ML20211D752
| ML20211D752 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 06/09/1986 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| CON-#286-605 OL, NUDOCS 8606130142 | |
| Download: ML20211D752 (100) | |
Text
ORIGINAf_
O UN11EU STATES
] NUCLEAR REGULATORY COMMISSION IN THE MATTER OF:
DOCKET NO:
50-456 OL 50-457 OL COMMONWEALTH EDISON COMPANY
~
(Braidwood Station, Units 1 & 2) l l
LOCATION:
JOLIET, ILLINOIS PAGES: 3411 - 3509 l
DATE:
MONDAY, JUNE 9, 1986 1
/'
8606130142 860609 PDR ADOCK 05000456 T
pop ACE-FEDERAL REPORTERS, INC.
OffiaalReporters 444 North CapitolStreet Washington, D.C. 20001 (202)347-3700 NATIONWIDE COVERAGE
3411 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
(Braidwood Station, Units 1 8
and 2)
___x 9
10 College of St. Francis Wilcox and Taylor Streets 11 Joliet, Illinois 60435 12 Monday, June 9, 1986.
13 The hearing in the above-entitled matter reconvened 14 at 2:00 P.
M.
15 16 BEFORE:
17 JUDGE HERBERT GROSSMAN, Chairman Atomic Safety and Licensing Board I
18 U. S. Nuclear Regulatory Commission Washington, D.
C.
JUDGE RICH ARD F. COLE, Member, 20 Atomic Safety and Licensing Board U.
S. Nuclear Regulatory Commission 21 Washington, D. C.
l 22 JUDGE A. DIXON CALLIH AN, Member, 1
Atomic Safety and Licensing Board 23 U.
S. Nuclear Regulatory Commission Washington, D. C.
24 APPEARANCES:
()
25 On behalf of the Applicant:
AnnnFag Dopnrki ng Marvice. Ltd.
Geneva, Illinois 60134 (312) 232-0262 L
3412 O
1 MICHAEL I. MILL ER, ESQ.
2 EL EN A Z. KEZELIS, ESQ.
Isham, Lincoln & Beale 3
Three First National Plaza Chicago, Illinois 60602 4
On behalf of the Nuclear Regulatory 5
Commission Staff:
6 ELAINE I.
CHAN, ESQ.
GREGORY ALAN BERRY, ESQ.
7 U.
S. Nuclear Regulatory Commission 7335 Old Georgetown Road 8
Bethesda, Maryland 20014 9
On behalf of the Intervenors:
ROBERT GUILD, ESQ.
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24
()
Sonntaa Reportina Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
3413 O
1 EXHIBIT INDEX Marked Received 2
Intervenors' Group Exhibit No. 35 3428 3440 3
Applicant's Group Exhibit 4
No. 13 3499 5
TESTIMONY OF ANTHONY SIMILE (Continued) 6 CROSS EXAMINATION (Continued)
BY MR. GUILD:
3415 7
CROSS EXAMINATION 8
BY MS. CHAN:
3441 9
BOARD EXAMINATION BY JUDGE COLE:
3446 10 REDIRECT EXAMINATION 11 BY MR. MILLER :
3450 12 BOARD EXAMINATION
()
BY JUDGE CALLIH AN:
3467 RECROSS EXAMINATION 14 BY MR. GUILD:
3471 15 REDIRECT EXAMINATION (Continued)
BY MR. MILLER:
3485 16 BOARD EXAMINATION 17 BY JUDGE CALLIHAN:
3486 18 REDIRECT EXAMINATION (Continued)
BY MR. MILLER :
3487 19 BOARD EXAMINATION 20 BY JUDGE GROSSMAN:
3496 21 REDIRECT EXAMIN ATION (Continued)
BY MR. MILLER :
3497 22 BOARD EXAMINATION 23 BY JUDGE GROSSMAN:
3497 24 REDIRECT EXAMINATION (Continued)
BY MR. MILL ER :
3498 CE) 25 om..e.c o,emreinc m.r.1-,,
r a.
Geneva, Illinois 60134 (312) 232-0262
3414 O
1 JUDGE GROSSMAN:
The hearing is reconvened.
2 This is the 16th day of hearing.
3 We ended on Friday with Mr. Cuild cross-examining 4
Mr. Simile.
5 Mr. Simile, you remain sworn.
6 Mr. Guild, you may proceed.
7 MR. MILLER :
Your Honor, before Mr. Guild 8
resumes his examination, it was called to my attention 9
that the copies of the AWS D1.1-1975 code that we passed 10 out on Friday had highlighting which did not Xerox well, 11 and so I have clean copies of the code, which I'd be 12 happy to pass out to the Board and to the parties.
13 (Indicating.)
14 MR. BERRY:
This was marked as Exhibit No. --
15 MR. MILLER:
I'm trying to determine that.,
16 JUDGE CALLIHAN:
33.
17 MR. MILLER:
No, no, no.
It's an Applicant's 18 exhibit.
19 JUDGE CALLIHAN:
Excuse me.
I beg your 20 pardon.
21 12.
22 JUDGE GROSSMAN:
Is there some more 23 housekeeping now?
l 24 MR. MILLER:
I don't think so.
25 I also have copies of AWS D1.3.
(}
l Sonntac Reportino Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
3415
()
1 JUDGE GROSSMAN:
Oh, okay.
I wa's going to 2
ask you about that.
3 MR. MILLER :
Unless the Chairman has 4
questions on it immediately, I think I'd like to consult 5
with someone --
6 JUDGE GROSSMAN:
That's fine.
7 MR. MILLER:
-- about it.
I think I have 8
three different editions here, and I want to make 9
certain which ones.
10 JUDGE GROSSMAN:
All right.
11 Why don't you just proceed, Mr. Guild, with your 12 cross examination.
13 MR. GUILD:
Thank you, Mr. Chairman.
14 Good afternoon, Mr. Simile.
15 THE WITNESS:
Good afternoon.
16 CROSS EXAMINATION 17 (Continued) 18 BY MR. GUILD:
19 Q
On Pages 19 and following of your profiled testimony, 20 beginning with Question and Answer 24, you address the 21 topic of certain complaints by QC Inspectors regarding 22 the Sargent & Lundy cable pan hanger walkdown program --
23 A
Yes.
24 0
-- correct?
(])
25 Now, can you identify the nonconformance report
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i.g s..
4.,. a.
Geneva, Illinois 60134 (312) 232-0262
3416 O
1 that was the basis for that walkdown program, please?
l 2
A CECO NCR 708 and 709.
3 0
What were the nonconforming conditions that were the 4
subject of those nonconformance reports, please?
5 A
I believe it was the vendor-supplied hsngers.
6 Q
Now, when you say a " vendor-supplied" hanger, are you 7
referring to a hanger that was fabricated by another 8
vendor but that was installed by Comstock?
j 9
A Yes.
10 0
And who was the vendor who supplied the vendor-supplied 11 hangers in question?
12 A
System Controls.
13 0
System Controls Corporation?
14 A
I believe; System Controls.
15 Q
Do you know if their formal name is System Controls 16 Corporation?
1 17 A
No, I do not.
18 0
And what was the nature of the nonconforming conditions 19 regarding the Systems control-supplied hangers?
l 20 A
The vendor welds as far as --
21 0
The welding -- I'm sorry?
22 A
As far as I can remember, it was the welding f rom the 23 vendor.
24 0
You don't recall specifically what the nature of the l
(])
25 nonconformance was?
i Sonntaq Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262 i
3417 O
1 A
No, sir.
2 0
But your recollection is that it had to do with the 3
quality or acceptability of the welds performed by 4
System Controls Corporation or Systems Control in the 5
f abrication of the hangers?
7 6
A Yes, sir.
7 0
All right.
8 Now, is it correct that as a part of the corrective 9
action for that nonconforming condition, there was 10 developed what you've described in your testimony as the 11 Sargent & Lundy cable pan hanger walkdown program?
12 A
Yes.
13 Q
Now, do I understand correctly that the essence of thap 14 program is that the hangers in the field were I
15 essentially as-built; that drawings were made reflecting 16 the as-built condition of those hangers; those as-built 17 conditions were reviewed by Sargent & Lundy engineers 18 for design acceptability and/or hangers were reworked as 19 needed; and that the final as-built condition of the 20 hangers as approved by Sargent & Lundy was then 21 incorporated in revised design drawings?
l 22 A
Originally what they did -- S & L drew the hanger onto 23 one drawing, and that drawing was taken to the field 24 with an S & L engineer and one of Comstock's QC
(}
25 Inspectors.
MannFag Reparting Service. Ltd.
Geneva, Illinois 60134 (312) 232-0262
3418 O
1 The drawing was compared to the hanger as it was 2
installed in the field; and if the hanger differed from 3
the drawing that was given by S & L, those items were 4
red-lined and concurred with by both the engineer and 5
the inspector.
6 That drawing was returned to Engineering for an 7
analysis.
8 0
All right.
9 Then I think I stated the following:
If the 10 red-lined version, the as-built version, of hanger 11 configuration was deemed acceptable by Sargent & Lundy 12 Engineers, that 'as-built configuration was accepted and 13 incorporated in a revised design drawing?
14 A
There was a Rev. A drawing issued.
That Rev. A drawing 15 was then compared to the red-lined drawing by an
'l 16 inspector to ensure that they both did agree, and then 17 the hanger was accepted for configuration, yes.
l 18 0
All right.
19 Now, normally -- do I understand correctly that 20 normally the function of the Comstock inspectors was to 21 inspect these vendor-supplied hangers for configuration?
22 A
Yes.
23 0
All right.
24 And they evidenced their acceptance of those
(])
25 hangers by the completion of a Form 7?
Sonntaq Reporting Service, ___ Ltd.
Geneva, Illinois 60134 (312) 232-0262
_ - _ _ _ ~ _
3419 i
O 1
A Yes.
2 Q
Now, attached to your testimony, the last attachment is 3
a series of documents that describe the revised hanger 4
walkdown program; correct?
5 A
Yes.
6 Q
That's not the original hanger walkdown program, is it?
7 A
No, it isn't.
i l
8 Q
I'm looking at a Commonwealth Edison Company June 27, l
9 1985, letter to Comstock with an attached procedure.
10 MR. GUILD:
Judges, it's at the very end of 11 Mr. Simile's testimony, the very last attachment, a 12 multi-page document.
13 BY MR. GUILD:
14 Q
Do you have that before you, Mr. Simile?
15 A
Yes, I do.
I 16 Q
All right, sir.
4 17 Now, if you turn to the second to the last page in i
18 that attachment, I see a form in the right bottom corner 19 that has Form No. 7 on it.
l 20 Is that the configuration inspection checklist; I
21 A
Yes, sir.
s i
22 JUDGE COLE:
Excuse me.
I'm not sure I'm r
23 with you.
24 MR. GUILD:
Judge, the second to the last
]
25 page of the folder.
'l p
i ca==*=a n nar ina c ryic.. r.ea e
Geneva, Illinois 60134 (312) 232-0262
3420
(
1 JUDGE COLE:
It's the third --
4 2
MR. GUILD:
I miscounted.
Sorry.
3 JUDGE COLE:
Okay.
I see it.
Thank you.
4 BY MR. GUILD:
5 Q
Now, the form as it appears here is not a Form 7, is it?
3 6
A It's a Form 7 with the two additional remarks in the 7
remarks section added.
8 Q
All right.
9 So the remarks were added to the Form 7 as part of
)
10 the revision to the walkdown procedure that is described 11 in the June 27th transmittal that's attached to your 12 testimony; correct?
13 A
Yes.
14 Q
All right.
]
15 But am I correct in my understanding that the 16 original Form 7, as used by your configuration i
17 inspectors, contained simply blank spaces under the 18 remarks section which were to be filled out by the 19 inspector in the field?
20 A
Yes.
21 Q
Pardon me?
I 22 A
Yes, sir.
23 Q
All right.
24 Now, let me ask you a few more questions about the 25 procedure as it existed originally with the walkdown
[}
i f
Sonntaa Reporting _Ettvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
3421 O
1 program.
2 Now, is it correct that the changes reflecting the 3
deviations between the field-observed condition, the 4
as-built condition, and the design drawing with which 5
the walkdown was performed -- that those design 6
differences were red-lined on the design drawing?
7 A
Yes.
8 Q
In essence, the deviations from design in the as-built 9
condition were marked in red pencil on the drawing 10 itself?
11 A
Yes.
12 Q
The QC Inspector, then, the Comstock inspector, under 13 the original program was asked to complete the Form 7 in 14 its original form without the added notations in the 15 remarks block and to sign and date that form, indicating 16 only that he, the QC Inspector for Comstock, had 17 compared the red-lined drawing with the field-observed 1
18 condition and that he agreed that the red-lined drawing 19 accurately reflected the observed field configuration?
20 A
Yes.
21 Q
Subsequently with the revision that you attached to your 22 testimony, that practice was changed, was it not?
23 A
Yes, it was.
24 Q
Now, under the original hanger walkdown program, am I
(]}
25 correct, then, that when the red-lined field drawing l
Annntag RepntH ng Amrvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
3422 0
1 came back out of the field, two things happened in 2
substance:
3 First, there was an engineering evaluation and 4
determination that the as-built red-lined condition was 5
acceptable; is that right?
6 A
S & L analyzed the hanger was it was built, yes.
7 Q
And either rejected or accepted the as-built condition?
8 A
Yes.
9 Q
The deviation f rom the original design?
10 A
Yes.
11 Q
All right.
12 And the second thing that happened was a Quality 13 Control Inspector employed by Comstock would then take 14 the red-lined drawing that was made in the field and 15 compare it with the final revision of the drawing that 16 had incorporated the red-lined features te determine 17 that the final design drawing accurately incorporated 18 the red-lined changes?
19 A
Yes.
20 Q
All right, sir.
21 Now, what was your role in this walkdown program, 22 Mr. Simile?
23 A
I was the supervisor.
24 Q
All right.
/]}
25 And who did you supervise in the performance of Sonnt;a_g RepqdiCgryicef_ Ltd.
Geneva, Illinoio 60134 (312) 232-0262
3423 O
1 this walkdown program?
2 A
I -- there were five inspectors that were involved with 3
this program.
4 Q
And were they Level II inspectors?
5 A
'Yes, they are.
6 0
Were they welding and configuration inspectors?
7 A
Yes.
8 Q
Can you identify them by name, please?
9 A
Bruce Brown, Larry Perryman, Mickey Gerrish --
10 JUDGE GROSSMAN:
Could you spell that, 11 please?
12 THE WITNESS:
I t ' s G-E- R-R-I-S-H.
13 A
(Continuing.)
I can't remember the other two 14 initially.
15 BY MR. GUILD:
16 Q
There were two others?
i 17 A
Yes.
There were five.
18 Q
How about Ron Lamb?
19 A
Ron Lamb was a reviewer.
20 Q
He was a --
21 A
He was not walking the hangers down.
i 22 Q
Was he a document reviewer?
23 A
He was a Level II inspector that reviewed the red-lined 24 drawings when they came back with the Rev. A drawings.
I
(])
25 Q
He performed the second quality control function I asked i
cannemg nannrefng n tyica. r+d.
I e
l Geneva, Illinois 60134
(
(312) 232-0262
3424 1
you about?
2 A
Yes.
3 0
All right.
4 He was not one of the five that you counted, 5
though?
6 A
He was not one of the inspectors walking the hangers 7
down, no.
8 0
And there were two others aside f rom Messrs. Brown, 9
Perryman and Gerrish, and you simply can't recall them 10 today?
11 A
Right.
12 0
All right, sir.
}
Now, when you state in your testimony at Page 19 13 14 that -- I'm sorry; Page 20, the bottom of the page, last 15 paragraph, "Several Comstock QC Inspectors complained 16 about the program," can you identify who -- which 17 inspectors made such complaints?
18 A
They all came over as a group.
19 0
When you say "all," who are you speaking of ?
20 A
It was the five that were doing the walkdown.
21 Q
So not just some inspectors; all the inspectors involved 22 in the walkdown program complained?
23 A
The five that were doing the actual field inspection, 24 yes.
25 0
Were there any others dcing the walkdown program?
{ Sonntan Reportifo Service,_Ltil. Geneva, Illinois 60134 (312) 232-0262
i 3425 O 1 A There were inspectors reviewing the Rev. A's to the Rev. 2 0's, yes. 3 Q That was Mr. Lamb and others? 4 A Yes. 5 0 Okay. 6 Now, you state that their main complaint was that 7 the work they were doing was more appropriate for a 8 Level I inspector. 9 Are you saying that, in effect, as yott state here, 10 their main complaint was that they were being asked to 11 do work that was too menial for their level of skills? 12 A I think that was part of it. ( I think part of it was that they were taking the 13 14 information and the data and, in their minds, they were 15 signing off for the configuration at the bottom when, in 16 essence, they weren't. 17 0 Well, wasn't that, in fact, their main complaint and not 18 anything about the trivial character or the menial 19 character of their work? 20 A The main complaint was were they accepting the hanger or j l 21 not; and when it was explained to them that they 22 weren't, then this other part of it came out, yes. l 23 0 Well, sir, their main complaint was, was it not, that by l 24 signing the Form 7 as it appears as an attachment to 25 your testimony, the third page f rom the end, without any (} % u g_a. m, m..., m Geneva, Illinois 60134 (312) 232-0262
3426 O 1 further notations on the face of the form, that pursuant 2 to the configuration inspection procedures of Comstock, 3 by dating and signing the form, they would be evidencing 4 the complete inspection and acceptance of all of the 5 above attributes of those hangers? 6 A only to the red-lined drawing. 7 Q But wasn' t their concern expressed to you, sir, that by 8 signing the Form 7, they would be evidencing greater -- 1 9 broader inspection findings than were, in fact, the 10 extent of the narrow inspection they were performing? 11 A Yes. They felt they were accepting the hanger. 12 Q And accepting it to all of the acceptance criteria that 13 are shown on Form 77 14 A Yes. 15 Q And that included, among other things, the welds on the 16 hanger, did it not? 17 A No, sit. 18 0 The signing of the Form 7 doesn't evidence an inspection l 19 of the welds -- l 20 A No, sir. 21 Q -- is that your testimony? 22 Did the inspectors express to you, as you recall, a l 23 concern that their inspection might be taken as I 24 evidencing an inspection of the welds on the hangers? l ] 25 A originally when the program first started, we had talked Sonntaa Reportino Service, Ltd. ( Geneva, Illinois 60134 l (312) 232-0262 L
i 3427 O 1 about inspecting the welds and the configuration both. 2 At that time it was established that only the i 3 configuration inspection would be done. 4 There's a separate form for the weld inspection 5 which we did not use for this program. 6 Q All right. 7 So you don't recall any inspectors -- that wasn' t 8 cractly responsive to my question, I don't believe, but 9 I'll ask it another way. 10 You don't recall, you say, any concerns expressed i 11 by these inspectors that their inspection would be taken 12 as representing an inspection of not only the ( 13 configuration but the welds? 14 A No. 15 Q You do recall, though, that the concern was that all of 16 the configuration acceptance criteria would be taken as i 17 approved when they signed the Form 7? l 18 A How they felt about it, yes, i 19 Q All right. l 20 Mr. Simile, I want to show you a series of 21 documents, please. 22 Mr. Simile, do you have before you three Read and i 23 Reply Memos? l 24 A Yes, I do. l 25 Q They are dated chronologically, beginning with the [} .....g..em. 1 g.. 4m., r 2. Geneva, Illinois 60134 (312) 232-0262
3428 ("% V 1 earliest, 5/8/85, S/13/85 and 5/17/85. 2 The earlier of them is f rom Mr. Perryman to you, 3 Mr. Landers and Mr. Schriener? 4 A Schriener. 5 Q Okay. 6 The 5/13 document, Mr. Perryman to Mr. DeWald; and 7 the 5/17 document, Mr. Perryman to you, Messrs. DeWald, 8 Seltmann and Schriener. 9 Can you identify these documents, Mr. Simile? 10 A Yes, sir. 11 Q Have you seen them before? 12 A Yes, sir. 13 Q Did you receive copies of them at the time they were 14 written or thereaf ter, shortly thereaf ter? 15 A Yes. 16 MR. GUILD: Mr. Chairman, I'd ask that these 17 three documents as a group be marked for identification 18 as Intervenors' Exhibit 35. 19 JUDGE GROSSMAN: So marked. 20 (The documents were thereupon marked 21 Intervenors' Group Exhibit No. 35 for 22 identification as of June 9, 1986.) l 23 BY MR. GUILD: 24 Q Now, the first of these documents, the 5/8/85 document 25 entitled "Transf er," represents Mr. Perryman's request (} Sonntaa Repor tina Service, _.Ltd. Geneva, Illinois 60134 (312) 232-0262
's 3429 () 1 to you and others that he be transferred f rom the i 2 Sargent & Lundy cable pan hanger walkdown program back 3 to his normal duties of -- back to his normal duties of i 4 in-process weld and configuration inspections; correct? 5 A Yes. 6 Q Now, did Mr. Perryman make this written complaint to you 7 af ter he and the four other walkdown inspectors came to 8 you with their concerns? 9 A I'm not sure. 10 Q All right. 11 You received this request, did you not? 12 A Yes, I did. 13 Q And did you reply in writing to it? 14 A This request -- the first request that I received was on 15 5/7/ 85. 16 0 Was that in writing, a written document? 17 A Yes, it was. l 18 Q Was it a Read and Reply Memo? 19 A Yes, 'it was. 20 0 Did you respond to that? 21 A Well, the second request I got was 5/8. 22 Q so this was the second request you got? l 23 A So I hadn't had much time to really evaluate it when the 24 second request came through. 25 Q The answer, then, is that you didn't respond to the 5/7 (} nm...e s.pm.e4 e n.. 4e., tea. Geneva, Illinois 60134 (312) 232-0262
3 3430 () I request in writing? 2 A No,.I didn t. j 8 3 Q-Did you respond to this, the second request, the 5/8 f 4 request, in writing? 5 A No, I didn't. 6 Again, I still didn't have enough time to evaluate 7 the transf er of Mr. Perryman at the time and at the date 8 and where the job was at when he requested the transfer. 9 Q All right, sir. Let's look at the second document, the 10 5/13/85 request. 11 Mr. Perryman there correctly states, does he not, 12 that he had sent in two previous requests to be 13 transf erred, a 5/7 and a 5/8 request? 14 A Yes, sir. 15 Q He ends, "I think it is irresponsible and bad management 16 practice between supervisors and inspectors not to 17 answer written requests. " 18 You responded to that one, didn't you? 19 A Yes, I did. I had a few days to evaluate the situation l 20 with the cable pan walkdown. I 21 It was a short-term project and we expected to have 22 it completed shortly, so I elected not to transf er him 23 at that time. 24 Q And your answer doesn't state what you just said. It 25 says on the f ace of this Read and Reply Memo, " Transfer (} l Sonntaa Reporting Service, Ltd. Geneva, Illinois 60134 (312) 232-0262
3431 () 1 is not possible at the present time." 2 That's your name, isn' t it? 3 A Yes, it is. 4 Q Did you pass the memo on, then, to Mr. DeWald, the 5 manager? 6 A Yes, I did. 7 Q And that's Mr. DeWald's handwriting below yours, is it 8 not? 9 A Yes, sir. 10 Q All right, sir. 11 Now, had you talked to Mr. Perryman and the four 12 other walkdown inspectors to hear their complaints about 13 the use of their signing the Form 7, the purpose to 14 which that Form 7 was put, before you got the 5/13 l l 15 request for transfer? 16 A Only going by dates, which -- I think Rev. C was the 17 date that we changed the Form 7, which was 5/21, so at i 18 that time I really can' t say if I did or not. l 19 0 Well, you're looking at a date in your attachment; 20 correct? 21 A Right. 22 0 And that's the date on which the revision was effective; 23 is that right? 24 A Yes. 25 0 Okay. {} -..eec .per.1 y m.r.4., r. a. Geneva, Illinois 60134 (312) 232-0262 l
3432 0 1 The revision that made the change to the Form 7 2 noting the -- making the notes in the remarks section? 3 A Yes. 4 Q All right. 5 5/17/ 85, the third memo in this exhibit -- and I 6 gather the fourth memo f rom Mr. Perryman on the subject; 7 correct? 8 A Yes. 9 Q Here Mr. Perryman renews his request and states, "I was 10 informed that I was verifying the as-built dimension 11 inf ormation of the hangers," B-G-R-S; correct? 12 Is that the abbreviation for " hangers"? 13 A Yes. 14 Q "And this inf ormation was not to determine" -- can you 15 make out that word? 16 A Actual. 17 0 " actual acceptance in any way, shape or form other 18 than my own review at a later date for these hangers" -- 19 correct? 20 A Yes. 21 Q Is he referring, do you understand, to his later review 22 as a configuration inspector? 23 A Yes. 24 0 All right. / 25 "to,an approved design document. Any intention {]) Sonntao Reporting Service, Ltd. Geneva, Illinois 60134 (312) 232-0262 ~
3433 O 1 of use of the Form 7's I have signed up to this date, 2 other than dimensional verification, was not my intent. 3 "At this time I wish to make corrections to my Form 4 7 's in accordance to Procedure 4.13.1 to reflect this 5 fact." 6 Did you get that memo? 7 A I would say yes. 8 Q Well, you might say yes, but did you get that memo? 9 A I -- I'm not sure. 10 Q Did you reply to that memo? 11 A I don' t see my name anywhere on it. 12 O Well, I don't, either, Mr. Simile, but could you answer 13 the question directly, please? 14 Did you -- 15 A I don't know. 16 JUDGE GROSSMAN: Well, if you had replied, l 17 would your name be on that memo? i 18 THE WITNESS: Yes, normally. There was a j 19 transfer made, if that's what you' re asking. 20 MR. GUILD: Yes. I'm going to ask you about 21 that in just a moment, Mr. Simile. 22 BY MR. GUILD: 23 Q Wasn' t Mr. Perryman, the author of this memo, in fact, 24 transferred not back to configurations and welding but 25 to the night shift for termination inspections? (} snnneng n.pnreing s ruic _ r+ a. Geneva, Illinois 60134 (312) 232-0262
3434 i 1 A Yes, he was. 2 Q And didn' t you, in fact, come into the QC trailer and 3 address Mr. Perryman and Mr. Bossong, another one of the 4 inspectors, in front of the other QC Inspectors who 5 worked on the walkdown and say in substance, "Come see 6 me after work. You have been transferred, and you won't 7 like where you are going"? 8 A I did go over and see them and tell them to see me af ter 9 they were finished about their transfers. 10 Q And did you say those words or words to that effect? 11 A Yes. 12 0 Were you aware, when you made that transfer of Mr. ( Perryman to the night shift for termination work, that 13 14 Mr. Perryman had expressed these concerns that are 15 reflected in his 5/17/85 memo, the concerns that were 16 expressed to you by he and the other four walkdown 17 inspectors? 18 A Yes, I was, and that's why we revised the supplement for 19 the NCR's. 20 Q And that's why you transferred him to night shif t for l 21 termination work? 22 .A No, sir. I 23 Q I see. 24 A The reason he was transferred -- l 25 Q Well, sir, I didn't ask you that. Perhaps someone else [} Sonntag Reporting Service, Ltd. Geneva, Illinois 60134 (312) 232-0262
3435 O 1 would like to. 2 But your statement is you didn't transf er him in 3 retaliation for having expressed these concerns; is that 4 your testimony? 5 A That'c correct. 6 Q All right, sir. 7 Were you aware that Mr. Perryman didn't like night 8 shif t work generally; that if he had a choice, he would 9 not choose night shif t work? l 10 A There was a situation at that time where a second shif t 11 had started and -- 12 0 If you would just answer that question, Mr. Simile, 13 please, I'd appreciate it. 14 A He never told me personally. 15 Q Well, you were aware he didn't like where he was going; 16 you said that to him? 17 A No, sir. t 18 Q You don't recall ever saying that to him? 19 A No. 20 0 You don't recall saying to him, "And you won't like 21 where you're going"? l 22 A No, sir. l 23 0 Were you aware that Mr. Perryman's mother was suffering l l 24 a fatal illness at that time? 25 A No, si r. [} snnnean nonnreino s.ruic. r+a _ Geneva, Illinois 60134 (312) 232-0262
3436 O 1 Q Are you aware that she subsequently died? 2 A Yes, sir. 3 0 And you're aware that in part he said he didn't want to 4 be transf erred to the night shif t because it would keep 5 him f rom being at home with his dying mother? 6 A No, sir. 7 Q You weren't aware of that when you transferred him? 8 A No, sir. 9 Q You learned of that later? 10 A The day he was transferred, he told me that it was 11 unf air for me to do that; that he was going to the Labor 12 Relations Board and I would hear f rom them. ( 13 When he got on second shift, he did not request to i 14 be taktn back off. In fact, at that time he was deemed 15 to be the second shift steward for the union and elected 16 to stay there. 17 0 Well, aren't you aware that his mother died several days l 18 after you transferred him to the night shift? 19 A Yes, sir. l 20 Q And that that obviated the personal reason why i 21 transferring him to the night shift was something that 22 he was strongly against? 23 A No, sir. 24 Q Didn' t you, in fact, change the procedure, as Mr. 25 Perryman and the others had sought, on the very day you (} Sonntaq Reporting Service, Ltd. i Geneva, Illinois 60134 (312) 232-0262
3437 O 1 transferred him to the night shift for terminations? 2 A It could have been that day, yes. 3 Q Are you aware that Mr. Perryman went to Mr. DeWald to 4 seek Mr. DeWald's support in trying to reverse your 5 decision to transfer him to the night shift? 6 A Yes, sir. 7 Q And didn't you, in fact, go to Mr. DeWald and talk Mr. 8 DeWald out of transferring him back to day shift? 9 A Mr. DeWald and I concurred that the second shif t 10 transfer was needed at that time. 11 Q Mr. DeWald then responds on the 31st of May to Mr. 12 Perryman's May 17th Read and Reply Memo; I quote, 13 " Transfer from walkdown is granted. Supplement has been 14 revised to include your concerns." \\ 15 A Yes, sir. 16 Q That reflects Mr. Perryman's transfer not to where he 17 wanted to go but to the night shift; correct? 18 A That's correct. 19 0 And that reflects the revision of the procedure l l 20 reflecting Mr. Perryman's concern, that revisien being 21 the revision attached to your testimony? 22 A Yes, sir -- well, I don' t know that it's the one ~ 23 attached. It's probably the one previous. l 24 Q Well, the revision to include the language on the Form 25 7 -- m _... _.. m_ 4 -... 4_.. tea. Geneva', Illinois 60134 (312) 232-0262
3438 O 1 A Yes. 2 0 -- correct? 3 A Yes. 4 Q Your statement is that revision of the Form 7's, 5 including the language about the limited purpose for 6 which the Form 7 's were completed -- it may hav_e been 7 added at a previous revision? 8 A I believe it was added on the May 21st revision, as 9 shown on the cover letter. 10 Q It may have been added with the revision that was 11 proposed or adopted on the very day that you transf erred 12 Mr. Perryman to the night shift? 13 A I can't remember dates. It could have been. 14 Q Now, if you look at the Attachment 1 to your Form 7 -- 15 that is, the last document in the attachments to your 1 16 testimony -- does the special note at the bottom explain 17 the revised purpose for which the Form 7's were to be 18 completed in response to the complaints by the walkdown 19 inspectors? 20 A Yes. 21 Q All right. l 22 "The Form 7's initiated prior to the date of 23 implementation of Revision 2 of this supplement were 24 completed and signed in the QC Inspector block on the 25 checklist. This signature verifies field conformance," {} Sonntac Reporting Service, Ltd. Geneva, Illinois 60134 l (312) 232-0262 l
3439 i O 1 et cetera. The ' reviewed by' statement" -- I skipped a 2 sentence there. 3 "The ' reviewed by' statement will be lined out, 4 initialed and dated. These checklists will then be 5 reviewed in accordance with Item 5 above." 6 That Item 5 refers to the second QC Inspector who 7 will perform the review of the final documentation and 8 then complete the " reviewed by" section; correct? 9 A What this did -- or entailed -- originally the walkdown 10 inspector signed in the inspector's block, and the 11 inspector that was reviewing the Rev. A to the Rev. O 12 signed in the " reviewed by" block, accepting the 13 hanger -- 14 0 I see. 15 A -- which -- in that case there was not a review by 16 another Level II for acceptance of the form. 17 So we added a third signature to the forms that 18 were done previous to this revision, which was required 19 by our procedures. 20 0 Which was what the Level II -- 21 A The Level II review only for the document for being 22 complete. 23 Q Per the procedure? 24 A Yes. 25 Q Per the pre-existing configuration procedure -- (} snnneng nonnr ei ng servi c.. r+ a. Geneva, Illinois 60134 (312) 232-0262
3440 1 A Yes. 2 0 -- for completeness and clarity? 3 A Right. 4 0 Okay. 5 And that instruction change and line-through of the 6 " reviewed by" block was in part in conf ormity with Mr. 7 Perryman's request in his May 17, '85, memo that he be 8 allowed to make supplements to all the Form 7's he had 9 completed to clarify what the intent was of his Level II 10 signature? 11 A Yes. 12 Q His signature; correct? CE) 13 A Yes., 14 MR. GUILD: Mr. Chairman, that completes my 15 examination. 16 Thank you, Mr. Simile. 17 I would move the three -- the Group Exhibit 35, the 18 three documents, in evidence at this time. \\ 19 MR. MILLER: No objection. 20 JUDGE GROSSMAN: Any obj ection? 21 MS. CH AN : No objection. 22 JUDGE GROSSMAN: Admitted. 23 (Intervenors' Group Exhibit No. 35 for 24 identification was thereupon received in 25 evidence as Intervenors' Group ExhiFit (]} Sonntaq Reporting Service, Ltd. Geneva, Illinois 60134 (312) 232-0262
3441 0 1 No. 35 in evidence.) 2 JUDGE GROSSMAN: Miss Chan? 3 MS. CH AN : Can we have a break, please? 4 JUDGE GROSSMAN: Sure. 10 minutes. 5 (WHEREU PON, a recess was had, after which 6 the proceedings were resumed as follows:) 7 JUDGE GROSSMAN: Miss Chan? 8 MS. CH AN : Yes. I'm ready. CRO'S EXAMINATION S 9 10 BY MS. CHAN: 11 Q Mr. Simile, could you please describe your duties as a 12 Level III weld inspector at Perry? 13 A I was responsible for the welding program at Perry, 14 which included the revisions of the procedures, i 15 qualification of the Level II inspectors and the 16 qualification of the welders and subsequent procedure 17 revisions to the welding program. 18 0 When you said you were responsible for revision of l 19 procedures, did that include the qualifying of those l l 20 procedures? 21 A For the welding procedures? 22 O Yes. 23 A Yes. 24 JUDGE GROSSMAN: By the way, Mr. Simile, 25 although Miss Chan is asking you the questions, the (} AnnnFag Maporti ng Service. Ltd. Geneva, Illinois 60134 (312) 232-0262
3442 \\ O 1 answers ought to be directed here -- 2 THE WITNESS : Okay. 3 JUDGE GROSSMAN: -- so we all can hear. 4 BY MS. CHAN: 5 Q How long did you hold that position? 6 A I would say approximately a year. I'm not sure of the 7 dates, so -- 8 Q Were you supervising weld inspectors, also? 9 A Yes, I was. 10 Q What level? 11 A Level II's. 12 Q How large was the welding inspection program at Perry? O k-13 A As far as inspectors? 14 Q Yes. 15 A I would say between 20 and 30. 16 0 Could you do the same thing: Describe the senior weld 17 inspector duties at the Beaver Valley nuclear station? l 18 A At the Beaver Valley station, we were responsible f or -- i l 19 Q You yourself; not "we." 20 A I was -- I was responsible for weld inspectors, yes. 21 0 Could you -- were you responsible for qualifying l 22 procedures? l 23 A No; strictly just inspections in the field. 24 0 So you only did inspections? (]) 25 A Yes. Sonntaq Reporting Service, Ltd. Geneva, Illinois 60134 (312) 232-0262 l
3443 C) 1 Q No supervisory duties? 2 A No. 3 Q Could you describe your duties as the QA Manager at Spec 4 Consultants? 5 A I was responsible for the overall QA program that we had 6 in place at the time. 7 0 Does that mean that you qualified procedures? 8 A Yes. 9 Q Did you qualify welders? 10 ' A Yes. 11 Q Did you qualify weld inspectors? 12 A Yes. 13 Q And were you supervising those inspectors? 14 A Yes. 15 Q And what level were they? 16 A They were Level II's. 17 0 And how large was the weld inspection program at Spec l 18 Consultants? l 19 A I think the most we ever had was 10. 20 0 In your position as the Level III weld inspector for 21 Energy Consultants, what were your duties? 22 A I was certified without any duties at all. I was in the 23 marketing aspect with Energy Consultants. 24 Q In all these positions you've held, was your performance 25 in these jobs evaluated in some manner? (]} l ennntag nepareing scet.4co. r+ a _ Geneva, Illinois 60134 (312) 232-0262
.3444 O 1 A Yes. 2 0 What was -- what were your ratings in your supervisory 3 positions? 4 Why don't we start with Perry? 5 A I can' t say that I've ever seen my evaluations, but I 6 would say I was rated f airly high. 7 Q How about at Beaver Valley? 8 A I would say the same. 9 Q And Spec Consultants? 10 A The same. 11 Q Were you considered part of the QC management team at 12 Perry -- 13 A Yes. 14 0 -- in the position you were in? l l 15 How about at Beaver Valley? 16 A I would say no. 17 Q How about Spec Consultants? 18 A Yes. l 19 Q And at Braidwood? 20 A Yes. ) 21 Q When I was speaking of Braidwood, I wanted to clarify 22 that I was asking if you were part of the QC management 23 in your earlier position, not the position -- ~ 24 A Yes. 25 0 -- you currently hold, (} 1 Sonntac Reportina Service, Ltd. Geneva, Illinois 60134 (312) 232-0262
3445 O 1 Were you assigned as the point of contact by -Irv 2 DeWald for Mr. Schapker of the NRC during his 3 inspections at Braidwood? 4 A I don't know if it was f rom Irv or if it was f rom CECO. 5 Q But you were -- you were his point of contact? 6 A Irv was my immediate supervisor, yes. 7 Q Were you the point of contact for Mr. Schapker -- 8 A Oh, yes, yes. 9 0 -- for LKC? 10 A Yes. 11 0 If Mr. Schapker wanted to look at LKC weld procedures, 12 would he come to you? 13 A
- Yes.
14 0 If he wanted to look at other documentation about 15 Comstock's welding procedures, would he come to you? 16 A Yes. 17 0 Is that what you meant in your testimony when you l 18 mentioned that you assisted Mr. Schapker in his 19 inspections? 20 A Yes. 21 Q I'm ref erring back now to the discussion on Friday about 22 filler material, 23 A Yes. j 24 Q Can :rou tell me if porosity and cracking are readily 1 []} 25 apparent to the welder and QC Inspector? gnnnen g nonnr ei ng.q,rvi ce, r.e a _ Geneva, Illinois 60134 (312) 232-0262
3446 O 1 A Yes. 2 0 What does Appendix E require for weld filler metal 3 control? 4 A I'm not real sure that I could just recite it. 5 Q Let me give you an example. 6 Is rod lying on the ground alone a nonconforming 7 condition or is it just that it could lead to a 8 nonconforming condition if it's installed? 9 A It could lead to a nonconforming condition if used. 10 Q Going back to the discussion about the members of your 11 car pool, who else besides Rick Saklak was in the car 12 pool with you? O 13 A Bob Seltmann and Tom Zych. 14 Q Could you spell Mr. Zych's last name? 15 -A It 's Z-Y-C-B. 16 0 What was his position? 17 A He is a QC Inspector. 18 Q With Comstock? l 19 A Yes. 20 MS. CH AN : The Staff has no further questions 21 at this time. 22 JUDGE GROSSMAN: Mr. Miller -- oh, excuse me. 23 JUDGE COLE: I have just a couple questions, 24 Mr. Simile. (]) 25 BOARD EXAMINATION Sonntaq Reporting Service, Ltd. Geneva, Illinois 60134 (312) 232-0262
3447 O 1 BY JUDGE COLE: 2 Q On Page 11 of your testimony, in response to Question 3 16, the results of your investigation and then the 4 paragraph that begins, " Summarizing the results of my 5 investigation" -- do you see that, sir? 6 A Yes. 7 Q Now, the last portion of that paragraph, where you -8 indicate that "the AWS code provides that the code 9 applicable at the time of contracting remains the 10 applicable code" -- 11 A Yes. 12 0 -- what is your basis for that, sir, and/or where does 13 it appear in the AWS code? 14 A It doesn' t appear in the code. It was an interpretation 15 by AWS, and it was published in their AWS Welding l 16 Journal. 17 Q Did you have the opportunity to further identify exactly 18 what that publication was or is and where is it? 19 A No, I didn't. 20 Q All right, sir. 21 On Page 12, I just want to make sure I understand 22 what you wrote here, sir. On the bottom of Page 12 and 23 the top of Page 13, there's some statements I would like 24 to have your explanation of. (]} 25 For example, in the last sentence that -- on Page l nnnnemg nepnrei ng service. r+ a. Geneva, Illinois 60134 (312) 232-0262
3448 i (^') 1 12 that ends on 13, you say, "All reworked welds are to 2 be replaced using the qualified procedure." 3 What's a reworked weld? 4 A What I meant here were the welds that were welded out of 5 position. 6 0 Oh, so it wasn't actually reworked; it was incorrectly 7 proceduced or you weren't qualified for that position 8 so, therefore, it wasn't a legitimate weld? 9 A Right. It would have to be reworked. 10 0 All right, sir. 11 - Now, there's a sentence that reads as follows, "The 12 disposition is that all horizontal and stainless steel l 13 overhead welds installed using the unqualified procedure 14 are to be removed." 15 I guess I don't understand how you would remove'a 16 weld. I can see redoing the weld with a qualified 17 procedure, but how do you remove a weld? 18 What did you mean by that? 19 A They were to be ground out. The weld was to be ground 20 out, removed and a new weld put in. 21 0 All right, sir. 22 With respect to the structural welding code, 23 Applicant's Exhibit 12, there were certain sections in 24 there that were referred to by Mr. Vannier; and I guess 25 I still have a problem with one section, Mr. Miller. () Sonntac Reportino Service, Ltd. Geneva, Illinois 60134 (312) 232-0262
3449 O 1 Let me see if I can find the page. 2 It's Page 86, Section 8.2.1. I still have the -- 3 the words are still covered over by a marker, and I 4 cannot determine what it says. 5 Do you have a clean copy of the American Welding 6 Society Code, Mr. Simile? 7 A It's not cican, but I can -- 8 Q Can you read what those words are to me -- 9 A Yes, I can. 10 Q -- on Page 86 under Section 8.2.17 11 A It says, " Steel base metal to be welded under this code 12 shall conform to the requirements of the latest edition 13 of one of the specifications listed below. Combinations 14 of any of the steel base metals specified may be welded 15 together." 16 JUDGE GROSSMAN: Could the Reporter please 17 repeat that? 18 (The answer was thereupon read by the 19 Reporter.) 20 JUDGE GROSSMAN: Thank you. 21 JUDGE COLE: All right. Thank you, Mr. 22 Simile. That's all I have. 23 JCDGE GROSSMAN: Mr. Miller? t 24 MR. MILLER: Thank you, your Honor. We're i (]) going to co*py that one page and substitute it. I 25 .... c..pm. m.c m.,. -.. r a_ Geneva, Illinois 60134 (312) 232-0262
3450 V, % 1 apologize again to the parties. 2 JUDGE GROSSMAN: Again, let me remind you, 3 Mr. Miller, about the first question that Judge Cole 4 had; that we aren't going to accept this testimony with 5 regard to that publication that we don't have cited to 6 us or copies of, so -- 7 MR. MILLER: Right, the interpretations of 8 Mr. Simile's -- 9 JUDGE GROSSMAN: Yes. 10 MR. MILLER : I understand that. 11 JUDGE COLE: Didn't you indicate that one of 12 your latsr witnesses would be specifically addressing O 13 that? i 14 MR. MILLER: Right; Mr. Kurtz. l 15 REDIRECT EXAMINATION 16 BY MR. MILLER: ( l 17 0 Mr. Simile, do you have before you a set of the exhibits l l 18 that were marked for identification? 19 They are the changes to the specification 2790, S & l 20 L Form 1701, two sets of welding procedures and the AWS 21
- code, 22 A
I don' t have all of them. 23 0 Are they somewhere in the room that you can get to? l 24 A I don't know. (]) 25 MR. MILLER: We'll get a copy and supply them i j Sonntaq Reporting Service, Ltd. Geneva, Illinois 60134 (312) 232-0262 L--
3451 0 1 to the witness, 2 Your Honor, I'd like to state for the record that 3 there was a question raised on Friday with respect to 4 these specification pages that were marked for 5 identification as Applicant's Exhibits 7 and 8. 6 Af ter we lef t our office, copies of the full 7 Amendment 39, 40, 41 and 42 to the specification were 8 delivered; and we'll have them here tomorrow morning. 9 I'm afraid Mr. Simile may have to come back, but I'd 10 like to conduct my examination of Mr. Simile on these 11 documents, if I may. 12 JUDGE GROSSMAN: Sure. 13 BY MR. MILLER: 14 0 Mr. Simile, turning first to Applicant's Exhibit No. 7, 15 could you describe for us what welding codes, if any, 16 are specified for use in the Comstock scope of work? 17 A There are three codes specified. l 18 0 And what are they? 19 A The ASME Section 9, AWS D1.1 and AWS D1.3. 20 0 All right, sir. 21 And where do you find that in Exhibit 77 22 A It's listed under 401.18 for welders qualification, 23 401.19.1, 401.19.1 Paragraph E and 401.19.2. 24 JUDGE CALLIHAN: Excuse me, Mr. Miller. () 25 Mr. Simile, can you give us a more complete smn.tec m.pmt i.c m.r.4m.. ,, a. l Geneva, Illinois 60134 (312) 232-0262
3452 0 1 designation to that which you refer to as ASME Section 2 9? 3 THE WITNESS: It's the ASME boiler and 4 pressure vessel code, Section 9. 5 JUDGE CALLIH AN : Thank you. 6 BY MR. MILL ER : 7 Q Mr. Simile, to your knowledge, which codes have been a applied to the Comstock scope of work at Braidwood? 9 A AWS Dl.1. 10 Q Have you had occasion to review this specification f rom 11 time to time prior to today? 12 A Yes. 13 Q What is your understanding of the reference to the ASME 14 boiler and pressure vessel code, Section 9, and AWS 15 D1.3? 16 A My understanding is that if we elected to use those 17 codes for this criteria, then we were allowed tot it was i 18 acceptable. 19 0 When you say "we," who are you referring to, sir? 20 A Comstock. 21 0 To your knowledge, did Comstock ever make such an 22 election? t l l 23 A No. 24 0 Why not? l (]} 25 A Our procedures have already been qualified to D1.1-1975. Sonntac Reporting Service, Ltd. Geneva, Illinois 60134 (312) 232-0262
3453 O 1 The welders had already been qualified to D1.1-1975. 2 They were used to using the procedures, and we felt it 3 unnecessary to make any changes. 4 Q Turning, if you would, Mr. Simile, to Applicant's 5 Exhibit 8 for identification, could you point out for 6 the Board and the parties where the welding codes which 7 were applicable to Comstock's scope of work are 8 specified in that document? 9 A 401.18.1. 10 Q And which codes are specified there? 11 A There is AWS D1.1, which is specified; and at the option 12 of the contractor, D1.3 may be used and again welders 13 could be qualified using D1.1, D1.3 or the ASME code 14 Section 9. 15 0 All right. 16 Af ter this Amendment 42, which is indicated in the 17 right-hand margin of Applicant's Exhibit 8 for 18 identification, what codes -- what welding codes were 19 actually in use for the Comstock scope of work at 20 3raidwood? 21 A AWS D1.1-197 5. 22 MR. GUILD: I'm sorry. Was that question 23 "after" or "at"? 24 MR. MILLER: After this amendment -- 25 (Indicating.) ({} ..em. 4 g m. 4m., tea. mm.... Geneva, Illinois 60134 (312) 232-0262
3454 /~N N_] 1 MR. GUILD: Thank you. 2 MR. MILLER: -- 42. 3 BY MR. MII LER : 4 0 Now, Mr. Simile, turning back for just a second to S Exhibit 7 for identification, the last page of that, 6 Paragraph 401.19.1, refers to a Form 1701. 7 Do you see that? 8 A Yes. 9 0 What do you understand that Form 1701 to refer to? 10 A It is Sargent & Lundy's standard specification for 11 welding and steel construction. 12 Q All right, sir. 13 And have you had occasion, since you've been 14 employed at the Braidwood site, to review that Form 15 17017 16 A Yes. 17 Q And is that the document that has previously been marked 18 as Applicant's Exhibit 9 for identification? 19 A Yes. 20 0 Okay. 21 What welding code, if any, is specified in that 22 standard specification Form 17017 23 A AWS D1.1. 24 0 Is there any other welding code specified there? 25 A The ASME Section 9 is specified, yes, for nuclear work. {} Sonntaq Reporting Service, Ltd. Geneva, Illinois 60134 (312) 232-0262
3455 O 1 0 Where is that? 2 A Page A-1, " Additional Requirements f or Nuclear Saf ety 3 Related Work." 4 0 And that refers, does it not, to certain specified 5 components on which the work is to be performed? 6 A Yes. 7 Q Are any of those components within Comatock's scope of 8 work? 9 A No. 10 0 Mr. Simile, you arrived at the Braidwood site on August 11 28th, I believe,1984. 12 When did you first see the specifications, Sargent O 13 & Lundy Spec 2790 and the Form 170l? 14 A It was either the first day or the second day I was i 15 there. 16 0 Was this part of your indoctrination to the Braidwood 17 site? 18 A
- Yes, 19 Q
I'd now like you to turn, Mr. Simile, to Applicant's j 20 Exhibit 10 for identification, which is Procedure 4.3.3, 21 Revision C. l 22 When did you first see this document, Mr. Simile? 23 A This was the welding procedure that was in effect at the 24 time that I arrived on-site. 25 0 How soon af ter your arrival did you get a copy of this? () m, e.y..per ime m.r.4-., tea _ e e Geneva, Illinois 60134 (312) 232-0262 l
I 3456 i O 1 A I would say within the first two days. 2 0 All right. 3 Now, Mr. Simile, I'd like you to describe for the 4 Licensing Board and the parties how, using Applicant's 5 Exhibit 10 for identification, one can establich what 6 base metals are qualified by the Comstock procedure. 7 A The first section that talks about the qualifications of 8 which base metals apply is on the first page of the 9 procedure, Section 2 in the scope, which states, 10 " Structural welding code is applicable to the base 11 metals specified in AWS Dl.1-75, Section 8.2 and 10.2, 12 or as specified by a weld procedure test record." 13 Again on the first page in Section 3.1, base metal, 14 " Steel will comply with the specifications of AWS 15 D1.1-75, Paragraph 8.2 and 10.2, or as specified by a 16 welding procedure test record." 17 Q Mr. Simile, could you differentiate for us between a 18 prequalified welding procedure and a welding procedure 19 that is specially qualified? 20 A A prequalified welding procedure would be a procedure 21 meeting the parameters set by AWS. 22 A procedure qualification would be a qualification 23 where one of the parameters f alls outside of AWS 24 recommendations. (]} 25 0 All right. Sonntaa Reportino Service, Ltd. Geneva, Illinois 60134 (312) 232-0262
3457 O 1 In the paragraphs that you've just read into the 2 record f rom Applicant's Exhibit 10, there's a ref erence 3 to a welding procedure test record. 4 A Yes. 5 0 Is that for a prequalified weld procedure or a specially 6 qualified weld procedure? 7 A This would be a specially qualified weld procedure with 8 the parameters f alling outside of AWS Dl.l. 9 0 Now, I'd like to call your attention, Mr. Simile, to 10 Attachment O to this procedure. I always have a little 11 trouble finding these myself. It's about two thirds of 12 the way back. The reference " Attachment 0" is simply 13 typed in near the bottom of the page. 14 Perhaps I might just display it to the Board. 15 (Indicating.) 16 JUDGE COLE: Does it have a number on tbe 17 bottom of the page? 18 It might be easier to find that way. 19 MR. MILLER : Mine does not, I' m sor ry to say. 20 JUDGE CALLIH AN : 7 21 MR. MILLER : Yes, Attachment O. 22 (Indicating.) l 23 BY MR. MILLER: I l 24 Q Now, first of all, Mr. Simile, could you describe for 25 the Board and the parties what these various attachments [} nnnnean n onn r ei nn s.rvic. r.e a _ Ge5eva', I1115ois 60134 (312) 232-0262
3458 0 1 are, including Attachment 0? 2 A These are procedure qualification test records of 3 qualifications that Comstock had perf ormed. 4 Q Now, there's a ref erence on Attachment 0 to " ASTM 5 A446-A500B." 6 Do you see that? 7 A Yes. 8 0 What does that indicate, sir? 9 A That indicates the two base metals that were used for 10 the procedure qualification. 11 Q All right. 12 To your knowledge, was A446 material being welded 13 to A36 material in accordance with the parameters 14 specified in Attachment 07 ( 15 A Yes. I 16 0 All right, sir. 17 Was that a qualified procedure, Mr. Simile? 18 A Yes. 19 0 Would you please explain the basis for your answer? 20 A It again goes back to Procedure -- the first page of 21 Procedure 3.1.1, which states that, "The steel shall 22 comply with Paragraph 8.2 and 10.2 of AWS. " 23 The weld procedure specification lists the material 24 as not listed in AWS for the qualification.
- However, 25 this does not prohibit Section 8.2 or 10.2 f rom being
[]} Sonntaq Reporting Service, Ltd. Geneva, Illinois 60134 (312) 232-0262
3459 O 1 applied to those metals that were welded for the 2 qualification. 3 0 All right, sir. 4 Would you now turn to Applicant's Exhibit 12 for 5 identification, which is the AWS code, and, if you 6 would, describe for us how, by reference to the AWS 7 code, one could ascertain whether the welding of A446 to i 8 A36 material was a prequalified procedure? 9 A Was a prequalified -- 10 0 Was a procedure using prequalified materials. 11 A If you go to Section 8.2 on Page 86, it lists the 12 materials that are considered prequalified. ( 13 Under 8.2.3, it states, "When a steel other than 14 those listed in 8.2.1 is approved under the general" -- 15 "under the provisions of the general building code and 16 such steel is proposed for welded construction, the i 17 weldability of the steel and the procedure for welding ( 18 it shall be established by qualification in accordance 19 with the requirements of 5.2." \\ 20 If you go back to Section 5.2, it will refer you to 21 Part B, Part B being procedure qualification. Under 22 procedure qualification, Section 5.5.1.1, " Qualification 23 of a welding procedure established with a base metal 24 included in 10.2" -- 25 MR. GUILD: Excuse me. Can the witness slow {} snnnen g nennr ei ng servi c.. r.e a _ Geneva, Illinois 60134 (312) 232-0262
1,, ; 3460 ~ ^ 1 / l 1 dowd? 2 MR. MILLER : Yes. This is sort of like 3 interpreting a statute. 4 JUDGE GROSSMAN: What was the reference? u S THE WITNESS: 5.5.1.1. l 6* MR. MILLER: What page? 7 MR. GUILD: Give us a'page number. l 8 TH E WITN ESS : Page.45-i j 9 A (Continuing. ) As it reads,, "N6t listdd.in 5.5.1.2 10 having a minimum specified yield point less than 50,000 11 pai shall qualify the procedure for welding any other l 12 ba[e metal or combination of those base metals included i ( ,n 13 in 10.2 that have a minimum specified yield point equal 14 to or less than the base metal used in the test." 15 BY MR., MILLER : 16 Q You' re reading f rom 5.5.1.1; is that correct? , 17 A Yes. 18 Q . All right. 19 ~, Now, that leads us to yet another provision of the _c[de; correct, Section 10.2? 20 21 A 10.2 is -- again Section 10.2 lists the materials that 22 are prequalified. -23 0 on what page is that, sir? 24 A That is on Page 107. ({} 25 Q All right. ~ _ Sonntaa Reportino Service, Ltd. Geneva, Illinois 60134 s (312) 232-0262
3461 0 1 A On Page 108, Paragraph 10.2.3, it will take you back 2 again to Section 5.2. 3 Q Now, then, having taken us through the code, could you 4 describe how one would determine that the welding of 5 A446 to A36 was the welding of two qualified materials 6 under those provisions of the code? 7 A A36 is listed as a prequalified material under these 8 sections, and its yield point is less than 50,000 pai. 9 JUDGE GROSSMAN: Excuse me. Where is A36 10 listed? 11 THE WITNESS: It is listed in Section 12 10.2.1.1 on Page 107, and it is also listed in Section 13 8.2.1.1 on Page 86. I 14 BY MR. MILL ER : 15 0 Mr. Simile, in your opinion, in order to meet the 16 requirements of the AWS code, what changes, if any, were 17 required to Attachment O since there was, in fact, 18 welding of A446 to A36 material taking place? 19 A There were no changes required for Attachment O. 20 0 Why not, sir? l 21 A Because the material specification listed was for the 22 test or for the base metal of the two members being 23 welded f or the qualification. This took care of welding l 24 any other of the prequalified materials listed. 25 0 And is A36 one of those prequalified materials? I (]) nnnntag nennr ei ng s rui n.. r+ a _ Geneva, Illinois 60134 (312) 232-0262
3462 O 1 A Yes, it is. 2 Q Do you know whether or not there was any change made to 3 Attachment O after Mr. Puckett raised his concerns 4 regarding the welding of A446 and A36 material? 5 A Yes, there was. 6 Q, How would you characterize that change to the procedure, 7 sir? 8 A There were two changes made. The weld symbol was 9 changed to reflect a fillet weld instead of a flare 10 bevel; and on Attachment 01, the macroetch for 11 qualification was unacceptable. 12 MR. GUILD: I'm sorry. Can the witness slow 13 down or give us a reference to where he's -- 14 THE WITN ESS : On the next page, 01. 15 MR. MILL ER : He is on Attachment O of 16 Applicant's Exhibit 10. 17 MR. GUILD: 01 is the next page? 18 TH E WITN ESS : I'm sorry; O2 and 03. 19 A (Continuing.) In the middle of the page under the l s l 20 laboratory test number for the macroetch tests, these 21 tests were unacceptable for his quallfication. 22 BY MR. MILLER: 23 0 All right. 24 Now, 40 would identify those specific problems with 25 Attachment O as it's found in Revision C7 (} Sonntaa Reportino Service, Ltd. Geneva, Illinois 60134 (312) 232-0262
3463 O 1 A Who should? 2 Q Who did, to your knowledge? 3 A S & L. 4 Q Thank you, sir. 5 And whose responsibility was it, if you know, to 6 make the necessary changes in the procedure? 7 A Comstock. 8 Q Do you know which individual at Comstock made those 9 changes, if anybody? 10 A Who made the changes on 017 11 Q Yes, sir. 12 A I don't know who did make the change. 13 Q Do you know -- 14 A I know who should. 15 0 What role, if any -- well -- l 16 MR. GUILD: Excuse met Did the witness refer 17 to 017 18 I thought he changed his answer and said 02 and 03. 19 THE WITNESS: It's 02 and 03. 20 BY MR. MILLER: 21 Q All three of those required a change in the -- 22 A If you ref er to Page 2 of 2 of the comments f rom 23 S & L -- 24 0 Where are those located sir? 25 A At the beginning. That would be the third page, {} nnnneng nannr*4 ng garvica. r.ta. Geneva, Illinois 60134 (312) 232-0262
3464 O / 1 Paragraph E. 2 The procedure qualification attachments 01, 02, 03 3 and 04 are unacceptable, since the required effective l 4 throat is one-eighth inch yet none of the test data 5 meets this requirement. 6 So it's all four attachments. 7 0 Well, to your knowledge, Mr. Simile, did there come a 8 time when Attachmcnt 0 was changed with respect to the 9 materials that were identified on the first line of that 10 attachment? 11 A Rev. D did not show any change. 12 Q Sir, are you aware of the disposition of NCR 30997 13 A Yes, I am. l 14 Q What changes in the procedure, if any, did that call 15 for? 16 A It called for A36 to be added to these attachments. 17 Q Now, what effect, if any, on the welding work that had 18 gone on in the field prior to the addition of A36 as a 19 material specification in Attachment 0 took place? 20 A None. 21 Q Why is that? 22 Why was there no effect in not having this material 23 listed on Attachment 0? 24 A Because the material was already prequalified by this (]) 25 procedure qualification. Sonntaq Reportina Service, Ltd. Geneva, Illinois 60134 (312) 232-0262
3465 ( 1 MR. MILLER: May I have just a minute? 2 JUDGE GROSSMAN: Yes. 3 BY MR. MILL ER : 4 Q Now, Mr. Simile, have you had occasion to stop work 5 since you've been employed at the Braidwood site? 6 A I have stopped work on specific items. 1 7 I have not formally issued a stop-work, no. 8 Q Sir, would you describe the circumstances under which I 9 you have stopped work on a particular item? 10 A We had a particular installation with a very unique 11 joint detail that was not qualified to our procedure. 12 That work was stopped until a procedure qualification 13 could be made and found acceptable. 14 Q All right, sir. 15 Did you discover that this work was taking place 16 pursuant to an unqualified proce' dure? 17 A The work did not start. The work was brought to my f 18 attention by a Level II inspector. l 19 0 Do you remember the name of that inspector? l l 20 A Mike Mustered. i 21 Q And was there any sort of documentation prepared with 22 respect to this unqualified procedure? 23 A The only documentation that was prepared was a procedure 24 qualification record to get this joint design qualified. 25 0 Was -- did any work take place pending the qualification (} snnneng nonnrH ng s rvic.. r.e a. Geneva, Illinois 60134 (312) 232-0262
3466 O 1 of this procedure? 2 A No, sir. It was a requirement for the fit-up to be 3 inspected by Quality Control, and that work would not 4 get past that point. 5 0 Now, I'd like you to turn to Applicant's Exhibit 11 for 6 identification, and I'd ask you to describe to the Board 7 and the parties how this document came to be created. 8 A Exhibit 11 is Revision F to Procedure 4.3.3. 9 This revision took place after myself and our 10 corporate welding engineer arrived at the site and we 11 revised the layout of 4.3.3. We deleted a lot of 12 unnecessary inf ormation and simplified the whole i 13 procedure. l 14 Q All right. l 15 How does Revision F identify the types of materials 16 which are qualified for welding within the Comstock 17 scope of work? 18 A We have listed on Page 14 of 14 all the prequalified 19 material that can be welded with this procedure. l 20 0 I notice that there is a table there. 21 Where did that table come f rom? 22 A That table came f rom AWS D1.1. 23 0 And which section of the AWS code? 24 A That came out of Section 4. 25 Q Mr. Simile, are the attachnents, such as Attachment O (} l l Sonntaq Reporting Service, Ltd. Geneva, Illinois 60134 (312) 232-0262
3467 t 1 that you identified in Applicant's Exhibit 10, still 2 contained in Applicant's Exhibit ll? 3 A No, th ey ' re not. 4 Q Why not? 5 A The A446 material was found by S & L to be considered as 6 a prequalified material, and a procedure qualification 7 for weldability of this material was waived. 8 Q And who initiated that decision by -- the review that 9 led to that decision by Sargent & Lundy? 10 Did you or did somebody else? 11 A This would be f rom their engineering. 12 0 I see. 13 A It was a spec change. 14 MR. MILLER : Your Honor, that concludes my l l 15 examination of Mr. Simile on these documents. I'm going 16 to go on to other subjects, but I'd be glad to have -- 17 if the Board has any questions at this point in time 18 while it's f resh, perhaps Mr. Simile could respond to 19 th em. 20 BOARD EXAMINATION 21 BY JUDGE CALLIHAN: 22 Q I have a general question, Mr. Simile, which is perhaps 23 illustrated by a glance at Attachment O to Applicant's 24 Exhibit 10, in the diagram there, which I will describe 25 in layman's words as a piece of rectangular tubing to (]) l Sonntag neporting Sarvica. r+ a. Geneva, Illinois 60134 (312) 232-0262
3468 () 1 which there seems to be' attached two pieces of Unistrut 2 P-1001. 3 Is my characterization correct? 4 A Yes. 5 0 In cases of items such as Unistrut, which were 6 factory-made -- and in this case it looks like those two 7 pieces of Unistrut are back to back. 8 A Yes. 9 0 -- how are they fastened, Unistrut to Unistrut? 10 Is that a factory job or is that done in the field? 11 A The majority of which we received was f actory job. 12 However, we did weld back to back in the field using 13 stitch welds. 14 0 What assurance do you have of the integrity and 15 acceptable characteristics of the back-to-back shop 16 welding of, say, P-1001 Unistrut as illustrated here? 17 A There was a certificate of conformance received with the 18 material from the vender, and we do receipt inspection 19 on the ma:erial coming to the job. 20 0 So you hava your own in-house inspection, and you have a 21 certification -- 22 A Yes. 23 0 -- f rom the manuf acturer? 24 Does the nuclear -- perhaps I shouldn' t ask this. (]} 25 Maybe I'll direct it to the Staff. Sonntaa Reportina Service, Ltd. Geneva, Illinois 60134 (312) 232-0262
3469 O 1 But since you' re here, does the Nuclear Regulatory 2 Commission go back to the Unistrut people, the 3 manufacturer, and, to your knowledge, get a 4 certification or inspect or feel or bend those factory 5 jobs? 6 If this is beyond your ken, don't hesitate to say 7 so -- 8 A I couldn't say for sure. 9 0 -- and I'll get the Staff to answer it one of these 10 days. 11 A I couldn' t say for sure. 12 JUDGE CALLIH AN : That's understandable. 13 Thank you very much. 14 MS. CH AN : Your Honor, did I take that to be 15 a request that the Staff look into it? 16 JUDGE GROSSMAN: Pardon? 17 JUDGE CALLIHAN: Sometime. Sometime the 18 Staff can tell me about it; not today nececsarily, 19 unless you want to, unless you' re prepared to. 20 MS. CHAN: We' re not prepared to answer your 21 question, but -- 22 JUDGE CALLIHAN: Well, think about it. Put 23 it on your list. 24 MS. CH AN : I'll think about it. 25 THE WITN ESS : Can we take a short break? (} nnnneng pannr et ng garnica. r+ a. Geneva, Illinois 60134 (312) 232-0262
3470 O 1 MS. CH AN : I believe the witness just asked 2 for a break. 3 THE WITNESS: Can we take a short break? 4 JUDGE GROSSMAN: Certainly. I'm sorry. 5 Anytime you care to. 6 You ought to tell your witnesses. 7 MR. MILLER: I have, but I neglected to 8 remind him this morning. 9 JUDGE GROSSMAN: Okay. We'll take 10 10 minutes. 11 (WHEREU PON, a recess was had, after which 12 the proceedings were resumed as follows:) 13 JUDGE GROSSMAN: We're back on the record. 14 Proceed, Mr. Miller. 15 MR. MILLER: Thank you. 16 MR. GUILD: Mr. Chairman, I understood Mr. ( 17 Miller to say he was going to move on to another l 18 subject. 19 I don't know what the Board's or Mr. Miller's 20 pleasure is; but in light of the redirect on the code l 21 subjects, I do have some questions on that subject. I 22 can do it at any time. 23 MR. MILLER: I think it would be useful to l 24 have it all in one place in the transcript. 1 25 JUDGE GROSSMAN: That's fine. (} Sonntaq Reporting Service, Ltd. Geneva, Illinois 60134 (312) 232-0262
3471 ( 1 Proceed, Mr. Guild. 2 RECROSS EXAMINATION 3 BY MR. GUILD: 4 0 If you would turn, in your, Procedure 4.3.3, to the 5 that you ref erred to, please -- ~ 6 A Which revision? 7 Q Well, I'm looking at the revision which you handed me, 8 and it appears to be -- 9 A Rev. C? 10 Q Yes, Rev. C. It's marked as Applicant's Exhibit 10 for 11 identification. 12 Do you have that document? i () 13 A Yes. 14 Q Now, this document is entitled "Prequalified Joint 15 Welding Procedure, Procedure Specification." i i 16 A Yes. s 17 0 All right. 18 Now, this isn' t a PQR, is it? l 19 A This -- it is and it isn't. 20 If you look at the bottom, it says "For PQR's, see 21 Attachments 01, 02, 03 and 04." 22 0 I see. 23 A What they did was combine all four qualifications on one i 24 sheet, using the prequalified sheet with the []) 25 qualifications to back it up. snnneng n.pnrH ng Marvi co, T.F A. Geneva, Illinois 60134 (312) 232-0262
3472 0 1 Q I see, okay. 2 So Attachments 01 through 3 -- 01 through 4 are the 3 PQR's? 4 A Yes. 5 Q They' re documents that follow, and they' re entitled 6 " Welding Procedure Qualification Test Record"? 7 A Yes. 8 Q The acronym used is PQR for that? 9 A Yes. 10 Q All right. 11 Now, I thought I understood you to say, in response 12 to Mr. Miller, that as a result of the disposition of () 13 NCR 3099, those PQR's, Attachments 01 through 4, were 14 amended to specify A36; is that correct? 15 A Yes. I believe that's what the NCR said to do. 16 Q All right. 17 Now, my memory may be f aulty -- it certainly is 18 often -- and I don't have the transcript reference; but 19 I recall you testifying last week that when I asked the 20 question, "Were the PQR's changed," your answer was, 21 "No. The PQR's weren't changed, because the PQR's 22 always correctly specified the material that had, in 23 fact, been used t'o qualify the procedure. The only 24 amendments made were to the body of the procedure ] 25 itself." Sonntaa Reportina Service, Ltd. Geneva, Illinois 60134 (312) 232-0262
3473 O 1 Did you so testify? 2 A I don' t remember talking about -- 3 MR. MILL ER : I believe it was Mr. Louden's 4 testimony, and he testified generally. 5 MR GUILD: I see. I'm blaming the wrong 6 man, and I take that back, Mr. Simile. 7 JUDGE GROSSMAN : My recollection of Mr. 8 Louden's testimony was that the PQR's were not changed 9 to include the A36 but only the welding procedure itself 10 was changed. 11 MR. GUILD: That's my recollection. I've got 12 the wrong man. 13 JUDGE GROSSMAN : What that means, I'm not 14 sure I understand, but that's my recollection of his 15 testimony. 16 Is that what you recall, too, Mr. Guild? 17 MR. GUILD: Yes, it is, Judge. This is the 18 wrong witness and I apologize to Mr. Simile, but that is l l 19 what I recall hearing. 20 BY MR. GUILD: 21 Q If that was indeed Mr. Louden's testimony, he was 22 incorrect with respect to the Comstock procedures? 23 A Yes. 24 Q All right. 25 Now, looking at that same attachment, the picture, (} l ennr i nn s.rui ce, r+ a _ gnnntan n e Geneva, Illinois 60134 (312) 232-0262
3474 O 1 the joint design drawing there, I see two dissimilar 2 metals or different metals; and as Judge callihan 3 identified them, there's a rectangular tube and two 4 pieces of Unistrut. 5 It's the Unistrut welded to the tube that's 6 reflected in this joint detail; correct? 7 A Yes. 8 Q All right. 9 Now, which of those materials or those pieces of 10 metal is A500B7 11 A It would be the tube steel. 12 0 A500B designates a tube steel; is that right? 13 A Yes. 14 Q All right. 15 And which of those metals would be on A4467 l 16 A It would be the Unistrut. 17 0 A446 is galvanized, thin-gauge metal and in this case is 18 formed into a Unistrut? 19 A Yes. 20 0 All right. 21 And which of those materials, if any, is A367 22 A Neither materials are A36. 23 0 All right. 24 A36 is plate steel, is it not? 25 A Yes, it is. (} Sonntac Reportino Service, Ltd. Geneva, Illinois 60134 (312) 232-0262
3475 O 1 Q It's not steel in the form of a tube; it's in the form 2 of a plate? 3 A Correct. 4 Q All right. 5 And if you formed a tube out of what was A36, it 6 would no longer be A367 7 A Correct. 8 Q Now, you told me -- or you told your counsel that one of 9 the things that Sargent & Lundy did when they commented 10 on your proposed revision, that comment reflected at 11 Paragraph E of the cover sheet, the third page into your 12 attachment -- into your Exhibit 10 -- is that -- well, I 13 take it back; perhaps not that comment. 14 You stated that the PQR's had to be further revised 15 to specify that this -- the weld symbol had to be 16 changed to indicate a fillet weld instead of a flare 17 bevel weld; correct? 18 A No, no. 19 The -- at the beginning of the procedure, the 20 comment is on the macroetch tests that were perf ormed. 21 Q Let me stop you. I'm just being unclear. 22 You did testify earlier that there was indeed a 23 change required to specify a fillet weld in the 24 -- (]) 25 A Yes. mm....e..pm. 4,9 m.. 4., t,a. Geneva, Illinois 60134 I (312) 232-0262 1
3476 O 1 Q -- as opposed to a flare bevel groove? 2 A That was changed, yes. However, it was not reflected in 3 these comments. 4 0 I see, but that's not the point of my question. 5 The point of the question is: That change was 6 mades right? 7 A Yes. m 8 0 That was made, was it not, because what appears on this 9 joint design is indeed a flare bevel weld, is it not, 10 the joint design for 0? 11 A This joint design was considered by S & L to be a fillet 12 weld. 13 0 Well, isn't it a fillet weld when you weld it to a plate 14 and a flare bevel weld when you weld it to a tube? 15 A No. 16 A flare bevel weld -- i 17 0 All right. 18 A -- is -- a flare bevel can be a piece of tube being 19 welded to a plate, yes. 20 0 I see, I see, okay. Folk-engineering fails again. 21 (Laughter.) 22 I appreciate you clarifying that. 23 Why is that -- can you just explain what the error 24 was in the PQR7 / 25 A S & L' determined'that the radius on the Unistrut was so l [} Sonntaq Reporting Service, Ltd. 1 Geneva, Illinois 60134 (312) 232-0262
3477 0 1 small that it was to be considered as a fillet and not 2 as a flare bevel. 3 0 I see. 4 But am I understanding correctly that if it were a l 5 greater-radius -- a tighter-radius tube, then indeed it 6 would be a flare bevel weld? 7 You're welding a piece of Unistrut to a piece of 8 tube, and the radius was of a -- it was a curved 9 surface? 10 A If you welded a piece of tube steel to a flat plate, 11 that would be considered a flare bevel. 12 0 I see. 13 But this particular tube is rectilinear enough and 14 the surf ace to which it is welded is flat enough that it 15 was considered a fillet weld? 16 A It was welded on the flat surface, the tube. 17 0 Therefore, a fillet weld? 18 A Yes. 19 0 Now, did Sargent & Lundy approve the procedure with the 20 unrevised Attachment 0 in the first instance? 21 By that I mean, prior to NCR 3099. 22 A They gave it a Status 2 comment. 23 0 What does that mean? 24 A Which means you can proceed; however, their comments 25 must be incorporated. {} Rnnntag Reporting Marwice. T.t d. Geneva, Illinois 60134 (312) 232-0262
3478 () 1 Q Did their comments at that time indicate that the symbol I 2 should be changed for a fillet weld -- to show a fillet 3 weld instead of a flare bevel? 4 A No, sir. That's what -- these comments did not address 5 the symbol. 6 0 Did not address -- t 7 A The weld symbol. 8 0 I see. 9 When did they -- or when did someone discover that 10 indeed the weld symbol was wrong? 11 A There was a determination made by S & L that those welds 12 were to be considered as fillet welds. 1 13 Q Yes, but ahen did they make that determination? 14 A That was after the Status 2 comments. 15 Q Okay. 16 So when they did the Status 2 comments, they didn't 17 catch what they later identified as a weld symbol error? 18 A They didn't identify it as an error, no. 19 Q Well, did they ever consider it as an error? 20 A They changed their designation of that weld to a fillet 21 weld. 22 Q They changed their position later on? 23 A Yes. 24 Q Okay. (]) 25 I mean, the weld didn' t change? Sonntaa Reportino Service, Ltd. Geneva, Illinois 60134 (312) 232-0262
3479 O 1 A No. 2 Q They just changed their position? 3 A Correct. 4 Q I see. All right, sir. 5 Now, what is the relationship, if any, Mr. Simile, 6 between the effective throat requirement and the 7 character of the weld as a flare bevel weld or a fillet 8 weld, on the other hand? 9 A The effective throat for a flare bevel is measured f rom 10 the straight end of the tube perpendicular to the plate, 11 whereas the effective throat of the fillet weld is 12 measured f rom the face of the weld to the root of the 13 weld. 14 0 And what, if any, was the change in the designation of 15 the weld symbol -- what was the effect, if any, of the 16 change in designation of the weld symbol on the 17 measurement of the effective throat of the weld that was i 18 being qualified? l l 19 A The effective throat of the fillet weld would be 20 considerably more. I 21 Q So when they changed it to treat it as -- when it was 22 originally specified as a flare bevel weld, then the 23 throat requirement would have been greater? 24 A It would have been lesser. (]) 25 0 It would have been less, okay. .....g..pm.~.g m.t.4m., , a. Geneva, Illinois 60134 (312) 232-0262
3480 GO 1 And the throat actually achieved would have failed 2 to meet the specified one-eighth inch? 3 A The throat -- the throat actually achieved -- half of it 4 would be thrown out for the macroetch. i 5 0 So then would you explain: What is the basis for the 6 Comment E that appears in Sargent & Lundy's comments? 7 A Because the ef fective throat has f ailed. 8 0 Why did the effective throats f ail? 9 A They were undersized. 10 0 Why were they undersized? 11 A Because of the measurement, the test that was taken. 12 0 Was that because of the weld symbol error? 13 A Well, it was because it was a flare bevel, yes. 14 0 I see. 15 Now, if you would look, please, at Exhibit 8 for 16 identification -- that is, the amendment to the Sargent 17 & Lundy Specification L-2790 -- now, there at Paragraph 18 401.18.1, there is specified that the contractor -- in 19 this case, Comstock -- has the option of using AWS D1.3 l 20 code for welding base materials thinner than one-eighth 21 inch; correct? 22 A Yes. 23 0 Now, is A446 thinner than one-eighth inch? 24 A Yes. 25 0 Does this specification give Comstock the option to (} Sonntaa ReportlD9 Service, Ltd. Geneva, Illinois 60134 (312) 232-0262
3481 0 1 utilize the AWS D1.3 code, then, in procedures for 2 welding A4467 l 3 A Yes, it does. 4 0 Let's look at Applicant's 9 for identification. That is 5 the Sargent & Lundy form 170,. 6 Mr. Miller asked you wnether this Sargenc & Lundy 7 form, the structural standard document, specified any 8 welding codes to be used; and I believe your statement 9 was that as it was relevant to Comstock's scope of work, j 10 it specifies only D1.1; correct? 11 A That's correct. 12 0 It specifies the ASME Section 9, but that applies to 13 work beyond Comstock's scope? 14 A That's correct. 15 0 And it doesn't specify AWS D1.3; correct? 16 A No, it doesn't. 17 0 Well, isn' t that because the Revision C of this Form 18 1701 was dated December 20, 1977, before there was an 19 AWS D1.3 code? 20 A Yes, it is, and that's still the revision that is ) 21 current today. 22 Q All right, sir. P 23 That hasn' t been amended f urther -- 24 A No, sir. 25 Q -- af ter the promulgation of the D1.3 code? (]} t annnemn n a nn r + 4 nn nervien r> a. Geneva, Illinois 60134 (312) 232-0262
3482 1 A-No, sir. 2 Q But it could be consistent with the specification, and 3 it could add D1.3 -- 4 A Sure. 5 0 -- for thinner than one-eighth-inch material? 6 A It could be. 7 Q Such as A446; right? 8 A It could be, yes. 9 Q Now, the AWS D1.1 code lists as a prequalified material 10 A36, does it not? 11 A Yes, it does. 12 Q And it lists as a prequalified material A500, does it ~ 13 not? 14 A Yese it does. 15 0 Both of those are materials that are greater than 16 one-eighth inch in thickness, are they not? 17 A Yes. 18 Q All right. l 19 The AWS D1.1 code is a structural welding code; 20 correct? 21 A D1.17 22 Q D1.1 is a structural welding code -- 23 A Yes. j 24 Q -- correct? 25 Now, that structural welding code does not. list (]} i _Sonntaa Reporting Service, Ltd. Geneva, Illinois 60134 (312) 232-0262
3483 I O V 1 A446, the thin-gauge, galvanized material which is less 2 than one-eighth inch in thickness; correct? 3 A That's correct. 4 Q All right, and that is why you had to establish the S qualification of welding the -- well, strike that. 6 That is the basis -- the absence of the listing of 7 A446 from the D1.1 code is the basis for making 8 reference to the series of code provisions you referred 9 to in responding to Mr. Miller's question to establish 10 the qualification of A446 as a nonlisted material? 11 A That's correct. 12 0 All right. 13 Isn't it the case, Mr. Simile, that A446 is not 14 listed in the structural welding code, the AWS D1.1 15 code, because the AWS D1.1 code was never intended to 16 apply to specify the welding of materials less than 17 one-cighth inch in thickness, such as A4467 1 18 A I can' t say that. 10 0 You don't know the answer to the question? 20 A I don' t -- I don' t think anyone can say what the AWS 21 code intended. 22 0 All right, sir. i 23 A An interpretation f rom AWS does specifically state that 24 it was not intended to be used strictly for material 25 over one-eighth inch. [ () N^untag.Jtap r Fi tuJ Gervice : LFL Geneve, Illinois 60134 (312) 232-0262 ,.,,-,,,,,.,.-,e ,n ---n ~. - - - - -, -
3484 O 1 0 The AWS Dl.1 was not intended for use of material less 2 than one-eighth inch? 3 A It could be used for material less than one-eighth inch, 4 yes. 5 0 But it was not intended for material less than -- 6 A It doesn' t say that. 7 Q I'm sorry. I just misunderstood your last answer. 8 Your interpretation was what?' 9 A AWS has made an interpretation that Dl.1 can indeed be 10 used f or materials less than one-eighth inch. 11 Q That's the reference to the weld journal article that -- 12 I'm sorry. 13 Can you give us a reference, please? 14 A No, I cannot. 15 JUDGE GROSSHAN: That's the same reference 16 we' re missing; right? 17 TH E WITN ESS : Yes. { 18 BY MR. GUILD: 19 0 Is it indeed the same reference we' re missing? l l 20 A Well, the '75 edition of the code did not specify any 21 intended thickness of material. They didn' t specify 22 that until they wrote the edition of D1.3 for thin 23 meterial. l 24 0 But it didn't liet A446, which is a thin-gauge material? (]) 25 A They didn't conoider it as prequalified material, no, _Sonntaq Beporti_nq Serv _ ice, _ Ltd. i = Geneva, Illinois 60134 (312) 232-0262 a
3485 O 1 they did not. 2 MR. GUILD: Thank you. That's all I have. 3 JUDGE GROSSMAN: Mr. Miller? 4 REDIRECT EXAMINATION 5 (Continued) 6 BY MR. MILLER : 7 Q Let me just go back on this subject, Mr. Simile. 8 There's a reference to Attachment 0, the effective 9 throat of the weld as being less than necessary to 10 qualify a flare bevel -- 11 A Yes. 12 0 -- weld. 13 Would the effective throat have been adequate to 14 qualify the weld as a fillet weld? 15 A You would have to have the sample to determine that. 16 JUDGE GROSSMAN: I'm sorry. What was the i l 17 answer? 18 THE WITNESS: You'd have to have the sample 19 to determine it. 20 A (Continuing. ) The measurements are taken f rom 21 different points. 22 On the fillet weld, the measurement is taken f rom 23 the root to the closest part of the f ace of the weld, so 24 the distance of the effective throat is going to vary on (]) 25 a fillet weld to the smallest portion of the weld. 9aant=0 neporting Saruing, r+ a. Geneva, Illinois 60134 (312) 232-0262
3486 O 1 (Indicating.) 2 If I can draw it, I can -- 3 BY JUDGE GROSSMAN: 4 0 Well, is it the case that before the symbol was changed, 5 that the welding of A36 material would not have 6 qualified because the measurement would have been taken 7 differently? 8 A The material wouldn't make any difference. 9 The weld itself would not qualify. I would not be 10 able to tell you if this would qualify for a fillet 11 weld, but the material wouldn' t make any difference. I 12 JUDGE CALLIH AN: Excuse me, Mr. Miller. 13 MR. MILLER: Sure. 14 BOARD EXAMINATION 15 BY JUDGE CALLIBAN: 16 0 I don't know whether I misheard or whether this is just 17 my faulty memory. 18 Let's, for the sake of identification, identify a 19 piece of Unistrut as a square or hollow tube with most 20 of one side missing. Let's look at that part of the 21 fourth side which remains. 22 What's its thickness in P-10017 l l 23 A I believe it's 102,.102. t 24 0 Inches? (]} 25 A Yes. l Sonntaa Recortina Service, Ltd. Geneva, Illinois 60134 (312) 232-0262
3487 1 Q I see. 2 So it is less than -- 3 A It is less than one-eighth. 4 Q Less than a quarter of an inch? 5 A It's less than one-eighth, yes. 6 0 I'm sorry; less than an eighth of an inch, yes, barely. 7 A Barely. 8 JUDGE CALLIHAN: Thank you. 9 JUDGE GROSSMAN : Excuse me. 10 Did Staff have any questions on this topic while 11 it's fresh in our minds? 12 MR. BERRY: Not at this time. 13 MS. CHAN: Not at this time, your Honor. 14 JUDGE GROSSMAN: Mr. Miller? 15 REDIRECT EXAMINATION I 16 (Continued) 17 BY MR. MILLER: 18 0 Mr. Simile, I've placed before you a document that's 19 been bound into the record as an attachment to Mr. 20 DeWald's testimony. It's Attachment 4 to his prepared 21 testimony on this issue, and it's the Employee Warning 22 Record that's directed to a Mr. Herschel Stout. I think i l 23 Mr. Guild asked you whether or not you ever followed Mr. 24 Stout and watched him or any of that. l (]} 25 Do you recall those questions? l I Cnnnten D a nn r t 4_ n n Marvies. f} d. Geneva, Illinois 60134 (312) 232-0262
1 3488
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O 1 A Yes. 2 Q Could you'take a minute and look at the daily inspection 3' status reports that are attached to this employee 4 warning? 5 Then I have a few questions for you on it. 6 I'd like you'to' turn, if you would, first to I 7 believe it's the first daily inspection report that Mr. 8 Stout filled out t. hat's in this package. It bears a 9 ~ date in the upper right-hand corner of January 30, '85. 10 Do you seo that? s 11 A Yesc "
- 12 Q
And'perhaps you could help us by~ describing what the O 13 different columns on that inspection status report 14 reflect. 15 A The first column is the item, which would identify the 16 type of inspection being performed, "W" in this case 17 being welding. ' 18 " Identification" is the drawing number. "Q uanti ty " 19 is the specific item number. 20 THE WITNESS: Am I going too fast? i 21 JUDGE GROSSMAN: That's okay. 22 MR. MILLER: I'll turn this over to the 23 Board, and I'll peer over the witness' shoulder. 24 (Indicating.) 25 MP,. MILLER : Go ahead, Mr. Simile. ~ So ntaq Reportinq_ Service, Ltd. Geneva, Illinois 60134 (312) 232-0262
l 3489 ([) 1 A (Continuing.) "Date inspection requested" is the date 2 he was given the assignment,.I think. " Inspector 3 assigned" is Herschel Stout, and the "date completed" 4 was the date he did the inspections. 5 BY MR. MILLER: 6 Q All right, sir. 7 The first line item is a welding inspection, and 8 then over in the f ar right-hand portion of the status 9 report is a word that appears to be " painted." 10 What does that indicate to you, sir? 11 A This indicates that the weld was painted at the time he 12 got to the field to do his inspection. () 13 0 Could you describe for us generally how an inspector in 14 January of 1985 would have gone about getting his daily 15 assignments of inspections and then what his routine was 16 generally after that? 17 A In the case of Herschel, he would get his assignments 18 from his lead inspector, at which time he would do the 19 required research to get his drawings, see what details 20 needed to be inspected, what type of welds needed to be 21 inspected, the drawings that he would require in the 22 field and then proceed to the field to do his 23 inspection. 24 0 All right. 25 And once he found a weld that was painted, what, if (} t snnneag nonnrti ng service, r+ a. Geneva, Illinois 60134 (312) 232-0262
3490 AU 1 anything, was he to do with respect to his inspection? 2 A If the inspection was not completed at that time, that 3 weld would be turned over on a paint list to the foreman 4 to have the paint removed. 5 0 The next line item is a weld inspection that was, in 6 fact, completed on that day. 7 Can you tell, Mr. Simile, the nature of the 8 component on which that inspection was completed? 9 A It was a junction box. 10 0 Thank you, sir. 11 And do you know how many welds were on that 12 junction box? 13 A No, I do not. 14 Q Sir, do you know the range of welds on junction boxes? 15 A The range would vary depending on the support. The 16 average is four to ten welds. Some get more complicated 17 than that. 18 In this case, this was a reinspection because of a 19 PTL rej ect, and I wouldn' t know the amount of -- the 1 20 number of welds. 21 Q All right. l 22 Is the number of welds discernible from other 23 records in Comstock's -- 24 A Yes, it is. l (} 25 Q -- possession? Sonntaa Reportina Service, Ltd. Geneva, Illinois 60134 (312) 232-0262
i 3491 O 1 The next line item -- what does that indicate? 2 A The next line item again is a weld inspection on a 3 junction box. 4 It could not be completed because the welds were 5 fireproofed and painted. 6 Q All right. 7 Then the next one -- could you tell what type of 8 component that inspection -- 9 A Again, it's a weld inspection on a junction box that was 10 completed and found to be acceptable. 11 Q All right, sir. 12 And the last two? 13 A The last two are junction box inspections that were 14 nonsaf ety -- excuse me -- that did not have any welds on 15 them. 16 0 How can you tell that they did not have any welds on l 17 them? 18 A The inspection section is marked "NAQCW," which means 19 not applicable for QC weld inspection. 20 0 How are these junction boxes -- 21 A They were probably bolted. 22 Q So on January 30th Mr. Stout went out in the field, 23 found two of his inspections -- that the junction boxes - 24 were painted and two were bolted and two he inspected; {}} 25 correct? Sonntag Repor+ing Service: Lea-Geneva, Illinois 60134 (312) 232-0262
3492 0 1 A Correct. 2 0 The column that's marked " identification" on this 3 inspection status report, Mr. Simile -- 4 A Yes. 5 0 -- what is the reference to those letters and numbers? 6 A These are the drawing numbers that these items would 7 appear on. 8 Q Did the inspector take a copy of each drawing with him 9 in the field as he conducted his inspection? 10 A He would normally get the details off of these drawings 11 in the locations of where the junction box was at and 12 take the detail drawings to the field, yes. 13 Q There's a notation in handwriting, "4 in 10 hours," up 14 at the top. 15 Is that in your handwriting, by any chance? i 16 A No, it isn't. 17 Q Have you ever seen these status reports before? 18 A Yes. 19 Q In what connection? 20 A I saw them when the written warning was given. 21 Q I'd like you to turn to the next one, if you would. 22 Again, these are three welding inspections. 23 A Yes. 24 Q Two of them do not involve welds, however; is that (]} 25 correct? Sonntaq Reporting Service, Ltd. Geneva, Illinois 60134 (312) 232-0262
3493 ( 1 A That's correct. 2 0 And then there was one that he inspected and it was 3 accepted. 4 What is -- there's an asterisk af ter the " accept" 5 column. 6 What does that -- 7 A This indicates that the weld was inspected for an 8 unspecified weld, which -- the only inspections for that 9 type of weld would be for cracks and undercut. 10 0 What is an unspecified weld, sir? 11 A An unspecified weld would be a weld that was an 12 additional weld than required by the drawing or a weld 13 that the engineer has deemed not required and then would 14 become unspecified. 15 Q And was there then a full weld inspection conducted of 16 those welds? 17 A No. These welds -- if it was deemed unspecified, it 18 would be inspected strictly for cracks and undercut. 19 0 Can you tell, by looking, on what component that 20 unspecified weld was located? 21 A It was on a junction box. l 22 Q Now, I'm not at this time going to burden the record by l 23 going through the remainder of these daily inspection l 24 status reports. Let me just -- if you would turn to the 25 inspection report for February -- daily inspection (]} snnneng nepnrei ng service, tra. Geneva, Illinois 60134 (312) 232-0262
3494 O ~ 1 status report for February 13th -- 2 A Okay. 3 0 -- am I correct that this indicates that he was assigned 4 to four weld inspections, and each of them were found 5 painted and rustproofed; correct? 6 A Correct. 7 Q So no inspection activity took place; is that correct? 8 A Correct. 9 0 There's a double asterisk. 10 Can you decipher that for us? 11 A It appears to read, " Mix up on plate and junction box 12 and had foreman clean welds, started inspection" -- 13 something. 14 Q All right, si r. l l 15 On the next one, the next sheet -- that is, for 16 February 14, 1985 -- can you again tell us what the 17 notations under the " inspections" column are? 18 A The first two boxes were inspected and rejected. The 19 third one says "not in location"; the last two, "for 20 further cleaning of welds." 21 Q What's involved in cleaning a weld, sir? 22 A The craf t have to go to the installation and remove the 23 weld -- remove the paint f rom the welds. 24 Q What instructions, if any, were the inspectors given in 25 a situation like the one that conf conted Mr. Stout on /]} 1 Sonntaq Reporting Service, Ltd. Geneva, Illinois 60134 (312) 232-0262
3495 O 1 February 13th, where he went to each of four weld 2 locations and found that each of the welds were painted 3 and rustproofed and couldn't be inspected? 4 A Those items were to be brought back to the lead and 5 would be put on a paint list and issued to the field for 6 cleaning. 7 Q And how was the inspector to spend his day in such a 4 8 situation? 9 A He was to come back and get additional work. 10 0 Why is it that these inspections couldn't be conducted 11 through paint? 12 A The weld inspection -- per our Inspection Procedure 13 4.8.3, it cannot be performed unless the welds are 14 clean. 15 Q Now, I think when you responded to Mr. Guild's questions 16 about whether you followed Mr. Stout around and watched 17 him, I think you -- my notes indicate that you said you 18 treated him the same as any other inspector when you 19 were out in the field. 20 Did you ever observe Mr. Stout actually conducting 21 inspections? t 22 A Not very often. 23 0 When you observed him, what was he doing? 24 A Normally he was walking or standing in the plant, (]) 25 talking with other inspectors. nnnntag nonnrei ng service. r.t a. Geneva, Illinois 60134 (312) 232-0262
3496 O 1 Q What, if anything, did you say to him when you saw him 2 standing and talking to other inspectors? 3 A I didn't confront him in the field. 4 Q Did you ever confront him? 5 A I confronted him in the office. 6 0 What did you say? l 7 A I asked him what he was doing in the field. i 8 0 What was Mr. Stout's response? l 9 A He got a little bit upset that I would question what he 10 does as an inspector. He wanted to know if I was 11 putting quotas on him and trying to demand so many 12 inspections a day. 13 Q What was your response to that comment? 14 A "No"; I was just curious as to what he was working on. 15 Q Did you ever get an answer to that question? 16 A No, sir. 17 JUDGE GROSSMAN: Excuse me. 18 BOARD EXAMINATION 19 BY JUDGE GROSSMAN: 20 Q Did you put the notation "O in 10 hours" on this thing? l 21 A No, I didn't. 22 MR. MILLER: I asked him if it was his 23 handw riting, and he says it was not. 24 BY JUDGE GROSSMAN : s (]) 25 Q Do you know who did? Sonntaq Repo r ting Service, Ltd. Geneva, Illinois 60134 (312) 232-0262
3497 O 1 A I'm not sure. 2 0 What were these things supposed to signify? 3 A These were individual status reports that the inspector 4 turned in daily on the work he performed. 5 REDIRECT EXAMINATION 6 (Continued) 7 BY MR. MILL ER : 8 0 Well, what use was made of them in connection with Mr. 9 Stout's warning? 10 A For his warning? 11 Q Ye s, si r. 12 BOARD EXAMINATION f 13 BY JUDGE GROSSMAN: 14 0 Is it your opinion that these were supposed to represent 15 the amount of work he's done in one day -- 16 A Yes. 17 Q -- those comments? 18 Well, do you have any idea -- let me ask you: 19 Isn't checking a weld and rejecting it considered work? 20 A Absolutely. 21 Q Do you have any idea why, on this February 14th one in 22 which Mr. Stout apparently performed inspections on two 23 welds which he rej ected, the notation says "O in 10 24 hours"? (]) 25 A No. They were -- they were definitely inspections. cnnn*=g nener ing g ruice, r+ a _ v Geneva, Illinois 60134 (312) 232-0262
3498 O 1 JUDGE GROSSMAN: Mr. Miller? 2 REDIRECT EXAMINATION 3 (Continued) 4 BY MR. MILLER: 5 0 Mr. Simile, was the inspection of junction boxes a 6 specific activity that was assigned to identified 7 inspectors? 8 A Yes, it was. 9 0 In addition to Mr. Stout, were there other inspectors 10 assigned to the inspection of junction boxes in January 11 and February of 1985? 12 A Yes, sir. 13 Q I know you don't have the status reports in front of you 14 of those other inspectors. 15 Do you have any recollection of what any other -- 16 the number generally that any other inspector inspected? ~ 17 A I really couldn' t say. 18 Q All right, sir. I'd like to move on now to another 19 subject, and that's the review of the welder 20 qualification records. 21 Mr. Guild asked you a few questions about your 22 review of the welder qualification records when you came 23 on-site. 24 I think you stated that you had, in fact, initiated 25 -a nonconformance report for the discrepancies that you (~ } Sonntaa Reportina Service, Ltd. Geneva, Illinois 60134 (312) 232-0262 A -u.
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3499 i O 1 identified as a result of the concerns expressed by Mr. 2 Puckett. 3 Do you recall that? 4 A Yes. 5 MR. MILLER: I'd like the Reporter to mark as 6 Applicant's Exhibit -- 13 or 147 7 I'm not certain. 8 JUDGE GROSSMAN: 13. 9 JUDGE COLE: We stopped at 12. 10 MR. MILL ER : -- 13 for identification a group 11 of nonconf ormance reports. I'll identify them for the 12 record in a second. 13 These are L. K. Comstock & Company Nonconf ormance 14 Reports 3710, 4649, 4650, 4651, 4652, 4653, 4654, 4655, 15 4656, 4795, 5014, 5015, 5016, 5017, 5018, 5028, 5029 and 16 5044. 17 (The documents were thereupon marked 18 Applicant's Group Exhibit No.13 for 19 identification as of June 9, 1986.) 20 BY MR. MILLER : 21 Q Mr. Simile, first of all, can you tell us whether your 22 name or initials appear on each of these nonconf ormance 23 reports? l l 24 A All but one. l l l (]} 25 Q And which is the one on which they do not appear? snnneng nonnr ei ng servi c.. r.e a. Geneva, Illinois 60134 (312) 232-0262
3500 O 1 A The last, NCR 5044, 2 Q-In the course of your duties at Comstock, have you had 3 occasion to review 5044? 4 A Yes. 5 Q Now, first of all, Mr. Simile, the first one in the 6 stack, No. 3710, shows your signature as originator, and 7 the date is December 17, 1984. 8 Is that the date that you initiated this 9 nonconf ormance report? 10 A Yes, it is. 11 Q At that point in time, Mr. Simile, were you certified as 12 a Level III weld inspector? 13 A Not at Braidwood. [ 14 Q Were you certified as a Level II weld inspector? l 15 A Not at Braidwood. 16 Q What, if anything, had anyone at Braidwood told you 17 about initiating nonconformance reports prior to the 18 time that you were certified? 19 A There was a -- I can't recall if it was a procedure 20 revision at the time. 21 When I first arrived on-site, the -- the persons 22 generating nonconformances were to be certified 23 inspectors. At this time this was not a requirement. 24 0 You've got me a little confused with your time periods (]} 25 here. Sonntaq Reporting Service, Ltd. Geneva, Illinois 60134 (312) 232-0262
3501 ) 1 ) ( 1 When you first came on-site, was there a procedural 2 requirement that an inspector be certified before 3 initiating an NCR7 4 A I believe there was. 5 0 During your tenure prior to December 17, 1984, that was 6 changed? 7 A Yes. 8 0 Was that in a Comstock quality control procedure? 9 A Yes. 10 Q Do you know the number of -- 11 A 4.11.1. 12 Q Pardon me? 13 A It would be 4.11.1. 14 Q Now, Mr. Simile, can you describe the circumstances 15 under which NCR 3710 was initiated by you? 16 A This NCR was due to -- a result of the review of the i 17 welder qualifications that I was requested to perform by l 18 Irv DeWald. j 19 Q All right, sir. 20 And where in this NCR are the nature of the 21 deficiencies that you found in your review of these 22 welder qualification records described? 23 A The deficiencies would be listed on the third page, 24 which is Page -- designated Page 2 of 4. 25 Q Could you just state for the record what those three []} nnnnean n o nn r ei nn servic. r.e a. Geneva, Illinois 60134 (312) 232-0262
3502 4 O 1 deficiencies are? 2 A The three deficiencies that I found at this time were: 3 "1. The Form 88 requires the brand name of the 4 electrode used. The brand name was not documented. 5 "2. The Form 88 shows the wrong base metal 6 specification for the material used. Example: One-inch 7 plate was used for the test and the material on the Form 8 88 is listed as A-106 Grade B pipe. 9 "3. The Form 88 shows the wrong specifications for 10 the electrodes. Example: E7018 was used, and the Form 11 88 shows A5.4 for the filler metal specification." 12 0 All right. () I l 13 Now, I think the example -- the first example is 14 self-evident as to what the-discrepancy was. 15 On the second example, how could you tell that, in 16 fact, one-inch plate was used for the test when the 17 material on the Form 88 was listed as pipe? 18 A Because of the test positions that the plates were 19 tested in. 20 The positions on the Form 88 would show 3G and 4G, 21 which are plate positions; and the position for the pipe 22 test would be 6G. 23 Q All right. 24 Example 3 -- how could you tell -- well, first of 25 all, what is the significance of AS.4 for the filler (]) l Sonntaq R epo r ting Service, Ltd. Geneva, Illinois 60134 (312) 232-0262
3503 ( 1 metal specification? 2 A AS.4 is a specification for stainless steel. 3 Q How could you tell that, in fact, an E7018 electrode was 4 used? 5 A The form would show and designate as an F4 electrode 6 being used. The F4 electrode we use is E7018. 7 0 Then there follow in this stack a series of NCR's that 8 run consecutively f rom No. 4649 to 4656. 9 You initiated each one of these; is that correct? 10 A That's correct. 11 0 Can you describe for us what the nature -- well, where 12 is the nature of the discrepancy identified on each of 13 these NCR's? 14 A It's identified under the " description of 15 nonconf ormance. " 16 Q And are any of them -- do any of them have, in effect, a 17 continuation sheet? 18 A Yes. i 19 Q Sir, where is that found? 20 A NCR 4655 would have a continuation sheet, which would be 21 the third page of the NCR copied. 22 Q Now, Mr. Simile, all of these NCR's, 4649 through 4656, 23 were initiated at approxinately the same time; is that 24 correct? (]) 25 A Yes, they were. nnnneng nonnrei ng snevi ce. r.e a. Geneva, Illinois 60134 (312) 232-0262
3504 O 1 Q And under what circumstances did these discrepancies 2 come to your attention? 3 A These discrepancies were brought to my attention af ter 4 the NCR inspector, Mr. Schapker, was in the Comstock 5 facility, investigating the Worley Puckett allegations. 6 0 When you initiated NCR 3710, why was it that you didn't 7 catch these discrepancies that are identified in the 8 subsequent NCR's, 4649 through 46567 9 A Some of the items that were rejected I wasn't looking 10 for. Some of the items that were rejected I just 11 missed. 12 Q All right. ( 13 Could you describe for us what the nature of the 14 discrepancies were in this series of NCR's? 15 A NCR 4649 is the same as NCR 3710 for Item No. 2, which 16 is having the base metal listed as A-106 in lieu of A36 i 17 and vice versa. 18 NCR 4650 -- the first nonconf ormance was that the 19 thickness range was not filled in. The test given was 20 the test for the unlimited thickness. 21 Item 2, the thickness range was listed as 22 three-eighths, when the actual thickness of 23 qualification was three-quarters of an inch. 24 In addition, the filler metal was not identified. 25 The filler metal was listed typed on the form E7018, (} Sonntaa Reporting Service, Ltd. Geneva, Illinois 60134 (312) 232-0262
3505 0 1 E308 and E309, but none were circled. 2 0 Sir, how could you, without the filler -- for example, 3 on that last one, without the filler metal being 4 circled, how could you determine what correct weld 5 filler metal was, in fact, used? 6 A In review of the Form 88 for that test, which is the 7 fourth page on the NCR, the material is listed as 736 8 material, three-eighths-inch plate; and the test 9 results, root and face tests, were at a classification 10 listed as E7018, E308 or E309, but the specification 11 number is listed as AWS A5.1. In addition, it is an F 12 No. 4. 13 0 I'm sorry. 14 Is the F number a separate item that's to be filled l 15 in on the test record? I 16 A Yes. t 17 0 Continue to 4651 please. 18 A NCR 4651, Item 1, the material was corrected to show the 19 proper material used, but the change was initialed and 20 not dated. This was a procedural violation to Comstock 21 procedures. l 22 ltem 2, the test results were corrected f rom root i j 23 and face bends to the test performed of side bends. 24 Again, the changes were initialed but not dated, which 25 was a procedure violation. {}} mm....g..gm.. g m.. 4m.. tea. Geneva, Illinois 60134 (312) 232-0262
3506 O 1 Q All right, sir. 2 4652? 3 A NCR 4652 -- the welder qualification record showed a 4 thickness range as unlimited. The welders performed 5 weld te_ts on materials requiring a limited thickness. 6 Both of these qualifications were in stainless steel, 7 one on a three-inch Schedule 40 test and one on a 8 three-inch Schedule 160. 9 0 Well, the f act was that the tests indicated that the 10 welder should have been limited in his thickness range; 11 is that correct? 12 A That's correct, and he was referenced as being unlimited 13 for stainless steel welding. 14 0 What investigation, if any, did you make to determine 15 whether or not those welders had performed welds on i 16 stainless steel material outside their thickness range? 17 A We investigated the material thicknesses that we weld, 18 and none of the thickness ranges are above their range 19 of qualification. 20 Q All right, sir. 21 4653? 22 A 4653 -- the Form 88 was not signed by Comstock. PTL 23 test results were not entered on the Form 88, and test 24 results were acceptable. 25 The second discrepancy was that the Form 88 was not (} Sonntaa Reporting Service, Ltd. Geneva, Illinois 60134 (312) 232-0262
3507 1 signed by Comstock. Again, the test results were 2 acceptable. 3 0 All right, sir. 4 46547 5 A The Form 88 showed the welder originally qualified on a 6 one-inch plate in the 3G and 4G positions on 5/8 of 7 1980. He was given a three-eighths-inch requalification 8 test in the 3G and 4G positica on 4/16/81. 9 The three-eighths-inch on the Form 88 was changed 10 to one-inch in error by the inspector administering the 11 test. The test results are root and face bends for 12 three-eighths-inch plate and are accepted. 13 0 Well, what is the significance of the thickness of the 14 material on which the requalification test was given? 15 A The requalification test -- if the welder was originally 16 qualified for unlimited thickness, he could requalify on 17 a three-eighths-inch coupon and, if acceptable, maintain 18 his unlimited-thickness qualification. 19 0 Is that, in fact, what happened here? 20 A Yes. 21 Unfortunately, the inspector changed the 22 three-eighths en the form to one-inch because the 23 thickness range referenced unlimited thickness. 24 0 All right, sir. 25 4655? [} m antag on,nra ng_s:,ruic.. r+a_ n Geneva, Illinois 60134 (312) 232-0262
3508 O 1 A A six-inch Schedule 80 test was given 4/20/79 and not 2 signed by Comstock. The PTL test results were accepted. 3 In addition, the visual inspection on the test is signed 4 in the wrong area. The test results f rom PTL are 5 acceptable, with a continuation sheet. 6 The welder retested on one-inch plate in the 3G and 7 4G positions on 12/1/80. The material specification had 8 A106 and A304 stainless steel typed in. The material 9 used was A36 plate. 10 Filler metal classification had E7018, 308 and 309 11 typed in without the type of rod being used circled. 12 The bend tests f rom the PTL reports were accepted. 13 In addition, Mr. Mead was retested on one-inch plate 14 again in the 3G and 4G positions and found to be 15 acceptable in July of '82 and September of '85. 16 Q What is the significance that A36 material was used when 17 the ASTM specification was supposed to be A106? 18 A Again, the A106 material would only be used for a pipe 19 test; and the test positions given were 3G and 4G, which 20 were plate tests. 21 Q All right. 22 Finally in this series, Mr. Simile, No. 4656. l 23 What's the nature of the discrepancy there? 24 A A welder visual inspection was not performed on his l 25 original six-inch Schedule 80 test on 11/13/78. The l [} Sonntac Reportino Service, Ltd. Geneva, Illinois 60134 (312) 232-0262
... ~ 3509 1 side bend tests were acceptable. 2 In addition, he pascad a three-eighths 3G and 4G 3 test for requalification on 5/1/80. 4 Q Now, Mr. Simile, have you had occasion to review welder 5 qualification records at sites other than Braidwood? 6 A Yes. 7 Q Are the type of discrepancies that you've described and 8 that are documented on these Comstock NCR's Nos. 4649 9 through 4656 common or uncommon, in your experience? 10 A I think the type of discrepancy would be a common error. 11 0 Taken as a group, how would you characterize the 12 significance of these discrepancies? O 13 A Minor. 14 MR. MILLER : Off the record. 15 (There followed a discussion outside the t 16 record.) f 17 JUDGE GROSSMAN: Back on the record. 18 We'll recess now until 9:00 o' clock tomorrow i 19 morning. 20 (WHER EU PON, the hearing of the 21 above-entitled matter was continued to l 22 the 10th day of June, at the hour of 9:00 23 o' clock A. M.) i 24 C:) 25 l onntag D= porting Aervice-L*d-c Geneva, Illinois 60134 (312) 232-0262
CERTIFICATE OF OFFICIAL REPORTER b,, This is to certify that the attached proceedings before the UNITED STATES NUCLEAR REGULATORY COMMISSION in the matter of: NAME OF PROCEEDING: COMMONWEALTH EDISON COMPANY (Braidwood Station, Units 1 & 2) DOCKET NO.: 50-456 OL; 50-457 OL PLACE: JOLIET, ILLINOIS DATE: MONDAY, JUNE 9, 1986 were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission. (sigt) (TYPED) GLENN SONNTAG Official Reporter ACE-FEDERAL REPORTERS, INC. Reporter's Affiliation (3 w)}}