ML20213C989
| ML20213C989 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 10/31/1986 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| CON-#486-1515 OL, NUDOCS 8611100380 | |
| Download: ML20213C989 (100) | |
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t UNITED STATES <
NUCLEAR REGULATORY COMMISSION IN THE MATTER OF: DOCKET NO: 50-456 OL 50-457 OL COMMONWEALTH. EDISON COMPANY (Braidwood Station, Units 1 and 2) l l
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LOCATION: CHICAGO, ILLINOIS PAGES: 16581 - 16660 DATE: FRIDAY, OCTOBER 31, 1986 k
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0 Q ACE-FEDERAL REPORTERS, LNc.
Official Reporters 444 North CapitolStreet Washington, D.C. 20001 8611100380 861031 (202)347-3700 PDR ADOCK 05000456 -
T PDR NADONWIDE COVERAGE ,
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-f v) 1 UNITED STATES OF AMERICA I I
2 NUCLEAR REGULATORY COMMISSION l
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{ 3 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4
__----------__--_x l 5 :
} In the Matter of: :
} 6 : Docket No. 50-456 OL
) COMMONWEALTH EDISON COMPANY : 50-457 OL ,
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- i (Braidwood Station, Units 1 :
8 and 2) :
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10 Pages 16581 - 16660 )
11 United States District Courthouse Courtroom 1743 l I~)
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12 219 South Dearborn Street Chicago, Illinois 60604 l 13 Friday, October 31, 1986.
l l 15 The hearing in the above-entitled matter reconvened l l
I l 16 at 8:00 A. M.
l 17 BEFORE:
18 JUDGE HERBERT GROSSMAN, Chairman 19 Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission 20 Washington, D. C.
21 JUDGE RICHARD F. COLE, Member, Atomic Safety and Licensing. Board 22 U. S. Nuclear Regulatory Commission Washington, D. C.
23 JUDGE A. DIXON CALLIHAN, Member, 24 Atomic Safety and Licensing Board f( 25 U. S. Nuclear Regulatory Commission Washington, D. C.
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iN I 1 APPEARANCES-l 1
2 On behalf of the Applicant:
3 MICHAEL I. MILLER, ESQ.
PETER THORNTON, ESO. l 4 Isham, Lincoln & Beale Three First National Plaza l 5 Chicago, Illinois 60602 l l
6 On behalf of the Nuclear Regulatory Commission Staff:
7 GREGORY ALAN BERRY, ESQ.
8 ELAINE I. CH AN , ESO.
U. S. Nuclear Regulatory Commission 9 7335 Old Georgetown Road Bethesda, Maryland 20014 10 On behalf of the Intervenors:
11 ROBERT GUILD, ESQ. l Is\ 12 l
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1 EXHIBIT INDEX Marked Received 2 Applicant's Exhibit No. 90 16608 3 Staff Exhibit No. 24 16637 4
TESTIMONY OF JOSEPH PAUL HII 5
DIRECT EXAMINATION 6 BY MR. THORNTON: 16605 7 Prefiled testimony of Joseph Paul Hii 16608 8
CROSS EXAMINATION 9 Enf MR. GUILD: 16609 10 CROSS EXAMINATION
! BY MR. BERRY: 16637 11 BOARD EXAMINATION I\; 12 BY JUDGE GROSSMAN: 16644 N./
13 REDIRECT EXAMINATION BY MR. THORNTON: 16646 14 RECROSS EXAMINATION 2 15 BY MR. GUILD: 16650 16 BOARD EXAMINATION BY JUDGE CALLIHAN: 16652
'17 BOARD EXAMINATION 18 BY JUDGE GROSSMAN: 16653 19 RECROSS EXAMINATION BY MR. BERRY: 16654 20 BOARD EXAMINATION 21 BY JUDGE GROSSMAN: 16655 22 RECROSS EXAMINATION (Continued)
BY MR. GUILD: 16655 23 24 4
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1 JUDGE GROSSMAN: The hearing is reconvened.
2 This is the 85th day of hearing.
3 Do we have any preliminary matters?
4 MR. BERRY: Just one, Mr. Chairman.
5 Yesterday Staff held an in-camera briefing with the 6 Board with respect to a recent allegation that came to 7 Staff's attention in some weeks past that we brought to 8 the parties' attention.
9 During that briefing we made available to the Board 10 a copy of a memorandum dated October 20th from Charles 11 H. Weil and Carl J. Paperiello. We agreed with the 12 Board that copies, expurgated copies, of that document 13 should be made available to the parties.
14 We undertook to produce such copies, and I have 15 them with me in the courtroom today and available to 16 distribute to counsel for the Applicant and the 17 Intervenors, subject to the same protective provisions 18 that have attached to the documents previously 19 disclosed.
20 JUDGE GROSSMAN: Okay.
21 Mr. Miller, you look a little puzzled. Let me 22 refresh your recollection that this concerns a further 23 alleger, and we had some discussion about that at some 24 earlier occasion.
25 Now, let me indicate that there were a number of Sonntag Reporting Service, Ltd.
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1- concerns raised by the alleger. There were eight 2 original concerns. We had our in-camera briefing 3 yesterday morning with regard to these concerns.
. 4 The Board directed -- and it was acceptable to-5 Staff -- that Staff turn over a redacted version-of the 6 inspection tieport, which basically -- I'm sorry. It's 7 not an inspection report, but it's a memorandum written 8 by -- drafted by the inspector, who happened to have 9 been Mr. Schapker inspecting those concerns.
10 Now, with regard to the first five concerns, we 11 decided that they were not relevant. Therefore, we're 12 not requesting Staff to turn over any information with 13 regard to those concerns. Those have been redacted from
-14 what is being turned over to counsel.
15 There were two additional concerns, raised by the 16 alleger, that had not been field-investigated yet by Mr.
17 Schapker. We reserved judgment on whether those matters 4
18 were relevant.
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19 Since they were also discussed in this memorandum 20 draf ted by Mr. Schapker and apparently signed by Mr.
21 Weil, approved by Mr. Weil as a reviewer and signed by 22 him, we redacted those two allegations until there is 23 some further investigation and further briefing to the 24 Board.
25 Now, that leaves Concerns 6, 7 and 8.
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1 In those concerns there are some names. It was the 2 position of Staff that those names might lead to the 3 identification of the alleger, and Staff took the 4 position that those names should be redacted. The 5 Board, by majority vote, agreed with the Staff and 6 redacted those names.
7 I dissent from that; and I believe, at least with 8 regard to Concern No. 7 and the second part of that, 9 that that name should be disclosed to the parties and 10 perhaps some other names within 6, 7 and 8.
11 I only state that for the record now so that the 12 parties have whatever recourse they wish in briefing the 13 case or in appeal. That's basically why I'm pointing 14 that out.
15 I will say my feeling was that, at least with 16 regard to that one name and possibly with regard to some 17 others, the information may not be useful without those 18 names.
19 Now, what has been turned over, the redacted 20 version, is subject to the same protective order that we 21 have promulgated or directed that the parties be bound 22 by, which means that the memorandum, the document, can 23 only be perused and viewed by legal counsel, the trial 24 counsel here, and not to the client or to anyone beyond
( j 25 counsel; that is, with regard to Applicant and Sonntag Reporting Service, Ltd. i Geneva, Illinois 60134 ,
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D 1 Intervenors. .
2 We have no similar restriction on-Staff, at least 3 with regard to this document.
4 Did I state everything correctly from your point of 5 view, Mr. Berry?
2 6 MR. BERRY: Yes, except one clarification, 7 Mr. Chairman.
i j 8 The document -- you stated that it was prepared by 9 Mr. Schapker, reviewed by Mr. Weil; and I believe it was 10 prepared by Mr. Weil and, I guess, concurred in or Mr.
11 Schapker agreed with it. But the document represents i
! #~'N 12 the work product of Mr. Weil.
t 13 JUDGE GROSSMAN: Oh, okay.
j 14 But my understanding was that Mr. Schapker did all' f 15 of the field investigation, although Mr. Weil did 16 discuss the allegations with the alleger.
- 17 MR. BERRY: That's correct.
l l 18 JUDGE GROSSMAN: And so the memorandum, while 19 written by Mr. Weil, then, does reflect the fieldwork by 20 - Mr. Schapker.
! 21 Is that so?
22 MR. BERRY: Well, I really believe it's more 23 the other way around.
24 Mr. Weil contacted the alleger and found additional
. 25 inf ormation, and Mr. Schapker used that inf ormation to Sonntag Reporting Service, Ltd.
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I conduct the field inspection.
2 JUDGE GROSSMAN: Oh, okay. Well, that's 3 fine. I just want to get that straight on the record.
3 4 MR. GUILD: Mr. Chairman?
I 5' JUDGE GROSSMAN: Are there any other 6 preliminary matters?
7 MR. . GUILD: .Mr. Chairman, when you referred 8 to " trial counsel," I assume, consistent with prior 9 practice with respect to the protective order, that
- 10 includes my trial assistants, who are not formally q
11 counsel.
12 JUDGE 'GROSSMAN : Yes. We've already
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- 13 discussed.that, and that's been extended to your trial i
j 14 assistants whether or not they're members of the bar.
15 MR. MILLER: Your Honor, could we approach 16 the bench?.
.i 17 JUDGE GROSSMAN: Sure.
18 Perhaps the witness ought to go to the back of the 19 courtroom, then.
20 MR. THORNTON: Do you want to step out?
f 21 (Witness excused.)
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- 22 MR. MILLER
- In the past there have been
! 23 indications that even though the document itself is l
l 24 restricted in terms of its dissemination to trial 25 counsel, that the information that is in it can be the i, ,
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4 There are many facts that are set forth in this 5 document which are able to be checked, if you will, by 6 getting to the specific pieces of paper.
7 I-just want to confirm with the Board and with the 8 Staff that that sort of investigation can go forward 9 without any attribution to the NRC investigation or to 10 any individual that you mentioned here.
11 JUDGE GROSSMAN: I don't believe that's the 12 case with regard to this document.
13 I think that any further investigation, which 14 includes contact with your client, would jeopardize the 15 identity of that individual.
16 Is that your understanding, Mr. Berry?
17 MR. BERRY: I believe so. But what I'll 18 represent, Mr. Chairman, is that I'll discuss this 19 matter again with the Region.
20 Mr. Miller has, I believe, portrayed what's been 21 the prior practice. As we mentioned before, this 22 document here, with respect to this particular alleger 23 -- he has been granted confidentiality. So it does 24 stand at a slightly different footing.
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4 JUDGE GROSSMAN: The reason I say there's a 5 difference, though, is that I-think, by your discussing 6 these~ matters with your client, your client could well 7 identify that individual.
8 So with regard to this particular document, perhaps 9 the only use for it might be on examination of witnesses i
10 here. If that occurs, then you might ask that the Board 11 have an in-camera session with regard to that. Also, 12 there's an opportunity for briefing on this.
(
13 I don't know how much practical investigation can 14 be done in the form that you've received that. With 15 your, Mr. Miller, going to your client with that, I 16 think the only result would be the identification of the 17 alleger, rather than anything constructive.
18 I don't know. I can only make my personal j 19 cvaluation.
20 MR. MILLER: Sure.
l 21 JUDGE GROSSMAN: I can't really -- j 22 MR. MILLER: Well, there are, of course, 23 specific documents identified in Concern No. 8 that 24 could be obtained and made available to Mr. Guild and j (j 25 the Staff, for that matter.
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1 Again, I think that we could frame a request or 2 undertake a search with personnel from our own office 3- for these documents without necessarily indicating the 4 purpose for which it was sought.
5 But if you're concerned about compromising the 6 identity of the alleger even by that step, well, of 7 ' course, we won't do it.
8 JUDGE GROSSMAN: Well, I don't know that 9 without having the full context of that Concern No. 8, 10 which we've gotten considerably more in camera yesterday 11 than is here, that just the location of that document 12 itself means anything with regard to this allegation.
13 I don't think that the existence of the document 14 itself was the concern.
15 JUDGE COLE: I agree.
16 JUDGE GROSSMAN: The fact that you might find 17 that document somewhere is not really what was a problem 18 here.
i 19 I don't want to say any more, because I'm concerned 20 about disclosing more than is in this document. I just 21 don't want to leave you with an erroneous opinion.
22 MR. GUILD: The only thing I'd add, Mr.
23 Chairman, is that as Mr. Miller has probably observed in ,
24 the past, in an adversary proceeding, both the 1 25 adversaries in this case, Applicant and Intervenors, l
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1 have an interest in investigating facts that are of 2 relevance. Without disparaging the NRC Staff's approach 3 to investigating for their purposes, we have our own 4 purposes.
5 We would just urge the Board and the Staff to 6 disclose as much information to the adversaries as 7 possible so we can do our own work and not have to 8 simply rely on Mr. Berry or Mr. Schapker or the Staff to 9 reach its own conclusions.
10 JUDGE GROSSMAN: Well, under our ruling, 11 Staff is always free to disclose more information 12 without coming to the Board.
(U} 13 Of course, we'd expect you to tell us what you're 14 disclosing further; but we have no prohibitions in our 15 order against Staff disclosing as much as it wishes, as 16 long as both parties are apprised of the information.
17 MR. BERRY: The Staff is just guided by the 18 Commission's policy statements and its good judgment, 19 and I believe our disclosure in this instance has been 20 more than sufficient.
21 I would note that, really, at the step we're at, 22 there's been a briefing to the Doard; and the Staff han 23 made known its views regarding the relevance of this s 24 information to the issues in the proceeding. That 25 matter is under consideration, and the Board has yet to Sonntag Reporting Service, Ltd.
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1 make a ruling on that.
2 So at this point I really don't see that it's 3 necessary for either Applicant or Intervenors to 4 undertake an investigation of these matters yet.
5 In the event the Board were to determine that these 6 matters were beyond the scope of the proceeding and were 7 not relevant and material to the proceeding, there would 8 be no need to conduct any investigation into that 9 matter.
10 So I don't believe that we shoul'd jump the gun at 11 this point. We should wait for the Board to review 12 what's been presented to them and make that 13 determination.
14 MR. GUILD: Mr. Chairman, if Mr. Berry is 15 speaking about Concern No. 8 and if he seriously 16 contests the relevance of that matter -- I don't say the 17 materiality; I say the relevance -- then perhaps we' re 18 not even speaking the same language here because --
19 MR. BERRY: Oh, well, I just want my position 20 to be clear.
21 This information was made availalle, made known to :
22 the Board and the parties, because the Staff did, in 23 fact, determine that it appeared to be relevant to the 24 proceeding. l 25 Now, the question is, under the Commission's policy 1
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1 statement regarding late-received allegations -- it is 2 relevance and materiality, and there is some guidance as 3 to what the Commission means by " materiality "
4 That is the matter that would have to be determined 5 by the Board before there's any further action taken.
6 MR. GUILD: Mr. Chairman, that is exactly the 7 problem I have.
8 You see, now we know that there's a matter that's 9 of colorable relevance. We think at this stage it's not 10 for the Board to determine materiality, because 11 materiality only goes to whether or not there should be 12 a Board notification in the first instance.
13 It's not simply a question of burdening the Board, 14 because there's two adversaries that know that there's 15 relevant information. It should be up to the adversary 16 parties to process that information and make our own 17 efforts to show materiality if we think it's material.
18 But it shouldn't depend on either the Staff's 19 judgment or the Board's judgment now that we've 20 identified a matter that's relevant.
21 The discovery rules come into play, in our view.
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Iv 1 to the adversaries to try to process that information.
2 JUDGE GROSSMAN: Well, let me just correct 3 one thing about -- I don't know if " correction" is the l
t 4 right word -- Mr. Berry's statement.
5 I, speaking as one Board member, do not view 6 Concern No. 8 as a new issue, a new concern. To the 7 extent that it's relevant, it is because it relates to 8 an issue that's already before us.
9 MR. BERRY: Yes, I agree, Mr. Chairman.
10 JUDGE GROSSMAN: Okay. Now, how that affects 11 what was said, I don't really know.
' 12 But I take it you' re saying now that the Board 13 hasn't yet gone forward and said these matters are 14 relevant or irrelevant?
15 I'm not sure whether you're putting the ball back 16 in our court for something further.
17 MR. BERRY: Let me make our position clear.
18 Ordinarily, as Intervenors pointed out, Staff would 19 receive an allegation, and we wouldn't have to do 20 anything until we determined whether this was a matter 21 this should be brought to the Bcard's attention.
22 In this particular instance, given the fact that in 23 this case Concern No. 8 appeared to relate to a matter s 24 then pending in the proceeding, we made known to the 25 Doard that we received the allegaticns.
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U 1 We did not conduct the preliminary investigation 2 contemplated by the Commission's policy statements 3 because that may well take a substantial amount of time 4 and the proceeding may well have been over.
! 5 In the interest of expediting that, we made known 6 to the Board that we received the allegations, but we 7 made known to the Board the information in the form 8 which we received it.
9 So subsequently we also notified the other parties 10 of that. Then we conducted the investigation, wherein l s
11 then at that point Staff took the position as to whether fT 12 the information was relevant and material.
V 13 Ordinarily in the normal course, what would have l 14 happened is we would have made that determination, l i
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15 notified the Board that we didn't believe it was )
16 material, and we would not have --
17 JUDGE GROSSMAN: Disclosed the information?
18 MR. BERRY: -- disclosed the information. l 19 JUDGE GROSSMAN: Okay, but let me make sure 20 now. l l
21 Because we've speeded it up, have you already
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22 determined whether this is relevant or not relevant or i
23 have you yet to make that determination? l 24 MR. BERRY: Material. !
25 JUDGE GROSSMAN: Okay, material. ;
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l 1 MR. BERRY: We made the determination, as we 2 stated yesterday, that Concern 8 is relevant. It is i 3 relevant.
4 The other matters reflected in the information that 5 we presented are not material to the proceeding. !
6 JUDGE GROSSMAN: Okay, but did you determine 7 that Concern 8 is material?
8 MR. BERRY: No. It's relevant, but-not 9 material, also. I believe when you review the 10 transcript from yesterday, you'll see our position.
11- JUDGE GROSSMAN: Okay. So basically you're 12 saying that none of these -- I'm not sure I understand.
13 Now, let's get to materialAty and relevance with 14 regard to all three of these things or each of the 15 three.
16 MR. BERRY: Our position is none of them are 17 relevant and material. One of them at least is 18 relevant, but the one that's relevant is not material.
19 JUDGE GROSSMAN: And that's No. 8 that you 20 say is relevant?
21 MR. BERRY: Yes.
22 JUDGE GROSSMAN: The other two you say are 23 not relevant? ;
24 MR. BERRY: Right.
25 JUDGE GROSSMAN: So No. 8 is relevant but not [
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1 material?
2 MR. PERRY: That's correct.
3 I believe that's reflected in the transcript from 4 yesterday.
5 JUDGE GROSSMAN: So it really is up to the 6 Board now to either agree or disagree with that and then 7 to take further action, so we'll have to caucus on that 8 and make our determination.
9 JUDGE COLE: Mr. Miller indicated the other 10 day as to the content of that October let letter, and I 11 found my copy of that letter.
12 MR. MILLER: Oh.
(
13 JUDGE COLE: So I think you could look at 14 that and get it back to me.
15 (Indicating.)
16 MR. MILLER: Thank you. I will.
17 JUDGE GROSSMAN: So far we haven't said 18 anything that has to be in camera. I don't like to make 19 items in camera when it's not necessary.
20 Is there any problem that you see with in camera 1
21 here, Mr. Berry?
22 MR. BERRY: No, your lionor.
23 JUDGE GROSSMAN: Okay. Maybe we'll discuss 24 this by ourselves, the Board, and maybe we'll have some
) 25 further opinion now.
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'v) 1 MR. GUILD: May I just take one position 2 briefly for the record so that I'm not at any point 3 accused of sleeping on my rights?
4 I just want to be perfectly clear, with respect to 5 Concern No. 8, that we formally request an opportunity 6 to discover any information that the NRC has that's 7 discoverable.
8 We believe it's relevant. We believe it's 9 reasonably calculated to lead to the identification of 10 admissible evidence.
11 I don't think I need to say anything further. I'm f~)
V 12 going to try to avoid saying anything more so we don't 13 have to go in camera, but I think the Board and parties 14 are aware of the substance.
15 JUDGE GROSSMAN: There's an implication from 16 what you're saying that you're not taking that same 17 position with regard to the other concerns.
18 MR. GUILD: I do want discovery of the other 19 concerns, but No. 8 on its face seems of apparent 20 discoverable character; and since Mr. Berry is not 21 taking the position that it's material, I have no other 22 position but to say that I think it's discoverable.
23 JUDGE GROSSMAN: Okay, but I expect that you 24 would want to read this and take further positions, both 25 parties.
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1 I will say that I think this cuts both ways and not 2 just with Intervenors having an interest in having it 3 discovered but, considering the burden of proof, that 4 Applicant may also have an interest.
5 I don't want to even attempt to define what the 6 interests are. That's for the parties to consider.
7 But maybe we'll take a very short break now, and we 8 may have some further ruling or we may not. I don't 9 want to waste too much time on this.
10 JUDGE CALLIHAN: Mr. Berry?
11 JUDGE GROSSMAN: I'm sorry. We're not 12 finished yet.
13 JUDGE CALLIHAN: If anybody looks into this, 14 the annoying typo on the eighth line of "new 15 information" in your contention might be pointed out. I 16 believe it's Hanger 5H3.
17 JUDGE COLE: Yes, that's correct.
18 JUDGE CALLIHAN: It's trivial, but it might 19 be annoying to somebody. Thank you.
20 MR. GUILD: Mr. Chairman, would there be an 21 objection f rom the Staf f or the Board to at some point 22 making this document an in-camera exhibit to see if it 23 could travel with the record for purposes of review?
24 JUDGE GROSSMAN: It is already in the 25 in-camera transcript that we have from yesterday's Sonntag Reporting Service, Ltd.
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1 briefing.
2 MR. GUILD: Fine. Thank you.
3 (WHEREUPON, a recess was had, after which 4 the proceedings were resumed as followst) 5 JUDGE COLE: Okay. We'd better hurry up 6 before we forget it.
7 (Laughter.)
8 JUDGE GROSSMAN: From what we've been 9 discussing here, it appears to the Board that Concern 10 No. 8 is relevant and material; that Concern No. 7, Nos.
11 1 and 2, are relevant; No. 2 is material; that Concern 12 No. 6 is relevant but not material.
( I don't think Judge Grossman 13 JUDGE COLE:
14 mentioned Item 3 under Concern No. 7.
15 JUDGE GROSSMAN: Okay. No. 3 being relevant t l 16 but not material. I thought that was part of what I l
l 17 said; but if not, that's how we decided.
18 Now, I don't know if we're required to take any 19 further action or whether the implications of our 20 determination are the actions themselves. i l
21 So Staff can consider our ruling and tell us if we 22 have to do anything further on that with regard to their 23 understanding of the policy statement.
! 24 If you have nothing further, we don't want to D
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2 MR. THORNTON: Excuse me, Judge Grossman.
3 Could I just ask one question? r 4 On 7, Nos. 1 and 2, as I heard you, you said 5 relevant.
6 Did you mean as with 3, relevant and.not material?
7 Did I miss it?
8 JUDGE GROSSMAN: No. 2 we said was relevant 9 and material.
10 MR. THORNTON: All right. I misheard.
11 That's fine.
, 12 JUDGE COLE: 1 and 3 were relevant but not C/ material, under Item 7, Concern 7.
13 14 MR. MILLER: Your Honor, having now the 15 ruling that at least two of these individual items are 16 relevant and material --
1 ~
17 JUDGE GROSSMAN: If you oit, you can speak 1
18 into the microphone.
19 MR. MILLER: -- I'd just urge the Staff to i
20 expedite their further advice to the parties as to what 21 can and cannot be done, because we are approaching what L 22 would otherwise be the conclusion of the hearing record.
23 JUDGE GROSSMAN: Which reminds me of one j g_s 24 further thing:
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1 determined were relevant but not material at this point, 2 because there are further recommendations we made to Mr.
3 Schapker with~ regard to the investigation.
4 If there are some matters that he reports back to 5 us one way or the other, it may determine whether there 6 is some materiality for what we cannot find to be at 7 this point material.
8 MR. MILLER: Your Honor, does the Board have 9 any estimate from Mr. Schapker as to when you're going 10 to hear further from him?
11 JUDGE GROSSMAN: I have no judgment as to Mr.
12 Schapker's investigatory --
13 MR. BERRY: That's correct. The Board has no 14 jurisdiction over directing the Staff in the course of 15 its duties.
16 But we are mindful of the proceeding and the 17 strains we're operating under. Consequently, I've 18 directed -- or I've requested Mr. Schapker to give this 19 matter his immediate attention.
20 JUDGE GROSSMAN: We' re f amiliar with the 21 precedent with regard to what we can direct and net 22 direct with regard to the Staff, so we'll just have to 23 await Mr. Schapker's further briefing.
24 MR. GUILD: Mr. Chairman --
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1 that has to be said, Mr. Guild, please try to do it as 2 quickly as possible.
3 MR. GUILD: Mr. Chairman, just to cover the 4 waterfront to protect our position, we would ask for 5 discovery, under the Commission's rules, of all matters 6 that are identified as relevant.to this proceeding 7 whether at this point identified by the Board as 8 material or not. We believe that's consistent with the 9 discovery rule.
10 JUDGE GROSSMAN: Okay, fine. Why don't we 11 call the witness in, then.
(O O
12 MR. BERRY: I would just object to that 13 request just for the record, and we're prepared to 14 respond to the matter more fully at a later date next 15 week.
16 JUDGE GROSSMAN: Okay. Let me point out to i 17 the Reporter there has not been said anything further 18 that would require an in-camera transcript here.
19 THE NOTARY: Okay.
20 JUDGE GROSSMAN: Mr. Thornton, please call 21 your next witness. I 22 MR. THORNTON: Yes, your Honor. My next 23 witness is Joseph 1111.
24 JUDGE GROSSMAN: Mr. Hii, would you please 25 stand and raise your right hand?
(
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262 l
l 16605 l
.\
1 (The witness was thereupon duly sworn.)
2 JUDGE GROSSMAN: Please be seated.
3 JOSEPH PAUL HII 4 called as a witness by the Applicant herein, having been-l 5 first duly sworn, was examined and testified as follows:
! 6 DIRECT EXAMINATION
^
7 BY MR. THORNTON:
8 0 Mr. Hii, would you please state your full name and your 9 business address for the record?
10 A I'm Joseph Paul Hii. I'm employed at the Braidwood 11 Station in Braceville, Illinois.
l 12 0 Mr. Hii, do you have in front of you a document
( consisting of eight typed pages, which is headed 13
} 14 " Rebuttal Testimony of Joseph Hii"?
15 A Yes, I do.
16 0 And is that testimony that you have prepared to submit i 17 in this proceeding?
18 A Yes, it is.
f 19 -0 And attached to that testimony, is there a number of i
20 documents which are labeled " Attachment 1 to Rebuttal 21 Testimony of Joseph Hii"?
l
! 22 A Yes, it is.
23 0 Are there any corrections or additions that you would 24 like to make to your prepared testimony?
l 7,,
i
( 25 A No, sir.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
16606
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1 Q Now, with regard to this attachment, Mr. Hii, are you .
2 the vault supervisor for the Comstock Company?
3 A Yes, I am.
4 Q And in that capacity, are you the custodian of the QC 5 documents that are maintained in that vault?
~6 A Yes, I am.
7 Q And does the attachment to your testimony represent 8 documents that you have personally looked for and found 9 among the records in that vault?
10 A Yes, they are.
11 Q Would you please turn to the first page of Attachment 1 12 to your rebuttal testimony.
b 13 Does that first page represent the document that 14 you personally located in the vault?
15 (Indicating.)
- 16 A This document itself?
17 Q The first Attachment 1, Mr. Hii.
18 A (Indicating.)
19 0 That's correct.
20 A What was the question, please?
21 0 Does that first page represent the document that you 22 found in the vault?
23 A No, it does not.
24 0 What does that represent?
25 A This document I filled out myself reflecting the Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
h 16607 A
k 1 documents attached that I did find in the vault.
2 .O Mr. Hii, I show you now a copy of some more documents.
3 These have been marked previously for identification as !
4 Applicant's Grcup Exhibit 90.
5 (Indicating.)
6 Would you take a minute to look at' them, please? )
l 7 Can you identify for us the documents that have l i 8 been identified as Applicant's Group Exhibit 90, Mr.
1 9- Hii? .l l
l 10 A Yes, I can. l' l
l 11 Q And what do they represent?
s 12 A These were the first 10 MRR's that I found on the search 1 N ~
l 13 that I performed.
l 14 0 Again, these are documents that were in your custody as
, 15 supervisor of the vault?
16 A Yes, they were.
17 0 And you made a personal search through the QC f, 18 documentation in the vault and found these documents 19 there?
l 20 A Yes, I did.
21 MR. THORNTON: Your Honor, I would ask that 22 Mr. Hii's testimony be admitted in evidence and bound 23 into the record as if read, including the attachments 24 thereto, and that Applicant's Exhibit 90 for 25 identification also be admitted in evidence.
Sonntag Reporting Service, Ltd.
Geneva, Ilfinois 60134 (312) 232-0262
16608 A
1 JUDGE GROSSMAN: Mr. Guild?
-2 MR. GUILD: I have no objection, Mr.
3 Chairman. l 4 MR. BERRY: No objection, Mr. Chairman.
5 JUDGE GROSSMAN: We'll receive all of that, 6 and the testimony with the exhibits attached will be 7 bound into the record as though presented here at the 8 hearing. That includes-receiving Applicant's Exhibit
- 9 90.
{
10 (The documents were thereupon received 11 into evidence as Applicant's Exhibit No. l 12 90.)
l 13 l
14 j 1s f
l 16 17 18 19 20 21 22 23 24 25 l l
Sonntag Reporting Service, Ltd. l Geneva, Illinois 60134 l
()
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY-AND LICENSING BOARD In the Matter of: -)
)
COMMONh'EALTH EDISON COMPANY ) Docket Nos. 50-456
) 50-457 (Braidwood Nuclear Power )
Station, Units 1 and 2) )
,- ~s REEUTTAL TESTIMONY OF JOSEPH HII l
l O\v
' 'V'[' '} . REBUTTAL TESTIMONY OF JOSEPH HII
.Q.l. Please state your name, employer and your present position.
A.l. My name is Joseph Hii. I am employed by L.K. Comstock as'its QC Supervisor of Document Control (" Vault Supervisor") at Commonwealth Edison Company's Braidwood-Station.
Q.2. Please describe your employment history with Comstock at-Braidwood.
A.2..I was first employed by Comstock at Braidwood in August, 1980 as a document control clerk. I became certified as a Quality Control Level I inspector in
- July of 1981, and attained certifications in CEA's and
_ Configurations. I became a Level II approximately one ye'ar later. In August of 1983, I also became certified in weld inspections. In mid-April, 1985, I took over-Mr. Rick Saklak's position as QC Supervisor, and I continued in that position until April, 1986, when I because the Vault Supervisor.
Q.3. Please describe your current responsibilities as Vault Supervisor.
A.3. I am responsible for supervising the personnel and activities related to Comstock QC records and QC record i
- l turnover. l l
-Q.4. What is the purpose of your testimony?
1
.c[ , } A.4. The purpose of my testimony is: ~ (a)-to describe my gj search for all Material Receipt Reports (MRR's). signed by Mr. John Seeders during the period August 8th through August 15th, 1984; (b) to describe my additional search.for any MRR's signed by bhr. Seeders on' August 16th or 17th, 1984; (c)~to respond to the testimony of others regarding a Form 19 checklist signed by Mr.
DeWald which is claimed to have more than a thousand welds documented on it; (d) to address my reason for visiting'the NRC on March 29, 1985; (e) to respond to Mr. Puckett's testimony that I lost a test on which he supposedly scored 100%; and (f) to describe what types of documents I found in Mr. Saklak's desk drawers when
() I replaced'him in April, 1985.
Q.5. Please describe the searches which you performed for Mr. Seeders' MRR's.
A.S. As I mentioned above, I performed.two sets of searches 4
for the MRR's. I first reviewed our Comstock QC Vault-records for MRR's from August 8th through August 15th, 1985. Later, counsel for CECO asked me to perform an additional search for MRR's signed by Mr. Seeders on August 16 or 17, 1985. I performed that search as well.
"Y
(>] In both cases, I performed my search in Comstock's Vault, the department for which I am personally responsible.
With respect to my earlier search, the ten sets of documents identified'as Applicant's Exhibit 90 constitute.the entirety of the.MRR's for Comstock during the period of August 8-15, 1984.
~
All of them appear to bear Mr.
Seeders' signature. Likewise, the threr cets of documents attached as Hii-I constitute the entirety of the MRR's for Comstock during August 16 and 17,;1984. They too, bear his signature.
Q.6.'Please describe your knowledge, if any, of the exist-ence of a Form 19 checklist signed by Mr. DeWald which documents the-inspection of more than a~ thousand welds.
A.6. I have heard many rumors about the DeWald Checklist.
I have never seen it, and to the best of my knowledge, (v~')
there is no such document. .In my capacity as Vault
. Supervisor, I am responsible _for certain turnover activities. One such responsibility is to ensure the completeness and acceptability of.each QC document
. package being turned over to Commonwealth Edison. In the course of these duties,-I am certain that if such a document existed, I'would have seen and remembered it.
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Q 7. Let me direct your attention now to the visit by 24 or so QC. inspectors to the NRC on March 29, 1985. Do you have-any, personal knowledge of such a visit?
JA.7.' Yes. I was one of the group of inspectors who went to 4
'the NRC during our lunch break.
Q.8. How did you learn that the visit;was to take place?.
- A.8. I overheard Mr. Larry Bossong tell'ing Mr. Franco Rolan that the NRC wanted anyone who might have'had an incident with Rick Saklak to go over.
, I had experienced an incident with Rick Saklak
, several years before. Because I : learned that Terry Gorman, who had witnessed my incident was going to visit the NRC, I decided to go'as well.- I wanted to make sure that if my incident with Saklak came up, that (f it would be accurately described.
Q.9. Please describe the incident you experienced with'Mr.
Saklak.
A.9. I can only recall now that it was in 1982 or early 1983, that he and I-were standing in .the vault area, and that Rick was yelling at me because I hadn't finished a project. .I recall trying to explain to'him-the problems I was having~with it, and that he kept saying "Do it, do it." I do not recall the nature of the project, although I did recall it in March, 1985.
The next day, I pulled Rick aside and talked to
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rN him about the incident and the problems I was having
'd ~
with the project. We discussed both the incident and the project, and resolved them both during that discussion.
Q.10.Did this incident cause you to fear Mr. Saklak thereafter?
A.10.No, it did not cause me to feel intimidated by Rick, nor.did it ca'use me to fear him. He did have a temper, and I felt.he lacked sensitivity in his dealings with personnel. Nevertheless, I always found' Rick to be quality-conscious and dedicated.
Q.ll.Did'you observe the circumstances underlying the March 29 group visit to the NRC?
A.ll.I observed that the visit appeared to be triggered by an incident the previous day between Saklak and Snyder. Although I was not a witness to the incident,
. f%
(-) I did hear about it from other inspectors. I also observed that tension and hostility existed between inspectors-i and management before our visit to the NRC. I experienced some of that hostility myself. I don't mean to suggest
.nat the incident between Snyder and Saklak wasn't serious, since I didn't see it. I do believe that some individuals saw the incident as an opportunity to make themselves appear more powerful than management.
Q.12.You mentioned in your prior answer that you " experienced" hostility from some inspectors. What did you mean by that?
.A.12.I was one of the members of the voting body who was opposed to unionization. I did not try to hide that t
/ fact. Among other irtidents during the course of the a !)
s d
a
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. g~'
union organizing ~ effort in.the late summer of 1984, the (J.
tires of my car were' slashed in the site parking lot on several different occasions. I was not the only one to whom this' happened.
.The atmosphere eased for a'short time after the union vote in November. By early 1985, I saw that the organizers and others'-in favor.of the union appeared to become impatient because the vote had'not been ratified.
Just a few weeks-before our visit to the NRC, the union staged a Saturday sick-out. I was one of the handful 1 of QC inspectors who'nevertheless reported to work that day. The inspectors who had supported the sick-out
.made clear'their hostility-to me after'this incident.
q( ) This led me to believe that they viewed me as siding with management.
Q.13.You also mentioned that you observed hostility and tension between the-OC inspectors and management. To what were you referring?
A.13.In addition to a general atmosphere of tension, several specific incidents led me to'that observation. First, the car vandalism I referred to earlier was experienced
.s 4
by several members of Comstock management as well.
Another specific incident was the sick-out, which I also referred to earlier.
.g.
- f I-
\~/ Q.14. Turning 1now to the topic of Mr. Worley Puckett, are you. familiar'with that. portion of his testimony that he had taken a test which was subsequently' lost, and that.you had told him that he had scored 100% on it?
A.14.Yes.
Q.15.Please describe your knowledge, if any, about the substance.of Mr. Puckett's testimony.
.A.15.I h' ave no recollection of such an incident ever taking place. I do not recall a test being lost or disap-pearing. Additionally, I-did not grade Mr. Puckett's tests, practical or written. I would not have known what his score was on any test unless someone else had graded it and then told me the r.esults. Finally, I have no r'e collection of ever telling. Mr. Puckett about any score he might have received.
f'\
l Q.16. Finally,~please describe the types of documents which you found in Mr. Saklak's desk drawers when you replaced him as QC Supervisor.
A.16.One of the first tasks assigned to me by Mr. Simile ~was to clean out the desk drawers that I was to use. When I took over, the drawers were locked. I remember' seeing files of carbon copies of speed memos (generally QC inspector requests for time-off, and memos reflecting excessive no-pay' status) and copies of-memos dealing with trend analyses, etc. all of which were on Comstock letterhead. I kept those materials which I felt.I l I
would need as the new QC Supervisor; the rest I gave to
)
Mr. Simile.
.O
(,) ' O.17.'Are you aware of what is commonly' referred to as Rick-Saklak's Pearl Harbor file?
A.17.Yes, I am.
Q.18.Please describe the circumstances under which you first became aware of it.
A.18.The first-.timelt saw it was in 1982, shortly after Rick became QC Supervisor. It was a folder marked with the words " Pearl Harbor", and Rick kept it_in his desk..
Q.19.Did you have.the opportunity to become aware of its
, contents?
A.19.Yes. All I can recall now is that I saw copies of craft installation reports which Rick'was keeping to show Mr. Frank Rolan that they were not being filled out properly, and copies of other " construction problem" documents which Rick would periodically bring to Mr.
Rolan's attention.
Q.20.Was the Pearl Harbor file in Mr. Saklak's desk when you became QC Supervisor?
~
. A.20.No. .
Q.21.Does this complete your testimony?
A.21.Yes.
(
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4 UNITED STATES OF AMERICA j NUCLEAR REGULATORY COMMISSION 1-BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
- In the Matter of
- )
I )
l COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456 3
) 50-457 j . (Braidwood: Nuclear-Power )
i' Station, Units 1 and 2) )
!LO i
!. ATTACHMENT I TO '
j REBUTTAL TESTIMONY OF JOSEPH HII I.
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BG-3 Revision 8 h' ".}! Q"ttj:'fAtypipT'
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~ g,g p ap April 4,1984 Page 13 of 26 EXHIBIT C MRR No.
Electrical Physical Characteristics (B) Page1 ACC. REJ. N/A
- 1. Is the MRR number affixed to each item or each lot?
- 2. Are identification markings affixed to the O items and iesibie? .
- 3. Are the identification markings traceable to the shipping manifest or supplied documentation?
- 4. Are protective covers or seals in-place and intact?
- 5. Are there any preservative coatings present and, if so, still functional?
- 6. Are there desiccants / inert gas purges present,--
and are they functional? I V I i D * *NI** ie O - ..
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Q BG-3 Revision 8 April 4,1984 Page 14 of 26 EXHIBIT C Electrical Physical Characteristics Page 2 ACC. REJ. N/A
- 7. If the device is fluid filled or has a lubrication reservoir, has the orientation of the device been such as to preclude damage or leakage?
4-
- 8. Are lugs and terminal bloc'ks per '
CECO /S & L Standards?
- 9. If welding is present, is it consistent with standard electrical construction?
- 10. Are painting or galvanizing in an acceptable condition for storage? (subjective review)
- 11. Are edges free of burrs and smoo{h? _.
- ~ ~
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(0019P)
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v BG-3 Revision 8 April 4,1984 Page 15 of 26 EXHIBIT C Electrical Physical Characteristics Page 3 ACC. REJ. N/A
- 12. Is fastening hardware tight and consistent with good workmanship practices?
(Note any abnormal conditions, missing bolts,
! nut, washers, etc.)
O 13. if there are any special site requirements for electrical insulation testing, has OAD performed these or been notified? gg,- .- .
. s.e,. r g
e .
- i. NY t (List whom and when notified .)
Results of test: !
- 14. Is there rust, oil, scale, or dirt present in / .
amounts that may impair the usefulness of the part?
- 15. Are dimensions of rolled or sheared steel stock within the applicable AISC guidelines?
- 16. Are dimensions of fabricated enclosures Q Qunction boxes, etc.) as ordered?
. NO.
', n : -t (0019P) -i^r
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BG-3 0 nevision :
April 4,1984 Page 16 of 26 EXHIBIT C Electrical Physical Characteristics Page 4
- 17. Are all cable ends sealed for outside storage?
- 18. Are Cable Reels standing in an upright position at the time of arrival?
- 19. Are there are any gouges or any damage to cable Q jacket?
COMMENTS:
..- --.q39,
. w, .;:
i Calibrated Equipment Used if Applicable l
- Record objective evidence for any measurements, dimensional checks, fluid levels, weld aspects, etc. taken during the receipt in-spection.
If calibrated equipment is used for any inspection, record I.D. l number and calibration due date. l i
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- Inspected by: . *' #
//
1584-*
Date: -[
(0019P) B RA J'.'!CO J
, WESTINGHOUSE ELECTRIC CORPORATION CONTROL DIVISION CERTIFICATE OF CONFORMANCE CENERAL ORDER NO. IN 11211-CGC gyg 8/9/84 CUSTCMER F.C. 30. 197234 SPECIFICATION S&L2755 ggy, PROJECT Braid Wood #1 DRAWING REY.
EQUIPMDT/ MATERIAL DESCRIPTION size 1 overload NUMBER OF FIECES 28 CUSTOMER TAG No. S & L Soee. 2755 REARKSg Sim to AA13A (S# IN 11210903 - P.O. 42-91684N)
QUALITT CONTORMANCE TO APPLICABLE CODES AND SPECIFICATION:
I Control Division - Fayetteville N. C. Plant .
Q. A. Program ' ' ' , ' ,,,,W L. . 5 g~ ,. .. =. u. . & - '?
O .
DEVIATION NOTICE (5) I x INONE [ 1 APPLICABLE QDRs ARE LISTD RELOW 37 QDR NUMBER
____________ _____ - - _ _ _ _ _ _ _ - __________________ _= ________ _
~
WE EEREBT CERTIFT THAT THE ITEMS LISTED ABOVE EAVE BEIN MANUFACTURED AND FABRICATED IN ACCORDANCE TO THE QUALITT REQUIREMDiTS OF THE CODES / STANDARDS /
SPECITICATIONS ITEMIZED ABOVE AND ALL OTHER CUSTOMER REQUIREMENTS LISTED IN THE CONTRACT 197234 . RECORDS RAVI BEEN/WILL BE (CIRCLE ONE)
TRANSMIITED TO
,1 c TE). .s/p1=o
- . .. s. iyo.
., , ., 2 O E Q.TOOD PREPARED ST Michael Li/LW /-(t. ) APPROYED ST .
'I
/0hy (QUALITY ASSURANCE DGINEER) (QUALITT Programs NGR)
y'" E V 18
,,,, Lou white - westingbouse 21ectriccGorp. IN CORRESPONDING SHOW OUR 2900 Doc Bennett Road o'c'" ao
- caTE av Fayetteville,;;C 2S306 PP #25654 8-10-84 l sdMS Cw& Yow (m's GR 69PP64t A'$ REFEREmCL AnD Dalt C0 Pit t 0, amy.10 COPf LS OF S em 70
.. 44.,4 ~ SHIPPED TO
.. . 4.......
Coimmonves1th Edison Company
++++++++++ o FF #25654 Braidwood Unit 1 Project Construction Dept ,
~
East of Rt. 53. I 1/2 miles so. of Rt. 113 1
!!!!!!!!!! '- araidw.ed. IL 60407
- ;;;;;;;; u.u c.C. P.C ..e f Atta: M.J. Wallace PaEPAIO COLLECT
. . O. 3. CH ARit TRAN SP. TO T AE COCE M0w TO SatP A*O AQUTE M ATERI AL LOC ATED IN Daf t uaTtstau TO GE $n* ppt 0 PsG NO. A wil mT l Ift. CuanTivv ICE N TIFIC A TION A N C QE $ C RIP'ICN
^
1 28 Siza 1 Overload -
Relays - Class 1E -
For Braidwood #1 -
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l l _ \ _ _ _. , _ _ . . . . , . _ _
O 4 rV I nJ f. I 1CT
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d MRR . / sew CECO Q.A.
RECEIPT INSPECTION CHECKLIST
, -m* . - " ;; I 6' E " . ),
p; .g e \, tv A. SHIPPING DAMAGE ACC REJ N/A
- 1. Corrosion / Exposure / Fire (Weathered. Road Salt, Contaminats) _
- 2. Tie-Down Failure / Rough Handling (Damaged Containers, Shifted Load)
- 3. Physical Damage (Broken Deformed, Cracked Parts) /
f~h Q 4. Inspection Performed Concurrent with Cognizant PCD Engineer or Designee /
- 5. Inspection Performed after Cognizant PCD Engineer or. Designee
- 6. Inspection Performed Prior to PCD Engineer's or Designee hl h1% O *3Ch 'f
.n /
> bs /* '
r Inspected By: / h*2 .e , < . ; wrI <.
Date: 6 R. A. VIGi;CCcnt (0158P)
O 4 6 4
1
- - , . - , - , -- , -- . - . - , , ----g,- --- - - - - .,y n. -. . . , - . _ . _ , . , , - , - - - .
. --.-----,.,r-
Q' BG-3 Revision 8 April 4,1984 Page 13 of 26 i
EXHIBIT'C !
MRR No. I%N i
Electrical Physical Characteristics (B) Page 1 ACC. REJ. N/A !
- 1. Is the MRR number affixed to each item or /
each lot?
.)
t
- 2. Are identification markings affixed to the /
O iiems and iegihie?
- 3. Are the identification markings traceable to /
the shipping manifest or supplied documentation?
- 4. Are protective covers or seals in-place and intact? -
- 5. Are there any preservative coatings present /
and, if so, still functional?
6.
\
Are there desiccants / inert gas purges present, / ,
l and are they functional? i O '
i l
(0019P) l
)
[] BG-3 Revision 8 April 4,1984 Page 14 of 26 EXHIBIT C Electrical Physical Characteristics Page 2 ACC. REJ. N/A
- 7. If the device is fluid filled or has a /
lubrication reservoir, has the orientation of the device been such as to preclude damage or leakage?
.s?.:if o n
- 8. Are lugs and terminal blocks per CECO /S & L Standards?
- 9. If welding is present, is it consistent with standard electrical construction?
- 10. Are painting or galvanizing in an acceptable condition for storage? (subjective review)
- 11. Are edges free of burrs and smoot,h?
o (0019P)
c* BG-3
.O Revision 8 April 4,1984 Page 15 of 26 EXHIBIT C Electrical Physical Characteristics Page 3 ACC. REJ. N/A
- 12. Is fastening hardware tight and consistent [
with good workmanship practices?
(Note any abnormal conditions, missing bolts, nut, washers, etc.)
~
O 13. ir ihere a,e any speciai siie reooi,emenis
/
for electrical insulation testing, has OAD performed these or been notified?
(List whom and when notified .)
Results of test: /
- 14. Is there rust, oil, scale, or dirt present in amounts that may impair the usefulness of the part?
l
- 15. Are dimensions of rolled or sheared steel stock within the applicable AISC guidelines?
- 16. Are dimensions of fabricated enclosures Q (junction boxes, etc.) as ordered?
(0019P)
.s BG-3 Revision 8 April 4,1984 Page 16 of 26 i
EXHIBIT C (
Electrical Physical Characteristics Page 4 1
- 17. Are all cable ends sealed for outside storage?
- 18. Are Cable Reels standing in an upright / l position at the time of arrival?
l
- 19. Are there are any gouges or any damage to cable f/
O Jacket?
COMMENTS:
= .-
(x+y l Calibrated Equipment Used if Applicable
- Record objective evidence for any measurements, dimensional checks, fluid levels, weld aspects, etc. taken during the receipt in-spection.
If calibrated equipment is used for any inspection, record I.D.
number and calibration due date.
/>J// bu 6-Ik 0
Q Inspected by: Aa n7 j epuI Date: S'/b-[k
' U (0019P) -
)
^
P 'i 21 17h MATERIAL AND EQUIPMENT RECEIVING AND INSPECTION REPORT f -( CECO ENGINEERING AND CONSTRUCTION 2 .5~-gg -
MRR # DATE: ' !$ -
SHIPPER be c '- /2Iec d // / C *a ORIGIN ,
- s ,- Ccasi.DATE b /6' CARRIER /" # N bdOfb '/ <- PRO # 2 7 / '/ O R CAR # -
CECO P.O. d / I/ CO NTR. R EC'V . / h e NSSS P.O. //? CEC 0 REC'V / b l SPEC OR OTHER 00C. O N3 / PREP. BY (MRC) I d # *'
STORAGE LOCATION 6d I "Y N STORAGE LEVEL C, or 0)
SHELF LIFE h (MONTHS) f (Indicate only if '1imited"! /
{
RECEIPT INSPECTION: (SEE PAGE 2)
EQUIP. OR 10ENT.#
, DESCRIPTION
/d g INSP HOLD TAG
. 5 5 2 23 i di Mi l Mod, faber Gjlic /Hede^o ,
[h s
&f b -0 C C C C -42 2 ~ 2 VS- / I &, V
/ 5 / 2_.
Y /5 /3 l r .
1 -
N 5 h h ? . i ,[ i$n 1
= --
i llde 1
\\ A $ i o B8a ;; N Ui 'l i OVAUTY ASSUhriCE ERAIDWOOD STATION ,
l i
- CODE CLASS: 1 SAFETY RELATED EON ASME SEC lli 2 - NON SAFETY RELATED
. 3 ASME SEC. lli
)
4 RELIABILITY RELATED Document Review QA Acceptance Sta. Const. P TW Acceptanes G S " / 7'b[
Cert. of Cont. 8, ?/?//-,~ ezi.e y ASME Data Report By: A/A ///2'/2 ud J-u-4 y QA Acceptance:
Complete 0ccument a. Interim / w 9-2/-84 PeckagoBy [N <m 7. h_[ b. Fina! 8 7.W44 E'/ - t F
>T QA Supr. Oate
-- ' '- F O R M Q.P. Y.1 Date (1-07 83) Rev.10 Page 1 of 2
f I
- - \
\,
RECEIPT INSPECTION CHECKLIST A. SHIPPING DAMAGE .
.o u m O 1.Qcsion/ Exposure / Fire
,0Vaathered, Road Sait. Contaminants)
- N*
Z 0 2.. Tie Down Failure / Rough Handling l //[ l l
/
, cc) jirnaged Containers. Shif ted load) lM l l C
m i
- 3. ysical Damage / !
ct(oken, Deformed, Cra, ked Parts) /
, / lM l l Inspected By # ,
- 8. PHYSICAL CHARACTERISTICS 1
/
l 1. RR No. Affixed to Material / Equipment \
(See e 1, Upper left Corner, For MRR No.) l l lM 4 2, Identification ings (Affixed. Legible) l l l l
- 3. Protective Covers / Seals (In Place. Intact) l l l l
- 4. Preservatives / Desiccants / Inert Gas / Lubricants (Per Site Instructions) l l l l
- 5. Dimensional / Workmanship (Random Check.Per Mft's. Orawints) l l ll
- 6. Electrical Insuletion Check (Per Site instructions l l ll )
- 7. Packagin eptable for Storage l ll
\
8 otted Connections Tight / g/ g l lp
.y. SEE ATTACHED CHECK LIST" Inspected by Ms/d/&lde Date [//(
C. DOCUMENTATION ' / / ,
~
f 1. Certificate of Conformance lq l l
- 1
, 2. Certificate of Cornpliance l l l
- 3. Certified Material Test Report 7= l l l
- 4. Other (Specify) i -
,l l l[
a- D. SPECIAL INSPECTION F5 .x specify l l l/
.o Remarks:
I I IL ,
Inspected By:
=
- tu Page 2 of 2
'" " 7 a e f f y, e ,
7: -
/
~' T
- 0 ? ?sT/78 MATERIAL AND EQUIPMENT RECElVING AND INSPECTION REPORT
'A CECO ENGINEERING AND CONSTRUCTION MRR # ! !
DATE: [ ~ /d ~ d 4 SHIPPER 86 / # $##Sc ORIGINM web /s Oc'_ C DATE [~f CARRIER PRO # 7 78-3 77S0-4RR CAR # - /E CECO P.O. /97234 CONTR.RECY M NSSS P.O. CECO RECV l
SPEC OR OTHER 00C. 2 7ID~ PREP. BY (M RC) h a Mdm l STORAGE LOCATION 5 F- -
3-+-1 STORAGE LEV ,C, or 0)
SHELF LIFE h (MONTHS)
(Indicate only if *1imited*l RECEl{T tHSPECTION: (SEE PAGE 2)
EQUIP. CR INSP HOLD TAG IDENT. #
DESCRIPTION
, g g , ,, ,
. 5 N b 5" ? k !$ ,$
sas 1 overlea & lay.s i gg / _,
g- clo.ss 2. e . .\
s -
f
._ _@LI .. . -
.g YEP se g- [ h ,- '
Y 0 e a '
.ST
- CODE CLASS: 1 SAFETY RELATE 0 NON ASME SEC.ill 2 NON SAFETY RELATED 3 ASME SEC.lli 4 R3 LIABILITY RELATED Oocument Review QA Acceptance Sta.C t.
[9)! M st- c 3/- W G O Cert.cf Conf.By AS(IE Data Report By: A//,) / ?l'! dc; m F-)/ f.7 QA Acceptance:bdm !#- 1/-#4 Cor.1plete 00cument \' a. Interim T
Package By b. Final QA Supr. Oste i'
F O R M Q.P. 71.1 Date (107-83) Rev.10 Page 1 of 2
RECEIPT INSPECTION CHECKLIST *l
, A. SHIPPING DAMAGE gg NJ . ba5 !
1$rosion/ Exposure / Fire $M O goathered, Road Salt, Contaminants) l9 l l
- 02. Down Failure / Rough Handling , /
, co yarnaged Containers, Shif ted Load) lTl l O
I M 3.
ical Damage oken, Deformed, Cracked Parts) _ e elT1l Inspected By B. PHYSICAL CHARACTERISTICS
- 1. RR No. Affixed to Material / Equipment (See e 1. Upper lef t Corner, Fcr MRR No.) l
- 2. Identification . ings (Affixed, Legible) l l l l l
- 3. Protective Covers / Seals (in Place. Intact) l l l l
- 4. Preservatives / Desiccants / inert Gas / Lubricants r eL
'- ~ ' '
(Per Site Instructions) t' i iVl l
~
,9 ; 't 'k '. ,
- b. Dimensional / Workmanship l '
(Random Check, Per Mft's. Drawings) l l ll l 6. Electrical Insulation Check (Per Site Instructions l l ll
- 7. Packagin eptable for Storage l ll 8 oited Connections Tight / /? , /[ l y l
S$E ATTACHED CHECK LIST" O Inspected by Mv N M /< M ate [///
z l l C. DOCUMENTATION
- 1. Certificate of Conformance
[
l9 l l
- 2. Certificate of Compliance . .
l l l
- 3. Certified Material Test Report l l l
- 4. Other (Specify) l l l
- 0. SPECIAL INSPECTION Specify '- l l l l l l IV Remarks:
,nspec,ed ey:
(Name and Dasef
/d f /hAn 4Jr sv [/g f Page 2 of 2
~
BG-3 Revision 8-April 4,1984 Page 13 of 26 l
EXHIBIT C MRR No. /(([/
Electrical Physical Characteristics (B) Page 1 ACC. RET. N/A
- 1. Is the MRR number a'ffixed to each item or each lot?
- 2. Are identification markings affixed to the O iiems and iegihie?
- 3. Are the identification markings traceable to the shipping manifest g supplied documentation?
-*;? ,.,. ;e.v.'cy
.t 1_ k
- 4. Are protective covers or seals in-place and intact? .
- 5. Are there any preservative coatings present and, if so, still functional?
- 6. Are there desiccants / inert gas purges present, and are they functional?
O MRR. N o.
(0019P) 3RAlDWoo]
.' l C), BG-3 v4 Revision 8 April 4,1984 Page 14 of 26- :
EXHIBIT C Electrical Physical Characteristics Page 2 ACC. REJ. N/A
- 7. If the device is fluid filled or has a lubrication reservoir, has the orientation of the device been such as to preclude damage or leakagc?
O U
- 8. Are lugs and terminal blocks per CECO /S & L Standards?
.-: gr
- 9. If welding is present, is it consistent with standard electrical construction?
- 10. Are painting or galvanizing in an acceptable condition for storage? (subjective review)
- 11. Are edges free of burrs and smooth?
.i]
s ,1 C ~C~"'O-O
. l;.. ';1 (0019P) 5 U! bh!Obb
~
j p BG-3 V Revision 8 April 4,1984 Page 15 of 26 l
EXHIBIT C j Electrical Physical Characteristics Page 3 ACC. REJ. N/A
- 12. Is fastening hardware tight and consistent with good workmanship practices?
(Note any abnormal conditions, missing bolts, nut, washers, etc.)
, 13. If there are any special site requirements for electrical insulation testing, has OAD performed these or been notified? .
gru y i
(List whom and when notified .)
Results of test:
- 14. Is there rust, oil, scale, or dirt present in amounts that may impair the usefulness of the part?
- 15. Are dimensions of rolled or sheared steel stock within the applicable AISC guidelines?
- 16. Are dimensions of fabricated enclosures O (junction boxes, etc.) as ordered? yga. NO.
.33~l (0019P) .g, .}((;}
BG-3
'{}
v- Revision 8 April 4,1984 Page 16 of 26 EXHIBIT C Electrical Physical Characteristics Page 4
- 17. Are all cable ends sealed for outside storage?
- 18. Are Cable Reels standing in an upright position at the time of arrival?
/
,. 19. Are there are any gouges or any damage to cable
) jacket?
COMMENTS:
o Calibrated Equipment Used if Applicable
- Record objective evidence for any measurements, dimensional checks, fluid levels, weld aspects, etc. taken during the receipt in-spection.
If calibrated equipment is used for any inspection, record I.D.
number and calibration due date.
g MRR. NO. inspecteo y M.d [ hr 15851 Date:
(0019PB RA JWOO J
- . - - , . - . - - , - . - - , _ , , , , - . . , , . - ~ . - _ . - - . - , - . --
s
~*
, WESTINGHOUSE ELECTRIC CORPORATION CONTROL DIVISION CERTIFICATE OF CONFORMANCE CENERAL ORDER NO.
IN 11211-CGC D&TE 8/9/84 197234 CUSTCMER F.C. 30. SPECITICATION S&L2755 REY.
Braid Wood #1 PROM DMG E Size 1 Overload EQUIPMENT / MATERIAL DESCRIPTION 75 NUMBER OF FIECES CUSTOMER TAG N0. S & L Spec. 2755 RDiARKS: Sim to AA13A (S# IN 11210903 - P. O. 42-91684N)
QUALITY CONTORMANCE TO APPLICABLE CODES AND SPECITICATION: )
DEVIATION NOTICI(S) [ x lNONE [ IAPPLICABLE QDRs ARE LISTED BELOW 3Y QDR NLMBER WE HERESY CERTITY T11AT THE ITEMS LISTED ABOVE EAVE BEEN MANUTACTURED AND FABRICATED IN ACCORDANCE TO THE QUALITY REQUIRIMENTS OF THE CODES / STANDARDS /
SPECITICATIONS ITIMIZED ABOVE AND ALL 01EER CUSTOMER REQUIREMENTS LISTED IN THE CONTRACT 197234 . RECO MS RAVE BEEN/WILL BE (CIRCLE ONI)
TRANSMITIID TO BT (DATE). MRR.NO.
, s e... 1 g BRAIDWOO PREPARED ST Michael Li/LW L((f Appggygg gy i t. h/o[gg (QUALITY ASSURANCE ENGINEER) (QUALITY Programs MGR)
"L" O R D E R l
F3$H 23970 E, g
IN COMEWONDING MOW Op raou Westinghouse Electric Corp. Lou White ,,,,, ,,, , ,,,g 2900 Doc Bennett Road
\ Fayettev111e .NC r 28306 = aaeaea cssro ateromwm o's a(rtatuct ano cart es
- Copics or tuv. to comits OF s/n To 4 $ HIPPED TO
.. . 4..+.
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- !!!!!!! r Commonwealth Edison Soupany Nd
!!!!!!!!!! 0 , Braidwood Unit 1
. PP #25353 Project ppnetruction Dept lllllllllI g East of Rt. 53. i 1/2 miles So. of Rt. 11
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RECEIPT IllSPECTION CHECXLIST A. SHIPPING DAMAGE ACC REJ N/A
- 1. Corrosion / Exposure / Fire j (Weathered, Road Salt, Contaminats) _.f. _
- 2. Tie-Down Failure / Rough Handling j (Damaged Containers, Shifted Load) '/
- 3. Physical Damage (Broken', Deformed, Cracked Parts)
) 4. Inspection Performed Concurrent with
\> Cognizant PCD Engineer or Designee 1 [
- 5. Inspection Performed after Cognizant ,
PCD Engineer or Designee _
- 6. Inspection Performed Prior to PCD Engineer's or Designee
- Mitfzqs..e,
,,/
Inspected By: v
>t e '
/ . ' /<bteor }.
- /
Date:
R. A. VG'Gil , ,
,p, i
' i : M. '.> *
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\.- , . .. u . M s h. t t
(0158P) n
4 BG-3 Revision 8 April 4,1984 Page 13 of 26 EXHIBIT C MRR No. /M<IN/
Electrical Physical Characteristics (B) Page1 ACC. REJ. N/A
- 1. Is the MRR number affixed to each item or /
each lot?
- 2. Are identification markings affixed to the
) items and legible?
- 3. Are the identification markings traceable to !
the shipping manifest or supplied documentation?
- 4. Are protective covers or seals in-place and [
Intact?
- 5. Are there any preservative coatings present and, if so, still functional?
- 6. Are there desiccants / inert gas purges present, and are they functional' I s
(0019P) ,
\ BG-3
\ Revision 8 April 4,1984 Page 14 of 26 EXHIBIT C Electrical Physical Characteristics Page 2 ACC. REJ. N/A-
- 7. If the device is fluid filled or has a /
lubrication reservoir, has the orientation of the device been such as to preclude damage or leakage?
- 8. Are lugs and terminal blocks per CECO /S & L Standards?
- 9. If welding is present, is it consistent with standard electrical construction?
- 10. Are painting or galvanizing in an acceptable '
condition for storage? (subjective review)
- 11. Are edges free of burrs and smooth?
s r L's I (0019P)
l..
BG-3 Revision 8 April 4,1984 Page 15 of 26 EXHIllIT C Electrical Physical Characteristics Page 3 ACC. RFJ. N/A
- 12. Is fastening hardware tight and consistent [
with good workmanship practices?
(Note any abnormal conditions, missing bolts, nut, washers, etc.)
- 13. If there are any special site requirements !
for electrical insulation testing, has OAD performed these or been notified? ,
. ,. y (List whom and when notified .)
Results of test:
- 14. Is there rust, oil, scale, or dirt present in amounts that may impair the usefulness of the part?
- 15. Are dimensions of rolled or sheared steel stock within the applicable AISC guidelines?
r
- 16. Arc dimensions of fabricated enclosures (junction boxes, etc.) as ordered?
(0019P)
BG-3 Revision 8 April 4,1984 Page 16 of 26 EXHIBIT C Electrical Physical Characteristics Page 4
- 17. Are all cable ends sealed for outside storage?
- 18. Are Cable Rects standing in an upright ,
position at the time of arrival?
l
- 19. Are there are any gouges or any damage to cable .
Jacket?
COMMENTS:
,t.
, c, y n, e.7 h.UNE,t Calibrated Equipment Used if Applicable ,
- Record objective evidence for any measurements, dimensional ;
checks, fluid levels, weld aspects, etc. taken during the receipt in-spection.
If calibrated equipment is used for any inspection, re ord I.D. !
number and calibration due date. / N 2jn g p..n. y 1
1 Inspected by: Dild
- ld'Wff d Date: i (0019P) R. A VIGNOCCHI
16609 1
G' 1 MR. THORNTON: Mr. Hii is-available for cross 2 examination, Mr. Chairman.
3 JUDGE GROSSMAN: Mr. Guild?
4 CROSS EXAMINATION 5 BY MR. GUILD:
6 Q Before you had the position of vault supervisor, you 7 inherited, at Mr. Saklak's departure, the position of 8 Supervisor of Quality Control Inspection, did you not?
9 A That's true.
10 0 Was that the General Supervisor position? Was that your 11 title at the time?
12 A No, it wasn't. I was the supervisor for receipt,
(
13 calibrations, CEA's, junction boxes and equipment.
14 0 All right, sir.
15 It was the supervisor over the inspection 16 disciplines that Mr. Saklak supervised at his departure 17 in April of 19857 18 A Yes, sir.
19 Q And you continued in that Supervisor of QC position I 20 until you took your vault supervisor job --
i i 21 A That's correct.
22 0 -- in the next year?
23 A Yes.
4 24 Q Now, what occasioned your going back and looking a 25 second time for Material Receipt Reports associated with
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Sonntag Reporting Service, Ltd.
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v 1 Mr. Seeders?
2 A Mr. Larry Seese came to me and told me that counsel for 3 CECO had requested the second search to.be performed.
4 0 Well, how come you didn't identify the documents that 5 are appended to your rebuttal testimony when you 6 performed the first search?
7 A The two dates in question, August 16th and 17th, were 8 not in the scope of what I was looking for the first 9 time.
10 0 Well, what were your instructions the first time?
11 A To find MRR's signed by John Seeders for August 8th to 12 August 15th.
V 13 0 I see.
14 What were your instructions the second time?
15 A To find MRR's generated by John Seeders -- I'm sorry --
16 all of the Comstock MRR's for~ August 16th and 17th, John 17 Seeders' or any other inspector's.
18 0 And that's what's appended to your testimony?
19 A Excuse me?
20 0 Those are the documents appended to your testimony?
21 A That's correct.
22 0 They're responsive to that request?
23 A That's correct.
24 Q All Comstock MRR's for that date were initiated by Mr.
) 25 Seeders? ,
l Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
16611 h) t,v 1 A Correct.
2 O What was your understanding of the purpose for the 3 second request?
4 A I'm not sure I understand the question.
5 0 Well --
6 A As far as purpose, I was just given instructions, and I 7 performed the function. I was not told why I was doing 8 it.
9 0 I see.
10 ,
Did you ever have any contact with counsel about 11 this instruction?
12 A No, sir.
O>
s_-
Did you have any contact -- I take it that you didn't 13 0 14 have any contact with counsel before you carried out 15 that instruction?
16 A Correct. I had no contact.
! 17 Q That was indirectly transmitted from counsel, through 18 Mr. Seese, to you?
19 A Correct.
4 20 0 Since you've carried out that instruction, have you had 21 any contact with counsel?
22 A Yes, I have.
23 0 And what is your understanding, as you sit here today,
_ 24 of the purpose for the second search?
25 A All I -- as far as I understand it, John said that he
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1 was -- he had too much of a workload during that time 2 period, and the additional obligation of keeping up the 3 Receiving Department hampered his productivity in 4 calibrations.
5 0 What was your understanding -- what is your 6 understanding, as you sit-here.today, of the purpose for 7 the second search?
8 A I believe the same.
9 0 Why do you understand that you were asked to go back a 10 second time and look for two additional days that you 11 didn' t look f or the first time?
12 A I don't know why I was asked the second time. I just 13 know that those two dates came up, and I was asked to 14 find the MRR's.
15 0 I see.
16 So you have no further understanding of why those 17 two. additional days were added?
18 A No, I do not. )
19 0 In toto, I take it, for the two periods of time, there 20 were 13 Material Receipt Reports associated with Mr.
21 Seeders?
22 A Correct.
l 23 0 The three attached to your testimony and Group Exhibit 24 90, the 10?
( 25 A Yes.
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[U 1 0 I see.
2 Now, you also testified about your opinion about I
3 the search for the DeWald 1,000-weld checklists.
4 You didn't find the 1,000-weld checklist, and you 5 expressed an opinion that you'd know about it if.it 6 existed?
l 7 A True.
8 0 Well, you do know that there are 1,000-weld checklists 9 reflecting Comstock Quality. Control inspections?
10 A Yes, there are.
11 0 And how many are there of the 1,000-weld checklists? j 12 A I know of only one.
l I 13 0 You know of only one? l 14 A Yes.
15 O All right, sir.
16 And is it your opinion that, given your position as 17 vault supervisor, you would be aware of others if there l 18 were others than the'~one?
19 A I am relatively sure that I would have run across it, 20 yes.
l 21 0 But your belief, as you sit here today, is that there's 22 only one?
23 A Correct.
t 24 0 And whose checklist is that?
25
( A That would be Rich Yanketis'.
l Sonntag Reporting Service, Ltd. l Geneva, Illinois 60134 (312) 232-0262
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,rx 1 Q But as far as you know, there are no others?
2 A Correct.
1 3 O If there were others, that would reflect limits on your 4- awareness and knowledge of the records that are 5 maintained in the vault?
6 A Possibly, yes.
7 0 All right, sir.
8 Now, you did, of course, run into some Irv DeWald 9 checklists? ,
10 A Yes, I did, when I performed the search.
a 11 Q And while you didn't find one with 1,000 welds on it, l 12 you found Irv DeWald checklists with large numbers of D)
I 13 welds on them, I take it?
14 A It depends on what you consider "large."
15 0 I guess that's true, isn't it? All right, sir.
16 Well, did you find any checklists in excess of 500 17 welds?
18 A Not that I recall. 500 was relatively the largest that i
19' I ran across. l 20 0 I see. Well, let me just ask you more directly:
21 Given your knowledge of the records, what is the 22 largest number of welds on a DeWald checklist with which 1
23 you are familiar?
24 A The exact number I couldn't give you. '
I 25 0 What's your best estimate, as you sit here today, of the
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4 j
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(312) 232-0262
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16615
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1 largest number of DeWald welds on a checklist?
2 A Approximately 500.
3 0 So if I were to say that there were weld checklists with 4 Mr..DeWald's signature on them in excess of 600, that, t
5 too, would reflect limits of your -- your limited 6 knowledge of the records for which you are the 7 custodian?
8 A I wouldn't be able to say yes or no, that it didn't
~
9 exist or not -- did exist or not, true.
10 0 I see.
11 Now, you also describe in your testimony your l_
12 knowledge of the Pearl Harbor File?
( }
13 A Yes.
14 0 And I think you may be the first -- well, I may not be
. 15 accurate in that, i 16 You've actually seen a file that had " Pearl Harbor" 17 written on it?
I 18 A Yes, I did.
19 0 But when you saw it, it was back in 1982 when you saw i
20 it?
i 21 A Yes, it would have been back in 1982.
l 22 0 All right.
l
- 23 And at that time the file was a single manila 24 folder that had " Pearl Harbor" at the top?
_s
(% 25 A It was a Pendaflex folder.
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u 1 Q A Pend --
2 A A Pendaflex folder.
3 0 I don't know what that is.
4 A It's a green folder that holds manilas in it.
5 0 It's a suspended file?
6 A Correct.
7 Q So it has room for a number of individual manila 8 folders, stand-up folders,.in it?
9 A Yes, sir.
10 0 It itself is relatively small.
11 What would you say the capacity of one of those --
12 is it "Pentaflex"?
(
13 A Pendaflex.
14 Depending on the variety -- they come in different j .15 sizes, of course -- it could hold anywhere from one 16 document, of course, up to 300.
i 17 0 I see.
18 Do you remember the size of the one that you i
19 observed that was the Pearl Harbor File?
20 A Not offhand, no, sir.
21 0 But given your understanding of the range of sizes in 22 which the Pendaflex suspended files come, 300 is the i
23 max, as far as you're aware?
- 24 A As far as I would estimate, yes.
25 0 Your estimate, all right, sir.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
r-16617 s i-N- ~
1 A I've never taken the time to count.
2 0 Well, did you see the Pearl Harbor. File after 1982?
3 A No, sir.
4 0 Well, are you aware that the. Pearl Harbor File grew from 5 being a single Pendaflex to being one or more drawers of 6 a separate file cabinet?
7 A No, sir.
8 0 When you inherited Mr. Saklak's job, as you testified, 9 you inventoried or reviewed the contents of his desk 10 drawers?
11 A Correct.
12 0 All right.
13 I take it that you didn't review the contents of 14 any free-standing independent file cabinets?
15 A No. I also did perform that, also.
16 Q Oh, you did do that?
j 17 A Yes, I did.
18 0 You just don't talk about that in your testimony?
19 A I forgot to mention that when I did fill out my 20 testimony.
21 0 Well, I take it that you would have recalled, when you 22 filled out your testimony, whether you saw the file that
- 23 actually said " Pearl Harbor" on it; and you didn't find 24 that?
25 A I did not find that.
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Sonntag Reporting Service, Ltd.
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1 Q All right, sir.
2 But you forgot to describe in your testimony your 3 review of Mr. Saklak's stand-up file cabinet?
4 A That's correct.
5 0 And there was a stand-up file cabinet next to his desk, 6 wasn't there?
7 A It was across from his desk.
8 0 All right.
9 And do you understand this is the file cabinet 10 that, as Mr. Saklak described it, followed him around 11 the site from various work locales to another'during the f~ j 12 course of~ time from '82 to '85 when he was assigned to NJ 13 the Comstock Quality control Department?
14 A I wouldn't know whether that was the particular file 15 cabinet that did follow him or not.
16 0 Well, what happened to the contents of that stand-up 17 file cabinet?
18 A Half of it I kept myself, and the rest of it I turned 19 over to Tony Simile.
20 0 And what did you do with the stuff you kept yourself?
21 A I still have it.
22 Q And what does that consist of?
23 A Comstock letterhead memorandums; memos from Commonwealth 24 Edison, Sargent & Lundy; clarification on procedures; 25 minutes gf meetings that Rick attended.
Sonntag Reporting Service, Ltd.
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1 Q And do you still have those identified as materials that 2 came from Mr. Saklak's file?
3 A Identified as being from Rick's --
4 0 .Yes.
5 A -- from Rick's file?
6 'No, I do not.
7 Q- I don't mean necessarily a tag on them that says that, 8 but what I.mean to suggest is: Are they identifiable in 9 any fashion as documents that came f rom this file 10 cabinet?
11 A Some of them, yes.
12 0 And how are they identified?
(
13 A Some of them have Rick's personal notes on the memos.
14 Some of them are addressed to Rick f rom Irv or someone 15 else.
16 0 I see.
17 And what materials did you turn over to Mr. Simile?
18 A The only thing -- other things that I found in the 19 drawer, other than those, were requests for time off 20 from the inspectors, memos to management on personnel 21 status changes, moving this inspector from this 22 discipline to another.
23 0 What was the approximate volume of material you turned 24 over to Mr. Simile? l 25 A There might have been approximately 200 pages.
Sonntag Reporting Service, Ltd.
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'l, I 1 - Q 2 < And by comparison, what was the approximate volume of 2 material that you retained for yourself?
3 A Approximately 200 to 300.
4 Q And these are from -- this is from the stand-up --
l 5 ,
free-standing file cabinet?
6 A Yes, sir.
7 Q. How many drawers were there in that free-standing file 8 cabinet?
9 A Two drawers.
t .
! 10 0 seYe they full? !
11 A- No, sir.
r e .-
12 ,Q~ How much material was in those two drawers?
(
13 A Approximately 500 pieces of paper.
14 Q All right, sir.
15
- fiSo that's the universe of what was in the two 16 drawers; part went to Mr. Simile, and part you kept --
1*e A Correct.
18 0 - 6 as'you've described?
19 JIn addition, there was what you describe in your 20 ,'. testimony, which was the contents of Mr. Saklak's desk?
~
S 21 K Right-22 MR. GUILD: Mr. Chairman, at this time 23- ' Inter'venors would renew one more time our request for 24 , ,
the production of documents. Those are the documents 25 that Mr. Hii has now identified as being the contents of Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134
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1 the free-standing file cabinet and Mr. Saklak's desk. ,
2 JUDGE GROSSMAN: Okay. I don't believe that 3 Applicant has control over that, and I'm not putting the 4 onus on Applicant.
5 I'll just direct the witness to not disclose those 6 documents to any party and to bring them in here, at 7 which time we will turn those over to counsel.
l 8 Is that agreeable to all the parties?
9 MR. GUILD: It is, Mr. Chairman, to 10 Intervenors. '
s 11 MR. MILLER: Yes, that,'s agreeable.
12 I don't know, as I sit here,' whether or not these 13 documents have, in fact, been made available at some '
f
.14 earlier point in time, whether they contain Bates Stamp 15 numbers or not. I just don't know.
16 JUDGE GROSSMAN: Oh, have you been aware of l 17 those documents, Mr. Miller?
l 18 MR. MILLER: Well, as I understand Mr. Hii's ;
1 19 testimony, they sound like relatively routine l
, 1 20 communications back and forth among the various entiti,es. s,
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21 at the site. It may well be that they. have been 22 produced.
23 But I think that the suggestion -- l l
24 JUDGE GROGSMAN: Oh, I see. i
( 25 You' re saying that you don't know about these Sonntag Reporting Service, Ltd. l Geneva, Illinois 60134 (312) 232-0262 i 1
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I 16622
['N s Q '
1 documents -- these copies that Mr. Hii has in l j
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2 particular, but some of those documents may already have 3 been turned over?
4 MR. MILLER: Correct.
9 5 JUDGE GROSSMAN: Okay. That's fine. We have 6 no problem with that. I would assume that some have l 7 already been.
8 But I take it there's no problem with getting Mr.
9 4 Hii to put all those documents in some file, not l 10 disclose them to anyone else, and just have them brought i
l 11 in to us; is.that correct? l 12 MR. MILLER: Certainly.
13 JUDGE GROSSMAN: No objection from you, Mr.
14 Berry?
15 MR. BERRY: None f rom the Staf f, Mr.
16 Chairman.
17 JUDGE GROSSMAN: Okay.
18 Is there any problem with that, Mr. Hii?
19 THE WITNESS: No problem. That will take a l s l 20 while, but no problem. l I 21 JUDGE GROSSMAN: Okay. Well, we do not want you to go through and select out documents. I think l
] 22 l
23 - it's in your interest to just bring the whole thing and 4 i I
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(' 24 not make any judgment. l l
25 I'm suggesting that as far as your interest with '
I t
Q Sonntag Reporting Service, Ltd.
, Geneva, Illinois 60134 (312) 232-0262
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l- your employer, also. I don't think you should have the 2 onus of having selected out the wrong documents.
3 So I'm just saying that just bring them all 4 together and bring them in here, and then we will have 5- counsel look over those documents. Therefore, you won't 6 have any problem with having made any-selection.
7 Is that agreeable to you?
8 THE WITNESS: That's agreeable. A lot of my 9 own personal ~ memos I merged with Rick's --
10 JUDGE GROSSMAN: Oh.
11 THE WITNESS: -- and put them in sequentially 12 by date, so you're going to get approximately 2,000
( )
13 pieces of paper.
14 MR. GUILD: I'd say bring it all, Mr.
15 Chai rman. We'll sort through it. I'd just as soon the 16 burden not be on the witness to do that.
17 JUDGE GROSSMAN: Well, I want to indicate, 18 though, that if you think there's any problem with~your 19 own documents here, I don't want to urge you to bring 20 those in without your reviewing.your own documents and ,
21 determining which you think might cause you a problem.
22 THE WITNESS: No. I don't have any problem l 23 with that.
24 I just wanted to get clarified the figure that I l 25 gave him; that what I received from Rick will be i
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1 substantially different from what I bring in, because my 2 own personal stuff is in there, also.
3 JUDGE GROSSMAN: Okay. But, again, I would 4 urge you, in your own interests, to review your own 5 documents and just make sure that there's nothing that 6 you're reluctant to disclose.
7 If there are some, you ought to separate them out 8 and check with us at least as to whether you are 9- required to turn those over.
10 THE WITNESS: Fine.
11 JUDGE GROSSMAN: I don't think we will compel m
(b i 12 13 you without giving you further advice, Is that agreeable, Mr. Miller?
14 MR. MILLER: Your Honor, the only thing I 15 would request is that, while I appreciate the safeguards 16 that the Board has erected here with respect to Mr. Hii 17 bringing these in for the Board, in the effort of 18 conserving hearing time, I was wondering whether at 19 least the initial view could be by counsel for the 20 Applicant.
21 JUDGE GROSSMAN: Absolutely. I have no 22 intention of reviewing those documents. Those are going 23 to be turned over to counsel jointly. Only if there is 24 some dispute, including Mr. Hii's reluctance to turn
.N 25 over some documents, would we ever get involved in that.
)
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V 1 I don't anticipate that there will be a problem.
2 MR. MILLER: All right. We'll try to arrange 3 for it either Monday or Tuesday of next week.
4 JUDGE GROSSMAN: But, again, I don't want any 5 of those documents disclosed to anyone first. It's 6 going to be disclosed as a joint, disclosure.
7 Fine. We've passed that.
8 Mr. Guild?
9 MR. GUILD: Yes.
10 BY MR. GUILD:
11 0 Mr. Hii, as you state in your testimony, you have been a 12 supervisor. You are a supervisor now. You have been a 13 supervisor of inspectors. You took Mr. Saklak's 14 position in March of 1985.
15 Before that time, you were a vocal opponent of the 16 effortE to organize the Quality Control Inspectors, the 17 unionization drive?
18 A That's true.
19 0 All right, sir.
20 You, though, despite the fact that you were a vocal 21 opponent of the union -- whatever relevance that has, if 22 any -- you were also a victim of Mr. Saklak's verbal 23 abuse, were you not?
24 A Yes, sir.
25 O Mr. Saklak didn't seem to differentiate between the v
Sonntag Reporting Service, Ltd.
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1 union supporters and the union opponents in dishing out i
2 his verbal abuse, did he?
3 A Not that I'm aware of, no.
4 0 Not in your case, in any event; right?
5 A Not in my case.
6 0 All right, sir.
7 Now, I take it that your recall, as you sit here 8 today, of the specific incident is somewhat clouded?
9 A Yes.
10 0 All right. 1 11 But you do recall somewhat vividly, as you recount
\ 12 at Page 4 of your testimony, that the dispute had to do (G 13 not with the union, did it?
14 A No, it did not.
15 0 It did not have to do with pay, did it?
16 A No,'it didn't.
17 0 It didn't have to do with morale, the lack of a kitchen j 18 at Comstock, did it?
19 A No, it did not.
20 0 The fire that had occurred in the Comstock office -- it 21 didn't have to do with that?
4 22 A No.
23 0 In fact, what it had to do with was your work as an 24 employee of the Quality Control Department at L. K.
Comstock?
( j 25 l
Sonntag Reporting Service, Ltd.
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16627 1 A It had to do with the project I was working on, yes.
2 0 And you can't recall the project at this time?
3 A No, I cannot.
4 Q All right.
5 But in any event, Saklak's interchange with you 6 didn't have to do with any of those extraneous matters:
7 the union or morale or working conditions.
8 It had to do with you not completing this project, 9 whatever it was, in a time or manner that was 10 satisfactory to Mr. Saklak?
11 A That's correct.
12 0 And you recall somewhat vividly, it appears, Saklak, I
(
13 take it, as he was characterized -- as was 14 characteristic of Mr. Saklak, rather forcibly saying,
'15 ." Do it, do it"?
16 A Yes, sir.
17 Q All right.
18 That stuck in your mind?
19 A Yes, it did..
20 0 And he was telling you that he didn't want to hear any 21 excuses or explanations at that time about your project, 22 whatever 'it was, your work project.
23 He just wanted you to get it done?
24 A Correct.
25 0 "Do it"?
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U 1 A Correc't.
2 0 All right.
3 Now, you also recount that, under the circumstances 4 you describe in your testimony, you went along with the 5 23 or so other inspectors on March' 29, 1985, to the 6 meeting at the site residents' office.
7 A That's correct.
8 0 All right.
9 And you state-that in part you did-so because you 10 understood that Mr. Terry Gorman, who had been a witness 11 to an encounter between you and Mr. Saklak, was going to 12 go?
13 A Yes.
14 Q And you wanted to assure yourself that whatever Mr.
15 Gorman's version of those facts were was consistent with 16 your own recollection?
17 A That's correct.
18 0 You don't recall the circumstances that occurred between l 19 you and Saklak now or at the - time you wrote your i 20 testimony, but you are pretty confident that you 21 remembered the circumstances in March of '85? l l
22 A Yes, sir.
23 0 All right.
24 So you wanted to make sure that Gorman was
[~) 25 accurate?
l I
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V 1 A Correct.
2 Q All right.
- 9 Well, you went along with the other fellows, 4 correct, to the NPC?
5 A I'didn't go with the other fellows. I was approximately 6 15 minutes late getting over there.
7 0 You came into the meeting, then,.after they were already 8 there?
9 A Yes, sir.
10 0 All right.
, 11 And was Mr. Gorman present?
12 A I believe he was, sir.
13 0 All right.
14 And did you hear Mr. Gorman make any recounting of 15 the incident between you and Mr. Saklak?
16 A No, sir.
17 0 So you simply didn't have an opportunity to accomplish 18 the purpose for your attending the meeting; that is, 19 assuring that Gorman was accurate?
20 He didn't refer to the matter?
21 A He didn't refer ~to the matter, no.
22 Q Did anyone else refer to the matter?
23 A 103, sir, not that I'm aware of.
, 24- 0 Okay.
25 So you were there, and I take it you stayed for the Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262 1
16630 1 balance of the meeting?
2- A Yes, sir.
3 0 And the meeting ended without any reference to your 4 run-in with Mr. Saklak.
5 Thereaf ter, af ter the meeting -- strike that.
6 Did you have anything to say at the meeting? ,
7 A' No, sir.
8~ 0 All right.
9 Thereafter, after the meeting was concluded, did 10 you have.any communication about that meeting with 11 anyone else at Comstock?
12 A Not that I -- not that I remember, sir.
(
13 0 You don't recall talking to anybody in Comstock 14 management about what transpired at the meeting?
15 A Not about what transpired, no.
16 0 Well, .did you talk to anybody at Comstock management 17 about the f act that you had gone to the meeting?
18 A Yes. I told Tony Simile that I had been there.
19 0 And you informed Mr. Simile that such a meeting had 20 happened?
21 A. Yes, sir.
22 0 And what did Mr. Simile say when you told him that the 23 inspectors had gone to the NRC?
g_ -24 A He didn't say anything. He already knew that they were j ) 25 going. It wasn't a secret.
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1 Q He didn't say anything at all?
2 A- No, sir.
'3 Q Not a word?
4 A Nothing.
5 Q Let's get this straight, now.
I 6 You spoke to Simile, and Simile did what?-
7 A He continued doing what he was -- he was on the phone 8 talking at the time. He continued with his conversation 9 on the phone. He acknowledged that he had heard me, and 10 I left.
11 0 Did he nod, shake his head?
12 A Yes, he nodded his head.
(
13 0 So he made no verbalization whatsoever?
14 A None whatsoever.
15 0 Who else did you . talk to about the f act that you had 16 gone to the meeting or.the substance of what transpired 17 at the meeting?
18 A No one that I can recall.
19 0 You didn't talk to Mr. DeWald about it?
20 A No, sir.
21 0 You didn't talk to Mr. Seltmann about it?
22 A No, sir.
23 0 You didn't talk to anyone else in supervision that you 24 recall?
s 25 A Not that I can recall.
i Sonntag Reporting Service, Ltd.
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16632 ss 1 Q All right.
2 Now, did you' subsequently get any documentation 3 regarding the meeting from the Nuclear Regulatory 4 Commis'sion Staff?
5 A Yes, I did.
6 0 I want to show you a copy of Int'rvenors' e Exhibit 42, 7 which is a non-in-camera version of an' April 5, 1985, 8 memo.
9 (Indicating.)
10 Mr. Hii, this memo-has names blacked out in it.
11 -That's not the original version of the memo. It's a 12 version that was introduced in evidence in this (v) 13 proceeding to mask the identities of the persons listed 14 in that memo.
15 I ask you whether you'veiseen a copy of that 16 document either in the form in which you're looking at 17 it now with the names blanked out or in the form where 18 the names were shown. I 19 A No, sir. This doesn't look familiar to me. 4 l
20 0 You didn't get a copy'of a letter -- I don't have it l 21 before me, but a transmittal letter from the NRC, saying 22 in substance, "
Dear Mr. Hii:
Thank you for coming and 23 talking to us. Enclosed is a memorandum documenting or
, ,, 24 summarizing concerns. Please review it and see if it's
- / l (N ,
) 25 accurate and contact us if we can be of any further i
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I assistance"?
2 That's a paraphrase, obviously. It would have been 3 a cover letter enclosing that document.
4 A No, sir, I don't remember seeing this before today.
5 0 Okay.
6 What document did you get from the NRC regarding 7 the meeting?
8 A I did receive a package from the NRC in the mail. If I 9 could see a copy of it, I would be able to identify it.
10 0 Sir, I have to figure out what it is before I can show 11 it to you, Mr. Hii.
12 Did you retain a copy of it?
(
13 A I might have. I'm not sure whether I still have a copy 14 of it or not.
15 MR. GUILD: Since he's coming back anyway, 16 Mr. Chairman, perhaps through the Chair I could ask Mr.
17 Hii to search for whatever he got f rom the NRC just so 18 the record is clear on what he received.
19 JUDGE GROSSMAN: If Mr. Berry on voir dire 20 would like to present some other document now, we can 21 show it to the witness and perhaps that will be the 22 document.
23 MR.. BERRY: We are searching for that. I 24 I would point out that Mr. Weil has testified in 25 this proceeding that he sent certain documents to a
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U 1 number of Comstock inspectors. Among them were the 2 group of documents encompassing Intervenors' Exhibit 42.
3 That would be the April 5th memo and the two March 29th 4 memos.
5 JUDGE GROSSMAN: Well, fine. Why don't we 6 just continue. Perhaps Miss Chan will come up with'a 7 recognizable document.
8 BY MR. GUILD:
9 0 All right, sir.
10 Whatever documents you got from the NRC, Mr. Hii, 11 you got in the April, 1985, time frame; and they 12 referred to the March 29th meeting?
(
13 A Yes, sir.
14 0 Let me show you the March 29th-memoranda. There are 15- two. They may also have some names blanked out.
16 No, they don't.
17 (Indicating.)
18 I ask whether you recognize those documents.
19 A This looks familiar, yes, sir.
20 0 All right, sir.
21 Now, my understanding, from your prior testimony, 22 is that the package that was sent to each of the persons 23 who left a name and address that day included the two 24 March 29th memos that are before you and the April 5th l (x 25 memo that I just showed you.
i
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1 Is it possible you also got the April 5th memo?
2 A' It is possible. I don't recognize it.
3 Q All right, sir.
4 But you do recognize.the March 29th memos?
5 A Yes, sir, this memo I do recognize.
6 0 All right,. sir. Fine. Thank you.
7 Now, when you got these memoranda in the mail, the 8 March 29th memos and the April 5th memo -- if, in fact,
.9 the April 5th memo was among them,' and I- recognize that 10 you're not able to identify that at this time -- did you 11 show copies of any of those documents to anyone at L. K.
12 Comstock?
13 A No, sir, I did not.
14 Q You didn't make copies available of those memoranda to 15 Mr. DeWald, Mr. Simile, Mr. Seltmann, Mr. Seese or 16 anyone in Comstock supervision?
17 A No, sir, I did not.
, 18 0 Did you discuss the contents of those documents with 19 anyone?
20 A No, sir, not.that I recall.
21 Q All right, sir.
22 MR. GUILD: If I could have just one moment, 23 Mr. Chairman --
24 JUDGE GROSSMAN: Maybe we should take a break
( 25 now.
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1 1 MR. GUILD: -- only to conf er with the Staf f.
2 If we could just take a moment now, Mr.' Chairman --
3 JUDGE ~ GROSSMAN : We might as well take our
- 4. 10-minute break now.
5 MR. GUILD: Fine, Judge.
6 (WHEREUPON, a recess was had, after which 7 the proceedings were resumed as follows:)
8 JUDGE GROSSMAN: Mr. Guild?
9 MR. GUILD: Thank you, Mr. Chairman.
10 BY MR. GUILD:
11 Q Now, Mr. Hii, there are two Mr. Hii's that have worked
. ()
12 for Comstock, aren't there?
4
.v 13 A Correct.
14 0 You're the junior; is that right? Are you-a junior?
15 A No, I am not a junior.
16 0 You are the son, though?
17 A Yes, sir.
- 18 Q And your father -- is he a Joe Hii as well?
1 19 A Yes, sir.
20 0 What does your father, Joe Hii, do at Comstock?
21 A For a while, he was project engineer. Now he is in 22 charge -- well, now he's on sick leave and has been for 23 three months.
24 0 Yes.
25 A Prior to that, he was in charge of material s
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1 coordination. I'm really not sure of everything his job 2 encompasses. '
3 0 " Material coordination" meaning the materials that are i
4 used in the electrical scope of work? ,
5 A .Yes, sir.
6 0 I see. All right. ,
7 MR. GUILD: Thank you. That's all I have, 8 Mr. Chairman.
9 JUDGE GROSSMAN: Oh, Mr. Berry?
10 CROSS EXAMINATION 11 BY MR. BERRY:
12 Q Mr. Hii, I show you an April 8, 1985, letter addressed 13 to you from Charles H. Keil.
14 (Indicating.)
15 I ask if you have received a copy of that.
16 MR. BERRY: I'd ask that this document be 17 marked for identification as the next Staff exhibit. I 18 believe that's No. 24.
l 19 (The document was thereupon marked Staff !
l 20 Exhibit No. 24 for idencification as of j 21 October 31, 1986.)
l 22 A Like I said before, I don't recognize it; but I probably 23 did receive it, yes.
l 24 BY MR. GUILD: I 25 0 Now, Mr. Hii, I direct your attention to Page 3 of your I
Sonntag Reporting Service, Ltd. I Geneva, Illinois 60134 l (312) 232-0262 j
16638 s) 1 prefiled testimony, your Answer 6, where you state that, 2 in connection with the Form 19 checklist, "I am certain 3 that if such a document existed, I would have seen and 1
4 remembered it."
5 Could you tell us the basis for that statement?
6 A My basis for that statement is that something that out l 7 of the ordinary is usually brought to my attention by 8 someone that works for me.
9 I also did perform a search for that document, 10 along with two of my assistants.
11 Q A Form 19 documenting the acceptance of 1,000 welds 12 would be out of the ordinary?
13 A Yes, it would be.
14 0 And why is that?
15 A Only because of the number of welds listed on there.
16 Most of them aren't for that large of an amount.
17 0 I direct your attention to Page 5 of your prefiled 18 testimony. It's a continuation of your Answer 9 where 19 you're discussing the incident with Mr. Saklak.
20 You state that, "We discussed both the incident and 21 project, and resolved them both during that discussion."
22 Do you recall, as you sit here today, what was the 23 resolution?
24 A The resolution to the project itself, no, I don't 25 recall. Since I don't recall the nature of the project, Sonntag Reporting Service, Ltd.
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1 I cannot remember what we decided to do about my 2 concerns about the project.
3 Q And continuing further, directing your attention to 4 Answer 11 of your prefiled testimony, again on Page 5, 5 in the last sentence in your answer, you state, "I do l 6 .believe that some of the individuals" -- that went to 7 the NRC on March 29th - "saw the incident as an 8 opportunity to make themselves appear more powerful than 9 management."
~10 I ask you if you could explain for us the basis of 11 .that statement.
12 A That is my opinion. I have no real tangible evidence to 13 back up my opinion.
14 However, that is the way. that I viewed the 15 attitudes of certain- members that did go over, from the 16 way that they acted af ter that visit.
17 0 What do you mean by when you say "more powerful than 18 management"? What does " powerful" mean?
19 A That they had more. control over what was going on.
20 0 Well, how did they act after they returned?
21 A Like I said before, there's nothing that I can
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22 .specifically put my finger on. That's why it's only an 23 opinion of mine.
24 They seemed to walk around the office with an air 25 about them of how important they were, the way -- just Sonntag Reporting Service, Ltd.
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1 the way they carried themselves.
2 The only incident that I can rememter happening was 3 there was a time when Irv DeWald and Larry Seese were --
4 they were in Irv's office. The door was cloced, and 5 they were discussing something. I don't know what. I
~6 wasn't in the office.
7 I saw Mr. Bossong just go walking into the office 8 without knocking or any concern whatsoever about what 9 wight be going on.
10 It seemed to be an example that he thought that he 11 was more important than whatever Larry and Irv were 12 doing.
(
13 0 Well, just to take that one incident, do you know 14 whether Mr. Bossong had been asked to come into the 15 office by Mr. DeWald or Mr. Seese?
16 A No, but I don't believe that he was, because they both 17 seemed very surprised when he opened up the door and 18 walked in.
19 Q Directing your attention to Page 7 of your prefiled 20 testimony, in Answer 15, the second sentence of your 21 answer, you state, " Additionally, I did not grade Mr.
22 Puckett's tests, practical or written."
23 I ask you: How are you certain of that?
24 A I am 98 percent certain that I did not grade Worley's 25 tests.
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1 Q Did'you know'Mr. Puckett?
2 A Yes, I did.
3 Q Have you graded anybody's tests?
4- A Yes, I have.
5 0 Can you.give us a number, an estimate, of how many 6 tests, practical or written, you've graded?
7 A I've probably graded, practical and written, about 15.
8 Q 15?
9 A 15 tests.
10 0 continuing to Answer 16 of,your prefiled testimony, 11 still on Page 7, you state that when you took over the 12 desk that had been assigned to Mr. Saklak, that the
-13 drawers were locked.
14 A Yes, sir.
4 15 0 How did you get them open?
16 A I was given a key.
17 Q 'By whom?
18 A By Mr. DeWald.
19 Q Did anyone else have a key, besides you and Mr. DeWald?
20 A Not that I'm aware of.
21 That was the only key. Irv gave it to me.
22 0 I see.
23 And you know that Mr. DeWald had received that key 24 from Mr. Saklak?
? 25 A I don't know where Irv got it from. I didn't ask.
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U 1 MR. BERRY: I have no further questions.
2 Thank you, Mr. Hii.
3 JUDGE CALLIHAN: Mr. Thornton, can you help l
4 me a bit by addressing the attachment to Mr. Hii's i 5 testimony and telling me why the attachment was 6 submitted?
7 I know what it is and where it came from and the 8 dates and so forth, but what's the purpose?
9 MR.- THORNTON: Well, let me attempt to do 10 that, Judge Callihan.. Mr. Miller is here, and it was 11 originally at his direction, I think, that this was-1- f 12 undertaken.
D But if you'll recall, when Mr. Seeders was 13 14 cross-examined, my recollection is somewhat similar to 15 what Mr. Hii testified to earlier.
16 There was some testimony from Mr. Seeders about his 17 workload during the periods -- the dates that are 18 indicated in Mr. Hii's Answer 5. There was some 19 testimony from Mr. Seeders that he was doing double duty 20 in Calibrations and Receiving at that period.
21 We, therefore, made an attempt to make a search of 22 the documents to determine what his workload in the 23 receiving area had been on those days. Mr. Hii 24 undertook his search for that purpose.
b
( ) 25 JUDGE CALLIHAN: So the purpose is to Sonntag Reporting Service, Ltd.
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(s 1 document Mr. Seeders' productivity at a particular time?
2 MR. THORNTON: Well, his workload in the 3 receiving area on those particular dates, yes, sir.
4 That's my understanding.
5 JUDGE CALLIHAN: What was his work' load --
6 MR. THORNTON : In the receiving area.
7 JUDGE CALLIHAN: -- in calibrations?
8 JUDGE GROSSMAN: Is my recollection correct 9 that Mr. Seeders testified that someone was on vacation 10 at that time and he was handling th'e materials-receiving 11 chore, in addition to his calibrations, at that point?
12 itR . MILLER: Yes, sir. That's referred to in 13 his August 17th letter where he was asked by somebody --
14 by Mr. Saklak, allegedly -- to have somebody else do the 15 legwork, and h'e would just fill out the pieces of paper.
16 JUDGE GROSSMAN: Right, okay. That's fine.
17 Thank you.
18 JUDGE CALLIHAN: That gives me a lead. Thank 19 you very much.
20 JUDGE GROSSMAN: Mr. Guild, could you tell me 21 again when Mr. Puckett was terminated, the date?
22 MR. GUILD: I'm a little foggy on that. I 23 heard Mr. DeWald yesterday say that it was Tuesday, the 24 28th of August.
25 JUDGE GROSSMAN: Okay, but around August Sonntag Reporting Service, Ltd.
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16644 (v) 1 28th?
2 MR. GUILD: It was, yes, sir, and the test 3 was graded the 26th, which was --
4 JUDGE GROSSMAN: And what was the year again?
5 MR. GUILD: 1984.
6 MR. MILLER: '84.
7 BOARD EXAMINATION 8 BY JUDGE GROSSMAN:
9 0 Sir, were you grading exams at.that time?
10 A During that time period, yes.
11 0 And was it your responsibility -- were you the sole 12 person responsible for grading exams at that time?
13 A No, sir.
14 0 Who were the others that graded?
15 A Any of the Lead Inspectors, any of the Level 'II 16 Inspectors would grade practical exams.
17 These are the actual field exams that I'm referring i 18 to, not the written exams.
i 19 0 So it was up to Level II's to do that? I I
20 A Yes, sir -- well, it could have been a Level III, also, )
21 but mostly the Level II's did that.
22 0 Under what circumstances did Level III's grade the l l
23 exams? l 24 A I can never recall a Level III grading an exam, but they D l 25 do have the capability of doing it. l l
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1 Q Well, how about Mr. DeWald? Was he in the practice of 2 grading exams?
3 A Mr. DeWald would review the results that the person 4 taking the exam had against that of the person that was 5 actually doing the inspection and overviewing-that 6 practical, and then actually Irv would assign the grade 7 itself on the exam in the pass-fail.
8 Q But someone else would determine whether on each 9 particular problem the person being graded had correctly 10 answered the question?
11 A Correct.
I 'T 12 Q Now, when you were discussing.Mr. Bossong, after the U 13 March 29th meeting, walking into Mr. DeWald's office, 14 was.that unusual for an inspector.to walk into Mr.
15 DeWald's office?
16 A When there's a meeting or the door is closed, yes, sir.
17 Q Didn't Mr. DeWald have -- I'm sorry.
18 Did he have an open door policy?
19 A Of course, he had an open door policy. But there is 20 also something known as common courtesy; that you knock 21 before you enter a room when the door is closed.
22 JUDGE GROSSMAN: I see. Okay, fine. Thank 23 you.
24 Mr. Thornton?
O
) 25 MR. THORNTON: Yes, your Honor.
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(~N 1 REDIRECT EXAMINATION 3
2 BY MR. THORNTON :
3 Q Mr. Hii, in response to a question f rom Mr. Berry about 4 your certainty that there were no 1,000-weld checklist 5 forms signed by Mr. DeWald in the vault, you explained 6 that you had made some search with two assistants for 7 such a checklist.
8 Do you recall when you undertook that search?
9 A That search would have been performed sometime in May or 10 June of this year.
11 Q And how did you go about conducting the search?
12 Let me ask you this first: Why did you undertake 13 that search?
14 A' Mr. Seltmann requested that we perform the search. He 15 explained that what he was looking for was a weld 16 inspection checklist with more than 1,000 welds 17 documented on it. He also explained to me that he was, 18 in particular, looking for a DeWald checklist. He told 19 us that the area in question was up on 439 elevation, 20 the Unit 1 side.
21 I recruited two of my helpers down in the vault to 22 help me with this search. We conducted the search in i
23 the files themselves, and we enlarged our scope to 24 include Elevation 401 on up to Elevation 463 in the aux
) 25 building for a Form 19 with more than 1,000 welds Sonntag Reporting Service, Ltd.
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1 documented on it.
2 We found one, which was for Rich Yanketis.
3 Q How many were documented on that one?
4 A 1,166, I believe.
5 Q Mr. Hii, in regard 'to your testimony regarding the March 6 29th visit to the NRC, you testified, I believe in 7 response to a question from Mr. Guild, that you did.not 8 make any verbal remarks during the course of that 9 meeting.
10 A That is correct.
11 Q Do you recall, during the course of that meeting, one of 12 the NRC Inspectors calling for an affirmative showing of
(
13 hands of inspectors who believed that production 14 pressure existed at L. K. Comstock?
15 A Yes.
16 MR. GUILD: Objection, Mr. Chairman.
17 If we're really going to get into the substance of 18 what went on in the meeting, having established this 19 witness didn't say anything and having established.the 20 only subject ~he touched on in his testimony -- that is, 21 the accuracy of the Gorman recounting of the incident 22 with Saklak -- was not dealt with in the meeting, he did' 23 not touch on the substance of what was said at all.
-24 Now, if we're going to probe Mr. Hii's observations 25 and recall of other things that happened at that Sonntag Reporting Service, Ltd.
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- q .pg ,
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nf
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\J 'f 1 meeting, we're going to recall-it in much more detail l
s 2 ?- t'h'an.. simply what Applicant chooses to focus. attention on 3 now. '
4 .
It's clearly beyond the scope of cross examination 5 .. and really expands the scope of what this witness is 6 being asked to talk about on rebuttal.-
7 ,
JUDGE GROSSMAN: Well, it does.
8 % Do you wish to expand the scope and go into those 9 matters?
10 -
MR. THORNTON: I really don't, your Honor,
, 11 '
and I don't believe that's what my question was directed i -
h G
12 to. It'was a foundation question.
13 Mf _I may, Mr. Guild's question was as to whether l l
l 14 Mr. Hii had made any verbal remarks during the course of l x $
15 that' meeting.
16 fI-am simply asking that foundation question to 17 elicit whether he made any nonverbal remarks during the I 18 course'of that meeting.
P 19 JUDGE GROSSMAN: And that's as f ar as you' re l l 1,
- 2 0 _. going? l 21 MR. THORNTON: It's really limited.to that. l l
,[ 22 JUDGE GROSSMAN: That's fine. Then you can l l
L 23 continue. '
24 You did hear that the witness answered yes to the ,
1 l 25 prior question, didn't you, Mr. Guild; that he did I
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16649 o 1 recall someone asking that?
a s t 2 MR. GUILD: Yes. Thank you, Mr. Chairman. '
l l
3 JUDGE GROSSMAN: You can go forward and ask )
l 4 him about his response. '
l 5 BY MR. THORNTON:
6 'O Did you raise your-hand.at that time, Mr. Hii? I(
)
7 A No, sir, I did not. l 8 Q Finally, Mr. Hii, you were asked a question by Mr. Berry 9 about your grading of tests, and you explained that you 10 and other Level II Inspectors graded some field 11 practical examinations.
l
( 12 Do you recall that? ,
13 A Yes, sir.
- 14 Q Did you or other Level II Inspectors -- let me just ask 15 you this
- Did you ever grade a mock practical l 16 examination?
17 Do you unn. Gtand the difference between those two?
l 18 A We do refer to the field practical exams as -- I'm l l 19 sorry.
1 20 The mock practical?
21 JUDGE GROSSMAN: Yes.
22 BY MR. THORNTON: i l
23 Q Let me ask you this question:
24 Are you familiar with welding examinations,
\
25 practical examinations, that are conducted not on actual I
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, I 1 installations in the field but on coupons that have been I
I l_ '2 ,
made up for such a purpose? {
3 ,
A Yes, I am familiar that some practical exams'have been
- ~
4 i taken on those. l l
5 0 And- are you f amiliar with the designation " mock l 1
t
\ 6 practical examination" as applied to the latter?
.si l ig ' ?l 7 A Asoppobedtoanactualfieldinstallation?
8 0 Yes, sir.
9 A Yes, sir.
3 10 Q And did you ever grade a mock practical examination?
1 11 A No, sir, I did not. l 5 !
12 3 0 Do you know whether any other Level II graded such a l l
~
!. 13 mock practical examination?
L.\ ,
% 14 A Not that I'm aware of.
4 , ,
- 15. O Are you aware of who did grade those mock practicals? i l
16 A I would imagine it would have been Mr. DeWald.
- i 17 MR. THORNTON: I don't have any further
- 18. questions, your Honor. i N 19 JUDGE GROSSMAN: Mr. Guild?
20 RECROSS. EXAMINATION 1
l 2i BY MR. GUILD:
1
~22 0- I take it, Mr. Hii, that you, in your search for
\c
! 23 checklists, didn't look at all of the welding checklists
(+
_s 24 in the Comstock vault, then?
l
( 25 A No, we did not look at all of them.
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's J 1 Q So you might have missed some --
2 A It's possible.
3 0 -- 1,000-weld checklists? 4 i
- 4 A It is possible.
5 0 You might have missed the 1,000-weld checklist of Mr.
6 DeWald in particular? 4 7 A Not given the fact that we were told that it was up on 8 439 elevation and that it would have been cable pan 9 hangers back at that time period that would have been 10 inspected.
11 Q Well, that's true, on the assumption that that is where
~12 it was.
l 13 But if, in fact, Mr. DeWald's 1,000-weld checklist 14 was not at that elevation nor at the elevations where 15 you did look but was somewhere else in the plant, you 16 wouldn't have found that within the scope of your l 17 search, would you?
l 18 A Correct.
l 19 0 I take it you didn't find a weld inspection checklist 20 that contained 1,215 welds, either, did you?
21 A No, sir, I don't recall.
22 0 Are you aware that the Nuclear Regulatory Commission 23 inspector, Mr. Mendez, found such a checklist?
24 A No, sir.
25 0 If he had, it would suggest that your search was not l
l l
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1 complete, since you didn't find it?
2 MR. THORNTON: I'll object to that question, 3 unless we have a definition of what's meant by 4- " complete."
5 The witness has-testified as to what the scope of 6 his search was.
7 JUDGE GROSSP.AN: I think you already have in 8 the record whatever factual material you need. The 9 witness already agreed that there could be checklists 10 that'he didn't find.
11 MR. GUILD: Understood. That's fine. I-12 withdraw the question.
(
13 That's all I have.
14 JUDGE GROSSMAN: Mr. Berry?
MR. BERRY:
15 No further questions.
16 BOARD EXAMINATION 17 BY JUDGE CALLIHAN:
18 Q Mr. Hii, going back to inspections'of either field or 19 mock welds for certification, you said Mr. DeWald was a 20 the likely person to have judged or evaluated a field 21 examination -- a practical examination.
22 Would he have done that in his capacity as a member 23 of management or whatever his official position was or 24 would he have done it because he was -- and I think he 25 was -- an inspector or had been an inspector?
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1 What was his particular authority for judging 2 practical exams?
-3 A He would have been doing that as the QC Manager.
4 JUDGE CALLIHAN:- Thank you.
5 BOARD EXAMINATION 6 BY JUDGE GROSSMAN:
7 Q- Why was there a difference between field inspection and 8 mock as far as who graded what?
9 A I think the problem that we' re running into is the way 10 I'm using the word " graded."
11 As far as the final outcome of whether someone has
( 12 passed or failed, that has always been left up to the QC 13 Manager to determine that portion.
14 We inspectors do say that we're grading field 15 practicals only because we're administering them and we 16 are the first line to look at whether the person had 17 found everything or not. We're not actually grading the 18 practical.
19 Irv actually takes the two test results and 20 compares them, and he's actually the one that does the 21 grading of the practical itself.
22 0 After the inspector has already decided, though, whether 23 the person-has failed on each item?
24 A Correct.
25 0 Okay.
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1 Now, .s i that any different with regard to the mock 2- practical?
3 A I believe so. I can't say for sure because I've never 4 done the mock practical exam, so I've never been in that 5 position to find out whether --
6 Q Oh, so your answer with regard to the mock really 7 related to the final grade on the mock exam?
8 A Yes, sir.
9 Q As far as you know -- well, you don't know whether, 10 then, there is any difference between who does the 11 original grading between the mock or the field?
f\ 12 A That is correct.
13 JUDGE GROSSMAN: Oh, okay.
14 Mr. Berry -- Mr. Thornton hasn' t had his turn yet, 15 but --
16 MR. THORNTON : I have nothing further anyway.
17 MR. BERRY: I'm sorry. I had a question. I 18 neglected to mention it.
19 JUDGE GROSSMAN: I'm sorry. This is part of 20 your original examination. Fine.
21 RECROSS EXAMINATION 22 BY MR. BERRY:
l 23 0 Mr. Hii, do they still utilize what you refer to as the 24 field inspection type of practical examination?
25 A I'm not sure, sir. I haven' t been involved with that Sonntag Reporting Service, Ltd.
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1 for over a year now.
2 -Q In August "of 1985,_ did they still use the field 3 inspection for practical examinations?
4 A Yes, sir.
5 MR. BERRY: Thank you. That's all.
6 BOARD EXAMINATION
. 7 BY JUDGE GROSSMAN:
1 8 0 Are you familiar with who supplied the key'for the mock 9 practical in August of 19847 10 A Yes. I believe that was Tom Vogt.
11 0 Who was that?
12 A Tom Vogt --
13 0 Oh.
14 A -- for the coupon practical.
15 JUDGE GROSSMAN : - Okay, fine.
16 Anything further? Mr. Guild?
17 MR. GUILD: Yes, sir, Mr. Chairman.
18 RECROSS EXAMINATION 19 (Continued) 20 BY MR. GUILD:
21' O Mr. Hii, let me show you Applicant's Exhibit 76 in 22 evidence. This is'an exam, a field practical, performed 23 by Mr. Puckett with a cover sheet. The cover sheet has 24 two-hand writings on it, one with a signature that reads 25 " George Nemeth."
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1 (Indicating.)
2 Mr. Nemeth was a Level II Inspector?
3 A Correct.
4 0 And the other has been previously. identified as Mr.
5 DeWald's handwriting.
6 There's no signature, but do you recognize that as 7 Mr. DeWald's handwriting?
8 A Yes. That appears to.be Irv's handwriting.
9 0 All right, sir.
10 Now, understanding the practice you've just 11 described that the ultimate authority for deciding 12 pass-fail in all qualifications was Mr. DeWald, the QC-13 Manager -- in this case, a field practical - 'if Mr.
14 Nemeth was the Level II Inspector that observed the 15 field condition and Mr. DeWald was the QC Manager who 16 made the ultimate pass-fail decision, do you know 17 whether or not in this~particular instance Mr. DeWald 18 determined that Mr. Puckett had failed the exam before 19 or after Mr. Nemeth wrote the description that appears 20 above Mr. DeWald's handwriting?
21 (Indicating.)
22 A Could you repeat the question, please?
23 0 Sure -- well, let me rephrase it.
24 Would it be consistent with your understanding of 25 the practice -- that is, the practice involving the use l
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L) 1 of a Level II to review the field condition but the 2 practice of Mr. DeWald to make the final pass-fail 3 judgment -- would it be consistent with your 4 understanding of that practice for Mr. DeWald to have 5 reviewed Mr. Puckett's field practical, determined that 6 Mr. Puckett failed the exam and then directed Mr. Nemeth 7 to document that fact by Nemeth's writing on the 8 transmittal form?
9 A No. It is my understanding that Mr. Nemeth would have 10 filled this out first, and then Mr. DeWald would have 11 reviewed the documentation.
( 12 0 Well, do you know for a fact whether the DeWald decision
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13 to flunk Mr. Puckett came first or whether it came 14 second?
15 A I don't know for sure, sir.
16 0 Well, we have Mr. Nemeth saying, with respect to Mr.
17 Puckett, "He has not passed."
18 The pass-fail decision would be Mr. DeWald's, would 19 it not?
20 A Correct.
21 MR. GUILD: That's all I have, Mr. Chairman.
22 JUDGE GROSSMAN: Mr. Berry?
23 MR. BERRY: Nothing further.
l 24 JUDGE GROSSMAN: Mr. Thornton?
25 MR. THORNTON: Nothing.
\~ /
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16658 1 JUDGE GROSSMAN: Thank you very much, Mr.
2 Hii.
3 Let's get the ground rules for Mr. Hii bringing 4 materials in. We don't want to take Board time; but on 5 the other hand, we won't have the courtroom open before.
6 Now, if counsel want to work out some other 7 arrangement in which they' re all present, we don' t want 8 to order that Mr. Hii bring the documents on Monday, 9 either. I think that would inconvenience Staff 10 somewhat.
11 But if you can work out some arrangement for
(~'N 12 earlier on Wednesday to have Mr. Hii bring the 13 documents, in which counsel will not view the documents 14 unless other counsel are present, that's fine. That's 15 acceptable to the Board.
16 You can just communicate-that to Mr. Hii, and he'll 17 bring the documents in.
18 Is that --
19 MR. BERRY: Mr. Chairman, I have no objection 20 to counsel for Applicant and Intervenors reviewing the 21 documents without the presence of the Staff.
22 MR. GUILD: The Wednesday proposal sounds 23 fine to me, Judge.
24 Perhaps if Mr. Miller or Thornton could agree --
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! I can meet at noon --
2 JUDGE GROSSMAN: I just want to say that we 3 don't require you, as long as counsel agree to something 4 other and communicate it to Mr. Hii that-counsel have 5 agreed on a certain measure, to bring the documents in 6 early. That's fine with us. Otherwise, Mr._Hii will 7 bring the documents in at 2:00 o' clock on Wednesday.
8 Is that fine?
9 THE WITNESS: That's fine.
10 MR. GUILD: We can work it out, Mr. Chairman, 11 I believe.
12 JUDGE GROSSMAN: Now, Judge Callihan can be 13 here Wednesday morning if you decide on using the 14 courtroom for-those documents and bringing them in here.
15 But I would suspect that Mr. Miller's office is 16 fine.
17 MR. GUILD: If it's okay with Mr. Miller -- -
18 MR. MILLER: Sure.
19 MR. GUILD: -- that's fine with me.
20 JUDGE GROSSMAN: So we'll adjourn now until 21 2:00 o' clock on Wednesday. !
22 If you're not back here, Mr. Hii, thank you very 23 much for testifying, and you're excused.
24 (Witness excused.)
h (WHEREUPON, at the hour of 10:00 A. M.,
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l 1 the hearing of the above-entitled matter 2 was continued to the 5th day of November, .
-3 1986, at-the hour of-2:00 o' clock P. M.)
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NO PAGE NUMBER CERTIFICATE OF OFFICIAL REPORTER 9
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: CHICAGO, ILLINOIS DATE: FRIDAY, CTOBER 31, 1986 a
were held as herein appears, and that this is the original transcript thereof for the file of the. United States Nuclear Regulatory Commission.
(sigt) [M ..
(TYPED) f hh Official Reporter Reporter's Affiliation l
O