portions of that hanger that were Systems J
20 Control Corporation welded.
4 21 It's simply beyond his competence.
22 JUDGE GROSSMAN: Well, we don't take his 23 testimony as saying that.
24 He was offering a reason -- he was offering an
- 25 opinion that some might be, but I don't believe he's Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13960 b
v 1 gone as far as to say that they were.
2 MR. GUILD: As long as that's understood,
- 3 Judge, that's fine.
t 4 JUDGE GROSSMAN: Well, I think it's pretty 5 clear by now.
6 MR. GUILD: I'll return to the subject on-7 recross, but that is all I have by way of voir dire.
8 JUDGE GROSSMAN: Thank you.
9 REDIRECT EXAMINATION
, 10 (Continued.)
i' 11 BY MR. STEPTOE:
12 Q Dr. Kaushal, did anyone from the NRC Staff or the NRC at 13 any time indicate to you that Chairman Palladino's 14 letter with respect to Diablo Canyon established any 15 requirements f or the BCAP program?
16 MR. GUILD: Hearsay; objection.
17 JUDGE GROSSMAN: On what grounds?
18 MR. GUILD: It's hearsay. I mean, he's being 19 asked what the NRC told him.
20 JUDGE GROSSMAN: Well, that's not hearsay.
i 21 MR. GUILD: Well, it is to the extent that 22 counsel is trying to establish what the NRC did or 23 didn't say or did or didn't do through this witness.
24 JUDGE GROSSMAN: What the NRC said or didn' t '
[\
( ,j 25 say to this witness is not hearsay, as far as his
, Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 r
(312) 232-0262
. 13961' -
- \
1 testimony goes.
2 If it's used to prove the truth of .what the NRC 3 told him, that would be a different matter, but I don't 4 understand this to go to that --
5 MR. GUILD: With that understanding, I have 6 no objection.
7 WITNESS KAUSHAL: May I have that question 8 reread?
9 JUDGE GROSSMAN: Well, the gist of the 10 question was: Did the NRC ever refer to the 11 requirements in that Dingell letter or any of those
~s 12 letters with regard to the CSR program?
i 13 WITNESS KAUSHAL: No, sir.
14 BY MR. STEPTOE:
15 Q Dr. Kaushal, you were unable to answer a number of l 16 questions, on the first day you were cross-examined, 17 with respect to the genesis of the BCAP program.
18 Do you recall that?
19 A (WITNESS KAUSHAL) Yes, that's correct.
L 20 0 Is there any member -- is any of the witnesses that f 21 Applicant is going to be calling with respect to BCAP 22 familiar with that subject?
, 23 MR. GUILD: Mr. Chairman, I guess I would say 24 if counsel wants to direct the Board's and parties' 25 attention to who they expect to be competent, that's Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13962
/N V
1 fine.
2 But asking Dr. Kaushal to speculate about what some 3 other witness might know or not know --
4 MR. STEPTOE: Fine.
5 I believe Mr. DelGeorge is familiar with that 6 subject matter, and I withdraw the question.
7 JUDGE GROSSMAN: Okay. You're withdrawing 8 it, fine.
9 BY MR. STEPTOE:
10 0 Now, there was some cross examination on the number of 11 pages of drafts of the BCAP report.
12 Do you recall that, Dr. Kaushal?
13 A (WITNESS KAUSHAL) Yes, I do.
14 0 There was some number quoted of something like 35,000 15 pages of documents were turned over in May, and most of 16 them related to the draf ts of the BCAP report.
17 Do you recall that, sir?
18 A (WITNESS KAUSHAL) I recall the question, yes.
19 Q Were any of those pages duplicates?
l 20 A (WITNESS KAUSHAL) Oh, probably a whole lot.
21 I have to -- I have to tell the background on that.
22 In the course of our business, a lot of paper was l
23 thrown away, you know, in the form of waste; and we had 24 a box full of stuff that was ready to be thrown away,
) 25 when Mr. Steptoe informed us that there was something in i
i Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13963
/~T i i Ag 1 the form of an interrogatory or otherwise and we weren't 2 supposed to throw away anything.
3 So that whole box of garbage was turned over to 4 counsel, and I think a lot of it ended up with the 5 Intervenors.
6 MR. GUILD: Now I know what I've been doing 7 for the last year, Judge.
8 (Laughter.)
9 A (WITNESS KAUSHAL) (Continuing.) Most of it was 10 duplicate, triplicate or quadruplicate copies of the 11 same thing.
[}
V 12 JUDGE GROSSMAN: Sorting out waste, Mr.
13 Guild?
14 MR. GUILD: Yes, sir, apparently.
15 (Laughter.)
16 BY MR. STEPTOE:
17 0 Now, there was some discussion of independence, Dr.
18 Kaushal. I believe you testified that you thought the 19 Independent Expert Overview Group satisfied the 20 requirements of the independence stated in the Palladino 21 letter.
22 Did you so testify?
23 A (WITNESS KAUSHAL) I testified that it was an 24 independent outfit.
1 () 25 I also vaguely recall saying something like based Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
)
13964 l
/N l
(_-)
l 1 on my cursory review of that letter, that they would, in 2 fact, satisfy that requirement. ;
3 I would not want to claim that that was based on a 4 detailed review.
5 JUDGE GROSSMAN: By the way, my reference 6 before to "the Dingell letters" included the Palladino 7 response.
8 WITNESS KAUSHAL: I understood your question 9 to mean that way, Judge.
10 BY MR. STEPTOE:
11 Q Dr. Kaushal, I've handed you a three-page document,
[)
v 12 Roman Numerals V-1, V-2, V-3.
13 (Indicating.)
14 A (WITNESS KAUSHAL) I see it.
15 Q This comes from the BCAP program document, does it not?
16 A (WITNESS KAUSHAL) Yes, it does.
4 17 0 Is it a description of the Independent Expert Overview 18 Group?
19 A (WITNESS KAUSHAL) Yes, it is.
20 0 Is it an accurate description of the functions of the 21 Independent Expert Overview Group as you perceive them?
22 A (WITNESS KAUSHAL) Yes, I would -- yes, it would be.
23 Actually, my recollection is that what is in here 24 is a relatively brief description; that their actual b)
( 25 work was -- seemed to me to be quite a bit more detailed Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13965 f3 k
1 than what I might have inferred f rom this.
2 0 Okay.
3 I'm going to direct your attention to Page V-2, the 4 bottom paragraph.
5 A (WITNESS KAUSHAL) Yes.
6 0 What do you understand this paragraph to -- strike that.
7 What requirements, if any, does the bottom 8 paragraph establish or what commitments, if any, does 9 this bottom paragraph establish with respect to the 10 independence of the Independent Expert Overview Group?
11 A (WITNESS KAUSHAL) I believe that paragraph states the 12 requirements for independence on that group.
13 0 And to the best of your knowledge and -- well, did the 14 IEOG comply with these requirements?
15 A (WITNESS KAUSHAL) To the best of my knowledge and 16 belief, that's correct, they did.
17 I do want to make a comment here. The first line 18 -- the first sentence in this paragraph, "will be f ree 19 of any significant contacts with Commonwealth Edison 20 Company" -- they did not have any prior contact with the 21 Commonwealth Edison Company.
22 Of course, in the course of BCAP activities, they 23 dealt with BCAP all the time.
24 0 Are you aware that -- do you know a man named Mr.
j 25 Hansel?
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 f (312) 232-0262
13966
/
U 1 A (WITNESS KAUSHAL) Yes, I do.
2 0 Was he the chairman of the Independent Expert Overview 3 Group?
4 A (WITNESS KAUSHAL) Yes, he was.
5 Q And do you know whether he had any contact with 6 Commonwealth Edison in connection with the Byron 7 licensing proceeding?
8 A (WITNESS KAUSHAL) My understanding is he did have 9 some, yes.
10 Q Are you aware of a man named Robert Laney?
-11 A (WITNESS KAUSHAL) Yes, I am.
12 Q What role did he play in the Independent Expert Overview
(
13 Group?
14 A (WITNESS KAUSHAL) He was one of the senior members of 15 the Independent Expert Overview Group.
16 Q Okay.
17 Do you know what role -- what contact, if any, he 18 had with Commonwealth Edison in the Byron licensing 19 proceeding?
20 A (WITNESS KAUSHAL) My understanding is he had some 21 contact with Edison with respect to the Byron 22 proceedings.
23 He may have testified in the proceedings, although 24 I'm not knowledgeable in detail of his contacts in that 25 respect.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
I- - 4 - :s 13967
\
l 1 MR. STEPTOE: Judge Grossman, I ask that this 2 three-page segment from the BCAP program document be 3 marked as Applicant's Exhibit No. 137.
4 JUDGE GROSSMAN: And offered at this time?
5 MR. STEPTOE: And I offer it at this time, 6 yes.
7 (The document was thereupon marked 8 Applicant's Exhibit No.137 for 9 identification as of October 8,1986.)-
10 JUDGE GROSSMAN: Mr. Guild?
4 11 MR. GUILD: I have no objection to it as 12 representing a portion of the BCAP program document. Of
(
13 course, it's not a substitute for proof of what the j 14 actual performance was by the IEOG.
15 Dr. Kaushal simply stating that this program 16 document excerpt reflects what they did does not 17 establish that as a fact. If it did, if it was being 18 offered for that purpose, I would object to it.
19 It obviously is a summary of what it was expected 2
20 to do.
21 JUDGE GROSSMAN: Mr. Berry?
22 MR. BERRY: The Staff has no objection, Mr.
23 Chairman.
24 JUDGE GROSSMAN: Okay. We'll admit that.
) 25 (The document was thereupon received into
. Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232 0262
__ __. . . - . _ . . . _ _ _ . . . . _ _ ~ _ . . . _ .__ . . _ _.
13968
'~
1 evidence as Applicant's Exhibit No. 137.)
2 JUDGE GROSSMAN: By the way, I don't believe 3 you offered 136.
4 MR. STEPTOE: I meant-to, Judge Grossman.
5 Thank you for reminding me.
, 6 I offer that exhibit.
7 JUDGE GROSSMAN: Mr. Guild?
8 MR. GUILD: I'm trying to find that one, 9 Judge.
10 I have no objection.
l 11 MR. BERRY: No objection f rom the Staff, Mr.
12 Chai rman.
J s
13 JUDGE GROSSMAN: Okay. That's received, j 14 also.
l 15- (The document was thereupon received into 16 evidence as Applicant's Exhibit No. 136.)
l l 17 JUDGE GROSSMAN: By the way, do you mind if I 18 interrupt and ask one or two questions on 137?
8 19 MR. STEPTOE: Not at all.
4 20 JUDGE GROSSMAN: Dr. Kaushal, do you know who l 21 decided on the standards of independence in arriving at 22 this document here?
23 WITNESS KAUSHAL: Your Honor, these l 24 guidelines or these criteria were put into the program A
I 25 document as input from Commonwealth Edison management.
- Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13969
.h
' \.s/
1 What other input they may have had to come up with' 2 these I'm not knowledgeable of.
! 3 JUDGE GROSSMAN: Okay.
4 Both Mr. Guild on cross examination and the Board 5' did ask or suggest that there be asked questions with 6 regard to Sargent & Lundy's independence.
7 Do you recall that the other day?
8 WITNESS KAUSHAL: Some questions were asked 9 regarding Sargent & Lundy, yes, your Honor.
10 JUDGE GROSSMAN: Okay.
11 Looking at that last paragraph on V-2, it is
[ 12 apparent, is it not, to you, Dr. Kaushal, that under D) 13 these requirements, Sargent & Lundy would not qualify as 14 an independent group?
15 I refer in particular to the word " design" in the 16 second line of that paragraph, the last word.
17 WITNESS KAUSHAL: I'm sorry. What page are 18 We on?
19 JUDGE GROSSMAN: The last paragraph on V-2, 20 Roman Numeral V-2.
21 WITNESS KAUSHAL: With respect to design? Is 22 that your question, your Honor?
23 JUDGE GROSSMAN: Well, I'm saying: Taking 24 into account the fact that there is the word " design,"
25 Sargent & Lundy would not qualify under the standards Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 f (312) 232-0262
13970 a
1 for independence that are set out in this document.
2 WITNESS KAUSHAL: For design, that would be 3 certainly true, yes, your Honor.
4 JUDGE GROSSMAN: Okay, fine.
5 Mr. Steptoe?
6 BY MR. STEPTOE:
7 Q Dr. Kaushal, did IEOG have any engineering resources as 8 a part of their effort?
9 A (WITNESS KAUSHAL) Not very extensive that I'm aware 10 of, Mr. Steptoe.
11 They had some people who were engineers.
[ \ 12 Q To your knowledge, did they make any review of Sargent &
13 Lundy's work?
14 A (WITNESS KAUSHAL) My understanding is that they did 15 make a review of Sargent & Lundy's work.
16 I believe they brought in some consultants, but I'm 17 not at this time recalling the exact extent of their 18 review of Sargent & Lundy's review on design-19 significance evaluation.
20 Q Dr. Kaushal, referring to Applicant's Exhibit 128, which 21 is the August 30, 1984, letter from Mr. O'Connor to Mr.
22 Keppler, responding to the NRC comments on the BCAP 23 program --
24 MR. GUILD: 138?
25 MR. STEPTOE: 128.
w Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 f (312) 232-0262
~ , . . - _ - ._. -
13971 A
( l
%d 1 WITNESS KAUSHAL: I don't have it with me.
2 MR. STEPTOE: I'll show it to you.
3 (Indicating.)
4 BY MR. STEPTOE:
5 0 I'm referring to the last page, which is entitled 4
6 " Protocol Governing Communications between Commonwealth 7 Edison Company and Evaluation Research Corporation, ERC, 8 in the Braidwood Construction Assessment Program."
9 (Indicating.)
, 10 A (WITNESS KAUSHAL) Yes, I see it.
11 JUDGE COLE: I believe that's one where you 12 were going to provide copies.
i 13 MR. STEPTOE: Oh, no.
14 (Laughter.)
! 15 JUDGE COLE: Because I don't have my copy, 16 either.
17 MR. GUILD: Which one is referenced?
18 MR. STEPTOE: (Indicating.)
19 BY MR. STEPTOE:
20 0 Is that protocol -- was that protocol established for 21 the conduct of ERC's work in connection with the BCAP 22 program?
23 A (WITNESS KAUSHAL) That is correct.
24 0 And did IEOG and ERC follow that protocol?
25 A (WITNESS KAUSHAL) To my knowledge, they did, yes.
i Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13972 f)
V 1 MR. MILLER: Let me hand you two copies of 2 Applicant's Exhibit 128, and I will get Judge Cole one 3 later.
4 BY MR. STEPTOE:
5 Q Mr. Kaushal, I hand you a document entitled " Evaluation c
4 6 of the Braidwood Construction- Assessment Program by the 7 Independent Expert Overview Group."
8 (Indicating.)
9 Are you f amiliar with this document?
10 A (WITNESS KAUSHAL) Yes, I am.
11 Q Does that reflect the final report of the IEOG with 12 respect to the BCAP effort?
i 13 A (WITNESS'KAUSHAL) My recollection is that it does, 14 yes.
15 Q Now, with respect to -- now, Paragraph No. 2 in the 16 protocol states that, "All exchanges of correspondence, 17 including drafts between ERC and CECO, will be submitted 18 to the administrator of NRC Region III at the same time 19 as they are submitted to CECO"; isn't that correct?
f 20 A (WITNESS KAUSHAL) That's correct. I recall that.
21 Q Now, sir, did you ever see a draft of the IEOG I
22 evaluation that I've just handed to you, prior to the
- 23 time that it was submitted finally on the record?
24 A (WITNESS KAUSHAL) No, I did not.
25 MR. STEPTOE: Your Honor, I ask that this
(
I
! Sonntag Reporting Service, Ltd.
, Geneva, Illinois 60134 (312) 232-0262
13973 ,
O 1 document, " Evaluation of the Braidwood Construction 2 Assessment Program by the Independent Expert Overview 3 Group," be marked for identification as Applicant's 4 Exhibit No.13 8.
5 I'm not offering it into evidence, Judge Grossman.
6 (The document was thereupon marked 7 Applicant's Exhibit No. 138 for 8 identification as of October 8, 1986.)
9 MR. STEPTOE: Judge Grossman, we're 10 approaching the noon hour.
11 I only have a few more questions that I need to
() 12 13 collect my thoughts on before we would bring Mr. Orlov up to the stand to address the data base issue, so if I 14 could --
15 JUDGE GROSSMAN: You'd like to recess now ,
16 until 1:15?
17 MR. STEPTOE: That would be fine.
18 JUDGE GROSSMAN: Okay, fine.
19 Just one more question before that: I referred you 20 to the word " design" in those standards in reference to 21 Sargent & Lundy; and you agreed that Sargent & Lundy 22 would not have met, if I understand your answer, that 23 standard of not having participated in design.
24 Wouldn't they also not have met the standard of not 25 having participated in Quality Assurance activities, Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (332) 232-0262
t 13974 1 also, Dr. Kaushal?
2 WITNESS KAUSHAL: Your Honor, I'm not really 3 familiar with what specific Quality Assurance activities 4 Sargent & Lundy participates in.
5 They do walkdowns and other things that are a 6 direct extension of their engineering activities.
7 JUDGE GROSSMAN: Well, they did close out a 8 number of diccrepancies, didn' t they, with use-as-is 9 designations and various other engineering changes when 10 the discrepant conditions were pointed out to them?
11 WITNESS KAUSHAL: Yes, sir. That is their 12 normal engineering function, your Honor. That's the way 13 I interpret it.
14 JUDGE GROSSMAN: Wouldn' t you consider that 15 as related to Quality Acsurance activities?
16 WITNESS KAUSHAL: Your Honor, I would not 17 want to get into a disagreement with you on that. It's 18 just not the way I would perceive Quality Assurance 19 activities, but I'm not sure that --
20 JUDGE GROSSMAN: So it's a matter of 21 interpretation, then, and it would not be your 22 interpretation?
23 WITNESS KAUSHAL: It would not be mine, sir, s 24 but that is not to say mine is perfect in that respect.
i 25 JUDGE GROSSMAN: Nor is mine, for that J
Sonntag Reporting Service, Ltd.
Geneva, Illinois bu134 (312) 232-0262
, 13975 :
O .
1 matter.
2 Fine. Why don't we recess until 1:15.
3 (WHEREUPON, the hearing was continued to 4 the hour of 1:15 o' clock P. M.)
5 6
7 8
9
, 10 11 12 13 14 15 16 17 18 19 20 l
21 l 22 1 1
23 l
24 25 i
, Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13976 ILJ )
l UNITED STATES OF AMERICA
- 2 NUCLEAR RDGULATORY COMMISSION 3 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4
__________________x 5 :
In the natter of: :
6 : Docket No. 50-456 OL COMMONWEALTH EDISON COMPANY : 50-457 OL 7 :
(Braidwood Station, Units 1 :
8 and 2) :
__________________x 9
10 Met pursuant to recess.
11 Wednesday, October 8, 1986.
1:15 P. M.
13 JUDG E G ROSSMAN: Back in session.
14 Mr. Steptoe.
15 MR. STEPTOE: Judge Grossman, I have a 16 prelimina ry matter.
17 In the course of final review and preparation for 18 the hearings, tha t is, bases being corrected and 19 reverified, we have uncovered that there is an apparent 20 problem in the way that Sargent & Lundy is counting 21 discrepant welds; and at this time Attachment No. 4 has 22 been received into evidence, and we're obviously not 23 going to be in a position to offer Attachment 4 into
_s 24 evidence until a review, which is now under way, is 25 compl eted.
(J')
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13977 j-t
- Q,/ . ,
1 We would' hope that that review would be completed 2 by Monday.
3 Mr. Kostal will be available to Mr. Guild to 4 explain to him the nature of the problem after the 5 hearings today off the record, and then at the time that 6 any corrections are made to Attschment 4, we would 7 explain it on the record for the Board.
8 JUDGE GROSSMAN: Attachment 4, are you 9 talking about Dr. Kaushal's --
10 MR. STEPTOE: Tha t's correct.
11 And the problem has to do with methodology for counting welds by Sargent & Lundy, (u )) - 13
'12 JUDGE G ROSSMAN: Okay.
14 But you said it hadn't been offered into evidence.
15 MR. STEPTOE: Well, it had been offered but 16 it_had not been received. I believe that is - correct.
17 Attachment 4 you reserved on, Judge G rossman, 18 because we didn't have Sargent & Lundy's witnesses here.
19 JUDGE GROSSMAN: That's fine.
20 BY MR. STEPTOE:
21 Q Mr. Shevlin, at Transcript Page 13630, the name of 22 Howard M. Seigers --
23 A (WITNESS SHEVLIN) Siegrist.
24 0 -- Siegrist was brought up, i N
) 25 Who is that?
Sonntaq Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13978 f }
1 A (WITNESS SHEVLIN) He's a certified Lead Quality 2 Inspector employed by Daniel in -- he was being used in 3 the capacity as a Lead Inspector as my appointed 4 designee during the course of the BCAP review.
5 0 Was he authorized under BCAP procedures to review BCAP 6 observations for completeness, clarity and accuracy?
7 A (WITNESS SH EVLIN) Yes, si r.
8 MR. GUILD: What was the transcript number?
9 MR. STEPTOE: 13630.
10 MR. GUILD: Thank you, 11 JUDGE GROSSMAN: Is the mike on?
[ '~
j 12 A (WITNESS KAUSH AL) Yes, it is on, sir.
13 (Indica ting .)
14 BY MR. STEPTOE:
15 Q Dr. Kaushal, you were asked, at Transcript Page 13539 16 through 13541, whether the results of the sampling 17 inspection performed -- of systems Control welding 18 performed pursuant to NRC 451 led to the conclusion that 19 the hangers were acceptable.
20 Do you recall that question?
21 A (WITNESS KAUSHAL) I recall the question, yes.
22 0 I believe you said you did not -- you did not know.
23 Have you since had a chance to look at NCR 451?
24 A (WITNESS KAUSH AL) Yes, I have.
! 'x i, l 25 Q Dr. Kaushal, I'm going to hand you a portion of NCR 451, N /
Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134
, (312) 232-0262
13979
\, j 1 which I would like marked for identification as 2 Applicant's Exhibit 139.
3 (Indica ting .)
4 (The document was thereupon marked 5 Applicant's Exhibit No.139 for 6 identification as of October 8, 1986.)
7 BY'MR. STEPTOE:
8 0 Can you tell from this document whether the result of 9 the sampling inspection of welding performed pursuant to 10 NCR 451 led to the conclusion that the hangers --
11 Systems Control hangers -- were acceptable?
12 A (WITNESS KAUSH AL) No. This document, in fact,
(
x~ ~ -
)
13 indicates that it's recognized that additional 14 deficiencies exist with Systems Control Corporation 15 supplied hangers, and then it states, "Th e se 16 discrepancies are currently being resolved via CECO NCR 17 708 Revision 1 and 709 Revision 1."
18 Q Okay.
19 The front page of what has been marked for 20 identification as Intervenors' Exhibit -- as Applicant's 21 Exhibit 139 is, in fact, a surveillance report signed by 22 Mr. Quaka, is it not?
23 A (WITNESS KAUSH AL) That is correct.
,, 24 Q And Mr. Quaka is who?
! x
! ) 25 A (WITNESS KAUSHAL) Mr. Quaka is the Quality Assurance NJ Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13980 I i
\ !
N/
1 Superinteadent at Braidwood.
2 Q And he signed this document in March of 19867 3 A (WITNESS KAUSHAL) This document is signed March 14, 4 1986, by Mr. Quaka.
5 0 And what is the significance of this document with 6 respect to NCR 451?
7 A (WITNESS KAUSH AL) This document here pertains to a 8 Braidwood QA Surveillance Report No. 5624, and the last 9 paragraph, the last line -- the last sentence states, 10 " Based on this surveillance" -- I believe it's referring 11 to NCR 451 -- I'm sorry. " Based on this, this
(' ) 12 surveillance is closed and should be used as a basis for L/ '
13 closure of NCR 451."
14 So it refers to a surveillance and states that 15 that surveillance is closed and can be used as a basis 16 for closing NCR 451, but at the same time it does 17 identify that -- it does not mean that all hangers are 18 free of defects, free of deficiencies, and states 19 additional deficiencies exist for System Control 20 Corpora tion supplied hangers.
21 HR. STEPTOE: Judge Grossman, I would request 22 that Applicant's Exhibit 139 marked for identification 23 be received into the record.
24 MR. GUILD: Mr. Chairman, as long as it's l N (x. ) 25 understood that it's not offered as to establish what
,s Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13981 t
x_-) -
1 the quality of those hangers are.
2 I don' t quarrel with the document' being an official
- 3 record, but it can't substitute for proof that the 4 document purports to simply document.
5 MR. STEPTOE: I don't have a problem with 6 that understanding, Judge Grossman.
7- It's offered to answer a question raised.
8 JUDGE GROSSMAN: Okay, that's. fine.
9 Mr. Berry.
10' MR.-BERRY: Staff has no obj ection, Mr.
11 Ch ai rman.
l 12- J UDG E G ROSSMAN : Okay. We'll accept the 13 document on the basis of the limitations.
14 . (The document was thereupon ' received into 15 evidence as Applicant's Exhibit No.139.)
16 MR. STEPTOE: Judge G rossman, at.this time I 17 would like to ask Mr. Orlov to join the panel.
J 18 JUDGE GROSSMAN: Mr. Guild, I take it you 19- have no objection to this?
- 20. MR. GUILD: No, sir, I don't.
21 JUDGE GROSSMAN: Mr. Orlov, please raise your 22 right hand, . remain standing.
23 (The witness was thereupon duly sworn.)
- 24 JUDG E GROSSMAN: Please be seated.
( 25 A (WITNESS ORLOV) Thank you. ,
L Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13982 j%
'( I
- \ _j 1 GEORGE MICHAEL ORLOV 2 called as a witness. by the Applicant herein, having been 3 first duly sworn, was examined and testified as follows:
4 DIRECT EXAMINATION 5 BY MR. STEPTOE:
6 Q Mr. Orlov, would you state your full name for the 7 record?
8 A (WITNESS ORLOV) George Michael ~ Orlov.
9 Q By .whom are you employed and -in what capacity?
, 10 A (WITNESS ORLO7) I'm a consultant for Commonwealth 11 Edison. I am currently the Staff Assistant to the 12 Braidwood Proj ect Manager.
'\
13 Q Prior to that time, what was your post with respect to 14 BCAP?
15 A (WITNESS ORLO7) I was the Assistant Director of BCAP, 16 responsible for the CSR engineering and the ' RPSR' 17 portions of BCAP.
18 Q You are going to have to keep your voice up so that the 19 Board can hear you.
20 A (WITNESS ORLOV) I'm sorry.
)
21 Q Hr. Orlov, would you please summarize your education and 22 work experience?
23 A (WITNESS ORLO7) I received a Bachelor of Science in 24 physics and a Master of Science in nuclear engineering
( p.
j j 25 from Massachusetts Institute of Technology in February, Sonntaq Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13983 l l
1 l
~J :
l 1 1978.
2 Since then, I've had a number of work experiences 3 related to both construction work, quality assessment 4 and the use of digital computers, data base. and 5 computing applications.
6 It started in 1977 when I developed a code which 7 calculated the multi-group exclusion --
8 MR. GUILD: I'm going to have to ask you to 9 speak up, please.
10 A (WITNESS ORLO7) Excuse me.
11 In 1977 my work experience began when I developed a
[' ') 12 computer code which calculated the cylindrical geometry V
13 multi-group exclusion to the neutron transport equation, 14 and I developed that code and implemented it on a Cyber 15 7600 compute r, 16 After that, I also -- also in 1977, I developed an 17 automated gamma ray standards lab, which measured 18 radioactive standard sources and calculated their 19 activities and provided automated data acquisition and 20 statistical analysis for those measurements, and that 21 was all audited using the 9825 Hewpltt-Packard computer.
22 Subsequent to that, I did a number of other -- a 23 number of other activities that were related to use of 24 digital computers and data bases, 7-t
( ) 25 I developed a material control and accountability
(/
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
I,
'13984 i ^).
C/
1 data base .for use in commercial nuclear licensing --
2 commercial nuclear fuel plants and operating licensees 3 to account for. movement and storage and transfer of
5 I also did an evaluation of special nuclear 6 material processing plant limit of error of inventory 7 dif ferences and inventory dif ference ' calculations, and 8 those calculations were implemented and performed using
'9 the code on an IBM 360 computer.
10 OY MR. STEPTOE:
11 Q. Mr. Orlov, will you please -- I know you've got a sof t h
.x) 12 voice.
13 Perhaps you could change positions with Dr. Kaushal 14 so I can be sure tha t --
15 A (WITNESS ORLO7) I'm sorry.
16' Q -- that you are heard by the Court Reporter as well as 17 by the Board, and please try to keep your voice up.
18 A (WITNESS ORLOV) Okay.
19 I'm trying to remember all the things- without the 20 thing in . front of me.
21 I also was part of a peer review program, peer
.22 review group, that reviewed a weld data base at the 23 Zimmer nuclear power station.
.24. The purpose of that data base was to confirm the L
25 acceptability of the welds, and specifically we wanted Sonntaq Reporting Se rvi ce, Ltd.
Geneva, Illinois 60134
( 312) ~ 232-0262
a 4
13985 y- )
% /;
s 1 to . assure ourselves 1that the person -- the welder: who ,
-2 made'the weld was qualified;'the inspectors who 3_ ' inspected those welds were. qualified; that appropriate 4 base and filler materials' were used, utilized, -in: making 3 the weldment; and that. the inspectors were qualified and 6- the procedures were qualified.
7- And again, that's a large data base employed at the
- 8. Zimmer plant to confirm the acceptability of the welds 9l In addition, I've had experiences -- work 10 experiences related to construction evaluation at 11 nuclear power sta tions.
'[ \ 12. Beginning in 1981, May of 1981, I was employed as a V'
13 . consultant by Cincinnati Gas E Electric Company as a
- 14. quality engineer, and my pt;.cary responsibility there 15 was review of construction deficiency non-conformance 16 reports. Specifically I reviewed the dispositions of 17 those Non-Conformance Reports for adequacy.
18 Then in September, 1982, I was assigned as the 19_ Assistant Director of the Zimmer Quality Confirmation
.20 Program.
21: That program was a program developed in
-22 accordance -- well, in conjunction with the Nuclear i 23 Regulatory Commission to resolve some of the concerns
[ 24 that the NRC had expressed in their Inspection Report
(. /~^s
() 25 8113 back in April of 1981.
i Sonntag Reporting Service, Ltd.
I Geneva, Illinois 60134 (312) 232-0262
r 13986 f
v
)
1 Later, being September of 1983, I became Director 2 of that program. That would -- that was tasks 3 which -- verifying specific aspects of the quality 4 construction at Zimmer.
5 At that same time, I also became the Director of 6 the program to verify the quality of construction and 7 another program developed in accordance -- in 8 conjunction with the NRC to, on a more broad base, more 9 globally look at the quality of work, construction work, 10 at the Zimmer nuclear power station.
11 Then in 19 84, February, after Zimmer was canceled, I 12 I came to Commonwealth Edison as a consultant, and V) 13 shortly thereafter began working on the BCAP program 14 do cum ent, and later, in June of 1984, was assigned as 15 the Assistant Director of the BCAP program for the RPSR 16 and CSR engineering efforts.
17 Q Mr. Orlov, wha t role, if any, did you play in the 18 compilation of Kaushal Attachment No. 4?
19 A (WITNESS ORLOV) Per Dr. Kaushal's request and in 20 conj unction with Dr. Kaushal, I coordinated many of the 21 activities that were involved in creating that data 22 base.
23 In particular, I coordinated with CECO Proj ect
,_, 24 Construction Department and Comstock Engineering to t s i
.v )
25 assure ourselves that we could get documents produced Sonntaa Reportino Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13987 v
)
1 for us that were associated with the BCAP reinspected 2 items.
3 I interf aced with Sargent & Lundy -- excuse me --
4 that's not correct, really.
5 I met with Sargent & Lundy and requested that data 6 on inspection point discrepant point welds inspected and 7 welds discrepant be produced to me in an appropriate 8 format.
9 I had a small staff of -- of QC engineers and 10 inspectors who -- who assisted me in reviewing the 11 Comstock inspection records to identify the scope of
[ ) 12 those inspections, the type of inspections, th e
'wl 13 inspector's name and the date of those inspections from 14 the Comstock QC records.
15 Then I combined the two -- results of those two 16 reviews, the Sargent & Lundy review for inspection point 17 and discrepancy point ccunts and the information f rom
.18 the Comstock records related to the Comstock inspectors, 19 and created what you have seen as Kaushal Exhihit 4, 20 which is the CSR data base.
21 (In d i.ca ting. )
22 Q Now, Mr. Orlov, in response to some questions which were 23 raised in the hearings by Mr. Guild with respect to 24 changes to Attachment No. 4, which were ' filed with the
! } 25 Board and the parties on September 30th, did you, in G
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13988
.j'
.r' 1 fact, prepare a memorandum explaining those changes?
2 A (WITNESS ORLO7) Yes, I did.
3 0 I hand you a three-page document entitled, " Memo." It's 4 a memorandum f rom you to Mr. Guild dated October 6, 5 1986.
6 Is this the memo that you prepared, sir?
7 A (WITNESS ORLOV) Yes, it is.
-8 Q And was this memorandum provided to Mr. Guild on Monday 9 of this week?
10 A (WITNESS ORLO7) Yes, it was.
11 Q And yesterday evening did you discuss these changes --
/ <
12 discuss these answers with Mr. Guild?
\ )
v 13 A (WITNESS ORLOV) Yes, I did.
14 MR. STEPTOE: Your Honor, I'd like that 15 marked for identification as Applicant's Exhibit 140.
16 (The document was thereupon marked 17 Applicant's Exhibit No. 140 for 18 identification as of October 1, 1986.)
19 BY MR. STEPTOE:
20 Q Mr. Orlov, perhaps we could go through these 21 e xplana tions one by one.
22 Can we start with -- well, we won' t do all of them, 23 but could we perhaps start with Cable Pan 31.
24 A (WITNESS ORLO7) Certainly.
p-l t, ) 25 Q Can you explain why the entry for Cable Pan 31 changed v
Sonntaq Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13989 7 i
't 1 ~during the September 30th revision to Attachment No. 4?
- 2. A (WITNESS ORLO7) Certainly.
3 In the latest review of the data base, it was a 4 100-percent review to assure ourselves that no Comstock 5 records that were applicable to the CSR data base had 6 been inadvertently omitted when they were put into the 7 data base, and as such, a number of additional records 8 were identified.
9 In the Cable Pan 31 record or item, tw o --
10 MR. GUILD: Excuse me.
11 I don't mean to interrupt unduly, but I would have 12 asked by way of voir dire to raise this point; but
] v'~'}13 counsel transmitted the corrections with a cover letter 14 explaining the basis for the change, and the
- 15. understanding was not that there was an inadvertence, 16 but that there were errors in' the apportionment of welds 17- among multiple Comstock inspectors.
18 I have no problem with Mr. Orlov explaining from 19 the document -- we have gone through that.-- but that 20 simply is not a complete explanation for the basis of 21 the review as I understand the explanation has been ,
22 given to me so far.
23 So the record doesn't get any further muddled on 24 this, I would ask if counsel will stipulate that the
- - fT l
} ) 25 basis for the last review was the basis as communicated Sonntaq Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13990
,~
\--)
1 to the . parties and Board by way of the September 30th 2 letter -- I'm trying to lay my hands on .it --
3 MR. STEPTOE: I' d h ave to ge t a co py ' of .th e 4 September 30th letter, by if I-wrote it, I'm hardly in a 5 position to disagree.
6 Perhaps we could --
7 JUDGE COLE: Her e's a co py of i t.
8 (Indica ting. )
9 MR. GUILD: One good record keeper.
10 MR. STEPTOE: I think I have it.
11 BY MR.'STEPTOE:
1 12 Q. Mr. Orlov, would you read the September 30, 1986, letter v[ \ 13 from me to Mr. Guild.
14 A (WITNESS ORLO7) Can I skip.to the second appropriate 15 paragraph or do you want me . to --
16 Q Please read it to yourself.
l- 17 A (WITNESS ORLOV) Okay.
18 Q Mr. Orlov, have you finished reading that letter?
19 A (WITNESS ORLOV) Yes, I have, i
20 0 Is the explanation offered in ti e second paragraph of 21 . that letter for the reason -- well, is the second 22 paragraph of that letter correct?
23 A (WITNESS ORLOV) Yes, it is.
j, 24 O Okay.
25 Could you explain more generally why those mistakes Sonntaq Reporting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
+
1 ,
^
, 13991 I%f 1
'l occurred; what the nature of the mistakes was and why 2 they. occurred? :
1-
.3 .A (WITNESS ORLO7) The mistakes identified in.your letter e 4~ here?
5' 0 -That's correct.
.6 Well, the mistakes tha't were identified in- the 7 letter and were ' forwarded to the Board with a revised --
i ,
8 a Revision 2 and a markup to. Attachment No. 4 of-Dr.
19 Kaushal's testimony.
'- , 10 'A (WITNESS ORLO7) You are talking about the 9/27 markup?
i 111 O' Tha t's correct.
,V
-[ 'h '12- -A (WITNESS ORLO7) When the data base was . initially being
- 13 put together, Mr. McCrany, one of Daniels' cons ultants 7.
c14 being used to~ review the Comstock records -- his 15 -interpretation of which records were supposed to be put 16 into 'the data base .was such that in certain. cases an i
17 earlier inspection record may not have been included in -
18- the data base, and that's a _very limited, narrow basis.
19 If. there were two inspection records, - both of which
! 20 were specifically identifying uniquely the one Comstock p :21 item _ which was reinspected by the CSR and they. Were 22 done, performed, on different dates by perhaps two h 23' dif ferent inspectors, Mr. McCrany would have included n
.,- 2-4 only- the latest inspection record in -the data base.
( j 25- (Indica ting . )
- Sonntaq Reporting Service, Ltd. i Geneva, Illinois 60134 (312) _232-0262
p-e 13992
/N f
.-- (v) ,
1 LNow, it is very rare that that type of condition 2 would have existed.
3 In fact, from this review -- from that 100 percent 4 review that we did and documented on September 27th,JI 5 believe only 20 additional such records were added to 6 the data base out of approximately over 1,200, so it was 7- a rather. minor error on our part.
8 It was an error which is --
9 MR. GUILD: Mr. Orlov, you continue to trail 10 off.- I'm losing -the last' half of your sentence, 11 A (WITNESS ORLO7) -I'm sorry. I apologiz e.
12 - It was a small error on our part, but we did
- [ '5d13: correct it in the 9/27/86 changes; to -the data base.
14 JUDGE GROSSMAN: Would that example that we 15 discussed the other day be one of those instances in 16 which we had an inspection record by Mr. DeWald and then 17 an identical inspection at a later date by Rick. Martin?
7 18 Would that have been one of those cases?
11 9 A (WITNESS ORLOV) Are you talking about Cable Pan Hanger 20 104?
21 MR. STEPTOE: Yes.
22 MR. GUILD: I believe that's the reference.
12 3 JUDG E GROSSMAN: Yes.
24 A (WITNESS ORLOV) I believe you are right.
! bN
- 25 No. In that case, those records would have been
- _ \s /
Sonntaq Repor ting Se rv i ce, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13993 d
a 1 included in the earlier versions of data, because each 2 of those records was what is commonly called a grid 3 inspection.
4 It is not a specific inspection for one unique 5 hangers. Ra the r, it is -- excuse me -- an inspection 6 for a number of cable pan hangers in one area of the 7 plant that are specifically delineated on the PTL cover 8 sheet.
9 In that case, both of Mr. Martin and Mr. DeWald, 10 inspections had been originally included in the data 11 base and still remain in the data base.
j 12 JUDGE GROSSMAN: Even though there were an
^~
13 identical number of welds inspected?
14 A (WITNESS ORLOV) Well, let me clarify that, if I may.
15 Mr. McCrany would only have not included earlier 16 versions of the Comstock records if bo'th the later and 17 earlier Comstock record only applied to one item.
18 JUDGE GROSSMAN: Okay.
19 A (WITNESS ORLO7) Fo r e xampl e --
20 JUDGE GROSSMAN: Well, clarify this.
21 This was done on a grid basis. Is that the reason 22 why they would have both been included?
23 A (WITNESS ORLO7) Yes, for grid type -- if one or both of
,_ 24 the inspections had been grid-type inspections, both of r s (J)~
25 those Constock records would have been included in the Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13994 7
_pl l' data base.
2 JUDG E GROSSMAN: Okay.
-3 A (WITNESS ORLOV) It's only in those few cases where you 4 have an Inspector A does an inspection on one hanger, 5 the entire hanger only, and another. Inspector, B, does 6 the same inspection, perhaps on a different date, of 7 that same unique one-only hanger --
8 JUDG E GROSSMAN: Okay.
9 A (WITNESS ORLOV) -- in tha t -- in tho se cases, .Mr.
10 McCrany. would not have included the earlier inspection r
11 record.
T '12 And, again, as I say -- as I said before, the.
.. [V ~13 number of -changes we had to make, based on' that type of 14 error, was actually very small, and I don' t believe it 15 was based -- that review was based on a misapportionment 16 of the -- of inspection points between two records as 17 had been inferred.
18 (Indica ting. )
19 MR. GUILD: Mr. Chairman,- I'd ask at this 20 point if we could simply read into the record the 21 explanation that Mr. Steptoe provided by his letter of
'22. the 30th.
23 Can I do tha t, sir ?
24 JUD3 E GROSSMAN: Well, rather than read it 4
g
( ) 25 in, why don't we just of fer that.
Sonntaq Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
13995 x
- ( \^
-1 If you have no objection', Mr. Guild, then we won' t 2 disqualify Mr. Steptoe ' f rom. being counsel here because
'3
~
of tha t.
4 MR. GUILD: That would be fine, Judge.-
5 , JUDGE GROSSMAN : Okay. We'll mark that, when 6 we get. sufficient copies, as Applicant's Exhibit 141,-
7 and we'll admit that exhibit.
8 (The document was thereupon marked 9 Applicant's : Exhibit No.141' for 10 identification as of October 8, :1986.)
11 (The document was thereupon received into
'\ l12 evidence as Applicant's Exhibit No'.141.)
s-
-13 MR. STEPTOE: Moving on to another subject, 14 Mr. Chairman, I'd like to have --
15 JUDGE GROSSMAN: Well, let me make it clear 16 we' re admitting that right now, but we'll get copies in-17 the f uture.
18 BY MR. STEPTOE:
L19 _Q Mr. Orlov, I just handed you a document, which is a L20 nine-page series of tables, tabulations.
l- -21 (Indica ting. )
! -2 2L The first page is marked " Invalids" and the Bates i 23' Stamp Numbers are AR006924006924through 6932.
l 24 Are you familiar with this document, sir ?
- 25 A (WITNESS ORLO7) Yes, I am.
f Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
}
h n '?
13996 Y % ,
l- -MR. STEPTOE:. May I have this marked as-2' Applicant's Exhibit No.- 141 --
3' JUDGE GROSSMAN: 142.
4 JUDGE COLE: 142.
s5 MR; STEPTOE: -- 142. !
6- JUDG E GROSSMAN: We just marked your' letter J7 and admitted it as 141.
8 'MR. STEPTOE: I'm sorry.
9; (The document was thereupon marked 10 ' Applicant's Exhibit No. 142 for -
1.,
11 identification as of October .8, 1986)
~s 12 -BY MR. STEPTOE:-
l 13 0 . Mr. Orlov, did you prepare this document?
- , ~14- A (WITNESS ORLOV) _I prepared
- a subst antial por tion of this document.
15
- 16- There are- some notes by_ Dr. Kaushal in the margins
.'17. and in- various places summing things, you know, but the 18- . numbers are substantially mine.
! i
! 19! Q Okay.
- j. 20 And you prepared it for Dr. Kaushal and myself, did 21' you not?
~
^
22 A (WITNESS ORLOV) Yes, I did.
! i-23- MR. STEPTOE: Okay.
, i 24 Now, there were a series of questions asked of Dr.
p [~%g L
/ 25 ,Kaushal-and the other members of the panel with respect Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 l I (312) 232-0262 i
13997 l 8 N_j 1 to how many CSR observations were invalidated on various 2 bases, and how many were declared out of scope, and, 3 Judge Grossman, the purpose of putting this table into 4 evidence is to try to answer those questions.
5 BY MR. STEPTOE:
6 0 Mr. Orlov, how did you go about preparing this document 7 or what was the source information for this document?
8 A (WITNESS ORLO7) I first generated, f rom the -- f rom the 9 computer data base that identified each and every CSR 10 inspection observation, a list of those observations. I 11 then went to the CECO QA vault, which contains all of 12 the BCAP CSR reinspection observations, and reviewed
('w.)) 13 each one.
14 My review was to determine the reason or some 15 general reasons for why observations -- for what basis 16 observations were either invalidated or made out of 17 s co pe.
18 Q Turning to the first page, Mr. Orlov, would you explain 19 what we're looking at?
20 A (WITNESS ORLO7) Certainly.
21 The columns represent the number of invalid 22 observations or actually observations that are either 23 partially or wholly invalid for each construction 24 category.
7
! N 25 Now, let me provide you a caveat to that. In the
( )
Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
4 13998
] )
- Ss /
1 first and the third through last' pages of these 2 documents,LI discuss reasons for invalids and-invalids 3 only for those observations pertaining 'to sample items.
4 -I did not summarize or categorize those 5 observations which were either invalidated or made out 6 of scope which pertain to XXX observations.
.7 XXX -observation, as I think was described earlier, 8 is.an observation which an inspector writes but that is 9 not part of his BCAP inspection scope.
10 He walks out in the field, he sees something. The i
11 -onus 'is on the inspector to report a deficiency. -- an I apparent discrepancy in construction; and we provided
- \g\ .1:2 13 - our inspector a mechanism to do that, and that is the
.14 XXX observations.
15 They are not part of our sample items, they weren' t
-16 par t of . the s cope of the BCAP; . but it was - a f ormalized 17 way to provide our inspectors a mechanism whereby
[ 18 potential construction defects could be identified and 19 forwarded to the construction department for resolution.-
20 There ar e -- ther efor e, since they are not really l
i L 21 part of the CSR scope, we didn' t really include them in I 22 the CSR results because we ' don't know -- how shall I say
(.
23 --- the denominators for those results, the total'--
L 24 total scope - of work looked a t and, therefore, I did no l [~'N -
l t 1 25 review for why we made those invalid or out of scope, i V i Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
4 13999 N
. i l H\,,,,/ -
1 So my..r eviews here ore - based only on the in scope 2' item.related observations..
3 (Indica ting .)
4 Q Okay.
5 Mr. . orlov, you said Page 1 and the third to the last.
4 7 You mean Page 1, Page 3, Page 4, through Page19?
8 A (WITNESS ORLOV) 3 through the last page.
9- -Q- .None of those have data related to the XXX observadions t
10 on th em ?
11 . A' (WITNESS.ORLO7) Correct. ,
12 Q Okay.
13 Now, could you explain what each row on the first 14 page signifies?
15 A (WITNESS ORLOV) Ce r tainly.
16 ' Ma e fi rs t r ow r epr esents tho se - obse rva tion s ---- th e 17 number of those observations in each construction I
18 category which we invalidated because the -- the 19 apparent defect or the apparent discrepancy the 20 construction -- the CSR inspector had identified was, in :
21 fact, in accordance with the Sargent & Lundy design.
22 I can try and give you a few examples of that, if I 23 may.
24 For example, in the EIN population, there were a
' 0 f:
\~/V). 25 number of junction boxes which the CSR inspector i
Sonntaq Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
,,- .. . .- - . . .- . . . - . - - - - , . ..- -~ ...-.-- -.- -
~
.l 4 14000 1'q./}
1 . identified as having. missing tack welds, and there's a 2- note : that goes with that j unction -box detail that says,-
-3: "These~ tack welds are optional,f and their purpose is for 4 . ease in erection. If you want to use them, 'you can. If 5 you don't, they serve no structural purpose."
6 Our inspectors identified a number of those tack.
.7 welds. as being missing.
8 When our engineers performed a review of that 9 observation, they opened up the design drawings, saw th e 10 note on the drawing that said tack welds are optional, 11' and, therefore, because these tack welds were missing,
'~'
v} 12 13 the -- a missing optional tack weld is not a --. is not a construction deficiency. It was in accordance,with the 14 Sargent & Lundy design. Therefore, we invalidated them.
15 _ (Indica ting.) .
.16 Q Could you go on to the second row.
' 17 - "In accordance with design at ticeiof original QC 18 inspection" -- or, '" Original QC," it says?
19 A- (WITNESS ORLOV)_ Certainly; and that's QC inspection.
20 It's shor tened f or that.
21 Our CSR inspectors, when they went out to do their 22l inspections, had, in their CSR inspection packages, 23 copies of the latest design drawings that were 24 applicable at the time those packages were prepared.
O
( 25' In all cases, af ter 6/3 0/19 84. In some cases, th ey 9:
Sonntag Reporting Service, Ltd.
- ~
Geneva, Illinois 60134 (312) 232-0262 i
F
^
h L
14001 i )
\ ~
s ,,/
,1 would identify a configuration of a particular item that .
2 looked nothing like' the drawing that they had in _ their.
package, -and based on -the CSR engineer's r eview of that' 4 _ apparent deficiency, they would be able to identify -
- 5. th a t, when that item was originally installed Land 6 originally QC-inspected by the Comstock inspector, that 7 that drawing that the Comstock inspector had had and to
'8 which he performed his inspection matched the condition 9 which our CSR inspector identified as discrcpant per the 10 latest-drawings.-
11 In'other words, it was a design change. Since the
- [ '} 12L time the original inspector had performed his V '
13 inspection, original Comstock inspector had performed 14 his inspection, a design change had been incorporated 15' into the drawings, but those things take some time 16 before they actually ' get reworked in the. field; and our i 17 inspector would identify as an apparent discrepancy 18 which, in fact, was not a discrepancy, a construction
- 19. discrepancy; and for those reasons, we invalidated those 20 type of observa tions.
-21 (Indica ting. )
22 Q Could you go down the third row, Mr. Orlov.
23- A (WITNESS ORLO7) The " Duplicate Observation" category is 24 a reason used for invalidating observations where two b)
V -
25 BCAP observations identified the identical condition.
Sonntag Repor ting Se rvi ce, Ltd.
Geneva, Illinois 60134 (312) 232-0262
/
14002
)
1 Most of those represent BCAP QA overinspection 2 inspectors identifying the same condition previously 3 identified by a CSR inspector.
4 Since they were doing blind inspections, for the 5 most par t, they didn't have our results in the package 6 to bias them originally, and they would perhaps have 7 written up the same -- we would have identified --
8 excuse me -- not we.
9 The CSR inspector would have identified a 10 di scr epancy , an apparent discrepancy. The BCAP overview 11 inspector, BCAP QA overview inspector would have come
[ 'T -
12 along and identified the same condition.
i.~ '
13 In some cases, those observations remain suitable 14 for further processing, and came to us f rom Q A, and we 15 would have to identify that this condition had already 16 been identified as part of the BCAP program by our own 17 inspector.
18 Therefore, one or the other of them had to be 19 invalidated because they represented two observations on 20 the same identical apparent defect.
21 (In dica ting .)
22 Q Could you go down to the next line, sir.
23 A (win 1ESS ORLOV) Certainly. f
,s 24 "Previously identified" is a category which we used
()
/ \
25 to invalidate observations.
Sonntaq Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262 t.
e- 14003'-
3i .31:
. Q ;'
1 When a condition that the CSR inspector -found11n 2 .the field had previously been identified by a Comstock
-3 or a CECO control . deficiency-type. document -- that is,
'4 for Comstock it would have been an ICR or an"NCR, or for 5' Ceco, it would have been.a CECO NCR.
6- In those cases, we would have reviewed those 7 deficiencies -- control deficiency-type documents, made -
- 8 a comparison of the type. of defect .that we had found,.
9 compared it to the defect that had been previously 10 identified in a control document, and we would
. .11 invalidate our own, because it had been previously
'}
~
12 identified by the proj ect and, therefore, CSR didn't 13 have to identify it.
14 Q Okay.
15 Mr. Orlov, the last line is marked " Incomplete f.
16 Construction with Documenta tion. "
1 -17 A (WITNESS ORLO/) Construction - at a power plant .is _ not .
18 stagnant. Things get completed and QC accepted, and 7 19 every once in a while, rework will be performed on those s
L 20 for one reason or another.
21 In these cases, we would have identified our sample 4
22- as having been completed and QC accepted, and then af ter 4
23 we've ' identified our sample, someone goes out, and 24 before we do our inspection, does rework to an item, 25 either temporary rework or -- excuse me -- moves an item u /.
Sonntag Reporting Service, Ltd.
! Geneva, Illinois 60134 (312) . 232-0262
7 -_
14004 f )
xJ l out of the way for an interference.
2 In those cases, where there was documentation 3 attesting to the fact that some construction was either 4 made incomplete or taken down, we would invalidate our 5 obse rva tion.
6 For example, if an observation says, "This cable 7 has been determinated," we walk out there with our 8 inspector and we identify that OTG, the Operations 9 Testing Group, had to lif t those leads to do come 10 testing on a piece of equipmer t, and they had a document
- 11. in their house saying, "Yes, we controlled the
( ') 12 removal" - "we controlled the lif ting of those leads
'~'
13 and we know that and we've got a controlled system for 14 that," we would invalidate those observations because 15 those really weren't a construction deficiency.
16 Rather, they were part of ongoing construction which was 17 appropriately documented.
18 Q Okay.
19 Could we go on to the second page of this exhibit, 20 please, Mr. Orlov.
21 It's a pretty busy table.
22 Could you please explain what it shows.
23 First of all, up at the top of the page, there is
_ 24 language tha t's cut off.
(~s ) 25 Can you tell me what that is supposed to say?
Sonntaq Reporting Se rvi ce, Ltd.
Geneva, Illinois 60134 L J32q232-0262
14005
> yy 1 1-h) '
11 A (WITt1ESS ORLOV) Yes; "BCAP Electrical Reinspection 2- Observations."
3^ 'Q what does this table represent,- sir?
4 A . (WITNESS ORLO7) This. represents a very summary table, 5 ;giving the dispositions of observations written, th e 6~ reinspection observations written in the electrical-7 disciplines- of . the BCAP.
8 It identifies for each population and distinguishes
'9 between those observations written against sample items
.10 - and those. written against non-sample items, ' the XXX 11 obse rva tion s.
/ 12 It will identify, just by sheer numbers, the number
\~-))'
13 tha t we made valid -- well, first of all, the total 14 observations written; the number which we validated, ,
15- both totally and partially; the ones we - the number we 16 invalidated, both totally and partially; the ones we 17 made out of scope, again, totally and partially; and 18- those that were made not suitable for further 19 pro ces sing.
20 Now, if I can explain a little bit what the partial 21- means and how I came up with tt'e numbers.
22 An observation, when written, may -- in one CSR 4-23 observation, may discuss a number of things that the
_ 24 inspector found; and in many cases, we would be able to (N 25 take that entire observation and say, "On th e whole, it Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
i-14006 J
1 is either valid or invalid or out of scope."
2 In some cases, we would have to say, "This 3 . observation" -- the first two paragraphs of it, for 4 example, would be valid, and the last paragraph 5 describing another type of condition, would be invalid, 6 and so it would be part valid, part invalid.
7 And that's why if you take the numbers in the 8 columns that say "both," both valid, both invalid, bo th 9 out of scope and both not suitable for further 10 processing -- if you add up those numbers, they don' t 11 add up to the total number of observations written.
') 12 They add up to more than the total number of 13 observa tions written.
14 But if you take the total number of totally valid, 15 totally invalid, totally out of scope, totally not 16 suitable for further processing, add all those up, and 17 then add up all the other par tially valid, invalid, out 18 of scope and not suitable for processing and multiply 19 that by .5 and add them up, you come up with the total 20 number of observations written. That's described in a 21 note on the right-hand side.
22 If that's conf using, I can try and go over that a 23 little more simplistically.
24 In any case, if an observation was both partially 7
( 25 valid and par tially invalid, it will show up twice in Sonntaq Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14007 n.
1 this table in two columns. It will account for one item 2 in two columns.
3 0 Could you explain what the row marked XXX -- or the rows 4 marked XXX indicate?
5 A (WITNESS ORLO7) Certainly.
6 Those are the observations -- let me give you an 7 exampl e.
8 XXX under cable, the XXX designation right under 9 the cable will identify those out of scope -- excuse 10 me -- the observations that were written against 11 non-sample items that were applicable to cable.
[ 12 As an example of that, we' re tracing a cable down
)
13 from one end to the other. As you heard earlier, our 14 cable inspections went f rom one end, one termination, 15 and we traced it all the way through the cable pans, 16 through conduits, all the way to the other piece of 17_ eq uipmen t.
18 If, in our inspection of that cable, we identified 19 an adjacent cable which may have had some apparent 20 defect, an apparent discrepancy, we would have 21 identified that other cable, which we weren't 22 inspecting, on the XXX observation; and our inspectors 23 were encouraged to identify those potential 24 discrepancies.
! 1 But in order not to confuse our sample, we gave
( ) 25 Sonntag Repor ting Se rvi ce, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14008 5\, /~
'l ! th em J that' XXX number so that- won't be associated with .
J! - the -cable we were inspecting, ~ because it really : wasn' t 3' l applicable to the ~ cable we' were inspecting, and that's 4 -what those columns mean.
5 JUDGE GROSSMAN: Excuse me.
6 I must have missed this. ]
7 .A (WITNESS ORLOV) .I'm sorry.
8 J UDG E .G ROSSMAN : But what's the difference-
-9' between a partially valid and a partially invalid?
10 A (WITNESS ORLD/) An observation may be . written on -- the 11 observation may describe more than one ' condition being j'# 12 potentially discrepant. It may : say that the conduit x,} '
^
13 hanger, for example, is three. inches too 'shor t and two 14 feet in the wrong direction.
15 Now, those are -- on one observation form, 16 described two different conditions.
, 17 JUDGE GROSSMAN: Yes.
18 A (WITNESS ORLO/) Now, one of those conditions might be 19 valid.
20 It -- the two feet in the wrong direction, out of 21 XY tolerance, may by a valid discrepancy, because the L
2
'2 tolerance for those hangers is usually six inches, but
.23 the three inches too short doesn't matter, because you
- 24 are allowed to shorten most conduit-type hangers, as an
/'\ .
4 25 e xam ple.
t Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14009 f3 j-
, :f N,
1 So we would vadidate that por tion of - the -
2' observation which dealt with the out of location hanger 3 and we would invalidate that portion of the observation 4 that described the' conduit cantilever being too short.
S' So on one observation record, which had one number, 6 ~ the observation would be both valid partially and 7 invalid, the other part of -it.
8 Am I' making any sense to you?
9 JUDGE GROSSMAN: Well, yes.
10 But let's change the example so that --
11 A (WITNESS ORLU/) Okay.
-[ T 12 J UDG E G ROSSMAN : --
there are three
&b 13 observations on one record, because I don't think it 14 makes sense unless you do that --
15' A (WITNESS ORLOV) Okay.
16 JUDGE GROSSMAN: -- and you . determine that 17 one observation is valid and two are invalid.
18 Now, hos does that show up here, one in the I
19 partially valid and two in the --
'20 ~ A (WITNESS ORLO/) No. An observation -- I'm sorry for 21 cutting you off, but an observation has, on Page 2, a 22 box that's checked -- there are three boxes. You ge t-i 23 three choices, valid, invalid or out of scope, and if it l
l 24 had marked in there valid, it would show up as one O
(f ) 25 observation partially valid. If it -- or -- e xcuse me.
Sonntag Reporting Service, Ltd.
- Geneva, Illinois 60134 (312) 232-0262
14010
(
1 I ~ it had a mark in only the valid box, that would 2 be one observation totally valid. If it had a mark in 3 both boxes -- irrespective of how many identified 4 discrepancies -- potential discrepancies were in the 5 obse rva tion, if it was marked in two columns, it would 6 be one CSR observation, partially valid partially 7 invalid.
8 So I wasn' t measuring the -- I wasn' t trying to 9 measure the weight of that valid or invalid.
10 The observation was either valid, invalid, out of 11 scope or par tially invalid and par tially valid, 12 partially valid and partially out of scope.
[ ))
13 JUDGE GROSSMAN: Okay.
14 My problem is simpler than I think you are going 15 into.
16 A (WITNESS ORLDI) Okay. I wouldn' t count 2 and 1. I 17 would count 1 and 1 under the partial columns, to answer 18 your question.
19 JUDGE GROSSMAN: Yes.
20 But that would make me think you would have an 21 equal number of partially valids and partially invalids.
22 A (WITNESS ORLO7) Yes.
23 JUDGE GROSSMAN: And I see you don't, and 24 that's what gave risa to my question in the first place, t
! ) 25 A (WITNESS ORLOV) I'm sorry.
Sonntaq Reporting Service, Ltd.
} Geneva, Illinois 60134 (312) 232-0262 l J
l 14011 ,
1
'Yt 1 If you take a look at -- sea, not every 2 observation, which is a partial, is partial valid and 3 par ti al invalid. Some of them are partial valid and 4 partial out of scope.
5 You see the third column, there's a partial out of 6 s co pe ?
7 JUDG E G ROSSMAN:
Yes.
8 A (WITNESS ORLOV) If you add up the par tial valid, th e 9 partial invalid, the partial out of scope and the 10 partiel not suitable for further processing, divide by 11 tw o, that will give you the total number of observations l \ 12 that -- observation records that were divided amongst
\
~'
13 different categories.
14 (Indica ting . )
15 Remember, you have a permutation of three boxes.
16 You have six different combinations that you can have 17 when you take any number -- take two at a time or three.
18 (Indica ting . )
19 Am I making sense?
20 MR. BERRY: Can we go through the first one 21 as an example?
22 A (WITNESS ORLOV) The first one?
23 MR. BERRY: Can you illustrate what you j ust 24 said?
(w/ ) 25 A (WITNESS ORLOV) Okay. On a CSR observation record, Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
{
14012 m
i s
1 Page 2 identifies the validity determination.
2 Okay. There are three boxes up in the right-hand 3 corner.
4 JUDG E GROSSMAN: .Righ t. -
5 A (WITNESS ORLOV) The boxes are valid, invalid and out of 6 scope.
7 Now, on a given observation record, one observation 8 record has one unique number, may identify, as you know, 9 more than one apparent discrepancy.
10 Now, that one observation can be marked valid, 11 invalid or out of scope. That's obvious.
[LJ } 12 JUDGE GROSSMAN: Okay.
13 I'm not sure -- before you go any further, did you 14 say that there would be two possibilities out of the 15 three for each one in which there was a partial?
16 A (WITNESS ORLOV) There would be six different 17 combinations that could be possible. That is, pa rtial 18 valid, par tial invalid; par tial valid, partial out of 19 scope; partial invalid, partial out of scope. That 20 makes three.
21 Now, we throw in not suitable for further 22 processing in there and add a couple more --
23 JUDG E GROSSMAN: Okay.
,_ 24 A (WITUESS ORLOV) -- and we throw a combina tion --
l -,
t 25 JUDG E GROSSMAN: What I ment to say was, in t._ /
)
Sonntaq Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14013
-~
1 every case in which there was a partial --
2 A (WITNESS ORLO7) Yes.
3 JUDGE GROSSMAN: -- there would be two 4 partials out of a possible three partials -- out of 5 three boxes ?
6 A (WITNESS ORLOI) Correct.
7 JUDGE GROSSMAN: In other words, it could be 8 a partial valid, partial invalid, or it could be a 9 par tial valid, pa r ti al o ut of s co pe, or it could be. a 10 partial invalid, partial out of scope?
11 A (WITNESS ORLOV) Correct.
12 J UDG E G ROSSMAN : Okay, fine.
['
RJ 13 That explains it.
14 A (WITNESS ORLO7) That's 99 percent right.
15 In one case, there was a partial not suitable for 16 further processing, and if we ignore that, what you said 17 is absolutely correct.
18 J UDG E G ROSSMAN: All right, fine.
19 A (WITNESS ORLOV) Okay. You could have theore tically had 20 the condition where you had all three, but that didn' t 21 h appe n.
22 JUDGE GROSSMAN: All right.
23 A (WITNESS ORLOV) That would be -- confuse the matters 24 even more.
(s j) 25 MR. GUILD: Just maintaining this flow, I Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14014
/
'~-
1 asked counsel whether there was a box for out of scope.
2 He pointed out that in one revision of the 3 obse rva tion, indeed the third box is out of scope.
4 But so that Mr. Orlov doesn' t ge t too f ar beyond my S f ollowing him, there was certainly a time when there was 6 no third box, out of scope, but they deemed things out 7 of s co pe ?
8 A (WITNESS ORLO/) No.
9 (Indi ca ting .)
10 MR. GUILD: He shakes his head.
11 A (WITNESS ORLOV) Before the date of that revision, there Th at ' s
'~
'} 12 was -- there were no out of scope observations.
13 why there was no box. Tha t makes it simple.
14 BY MR. STEPTOE:
15 0 Could you go on to the line marked "XXX" under " Cable. "
16 Can you explain what that signifies?
17 A (WITNESS ORLOV) Okay. Again, those represent the 18 observations written by the CSR inspectors that are 19 applicable -- that are, first of all, out of the CSR 20 scope of inspections.
21 They didn' t apply to an item which the CSR 22 inspector was tasked to inspect. He found something 23 else on his way out there adj acent to something that he
,_ 24 was -- to which he was supposed to be inspecting. It
! N
( ) 25 wasn' t part of our sample.
j Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14015 1 I believe here we looked at 120 cables. It would 2 have been f rom the balance of the plant not including 3 those 120 cables.
4 (Indica ting. )
5 Q Mr. O rl ov, there's also subtotals and both for the 6 population and f or the XXX's on this table, are there 7 not?
8 A (WITNESS ORLO7) Yes, there are.
9 _Q And could you just identify the little check marks in 10 what appears to be different handwriting over the table?
11 Can you identify the author of those check marks?
[
\
') 12 A (WITNESS ORLO/) Ce r tainly . Those are Nino Kaushal's 13 check marks. He checked my math and made sure that all 14 the numbers added up appropriately, and he compared the 15 numbers on this chart with some of the back-up 16 information to assure himself that what I did was 17 reasonable and proper, 18 0 Okay.
19 Could we go on to the third page of the table, sir.
20 J UDG E C ALLIH AN : Before we leave that, Mr.
21 Steptoe, may I ask a question, please?
22 A (WITNESS ORLOV) Certainly.
23 JUDG E CALLIH AN: Mr. Orlov, back in the XXX
,_ 24 category, does an inaccessible item -- do
/ N 25 inaccessibility items appear somewhere in this table?
i,
)
Sonntaq Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14016 j
1 Maybe in XXX?
2 A (WITNESS ORLO/) No; because by definition, if thEy were 3 inaccessible, we would not have been able to inspect 4 them, and if we were unable to inspect them, then we 5 couldn't have identified an observation.
6 We wouldn' t have written an observation just on the 7 basis that we couldn't perform an inspection because it 8 was inaccessible.
9 So nowhere will you see an observation that 10 identifies the inability to inspect an inaccessible item 11 or just that an item is inaccessible.
[
'N J
) 12 (Indicates.)
13 J UDG E CALLIH AN : Similarly, for those that 14 are not reproducible --
15 A (WITNESS ORLO/) Correct, yes.
16 J UDG E C ALLIH AN : -- like pull tension and so 17 for th ?
18 A (WITNESS ORLOV) Right. We wouldn' t have generated a 19 reinspection observation based on the fact we couldn't 20 inspect pull tension.
21 J UDG E C ALLIH AN : So they had f allen out of 22 the picture before you got that far?
23 A (WITNESS ORLOV) Yes, they were identified -- the areas
,_ 24 that we didn' t inspect are identified in those cover
! N i 25 memos to the checklist; but in most cases, we picked
)
Sonntaq Reporting Service, Ltd.
Geneva, Illinois 60134
- (312) 232-0262
.y .
~.
b r
14017
. , -m
( )
Q,)
1 -those ) inaccessible and unreproducible attributes ,up 'in 2~ our' doc review; inzfact, specifically one of the 3- attributes subject to check, according to' Mr. Guild's 4 words.
5 For Ehe most part, we tried to include those 6 non-recreateable attributes in the reinspection 7 category. We tried to pick those up in the
.8 . documentation review associated with the CSR items.
-9 Every time we had an inspection of an item --
10 reinspection of an item, we also reviewed the associated 11 .Comstock reinspection records for:that item, and if, for
['
' \_ -
12 e xample, there was a pull tension which we couldn't 13' recreate, we would review the Comstock QC records to 14 assure ourselves that the pull tension was appropriately 15 specified or the torque wrench value was appropriately 16 specified or the torque wrench was appropriately
- 17. calibrated.
18 Those things that we couldn' t reinspect because 19 ' they were non-recreateable, we looked for them in the 20 document review.
21 (Indica ting . )
22 JUDG E G ROSSMAN: Well, did you write an 23 observation on those deficiencies in the document?
24 A (WITNESS ORLO/) Assuming that there were deficiencies L
\
25 in the documenta tion.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
n.
14018
-f ~%; ,
2i L A_f:
1[ For rexample, if J the pull tension were. documented .
2 incorrectly or if the torque wrench was out of 3 calibration or if they used the wrong' torque wrench 4' Lvalue,.those'would have been identified on the_ doc-5- r eview observation, yes.
15 MR. STEPTOE: Judge Grossman, we have not.
7 of fered any testimony on the _ CSR documentation r eview, 8 which is not part of the evidence that we've offered.
9 JUDGE GROSSMAN: Okay.
11 0 It doesn' t go z into this particular category - the 11 categories that we have here?
[; 12 MR. STEPTOE: That's correct, that's correct.
13 I think that's by way of outside the scope of what
'14 we -- what we have planned as part of our rebuttal case.
15 JUDGE GROSSMAN: Okay.
16 MR. STEPTOE: Let the witness --
17- J U DG E C ALL1H AN : I'm --
t 18 MR. STEPTOE: Please go ahead.
19 ' JUDGE CALLIHAN: For the sake - of being 20 repetitious and with an apology, I'm back on XXX.
21 A (NITNESS ORLOV) Okay.
! 22 JUDG E CALLIHAN: Give me an example of a XXX i
23 item.
24 A I'll take cable -- cable, because that's an easy one.
! I )\
!- \.
25 That's the first one on the list.
l f.
Sonntaq Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
r 14019
~.
)
~
l We're looking at a cable that is routed from one 2 piece of equipment to another piece of equipment, and 3 that cable runs, in most cases, along with a number of 4 other cables. It's in cable pans with a number of other 5 cables. It's bundled up and tie wrapped together with a 6 number of other cables.
7 Now, if while I'm inspecting my cable, and it's in 8 a -- it's in a bundled package of a number of cables, I 9 see that there's a separation violation with my cable, 10 and another cable over here, let's say in f ree air, it's 11 closer to 12 inches, well, I know that every other cable j 12 in that bundle, being of the same signature, will also 13 violate the separation requirements with that other 14 ca bl e. I know that, and so I write an observation 15 saying, "All the cables in this bundle, in addition to 16 my cable, also violate the separation requirements or 17 apparently violate the separation requirements with this 18 other cable," even though none of those other cables 19 that are in that bundle where my cable goes through are 20 part of my sample.
21 JUDG E CALLIH AN: By quote, "my cable,"
22 unquote, do you mean --
23 A (WITNESS ORLO7) I mean --
, 24 JUDGE C ALLIHAN: -- one in the BCAP program,
/ N
( ) 25 one in the sample?
Sonntag Reportina Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
7 14020 i i 1 A -(WITNESS ORLOV) One in the BCAP program. 'Ih e one th e 2 inspector is currently out there tracing f rom one end to 3 the other, yes.
4 Or in some cases, we've written XXX observations 5 because the inspector is walking from -- from his office 6 out to the field, and he sees something that obviously 7 isn't right, like a damaged hanger, you know, or a pipe 8 that's lying on the ground or people stepping on things.
9 In fact, in one case we had a piece of scaffolding 10 erected on a small bore pipe, 11 Our inspectors would identify that, and the 12 mechanism for their being able to identify that is a XXX 13 observation.
14 (Indicating.)
15 J UDG E C ALLIH AN : W ell, the n , I have in mind N 16 minus 1 entitles, where N is the number of cables and 1 17 is yours.
18 A (WITNESS ORLOI) Okay.
19 JUD3E CALLIH AN: Does that go on -- the N 20 minus 1 add into the number of observations, the number 21 of samples, the popula tion? Does it appear anywhere.
22 down the line?
23 A (WITNESS ORLOI) llo; and let me try and tell you the 24 reasons for tha t.
,,_ x
('j I 25 Well, first of all, it doesn' t appear anywhere but Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262 f
14021 g
J' 1 the XXX observations, and those XXX observations aren't 2 factored into our results, and the the reason we 3 couldn't factor them into our results is because we 4 don' t know -- we know that the numerator, let's say, if 5 we want a fraction of percent ef fective -- okay -- which 6 I think CSR -- what CSR was looking at was percent 7 defective.
8 We knew that we found some deficient items on our 9 way out to the field because our inspectors were 10 obligated to write things up when they found 11 deficiencies, but we didn't know, on the inspector's n
( 12 path out there, how many things he identified as being i
}
/
13 okay. Therefore, we only get the bad and not the good.
14 And so we have a number of things in our numerator 15 that show up as bad, XXX's, but we have the 16 denominator -- the only way we could gauge our 17 denominator is say we know we at least looked at however 18 many XXX observations he wrote.
19 Therefore, we would have a hundred percent 20 defective in the XXX, even though he walked out in the 21 plant every day and look ' ! at thousands of other cables 22 but he never identified those as being acceptable.
23 Ther ef or e, since it wasn't part of our sample and
,_ 24 there was no way we could really make an accounting of
! N
( ) 25 those, we had to set them aside; but we assured v
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
~ ~
14022
%)
- . ;1 ourselves -that they would be documented not only on 2 lobservations L but they would be forwarded 'to PCD 'for 3 : resolution.
4^ They all<got documented onto an NCR --- I think
- 5 that's '6145 -- so they would be appropriately addressed, f
PCD and CECO -would look at those and do whatever 7- th ey -- h ad to to res olve th e con ce rn s .
l: . .
l 8 But in your -- in answer to_ your specific question, l 9 they figure nowhere in our results. Th ey don' t add . any fl-0 sam pl es, there is no way you can calculate anything f rom 11 them_ because you have only bad L-- only. nega tive results, l
f)
^%.J 12 ' and;you have no denominator of total things looked at at g 13 which we were looking. You have no denominator, so you-l
-14 can' t -- you can' t really como up with any o' pinions.
l-15 (Indi ca ting. )
l 16 JUDG E CALLIHAN: As a.for instance, they 17 don't appear on this chart?
- 18. A (WITNESS ORLO7) No, they don' t appear on that chart.
- 19 JUDGE C ALLIH AN
- All right.
l 20 Thank you very much.
L 21 JUDGE COLE: You said PCD?
=22 A (WITNESS ORLO7) I'm sorry. Proj ect Construction
--23 Depa r tmen t.
24 JUDG E COLE: Okay.
!' I 25 Thank you.
! w/
i Sonntaq Reportino Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14023 4
1 .A (WITNESS ORLOV) Tha t's CECO.
2 I'm sorry.
3 JUDGE COLE: Okay.
4 BY MR. STEPTOE:
5 Q The XXX's are, however, on this one page, the second 6 page of Applicant's --
7 A (WITNESS ORLOV) Yes.
8 0 -- Applicant's Exhibit 142? That's correct?
9 A (WITNESS ORLO7) Correct.
10 MR. GUILD: Just to be clea r, th e N CR 6145 11 includes all the XXX's?
t i 12 A (WITNESS ORLOV) Tha t's my understanding.
8 1
~
13 I haven' t gone through it and checked, but my 14 understanding is that it does.
15 MR. GUILD: Were all XXX's deemed valid?
16 A (WITNESS ORLOV) Well, no, sir. The definition of valid 17 or invalid -- yes -- excuse me -- correct.
18 MR. GUILD: If you invalidated the XXX, it 19 doesn' t appear in NCR 6145?
20 A Correct, invalid XXX will not appear in 6145 because it 21 does not represent a discrepancy, had no potential for 22 representing a real discrepancy.
23 MR. GUILD: And then -- but j ust one other
,_ 24 point, Mr. Orlov.
/ N
! ) 23 The out of scope column in your second page table,
's Sonntag Repor ting Service, Ltd.
Gencva, Illinois 60134 (312) 232-0262
1 14024 1
,n i
\
w,/
1 th ey, also, to the extent they are valid, are items that 2 appear in 6145, NCR 6145?
3 A (WITNESS ORLOV) W ell, I'm not quite sure of your 4 definition of valid.
5 We did not, for the most part, provide -- look in a 6 detailed way as to the validity of the out of scope 7 observations.
8 _ If we coni dn' t, on the f ace of them, immediately 9 determine that the observation was invalid, we made it 10 out of scope.
11 Many of those out of scope observations, for all I
) 12 know, could be invalid. We made no validity
\
/
13 determination of those.
14 MR. GUILD: You did make a validity 15 determination of some of them?
16 A (WITNESS ORLOV) We made -- some of them, th ey wer e 17 obviously invalid on the f ace of them. It took us no 18 ef fort to invalidate them because they were obviously in 19 accordance with the design.
20 So in those few cases.where we were able to 21 invalidate them, we did that, because we didn' t want to 22 be sending obviously invalid observations to PCD. Th ey 23 have enough to do.
24 MR. GUILD: All right sir.
(v)25 A (WITNESS ORLO7) But in terms of the out of scope ones, Sonntaq Repor ting Se rvi ce, Ltd, Geneva, Illinois 60134 (312) 232-0262
14025 x_/
1 you said that they were obviously valid, but I don't 2 know that. We didn' t do an in-depth review as we did 3 with others.
4 There very well may be, and I certainly expect that 5 in the out of scope observations there are a number of, 6 quote, " invalid observations."
7 So when we defined things as out of scope, we don't 8 say they are valid out of scope or invalid out of scope.
9 We just say, f rom BCAP's standpoint, th ey are out of 10 scope, period, 11 BY MR. STEPTOE:
i 12 Q Mr. Orlov, in the cable pan hanger -- for cable pan
~~
13 hangers unde r 614 5, the Board has already seen some 14 observations marked out of scope and valid for cable pan 15 hanger configuration.
16 A (WITNESS ORLOV) Valid for cable pan hanger 17 configura tion ?
18 Q That's righ t.
19 A (WITNESS ORLO/) Oh -- excuse me -- yes.
20 Q Would you explain how that occurred?
21 A (WITNESS ORLO7) Ce r tainly .
22 Cable pan hanger, if you look on this chart, you 23 will see 372 out of scope, 32 partially out of scope,
,_ 24 which represents a total of 404 observations which
) 25 either are totally or partially out of -- excuse me --
r l
l
- Sonntag Repor ting Se rvice, Ltd.
Genova, Illinois 60134 (312) 232-0262
s 14026-
^pg
?'s I )
a 1: out of scope forc capable pan hangers.
2 Some of those were initially marked valid and some -
3 were initially marked invalid.
4 . When we. Initially ' performed our -cable pan hanger 5 configuration inspections, we wrote up observations, and 6- Lwe initially determined some of them were potentially 7 valid and'some of them were invalid. -
.8- Later, based on additional information, in 9 particular resolution to NCR 708 and 709, we found that.
l 10 as. a valid -- as' a reasonable basis upon which we could-11 make cable pan hanger configuration observations out of
' [~ h 12 scope, and the reason .for that is _that we knew there was D 13 a documented walkdown -- 100 percent walkdown of cable i.
14 pan hanger configurations that was being undertaken by 15 Comstock and Sargent- & Lundy for the~ cable pan hanger 16 configurations.
j 17 So, therefore, we in BCAP said, "Well, BCAP is
. 18 trying to identify previously unidentified discrepancies i 19 for the basis of judging the quality of- the remaining 20 popula tion. "
]
21 And we knew, for example, that previously 22 identified problems did apply to cable pan hanger
[ 23 configuration -- and that's 708 and 709 was being 24 performed -- and we knew that this is going to be done
- I j 25 on a hundred-percent basis, so there was no reason for I
b Sonntag Repor ting Service, Ltd.
U Geneva, Illinois 60134 (312) 232-0262
m ~w
[
140271 f '--,
t
- V )-
, 21' BCAP to provide any - results forf cable : pan hangers.-
.2 We knew that they were al1< being hundred-percent-3 reinspected for configuration. : Th er ef or e, it did~really 4 no good for. BCAP to .~ provide results for cable pan 5 hangers, and we knew that a walkdown was being provided 6 to reinspect '100 percent of those cable pan hangers.
7 That was the basis in BCAP-06 for making those 8 results out of scope.
$ So in your table, all th e -- in yo ur ta bl e, . all th e 9 Q-L10 cable pan hanger configuration observations are in the .
- 11. out of scope column; la that correct? ~ .
[h
. b ].
12 A- (WITNESS ' ORLO7) No. Some of :them are, in f act, 13 invalid.
14 In fact, the '24 - totally and the 34 partially L
15 invalid observations you see there are, . in fact, 16 configuration inspections.
l'7 0 Could you explain what the percentage -- how the 18 percentages are computed that appear on this second
{ 19 page?
L20 A (WITNESS ORLO7) Yes.
21 You will see a note on the far right-hand side -
22 written vertically.
p 23 I wanted to, for each population -- for example, 24 cable, look at the 172 total cable observations written
() 25 and determine the percentage of observations -- the Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14028 i
n 1 total observa tions tha t were validated, invalidated and 2 made out of the scope and made not suitable for further 3 processing. ,
4 Q So f rom the table, 5 8 percent of the cable observations 5 were valid and 30 percent were invalid -- I'm sorry --
6 valid.or partially valid; 30 percent were invalid or 7 partially invalid; 2 percent were out of scope or 8 partially out of scope; and 10 percent were not suitable 9 for processing or partially not suitable for further 10 processing? Is that what those numbers mean?
11 A (WITNESS ORLOV) Yes, that's what those mean, with the
( ')
\ /
12 clarification that the way those numbers were calculated 13 is tha t, as a denominator, I used the total number of 14 observations written. For the numerator, I used the --
15 if I wanted to calculate valid, percentage of valid --
16 you see 5 8 percent there -- I would take 912 plus half 17 of 17 and divide that by 172, coming out with 58 18 percent.
19 Otherwise, if you add up the percentages, it won' t 20 add up to 100 percent.
21 (Indicating.)
22 Q Let's go on to the nexb page, Mr. Orlov.
23 Can you explain what this page, marked " Conduit,"
, 24 r epresents ?
i i
?, ) 25 A (WITNESS ORLO7) Certainly.
v' Sonntag Repor ting Se rvice, Ltd.
Genova, Illinois 60134 (312) 232-0262
r 14029
[h V
1 For each conduit reinspection electrical 2 observation,- I attempted to define what basis was used 3 for the invalidation of the observation, and those bases 4 are identified at the top of the page, and they are in 5 accordance with design, and' there are miscellaneous 6 reasons for that in accordance with design, and in 7 s pe cific, tha t -- there's a specific reason for that --
8 excuse me. Let me start over, t
9 That is a subset of in accordance with the design, i
10 but there's a specific reason for all of those, and it's 11 the same, and that is that they only had a -- those
,n 12 conduits only had a partial seg code label instead of a
[.
13 f ull seg code label, and that was in accordance with 14 design; but we had so many of them, I broke that out 15 separately so people could get more of a flavor for. why.
16 we invalidated things.
17' Incomplete construction with documentation I 18 already identified. :
- 19 There are two additional items on there which are 20 special categories, also, and those are loose flex l 21 without cable pull and bushing not tight.
l: 22 And I can go into those, if you like, Mr. Steptoe, l 23 and describe those a little more fully, 24- 0 No.
( ) 25 Just what category would they fit under on Page l?
l-l ,
i i~ Sonntac Repor ting Se rvice, Ltd.
Geneva, Illinois 60134
- ( 312) 232-0262
14030
/
j
')
1 A (WITNESS ORLOV) Bushings not tight would fit into in 2 accordance with design. Loose flex without cable pull 3 would go into incomplete construction with 4 documentation.
5 Q Can we go on to the next page. It's Cable Pans.
6 Again, I assume this is the breakout of the reasons 7 for the validation?
8 A (WITNESS ORLOV) Yes.
9 JUDG E COLE: What are the numbers that we' re 10 looking at on these pages?
11 A (WITNESS ORLO/) They are the last two suffixes of a
[, } 12 CSR observa tion. For example, in --
13 JUDG E COLE: That's fine.
14 Thank you.
15 A (WITNESS ORLO7) The first number is the package number, 16 the second number is the sequential number for that 17 package.
18 JUDG E COLE: Thank you.
19 BY MR. STEPTOE:
20 0 Cable pan -- cable pan doesn' t include any new concepts.
21 Ne'll move on.
22 A (WITNESS ORLO7) No.
23 Q The next page is Cable.
24 If there are any things that you haven' t already
(_ .
( 25 talked about on this page -- in par ticular the first
)
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14031 v
1 column, marked "Separa tion Previously Identified," could 2 you explain what that column means?
3 A (WITNESS ORLOV) Yes.
4 Both Comstock -- well, Comstock, in conj unction 5 with Sargent & Lundy, had a program in existence before 6 BCAP ever began where separation violations or apparent 7 separation violations would be documented by both 8 Comstock and Sargent & Lundy in structural walkdowns, 9 and those would be identified on a special cable 10 interaction report, some document with that name. I'm 11 not quite sure of the exact name -- and they would be
['Lj' 3 12 then incorporated into a design review by Sargent &
13 Lundy and put into a list of cable separation violations 14 that Sargent & Lundy would maintain.
15 (Indica ting . )
16 In each case, our CSR inspector identified a cable 17 separa tion viola tion or an apparent cable separa tion 18 violation that had been previously documented by the 19 Comstock-S & L system for identifying these cable 20 separation violations.
21 Q Now, Mr. Orlov, there are some stars on this page.
22 A (WITNESS ORLO7) Certainly.
l 23 Q Could you explain what that star means?
24 A (WITNESS ORLD/) Certainly.
7
/ T 25 There is -- in the first column, there's a star by l
( J.)
R l
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14032 i ,
',J 1 146 -- Observation 146-3.
2 What that means is that that observation was 3 invalidated for more than one reason, and so you will 4 also see 146-3 under "in accordance with design," the 5 second column, all th e w ay a t th e bottom.
6 (Indica ting. )
7 So you will see -- on that observation, you will 8 have seen more than one type -- more than one apparent 9 discrepancy identified on the observation.
10 One of those' apparent -- one or more of those 11 apparent discrepancies would have been invalidated due
('
iv'
) 12 to the fact that it was in accordance with design, and 13 the other portion of it would have been invalidated in 14 this case because the separation violation had been 15 pr eviously identified.
16 (Indicating.)
17 So wher eve r -- any time ther e's a sta r, it's one 18 observation record which has more than one -- falls into 19 more than one category for invalidation, for reasons for 20 invalida tion.
21 (In di ca ting . )
22 Q Mr. Orlov, turning back to Page 1, I note that some of 23 the numbers on Page 1 are halves.
24 A (WITNESS ORLO/) Correct.
(L.; ) 25 For e xample -- well, those star items I only Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14033 t 8 L ,)
1 counted half when I' did my tallies for describing the 2 total number of items in any one of these reasons for 3 invalidation, and that's because an observation that was 4 starred would show up in two separate reasons, and, 5 therefore, I gave half to one reason and half to the 6 other reason, so that when we totaled up our 7 obse rva tion s, they would come up with the right number 8 of observations either partially or totally invalidated 9 So you see under " cable" on the first page "in 10 accordance with design" is 22-1/2. That half represents 11 Observa tion No.146-3.
/ ,\ 12 You also see under "in accordance with design" --
N 13 e xcuse me -- under " cable" "separa tion pr eviou sly 14 identified," you also see previously identified 22-1/2, 15 also.
16 So that observation 146-3 accounts for the half "in 17 accordance with design" on the front page and half under :
18 "previously identified. "
19 Q !!r . Orlov, I'm going to ask you to turn ahead. Th e 20 remaining pages, until you get to the last page, are 21 essentially the same as you previously described. Ther e 22 don' t appear to be any new types of entries.
23 A (WITNESS ORLOV) Correct.
,, 24 Q Can we go to the last page called "out of scope. "
/ .
(vl 25 A (WITNESS ORLO7) Certainly.
Sonntag Reporting Service, Ltd.
Geneva, Illin ois 60134 (312) 232-0262
14034 i
n._
1 This is a description of each item observation that 2 was determined to be out of scope. In other words, 3 these are observations that were written against sample 4 items in the electrical population that were determined 5 to be out of scope; and you see a little "AKA Block 3."
6 That's a term of art.
7 We call them Block 3 because they were the third 8 block -- out of scope was the third block, so we know 9 that as Block 3.
10 (Indi ca ting. )
11 Q Now, this doesn't categorize any of the XXX out of
(' , 12 scopes; is that correct?
~
13 A (WITNESS ORLOV) Correct. It only identifies -- it 14 only categorizes those observations which were written 15 against sample items.
16 Q And you have cursory descriptions here for each 17 construction category followed by numbers, which, I take 18 it, refer to the observations in question?
19 A (WITNESS ORLOV) Yes, correct.
20 MR. STEPTOE: Judge G rossman, at this time I 21 move that Applicant's Exhibit No. 142 be received into 22 evidence.
23 I tender Mr. Orlov for cross examination.
24 JUDGE GROSSMAN: Any objection?
p_.
! N (v ) 25 MR. GUILD: No, sir, I have no obj ection.
Sonntag Repor ting Se rvice, Ltd.
Gencva, Illinois 60134 (312) 232-0262
14035 ns_
1 JUDGE GROSSMAN: Mr. Ber ry?
2 MR. BERRY: No obj ection f rom the Staff, Mr.
3 Chairman.
4 JUDG E G ROSSMAN: Received.
5 (The document was thereupon received into 6 evidence as Applicant's Exhibit No. 142.)
7 MR. STEPTOE: I should say that we probably 8 have some additional exhibits, which are in suspension 9 right now, and perhaps we can catch up on them later in 10 the day or tomorrow morning.
11 JUDGE GROSSMAN: Okay.
/ T 12 Did you wish to of f er the panel now for recross, C 13 is that it, or are you finished with the panel?
14 MR. STEPTOE: I'm finished with the panel, 15 yes, as well as with Mr. Orlov.
16 JUDG E GROSSMAN: Okay, fine.
17 Yes, Mr. G uild.
18 MR. GUILD: Should I proceed with my recross, 19 Mr. Chairmaa?
20 J UDG E G ROSSMAN : Your recross, yes, for the 21 panel and cross for Mr. Orlov or recross or whatever you 22 wish to call it.
23 CROSS EXAMINATION 24 BY MR. GUILD:
/x
/ \
( ) 25 Q Mr. Orlov, I appreciate you helped me last night walk s
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14036
./ \ #
);
llV
'If -through this.
2 The categories that you have used that appear on 3' both the first page of Applicant's 142 and in the more '
O 4. detailed pages for each of the population categories, 5- those are category explana tions for invalidity , that are
.6 your own, are they - not?
7 A (WITNESS ' ORLOV) Well, for the prima ry part, they come
- 8. out of BCAP-06, 9- If you take a look at Pa'ragraph 433, I believe in 10 accordance with design . is 433A;'in accordance with 11 design at the time of original QC is 433 maybe B.
L[ 12 Q They are your paraphrase of BCAP-06?-
13 A - (WITNESS ORLOV) Yes, they are my paraphrase; but they 14 a're in accordance with the reasons delineated in the 15 BCAP-06 procedure.
16 Q I see.
17 But it is clear that this represents your r 11 8 evalua tion of the reasons for these observa tions and '
19 assigning them among those categories? There was not'a 20 formal process in the observation process for thesc
. 21 observations of an assignment to one reason or another
- 2 7-. for validity?
, -~~-
-1 23 A (WITNESS ORLOV) Well, actually, towards the later 24 stages of BCAP, we actually did give it a paragraph p} 25 g
number A, B, C, D, E, F, G, H or whatever on the Page 2, Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 _
(312) 232-0262
14037 7
I i-
, G 1l and in those cases, I would look at that and I would 2 also read it, and in every case I concurred.
r 3 But for the most part, yes, these are my 4 evaluations of Page 2 and the reasons for invalidity, so
'S I categorized them, yes.
'6 Q All righ t.
7 Is there a revision point at which the BCAP-06 8 procedure called for the assignment of a subparagraph 9 explanation of the basis for invalidity?
10 A~ (WITNESS ORLOV) No. That was more in a response 'to 11 additional information that' BCAP Q A requested.
12 When BCAP QA looked at -- performed their J
13 hundred-percent review of all BCAP observations that 14 were made invalid, they added -- they had asked for 15 clarification that -additional information be provided.
16 In most cases, the answer' would be written out. It 17- says, "This is in accordance with the design. See 18 Sargent. & Lundy Paragraph" -- I mean -- e xcuse me --
19 " Drawing 20 E 3031 Rev F Paragraph" -- you know, " note 20 so and so or detail so and so."
'21 The -- in most cases, the explanations given on
-22 Page 2 of the observations are self-explanatory.
23 Most people -- any unenlightened person, who is not 24 familiar with BCAP, could ~ read the procedure, read the 25 reasons given on Page 2 and immediately be able to -
( j
< Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134
( 312) ' 232-0262
r -
14038 n-
)
1 figure out which category it belonged in.
2 (Indicating.)
3 Q I see.
4 But, in any event, for purposes of displaying the 5 data, this was your work?
6 A (WITNESS ORLO7) This is solely my work.
7 Q All right, sir.
8 Let's look at a couple of these categories here.
9 Now, take "in accordance with design." Are there 10 instances there of CSR inspector errors?
11 In other words, going to the field, reaching an l' i' 12 inspection conclusion which was at variance with the
'w_/
13 inspection attributes, and, therefore, determined to be 14 invalid on the basis that the actual field condition was 15 in accordance with design?
16 A _ (WITNESS ORLO7) We -- the answer to that is I wouldn' t 17 call it an error.
18 We encouraged our inspectors throughout the program 19 .tx) be conserva tive. If there was any doubt in their 20 minds, we encouraged them to write the observation.
21 In some cases, where there was any doubt, th e 22 inspector would write the observation, the engineer 23 would evaluate it -- the engineers worked closely with 24 'the inspectors -- come up with a reason for invalidity.
(d I 25 For e xample, a note on a detail drawir.g that the Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262 f
14039 p--
( )
ss 1 inspector may not have had or there was a note --
2 usually an inspection package for some of these 3 consisted of 10 or 15 drawings. It was an obscure note, 4 relaxing tolerances, in some cases, or providing for 5 alternate details.
6 A CSR inspector, being conservative, would have 7 said, "It doesn't exactly match my drawing"; wouldn't 6 have gone to look at the note; would have performed a 9 conservative inspection; would have written up the 10 observation; the observation would have been evaluated 11 by the engineer; and together the engineer and the
[ ') 12 inspector would have determined it was invalid based on -
LJ the note in the drawings.
13 14 So to characterize it, no, I wouldn' t call it an 15 inspector error. I would call it an overly-conse rva tive 16 inspection by the CSR inspectors; and they were 17 encouraged at all times to be overly conservative.
18 0 Well, sir, if there was a detail that specified that the 19 field condition was, indeed, acceptable and that detail 20 was simply overlooked by the CSR inspector, you would 21 agree with me, wouldn' t you, that that would represent 22 an instance of a CSR inspector error?
23 A (WITtiESS ORLOV) I would say it's a conservative error,
,_ 24 yes. They rej ected something where they probably should
( } 25 have accepted it, should have accepted it.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
.c, -
14040-
.f~h -
Ei 1-
'V- ,
1 'O Well, th ey m ay or m ay no t h ave caugh t -- htni 'h ad th e -
t.
2 perception that they were erring in a conservative 4 3 direction.
4 If they. were simply unaware. that the detail either 5 existed or was applicable to the condition they observed
~
6- in the field, it might turn out to be a -conservative ~
r es ul t, but would still represent inspector error, would 7
18 it not?
9 A (WITNESS ORLOI) The way you categorzie inspector error, 10 . yes.
11 I wouldn't categorize it as inspector error; and 12 the reason -for that is they would look at a- detail. and I{/~h'
\- l 13- they couldn' t err in the opposite. direction under these ;
-14 circumstances; and let me explain to the Board why they
'lSi > couldn ' t. 1 16- In some cases, you would be provided a detail for a L17 - _ particular connection, and in some instances you would 18 be allowed to use alternates for that' detail.
19 In other words, Sargent &' Lundy would provide a 20' given detail for a connection, and the field had some ,-
21 latitude, the crafts people had some latitude, into what -
.22 they had to install.
23' Ift it didn' t fit quite right using the exact detail 24l that was specified, they were allowed by Sargent & Lundy O-iJ 25 drawings to use alternative details.
Sonntag Reporting Service, Ltd.
"'~
Geneva, Illinois 60134
(
(312)- 232-0262 .
1
9, s s-
.14041
(_
1 In'other words, "If you can't put it in this way, 2 rotate it -90 degrees' and put it,in the other way"; and 3 they were , allowed to by' Sargent '& Lundy drawings.
4 In some cases -- and you will see many of these 5 that are in accordance with design -- you see cases 6 where the inspector looked at the detail drawing and 7 said, "What's out there doesn't match this exact detail
-8 drawing," and h'e would have written it up on an 9 obse rva tion.
10 Again, an observation is an apparent:---it's 11 defined in BCAP-06 as an apparent deficiency observed by
-12 .the inspector out in the field f rom -that specified by 13 Sargent &'Lundy drawings. It's not a deficiency.
11 They knew they had a safety net of CSR. engineering, ,
'15 with whom they worked closely, to make sure that they g 16 weren' t erring on -- they weren' t creating . unnecessary 17 observations in the --
-18 -Q Excuse me.
19 Did you - finish your answer, sir?
20 A (WITNESS ORLOV) Go ahead.
l R21 Q Let's take Intervenors' Exhibit 150, the disputed 22- validity determination -- invalidity determination EIN 23- 78-902, the junction box ceiling versus floor mounting l- 4
. 24 question.
'25 A (WITNESS ORLOI) Certainly.
l=
l l Sonntag Reporting Service, Ltd.
! Geneva, Illinois 60134
! (312) 232-0262
14042 N
1 Q Do you recall that one, sir?
-2' A L(WITNESS ORLO7) Yes, I~ recall that'one.
3 Q. ' All; right.
4 Was that an instance where the inspector had 5 available to him' all of the design drawings and -simply 6' reached a conclusion as to the as-built condition that 7 was at variance with the engineering judgment based on 8' the~same information?
9 A (WITNESS 'ORLO7) I would say that -- let me back up .and ,
.10- try to remember the beginning of your question ll. I would say he had enough information, 'yes; and .I
/'D ) 12 can show the Board what he had in his package, if you
-13 . will allow - me to go to the drawing -- to the board.-
~
14 Q Well, really, it's a much more simple guestion.
-15 A (WITNESS OFLO7)- Yes, he had enough information; yes, he 16 had enough information; he clearly had enough
. '17 information.
- 18 Q It represented. a dif ference of opinion between him and
- - 19 the engineer?
I 20 A (WITNESS ORLO7) It was a difference of opinion, ~yes.
r 21' Q And was not a -- well, it was a question of whether or I 22 not the ceiling detail applied to floors, and that's 23 a --
l 2
.4 A (WITNESS ~ ORLO7) Well, I think it's a little bit more 25 obvious than that.
i Sonntaq Reportinq Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14043
( )
~s' 1 If you actually see all the drawings that were in 2 the package, in fact, it should be obvious that what he 3 saw out there was in accordance with the design, because 4 the detail drawing that you were referencing is only 5 half of what he had. It was one specific detail showing 6 one connection.
7 He actually had the plan drawings showing the 8 junction box on the floor with the tube steel 9 connections and he had all that information before him 10 showing how the tube steel was supposed to be mounted on 11 the floor.
(' 12 Well, I assume --
') Q 13 A (WITNESS ORLO/) Excuse me.
14 However, to show one connection in greater detail, 15 you had to see a section of it.
16 Now, that one little section for the one connection 17 of the tube steel on the floor to the tube steel going 18 vertically up from that floor, Sargent & Lundy, in that 19 section -- and that section was specified as to exact 20 detail and drawing number that was specified -- if you 21 go to that small section, it will show a connection 22 showing tube steel welded to an imbed plate and it will 23 show the details for welding that; and in that 24 par ticular small detail, you will see a little note on (J)
\
25 the -- on the line that shows that -- where the imbed Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
d d
14044 7
f 1-A.j-is,' the , interface, concrete, -it takes off to. the right i
2 of the cciling.
3 As f ar as I'm concerned -- and all the engineers 4 that _I talked to about that one -- that ceiling is only .
5 a typical note saying ~ that that's an imbed in a concrete -
6 wall. . It's not a beam hanging in ' the ceiling.
-7 L So the inspector, I'believe, and all of our 8- inspectors agree, had sufficient information to-9 adequa tely make" a j udgment on that; but in this.- case,'
10 'there was one little question, an ambiguity in his mind, I 11 and:h'e correctly wrote that down, and the' engineers 12 correctly said that that was not a problem. . What was
}
13 out there was in accordance 'with the Sargent & ~ Lundy 14 'specified design. He had the right to do that.-
15- (Indica ting. )
- 16 He had the right --- we wanted him to bring up
-17 ambigui ties. We also wanted our engineers -- you asked l 18 a question.- You are trying to go one way .and I'm 19 not --
20 -Q No. Please finish your L answer, Mr. Orlov.
. 21 A (WITNESS ORLOV) Okay.
22 0 If you would listen to the question, please.-
23 JUDGE GROSSMAN: Yes, Mr. Orlov. I think it
,s '24 - was a lot simplier question than the answer.
,l I: 25 Just answer the questions.
4
. \_/ .
Sonntaq Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14045 i
?
-x.-
1 A (WITNESS ORLOV) Well, I wanted to clear up any innuendo 2 that might have been implied.
3 JUDGE GROSSMAN: Whether there was any 4 innuendo is for the attorneys to decide, and they'll 5 clear it u'.
6 A (WITNESS ORLO/) I'm sorry, Judge G rossman. I 7 apologiz e.
8 JUDG E G ROSSMAN: The witness just answers the 9 question.
10 BY MR. GUILD:
11 Q Was this an example of inspector error? By "this," I
-[ ]
J 12 mean EIN 078-902?
13 A (WITNESS ORLO/) No. I think the inspector was right to 14 bring that to our attention.
15 Q All right sir.
16 A (WITNESS ORLOI) I think it was within his prerogative.
17 When you have something that an inspector finds 18 perhaps at variance with what the engineer might have 19 wanted to be specified, he should bring it to the 20 engineer's attention because, after all, the inspector 21 is just the eyes of the engineer.
22 Q All right, sir.
23 You don' t really need to repeat yourself again.
24 The record is clear on your explanation, Mr. Orlov.
l (v ) 25 A (WITNESS ORLO/) Certainly.
Sonntag Repor ting Se rvi ce, Ltd.
Geneva, Illinois 60134 (312) 232-0262
c 14046 m
1 'Q~~ Well, the documents that are available to me are
-2; presumably the documents that were available to you when 13 you formed this committee to review the propriety of 4 this. invalidity determination?
5 A (WITNESS ORLOV) Yes.
'6 -Q All right.
.7 And the documents available to me include the 8 document that states ceiling with respect to' the detail ;
9 referenced in the specification.
10 A' (WITNESS OPLOV) Right; but --
11 Q Now, with reference -- with respect to your
( 12 categorization of in accordance with design as a basis
. 13 for invalidity, does that include- the observations that 14 were invalidated on the -basis of ECN 24544?
15 A (WITNESS ORLO/) Yes; and we had provided you that list 16 of 16 cable pan hangers which were invalidated based on is 17 that ECN. Yes, they were invalidated to that ECN.
18 -Q' All right, si r.
- 19' Now, this is the tolera 'ce ECN? You referred to it ;
. 20 as a tolerance ECN? .
21 A (WITNESS ORLO/) IL's the ECN 24 -- or 24544 which, I
- 22 beli eve, provides construction tolerances where there 23 were no tolerances previously.
24 .Q' 'Okay. You were helpful to explain this to me.
R
- 25 This drawing, this little point, much of this is a
[
' Sonntaq Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14047 i
~. J 1 foreign language to me.
2 You were helpful enough to explain this to me last 3 night, and perhaps I could ask you to explain parts of 4 it now for the Board and parties.
5 As I understand it, there is a plate at the top of 6 the vertical member on a cable pan hanger, this 7 particular hanger ?
8 A (WITNESS ORLO7) Yes.
9 Q It's called a gusset plate?
10 A (WITNESS ORLO7) Yes.
11 Q And it's used to weld the hanger to the structural
(, - '; 12 member overhead?
-\ .)
13 A (WITNESS ORLOV) Correct.
14 0 All righ t.
15 And I believe you characterized it for me last 16 night.
17 You have a vertical -- in the vertical is a piece 18 of Unistruc?
19 A (WITNESS ORLOV) Strut material, yes.
20' Q Strut material.
21 You wanted to have a greater area for the weldment 22 from the hanger to .a structural member greater than 23 simply the perimeter of the Unistrut?
,_s 24 A (WITNESS ORLOV) I believe that was the basis of the
/ 's (x._ J ) 25 design of that type of connection, yes.
Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
e . ,
14048 i- w
{Q
- \- '
,1 - .Q. So you specified a _ gusset : plateL to allow for a greater
- 2. ~ weld length; correct?
3 A (WITNESS ORLOV) Yes; simplistically, yes.
4 Q Well, I'm going to be simple _ about it.
5 If I'm being inaccurate about:it, tell me -- all-6 right -- but 'I'm trying to simplify this.
7 A (NITNESS ORLOV) Okay.
8 Q All righ t, -sir.
~
9 So the size of the gusset plate, that was something 10 that was an inspection attribute under CSR?
11 A (WITNESS ORLOV) Yes.
. m
-12 Q_ All right.
13 And as I understand it,- the - specification of the ,
14 gusset plate wasithe gusset plate was five -inches _ long?
15 A (WITNESS ORLO7)' Correct, five inches long.
16 Q And CSR inspectors -went to the field and found gusset 17 . plates that were at variance with . that. five-inch
-18 s pecifica tion ?
19' A (WITNESS ORLO7) I believe the number you would find 20 that our inspectors wrote up, for the most part, for 21 that observation is 4-7/8 inches long, yes.
22_ Q' All riglJ.
23' They wrote them up when they were at variance in
, 24 some degree with the five-inch specification?
1 / s (I\} 25- A (WITNESS ORLOI) Correct.
Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14049
. :\v(
1 .0 All right.
-2 Af ter BCAP was -- af ter BCAP commenced, af ter the 3' June 30, '84, cutoff date for the BCAP, population, ECN 4 255'-- 24544 was issued, effective March 22, 1985, 5 relaxing. the tolerances for, among other things, this 6 gusset plate?
7- A (WITNESS ORLO7) Well, do you want me to correct'you o
- j. 8 -where you were wrong?-
i .. 9 Q Yes, please.
10 A (WITNESS ORLO7), It provided tolerances where 'there were 11 no tolerances. It didn' t r elax tolerances, 12 . It provided a clarification to the -- providing j.-
i [~'}i:
\_s tolerances where there were no tolerances at all.
- '14 Q ; All right, sir.
15 A (WITNESS ORLO7) That's a little more specific.
, -- 16 Q Tha t's helpf ul.
17 And f or the -five-inch dimension of the gusset
,- 18 plate, the ECH provided that that dimension may vary by
- 19 plus two inches or minus four inches -- I'm sorry --
20 minus one-fourth --
l
~
21 A (WITNESS ORLO/) Yes.
22- Q -- one-four th of an inch ?
23 A (WITNESS ORLO7) One- four th , right, yes, minus a-i L24 q ua r te r.
j- s
.25 0- All right.
i' Sonntag Reporting Service, Ltd.
i' Geneva, Illinois 60134
.(312) 232-0262
14050 L) 1 Th a t ' s , as you explained to me, because since the 2 purpose of the gusset plate is to reinforce or make --
3 provide -- provide for a longer weld to support the 4 hanger, the critical tolerance was in the direction of 5 insuring that it was of sufficient size, sufficient 6 length, the gusset plate, so it was okay if .it was as 7 much as two inches longer; correct?
8 A (WITNESS ORLO/) Correct.
9 Q But the tolerance in the other direction was one-quarter 10 inch ? It had to be at least 4-3/4 inches?
11 A (WITNESS ORLOV) Correct.
[-
J
- 12 Q All right.
13 Now, as I understand it, despite the fact that 14 these gusset plates were subject to L. K. Comstoc k's 15 prior quality control acceptance, there were undersized 16 gusset plates identified?
17 A (WITNESS ORLO7) Well, by an eighth-inch, yes.
18 Q All right.
19 You checked the Comstock acceptance criteria and 20 found tha t, at the time that they were QC accepted, 21 there was no specification of a tolerance that said five 22 inches?
23 A (WITNESS ORLOV) No.
24 0 Why don't you correct me, then ?
p_ ,
! ) 25 A (WITNESS ORLO/) I didn't check it.
L ./
Sonntag Repor ting Se rvice, Ltd.
G eneva, Illinois 60134
[
(312) 232-0262
14051-
~
p--
-1 Q. fYoutdidn't check it?
~2 .A (WITNESS ORLO7). I di'dn' t check it, no.
- 3. Q 'You assumed somebody else checked it?
'4 You related to me it was checked, an'd I assumed ,
5 that you did.
6 A (WITNESS ORLO7) No, I don' t believe I said that.
7 .I' said we didn't check Comstock's inspection --
8 their procedure. I said I didn' t know.
9 O I see.
10 A (WITNESS ORLO7) I said there very well may have been 11 inspection tolerances for Comstock. I wasn't aware of
.(O: 12-any, any ch eck.
13 0 I see.
!- - - 14 I thought you told me--that you assumed that there
!- 15' was a -- I'm going to use a word ~ you probably 'didn' t
[
16: use -- a custom or a ~ customary application of reasonable 17 tolerances or --
E'
~
18 -A (WITNESS ORLO7) I- think I told'you' yesterday that when
! 19 measuring a five-inch dimension, we don't take out 20 either a micrometer or a laser infraometer and measure. '
i 21 to the nearest thousandth of an inch.
l22 Q_ You said that.
- 23E A- (WITNESS ORLO7) We take a standard six-inch ruler and l
- 24 we hold it up to this, and if it looks reasonably close 0
I . ^d )
i 25 to five inches, whatever that tolerance is -- I know it L
Sonntag ReDor ting Se rvice, Ltd.
p Geneva, Illinois 60134
- (312) 232-0252
14052 i 1
! /
x ,-
1 isn' t in thousands of an inch. It may be aa eighth of 2 an inch. That's what usually six-inch rulers are 3 divided down into. B ut tha t's it.
4 And if I was an inspector -- I assume that they had 5 some implicit tolerance in their inspection activities.
6 They obviously had to have some, because their tools 7 weren't micrometers.
8 0 All righ t, sir.
9 That's probably what you said, then --
10 A (WITNESS ORLOV) Right.
11 0 -- that you assumed Comstock had an implicit tolerance.
/
L ,)
) 12 You didn't, now I understand, check to see whether 13 or not the procedure had a specified tolerance?
14 A (WITNESS ORLOV) Correct.
15 They had measurement tools which weren' t accurate 16_ to a thousandth. They may have been accurate to, for 17 that type of measurement, an eighth.
18 Q All right, sir.
19 In any event, this ECN was written af ter the BCAP 20 program started, and it was written to specify 21 tolerances. Whether the tolerances had existed or not 22 before we don't know.
23 And on the basis of the ECN specifying, as we just 24 described, f or example, the gusset plate dimensions, f._ ,
observations for unacceptable dimensions on the gusset (v) 25 Sonntag Repor ting Service, Ltd.
Gencva, Illinois 60134 (312) 232-0262
14053 l -'
(
q] __
1 plate were invalidated on the basis that' they were now-2 in accordance with- design- per- the ECN ?
~
3' 'A (WITNESS ORLOV) Unacceptable is your word; ' but,' yes, : we .
4 invalidated those 16 instances in which' cable pan hanger 5 configuration was at perhaps variance to the exact -
~
6- dimension-as shown on the drawings, but was in 7 accordance with the tolerances which Sargent & Lundy 8 applied to all cable pan hanger connections via that -
- 9. generic-ECN.
10 Q I see. A11E righ t, sir.
~11 A -(WITNESS ORLOV) And, again, the1 tolerances -- the
['%./'}'
12 discrepancies we found in. those 16 cable pan hanger _
13 configuration observations were all in the order of an 14 eighth or a sixteenth of an inch undersized for a
.15- five-inch plate.
16 Q All right, sir.
17 Now, I understand there were also, fot - example, 18 some cable observations invalidated on the grounds that 19 while _ there were typically a four' digit segregation
- 20 code, the last two digits- of the _ segregation code were
-21 represented in addition by the color of the' segregation 22 code label; say, for example, green or brown?-
l 23 A (WITNESS ORLO7) They were actual -- actually colored, 24 depending on which division.
C'
, S[V }25- Q. Okay, okay.
d Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
. -, . . . . . - . - - . - - - . - - -.- . - ..~... - - . - - - - - - - .--
14054 i )
\,_,/
1 And tha t -- and tha t, in effect, those were 2 redundant segregation identifying features?
3 The absence of one or more of the last two digits 4 or correct last two digits was the basis for 5 observations.
6 This were invalidated on the grounds that, given 7 the color coding, the segregation codes in question were 8 still in accordance with design requirements?
9 A (WITNESS ORLO7) Yes, to -- let me clarify that a little 10 bi t --
11 Q Sure.
/ ) 12 A (WITNESS ORLOV) -- for you.
\_,/
13 That was really an error in -- on the part of the 14 ;SR engineers.
15 Now, I will define what I mean by error.
16 We looked at the engineering drawings for -- for 17 cable -- the requirements for cable segregation code 18 labels, and we saw that the segregation code consisted 19 of four letters. Typically it would be 1C2E or whatever 20 defining power, instrument or pole, divisional number, 21 and lE or 2 E, safety related or non-safety related --
22 correct me if I'm wrong -- and we had interpreted the 23 drawing to say you need all four symbols.
,s 24 Unfortunately, that's the way we wrote our initial i l' \
( ,/ 25 checklist; and our inspectors went out there, and in Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14055 i I
)
1 accordance with that checklist, identified a number of 2 seg code labels that were affixed to conduits and 3 junction boxes where there were only two letters and a 4 color, two symbols and a color. We had all sorts of 5 observations written this way.
6 We went back to the S & L design drawings to where 7 we had originally gotten this criteria and we noticed 8 there's an alternate way of doing it. You have a 9 choice. You can either use the four symbols or, as an 10 alternate, you can use two symbols and a color. Eith er 11 way is acceptable.
, - . ~
( ') 12 But when we wrote our -- our initial checklist, we
'J 13 wanted one of the two alterna tives.
14 Well, since Comstock had put them up either way --
15 o bv iou sly, in some cases, they would have put them up 16 with just the alternate method, the two letters and the 17 color -- we in CSR generated a number -- and I think the 18 number is documented in there -- a number of 19 observations identifying a condition in which the 20 installed seg code label was two letters and a color.
21- That was in accordance with design. It had always 22 been in accordance with design.
23 We went back, we changed our checklist, we made it 24 in accordance with the design requirements, we relaxed (J) 25 our criteria to what the design requirements were, and Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14056 i
-.j 1 then we proceeded to invalidate all these observations 2 written on that subj ect because they truly were invalid.
3 (Indica tion.)
4 Am I making myself clear?
5 Q Let me see if I am clear on the second category, in 6 accordance with design -- the first category, rather.
7 As I understand the process -- and any member of 8 the panel should chime in, please, if you can.
9 As I understand the process for CSR, the CSR 10 inspection attributes were, by design, to be reflective 11 of the approved design for the item in question. You
-~,
12 went out and wrote the attributes to reflect design
[V') 13 acceptability; is that correct?
14 A (WITNESS ORLO7) Yes, with certain caveats that are 15 identified in the cover letters.
16 Q In what are now identified in -- I missed the last word.
17 A (WITNESS ORLOV) Our attributes were developed in 18 accordance with the design drawings and specifications 19 with certain exceptions where we may have used alternate 20 criteria or relaxed criteria, and each of those 21 cases -- and there were very f ew -- each of those cases 22 are documented in the cover letters to the checklist 23 which I think were made an exhibit.
24 0 Understood, understood. All right, sir.
/ \
( ) 25 A (WITNESS ORLOV) S o --
N..)
~
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
r -
14057
- rf
'i
\,,;5 ~
l Q So it _ seems- to me -tha t, then, _the observations that were
.2 invalidated _on'the grounds of in accordance with design 3 must f all into one of two categories.
4- They are either a CSR inspector error, which isf .
5 then corrected because the reviewers, the engineers and -
-6 the Task Force, say, "No, you are-wrong. - That condition 7 in -the field that you observed is, in fact, in-R accordance with design. " That's Case.l.
3 Or alternately Case 2, you failed, in writing the 10 } CSR _ checklists, to' effectively specify the design 11 r equirements and, therefore, the- inspector went to the-12 field, found what he found, found it roj ectable in
[ )'h 13 accordance with the criteria given him, but af ter the 14 fact.the Task Force or' Task Force engineers determined 15 that they inappropriately specified the acceptance'
'16 criteria and that.the item was in accordance with 17 de sign ?
18 A- ( WITN ESS -_ ORLO7) You are right in both ~ cases. -We -
19 overcriticized, overinspected and overengineered, you 12 0 are right.
21 (In di ca ting . )
22 JUDG E GROSSMAN: W ell, Mr. Orlov, please j ust-
, 23 answer the questions without any editorial comment on 24- them.
^
25 h (WITNESS ORLO7) Yes, sir.
~
Sonntag Reporting Se rvice, Ltd.
G enev.a, - Illinois 60134-(312) 232-0262
14058
.J' 1 MR. GUILD: Mr. Chairman, I think that 2 counsel --
3 J UDG E G ROSSMAN : We'll take a break now.
4 MR. GUILD: It's time for a break.
5 JUDG E GROSSMAN: Right. We'll take 10 6 min utes.
7 (Whereupon, a recess was had, af ter which 8 the hearing was resumed, as follows:)
9 JUDG E GROSSMAN: Ready, Mr. Guild?
10 MR. GUILD: Yes, si r, Mr. Chairman.
11 BY.MR. GUILD:
/m
\ 12 Q Mr. Sh evlin, in your --
L.-] 13 JUDG E GROSSMAN: Oh, excuse me.
14 BY MR. GUILD:
15 0 -- discussions yesterday --
16 JUDGE GROSSMAN: I'm sorry to interrupt you, 17 Mr. Guild.
18 You gave him a question with two possibilities.
19 But when did S & L change the design requirements 20 for the items we were discussing with that ECN?
21 A (NITNESS ORLOV) The ECN, I believe, was issued in March 22 of 1985.
23 The ECN that provided the construction tolerances; 24 is tha t th e ECN ?
~
i
( ) 25 MR. GUILD: Yes.
N/
Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134
14059-
. ,.g .
( }
.v- >
1 A (WITNESS ORLOV) March of 1985.- ,
2 JUDGE GROSSMAN:- And was this ECN written 3 ,
'with regard to the BCAP program?
4- A (WITNESS ORLO7) It '.'as a general' design document that 5 -applied generically to all cable pan. hanger connections 6 using that type of detail, which is many.
7- I don' t -- I'm -- I don't believe it' was written --
8 it was not written j ust , f or BCAP, 'no. - It was --
- 9. JUDGE GROSSMAN: I see.
- 10' But the issue was precipitated by the~ BCAP
_11 inspection, wasn't it?
[ 12: A (WITNESS ORLO7) I don't know that. In fact, I never
- V} 13 heard - tha t. I couldn' t answer that.
14 You have to ask Sargent & Lundy.
15 JUDGE GROSSMAN: Does anyone else on the
~
. 16- panel have this information with regard to that?-
17 A' (WITNESS WOZNIAK) No, si r.
'18 A (WITNESS SHEV LIN) No.
19- A (WITNESS SMITH) No.
20 A- (WITNESS KAUSH AL) No, your Honor.
21- JUDGE GROSSMAN: Well, you had two t
22 possibilities -- oh, I'm norry.
- 23 Mr. Smith.
24 A (WITNESS SMITH) While I don't have specific information
_ %.)
) 25 rela tive to that activity, the subject AIR-009 that we
-Sonntag Reporting Service, Ltd.
r Geneva, Illinois 60134 (312) '232-0262
14060 m i
'j 1 talked about the other day, you know, when we talked 2 about whether the appropriate design documents were 3 applicable and when they were not applicable --
4 JUDG E G ROSSMAN: Yes.
5 A (WITNESS SMITH) -- it was this type of subject that 6 precipitated that AIR; and basically what we agreed upon 7 was if Sargent & Lundy issued a design document that was 8 applicable to everything -- not just the BCAP activity, 9 but it had to be applicable to all construction on site, 10 you know, of that class of -- of equipment, then BCAP 11 could use that document.
12 Otherwise, if Sargent & Lundy issued a design
-[('~*),
13 document prior to the sample selection, BCAP could use 14 it.
15 If they issued a design document af ter the sample 16 was selected, then we would not allow them to use it as 17 an invalidation -- as a reason to invalidate something, 18 even if there was no connection.
19 I mean, we just said, "Once the sample is known, 20 you cannot use documents anymore. The only reason" --
21 "the only time you can use a document af ter the sample 22 is known is if it's generic and applies to the whole 23 class of equipment. "
24 (Indica ting . )
CN JUDG E GROSSMAN: Well, apparently this ECN,
( ) 25 Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
$ (
14061-J_,
J 1 then, in March of 1985 was generic --
z 2L A' !(WITNESS SMITH) It was generic.
3' JUDGE GROSSHAN: -- because it was' adopted 4 af ter the sample had been selected -- the samples?
-5. A' (WITNESS SMITH) - Wh11, I assume it was after the sample -
6; was selected.
7~ J UDG E G ROSSMAN : W ell, so:there's a third 2 -
8 possibility other than if there was an error, the third 9 . possibility being in addition to an error by the .
1 10 -inspector or_ an error by someone determining . the design 11 r eq ui rem ents, the engineers -- the third possibility
/ 12 1 w} 13-b ing a subsequent change by _ Sargent & Lundy, which is what happened in this case; isn' t that ' correct, Mr.
- 14 O rlov ?
15 A (WITNESS' ORLO7) Yes,-your Honor, in -- in general, that' 16 would be correct.
4 l'7 This is one of the only- cases where 1. aov that we 18- used a design criteria that came out after the sample 19 ' selection that we used, and our basis for using 'it,
. 20 really, was not that it so much changed the design, but,
~21' rather, it provided a tolerance. that previously wasn' t
. 22 there, and that was the -basis for using that specific i'
23 one; and I believe that's -- that probably is the only 24- case -- a t least that's the only case I'm aware of now gs -
(x_/ ) 25 where we used a later generic design af ter our sample Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 '
(312)- 232-0262 -
)
i 14062-g' C=
V 1 was selected, after our inspections ~ may have. started 2' where we relied on :a later design.
3- JUDGE GROSSMAN: Okay.
4 And this applied to 15 items?
, 5: A (WITNESS ORLOV) It applied to 16. of our cable - pan ,
~6- hangers.-
.7 But the ECN in general, when it was written, was 8 written . by .Sargent & - Lundy to apply to all cable 9 hangers. ,
l'0 JUDG E GROSSMAN: Well, I understand that.
11: -But it applied to 16 items in your sample?
'A'
~
12 -(WITNESS ORLW) Yes,-sir, yes, your Honor.
. \s/ 13 JUDGE COLE: This is the change that just 14 added tolerances; is that correct?
15 A (WITNESS ORLOV) Provided correction - tolerances.
16 .- JUDG E COLE: Do you really consider.that a 17 major change?
18 A (WITNESS ORLO7) The reason we used it is because we 19: didn't- believe it was necessarily a change, but, rather, 120- a clarification, and that was the basis for using a
'21 later design.
It wasn' t really a change in design. It was a 23 cla rifica tion. That was our opinion at the time, and 24 that's why we used it.
- g 25 JUDGE COLE
- All right, sir.
-%() .
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
E 14063 1 Thank you.
2 JUDG E GROSSMAN: Mr. Guild.
3 BY MR. GUILD:
4 Q Mr. Shevlin, I return to you, sir.
5 You were asked by counsel and ' the Chairman about --
6 to evaluate the implications of Intervenors' Exhibit 7 145, the rates of discrepancies found by BCAP CSR, the 8 electrical populations -- the implications of those 9 discrepancy rates on work performance of Coa: stock 10 inspectors, 11 Do you recall that line of examination?
12 A (WITNESS SH D/LIN) Yes, sir.
')
13 Q And in response, you cited Juran, J- U- R- A- N, on quality 14 control for the proposition that an 80-percent accuracy 15 rate for Quality Control Inspectors was all that you 16 e xpected.
17 A (WITNESS SHEVLIN) That's generally what's expected, 18' yes, sir.
19 Q All right, sir.
20 I take it, then, that that's all you expected, an 21 80-percent accuracy rate, for your CSR inspectors?
22 A (WITNESS SHD/ LIN) With some qualification to that 23 statement, Mr. G uild.
24 0 Well, why don' t you make whatever qualification needs to
- x
) 25 be made to understand what exactly the standard was that
(
Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
2 14064
'r i /
Af 1- you did expect of ' the CSR inspectors.
2 A (WITNESS SHE7LIN) 'Juran, in _ arriving at that 80 ,
'3 per cen t, penalizes the inspector or takes away from his 24~ accuracy for rejecting good product.
5 - In CS R, we did not do tha t. An inspector who
-6 rej ected a good product was not penalized.
'~7- _Therefore, a much higher ~ accuracy rate was -- it 8- was termed in T the CSR a much higher agreement >
9 rate -- between the CSR inspector and those who were 10 overviewing him was expected.
L11 Q All right, sir.
[~'}
%J -
12 That's because if,; citing Juran, you assume that a 13 20-percent inaccuracy rate is acceptable, you are only'
. 14; counting inaccuracy on one side, and that is, failure'to 15 identify rejectable conditions?
16 A (WITNESS SHE7LIN) Yes, sir. -
17 Q You are not counting the proper rejection of acceptable
. 18 ' conditions?
19- A (WITNESS SHE7LIN) Correct, si r.
20 ~Q And if- we just . assume for purposes of argument- that
. 21- those errors occur equally in both directions on either c 22 side of what is deemed to be accurate, the error band 23 f alls on' both sides of accurate, then if you are finding i
24 that. there is an inaccuracy rate of, say, 10 percent in
!I J 25 the falling to identify rejectable conditions, tha t l
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14065
- ) -
1 would imply a total of 20 percent inaccuracy if we went 2 out and looked at the incidents -- or the instances 3 where acceptable items were found rejectable?
4 A (WITNESS SHE7LIN) Would you run that one by again?
5 Q- If the errors are distributed equally on either side of 6 accurate, you only counted half of them.
7 If you counted the other half, in effect, you would 8 find twice as high a rate of inaccurate inspections?
9 MR. STEPTOE: I object to the form of the 10 question.
11 A (WITNESS SHE7LIN) I'm not sure I can agree with that.
( 12 MR. STEPTOE: I think it's unclea r.
s ,,-
13 Perhaps he could ask the witness whether he agrees 14 with the assumption, whatever that assumption is, th a t ' s 15 in that question.
16 MR. GUILD: I think it's perfectly apparent.
17 I'll be happy to rephrase it a third time; but I 18 really don t want to lose the point of the question, 19 whe ther Mr. Steptoe wants the question answered the way 20 the question was asked or not.
21 MR. STEPTOE: I don't understand what errors 22 distributed equally on either side of accurate means.
23 JUDGE GROSSMAN: Well, I assume that means --
24 I'm not sure I'll phrase it any more eloquently -- that
( ) 25 half of them are on the side of rejecting acceptable and Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14066 t i m;;
1 the other half are on the side of accepting 2 rej ectable --
3 MR. GUILD: Do you follow that --
4 JUDGE GROSSMAN: -- but I don't know.
5 MR. GUILD: -- Mr. Shevlin? 4 6 JUDGE GROSSMAN: I'm not purporting to say 7 that it makes sense in the context; but these are 8 experts and we'll let them -- you have an expert on 9 Juran, so we can let him answer the question.
10 A (WITNESS SHEVLIN) I'm not claiming to be an expert on 11 Juran, your Honor.
/ T 12 BY MR. GUILD:
\ !
13 Q You only count half of the errors, and they were on one 14 side of the possible sources of inspector error?
15 -A (WITNESS SHEVLIN) I don't think -- I don't think I'm 16 necessarily prepared to agree with that, that it would 17 be proportionately -- that all errors would necessarily 18 be propor tionately divided in half, one side being 19 rej ecting good product and the other side being 20 accepting bad product.
21 Q Sir, we j ust don' t know.
22 A (WITNESS SHDTLIN) Tha t's correct.
23 Q But I'm asking you if you assume that is correct, 24 tha t --
/^N (R./ ) 25 A (WITNESS SHEILIN) No, I don't.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14067
)
v 1 I think that there would probably be a tendency --
2 a greater tendency to rej ect good product than there 3 would be to accept bad product.
4 Q All right, sir.
5 You agree with me, though, that there is some 6 unidentified rate of inaccuracy on the other side that 7 you have not counted?
8 A (WITNESS SH EVLIN) Yes, si r.
9 0- All right.
10 And in order to measure the total rate of accuracy, 11 or inaccuracy, on the other hand, you would have to know
('^
Nj
) 12 the instances in which an inspector -- a CSR inspector 13 in our case -- erred on the other side, erred by 14 rej ecting acceptable conditions?
15 A (WITNESS SH EVLIN) In order to get a true measurement of 16 an inspector's accuracy, yes, sir, you would need that.
17 Q In order to compare to the 80-20 relationship that you 18 cite in Juran?
19 A (WITNESS SHEVLIN) Yes.
20 Q Now, the other problem is that Juran, as he uses those 21 n umbe rs, presumes tha t you know wha t is accurate --
22 A (WITNESS SHEV LIN) Correct.
23 0 -- you have a standard to compare to?
p_
24 A (WITNESS SHEVLIN) That's exactly correct.
t, 25 0 All right.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14068 M
~
V 1 Well, in the' case of comparing the CSR inspector 2 re sul ta - to, in effect, the Comstock results, to'the 3: extent that -that's what you have .as the basis for 4 . measurement, -you;are not comparing the rate of accuracy 5 of. either inspector . to a set of known accurate
.6 conditions, are you? ,
7 A (WITNESS SHEVLIH) No, sir.
8- That's why I implied some reluctance to use a chart 9 or a set of data displayed in that fashion in order to 10 try and measure .the effectiveness of an inspector..
11 Q Well, that's another reason,- but that's not a_ reason you -
12 mentioned when you responded to your lawyer's question.
13 Another reason is that this . data, the CSR data, is 14 not with reference to a standard of accuracy, but it is 15 comparing two inspections of an item or a population of -
16 items, 'a sample of items; isn' t that correct?
17 'A (WITNESS SHE7LIN) Yes, si r, it's actually comparing a
~ 18 . rate of agreement between two different inspectors.
l 19 Q A rate of agreement. All right, si r.
20- Now, you know, there are some subj ects in school 21 that I did less well in -- and I won't tell you which 22 i ones those were -- but let's assume I'm taking a test in 23 school. and let's assume it's an objective test, so it's
'24 not an essay or something like that, but there are right t 25 and wrong answers to the questions, and there's a key --
Sonntag Reporting Service, Ltd.
Geneva, . Illinois 60134 (312) 232-0262
k l 1
14069 n
_i )
\ _ /.
.1' Lthe teacher: bas a key and known what the right or wrong 2' answers are. Some body of wise people decided, like law 3- school admission tests or something like that, what the 4 right' answers-were; and let's 'say -that 'instead of
.5 comparing my test ' score to the right answer, I compared 6- my test score to the fellow who is sitting next to me.
7_ . Now, there we would simply be computing or i
8 measuring the agreement rate between my ability to 9 answer those objective test questions, my score, if you 1
10~ will, and my friend's score-sitting next to me.
11 Do you f ollow me tha t fa r ?
[ 12 A (WITNESS SHE7LIN) Yes, sir, I follow you.
13 What does that agreement rate, the rate at which my Q-14 answers match up with the answers of the guy sitting >
15 next to me, have to say about either my- accuracy level 16 on that test or my friend's accuracy level, if'anything?
17 A (WITNESS SH E7LIN) Without. f urther assumptions, it says 18 nothing.
19 Q. All right, si r.
20 In order to determine the accuracy of my test or-my 21 f riend's test, we have - to compare it to the known 22- obj ectively correct answers, do we not?
23 A (WITNESS SHEVLIN) Yes, sir.
'24 Q Now, Mr. Juran uses his 80-20 figure.
And do you know wha t his source was, Mr. Ch evlin,
( )25
!~ Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312); 232-0262
14070 l \
t v
/
1 for the use of the figure 80 percent for accuracy as 2 we've just been discussing?
3 A (WITNESS SH EVLIN) Well, as I understand it, Mr.
4 Juran -- it's a -- it's a ratio that's been developed 5 over many, many years across a broad spectrum of 6 industry.
7 (Indica ting . )
8 0 Well, at Page 12-51 under " Inspector Errors," the 9 reference that I got from you, I guess, or from your 10 lawyer, in Juran 3 rd edition, we've got a couple of 11 notes.
12 Note 105 appears by the statement that reads as
(' ' )
13 f ollows : " Collectively these inspector errors result in 14 a performance of about 80 percent accuracy in finding 15 defects. I.e., inspectors find about 80 percent of the 16 defects actually present in the product and miss the 17 remaining 20 per cent. "
18 Now, then there's Footnote 105, and it says, " Note 19 by the editor Juran. " He's citing himself. Quote, 20 " Numerous studies in various countries have yielded the 21 80-20 ratio as a broad measure of quantified inspector 22 accuracy," and he goes on.
23 Do you know whether any of those numerous studies 24 are on the basis -- are based on quality control
/ \
is ) 25 inspections of construction activities in nuclear power v
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
c 14071 F
l
- 1. plants?
2 A (WITNESS SHE7LIN) No, I don't. ,
3 Q Mr. Juran goes on, at Page 12-53, in Footnote 110, 4 fur ther, quote, "While the figures of 80-20 are widely 5 accepted, there are numerous aspects which are not fully 6 researched. I.e., how this ratio changes with percent 7 defective in the product; with type of inspection 8 (Visual, mechanical, gauging, electrical, testing) ;. With 9 product complexity; with amount of time allotted for the 10 inspection, et cetera. For discussion f rom the 11 viewpoint of human factors plus some supporting data,
(]
/
12 e.g. , decreased product complexity results in increased 13 r es ult s. "
14 oc you agree with Mr. Juran in that respect?
15 A (WITNESS SH E7LIN) I agree that there -- that the 16 underlying aspects may not be fully researched; but I 17 have some -- a great deal of personal observation in the 18 construction industry about things that will affect the 19 performance of an inspector.
20 Some of these aspects --
21 Q All right, sir.
22 And you've documented the 80 percent accuracy 23 figure as what you judge as an appropriate measure of 24 Quality Control Inspector accuracy in the business?
( ) 25 A (NITNESS SH E7LIN) I agree with it. I believe my Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14072
~s .
I s._ -
)
1 personal experience supports it.
2 0 Okay.
3 Juran goes on, at Note 111, the same page, 12-53, 4 "There is evidence that some animals can outperform 5 human inspectors. E.g., pigeons were found to be over-6 98 percent accurate in finding defects in diodes and in 7 empty drug capsules. "
8 MR. STEPTOE: Are these harassed pigeons?
9 ( Laugh ter . )
10 MR. GUILD: Obviously not. Well-fed and 11 well-trained pigeons.
O 12 BY MR. GUILD:
%) 13 And that reinforces the point, Mr. Shevlin, that we' re Q
14 dealing with f allible people and humans, and they make 15 errors, probably more errors than animals do if you take 16 Dr. Juran -- or Mr. Juran --
17 A (WITNESS SHEVLIN) Apparently in the case of diodes and 18 pigeons.
19 Q Diodes and pigeons.
20 You don' t think it would be a good idea, Mr.
21 Shevlin, to substitute pigeons for quality control 22 inspectors in nuclear power plants?
23 A (WITNESS SHE7LIN) I'd hate to see it happen.
24 Q All right. I'm not surprised at that answer.
( ) 25 Well, sir, do you agree with what Mr. Juran has to l
N~s' )
Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14073 m
A y;
I say about how these errors happen, the cause of the
- 2 ' errors?'
3 I . direct your attention particularly to-what he 4 characterizes, at 12-56 cf his book, as willf ul 5 inspector errors: Management initiated.
6- There he identifies the following categories or 7 forms of management initiated inspector errors:
8 First, conflicting' management priorities; second, 9 management enforcement of specifications; third, 10 management apathy; and fourth, management fraud..
11 Let me take a couple of them and see if _ you agree
/ 12 w'ith what Mr.- Juran says' on these scores.
Q 13 First, conflicting management priorities. Juran 14 states, 12-57, " Management's priorities for. multiple 15 standards (quality, cost,' delivery, et . ce tera,) vary 16 with the state of the economic cycle. When the state of 17 management priorities ~is such that conformance to 18 quality standards is subordinated to the need for 19 meeting other standards, the inspector's actic.is are 12 0 inevitably af fected since he also is given multiple 21 standards to meet."
22 Do.you agree with Mr. Juran's observation in that
- 23 res pect ?
24 A (WITNESS ~ SHEVLIN) I think, again, with some 25 q ualifi ca tion, Mr. G uild.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134-(312) -232-0262
14074
%.s 1 Q All right, sir.
2 Why don' t you make whatever qualification you need 3 to.
4 A (WITNESS SHEVLIN) Management does have to juggle a 5 number of priorities. Management, obviously, has to be 6- concerned with cost and with schedule and with quality 7 and '
w ith whatever else they have on their mind at the 8 moment.
9 I think there's always a danger that -- or there 10 is -- comething that management should be aware of is to 11 carefully avoid the perception on the part of the
/
') 12 inspector that any of the other priorities should take 13 precedence over quality; but I -- I also don' t find it 14 is unreasonable that quality should be aware that these 15 other priorities exist and have a proper place.
16 Q All right, si r.
17 A (WITNESS SHE7LIN) My experience has been that proper 18 training of the inspectors and especially of the first 19 line of supervision of inspectors can effectively --
20 ef t'ectively negate that as a problem in construction.
21 Q All right, sir.
22 J UDG E G ROSSMAN : Nell, if I understand what 23 Juran is saying there, it is that that factor goes into 24 creating that 20 percent.
/ T
( l 25 In that your understanding of what Juran is saying x,,-
Sonntag Reporting Service, Ltd.
. Geneva, Illinois 60134 (312) 232-0262
14075 7--
"l 1 there?
2 A (WITNESS SHEVLIN) Yes, sir.
3 JUDGE GROSSMAN: Do you agree that that's one 4 of the factors that accounts for that 20 percent or that 5 goes --
6 A (WITNESS SHE7LIN) Yes, sir, absolutely.
7 JUDGE GROSSMAN : Yes. Okay.
8 BY MR. GUILD:
9 Q W ell, to be clea r --
10 A (WITNESS SHE7LIN) Excuse me, sir, 11 Q Sure.
12 A (WITNESS SHE7LIN) I don' t agree, Judge Grossman, that
( }
'~
13 it's -- that it represents a real significant part of 14 the 20 percent.
15 Q Well, of course, it depends on the specific 16 circumstan ce s, does it not?
17 A (WITNESS SHC7LIN) Sure.
18 Q Juran says it depends on, among other things, the stage 19 of the economic cycle, cost pressures on management.
20 A (WITNESS SH E7LIN) Sure.
21 Q So it may or may not be within the 20 percent? It may 22 account for errors that exceed the 20 percent or it may 23 account for a portion of the errors within the 20 24 per cent ?
(%
(xj ) 25 A (WITNESS SHE7LIN) My experience in construction is it's Sonntag Repor ting Se rvice, Ltd.
Genova, Illinois 60134 (312) 232-0262
_ _ = _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _
14076
~
i 1 generally not a big problem, but the potential always 2 exists there for it to become a problem.
3 Q All right.
4 The second identified form of management initiated 5 inspector errors identified by Juran, the same page, 6 management enforcement of specifications, quote, "When 7 managements fails to act on evidence of non-conformances 8 and on causes of defects, the inspectors procerly judge 9 management's real interest in quality from these deeds 10 rather than the propaganda. For example, if the 11 cupervision of the," capitalized, " Material Review Board
[x- 12 consistently accepts a chronic non-conformance condition 13 as fit f or use, the inspectors tend to quit reporting 14 these defects since they will be accepted anyhow. "
15 Do you agree with Mr. Juran's observation about 16 that form of management initiated inspector error?
17 A (NITNESS SHEVLIN) I think if we got out of the nuclear 18 environment, we could probably agree with it; but 19 it's -- it's -- it would be very difficul if not 20 impossibl e, for management to get away with not doing 21 something about reporting non-conformances in a nuclear 22 environment.
23 0 I take it that it would be your -- consistently your 24 opinion that if the Architect-Engineer, Sargent & Lundy,
[_ \
i
) 25 disposed of non-conformance reports consistently of a Sonntag Renor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
- ~ . , -- . ~- - - - . . -
14077 ,
,-ny ,
i ) '
% /-
1 1certain- type by specifying "use as is," 'that the ef fect-2 that- Juran states that I just read would not adversely-3 'af fect inspector performance?
~
4 A. .(WITNESS SHE7 LIN). Well, sir, in the first place, 5 Sargent & Lundy-is not management when we're dealing 6 with-' the contractors' inspectors or-with my inspectors.
7 Q Is that a. meaningful distinction?
8 A (WITNESS: SH EV LIN) He's the' engineer.
9 0 Is that a meaningf ul. distinction, do you think, for:
10 purposes of applying --
11 ~A (WITNESS SH E7LIN) . Ye s , sir, I.do.
12 All right.
0
'~~
13 A (WITNESS SHE7LIN) As an inspector, I don' t work f or 14- Sargent & Lundy.
15 He sets down a specification. I inspect to his
'16 s pe cifica tion. I report a non-conformance and he 17 -
dispositions it as he sees fit and that satisfies me.
18 You obviously read some of this; and -later we get
.19 into willful inspector errors and we talk to rounding 20 off and --
21 Q Some of.it.
22- A (WITNESS SHE7LIN) -- you know, we talked of such things 23 as simply not reporting something because it's more
-- 2 4 hassle than the inspector perceives it to be worth.
25 (Indica ting . )
N.J Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
p- ..
14078 1 I think that's where the "use as is" disposition 2 comes in.
3 0 Okay.
4 A (WITNESS SHE7LIN) And, yes, I think an inspector, in 5 the long run, will, especially in minor defects, you 6 know, simply quit socing those defects if his experience 7 has shown him that they will always be accepted as is; 8 and the problem there is not the inspectors and it's not 9 the inspector management's problem. It's the problem of 10 the specification writer.
11 If he's always going to accept it as is, why not n 12 take that -- that standard out of spec or put that
( )
13 standard into a more realistic perspective.
14 (Indicating.)
15 Q Your experience -- I'm sorry.
16 A (UITNESS SHE7LIN) That does contribute to inspector 17 error, measurements of inspector error.
18 0 Well, in your experience, Mr. Shevlin, might that 19 phenomenon -- tha t is, the recurring "use as is" 20 disposition, " accept as is" disposition -- might that 21 also influence the inspector's judgment on other 22 defective conditions; say, you know, "What the heck.
23 They are just going to write 'use as is' for this one as 24 well . " Therefore, ignore it or miss it?
( ) 25 A (WITNESS SHE7LIN) I -- I -- could you give me an Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
n 14079
,/
1 e xample ?
2 .Q Well, "use as is" dispositions for Attribute A.
3 If I follow your response with respect to Attribute 4 A, in the future the inspector may just fail to see 5 defects on Attribute A.
6 Wouldn' t you expect that the phenomenon of having 7 his inspection decision, in effect, dis counted 8 repeatedly on Attribute A might spill over to Attribute 9 B, C or D? The inspector might consciously or 10 unconsciously fail to be as diligent inspecting the 11 other attributes?
[ j 12 A (WITNESS SHEVLIN) No, sir, I don' t -- I don' t see that i /
13 as being much of a potential.
14 An inspector, espe ci ally, again, in the nuclear 15 area, is rather hardheaded and rather narrow-minded.
16 Q You speak from experience, Mr. Shevlin.
17 A . (WITNESS SHE7LIN) Tha t, too, from experience.
18 No. If -- if the engineer repeatedly accepts as is 19 my report of undercut, it's not going to af fect how I 20 see a crack --
21 Q All righ t, sir.
22 A (WITNESS SHEVLIN) -- if that was your point.
23 Q All right.
24 Is it possible that more particularly in the case
/
( ) 25 of the CSR inspector, the experience of having CSR Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14080-L/
1 . inspectors' observa tions invalidated, f or whatever 2 reason, might cause that CSR inspector to just not see c 3' . .those kinds lof defects or other kinds of defects because 4- ~of 'the signal that .is sent to him about how 5- management -- how management considers inspection 6 results?
'7 A (WITNESS SHEVLIN) No, sir. If anything, the contrary 8 is true, the opposite is true.
9 As Mr. Orlov pointed out earlier, the CSR inspector was encouraged 'to write anything. The least little
' llt thing .he found that he thought to be out of order or he 12- perceived to be out of order, he was encouraged to write 13 up.
14 Q All right.
15 A (WITNESS SHE7LIN) That was compounded by extensive 16 multi-tiered overview, which created pressure on the 17 inspector not to be caught having missed something.
18 In the area of invalida tion --
19 Q Well --
20 A (WITNESS SHEVLIN) -- as I think I brought out in my 21 prefiled testimony, at least in my area of interest,
'22 'the -- the engineer was -- he knew '.'p f ront that we 23 would not accept any form of invalidation without 24 concrete proof, obj ective evidence, that that i 25 observation would -- was, in fact, invalid.
b Sonntaq Reporting Service, Ltd.
Geneva, Illinois 60134 l (312) 232-0262
a -
14081
,a
( }
\_/
(In dica ting . )
1 2 So in every case that we had an invalidation, we 3 were satisfied that the engineer had made a correct 4 decision and we never did contest it.
5 JUDGE GROSSMAN: Well, Mr. G uild, let's see 6 if we can shortcut this.
7 You've read that Juran handbook and this section, 8 Mr. Shevlin.
9 Wouldn't you say that what Mr. Guild is reading now 10 are examples of what goes into what Mr. Juran estimates 11 to be about a 20-percent error for inspectors?
12 A (WITNESS SHEILIN) Yes, your Honor, I would.
\~_/
13 JUDG E G ROSSMAN: Okay.
14 And now aren' t.you saying tha t a n umber of those 15 items wouldn' t apply to a nuclear program in the first 16 place; tha t is, the usual QC inspection program or to 17 the CSR program that we' re discussing right now? Isn't 18 that what you are saying, ba sically ?
19 A (WITNESS SH D/LIN) Yes, your Honor.
20 JUDGE GROSSMAN: Okay.
21 Well, doesn' t that indicate, then, that perhaps 22 tha t 80-20 per cen t -- that dichotomy perhaps should not 23 apply either to the QC program or to the CSR program; 24 that you would expect that the percentage of error would
/ \
be considerably less than 20 percent?
( ) 25 Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14082 p\
(v) 1 A (WITNESS SH E7LIN) No, your Honor, because where it --
2 some of the f actors discussed here are obviously aimed 3 at the production line, manufacturing, that sort of 4 thing. There are other factors that will take their 5 pla ce.
6 It's been my general experience that if an 7 inspector will produce -- consistently, day in and day 8 out, give Epu 80 percent, you got a good man.
9 JUDGE GROSSMAN: W ell, I thought I'd shortcut 10 this, Mr. Shevlin, but I don' t think you are going to 11 have it both ways.
[~)
V 12 Either those factors are going to be present here 13 and would account for an expected 20-percent discrepancy 14 or they are not going to be present and the discrepancy 15 rate ought to be lower.
16 But if-you think you can support both positions, 17 we'll just continue with this.
18 A (WITNESS SHE7LIN) Your Honor, I'm not trying to support 19 bo th po si tion s.
20 I'm j ust trying to make a point that some of the 21 factors cited here certainly enter the picture in 22 nuclear construction, some of them obviously don' t; but 23 there are maybe some other -- some factors considered 24 that are not presented here that also enter it and it fx t I 25 kind of all evens out.
V Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14083 fS GI 1 The basic premise I agree with.
2 BY MR. GUILD:
3 Q Now, one of the explanations that you gave, Mr. Shevlin, 4 and perhaps endorsed or spawned by Dr. Kaushal for th e 5 reason why Intervenors' Exhibit 145, the measurement of 6 discrepancy rates by item, by weld, as opposed to by 7 inspection point, was not a useful measure was that, in 8 effect, it took complex items and treated them the same 9 as less complex items.
10 Did I understand your testimony correctly on that?
11 A (WITNESS SHEILIN) Ye s, yes.
[h 12 Q You have some hangers that are more complex than other 13 hangers in the cable pan hanger area?
14 A (WITNESS SH EVLIN) And, in turn, more opportunities for 15 error, yes.
16 Q And you used this sort of example: You said, "W ell , the 17 fact that in your car a cigarette lighter isn't working 18 is not indicative of the fact that the car is broken";
19 right?
20 A (WITNESS SHEILIN) Yes, sir.
21 Q But you didn' t inspect any cigarette lighters here, did 22 you?
23 1 (WITNESS SHD/LIN) No.
24 0 You went out and inspected potentially design 25 significant attributes?
Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14084
, ~ .
1 A (WITNESS SH E7LIN) Tha t's correct.
2 Q All righ t, sir.
3 And so all of the discrepancies that are reflected 4 on Intervenors' Exhibit 145 all reflect discrepancies to 5 those design or potentially design significant 6 attributes; right?
7 A (UITNESS SHE7LIH) Potentially.
8 Q Okay.
9 And the Comstock inspectors, while they had a set 10 of acceptance criteria that were broader than the CSR 11 criteria because they weren' t j ust looking f or (n)
~.s' 12 potentially design significant discrepancies, th ey were 13 looking for violations of acceptance criteria, period --
14 those Comstock inspectors weren't looking for cigarette 15 lighters either, were they ?
16 A (WITNESS SHEVLIU) No, sir.
17 0 They were only looking for safety related -- for defects 18 in safety-related components, materials or systems?
19 We' re not talking about the ciga rette lighters in any of 20 this discussion, are we --
21 A (WITNESS SH E7LIN) No.
22 0 -- because they are not quality control ins pected ?
23 Now, we talk about the incidence of discrepancies, 24 and that incidence is shown on Intervonors' Exhibit 145, t ) 25 and those reflect, in each instance, the failure of a v
Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
l 14085 fm
(% )\
1 single attribute to meet acceptance criteria; correct?
2 There may be more than one discrepant condition for 3 an item, but the unit of count is a discrepant -- a 4 discrepancy is one attribute that is rej ectable; right, 5 Mr. Sh evlin ?
6 A (WITNESS SHE7LIN) That's an observation.
7 Q Is that a true statement?
8 A (WITNESS SHEV LIN) One item failing to meet the criteria 9 would --
10 Q One attribute f ailing to meet the --
11 A (WITNESS SH E7LIN) One attribute would create --
[C 12 Q A discrepancy ?
13 A -- an obse rva tion.
14 0 Well, a discrepancy. All righ t.
15 Now, I understand that when you take the results of 16 BCAP CSR, you don' t stop at saying if there are, for 17 example, an 86.9 percent discrepancy rate in the 18 population of cable pan hangers, that there will be an 19 86.9 percent discrepancy rate in the entire popula tion 20 of cable pan hangers. You then go on and say, "There 21 will be no design significant defects in the population 22 of cable pan hangers. "
23 Isn' t tha t wha t you say, Dr. Kau sh al ?
l l 24 A (UITNESS KAUSH AL) That's what I said, yes.
/
25 0 And simila rly, if I went through the rect of the
( ( j sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262 i- _ _ _ _ _ . _ . _ . - - - - . _. _ .. _ _ _ . _ . _ . _ _ _ _ .- ___
14086 m
/ \
t !
x/
1 popula tions, you don't simply state that the same 2 incidence of discrepancy rates found in the samples will 3 also be found in the popula tions. You make the judgment 4 that there will be a zero defect rate if you use the 5 definition of design significant defect for each of the 6 populations?
7 A (WITNESS KAUSH AL) Was the question directed to me?
8 Q Yes, sir, Dr. Kau sh al .
9 A (WITNESS KAUSH AL) The statement that there is no 10 design significant discrepancy in that population takes 11 Into account whatever number of discrepancies had been (n\
w]
12 found in that popula tion, and having been evaluated, an 13 assessment has been made that none of them is design 14 significant --
15 Q All right, sir.
16 A (UITNESS KAUSH AL) -- and, therefore, simply for a 17 sta tistical concept, you have an answer that there is no 18 design significant discrepancy in the sample that you 19 inspected, and you can extend that beyond.
20 Q W el l, sir, in fact, you make more than just a 21 sta tistical extension. You make an extension that is 22 founded and necessarily founded on engineering judgment?
23 A (HITNESS KAUSH AL) The engineering judgment actually 24 gives it even further credibility, yes, o
('O 25 Q Well, sir, it is not just f urther credibility. It is an
%t Sonntag Reporting Service, Ltd. l Geneva, Illinois 60134 (312) 232-0262 l
,.- - - .. . ~ . . - - - - - . ._. . .--- . . - - - _ -
l I
l 14087 !
h l
/~'% !
- N ,/
s 4 1 i
1 absolute essential basis for making the leap from 86.9 l i l j 2 percent discrepancy rate in the population of cable pan j t
\
{ 3 hangers or any other population to the assertion that l
! l 4 there are zero design significant defects in the rest of j l 1
! 5 the cable pan hanger population or whatever other ;
l 6 population?
) !
7 A (WITNESS KAUSH AL) It's not a big leap to me, Mr.
l t 4
! 8 G uild. I l
! 9 I t' s -- the result is that, in that population, 3 10 there is no design significant discrepancy.
I 11 0 That's the conclusion that you reach? !
i
[\
\s-12 A (WITNESS KAUSH AL) Well, that is -- that is actually a f I
13 result that, in the sample that has been inspected, !
14 there is no design significant discrepancy. l i
15 0 Yes, sir.
16 A (WITNE3S KAUSH AL) That is a fact. ,
I 17 Q Uell, sir, tha t's a conclusion, j 18 But you are making a generalization f rom the sample i 19 results to the population, are you not?
20 A (WITNESS KAUSH AL) Well, what I said was that in the
{
l 21 sample it's a result. Tha t is a straight, pure, simple I
22 fact -- l 23 0 Well, si r -- !
24 A (WITNESS KAUSH AL) --
that for the sample, there are no b
(s_/ \, 25 design significance discrepancies. :
i I
Sonntaa Reporting Service, Ltd. _
Geneva, Illinois 60134 [
(312) 232-0262 ;
14088
[~'
N--)J l Q Now, I don' t mean to mince words with you unduly, but 2 that f act is not exactly the same f act as that you and I 3 are here in this room and the sky is blue.
4 It's a fact that is a result of a conclusion that 5 is founded on someone's judgment or maybe a lot of 6 pe opl es' j udgm ent, engineering j udgment; correct?
7 A (WITNESS KAUSH AL) I don't understand what you are 8 saying.
9 Q Somebody did a whole lot of pencil whipping of these 10 dis cr epan ci n s, among other things.
11 Cable Pan Hange r 104, somebody had to make some
[V 12 judgments and do some calculations and apply some 13 engineering and logic and reach a conclusion; correct?
14 A (WITNESS KAUSHah) !!r. G uild, what you cre calling 15 judgments, those judgments are no different than doing 16 the initial calculation that is done -- that is the 17 basis of the design.
18 Q It is not a fact in the sense that -- well, all right, 19 si r.
20 But you do then make a generalization to something 21 that you hadn' t looked at, something tha t you b adn't 22 evaluated, and that's the rest of the population?
23 A (WITNESS KAUSH AL) Tha t is correct.
24 Q And that judgment -- or that inference to the reat of (A_)25 the populction is based on engineering judgment?
Sonntag Reporting Service, Ltd. -_
Geneva, Illinois 60134 (312) 232-0262 f _ _ _ _
l 14089 O
1 A (WITNESS KAUSH AL) That is based on judgment, yes.
2 Q All right. !
3 Now, I understand, Dr. Kaushal, that for, let's t
4 say, the population of cable pan hangers, for the welds !
5 on those cable pan hangers, we can say that 14.4 percent !
6 of them are discrepant, and tha t's the result of CSR;
! 7 correct? !
- 8 A (WITNESS KAUSHAL) 1 believe that is correct in terms j l
9 of welds. That number is appro:tima tely, i 10 I don' t recall the exact number. !
(
11 Q All right, sir, j 12 Well, we can make the inference, assuming all other l 13 things are given, and that is that the sampling process l 14 is adequate and that the evaluation of the -- the l
i 15 inspection is effective, the evalua tion of the results !
I !
16 are correct -- assuming all those things, and maybe 17 others that I just lef t out of that, you can make the 18 inference, can you not, Dr. Kaushal, that there are 14.4 !
i
! 19 percent welds discrepant in the rest of the cable pan 20 hanger population?
21 A (WITNESS KAUSH AL) Tha t will be a reasonable 1 :
22 assumption; but you have to understand with that blanket l 23 statement as to what the nature of those discrepancies 24 is. l 25 Q All right, si r.
l Sonntag Rcporting Service, Ltd. s Geneva, Illinois 60134 ;
(312) 232-0262 -
W--- _-_- -
f.
1 14090 4
!O j 1 And that in the case of cable pan hangers as a 1
2 popul ation, 53 percent of the cabic pan hangers in the 3 popula tion will have discrepancies that are notable in 4 character. As the term " notable" is used in CSR, a
. 5 reduction of 10 percent or more in the -- let me make
- j. i j G sure I get the term right -- load-carrying capability of l i i
! 7 the item? l i 8 A (WITNESS KAUSH AL) I believe that capacity is the word [
i i l 9 tha t's used sometimes. ;
! 10 0 Ca pa ci ty . I l l 11 A (WITNESS KAUSH AL) But, again, you have to put in it
{
12 light of how much capacity is there in the first place, t 13 If there is a f actor of 10 margin to start with, 10 :-
I l 14 percent reduction doesn't do anything.
I l l 15 0 All right, sir, f
< l i
l 16 But that is the result of the evaluation of those i
i 17 discrepant conditions, an evaluation that was done for ;
I j 18 the sample items by Sargent & Lundy ?
I I
19 A (NITNESS KAUSH AL) That is correct.
l l
l 20 0 And no such evaluation has been done of the remainder of j
! t j 21 those discrepancies, whether notabic or otherwise, in l
22 the rest of the populations? !
23 A (WI Tt1ESS KA!1SH AL) There isn't an evaluation one by one l 24 for every item there is in the plant, but there is a 25 general assessment made based on the Sonntag Reporting Service, Ltd. I" q
Geneva, Illinois 60134 1 (312) 232-0262 ,
i ,
l.
1 14091 l
\e l
I architect-engineer's knowledge of the kind of design l 2 margins that exist in the design of the plant and what l l <
3 the implication is of the discrepancies found with !
! 4 respect to that design margin. j i i j 5 0 All right, sir. l I !
( 6 And, in fact, you haven' t even identified the other l' l
7 discrepant conditions in the remainder of the population r 8 aside f rom the population samplea that are a part of l l 9 BCAP CSR? I t
l l r
10 A (UITNESS KAUSHAL) No. That is inherent and ;
I t 11 fundamental to the compling program.
l (
12 0 All righ t, sir.
13 How, here's the leap of faith.
l !
E 14 We know that if you asst:me all other thinga are --
l 15 if you assume that you can make these inferencen in the I ;
16 first instance, we know that there's going to be 14.4 i
17 percent discrepant welds in the rest of the cable pan l 18 hanger population -- all right, sir -- and we may be 19 able to make some inferences, for argument sake, about l
20 the incidence of cracked welds, i 21 Do you think we can do tha t, sir? j 22 A (WITNESS KAUSH AL) You may be. I -- I don' t -- I' m l 23 no t -- ye s, you can make some assessmenta; but I don't 24 know how that assessment was made. !
25 Q I don't, either, and I don't kn ow the data is there.
i Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262 i
14092 O
1 But let's assume you add the data on the rates of 2 incidence of cracked welds in your sample.
3 Would you feel comfortable making inferences to the 4 rest of the population about the incidence of cracked 5 welds?
6 A (WITNESS KAUSH AL) Assessments can be made in that 7 res pe ct.
O Q All right.
9 And, similarly, other kinds of specific types of 10 defects --
11 A (WITNESS KAUSH AL) That's correct.
12 0 -- weld defects ?
13 All right. But when you do your engineering 14 evaluation -- when sargent & Lundy does the engineering 15 ovaluation of the discrepancies that have beer.
16 Identified in the sample, they just don't consider the 17 cracked weld, do they, or the discrepancy it self in 18 isola tion f rom its circumstance in the pla t, do th ey ?
19 A (MITNESS KAUSH AL) I'm not really sure of your i
20 question, Mr. Guild.
i 21 Q All right, sir.
22 Well, the R value, the capacity reduction factor, 23 reflects a measure of the discrepancy itself in i
i 24 isolation, does it not?
25 A (WI TN ESS K AUSH AL) The a value is usually calculated Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
i l
14093 7s l f )
1 by -- w ell, it could be by several ways. It could be 2 for that weld or it could be on an assesszent of that 3 par ticular item as a whole.
4 Q Ty pi cally , it's calculated on the basis of the 5 discrepancy itself.
6 If there's any reduction in length ot' a weld, for 7 e xam pl e, the R value represents the relationship between 8 the reduced as-built length of the weld and the 9 ac-designed length of the weld?
l 10 A (WITNESS KAU511 AL) Well, you will have to talk to Mr.
11 Kostal on that; but my undetstanding is that where it is
(' )
i
'~'
12 obvious that it doesn' _ make much difference anyway, it 13 may have been done tha t way, but where there is any 14 question, the whole item would be subjected to 15 analysis -- to analysis ao a whole.
16 Q Well, we will talk to Mr. Koatal about that.
17 But in any event, we fan agree, can' t we, Dr.
l 10 Kaushal, that when you do the design significance 19 evalua tion, you consider not juct tha t crack or that 20 cracked wold as an integral aspect of a larger component 21 or serico c'J componente in the plant ?
22 A (WITNESS KAUSII AL) Does the anceaament -- is the 23 asseannent done on a . eries of components ?
24 0 It la done --
,0 What's the question?
( ) 25 A (WITNESS KAUS'I AL) w/
Sonntaa Reporting Se rv i ce , Ltd.
Geneva, Illiticia 60134 (312) 232-0262
__.- . . _ _ _ _ _ _ _ - - - - - - _ _ _ . . - - _ _ _ .-- ._ - - - _ . ~ .- - - .. - -
14094
- O i
1 Q I'm sor ry. What?
L l- 2 A (WITNESS KAUSHAL) Would you repeat the question?
l L 3 Q Do you consider that discrepant weld not all 07 it sel f, 4 but you consider it in its place on a particular f
l 5 component?
6 A (EITNESS KAUSH AL) I would think so, yes.
7 Q All right, sir. ;
8 Now, you consider, for example, whether, if it's a 9 weld that's not there at all, if there is no weld i a
10 because the weld that is specified wasn' t present -- you !
4 l 11 consider whether or not there's an adjacent weld to !
> ?
12 determine whether or not the absence of the soecified !
l 13 weld has design significance for the component?
14 A (NITNESS KAUSHAL) I would think those assessments will j 15 be Aneluded, ye s. ;
1G Q All righ, sir.
l L 17 Now --
10 JUDG E GROSS?1AN: Excuse me.
s i 19 Mr. Guild, are you sure this is the right witness l
L 20 to be asking those questions of, because I thin!: you are l l
l 21 going to have to go through that again with Mr. Kost al ? l 22 MR. GUILD: I may well have to do that, Judge.
l l 23 JUD3E GROSSMAN: And you may get dif ferent !
I 24 answ e r s, because I don' t know that this witness is 25 competent to go into tha t.
I ,
t
- Sonntag Renorting Service, Ltd. l t Geneva, Illinois 60134 l (312) 232-0262 j
{
l l
! 14095 i i l9 i
l 1 MR. GUILD: All right, si r. l i
! 2 BY MR. GUILD:
l )
l 3 Q In any event, Dr. Kaushal, I take it it's your belief, I
i 4 sir, tha t you can, indeed, generalize from a rate of I
l 5 incidence of defects in your sample to the population as l
? G a whole, notwithstanding the fact that you don't know 7 where that defective weld is going to occur in !
! 8 unidentified defective items in the rest of the l
! i l 9 population? ,
! i
{ 10 A (NITNESS KAUSH AL) I believe that we can generalize, r l
11 yes, 12 0 All righ t, sir.
13 But, again, somebody else has made those judgments; j
{
14 I take it Sargent & Lundy?
l 15 A (WITNESS KAUSHAL) That's correct. f 16 JUD3E GROSSMAN: Excuse me. ,
I 17 Having cautioned Mr. Guild about inquiring into the i 18 categorization process, I'm going to ask you something 19 myself along those lines, even though you are not Mr.
i 20 Kostal, r t
21 In determining the design significance of the 22 items, were all the discrepant items considered or only i
~
! 23 those that had R values less than .9 percent? Do you l I i 24 know tha t ? l 25 A (WITNESS KAUSH AL) Your Honor, in the evalua tion, all t
Sonntag Repor ting Se rvice, Ltd. l Genova, Illinois G0134 (312) 232-0262 l
14096 (m)
'v' 1 the discrepancies that are there were considered.
2 If a particular weld is so insignificant 1y 3 discrepant tnat it has imperceptible af fect on the R 4 value, then its effect on the overall capability of the 5 item is also very small or insignificant, so, in effect, G it doesn' t make any difference.
7 But to answer your question directly, all 8 discrepancies are taken into account in the evaluation.
9 JUDGE GROSSMAN: And a calcula tion, then, was 10 made on every item that was found to have any discrepant 11 obse rva tion , then ?
)
j 12 A (HITNESS KAUS:1AL) There is a calculation.
13 In some cases, the calcula tion may be very simple, 14 which is that the discrepancy is small, and very quickly 15 one can come to the conclusion that it has no ef fect on 16 the item; but in effect, all discrepancica were 17 considered and an evaluation waa made.
18 Now, you saw a relatively large calculation 19 yesterday with regard to one of four items. Tha t is by 20 no means typical of every calculation.
21 Some of them are very, very simple, becauce the 22 discrepancies are co insignificant.
23 (In di ca ting . )
24 JUDG E GROSSMAN: And f ou are sure about that?
( 25 A (NITUCSS KAustl AL) Yes, ni r.
Sonntag Reporting Service, Ltd.
Geneva, I111noia 60134 (312) 232-0262
14097 ym.
E I
\s /
1 JUDGE GROSSMAN: Okay.
2 The reason I ask you that, even though it appears I 3 to be Mr. Kostal's province, is that I really wanted to 4 determine sample size with regard to the design 5 significant determinations, which is really your l
6 province.
7 And you are sure, then, that the entire sample 8 population was taken into account, then ?
9 A (UITNESS KAUSH AL) Absolutely, yes, sir.
l 10 JUDGE GROSSMAN : Okay.
11 MR. STEPTOE: Judge Grossman, I guess I'm a 12 little less sure than my witness as to one thing that U }
[
13 you asked.
14 You were asking about calculations at one point and 15 Dr. Kaushal was talking about calculations and then 16 evaluations.
17 May I be specific and ask a question?
18 JUDG E GRO3SMAN: Sure.
19 MR. STEPTOE: Would there be a -- for every
> 20 dis crepancy or observa tion tha t was valid, found par t of 1
21 BCAP, would there be a calculation of an R value?
22 Would there be a mathema tical calc ula tion ?
23 A (WITNESS KAUSHAL) Of an R value for every discropancy?
24 Q Yes; taking you away from wolds now.
N
) 25 A (WITNESS KAUSH AL) I don' t -- your Honor, maybe I am l Sonntaq Reporting Se rv i ce, Ltd.
Genova, Illinois G0134 (312) 232-0262 L ___ _ - - - - - _ _ _ _ _ - - - - - - - - - - - -
14098 O
1 mixing things, and let me correct that.
2 I tend to -- I tend to use the word " calculation" 3 and "eveluation" kind of interchangeably.
4 Every discrepancy is evaluated. Whether there is a 5 calculation, a calc number with respect to that, I guess 6 I'll have to back off on that.
7 JUDGE GROSSMAN: Okay.
8 Mr. Steptoe, I was not asking about the R value 9 calcula tio n.
10 I was asking about the design significant 11 evalua tion and whether, in making that evaluation, eve ry 12 item was considered.
13 MR. STEPTOE: Yes, Judge G rossman.
14 I think the answer you got to that question, as far 15 as I know, is correct, too.
16 I just was concerned about the possible inference 17 that there were mathematical calculations for each 18 observation; and I think when we get the enginecra up 19 here, par ticula rly Mr. Thorne11, there may be some casen 20 where written evaluation was performed rather than 21 ma thema tical calcula tion.
22 J UDG E G ROSS!!AN : I noe. Okay.
23 Tha t' n fine.
24 A (WITNESS KAUSil AL) If I may add, ai r, that's where I h25 was saying I tend to use the term "evalua tion" and Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
} l l
I
! 14099
)
( l
,! - 1 " calculation" interchangeably, and I apologize for that l'
l 2 mix up. l t
l 3 (Indica ting) !
l !
j 4 I4 R. STEPTOE: Thank you, Judge Grossman. l l
5 BY IIR. GUILD: I 6 0 lir . Shevlin, the other day you were talking about why, l I i I again, you thought that using inspection points and 7 l 1
8 discrepancy points was a more appropriate way of i
' reviewing the CSR data as contrasted with viewing them 9
I !
! 10 on the basis of welds or items.
11 I heard you say that in all cases Sargent & Lundy j 12 was conservative in the inspection point counting 13 approach that it used. j f
14 Was that your testimony ? j l
j 15 A (NITNESS SH D/LIN) I don't know that I said in all j 16 cases, !!r. Guild, but I think that was generally a f l
j' 17 little more conserva tive.
l l 18 Q And I take it that you think that Sargent & Lundy-was 19 being conservative in using -- I think you counted 17 l 20 attributes per weld? f i !
i 21 A (WITNESS SHE/ LIN) In the electrical area, there are 17 >
( 22 attributes on the welding checklist, and depending on ;
i 23 the geometry of the ucid, all thone attributes may not l 24 be applicable. !
25 0 Your bolief in that a concervative way of measuring weld i
l Sonntag Repor ting Service, Ltd. (
l Genava, Illinoin 60134 l j (312) 232-0262 j
- - . . . - - . . - - _ _ ~ _ - - - . - - . .
- - 14100 i LO L
1 inspection results is to treat each weld as having 17 :
2 attributes, depending on the geometry of the weld? l 3 A (WITNESS SHD/LIN) Yes.
4 Q I mean, even without considering the geometry of the !
5 weld, you've got 14 attributes?
6 A (WITNESS SHD/ LIN) That's righ t.
l l
7 0 Now, do you recall that once upon a time, you even went -
8 out and counted a weld size by assigning three
{ r 9 inspection attributes for each weld on the question of .
10 weld size? I 11 A (WITNESS SH EVLIN) Yes.
12 Q Somebody decided that that was a little excessive, I 13 take it, and cut it back and made that just one? )
i 14 A (WITNESS SUD/LIN) That's correct. [
i 15 Q So they didn't start out connervative, anyhow, but they ;
16 got a littic better, knocked off two counta per weld.
! 17 Here you involved in that decision? Was that your I
- i 18 responalbility, Mr. Shevlin? l
! 19 A (WITNESS SH D/LIN) I'm corry. I don't quite underntand. l I l j 20 Am I involved in -- (
21 Q Were you involved in tha decision to reduce the 22 inspection point counting for welds by two per weld to 23 call weld size only one point and not three points? (
l 24 A (WITNESS SHD/LIN) I would have agreed to it. l 25 3 Do you know who was the cource of that change ?
i I
sonntag Reporting Service, Ltd, ;
Geneva, Illinoin 60134 l t (312) 232-0262
! l
14101
! i 1 A (WITt1ESS SHE7 LID) No, sir.
2 Of all the attributes -- not only in the welding, 3 but in the entire mechanical area, I couldn' t recall who 4 was the cource of change in any given attribute.
5 Q Dr. Kaushal, do you know who changed the approach to 6 counting wold inspection points and decided to coent 7 weld size as only one instead of three?
8 A (WITNESS KAUGH AL) No, si r, I don't.
9 Q How about you, Mr. Orlov ?
10 A (WITNESS ORLO/) I'm not f amiliar with who changed it 11 from three to one.
12 Q At one point they counted minsing welds as an attribute
[V) 13 f or welds. They deleted that one. All right.
14 Doco anybody knoi?
15 A (WITNESS KAUSH AL) I don't recall tha t.
16 Q Mincing weld appears at the bottom of the checklict.
17 I'm looking at Intervonors' Exhibit 155 A, the la diccrepancy counting f orm. Is minaing wcld in or out.
19 In that an inspection point that you counted for 20 welds or not?
21 A (HITNESS KAUSH AL) I believe in the latent checklint 22 it'a not, but I'm not sure.
23 Q All right, air.
24 Don' t you recogniz e the phenomenon, Dr. Kaunhal, (O
v )
25 that if you have enough inopoction pointa -- in thic Sonntag Reporting Service, Ltd.
Geneva, Illinola 60134 (312) 232-0252
14102 0
1 case, you count enough things about anything -- that you 2 dilute the things that matter so much that the results 3 become unmeaningf ul?
4 A (WITNESS KAUSI1 AL) tio , I don't. I mean, obviously one 5 can carry that point to an extreme in an unreasonable 6 fashion, but I don' t belicyc that that -- the inspection 7 point counts that were establinhed is unreasonabic in 8 that respect.
9 0 I had a statistician friend say, for example, "If you 10 are trying to measure the dif ferences between men and 11 women," variations which are apparent to any of us who 12 fall into one category or the other, "and you count 13 onough fingern, toes, a rm s, hairs, cycc, you wind up 14 proving statistically that ,cn and women have no 15 cignificant variation, no difference."
1G I mean, that becomca abaurd if you are not focusing 17 on what you want to moacure.
18 Now, isn' t it more sensible for thcao --
19 MR. STEPTOE: Judge G rossman, in he going to 20 ack the witnena whether he agrees or disagreen with that 21 statement?
22 Ile juct made a speech.
23 JUDG E G ROSS!!AN: Well, that's all right.
24 !!c's going to ask a question.
25 BY MR. GUILD:
Sonntag Deporting Service, Ltd.
Goneva, Illinois 60134 (312) 232-02G2
14103 V
1 Q Docan't it make more sense to look at what matters here, 2 and that is whether or not, accuming all otner thinga 3 are appropriate for this point of reference -- whether 4 or not the L. K. Comstock QC Inspectors, when inspecting 5 items in the electrical populations, conduit, cables, 6 cabic pan hangers, et cetera -- whether they identified 7 a rejectable condition on that item? Isn' t tha t the 8 concible f rame of reference, Dr. Kauchal?
9 A (win 1ESS EAUSH AL) fir. G uild, no, in the scnce that you 10 are talking about.
11 The identification of populationn of what
[v } 12 constitutes an item in a judgment that we mado f rom the 13 point of view of identifying sampics.
14 That judgment was not made on the banis of what 15 would conctitute a reanonable unit of inopoction to come 1G up with concluciona in that regard, 17 O bv io u sly, I could have cet up a sample of 60 18 welds. I didn' t -- you know, we didn' t -- we didn' t se t 19 up a campic of 60 wolds throughout the plant.
20 So we wanted to take a resaonabic cample, having 21 reaconable innpoetion units, but having then come up 22 with varying unita of -- unita of varying complexity, wo 23 had to reduce it to the common act of reference, and 24 that's the way the incpection pointe came up.
(~'
25 (In di ca ting . )
i
(
Sonntag nenorting Service, Ltd.
Geneva, Illinoin 60134
, (312) 232-0262
14104 I
v 1 Q I see.
2 Dr. Kaushal, do you recogniz e -- and I understand 3 the CSR and DCAP was done for a purpose other than this 4 proceeding. It was done other than 'or responding to 5 questions about baracament, intimida tion and production G precauce at L. K. Comstock.
7 With that understanding, do you recogniz e, Dr.
l 0 Kaushal, that the way the L. K. Comatock guality control 9 nyctem worked, that in order for an item in the field to 10 get into the prococa where engineers could consider the 11 nature and significance of defects, that the Comstock 12 inspector had to determine the item rejectable and v
13 initiate some control documentation, cuch as an 14 Non-Conformance Report or an Inspection Correction 15 Report?
16 A (WITNESS KAUSHAL) Are you csking me to -- in that --
17 what wac the question? I'm cor ry.
18 0 Are you aware that that is the way the comotock quality .
19 control system functioned, sir?
20 A (WITNESS KAUSTIAL) What I'm aware of, Mr. Guild, is 21 that the Comotock quality control procesc identifies a 22 non-conforming condition, which may be a small portion 23 of the total incpection that was done.
24 Now, it Ic true that the item at that point -- that 25 par ticular incpection la not complete, but -- and there 4
Sonntag Reporting Service, Ltd.
Geneva, I111noin 60.134
- (312) 232-0262
l 14105 i
tx l
~,
i l 1 >
may be an ICR -- what is it called -- an Inspection j J 2 Cortection Report may be issued -- 1 l
3 Q Ye s, si r.
L 4 A (WITNESS KAUSH AL) -- which pertains to that small l
5 portion of the inspection that was not found in a I 6 conforming condition, j i
l 7 As noon as that non-conforming condition is fixed, !
l l 8 that item can be considered acceptable. l l l 9 0 All right, sir, t 10 But if a Comstock inspector in cent out to inspect I
11 a hanger and there are discrepancies on that hanger, th e i
f}
N_/
12 precondition to anyone in engineering or otherwico l l
13 cvaluating those discrapancien in that hanger is that i l
14 the Comatock inspector identify on his checklist that 15 that hanger has at least one rejectable condition; i 1G correct?
17 A (UITUESS KAUSH AL) Yes. i 18 Q All right.
19 He does that, an ICR or an NCR getc writton and 20 nomebod/ in engineering evaluates that diccrepant 21 condition? ,
22 A (UITNESS KAUSMAL) It may never got to enginocring 23 cval ua tion. It may be go back and fix it. .
24 Q It may be go back and fix it. !
(v 25 And in thin cace, the dis crepancy doenn' t r equire sonntag neporting Service, Ltd.
Genova, Illinoic 60134 232-0262 (
(312)
r-14106 V
1 an engineering evalua tion because it's been repaired?
2 A (WITNESS KAUSH AL) Right.
3 Q Houldn' t you agree, then, Dr. Kau sh al, tha t th e 4 appropriate unit of measure, then, if an inspector at 5 Comstock in sent out to inspect a cable pan hanger as an G item, that's his task to inspect that hanger -- the 7 appropriate unit of measure for that inspector's 8 performance was whether he identified a rej ectable 9 condition in this item so that it could be the subject 10 of fur ther review?
11 A (UITNESS KAUSH AL) Appropriate measure of -- what was I \ 12 that? I'm sorry.
(w 13 0 That inspector's performance, the Quality Control 14 Inspector's performance.
15 A (WITN3SS KAUSHAL) I -- I'm not knowledgeable on what 16 the performance standard is that's used for his 17 performance in that respect.
18 He is expected to identify non-conf orming 19 conditiona if they exist; that's correct.
20 Q All right, sir.
21 Mr. Shevlin, let's take the weld inspection area.
22 I guess you would agree tha t ueld inspection is 23 subj ectivo, an we distinguich obj ective attributes or 24 obj ective inspection n f rom subj ective inspections ?
ON I generally agree witn that, yes, 25 A (UITNESS SHE/ LIN)
!.x_-)'
Sonntag Repor ting Se rvice, Ltd.
G eneva, Illinois 60134 (312) 232-0262
14107 33
\ )
v 1 si r.
2 Q And that that's because it requires some judgment on the 3 part of a Weld Inspector in reaching an inspection 4 decision about acceptance or rej ection?
5 A (WITNESS SH E7LIN) Yes, si r.
6 Q All right.
7 Now, I take it you would agree that there are --
8 it's not to say there isn't judgment in other inspection 9 decisions as well.
10 It's just that weld inspection inherently calls for 11 more judgment rela tive to other types of quality control Ih 12 inspections?
U I think that's generally true.
13 A (HITNESS SHE7LIN) 14 Q All right, si r.
15 Now, would you agree that some inspectors -- Weld 16 Inspectors -- are more, to use your term, hardnosed, 17 strict, rigid, about accepting or rej ecting welds than 18 o the rs ?
19 A (WITNESS SHEV LIN) Yes.
20 0 All right.
21 A (WITNESS SHE7LIN) That's a pretty well-known f act.
22 Q All right.
23 Some acid Inspectora, for example, apply a 24 workmanship standard that is not specifically a weld O
( )' 25 inspection attribute, but is based on that Weld Sonntag Repor ting Service, Ltd.
Geneva, Illinoin 60134 (312) 232-0262
14108
,m i I x /
1 Inspector's experience and judgment, perhaps as a welder 2 himself, to be able to identify what is a workmanlike 3 weld from a non-workmanlike weld?
4 A (HITNESS SHE7LIN) I take it here that you are talking 5 about imposing a criteria over and above that which is 6 in the controlling document?
7 Q Yes, si r.
8 A (WITNESS SHE7LIN) I have seen inspectors do that, yes.
9 Q All right, sir.
10 And some inspectors just become known as being 11 sticklers and requiring -- expecting that welders will
[~
\
) i 12 do welds that are of workmanlike quality and regardless-
~
13 of whether that workmanship standard is -- is above and 14 beyond the call of specific acceptance criteria?
15 A (WITNESS SH EVLIN) The question ?
16 Q Yes.
17 That some Weld Inspectors will apply . a standard 18 tha t -- of workmanship that is above the standard for 19 other inspectors and beyond what's set out as 20 accept /rej ect critoria ?
21 A (WITNESS SUD/ LIN) Uc try to avoid that, but it will 22 happen, yes.
23 Q All right, all righ t.
24 But wouldn' t you agree, Mr. Shevlin, tha t while f)v 25 there may ba variability be tween inspectors on issuc a of Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14109
'V 1 wor kman ship, that the sort of bottom-line requirement 2 for a Held Inspector is that he have enough skill and 3 knowledge and ability, motiva tion, to be able to 4 identify and document rejectable weld conditions?
5 A (WIT 11ESS SH E/LIN) Yes, tha t's the basic function.
6 0 All right.
7 Particularly in the context of a nuclear power 8 pla n t, we want to err on the side of conservatism, don't 9 we?
10 A (HITNESS SHD/LIN) If we have to err, yes, sir, 11 Q All right.
/' h 12 Now, wouldn' t you agree, then, Mr. Shevlin, that 13 what's critical is not the box score of an inspector on 14 a list of inspection points, breaking a weld doan into 15 14 or 17 attributes, but whether or not a Weld Inspector 10 can identify what are rej ectable conditions in that 17 w el d, up or down, accept or reject?
18 A (WITNESS SHEILIN) Well, I don' t guess you can have one 19 without the other.
20 If you don' t give him the attributes, which must be 21 considered in any given criteria for each of those 22 attributes, then you have not -- not put him in a 23 position where he can make the inspection.
24 Q All right, sir, f
(5) 25 But don' t you measure your inspector's performance, Sonntaq Repor ting S e rv i ce, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14110 t I
'w/
1 as you supervise Weld Inspectors, not just BCAP, but 2 generally in your experience in the construction of 3 nuclear power plants, by the standard of whether or not 4 they can identify a rej ectable weld condition?
5 A (WITNESS SHE7LIN) In par t.
G Q And while inspectors may differ in their workmanship 7 standards that may be above and beyond the acceptance 8 criteria, you wouldn' t retain a Weld Inspector that 9 allowed cracks to get by, lack of fusion to get by; 10 agreed?
11 A (WITNESS SHE7LIN) I wouldr.' t keep one that regularly
[ \ 12 let it get by.
13 Q All righ t, sir.
14 Just for a f rame of reference, what was the nature 15 of the performance problems with the inspector --
16 agreed, outside the electrical area -- who you said you 17 took off inspections and did 100-percent reinspection on 18 because of problems identified in his early work?
19 A (WITNESS SH E7LIN) I don' t think I ca n -- I don't think 20 I can recall specifics on that, Mr. Guild, except to say 21 that it was both welding and mechanical.
22 Q All right.
23 Did he f ail to identify rej ectable weld conditions?
24 A (WITNESS SH C7LIN) He failed to identify rejectable (f')\ 25 conditions and he rej ected a lot of acceptable Sonntag Recor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14111
/ )
'LJ l conditions tha t -- that were pretty obvious.
2 0 All righ t.
3 JUDG E G ROSSMAN: Mr. Guild, I don' t think 4 this examination is profitable.
5 These are the kinds of questions that you would put G to your own expert; but I just don't think that you can 7 get adverse witnesses to give you the same kind of 8 discussion that would benefit your case. It just 9 doesn' t happen.
10 MR. GUILD: Well, sir, I appreciate your 11 judgment.
-s (b 12 unfortunately, somewhat handicapped because i I'm, 13 all the experts are in the employ of Commonwealth Edison 14 Company here, and I'm somewhat --
15 JUDGE GROSSMAN: Well, I understand that; but 16 you are just not going to get an exposition, which is 17 what you want, tha t's going to benefit you.
18 MR. GUILD: No, sir. I think that --
19 JUDGE GROSSMAN: You can examine them and 20 elicit f acts that might help your case, but you are not i
21 going to get a discourse that's going to help your case, 22 and that's what are asking for.
23 MR. GUILD: Understood.
24 I apologiz e if that's what it appears. I'm not
( )l 25 trying to get a discourse frca Mr. Sh evli n. I'm trying Sonntaa Reporting Service, Ltd.
Geneva, Illinois 60134 -
(312) 232-0262
14112
/ ' ' ')
s i
'J l to ask focused questions and get him to establish points 2 that I think support our position with respect to how 3 you evaluate these results.
4 JUDG E GROSSMAU: Okay.
5 The only reason -- I think it's wasting time, and I G have an obligation to keep us moving, and I just don' t 7 think that these kinds of areas are the kinds that you 8 can get an adverse expert to support your case, as 9 legitimate as your position might be.
10 MR. GUILD: Understood, Judge, 11 I wish I had an expert of my own to be able to put gs 12 up to say these things. I don' t, unfortunately.
i }
's_ /
13 BY MR. GUILD:
14 Q Mr. Shevlin, you stated that your practico for the CSR 15 inspectors was to have them go to the field, perform 16 their inspections and complete their inspection 17 checklists in the field while they were observing the 18 field conditions.
19 Is that your testimony ?
20 A (WITNESS SHD/LIN) Insof ar as if it's practical, yes, 21 sir.
22 O All righ t, sir.
23 And what is the basis for having an inspector 24 complete the checklist in the field as opposed to doing
/q (v) 25 it later in the office, for example, within the limits Sonntag Repor ting Se rvice, Ltd.
G eneva, Illinois 60134 (312) 232-0262
14113
\ /'
1 of practicality?
2 A (WITNESS SHE7 LIN) A short pencil is better than a long 3 memory.
4 Q All ri gh t, sir.
5 JUDG E COLE: I'm sorry. I didn' t hear that.
6 A (WITNESS SH EVLIN) A short pencil is better than a long 7 memory. Write it down now instead of trying to remember 8 it and write it down later.
9 BY MR. GUILD:
10 0 And that's because you may not accurately reflect the 11 field-observed conditions as your memory gets long, if
/
(m) 12 you wait until later to do your documentation?
V 13 A (WITNESS SH E7LIN) Well, yes, si r, tha t's f ai rly 14 obvious. You do several pieces of work, you try to keep 15 track of all that stuff in your head and then come back 16 and write it down --
17 Q All right, si r .
18 A (WITNESS SHDILIN) -- you are asking to make mistakes.
19 Q You are asking to make mistakes.
20 I take it you haven' t performed a review of the L.
21 K. Comstock quality control inspection practices in that 22 regard?
23 A (WITNESS SHE7LIN) I have nothing to do with Comstock, 24 sir.
(O) 25 Q But the f ailure to do documentation in the field at the Sonntaq Reporting Se rvi ce, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14114 ,
4 x**
i\ \
/
V 1 time of inspection would increase the likelihood of 2 inspector error?
3 A (WITNESS SH E7LIN) In my view, it would.
4 0 Now, Mr. Woz niak, let's talk more about the conduit 5 hanger reverification program.
6 I have a document here.
7 Now, you identified, from the reverification 8 program, Mr. Wozniak, seven new conduit hanger 9 obse rva tions ?
10 A (WITNESS WOZ NIAK) Ye s, we did.
11 Q All right.
[' 12 Four of them are conduit identification missing; 13 ,
one is an undersize baseplate; another is a baseplate 14 not installed; another one is a conduit identification 15 missing.
16 A (WITNESS WOZ NIAK) Yes.
17 Q Do you agree with that, sir?
18 A (WITNESS WOZ NIAK) Yes.
19 Q Mow, that was having reviewed 51 conduit hanger l 20 inspection packages; correct?
l 21 A (WITNESS WOZNI AK) Yes.
! 22 0 And that was having gone out and reinspected only 13 of l 23 tho se ?
24 A (MITNESS WOZ NIAK) 13 that required field R
( ) 25 r everifica tion, yes.
l Sonntag Reporting Service, Ltd.
j Geneva, Illinoin 60134 l (312) 232-0262
14115 n
1 Q And only as to the attributes that were specifically set 2 out in the NRC Concern 11?
3 A (WITNESS WOZNIAK) Yes; as the reverification plan was 4 developed, yes.
5 0 All right, si r.
6 But yet you still found 7 additional observations 7 from either a sample of 51 or a sample of 13, de pen ding 8 on what you want to call your sample size?
9 A (WITUESS WOZNIAK) Yes; but you will note, I think, as 10 you j ust stated, 5 of those were due to the 11 clarifica tion of Attribute 7.
12 Q Well, indeed, wouldn' t you expect that if you went back
[' u} 13 out and reviewed other attributes or other populations, 14 that you would find additional observations in the same 15 proportion at least as you found additional observations 16 in the conduit banger area?
17 A (WITNESS WOZNIAK) W ell, inasmuch as like I just stated,
! 18 that five of these'seven observations were due to a 19 clarification of ab attribute, another one was due to 20 the inappropriate documentation of an inspection, 21 leaving one so-called inspector miss, what opinion, you 22 know, is offered here?
23 k - I can't really give an opinion on one 24 reverifica tion of one miss.
(In di ca ting. )
) 25 Sonntaq Reporting Service, Ltd. ,
Geneva, Illinois 60134 (312) 232-0262 i
14116
,m i \
\)x 1 Q You wouldn't expect to find additional observations if 2 you looked at additional attributes or additional 3 popula tions ?
4 A (WITNESS WO3 NIAE) I guess I can' t draw an opinion f rom 5 tha t.
6 Q All right.
7 In any event, it's clear you didn' t look at 8 additional attributes nor did you look at additional 9 populations?
10 A (WITNESS WOZ NIAK) No, sir; just the reverification 11 program itself.
12 Q Mr. Shevlin, there was some testimony about when weld
[ ]
'xs' 13 maps got performed, and I was a little bit unclear about 14 how to understand your answer.
15 I gathered that f or a time weld maps weren' t 16 performed and then you decided to do weld maps. You 17 stopped, you went back and did weld maps on all of the 18 preceding observations that had not up to that point had 19 maps done; is that correct?
20 A (WITNESS SHE7 LIN) Yes; that's generally correct, yes, 21 ci r.
22 0 All right.
23 How long did you go before you stopped and went 24 back and redid the weld maps?
( ) 25 A (WITNESS SUE 7 LIN) In time, I don' t know, but -- that's N,/
Sonntag Renor ting Se rv i ce, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14117
\ )
v 1 a long time ago, Mr. G uild.
2 I can guess 50 or 60 observations, maybe --
3 Q All right.
4 A (WITNESS SHE7LIN) -- across all populations.
5 0 All right.
6 Weld observations?
7 A (WITNESS SHE7LIN) Right; but that's across all the 8 populations that were working at the time.
9 0 All right.
10 And how many total weld observations, just for a 11 frame of reference, appro ximat ely ?
/ 12 A (WITNESS SHE7 LIN) Probably about 50 or 60 --
N~-
13 Q No, si r.
14 By comparison to how many observations did you wind 15 up doing in the weld area total across all populations.
16 A (WITNESS SHE7 LIN) Oh, I don't know. I have no idea.
17 Q Does anybody else on the panel have a more precise 18 recollection of when the weld maps started?
19 A (WITNESS SMITH) No.
20 A (WITNESS WOZ NIAK) No.
21 A (NI TN ESS KAUSH AL) I don't.
l 22 A (WITNESS SHE/LIN) It started very early in the program.
23 (In di ca ting . )
24 Q All right, sir.
I ) 25 What prompted you to stop and go back and do weld
\d Sonntag Reporting Se rvi ce, Ltd.
Geneva, Illinois 60134 (332) 232-0262
14118
,- y I \
1 maps when you hadn't done them before?
2 A (WITNESS SHE7LIN) Man power considerations.
3 Sargent & Lundy required the weld maps. I guess 4 there were a lot of options. Would Sargent & Lundy go 5 create them, would we use our inspectors to go create 6 them, would Commonwealth Edison hire comebody else; and 7 eventually the decision came back that my group would be 8 responsible --
9 Q All right, sir.
10 A (WITNESS SHE7LIN) -- and, of course, by then there was 11 some backlog created; and I found it more efficient and Imi 12 more convenient to my operation to j ust stop what I was b 13 doing, get the backlog of weld maps out of the way and 14 then go on and from that point forward, have new 15 observations and new weld maps prepared simultaneously.
16 (Indica ting. )
17 Q All right, si r.
18 But Sargent & Lundy was the genesis of requiring 19 the weld maps that hadn't been donc up to that point?
20 A (WITNESS SHD/LIN) That's as I understand it, yes.
21 Q All right, sir.
22 Now, let's talk about NCR 6145, Mr. Woz niak.
23 I believe you volunteered that you read the 1,200 l 24 whatever pages it was in Attachment 6.
/~'N
!(v ) 25 A (WITNESS WOZNI AK) Yes, sir.
l l
i Sonntag Renorting Service, Ltd.
l Geneva, Illinois 60134 (312) 232-0262
14119 i )
w./
1 Q All right.
2 I sympathize.
3 Part of that Attachment 6 -- Attachment 6 related 4 to cable pan hangers?
5 A (WITNESS WOZ NIAK) That is correct.
6 Q Part of that Attachment 6 was the configura tion 7 observations f or that -population?
8 A (WITNESS WOZNIAK) Yes.
9 Q All right, sir.
10 Now, the walkdown that was the basis for the out of 11 scope treatment of those configuration observations was I h 12 prompted by CECO NCR 708 and 709; correct?
13 A (NITNESS WOZNIAK) Tha t, and among other things, I 14 assume, but those being a factor of it, yes, 15 0 All right, si r.
16 The walkdown that Sargent & Lundy was to perform 17 was for configuration only?
18 A (WITNESS WOZ NIAK) As the original proj ect instruction 19 began, I believe tha t was the feeling, yes.
20 Q Then it was specified that you looked for weld presence?
21 A (WITNESS WOZNI AK) Tha t is correct.
22 0 All righ t.
23 But the walkdown didn' t include a review of weld 24 adequacy or weld acceptability?
(N
(\_/ ) 25 A (WITNESS WOZ NIAK) Weld quality ? l i
l Sonntag Repor ting Se rvice, Ltd. 1 I
Geneva, Illinois 60134 (312) 232-0262
r 14120 7 m.
t 1 i / ,
\_/ !
l Q Weld quality.
2 A (WITNESS WOZ NIAK) No, I don' t believe so.
3 0 All right, sir; and you agree with that.
4 Do you know, Mr. Shevlin, or do you have anything 5 to add to that?
6 A (WITNESS SHE7LIN) No, sir.
7 0 All right, sir.
8 Now, that was because the NCR 708 and 709 were 9 preceded by NCR -- I'm losing my papers in the shuffle 10 here -- 451; correct?
11 A (WITNESS WOZNIAK) Excuse me?
[ 'A 12 Q Applicant's Exhibit 139.
'N 13 A (WITNESS WOZNIAK) 451 preceded 708 and 709?
14 Q Right.
15 A (WITNESS WOZ NIAK) That is correct.
16 Q All right.
17 And 451 was initiated in December of 1982 for 18 problems with System control Corporation welding on 19 cabic pan hangers?
20 A (WITNESS WOZNIAK) I believe tha t's correct.
21 Q Do you know whether or not -- anybody on the panel --
22 the weld defects in cable pan hangers were identified 23 and corrected?
24 A (WITNESS WOZ NIAK) Can you rephrase that?
! (~'N
, ( } 25 You mean --
'O '
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14121 t )
\s' 1 Q Sure, s ure.
2 A (WITNESS WOZ NIAK) -- weld defects that were not shown 3 on the out of scope NCR or weld defects that were valid 4 observations that are put on another NCR that were, in 5 fact, cor r e cted ?
6 0 Well, to be clear, the weld defects in cable pan 7 hangers.
8 Now, the 708 and 709 NCR's did not include weld 9 quality as one of the -- within the scope of those 10 NCR's. We've established that?
11 A (WITNESS WOZNIAK) Correct.
,s
/ T 12 Q My question is:
'\. I 13 Whatever defects that are out there in those 14 Systema Control Corporation welded cable pan hangers, 15 have those defects been identified and corrected?
16 A (WITNESS HOZNIAK) Mr. G uild, I believe one vould have 17 to look first at the disposition to NCR 708 and 709 and 18 whatever those dispositions r equired of the Systems 19 Control weld, which, by the way, I'm not intimately 20 involved with, the disposition of those two NCR's, 21 Q Well, I think what's established, is it not, sir, is 22 that 708 and 709 don't deal with weld quality, but 451 23 docs? The 1982 NCR -- CECO NCR 451 does deal with weld 24 quality; correct ?
( ) 25 A (WITNESS WOZ NIAK) Okay,
%J Sonntag Repor tino Se rvi ce, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14122 i i LJ l Q I mean, I'm not asking you to agree just for the sake of 2 agreement.
3 Are you aware of that?
4 A (WITNESS WOZ NIAK) You j ust told me that 708 and 709 5 were Systems Control.
6 Q Did not -- right, but were not weld quality. Th ey 7 were -- they are configuration and weld presence; at 8 least presence as the final walk -- as the walkdown 9 program finally developed.
10 That was your testimony; right?
11 A (WITNESS WO3NIAK) Yes.
[ ) 12 0 All right.
\ /
13 451, CECO NCR 451, Applicant's Exhibit 139, 14 " Description of non-conforman ce. System Control hanger 15 does not meet AWS D1.1-75. "
16 All righ t, si r.
17 Now, isn' t it true that the disposition of CECO NCR 18 451 that was initiated in 1982 didn't take place until 19 March of 1986, and in March of 1986, Commonwealth Edison 20 Company dispositioned this NCR without taking any rework 21 or any corrective action on the basis of a Sargent &
22 Lundy sampling and evalus tion?
23 A (WITNESS WOZ NIAK) That I don' t -- that, again, I don' t 24 know the intricate details of all three of the NCR's you PN
() 25 mentioned nor the intricate details of what Sargent &
Sonntag Repor ting Se rvice, Ltd.
G eneva, Illinois 60134 (312) 232-0262
14123
,n
.I )
b/
1 Lundy did while they were out there along with Comstock 2 inspectors on the as-built configuration walkdown.
3 I do --
4 Q Anybody else on the panel?
5 Dr. Kau sh al, do you know?
6 A (WITNESS KAUSH AL) I'm sorry. My mind was distracted a 7 little.
8 Could you repeat the question?
9 0 Were you aware, sir, that the disposition of NCR 451 --
10 A (WITNESS KAUSH AL) Yes.
11 0 -- was to simply accept as is the Systems Control n
( T 12 Corporation weld defects on the basis of the evaluation
\_ Y 13 -of a small sample of those welds?
14 A (WITNESS KAUSH AL) Mr. Guild, I don' t recall th a t.
15 A (WITNESS SMITH) Mr. G uild, I thought you said anybody 16 on the panel.
17 Q Sure.
18 A (WITNESS SMITH) I do recall that; and it was based on 19 a sample -- a randomly-chosen sample as stated, I 20 believe, in the letters f rom Sargent & Lundy to Edison.
21 (Indi ca ting . )
22 Q And you agree, then, Mr. Smith, that those weld defects 23 in the rest of the population of Systems Control 24 Corporation cable pan hangers have not been identified O
( )z 25 or corrected?
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 g (312) 232-0262
14124 t Y
\_,/
1 A (WITNESS SMITH) Tha t's correct.
2 Q Now, Dr. Kaushal, in your testimony at Page 10 --
3 A (WITNESS KAUSH AL) Excuse me. Can I get -- pass me my 4 stack of papers, pl ease.
5 A (WITNESS ORLOV) All right.
6 (Indi ca ting. )
7 A (WITNESS KAUSH AL) Yes, sir.
8 Q Your testimony at Page 10, sir, you state, in part, 9 Answer 17, "The provisions of 10 CFR 50 Appendix B are 10 not necessarily applicable to the CSR efforts. "
11 A Tha t's correct.
[^)
V 12 Q Now, I take it that is the position not only -- that's 13 not only your opinion, that is the position of the 14 Braidwood Construction Assessment Program Task Force?
15 A (NITNESS KAUSH AL) Oh, I wouldn't say it tha t way, 16 because it would be -- as f ar as the Task Force is 17 con ce rned, it would be immaterial and not a matter that 18 they would have to have an opinion on.
19 Q Well, is it the position of Commonwealth Edison Company, 20 sir?
21 A (WITNESS KAUSH AL) I'm not really sure I asked 22 Commonwealth Edison por se whether or not that's their 23 position.
l 24 As I have stated before, the company committed to l r" (N 25 doing the program in accordance with the Commonwealth i Sonntag Repor ting Service, Ltd.
l Geneva, Illinois 60134 (312) 232-0262
14125
( )
(,'
1 Edison Quality Assurance Program.
2 Q Yes, sir.
3 Well, at least it's your position, Dr. Ka ush al, and 4 it's your testimony?
5 A (WITNESS KAUSH AL) Yes, sir.
6 Q Did you ever state that position to anybody before you 7 wrote it in your testimony?
8 A (WITNESS KAUSH AL) Oh, I'm sure I've stated it to 9 people, yes.
10 Q Did you state it to people when you were the BCAP 11 Director?
m 12 A You mean to my Task Force people?
[Gj (WITNESS KAUSH AL) 13 Q To anybody, si r.
14 A (WITNESS KAUSH AL) As I said, I must have talked to 15 peo pl e.
16 I don' t recall exactly who I talked to on that 17 su bj e ct.
18 Q It's likely that you talked to other people on the Task 19 Force?
20 A (WITNESS KAUSH AL) Well, let me -- let me respond to it 21 this way:
22 Everybody in the Task Force fully well understood 23 that everything was to be done in accordance with the 24 quality assurance requirements, and the plans,
(
ON) 25 procedures and all were done accordingly, and very Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14126 !
! \
)
t-x-1 strictly, if I may say so; and Mr. Smith here made sure 2 of that.
3 0 All right, sir. Well, that's not exactly my question.
4 I'm trying to be precise about this.
5 You more than likely related your position that's 6 reflected in the centence I read to the BCAP -- other 7 members of the BCAP Task Force when you were BCAP 8 Director?
9 A (WITNESS KAUSH AL) I do not specifically recall 10 engaging in that discussion with anyone --
11 Q All right, sir.
12 -- in the Task Force, that is.
('%/ ') A (WITNESS KAUSU AL) 13 Q Well, let's be a little more precise.
14 Did you ever take that position with the Nuclear 15 Regulatory Commission or any of their representives; 16 that is, the position that provisions of 10 CFR 50 17 Appendix B are not necessarily applicable to the CSR 18 effort?
19 A (WITNESS KAUSHAL) I believe the position that has been 20 taken is that DCAP was not a requirement, it's not a 21 regulatory requirement.
22 The rest is a logical deduction on my part.
23 0 So you did take that position with the NRC?
24 A (NITNESS KAUSH AL) What I am saying is the position I
) 25 that was taken was that it was not a requirement -- that Sonntag Reporting Se rvice, Ltd.
G enova, Illinois 60134 (312) 232-0262
I 14127
( I LJ 1 the program itself was not a requirement.
2 Q All right, sir.
3 And this proposition that you state in your 4 testimony you believe to be a logical corollary to that 5 proposition ?
6 A (WITNESS KAUSH AL) On my part, yes.
7 Q All right, si r .
8 And you believe that the NRC understood that 9 logical corolla ry ?
10 A (WITNESS KAUSH AL) No, NRC never really accepted that; 11 and the program was always expected to be done in
<~m
( ') 12 accordance with the quality assurance requirements.
\s' 13 0 Well, you've now read the BCAP Inspector, Mr. Gardner's, 14 deposition testimony where he takes the position on that 15 question. It's in eviden ce.
16 A (WITNESS KAUSH AL) I recall reading something, yes.
17 Q All right, si r.
18 A (WITNESS KAUSH AL) I don' t fully recall the exact words.
19 Q All right, sir.
20 What I would really like to understand, then, is if 21 you took this position -- tha t is, that BCAP was not a 22 regulatory requirement with the logical corollary that 23 Appendix B did not necessarily apply to BCAP -- and the 24 NRC didn' t agree with that, is there any written (Gs 25 position by the NRC stating that disagreement and any Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14128
\v\
1 response from Commonwealth Edison Company, in turn, 2 saying that, notwithstanding your position, "We will 3 proceed with the view that BCAP is not a regulatory 4 r eq ui rement" ?
5 MR. STEPTOE: I'm sorry. Could we have that 6 read back?
7 I think there was -- may I have it read back?
8 MR. GUILD: I'll be happy to rephrase.
9 MR. STEPTOE: I thought there was an extra 10 not in there.
11 MR. GUILD: Might well be. The hour is late.
,m,
[ ') 12 BY MR. GUILD:
\j 13 Q Did that position ever get stated in writing, aside from 14 in your testimony, in any communication with the NRC, 15 Dr. Kaushal?
16 A (WITNESS KAUSHAL) I don' t recall that, Mr. Guild.
17 Q Do you recall the NRC, in turn, ever sta ting in writing 18 that they disputed your position that BCAP was not a 19 regulatory r equirement, or the corolla ry, that Appendix 20 B is not necessarily applicable?
21 A (WITNESS KAUSH AL) I don' t recall any discussion with 22 respect to Appendix B, but I do recall that in some of 23 the public meetings that I have talked about earlier, 24 NRC made it clear that they expected the program to be f'N)
- 25 done and done in accordance with the quality asaurance s/
s Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14129 s
',QJ l r eq uir ement s.
2 MR. GUILD: all right, sir.
3 Mr. Chairman, it's almost 5 :00. I don' t have a lot 4 more, but perhaps I can collect my notes over the 5 evening and make it short tomorrow.
6 J UDG E G ROSSMAN : Okay. Before we recess, 7 though, refresh my recollection.
8 Here any observations invalidated because of the 9 pendency of NCR 451?
10 MR. GUILD: W ell, sir, none of them 11 r eflect -- as I unde rstand it, none of them cite to 451.
(' j 12 They cite to 708 and 709. 708, 709 and 451 cite each
'\m /
13 other, I think, and all explain the general significance 14 of 708 and 709. It was in discovery or informal 15 discussions that the link was made that 451 was the 16 source NCR.
17 I'm not sure whether that's within the knowledge of 18 the panelists or not.
19 Perhaps they could --
20 JUDGE GROSSMAN: All right.
21 Mr. Orlov?
22 A (WITNESS ORLOI) No CSR inspection observations were 23 ever invalidated by UCR 451. Th ey j ust were no t.
24 J UD3 E G ROSSMAN: W ell, let mc j ust ask you:
p (v) 25 Were any observations invalidated on the basis of Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
m __
14130 p}
's
%/
( 1 NCR's 708 or 709?
l 2 A (WITNESS ORLO7) No, they were not.
3 JUDG E GROSSMAN: Okay.
4 MR. BERRY: Could I have Dr. Kaushal's last 5 answer read back?
6 J UDG E G ROSSMAN : I'm sorry.
7 Mr. Berry, you will have to speak up.
8 MR. BERRY: Could the Reporter read back Dr.
9 Kaushal's last answer.
10 (The record was thereupon read by the 11 R epor te t . )
[' 12 MR. BERRY: Could I j ust ask, Dr. Ka ush al, if 13 the quality assurance r equirements of Appendix B --
14 A (WITNESS KAUSU AL) I'm sorry, sir.
15 MR. BERRY: Your last answer there that 16 stated that they expected the CSR program be carried out 17 in accordance with quality assurance requirements, did 18 you mean the quality assurance requirements of 10 CFR 19 Part 50 Appendix B ?
20 A (WITNESS KAUSHAL) Mr. Berry, that automatically 21 f ollows f rom wha t I h ave stated befor e.
22 Commonwealth Edison Quality Assurance Program meets 23 the r equirements of 10 CFR Appendix B, and tha t's a 24 program that we were.doing the program according to.
Oj t 25 MR. BERRY: Thank you.
Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0252
. . _ _ .__ _ ___ _. ~ . _ _ . . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ . _ . _ _ _ _
l 14131 l
! l l 1 JUDGE GROSSMAN: Okay. We'll recess until l
l 2 9:00 o' clock tomorrow morning. ,
I 3 (WH ER EU PON, a t 4:55 P. M., the hearing of l
l 4 the above-entitled matter was continued i l 5 to the 9 th day of October, 19 86, a t th e i l
l- 6 hour of 9:00 A. M.)
- i l
- 7 ,
! 8 l l l l 9 !
! 10 l i
1
!, 11 l
! 12 l
13 4 l
- 14 !
15
- 16 l l
i '
l 17 l
l
, l i
19 !
1 i
20 l l
, 21 22 l
23 ,
i 24 i t
i sonntaa nenortinq service, Ltd.
{ Geneva, Illinois 60134 ,
- j. . . . . (312) 232-0262 i
f NO PAGE NUMBER CERTIFICATE OF OFFICIAL REPORTER This is to certify that the attached proceedings before the UNITED STETES NUCLEAR REGULATORY COMMISSION in the matter of:
NAME OF PROCEEDING: Braidwood Station Units 1 6 2 DOCKET NO.: 50-456/457-OL PLACE: Chicago, Illinois DATE: Wednesday, October 15, 1986 were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission.
1 s
(sigt) dVD[ D (TYPED) Nancy h. Hhh
! Official Reporter Reporter's Affiliation l
l 4
- O s
t i
i y- , - , - , , , , - - . , - . . . - - - , - - - , -- yw-.--4. _ - , . . - _ _ - - ,, ___,---,------,,.,___.,,,.m ,,-,,-_,,--,_,,..._,._,--.-,,,---..---.m.,-- -
, . _ - . - , - - - ,