ML20213G558
| ML20213G558 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 11/12/1986 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| CON-#486-1618 OL, NUDOCS 8611180200 | |
| Download: ML20213G558 (60) | |
Text
Al O
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)
LOCATION:
CHICAGO, ILLINOIS PAGES:
17009 - 17066 DATE:
WEDNESDAY, NOVEMBER 12, 1986 b
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AG-FEDERAL REPORTERS, LNc.
O OfficialReporters 444 North CapitolStreet Washington, D.C. 20001 e611180200 861112 PDR ADOCK 05000456 (202) 347-3700 T
PDR NATIONWIDE COVERAGE l
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17009 I
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UNITED STATES OF AMERICA 3
NUCLEAR REGULATORY COMMISSION i
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD I
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In the Matter of:
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- Docket No. 50-456 i
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COMMONWEALTH EDISON COMPANY 50-457 i
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l (Braidwood Station, Units 1
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9 and 2)
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1 11 Page: 17,009 - 17066 l
United States District Court House l
13 Courtroom 1743 i
Chicago,. Illinois 60604
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14 Wednesday, November 12, 1986 y
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16 The hearing in the above-entitled matter reconvened 17 at 2:00 P. M.
t 18 BEFORE:
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19 JUDGE HERBERT GROSSMAN, Chairman 20 Atomic Safety and Licensing Board
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U.
S.
Nuclear Regulatory Commission i
21 Washington, D. C.
l 22 JUDGE RICHARD F. COLE, Member, l
Atomic Safety and Licensing Board 23 U.
S.
Nuclear Regulatory Commission I
Washington, D.
C.
24 JUDGE A.
DIXON CALLIHAN, Member, O
25 Atomic Safety and Licensing Board
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S. Nuclear Regulatory Commission t
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APPEARANCES:
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On behalf of the Applicant:
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MICHAEL I. MILLER, ESQ.
l PHILIP P.
STEPTOE, III, ESO.
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5 Isham, Lincoln & Beale Three First National Plaza 1
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Chicago, Illinois 60602 l
7 On behalf of the Nuclear Regulatory 1
8 Commission Staff:
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9 GREGORY ALAN BERRY, ESQ.
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ELAINE I. CHAN, ESQ.
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10 U.
S. Nuclear Regulatory Commission 7335 Old Georgetown Road 11 Bethesda, Maryland 20014 l
l 12 On behalf of the Intervenor:
1 13 ROBERT GUILD, ESQ.
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1 EXHIBIT INDEX Marked Received i
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Intervenors' Exhibit No. 191 17020 17041 I
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Applicant's Exhibits Nos. 182, i
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TESTIMONY OF LOUIS OWEN DEL GEORGE l
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RECROSS EXAMINATION (Continued)
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BY MR. GUILD:
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RECROSS EXAMINATION l
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REDIRECT EXAMINATION (Continued)
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6 BY MR. STEPTOE:
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7 RECROSS EXAMINATION (Continued) l i
BY MR. GUILD:
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1 JUDGE GROSSMAN:
The hearing is reconvened.
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This is the 89th day of hearing.
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3 Are there any preliminary matters before we go on l
4 to the witness?
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MR. STEPTOE:
Judge Grossman, I have one s
6 preliminary matter.
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Due to our mistake, the Revision 2 of Attachment 2C l
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DelGeorge-1 through 6, which are the bar charts, were I
9 not given to the Court Reporter and didn't get bound j
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10 into the record.
The wrong charts got bound into the 1
4 11 record.
r 12 I ask that we be allowed to give the Cour t Repor ter
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13 the right copies and ask him to make the change.
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14 JUDGE GROSSMAN:
Have you checked this out l
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15 with the Reporter?
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16 MR. STEPTOE:
No, I haven't.
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17 I'll check at the next break.
l 18 JUDGE GROSSMAN:
Well, let's take a recess i
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t 20 MR. STEPTOE:
Okay.
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j 21 (There followed a discussion outside the i
22 record.)
23 JUDGE GROSSMAN:
Okay.
We're back on the I
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24 record.
25 The Reporter indicates that he can make the I
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substitution, so we'll just get the revised exhibits l
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bound in instead of the others.
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3 Is there anything further in the way of preliminary
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4 matters?
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Mr. Guild.
6 MR. GUILD:
Yes, Mr. Chairman.
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Applicant's counsel and I spent the better par t of j
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8 yesterday reviewing the documents that Mr. Joe Hii, Jr.,
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9 produced, the Pearl Harbor File or related documents, i
l 10 and I simply want to report that the documents are
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f 11 voluminous.
It took the better part of a day to simply j
12 review them the first time, and Applicant is making them L
l 13 available to have copies made.
j 14 I haven't had a chance to reach any conclusions f
15 about them, but I want to alert the Board and parties l
16 there may be material matters contained in those t
j 17 documents, and I will move as expeditiously as I can to i
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18 evaluate them and try to keep the Board and parties l
l 19 informed about proposed action we have taken.
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20 JUDGE GROSSMAN:
Smoking guns; is that it?
i 21 MR. GUILD:
Those Kamikazi planes coming over
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l 22 the horizon, Judge.
23 JUDGE GROSSMAN:
That's fine.
24 Anything further before we resume with the witness?
25 (No response.)
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JUDGE GROSSMAN:
Nothing.
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2 So why don't we resume.
Mr. DelGeorge, you remain i
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under oath.
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THE WITNESS:
Yes, sir.
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5 JUDGE GROSSMAN:
And Mr. Steptoe, you were 1
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redirecting, I believe, were you not?
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MR. STEPTOE:
No, Judge Grossman.
I think it i
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was still Mr. Guild 's cross examination.
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JUDGE GROSSMAN:
Oh, we were.
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10 MR. GUILD:
I'm almost done, Mr. Chairman, i
11 but I have a few more questions.
j 12 MR. GUILD:
Mr. DelGeorge, welcome back.
13 THE WITNESS :
Thank you.
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14 RECROSS EXAMINATION I
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15 (Continued)
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16 BY MR. GUILD:
17 Q
You recall, just before we recessed at the end of last l
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18 week, I asked you whether there was any empirical I
I 19 measures of variation in BCAP CSR inspector accuracy l
20 rates.
i 21 Now, we got into somewhat of a colloquy on that l'
22 cubject, and you made reference to Mr. Smith's BCAP QA i
23 overinspection of the BCAP inspectors.
24 Do you recall that testimony?
25 A
Yes, sir, i
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Q Let's take a moment and look at Mr. Smith's testimony in j
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2 that regard.
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This is part of the Kaushal panel's testimony.
Mr.
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4 Smith's testimony on this subject begins at Page 5 and i
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5 extends, oh, through maybe Page 13 of the prefiled j
6 direct testimony.
7 You recognize, of course, that what Mr. Smith and 8
the BCAP overinspectors did, Mr. DelGeorge, is, first of 9
all, they only -- they started out looking only at the j
10 first 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of a BCAP CSR inspector's work, and of i
11 that work, they did a 20-percent sample for each I
12 inspector?
i 13 A
I recall that being an element of what they did, yes.
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14 Q
That's at Page 5 of the testimony.
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15 Then they sought to do a 10-percent overinspection j
f 16 sample, not of inspectors' work, but 10 percent of each 1
17 of the BCAP CSR construction categories.
In the case of j
18 electrical, that would mean 10 percent of the items in, i
19 say, the conduit sample, et cetera.
20 Did you understand tha t's wha t Mr. Smith's BCAP QA l
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21 overinspectors did?
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l 22 A
I don't have a specific recollection as to that point.
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All right.
That's Page 7 of his prefiled testimony.
j 24 MR. STEPTOE May the witness see Mr. Smith's 25 testimony?
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1 MR. GUILD:
I'm really testing his l
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2 recollection.
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I think the record reflects that's what his f
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4 testimony says.
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5 BY MR. GUILD:
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And that the only -- beyond the first 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> -- that l
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is, the 20-percent sample, the initial inspectors' f
8 work -- the only continuing sample that was made at all i
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9 by Mr. Smith's overinspection group was, on an inspector i
10 basis -- that is, a BCAP CSR innpector basis -- was to l
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11 assure that of the 10 percent of each construction 12 category, they captured at least 1, only 1, inspection 13 by each CSR inspector for each CSR construction 14 population?
15 And, again, tha t 's a t Page 7.
I 16 A
And by "one inspection," do you make reference to what 17 might be the inspection of an entire cable pan support 18 or equipment item?
19 Q
Yes.
He did it on an item basis, and not an inspection
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20 point basis; that's correct.
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21 And he, of course, displayed his data not on an 1
22 inspection point basis, either, but on the basis of f
f 23 attributes.
l 24 You are aware of that, aren't you?
25 A
Yes.
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That on that basis, he measured the -- he utilized the 2
95/90 acceptance criteria on the basis of attribute 1
3 reject or accept, not inspection points?
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Yes, sir.
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All right.
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6 And, therefore, for the entire construction 7
category of cable pan hangers, there were a total of 11 8
items overinspected by the BCAP QA overinspectors?
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9 A
I don't have a specific recollection as to that, bu t --
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10 Q
Right.
Page 11.
11 Well, it's clear, is it not, Mr. DelGeorge, that 12 Mr. Smith and the BCAP QA overinspectors made no l
13 effort -- they did not intend to attempt to measure CSR 14 inspector accuracy variance over time?
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15 A
That may, in fact, be the case; but my recollection of l
i 16 the question that was put to me last week asked me l
17 whether or not there was a variation accessed between 18 inspectors and for an inspector between items inspected, l
19 and I believe the various reviews that you have l
20 described today do, in fact, address those two types of 21 variation.
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22 Q
Well --
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It was my point, made last week, that the fact that all j
24 agreement rates were very high and that the fact that 25 all inspections were conducted in a very short period of Sonntag Reporting Service, L td.
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1 time itself provided an indication that there was little l
2 variation, if any, at the time.
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0 So it's not Mr. Smith's sampling at all that you rely on I
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4 for your assumption that accuracy rates by the CSR l
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inspectors did not vary over time, since Mr. Smith i
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didn't sample for that fact?
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7 A
No, not exactly.
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I relied on Mr. Smith's sampling as a mechanism for l
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9 producing data, data that did span the period over which l
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11 nine-month period when Daniels performed reinspections l
1 12 of Comstock work in the field --
13 Q
Yes.
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and that data provided a basis for evaluating the l
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15 relative performance between Daniels inspectors, and it l
provided a basis for evaluating the relative performance j
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17 of a Daniels inspector for various inspection l
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j 19 Given that data and the fact that the inspection
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20 activities themselves were conducted over a very short j
21 period of time, I said last week, and I believe today, l
22 that there is a basis for concluding that there was no 23 variation in time.
l 24 Q
But not strictly relying on Mr. Smith's data, since he 25 didn't seek to do that?
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A I believe, if given the description that you have i
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2 provided today -- and I have no reason to doubt that l
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that isn't an accurate description -- I don't know of f
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any specific variation calculation over time that Mr.
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Smith attempted to develop.
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6 Q
Understood.
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7 Mr. DelGeorge, let me show you a Xerographic I
8 reproduction piece of artwork that -- a chart that, I l
9 believe, you prepared.
10 (Ind ica ting. )
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11 Is this your work, sir -- a copy of your work?
i 12 A
Yes, sir.
13 MR. GUILD:
Mr. Chairman, I believe the next l
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14 Intervenors' number is 190, and I would ask this be i
I 15 marked as Intervenors' --
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f 16 JUDGE GROSSMAN:
No.
It is 191.
17 MR. GUILD:
-- 191.
Thank you.
18 All right.
i 19 (The document was thereupon marked I
I 20 Intervenors' Exhibit No. 191 for 21 identification as of November 12, 1986.)
22 BY MR. GUILD:
23 Q
Now, looking at this document horizontally, Mr.
24 DelGeorge, I see a scale on the bottom that reads 1982 25 through 1986.
Sonntag Reporting Se r v ic e, Ltd.
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1 I take it that represents time?
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2 A
Yes, sir.
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3 0
Okay.
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4 And there's a vertical axis, and it has some 5
entries that appear to read, " Miscellaneous Personnel,"
6 "DeWald," "Saklak," "Puckett,"
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" Administrative Issues," " Pay," and, " Training."
8 Did I read that correctly?
9 A
Yes, sir.
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And then, by those main headings on the vertical axis,
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11 there are horizontal time lines with various entries.
i 12 The entries are arrows indicating points in time with 13 either names or descriptive titles by them.
j 14 Am I interpreting correctly so far?
l 15 A
Yes, sir.
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All right.
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17 Let's take the bottom first; that is,
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" Administrative Issues," " Pay," and, " Training."
19 Could you explain what the entries are for that bar l
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21 A
The entries there represent comments made by inspectors, 22 through deposition transcripts which I reviewed, or
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23 hearing testimony that was provided at the point in time 24 that I had -- prior to the point in time that I i
25 submitted my prefiled testimony, where those QC f
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inspectors identified certain administrative issues as 1
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constituting a concern with respect to the organization i
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or implementation of the QC program within the Comstock I
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organization.
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All right, sir.
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Now, is your source the same for the other data s
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8 A
Yes, sir.
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Q All right.
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10 And, again, that's the record in this proceeding --
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l 11 your review of the record in this proceeding?
12 A
Yes, sir.
j 13 Q
All right.
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14 Did you rely on any extraneous sources of l
I 15 information -- that is, your knowledge outside of the f
16 record in this proceeding -- for data?
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17 A
No, sir.
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18 0
Okay.
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l 19 Now, let's just -- I'm looking -- I got the table l
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20 vertical so I can read the entries.
I'm still looking
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l 21 under " Adiainis trative issues," " Pay," and " Training."
22 The first issue in time appears the middle of
'83, I
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23 and it says, " Organize Effect" -- "O-R-G E-F-F.
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24 Can you tell me what that means?
l 25 A
Organizational ef fectiveness is my recollection.
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Q All right.
2 That was a concern?
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3 A
That was a concern expressed by an inspec tor, whose name l
4 I don't recall, at about that point in time.
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All right, sir.
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6 And just below that it says, " Pay A-0-J."
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Is that adjustment?
8 A
Yes.
9 Q
And is that a complaint about a pay change?
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10 A
No.
It was a discussion of the pay adjustment, and I 11 believe at least one inspector expressed a concern about i
12 its inequity.
13 Q
All right.
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14 What's the next entry just after -- in early
'84, i
15 sir?
16 A
Inspector increase.
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Is that numbers of inspectors?
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18 A
Yes, the number of inspectors increased measurably, and t
I 19 that was reported on by a number of inspectors as f
20 occurring in that time period.
21
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All right, sir.
i 22 So the fact there's one entry on this chart may be 23 indicative of one or more sources of that same fact; is l
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24 that correct?
25 A
Well, it will typically represent a single source.
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1 There may be a few entries -- and I don't recall 2
that being one of them -- where more than one individual l
3 expressed a similar concern and that would not have been 4
shown as two arrows.
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0 Okay.
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6 Well, for example, we're going to get over to the j
7 next bar.
I see the name Seeders there.
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8 Of course, the record reflects concerns expressed j
9 by Mr. Seeders, and a number of witnesses in deposition 10 and live testimony mentioned those same issues and Mr.
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j 11 Seeders by name.
l 12 You show only one entry, though; correct?
13 A
That's correct.
l 14 Q
So there may be more than one source for a single fact l
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j 15 that's indicated on this table?
16 A
Yes, sir.
17 Q
Back to now " Pay" -
" Administrative Issues."
Excuse 18 me.
19 1984, again, just below " Inspector Increase,"
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l 20 is that " Training"?
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21 A
Yes.
I 22 O
" Training" what?
23 A
The abbreviation represents an expression of a concern l
24 with respect to the training program, P-R-R.
25 Q
Training program.
All right.
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" Pay Problem," is that the next entry?
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2 A
Yes.
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Can you recall the source of that information?
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4 A
Again, it is an expression of a concern from at least l
5 one inspector, and I don't recall the specific l
6 inspector.
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0 How about the entry below that, Mr. DelGeorge?
8 A
That is an expression of concern with respect to -- I l
9 believe it was characterized as an attitude problem 10 within the QC organization.
l 11 Q
All right.
12 Was it directed at management or at inspectors or 13 generally?
i 14 A
I believe it reflected a declining morale, is probably 15 the best way to characterize it, of QC inspectors.
16 Q
All right, sir.
17 The entry below that, is that "L.
K. C. Contract"?
18 A
Yes.
That was the first instance that I could find 19 reported in the record where a QC Inspector indicated 20 having heard that the Comstock contract was being j
21 reconsidered by Commonwealth Edison.
22 0
I see.
23 And that's the import of the next entry as well, 24 1985?
25 A
Yes, sir.
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Q All right.
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And "B-P-I C-O-N-T,"
that's BPI's contention?
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A Yes, sir.
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0 Is that indicative of the date on which that was filed?
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A I believe it may be the date on which it was admitted, t
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but I'm not certain at this point.
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0 All right.
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Then the next bar reads "Puckett."
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And what's the significance of the separate time i
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j 10 lines for Puckett, Saklak, DeWald and miscellaneous i
l 11 personnel on the vertical axis, Mr. DelGeorge?
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r 12 A
Well, I didn't identify specific events with respect to 13 Mr. Puckett, although they were identifiable, l
14 I just colored in -- cross hatched in the period of j
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15 time over which the various events occurred during Mr.
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16 Puckett's tenure.
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l 17 The next two horizontal sections, the Saklak
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l 18 section and the DeWald section, constitute expressions j
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l 19 of concern by specific inspectors of identifiable events 1
20 related to Mr. Saklak or Mr. DeWald.
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l 21 Q
Now, let me see if I can read this correctly.
I 22 I'm looking at this horizontally again with the 23 time line at the bottom.
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l 24 Where are the entries for -- I'm looking f rom the 25 top now.
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Where are the entries for miscellaneous personnel?
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2 Are they the ones directly to the right of that term?
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A Yes, sir.
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4 Q
And for Saklak, they are sort of below the name Saklak l
5 and to the right?
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A Yes, sir.
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Q For Puckett, as you state, that's simply the shaded-in j
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portion representing his tenure on site?
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A Yes, sir.
i 10 Q
All right, sir.
l 11 JUDGE GROSSMAN:
Excuse me.
12 I believe for Saklak it's below his name to the 13 left.
t 14 To the right is the DeWald -- oh, I'm sorry.
It
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15 depends on how you are reading this.
16 Couldn't this have been done with -- holding it the I
l 17 long way, up and down, you could have changed those i
18 things on the top, the titles on the top?
You could j
l 19 have made them horizontal, couldn't you, and that would 20 have done the job?
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21 There's no rignificance to those being in one r
22 direction and the others being in the other direction, f
23 is there?
24 THE WITNESS:
No, sir.
It was just an 25 identifier for the column or row, whichever way you view I
Sonntag Reporting Service, r, td.
f Genova, Illinois 60134 l
(312) 232-0262 j
L i
17028 i e i
i i
j 1
the exhibit.
l 2
JUDGE GROSSMAN:
Okay --
1 I
l 3
MR. GUILD:
All right.
I 4
JUDGE GROSSMAN:
-- fine.
I j
5 BY MR. GUILD:
l 6
Q All right, sir.
I 5
7 And so the only entry by Mr. Puckett's name across l
8 the time line is, as you stated, the shaded-in por tion f
}
i 9
reflecting his tenure; correct?
l l
10 A
Yes, sir, i
}
11 Q
And then below that, for " Administrative issues," " Pay,"
{
s 12
" Training," are the entries we 've just discussed?
13 A
Yes, sir.
j 14 Q
Let's go to Saklak then.
15 "Saklak arrives," that's the date he became 16 supervisor of Quality Control Inspectors?
l 17 A
Yes, sir.
l 18 Q
You have a Martin entry.
l l
19 Is that Richard Martin?
20 A
Yes, sir.
I l
21 Q
And what Martin matter is that?
l l
22 A
It's my recollection that that was the event wherein Mr.
I i
23 Saklak is alleged to have strongly criticized Mr. Martin
\\
24 for having lost his tape measure or not having carried 25 his tape measure in to the field.
l Sonntag Reporting Service, L td.
Geneva, Illinois 60134 (312) 232-0262
i
(
s 17029
}
O 1
In any case, it constitutes an interaction with Mr.
2 Saklak, which was identified by Mr. Martin as a negative l
3 interaction with Mr. Saklak.
l 4
Q Mr. Martin said Mr. Saklak was on the verge of firing 5
him; that's the inciden t?
6 A
That may be the case.
l 1
l 7
My specific recollection is that it was an j
8 expression of concern related to the tape measure.
l 9
Q The tape measure stuck in your mind; perhaps being fired l
l 10 stuck in Mr. Martin's.
11 A
As I may have -- I believe I did indicate last week, in l
t 12 putting together my testimony, and specifically with 13 respect to the development of this exhibit, I didn't l
l 14 make a judgment one way or the other about the event i
i 15 other than to assume that had the concern been expressed 16 by an inspector, that it should be taken as alleged, as i
17 an event of harassment, intimidation and/or excessive 18 pressure.
l 19 0
Okay, okay.
20 Let's move quickly, if we can.
l 21
" Schirmer," you have a question mark by it.
22 I take it Mr. Schirmer was or is a Quality Control i
23 Inspector?
24 A
That's correct.
l 25 0
What's the significance of that entry?
i Sonntag Reporting Service, Ltd.
Geneva, Illinoic 60134 (312) 232-0262
I 17030 4
1 A
Well, the reason it's marked with a question mark is 2
that at the time -- my recollection is that at the time 3
I prepared this figure, I was still confirming the date.
4 The specific event in question is not one that was 5
identified by Mr. Schirmer but by another inspector 4
I 6
other than Mr. Schirmer.
7 Q
Can you recall who that is?
8 A
I believe it was Miss Sproull.
2 9
Q Miss Sproull.
i 10 In deposition?
11 A
I believe so, yes.
i 12 Q
She's not testified in the proceeding itself.
13 All right.
"Rolan" -- I'm reading down, "Rolan, 14 Mustered, Hunter, Holley, Seeders, Stewart, Rolan."
15 I take it there are two Rolan matters that are 16 involved with Mr. Saklak that you identified?
17 A
Yes, sir.
18 0
Okay.
"Lechner and Snyder."
I 19 Now, where did you -- all of those gentlemen have 20 testified.
21 How about Mr. Lechner:
22 Where did you derive the entry for Mr. Lechner?
23 A
I believe that event was identified by another QC 24 Inspector, and I don't recall at this point who that 25 inspector was.
i Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
. _ ~. -. -.-- _ _ _ _ _ ~_.
- -. -. _ _ _. _ _ _ ~ _ - _ _ _ _ _ _ - _
17031
~
~.
r i
t 1
The event involved a disciplinary action where Mr.
j i
2 Saklak verbally rais,ed his V'oice at Mr. Lechner because l
+
3 of Mr. Lechner 's alleged condu'ct'during the course of an
(
4 NRC inspection that he and Mr. Saklak had been involved f
l 5
in.
j i
6 Q
All r igh t.'
l Ind then "Snyder" is the last entry.
7 8
And that was the' incident between Mr. Saklak and f
9 Mr. Snyder that ultimately led to Mr. Saklak's 10 termination?
l l
11 A
Yes, si-12 Q
All right.
l 13 Qilckly rWQ, the DeWalil time line.
j t
14 "DeWald arriver."
I take it that's when he j
l j
15 returned as Quality Control Manager?
i 6
16 A
Yes, sir.
7, t
l
{
j 17 Q
All right.
"Ric k er Bcuman, Hunter, Perryman, Phillips, j
18 Sproull,E[nudenandflunter."
+
19 All shone have toetified in dapnsition o.
in,the
{
j i
1 20 proceeding except Mr.t.Asmussen.
l Where did you deriv'e Mi, Asmusscn'c entry?
(
21 l
22 A
I don't recall whettier that came from a deposition j
i 23 transcript or from the hearing transcript of Mr.
i 24 DeWald's testimony.
l 25 0
Was that Mr. Asmuseen's complaints about the thousand l
Sonntag P.spetting hoevice, Ltd.
Geneva;-Illinois 60134 (312) 232-0262 i
i
i l
I I
i 17032 11e j
1 welds and poor past weld inspection practices?
l i
i i
2 A
It had to do with that interaction with Mr. DeWald, yes.
]
I
(
3 Q
All right.
\\
4 And finally, under " Miscellaneous Personnel," the f
5 first entry at the top, reading sideways again, is 6
" Inspector Increase."
I 7
Again, is that the number of inspectors?
I l
j 8
A Yes, sir.
t
)
9 Q
All right.
j l
10 And what's the source of that information?
i 11 A
Again, it's a ccmment made by one or more inspectors, 12 that I can't identify at this point, that at that point l
13 in time, there was an increase in the number of
)
I j
14 inspectors at the site.
i i
15 Q
All right.
l 1
I 16 "Corcoran," is that the former Quality Control j
i 17 Manager?
i 18 A
Yes, sir.
l l
19 Q
Is that the date on which he became Quality Control
{
1 20 Manager?
j 21 A
No, sir.
(
j l
22 Q
Is that tne date when he left?
j 23 A
No, sir.
24 0
Why don't you explain what it is.
j 25 A
In one of either a deposition or hearing transcript of a I
Sonntag Reporting Service, Ltd.
(
Geneva, Illinois 60134 i
r (312) 232-0262 s
i 1
]
i l ': A
~
m s
I t
~'
17033 s
4,m
(
[
v' 1
1 QC Inspector, thUre was a comment made -- and this, 2
again, may alsv be a part of the record with respect to 3'
Mr. DeWald's testimony here -- that Mr. Corcoran 4
authored a memo, at or about the date shown on this time 5
line, concerning a negative trend in QC performance that 6
had been identified recently by the Commonwealth Edison 7 ',
Unit Concept Inspection Program.
,, g 8
Q And Mr. DeWald made reference to this is your 9
recollection?
10 A
I don't have a specific recollection.
11 It's one of those three sources that identified 12 this event.
N 1
13 Q
All right, sir.
14 You have a band below the next set of entries that g
15 has the-label " Inspection Backlog."
16 What does that indicate?
t 17 A
That was the period over time that had been identified i
18 by a number of sources as involving a large inspection 19 backlog in the Comstock -- of Comstock QC work with 20 respect to, I believe, specifically cable pan hanger 21 welding inspections.
22 Q
Well, that appears to begin at the point where Mr.
23 DeWaild arrives; correct?
24 A
Yes.
5 25 And, in fact, I think there was --
t Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
I 17034
/
N G')
/
1 Q
All right.
2 A
-- there was an inspection backlog that preceded Mr.
3 DeWald's tenure as QC Manager, but the period after Mr.
4 DeWald was the period that had been referred to by many 5
inspectors as one involving a significant pressure.
6 Q
Yes.
7 Mr. DeWald, of course, inherited a backlog from his 8
predecessor of quality control inspections?
9 A
He came to the job and that backlog existed.
10 I don't know that it's fair to say he inherited it 11 from someone.
O 12 Q
All right.
G 13 In fact, that span appears to -- for inspection 14 backlog, according to your figure, shows -- is shown as 15 ending in the -- approximately the third quarter -- I'm 16 sorry -- beginning of the fourth quarter, 1984.
17 And is that, in fact, when the inspection backlog 18 ended, as you recall?
19 A
I believe it did end at or about that time.
20 But, again, this was the period referred to by 21 inspectors, and I think it was their general 22 recollection that the backlog was substantially 23 eliminated at the end of the third quarter of 1984.
24 0
All right, sir.
p}
25 g
Now, we have three entries for Martin --
Sonntag Reporting Service, L td.
Geneva, Illinois 60134
~
(312) 232-0262
17035 9
1 JUDGE GROSSMAN:
Four entries.
2 BY MR. GUILD:
3 0
-- and then a fourth, three clustered together right at 4
the beginning of that period for backlog --
5 inspection -- inspection backlog.
6 And what are those Martin entries?
7 A
My recollection is that those are all identifiable items 8
in the deposition transcript of Mr. Martin.
9 Q
Al] right.
10 I take it you can't recall at this time what they 11 were?
12 A
Well, one of them, I know, involves the event -- well, I 13 believe one of them involves the event where the 14 derogatory note was left in an area that Mr. Martin was 15 inspecting.
16 At this point, I don't have a specific recollection 17 as to the other events.
18 Q
All right, sir.
19 Coss there, C-O-S-S, Mr. Coss has not been a 20 witness in the proceeding.
21 Do you recall what the event is shown for Mr. Coss?
22 A
My recollection is that it came from a deposition 23 transcript, and it was a concern expressed that Mr.
24 Coss' certifications had been allowed to lapse, 25 allegedly because of what I'll characterize as age Sonntag Reporting Service, G td.
Geneva, Illinois 60134 (312) 232-0262
i
(
i i
17036 i
j j
l 1
discrimination; but it seemed to me that this l
2 represented a concern about the way -- at least a i
)
3 concern felt by this inspector about the way his l
l 4
management was treating him at that point in time.
I l
5 0
Okay.
1 l
l 6
" Seeders," another entry for Mr. Seeders.
Now, Mr. Seeders, of course, appears under the l
l l
7 t
i 8
Saklak time line as well.
l l
i l
9 What does the entry for Mr. Seeders under j
l l
10
" Miscellaneous' represent?
l 11 A
My recollection is that Mr. Seeders identified a j
12 concern, ugain, which I'll characterize as a morale 13 problem at or about that point in time.
j l
l 14 I don't have in mind a specific event, but my I
I f
15 recollection is that that was a point in time for which I
t l
16 Mr. Seeders expressed a concern, f
17 Q
All right, sir.
i
(
18 The next entry on that miscellaneous personnel time I
i 19 line reads, " Overtime Bating."
i 20 What does that represent?
l t
21 A
Again, I don't recall the specific inspector, but 22 someone identified at that point in time that overtime l
23 was being used to in:Juce higher productivity from QC 24 Inspectors.
25 0
" Bowman" is an entry and then there's an entry of a l
l l
Sonntag Reporting Se rvice, L td.
Geneva, Illinois 60134
[
(312) 232-0262
17037 9
1 dashed line with the name "Peterson."
2 What does that indicate?
3 A
The Peterson event, as I recall -- and I don't recall at 4
this point why the line is dashed rather than solid --
5 but the Peterson event involved a situation where Mr.
6 Peterson expressed a concern that the degree to which he 7
chose to clean welds prior to conducting an inspection 8
was being questioned by his Lead Inspector, I believe, 9
as being excessive.
That is, the period of time was 10 excessive.
11 Q
I see.
12 A
So this was not -- my recollection is that this is not 13 an event that involved a specific QC Depar tment Manager, 14 but, rather, an interaction between inspectors where one 15 was a Lead.
That's my recollection of this.
16 Q
All right.
17 And then there's an entry that reads, "Seltmann 18 Promo."
19 Mr. Seltmann's promotion to a position where he l
l 20 took Mr. DeWald 's responsibilities?
l 21 A
Well, that's the point in time, as I recall, that Mr.
22 Seltmann became the overall manager of both the quality 23 assurance and the quality control functions within the 24 Comstock organization.
25 Q
Yes.
l Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
17038 O
1 And then last there's an entry that reads, 2
"Dominique."
3 What does that refer to?
4 A
My recollection is that that event involved an 5
interaction between Mr. Dominique and Mr. Simile, and I 6
don't know that -- I don't have a specific recollection 7
as to the nature of the event.
8 0
All right.
9 Well, Mr. Dominique has not been a witness in this 10 proceeding except by Edison on rebuttal.
11 I heard nothing from him on this score at that 12 time.
13 Can you recall what your source was for the 14 Dominique event?
15 A
I'm sure it would have been a deposition transcript.
16 Q
All right, sir.
17 Now, for what purpose did you prepare this figure, 18 Mr. DelGeorge?
19 I know you weren't expecting it to be enshrined as 20 an exhibit in the proceeding -- a t leas t I don't expect 21 you were.
22 But did you prepare it for your own use?
23 A
Well, I prepared it for my own use in connection with 24 the reviews that I conducted in preparing testimony for 25 this proceeding.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
17039 sm (v) 1 Q
When you testified that you made a review to identify 2
trends and correlation between work performance 3
variations, if any, and acts of harassment or 4
intimidation or production pressure, was this figure 5
intended to be a source for iden tifying the cause, if 6
you will of the acts of harassment, intimidation and 7
production pressure?
8 A
Weli, it served that purpose.
9 It also provided me with a basis for assessing the 10 intensity of -- or the level of concern of the QC 11 Inspectors whose concerns have been expressed either N
12 before this proceeding in the form of deposition or s
13 during this proceeding in the form of testimony, and it 14 was an element of the basis upon which I concluded that 15 for certain periods of time, there was, in fact, a 16 perception that there was pervasive harassment, 17 intimidation and production pressure.
18 Q
I see.
19 A
So I used it both in a general sense to assess when, 20 based on the perception of individuals at the site, the 21 pressure -- the alleged pressure was the most intense, 22 and then I also used it to test, on an individual basis, 23 certain inspector performance where a specific event 24 might be identifiable.
/%
4 25 0
All right, sir.
's /
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
17040
( ~)
V 1
Now, wha t I understood from your testimony a few 2
moments ago was you prepared this table before you 3
prepared your prefiled testimony in this proceeding.
4 A
Yes, the notes that I developed were prepared before; 5
and I think this is really a cleaner version of notes 6
and similar bar charts that I produced on an individual 7
element basis.
8 This consolidation -- I don't remember whether this 9
consolidation of information was produced before the 10 testimony was filed, but the development of the 11 information was produced before the testimony was filed.
j 12 Q
The information on which the table is based?
d 13 A
Yes, sir.
14 O
All right, sir.
15 Now, that -- and when was that testimony prepared?
16 A
Well, in the July time frame --
17 0
All right, sir.
18 A
filed in August some time.
19 Q
All right, sir.
20 So this only incorporates, in a limited degree, 21 because of the timing of its preparation or the timing 22 of the data accumulation on which it's based -- it only 23 incorporates, in a limited degree, the evidence actually 24 in this proceeding beyond discovery, beyond deposition?
25 A
Well, if by that you mean that it may not include every
,w/
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
c.
i 1
l l
17041 lO l
1 event that's been discussed in this proceeding, I would t
2 agree that there may be events that, given the timing of l
3 this work, that are not reflected in this exhibit.
I j
4 Q
Yes.
l l
5 For example, Mr. Gregory Asmussen made complaints i
j 6
to the NRC in the summer of '86 and presented testimony
?
7 later in this proceeding about events that transpired 8
beginning in January of '86 and extending into the 9
summer of
'86.
10 And those are not displayed here?
11 A
That's correct.
12 Q
And similarly, Mr. Richard Martin made further l
13 complaints about events that occurred to him in the 14 spring of
'86.
i l
15 And they are not displayed here, either?
i l
16 A
That's correct.
i i
17 Q
There may be others?
j 18 A
Yes, sir.
i t
19 MR. GUILD:
All right.
I 1
20 Mr. Chairman, I would move the admission of i
21 Intervenors' 191 in evidence.
]
l 22 JUDGE GROSSMAN:
Any objection?
f i
l 23 MR. STEPTOE:
No objection.
24 MR. BERRY:
No objection.
25 JUDGE GROSSMAN:
Received.
I l
J
]
Sonntag Reporting Service, L td.
j Geneva, Illinois 60134 i
(312) 232-0262 1
l 17042 l
fs (U)
I i
l 1
(The document was thereupon received into i
I 2
evidence as Intervenors' Exhibit No.
l, 3
191.)
4 MR. GUILD:
And that conclude my examination 5
of Mr. DelGeorge.
l 6
JUDGE GROSSMAN:
Okay.
1 7
Mr. Steptoe, I take it you wish -- oh, I'm sorry.
l l
8 Mr. Berry, i
l 9
MR. BERRY:
Thank you, Mr. Chairman.
i 10 RECROSS EXAMINATION 11 BY MR. BERRY:
! (J
\\
t 12 Q
Mr. DelGeorge, with reference to Intervenors' Exhibit l
l 13 191, I mean, what, if anything, does this exhibit tell 14 us?
15 A
Well, on its face, it tells us one thing, I believe, and 16 that is that the perception of the existence of a j
17 problem on the part of the QC Inspectors is most intense l
l 18 between the periods bounded by the end of August, 1983, i
I 19 and, I'd say, the third quarter of 1985; and in saying
(
20 that, recognize that there are identified events both i
l 21 before-and after those two limits, but they constitute i
j 22 much more isolated occurrences than is the case between l
23 the two limits.
i j
24 So in that sense, given the fact that many of the l
j 25 inspectors who expressed concern, the concerns that are
(% s i
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 I
(312) 232-0262
(
17043 (b
1 identified in this chart, were employed at the site 2
prior to that point in time -- that is, the end of the 3
third quarter of 1983 -- that that constitutes their 4
best recollection of the periods of intense pressure.
5 It does, I believe, support the view that that 6
perception of pressure increased as a function of time 7
and was most intense af ter the third quarter of 1983.
8 That's the first thing that I believe it says.
9 It also, I believe, says that there were -- with a 10 few possible exceptions, there are a number of isolated 11 occurrences where individuals identified problems with f')
12 their management or problems with the organization, but, N.)
13 again, as I say, it is only with respect to a few 14 individuals where there appears to be a continuing 15 expression of concern with respect to either individ ual 16 managers or management generally.
17 So I think that can be -- that can also be seen 18 from an examination of this exhibit.
19 Q
All right.
20 Assuming that you are correct, that the vast 21 majority of the complaints were raised between the -- I 22 guess in that two-year period comprising the period the 23 last quarter of August -- the last quarter of 1984 and 24 the -- '83 and the last quarter of 1985, what
/3()
25 conclusions, if any, can you draw from that?
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
17044 OV 1
A Well, again, on its face, it says that QC Inspectors, at 2
least those to whom questions on the subject had been 3
addressed and who have expressed an opinion, saw that 4
period as one of negative interaction with their 5
management.
6 It was on the basis of that that I concluded that 7
that is the period within which that stimulus, if 8
effective, and if, in fact, an accurate reflection of 9
the real environment at the time, should have manifested 10 a reaction on the part of the performance of the QC 11 Inspectors collectively or individ ually.
(h 12 Q
Mr. DelGeorge, do you have, I guess, an opinion as to, I 13 guess, for lack of a better way of putting it, the 14 chicken and the egg, you know, phenomenon here?
15 That period, August, 1983, into 1985, we have a 16 number of incidents, and I believe your testimony was 17 that it was during this period that the inspectors 18 perceived that there were problems.
19 Could it be that the reason they perceived that is 20 that you had a number of incidents or you had a number 21 of incidents because they perceived there was a problert.?
22 A
Both scenarios are possible; but clearly I claim no 23 expertise as a sociologist and I made no attempt to 24 interpret in that way, what the validity of the stimulus
(N 25 was.
t Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
3 i
i i
{
17045
?
t 1
1 I accepted it as a potential negative stimulus and 2
then tried to determine whether there was, in fact, a i
)
3 measurable reaction to it.
l
)
4 Q
All right.
i 5
I notice, also, that, I believe in response to a l
l 6
question from Mr. Guild, you indicated that the t
7 designation " Inspector Increase" under " Administrative 8
Issues, Pay and Training," in 1984 represented an j
9 increase in the number of inspectors?
l l
10 A
Yes, sir.
s 11 Q
Also, we see under the " Miscellaneous Personnel" bar --
i 12 A
Yes, sir.
l 13 0
-- is that also an increase in the number of inspectors?
?
i 14 A
That's my present recollection of what it is; and that i
i 15 just looking at it, that that may suggest an 16 inconsistency, but I have a --
i 17 Q
I don't know that it does.
l f
18 It's my recollection that there's been testimony in l
19 this proceeding that at some point prior to August of
(
f 20 1984, that there was an increase in the pay; and the l
21 question to you is:
j i
22 Is that reflected on your chart here?
23 A
Yes, sir, I believe it is.
(
24 At or about the beginning of the four th quarter of 25
'83, under the element of this exhibit identified as Sonntag Reporting Service, L td.
Geneva, Illinois 60134 (312) 232-0262
.)
I 17046 l
i ltill i
i r
i 1
" Administrative Issues," there is a pay adjustment line i
I 2
item identified.
l 3
0 All right.
f 4
Finally, Mr. DelGeorge, let me ask you if this l
i 5
refreshes your recollection as to what the entry under l
\\
6
" Miscellaneous Personnel" for Mr. Dominique -- what that l
l 7
could be.
8 My recollection is that a witness testified in a t
I 9
deposition that Mr. Dominique was criticized for writing l
l j
l l
11 A
That may be; and the connection tha t -- the only l
12 connection that I recall is that the criticism was l
13 focused on Mr. Simile; that the connection between I
14 Simile and Dominique is the one that I recall, and it l
15 may, in fact, have been associated with how ICR's or f
i j
16 NCR's were written.
17 Q
Yes, yes, my recollection was that it came -- a witness l
3 j
18 in a deposition mentioned that, and I think it was the f
l 19 1986 time frame.
l j
20 So I just wonder if that refreshed your t
1 21 recollection as to that.
I l
22 A
My recollection is expressed as I just discussed it.
23 I don't have a clearer one.
j 1
l 24 MR. BERRY:
Thank you, Mr. DelGeorge.
25 JUDGE GROSSMAN:
Mr. Steptoe, I take it you I
f j
Sonntag Reporting Service, L td.
i j
Geneva, Illinois 60134
[
(312) 232-0262
)
l
'I 9
I 17047 i
i i
1 wish to renew your offer of the exhibits now?
i i
2 MR. STEPTOE:
Yes.
l 1
3 I have a few further questions for the witness; 1
)
4 but, yes, I offer Applicant's Exhibits 182, 183 and 184.
l 5
JUDGE'GROSSMAN:
Mr. Guild.
l 6
MR. GUILD:
Let me double check, Mr.
7 Chairman.
f 8
Those are the recalcs --
i I
9 JUDGE GROSSMAN:
Of Intervenors' Exhibit 188.
I 10 MR. GUILD:
I'm sorry, Mr. Chairman?
11 Yes, exactly, that 's r ight.
i 12 We have no objection, Mr. Chairman.
13 JUDGE GROSSMAN:
Mr. Berry, f
l 14 MR. BERRY:
No objection.
15 JUDGE GROSSMAN:
Okay.
Those are admitted.
16 (The documents were thereupon received 17 into evidence as Applicant's Exhibits 18 Nos. 182, 183 and 184.)
[
l l
19 JUDGE GROSSMAN:
And you may continue your l
20 redirect.
l 21 MR. STEPTOE:
Okay.
l i
22 REDIRECT EXAMINATION 1
23 (Continued)
I r
24 BY MR. STEPTOE:
25 Q
Mr. De1 George, first one question.
l k
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262 t
17048 O
1 Was there a period of time when Comstock performed 2
less than 100 percent inspections of safety-related 3
items?
4 A
Yes, sir, there was; and it specifically had to do with 5
the configuration inspection of electrical supports.
At 6
least that's my recollection.
7 Q
Okay.
8 And did there come a time when that changed?
9 A
Yes.
10 Q
Okay.
11 Is that time -- and it went to 100 percent 12 inspection?
13 A
It went from 35 percent, as I recall, to 100 percent, 14 yes.
15 0
Is that shown anywhere on your chart?
16 A
No, sir, it isn't.
17 It would have -- my recollection is that it 18 preceded 1983, although it was at the end of
'82, the 19 beginning of 1983; but, again, that, in itself, was not 20 identified as a concern by any inspector, and for that 21 reason, wasn't displayed in this figure.
22 Q
All right.
23 At the beginning of the redirect examination on i
24 Friday, at Transcript 16917, I asked you whe ther you
(
25 agreed with Intervenors' use of the term " accuracy" in Sonntag Reoorting Service, L td.
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Intervenors' Exhibit 188, and I believe you said that l'
l 2
you thought the term " accuracy" should take into account I
3 the fact that overinspectors will reject good work l
j 4
sometimes.
5 Do you recall that?
l i
6 A
Yes, sir.
i 7
0 Then Mr. Guild, on recross, asked you whether Mr. Juran, 8
Page 12-51, speaks about accuracy in the sense that j
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9 Intervenors used it -- that is, accuracy in finding i
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10 defects -- and you replied, "In this section of the 11 document, yes, sir."
12 Do you recall that?
13 A
Yes, sir.
t 14 Q
Did you have another section of Juran in mind --
15 A
Yes, sir, I did, i
i c
l 16 0
-- when you made that answer?
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17 A
Yes, sir.
18 Q
Can you identify it, if I give you the Juran book?
l 19 A
Yes, sir.
(
I 20 Q
All right.
l 21 (Indicating.)
l l
22 A
The discussion that I had in mind is contained on Page
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23 12-60 of the text to which Mr. Guild made reference, and 24 specifically it says a statement in the second paragraph l
25 on that page, which reads, " Numerous s tudies have shown I
Y l
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l that inspector errors in rejecting good product 2
outnumber the errors of accepting bad product," and that 3
statement is footnoted, and the footnote, which is 4
identified as Footnote 126, reads, "In part, this arises 5
because the good product outnumbers the bad and, he n':c,
6 afford greater opportunity for error, but it also arises 7
in part from the fact that acceptance of defects often 8
comes dramatically to the attention of higher management 9
whereas rejection of good product seldom does."
10 MR. STEPTOE:
Judge Grossman, I have nothing 11 further.
12 JUDGE GROSSMAN:
Mr. Guild.
13 MR. GUILD:
May I have just one second, 14 Judge.
15 RECROSS EXAMINATION 16 (Continued) 17 BY MR. GUILD:
18 Q
Well, sir, Juran indeed says the words you quoted, Mr.
19 DelGeorge, but those are spoken in terms of absolute 20 numbers, because the absolute numbers of good product 21 exceed the absolute numbers of bad product.
22 But that doesn't alter the percentage accuracy, 23 does it?
24 A
Sir, I think Mr. Juran makes two comments.
25 One is the one that you just alluded to -- that is, Sonntag Reporting Service, Ltd.
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1 the fact tha t there is a larger quantity of good product i-l 2
presents a greater opportunity, and as a matter of 3
absolute volume, will increase the number of items that j
4 might be falsely rejected -- but the second point that's i
l 5
made in Footnote 126 I believe goes to the fact that 6
where we have a condition where rejected items -- where l
l 7
the reject is falsely rejected, it's good product, is 8
not itself the subject of an expression of concern by i
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9 management that there -- I interpret this as meaning I
10 that there will be a lesser sensitivity on the part of 1
1 l
l 11 the inspector to rejecting good product than there would j
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12 accepting rejectable product, which will, in fact, come
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13 to the attention of management.
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14 Q
Okay.
15 So --
16 A
So there are two elements.
I 17 0
-- there are two elements.
18 One element is simply a function of the larger i
19 numbers of acceptable qualities in a product being l
i 20 inspected.
Therefore, there will be a larger number of 21 accuracy -- of errors on that score, even if there's the 22 same percentage accuracy on both sides of the accuracy i
23 coin.
24 That's one point that he makes; correct?
[~')N 25 A
Yes, sir.
(
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The second point he makes is that where there is a 2
strong negative sanction for failing to identify 3
rejectable product, that will influence inspectors in 4
that respect?
5 A
Well, I don't know that he specifically refers to strong 6
negative sanction.
7 Q
No.
He does.
8 What he says here is, "But it also arises in part 9
from the fact that acceptance of defects often comes 10 dramatically to the attention of higher management," et 11 cetera.
12 A
That, I think, goes to the identification and not the 13 reaction of management to the identification.
14 Q
Well I read drama as suggesting that there is some 15 qualitative response by management that differs in 16 respect to one kind of error from another.
17 Don't you?
18 A
I think that is probably a part of it, yes.
19 Q
So to determine whether or not Juran really, when he's 20 talking about nuclear Quality Control Inspectors or BCAP 21 inspectors or BCAP QA overinspectors, aside from the 22 Point 1, which has to do with simply the incidence of 23 good product versus bad product, one would have to look 24 to the bottom-line question of what exactly the 25 consequences are of the type of error to determine Sonntag Reporting Service, Ltd.
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1 whether those consequences have an influence on the j
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2 accuracy rate?
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1 3
A That may be part of it.
I can't speak for Juran.
i 4
I believe that's a reasonable interpretation.
j 5
MR. GUILD:
All right.
f l
6 That's all I have, Mr. Chairman.
i 7
JUDGE GROSSMAN:
Mr. Berry.
8 MR. BERRY:
Nothing further, Mr. Chairman.
l j
9 JUDGE GROSSMAN:
Well, thank you very much, i
10 Mr. DelGeorge.
I i
11 THE WITNESS:
Thank you.
j 12 JUDGE GROSSMAN:
You are excused now unless l
13 one of the parties wishes to recall you for anything.
i 14 (Witness excused.)
l l
15 MR. GUILD:
Mr. Chairman, I wish at this time l
16 to renew my objection to the receipt of Mr. DelGeorge's l
17 testimony.
l l
l I guess I would make this by way of a motion to 18 l
19 strike.
i 20 Intervenors move to strike Mr. DelGeorge's I
21 testimony pursuant to Rule 703 of the Federal Rules of 22 Evidence.
23 The basis for the motion to strike, in short, is l
l I
24 the absence of a demonstrated reliable foundation behind 25 the opinion evidence that Mr. DelGeorge has offered.
1 Sonntag Reporting Service, Ltd.
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The record, after cross examination now, amply 2
reflects that the foundation for Mr. DelGeorge's 3
testimony is flawed in two important respects.
4 There may be others, but at least with respect to j
5 the admissibility of the testimony in these respects:
6 First, it relies principally upon the thesis that 7
the agreement rate -- that is, the rate at which 8
overinspectors, CSR inspectors or PTL inspectors, agree 9
with the product condition -- strike that -- the degree 10 to which they find defects in a product -- that is, the 11 electrical sample items given to them expressed in terms f
12 of an agreemenc rate, percentage of 100 -- that 13 agreement rate is an ef fective measure of the original 14 inspector's work performance.
15 That is a theoretical foundation for Mr.
16 DelGeorge's testimony, and it's simply a foundation 17 without any reliable evidentiary support.
18 Intervenors have demonstrated, we believe, that it 19 simply is false, as a matter of logic, to conclude that 20 agreement rates are a consistent measure of anything; if 21 anything, perhaps a surrogate for the quality of the 22 product that's reviewed by the overinspector or 23 reinspector, again taking into account there's 24 inaccuracy and errors going to occur at that rate, 25 too -- or at that poin t, too.
Sonntag Reporting Service, Ltd.
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So there may be defects that aren't identified, but 2
because of the phenomenon principally of the fact that 3
what is sampled by the overinspector or reinspector is 4
simply not the same thing that was inspected by the 5
first inspector, there is no reliable relationship 6
between the two that can be the basis for using 7
agreement rates as a measure.
8 Now, that is, of course, because of the consistent 9
phenomenon of only looking at what's been found to be 10 100 percent acceptable product, 11 What's been found rejectable in the first instance 12 is removed from the sample and fixed and put back in or 13 removed from the sample and either not fixed and not put 14 back in, but in either event, there is not the same --
15 it's not the same sample, it's not the same piece of
'l 16 work that's being reviewed by both the original 17 inspector and the overinspector, and as a statistical j
18 and mathematical matter, it simply is a given that 19 accuracy rates by the first inspector will not be 20 measured consistently by the expressed agreement rate.
21 Of course, there are other variables as well that l
22 make it impossible to use it even as a consistent, s
23 though imprecise, measure.
So that's the first point.
24 The first point is that agreement rates -- a false 25 premise underlies all of Mr. DelGeorge's testimony using i
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1 the measure of agreement rates.
2 Secondly, Mr. DelGeorge purports to make opinion 3
statements with respect to what he describes as 4
trending, seeking to identify trends.
5 Now, it's apparent that at least one-half of that 6
equation is what Mr. DelGeorge's understanding of the 7
record is in thir case.
It's the same record this Board 8
is going to have to look at.
9 It is, indeed, helpful, I think, to see what 10 Applicant's view of the case is reflected in 11 Intervenors' Exhibit 191, but essen tially that there's 12 nothing more here than what's already before this Board 13 to draw inferences from.
14 But fatally the problem here is that the data, 15 then, that Mr. DelGeorge relies on as the basis, the 16 evidentiary basis, for his opinion evidence -- the 17 effect data, if you will -- is the data on agreement 18 rates over time, and that data is fundamentally flawed 19 both first in the case that agreement rates don't mean 20 anything, and second, in the fact that there's such 21 variability in the sources of data over the periods of 22 time from which trends are supposed to be adduced that 1
23 no meaningful judgments, opinions, can be expressed on 24 the basis of that data.
(O) 25 For example, the data is aggregated it:to such Sonntag Reporting Service, Ltd.
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1 conglomerations of time and quantities of samples as to 4
4 2
be meaningless.
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3 The witness concedes that no data is sufficient to l
4 allow individual inspector basis judgments over time.
l l
f 5
The witness concedes that only after an agglomeration of I
6 the entire work force for all inspection points is there i
I l
7 suf ficient data with confidence to express opinions.
I l
8 The witness adds that there's suf ficient data, in 9
his opinion, to make judgments with less confidence t
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10 about smaller agglomeration of data -- say, for example, i
11 all welding -- but the more you disaggregate the data, I
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_.s 12 the less reliable, by the witness' own admission, is
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13 that data as a basis for trending over time.
14 Secondly, as reflected in Intervenors' Exhibit --
i 15 if I may have a moment.
It's the bar chart that 16 Applicant corrected --
l 17 JUDGE GROSSMAN:
Intervenors' Exhibit 188.
I 18 MR. GUILD:
Yes, Mr. Chairman.
Thank you.
19 190, I'm told, t
20 JUDGE GROSSMAN:
Oh, I'm sorry.
That's --
21 MR. GUILD:
190 is the corrected version, Mr.
22 Chairman, incorporating the revisions to Mr. DelGeorge's l
t 23 testimony.
i 24 JUDGE GROSSMAN:
Okay.
That's a revised 189.
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25 F in e, okay.
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But that's what you refer to?
2 MR. GUILD:
Yes, sir.
3 What that document reflects, Intervenors' 190, is, 4
of course, that even for the agglomerations of data that 5
Mr. DelGeorge believes he has sufficient sample size so 6
as to express opinions on trends, that Applicant has 7
failed to control for variables that, by its own 8
description, will influence the results.
9 For example, welding inspections predominate in the 10 period before Mr. Saklak's hiring -- that is, the first 11 half or more of the time period in issue -- and (m
12 non-welding or objective attributes, inspection points,
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13 predominate in the period after.
14 If you simply fail to control for the types of 15 things that you are sampling, you don't know what is 16 influencing the results you are looking at.
17 Those are the two principal flaws that we see in 18 Mr. DelGeorge's opinion evidence; that is, the use of 19 agreement rates and the failure to employ data 20 sufficient to draw any opinion evidence about trends 21 over time.
22 We think those are both fundamental flaws to Mr.
23 De1 George 's tes ti nony, and that, under Rule 703, it 24 makes Mr. DelGeorge's opinion evidence inadmissible.
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25 Let me cite two cases for that proposition:
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vercus Chrysle't Corpot.ation, D.
C. Circuit, 1977, 569 e
3 Fed 2nd 6606, Pages 671 and 672; and Soden, S-O-D:E-N, f'4 versus Frejght Liner Corporatio5, F-R-E-I-G-H-T, a 5th l
5 Circuit case, 1983, 714 Fed 2nd 498 at 503.
1 j
6 We believe that the authority interpretingfRule'703 7
stands for the proposition that simply because an expert n
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is tendered and says, "liere's my novel theory ^for how
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12 and production.'sessuer," the fact that the re.]e p
13 liberally allows e vert nitn c s testimony does not mean t !
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17 And here we,believe that it's demonstrated that tho p
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j 19 is simply so unrc. liable as to not merif. reliance on it 20 as expert testimony.
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- 1 21 JUDGE GROSSMAN:
Okay.'
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's 22 Mr.. Guild, before we get to Mr. Steptoe, it doesn't i
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24 infirmity to the testimony h2re.
25 I have no-doubt that ifwdread those two cases, l
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1 they would indicate that the testimony presented there 2
was so illogical and so flawed as a factual matter that 3
that constituted a legal infirmity to the testimony; but 4
I don't think we could find that in this case.
5 What you have raised are arguments that go to the 6
ultimate factual conclusion that we can draw from that 7
testimony, and we 'll certainly consider your arguments, 8
whether you have stated them here or whether you are 9
going to state them in your proposed findings, and I 10 think it would shorten the hearing if we didn't force 11 Mr. Steptoe to respond to that, because I don't think he f) 12 has to.
b 13 If you wish to put a counter argument in at this 14 po in t, since Mr. Guild has made his argument, we won't 15 precluding you from doing it, but I don't think it's 16 necessary, and it certainly isn't going to persuade us 17 any more than what we're going to see in the final 18 brief.
19 So that's up to you, Mr. Steptoe.
20 We 're going to deny the motion.
We 'll accept the 21 testimony.
22 MR. STEPTOE:
Judge Grossman, I'll take the 23 hint and not make any further argument.
i 24 I don't agree with everything that Mr. Guild said,
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25 and I think in some respects, his argument l
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briefing.
3 JUDGE GROSSMAN:
Fine.
4 MR. GUILD:
Mr. Chairman, I would appreciate i
5 knowing if I'm being called -- if it's being stated on 6
the record I mischaracterized his testimony, I'd 7,7 appreciate it if Mr.'Steptoe --
8 JUDGE GROSSMAN:
No, it's not 8
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't.
11 testimony is and Mr. Steptoe has his opinion as to how (v')
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unflawed the testimony is, and we'll draw our 13 conclusions froh the testimony after we've read the 14 respective briefs on this or proposed findings, 15 whichever form' we get the arguments in, and there really
'16 isn't any need to pursue that matter now, and that 's all i
17 that we're deciding; just that you haven't made any 18 prima facie showing that the testimony is so illogical 19 and so flawed that we couldn't consider it, and that's 20 all that there is before us, so we're denying the
., 21 motion.
22 Mr. Berry, did you have anything that you wished to i
23 delay the hearing over?
24 MR. BERRY:
No, I don't, Mr. Chairman.
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25 The Staf f will express its views, if any, it has on
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this matter in proposed findings.
2 JUDGE GROSSMAN:
Fine.
3 Do we have another witness?
4 MR. STEPTOE:
I'm afraid not, Judge Grossman.
5 JUDGE GROSSMAN:
Okay.
6 Well, I certainly hope -- you know, I was hoping --
7 of course, no one could tell whether the witness would 8
be through testifying, since neither of the parties, 9
active parties, in that regard were disclosing their 10 positions, but I would certainly hope that you can get 11 some bits and pieces to fill in if we have a short day, f~'
12 though we don't have it now.
'\\_-
13 MR. MILLER:
Well, your Honor, we 're about 14 out of bits and pieces, I'm afraid, and what we're 15 dealing with essentially are Applicant's witnesses who 16 are from outside this city and have other comm,itments.
17 We have scheduled them, giving a reasonable 18 expectation of the extent of cross examination; and I 19 regret, perhaps more than anybody, that we are, the 20 Board and the parties here, without a witness to take 21 the stand.
22 Dr. Frankel will be here tomorrow morning and be 23 prepared to go on; but I regret to say, at this point, 24 there is no one else this week beyond Dr. Frankel.
We O )
25
(
will then begin with Mr. Laney the following week.
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1 Mr. McGregor remains something of a wild card here, 2
since his attorney has still not received the 3
communication from the NRC Staff that he's been 4
expecting now for six weeks, and so that remains an 5
uncer ta in ty.
6 Other than that, with the remaining three expert 7
witnesses that we have, that will conclude our rebuttal 8
case.
9 There is, I understand, to be a Staff witness in 10 rebuttal; and I don ' t know whe ther Mr. Guild, on behalf 11 of Intervenors, has any plans to call any additional
[
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12 witnesses or not.
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v 13 JUDGE GROSSMAN:
Mr. Berry, I understand Mr.
14 Gardner will be here some time.
i 15 Is there any other Staff witness that we're going 16 to hear from?
17 MR. BERRY:
I don't anticipate at this time 18 tha t there will be, Mr. Chairman, although I would 19 reserve that option.
20 In this connection, I would point out that as you 21 recall, when Mr. McGregor was testifying, you know, when 22 he was with us before, that the Board gave the Staff the 23 courtesy of having the opportunity to call additional 24 witness or witnesses depending on the testimony elicited (j
25 by the parties of Mr. McGregar on cross examination.
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JUDGE GROSSMAN:
We're not holding you to it.
2 We just want an estimate.
3 We were hoping to conclude some time next week.
4 Now, is there any reason that anyone sees that 5
we 're not going to do that?
6 MR. BERRY:
I would say, Mr. Chairman, that 7
in view of the fact the Staf f does expect to present Mr.
8 Gardner, we are endeavoring to have his testimony -- his 9
prefiled testimony completed and made available to the 10 parties.
We were hopeful of having that done this week, 11 and we will make every effort to, but I'd like to alert
}
12 the parties right now that that may not be the case.
It
%s' 13 may be the first part of the next week before we can do 14 that.
15 I recall that I assured the parties that they would 16 have adequate time to review that testimony pr,ior to, 17 you know, his taking the stand, although I also in the 18 record make, you know, clear to the par ties what I 19 expect the nature of that testimony to be.
20 I would doubt seriously that the other parties 21 would agree, for example, to Mr. Gardner testifying on 22 the day after his testimony was filed.
23 Also, I would point out, from the Staff's point, 24 that the Staff does exercise prerogative to go last in 25 these proceedings; and as I understand it, upon the q j Sonntag Reporting Service, L td.
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completion of Applican t 's witnesses, provided Intervenor i
2 is not offering any more witnesses, that we would make l
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Mr. Gardner available.
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4 In the event that Intervenors would determine that j
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5 they have other witnesses to present, I believe that we I
6 should hear those witnesses before we hear the Staff i
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witnesses.
l f
8 So in view of that, Mr. Chairman, I would be j
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9 surprised that we can complete -- we would be completed 10 by next week.
l 11 I think, you know, Staff counsels' hotel i
12 reservations extend through the Thanksgiving recess.
f 13 MR. MILLER:
Your Honor, I would urge the j
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14 Board to urge the Staff to proceed in their desire to go I
l 15 last.
l 1
1 16 Otherwise, all of us are going to be sitting --
l 17 there's a potential at least for all of us sitting 18 around here with some time on our hands.
i 19 JUDGE GROSSMAM:
Well, the big hang up is l
20 closing this McGregor matter, and I don't think that we l
l l
21 can go around it, anyway.
f 22 If OIA would only come down with its formal finding l
23 on that, then we can get Mr. McGregor on and Staff's l
24 witness then will come on right after that.
25 That's the only matter that I believe Staff is l
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concerned about, with putting Mr. Garner on first, and 2
so that's the only way to handle it.
3 Now, have we heard anything further from OIA on j
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4 that, Mr. Berry?
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f 5
MR. BERRY:
No, we haven't, Mr. Chairman.
I 6
You recall that the Board Chairman made the j
7 suggestion -- made the statement last week at the l
l 8
conclusion of last week's session with respect to this l
9 matter.
10 I communicated that to OIA.
They are well aware of 11 the needs of the parties in this proceeding; and whether I '}
12 that will spur them to act with any greater speed, I (s /
i 13 can't say, but they are aware of that.
l l
14 JUDGE GROSSMAN:
Okay.
i 15 Well, that's all we can do, and I guess we might as l
l 16 well conclude the record for the day, and we'll just be i
I 17 back here at 9:00 o' clock tomorrow morning.
1 I
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18 We'll start with Dr. Frankel, and hopefully we'll t
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19 finish him by the end of tomorrow or Friday morning.
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20 So we're adjourned until 9:00 o' clock tomorrow.
l i
i 21 (WHEREUPON, at 3:20 P.
M.,
the hearing of l
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22 the above-entitled matter was continued l
23 to the 13th day of November, 1986, at the l
l l
l 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />
,f 9:00 A. M.)
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l L--)
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i NO PAGE NUMBER CERTIFICATE OF OFFICIAL REPORTER S
This is to certify that the attached proceedings before the UNITED ST5TES NUCLEAR REGULATORY COMMISSION in the matter of:
NAME OF PROCEEDING:
BRAIDWOOD STATION UNITS 1 62 COMMONNEALTil EDISON (llEARING)
DOCKET NO.:
50-456/457/0L PLACE:
ClllCAGO, ILLINOIS
/y.
._. J DATE:
WEDNESDAY, NOVEMBER 12, 1986 were held as herein appears, and that this is the originai transcript thereof for the file of the United States Nuclear Regulatory Commission.
(sigth A -# J_ h (TYPED) 1 l
l Official Reporter Reporter's Affiliation l
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1