ML20214C262
| ML20214C262 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 08/12/1986 |
| From: | COMMONWEALTH EDISON CO. |
| To: | |
| References | |
| OL-A-116, NUDOCS 8705200627 | |
| Download: ML20214C262 (10) | |
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1 UNITE 0 3'.'ATES OF AMERICA
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NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY & LICENSING BOARD [,
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In the matter of:
7 COMMONWEALTH EDISON COMPANY Docket No.59-456 59-457 8
(Braidwood Nuclear Power Station, 9
Units 1 and 2]
) 19
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11 Isham, Lincoln & Beale
)
Three First National Plaza 12 13 Sist Floor 14 '
Chicago, Illinois Wednesday, November 13, 1985 15
16 Deposition of:
WALTER J. SHEWSKI, called for
'17 18 examination by counsel for the Intervenor, BPI, pursuant to j.
19 notice, taken before Suzanne B. Young, a Notary Public in and 29 21 ANN RILEY
& ASSOCIATES, LTD.
(
22 1625 I Street, N.W.
293-3959 Washington, D.C.
8705200627 860812 PDR ADOCK 05000456 O
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1 for the District of Columbia, beginning at 10:10 a.m.,
when 2
were present on behalf of the respective parties:
3 4
APPEARANCES:
5 For the Licensee, Commonwealth Edison Company:
6 MICHAEL I. MILLER, ESQ.
7 Isham, Lincoln & Beale 8
Three National Plaza 9
Chicago, Illinois 69692 19 11 For the NRC' Staff:
12 ELAINE CHAN, Esq.
13 U.S. Nuclear Regulatory Commission 14 Office of the Executive Legal Director 15 Washington, D.C. 26555 16 17 18 19 29 21 22
3 1
APPEARANCES:
(Continued):
2
'3 For the Intervenor, BPI, et al.:
4 ROBERT GUILD, Esq.
i 5
199 North
Dearborn,
Suite 1399 6
Chicago, Illinois 69692 7
8 Also Present:
9 GEORGE MARCUS, Commonwealth Edison 18 11 12 13 14 15 16 17 18 19 29 21 22
?
- _ ?_,..
4 1
C0NTENTS 2
Witness:
Examination By:
Page No.:
S 3
WALTER J.
SHEWSKI Mr. Guild 5
4 5
6 7
8 9
10 11 12 13 14 15 16 17 18 19 20 21 22 I
l x
185 1
A' I don't believe I can specifically identify anybody.
2 Q
How about stop-works?
Tell me about any stop-works 3
at Braidwood that you,.the Edison Quality Assurance Department, 4
imposed?
5 A
I think in the certification statement, there is a 6
listing of the stop-works in there up to that date.
7 Q
Are there stop-works in there that were imposed by 8
Edison?
9 A
They are either imposed -- yes, they are Edison le stop-works, and they are either imposed directly by Quality 11 Assurance or influenced or required to be done by Quality 12 Assurance, but the stop-works were actually done by the 13 Production Department.
14 Q
By the contractor?
15 A
No.
The Project Construction Department.
They l
16 ordered the stop-work.
17 Q
Oh, I see.
18 A
We would rather they ordered a stop-work than us.
l l
19 Q
Okay.
Now I am looking at a table in here that says l
29 Exhibit C, Braidwood Station Stop-Work Actions Initiated by 21 Commonwealth Edison Company.
22 A
That's it.
l l
l
186 1
Q By " initiated," that means that either you in QA or 2
Project Construction required the stop-work?
What does 4
3
" initiated" mean; let me ask you that?
4 A
It means we initiated it, and that we either issued 5
a stop-work letter, or another department caused a stop-work,
-6 being Construction.
' 7 Q
Does that include situations where the contractor, t
8 themselves, issued a stop-work, and indirectly you would say 9
that you influenced them?
i 10 A
Well, if there was a direct relation, we would say 11 we caused the stop-work.
That's all.
12 Q
What I am driving at here is, when you say " initiated 13 by Commonwealth Edison Company," are these all cases where the 14 action was required by Edison and not by the contract --
15 A
Yes, they were required by Edison some way.
But the 16 person who issued the stop-work letter may have been Quality 17 Assurance, may have been the Project Construction, or may have 18 been a contractor.
19 Q
Have you ever directed a stop-work?
29 A
Sure.
21 Q
At Braidwood?
22 A
After -- all stop-works have to be cleared with me,
187
-1 and we have to determine whether or not the stop-work is 2
justified and proper, and if it is, then I direct them to go 3
ahead and do the stop-work as recommended, and I suggest to 4
them to try to get Construction to do the stop-work or get the 5
Construction of Edison to get the contractor to do the 6
stop-work, and if you don't get that, then we will initiate 7
the stop-work.
8 Q
Okay.
In what instances have you had to have your 9
department initiate the stop-work?
10 A
I don't recall which ones, which ones they are, but 11 the idea is that we were involved in initiating them, QA was.
12 Q
Well, what'I want you to do is, if you can, tell me 13 what the most significant instance was where you had to issue 14 or initiate the stop-work, you, the -- I'm going to show you 15 the list -- you, the Quality Assurance Department, had to 16 initiate a stop-work because, as you have just said, Project 17 Construction and the contractor wouldn't?
18 MR. MILLER:
I object to the form of the question, 19 but go ahead and answer it.
29
[ Witness reviewing document.]
21 THE WITNESS:
I would rather not try to sort out any 22 of these, which one was most important.
As far as I'm
188 1
concerned, they were all important and required a stop-work.
2 BY MR. GUILD:
3 Q
That wasn't my question.
My question was, using 4
that list to refresh your recollection, or anything else that 5
would help, identify for me any instance where, as'you have 6
just gotten done stating, Edison Quality Assurance had to 7
initiate the stop-work because Project Construction or the 8
contractor would not.
9 A
I couldn't be sure which ones of these we took the 10 lead role in.
I'd have to investigate that.
11 Q
Are there any where you took the lead role?
12 A
I probably took the lead role in every one of these, 13 but we did not do the actual writing of the letter.
And then 14 we have the proviso that that stop-work cannot be lifted 15 without the approval of QA.
16 Q
Here is the point of my question.
I am looking for 17 evidence where Quality Assurance at Commonwealth Edison, where 18 there is a conflict with production, takes the upper hand, if 19 there is such evidence, and you told me --
20 A
All these.
21 Q
Wait a second.
You told me that one of the 22 indications was your stop-work history.
Now you also outlined
L 189 1
that you tried to get Project Construction to initiate the 2
stop-work or the contractor, if it is a contractor, but if 3
they won't do it, you will do it.
4 Now I just want,you to identify any instance where 5
you had to do it, where Commonwealth Edison Quality Assurance 6
itself has had to initiate the stop-work.
7 A
If I was to pick one of these, I would not be sure I 8
was right, and we would have to get documentation to show it.
9 But all I'm trying to tell you, we were behind the 19 stop-work of every one of these, and if they weren't stopped 11 by Construction or they weren't stopped by the contractor, 12 then QA took the initiative to stop these.
13 Q
But none of those leap out at you as being ones 14 where you had to go to the mat and do the stop-work yourself?
15 A
Well, I don't remember.
16 Q
Okay.
And then I think you identified instances 17 where you have required changes as indicative of quality 18 assurance --
19 A
Say it again, please?
29 Q
You used the word " required changes" when I asked 21 you to tell me any evidence of areas where QA will control 22 over cost and schedule where there is a conflict.
199 1
What kind of changes have you required?
2 A
For example, if we did not have an adequate 3
procedure, we would stop the work until the procedure was in 4
place, that was acceptable, if we could not fidd another way 5
in order to assure ourselves that our work was being done 6
acceptably while the procedure was being written.
7 Q
Okay.
What are the most significant kinds of 8
changes that Edison Quality Assurance has required that are 9
indicative of quality assurance taking precedence where 10 there's a conflict with cost and schedule?
11 MR. MILLER:
Object to the form of the question.
12 THE WITNESS:
I can't answer that question.
I don't 13 know.
14 BY MR. GUILD:
15 Q
If there is a conflict between Quality Assurance and 16 Construction, Mr. Shewski, that cannot be resolved within the 17 Construction or Quality Assurance Departments, how is the 18 conflict resolved?
19 A
It would be resolved by the boss, the higher level 20 of the company.
21 Q
Who would that be?
22 A
In this case, it would be Mr. O'Connor, or probably 1
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