ML20214C715
| ML20214C715 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 02/17/1986 |
| From: | Gallo J ISHAM, LINCOLN & BEALE |
| To: | Guild R BUSINESS & PROFESSIONAL PEOPLE FOR THE PUBLIC INTERES |
| References | |
| CON-#186-131 OL, NUDOCS 8602210244 | |
| Download: ML20214C715 (2) | |
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ISHAM, LINCOLN & BEALE "
Tc3 %i c C G " N '" M A COUNSELORS AT LAW 000KEIED nsocO~~ecrcuf acus.= a. sure um uWFC
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cy,w o,,c, convo s assau. iers i o2 2o2833173o gwagg Fast NATBDMAL pt AgA HOSERT T L.INCOLNJ.4721400 86 FER 19 R2 :12 '<M'E*l"5 ou -
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February 17, 19 8 6 00cMETmci 9 :,v,r.t BRANCH Robert Guild, Esquire BPI 109 North Dearborn Street w <er Suite 1300
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(( bM( ff Chicago, IL 60602 k
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Dear Mr. Guild:
Your January 30, 1986 notice of depositions of Messrs. Geiseker, Kostal, Shevlin, Orlov and Quaka stated that you intended to inquire generally with respect to their knowledge concerning the QA contention.
I called you on January 31 to ascertain whether you really intended such a general inquiry of the five witnesses since it was my understanding that the primary purpose of the depositions was to inquire with respect to the affidavits these witnesses provided in support of the motion for summary disposition.
My interest was more than academic since the amognt of time needed for preparation of the five witnesses would be significantly greater if the inquiry were to be a general one.
You stated in response that because the February 18 deadline for filing your reply to the motion for summary disposition did not appear to allow rufficient time for a general inquiry, you were agreeable to limit the scope of the depositions.
Whereupon se agreed that the scope of the depositions would be limited to the subject matter of the five witnesses' affidavits -- the only exception being extraneous matters that could be reasonably linked to their testimony.
As a condition of this agreement, I also agreed that if you desired, I would make available any of these witnesses in the future for the purpose of inquiring with respect to other aspects of your QA contention.
The foregoing agreement served us well during the Geiseker deposition on February 12.
The terms of the agreement, including your acknowledgement of its existence, was succinctly set forth at Tr. 36-37; and we were able to accommodate each other's interest whenever there was a disagreement as to whether your questions were straying too far from the subject matter of the Geiseker affidavits.
8602210244 e60217 PDR ADOCK 05000456 DhN O
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-g-You can imagine my amazement when the next day, February 13, you denied that the foregoing agreement existed.
(Shevlin deposition, Tr. 49-53, and 55).
It was only after persistent questioning by Phil Steptoe that you conceded that
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a discussion of the matter had occurred at all.
It is true that you " signed nothing in blood" (Tr. 55); I simply accepted your oral representation on the matter.
However, the Geiseker deposition, Tr. 36-37, confirms the existence of the agreement.
Moreover, the efficacy of your contrary position on the 13th is belied by your slip of the tongue at page 56 of the Shevlin deposition when you defended your line of questioning on the ground it did not transgress the agreement which you adamantly denied existed one page earlier.
I can only conclude that lying about the matter was simply a shabby and unsuccessful attempt on your part to obtain an advantage in your dealings with Phil Steptoe.
You also slander and because the deposition was transcribed, libel my professional reputation and that of my firm's during the Shevlin deposition (Tr. 54 and 55-56).
I assume you are still complaining about the recent controversy concerning the hearing schedule where you alleged a breach of an agreement by. Mike Miller and me.
You persist in this point of view despite the Licensing Board's February 3 order holding that your allegation was without merit since no final agreement on schedule had been effected among the parties.
Your unwillingness to desist in this matter does not serve you well.
I have only one request at this point.
In the future when you have the irresistible impulse to repeat your slanderous conduct, please confront me directly on the matter.
I will be pleased to meet you before the Licensing Board, on deposition, or privately if you prefer.
Sincerely, d
eg Joseph Gallo JG/ kit cc:
Service List - copy of Shevlin deposition to NRC Enclosure
RCLATED gRRESPONDtN@
s 1
UNITED STATES OF AMERICA
$g 19 2
NUCLEAR REGULATORY COMMISS 99'72 3
BEFORE THE ATOMIC SAFETY & LIC G BOARD 44p;q 5
- - - - - - - - - - - - - - - - - - - -x 6
In the matter of:
Docket Nos.
7 COMMONWEALTH EDISON COMPANY 50-456 50-457 8
(Braidwood Nuclear Power Station, 9
Units 1 and 2) 10
- - - - - - - _ - - -x 11 Isham, Lincoln & Beale 12 Three First National Plaza j'
33
/U Chicago, Illinois i4 Thursday, February 13, 1986 15 The Deposition of EDWARD M. SHEVLIN, called 16 for examination by Counsel for Intervenor, taken before 17 Suzanne B. Young, a Notary Public in and for the District 18 of Columbia, at the offices of Isham, Lincoln & Deale, 19 Chicago, Illinois, on February 13, 1986, when were present 20 21 ANN RILEY & ASSOCIATES, LTD.
22 1625 I Street, N.W.
293-3950 Washington, D.C.
u 9
+V I
- T, e
2 I
on behalf of the respective parties:
2 APPEARANCES:
3 For the Licensee, Commonwealth Edison Company:
4 PHILIP P. STEPTOE, III, Esq.
Isham, Lincoln & Beale 5
Three First National Plaza Chicago, Illinois 60602 6
For the Intervenors, Rorem, et al.:
7 ROBERT GUILD, Esq.
8 109 North
Dearborn,
Suite 1300 Chicago, Illinois 60602 9
For the NRC Staff:
10 ELAINE CHAN, Esq.
11 Office of the Executive Legal Director U.S. Nuclear Regulatory Commission 12 Washington, D.C.
20555 4
15 16 17 18 19 20 21 22 O
4
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I E Q E_ X, 2
Witness Examination By:
Page No.
3 EDWARD M. SHEVLIN Mr. Guild 4
5 Mr. Steptoe 62 6
Mr. Guild 66 7
Mr. Steptoe 70 8
Mr. Guild 71 9
10 11 12 13 EXHIBITS s
( )
Exhibit No.
Description Identified ja Shevlin No. 1 Intervenors' Notice 15 of Deposition 1/3/86 8
16 Shevlin Group Exhibit Drawings, memos, reports, 12
,7 etc.
17 and No. 2 18 19 20 21 22 f'\\
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4 P. E E E E E E I._ E E E 1
2 10:10 a.m.
3 Whereupon, 4
EDWARD M. SHEVLIN, 5
called for examination by counsel for Intervenors, after 6
being sworn under oath, was examined and testified as 7
follows:
8 EXAMINATION 9
BY MS. GUILD:
10 0
Mr. Shevlin, would you state your full name and 11 your business address for the record, please?
12 A
My full name is Edward M. Shevlin, and my 13 business address is Braidwood Nuclear Station, Braidwood.
t x
14 O
And by whom are you employed?
15 A
I am employed by Daniel International Corporation.
16 O
And in what capacity?
17 A
I am currently working as a consultant in the, 18 Phillips-Getschow Mechanical Contractors organization.
19 0
You submitted an affidavit in this proceeding in 20 support of Commonwealth Edison Company's Motion for Summary 21 Disposition regarding a portion of Intervenors' quality 22 assurance contention, and I want to show you a document O
5 1
that is entitled " Affidavit of Edward Michael Shevlin on 2
Rorem QA Subcontention 12J, and it appears to be your 3
signature.
Is that your signature?
4 A
Yes, it is.
5 0
And is that your testimony, a document of 30 6
pages with attachments that follow that affidavit?
7 A
Yes.
8 Q
For the record, my name is Bob Guild.
I am 9
counsel for the Intervenors Bridgette Rorem and others, 10 in the Braidwood licensing proceeding on the quality 11 assurance contention, and I have got some questions for you 12 concerning your affidavit, Mr. Shevlin.
13 Before I begin, I understand that you may have 14 some corrections to your testimony.
15 A
- yes, 16 0
could I ask you to make those at this time, 17 please?
18 MR. STEPTOE:
We sent a letter out last week, 19 but why don't you go ahead and do it again just for 20 completeness.
21 MR. GUILD:
I would appreciate that.
22 THE WITNESS:
Okay.
There are, first, a number O
6
/(,),
1 of typographical errors.
2 MR. GUILD:
Why don't you just leave off the 3
typos unless they change the meaning of the testimony, d
THE WITNESS:
No, they mean nothing.
5 Second, on Answer 26, page 20, the second line 6
from the bottom, the number 20 should be 21.
Oh, excuse 7
me.
The second line from the bottom on page 20, the figure 8
0 foot, 0-3/8 inches should be O foot, 0-3/4 inches.
9 BY MR. GUILD:
10 0
I am looking at the last line.
Is that what your il reference is?
There is one word on the last line.
I 12 apologize. Thank you.
That should read 3/4 inch; correct?
13 fs A
Right.
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id O
All right.
Thank you.
15 A
Answer 35 on page 26, the second line from the 16 bottom, 20, should read 21.
17 O
All right, sir.
18 A
On Exhibit E, the page numbered E-521, in the 19 right-hand column, top, the number "7" should be number "8."
20 And the bottom number in that column, "12," should be "13."
21 O
All right, sir.
Are there any others?
22 A
Yes.
Answer 13, page 11, the fifth and sixth
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7 1
lines from the top, in both cases the word " bottom" should 2
be " top."
3 0
And how should the sentence read?
4 A
It should then read, "In the other case, the 5
BCAP Task Force recorded a 10-inch dimensional difference 6
from the top of the slab to the bottom of -- to the top of 7
a riser."
8 On the same page, the bottom line and the second 9
line from the bottom, " lower" should be " upper," and 10
" bottom" should be " top."
11 O
could you tell me how the sentence should read 12 as corrected?
r-13 A
It should then read, "The 10-inch dimensional 14 difference noted by the CAT was a simple error on the 15 inspector's part. She measured from the top of the slab to 16 the weld at the upper end of the riser."
17 MR. STEPTOE:
Bob, if I can interject, the 18 correction which Mr. Shevlin made to his own affidavit 19 substituting "21" for "20" also has to be carried over, as 20 I indicated in my letter last week, into Mr. Kostal's 21 affidavit at page 6, line 2, and I believe it also appears 22 in my statement of material facts on page 7, the sixth line O
8
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I from the bottom.
2 BY MR. GUILD:
3 Q
Are there any other corrections that are a part 4
of your testimony?
5 A
No.
6 Q
Mr. Shevlin, I want to show you a document that 7
has been marked for identification as Gieseker Deposition 8
Exhibit 1.
It is entitled, "Intervenors, Rorem, Et Al, 9
Notice of Depositions," dated 1/30/86.
It is directed to 10 you, among others, and I ask if you can identify that 11 document.
12 (Witness reviewing document.)
13 A
I have seen it.
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14 O
And what I would like to do is provide the 15 reporter of this Gieseker Exhibit and ask that it be marked 16 as the first exhibit to Mr. Shevlin's deposition.
17 (Shevlin Deposition Exhibit No. 1 la was marked for identification.)
19 BY MR. GUILD:
20 0
Mr. Shevlin, the second page of that notice asks 21 that you and the other deponents bring with you documents.
22 IIave you brought any documents responsive to O
V i
9 1
that request?
I 2
A The copies of the drawings which you were 3
furnished.
4 0
Are there any other documents that are responsive I
5 to the request that you bring with you, all documents in 6
your possession or subject to your control which are 7
the basis for your affidavit in support of the December 20 g
Motion for Summary Disposition?
9 A
In my affidavit I quoted Juran, the quality to handbook.
I have the handbook with me.
ii 0
Are there any other documents that are the basis l
l 12 for your testimony?
I believe your counsel before the 1
13 deposition identified additional documents that he has a l
l 14 copy of that are responsive to that request.
15 A
I used or referred to a number of papers that to are in the BCAP files, j
17 Q
All right.
What I would like you to do, Mr.
Is Shevlin, is to identify those documents for the record, and we may want'to copy them and have them made a part of 19 20 the record in this deposition; but if I could ask Mr.
I i
21 Steptoe to make available to you the stack of paper.
22 MR. STEPTOE:
Why don't you take a look at that l
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10 l ()
1 stack of papers and see whether you used any of those 2
documents.in preparing your affidavit.
3 (Witness reviewing documents.)
4 BY MR. GUILD:
5 Q
7 '11 tell you what, Mr. Shevlin.
Before you do o
that, let me get you to identify the drawing that you just 7
had reference to first.
If you could take the stack of l
8 paper that was made available first and tell me what those l.
1 9
are, please, if you would go page by page and identify 10 them.
11 (Witness reviewing documents.)
12 A
Identify these drawings.
13 0
Yes, please.
Sell me what they are.
S Id A
Okay.
The top page is a copy of Phillips-Getschow 15 construction piping drawing 1AAF8.
16 0
All right.
17 A
A copy of the Sargent & Lundy support drawing 18 1CS03029V.
19 A copy of a Westinghouse support drawing 1CSO4002S.
l 20 A later revision of the same drawing.
21 0
Can you identify the revision?
22 A
Revision D.
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1 0
To the Westinghouse drawing?
2 A
Yes.
The difference being that with Revision D 3
it has Sargent & Lundy's title clock on it.
4
-Q What was the revision of the first document you 5
identified, the first Westinghouse document?
6 A
Okay.
The same drawing, 1CSO4002S.
It's 7
Revision
- l, which has to do with engineering change notice 8
152471.
9 O
And is the Rev. D a later revision?
10 A
Rev. D is a later revision.
11 Another copy of the same support drawing with 12 a Westinghouse title block, Revision
- 2.
And the *2 13 relates to engineering change notice 16959.
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14 O
And is it, Rev.
- 2, before or after Rev. D?
15 A
Rev. D is the later.
16 Q.
All right.
17 A
Now, the next one is Westinghouse drawing 18 support ISXO6028R.
19 And the final drawing is a blowup of one portion 20 of the one I just mentioned.
21 MR. STEPTOE:
One portion of the what?
22 THE WITNESS:
Of the Westinghouse drawing I just I
N._ /
12 (D
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1 mentioned.
2 BY MR. GUILD:
3 Q
Okay.
4 A
It's just an enlargement of one corner of the 5
drawing.
6 MR. GUILD:
I would like to ask that the 7
reporter mark the drawings, to begin with, as the first 8
portion of Shevlin Group EFhibit 2, and we may add some 9
documents to that as we go forward.
10 (Shevlin Deposition Group Exhibit 11 No. 2 was marked for identification.)
12 BY MR. GUILD:
.<s 13 0
Mr. Shevlin, I interrupted you when you were
~
14 beginning to look through the stack of papers that Mr.
F 15 Steptoe made available to you.
16 (Witness reviewing documents.)
l'7 MR. STEPTOE: Bob, what I did in compiling the 18 stack was I just got all the reference documents that 19 were included in Commonwealth Edison's response to your 20 Interrogatories 58 and 59 with respect to Contention 12J.
21 Based on the previous conversations with Mr. Shevlin, I had 22 reason to believe that those vere the documents.
At least v
13 1
those included the documents that he had relied on other 2
than the ones he brought today.
3 I asked our paralegals to copy these documents, 4
and that's how we got this stack.
Now, the 'eralegals did 5
not find in our files three of those documents, and there-6 fore, Mr. Shevlin has not looked through those three 7
documents. They are listed on the front of the report, and 8
maybe Mr. Shevlin could look at them.
They are items 6, 7
9 and 8 in our reference list dated November 22, 1985, 13 which was included with our response to your Interrogatories 11 58 and 59.
He might be able to tell just by looking at the 12 brief caption whether or not he relied on those documents.
13 THE WITNESS:
I don't believe I did.
I don't
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14 recognize them.
15 BY MR. GUILDi 16 0
Mr. Shevlin, you have had an opportunity to 17 review the documents that Mr. Steptoe just described, and 18 can you tell me, of those documents, which were the basis 19 for your affidavit?
Can you go through the stack that you 20 have found, please?
21 A
This one.
22 Q
Can you tell me what it is?
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14 O
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1 A
It's a summation, pages E453 and 454.
2 A memo from Clinton to Byers, page E458.
An 3
attachment to that memo, page E459.
Another attachment, 4 to the same memo, page E460.
5 MR. STEPTOE:
Excuse me, Mr. Shevlin.
Is that 6
a two page attachment?
7 THE WITNESS:
Well, page E460 through E465.
8 An analysis sheet, pages E466 and 467.
9 A memo to Byers to Orlov, page E468.
10 A memo from Shevlin to Clinton, page E469 through 11 E473.
12 Summary sheets of the pipe support reverification.
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13 BY MR. GUILD:
hs)g 14 Q
Do those bear Bates stamp numbers, Mr. Shevlin?
j 15 A
I don't think they do.
16 Q
Well, how many documents are there, how many 17 pages?
18 A
Well, some of them do and some don't.
Oh, there 19 it is.
Okay.
One stamp is illegible.
It would appear that 20 it's probably 474.
21 Q
And the letter "E" to start?
Well, I will buy 22 that it's illegible.
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1 A
Sequentially it would be 474.
2 O
And the rest of them all have "E"?
You can make 3
out the "E" on the pages?
4 A
Yes.
I would say it's E474 through E482.
5 A stack of BCAP observations, page E483 through 6
E507.
7 An analysis of the new observations for the 8
reverification plan, E515 through E521.
9 Q
Let me stop you.
The BCAP observations, E413 10 through 507, are they the observations from the reverification 11 program?
12 A
I believe they are. At least some of them are.
13 Memo from Shevlin to Clinton, page E523 and E524.
14 to BCAP Memo 530, page E527 through 15 ES33.
16 BCAP Memo 593, which is page E536.
17 A memo from Shevlin to Clinton, page E537 through 18 E539.
19 A draft reverification plan, page E717 and 718 20 and 719.
21 Memo-from Shevlin to Clinton, page E722.
22 Memo from Shevlin to Clinton, page E723.
l
16
('h.
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1 Employee evaluation forms, page E724 through 2
729.
3 Memo from Shevlin to Clinton, page E730.
And a couple of statements or some figures 4
p from the Braidwood -- from the BCAP report, which the cover 6
is page 731.
7 Q
And you have the entire report there in front 8
of you?
9 A
Yes. I didn't use much of it.
10 Q
All right.
That report has been filed in the 11 proceeding and it's a little bit voluminous.
Let's leave 12 that out of the stack, and if in the course of your
,-q 13 deposition you need to make reference to a particular page,
(s) 14 if you could just identify that page; but other than that, 15 I would like to ask that the documents before you got to 1
16 the BCAP report be included within the Shevlin Group 17 Exhibit No.
2.
18 And if we could borrow your copy, Mr. Shevlin, 19 and make a copy of it.
20 MR. STEPTOE:
That's no problem, Mr. Guild.'
I 21 did notice that as the witness went through those documents, 22 in some cases he did not identify all of the documents that
, -.. _. _. ~. _
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I were stapled together, if you want to address that.
2 MR. GUILD:
Yes. I would like to only include 3
those that he has identified.
4 MR. STEPTOE:
Okay.
Shall we unstaple them?
)
5 MR. GUILD:
Yes, if that's okay.
I 6
MR. STEPTOE:
We would be glad to do that this 7
afternoon.
8 (Shevlin Deposition Group Exhibit 9
No. 2 additions were marked for 10 identification.)
11 BY MR. GUILD:
12 O
Mr. Shevlin, who prepared your testimony that 13 appears -- the 30 pages behind your affidavit?
14 A
I did.
15.
O Did you have any assistance in preparing that 16 testimony?
17 A
Editorial.
18 O
And by whom?
19 A
By one of my supervisors.
20 0
And who was that, please, that gentleman or r
21 lady?
22 A
Mr. Marquardt from PGCo to read it for editorial 4
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18 1
comment, language, English, spelling, punctuation, that 2
sort of thing.
3 Q
And who is Mr. Marquardt?
Do you have his full 4
name?
5 A
Gary Marquardt.
6 Q
Do you know how to spell his last name?
7 A
M-a-r-q-u-a-r-d-t.
8 Q
And what is Mr. Marquardt's position?
9 A
I don't know his position title.
His position 10 is a lead over a small group of quality consultants.
11 Q
And you are among that group?
12 A
Correct.
/
'N 13 0
Is he employed by.Phillips-Getschow?
I,)
14 A
Correct.
15 0
All right.
16 Did anyone else assist you in your testimony?
I'7 A
No.
18 0
How about your counsel?
Did you work with any 19 of the lawyers in preparing your testimony?
20 A
They furnished the questions; I furnished the 21 answers.
22 Q
Did they participate in the editing process?
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1 A
Possibly for editorial.
s 2
Q And who was that, by name?
3 A
Phil Steptoe.
4 O
All right, Mr. Shevlin. Can you go through your-5 testimony, please, and identify any changes that you made 6
after the draft answers that you prepared to the questions 7
that were submitted to you by your counsel?
8 A
I don't think I understand.
9 Q
Can you identify any changes that were made to 10 your testimony?
11 A
In substance?
12 Q
Any changes at all, sir.
<- x 13-A I don't really understand what you are trying to
~"
14 get at.
15 0
Is this testimony that has been filed, Mr.
16 Shevlin, identical to the testimony that you prepared?
17 A
Except for grammar, punctuation, spelling and 18 the changes that we discussed earlier.
19 Q
Can you identify any of those changes, any 20 changes at all that have been made to your testimony in 21 the drafting and editing process?
22 A
I doubt it.
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20
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Q Take a moment and review the testimony, and if 2
you can identify any, I would appreciate it, please.
3 (Witness reviewing document.)
4 A
Some asked me to explain --
5 0
Where are you at, Mr. Shevlin?
6 A
The top of page 12.
Someone asked me to explain 7
what I meant by the term " takeout."
I remember that.
8 Q
All right.
9 And you prepared Exhibit A in response to that to question?
11 A
Right.
And the handwritten sketches, the hand-12 prepared sketches shown as exhibits, I was asked to prepare 13 those as a visual aid.
7,,
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14 Q
And you prepared those?
15 A
I prepared those, 16 Q
Those are Exhibits B through --
I'7 A
I think A through E.
No, A through D.
18 Q
All right.
19 Any other changes?
20 A
I think that's all.
At least that is all I 21 recognize.
22 Q
Okay.
J
21
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(,,f I
Who-prepared your attachment -- it doesn't 2.
appear to have an identification.
It follows Attachment D, 3
and it has the Bates number of E521.
d A
That is part of the BCAP files.
5 0
Who prepared -that; do you know?
6 A
No, I don't remember.
7 0
What is it?
Can you identify it, please?
8 A
It's a summary of the findings of the support 9
verification program that we did about a year ago.
10 Q
And Exhibit E, can you tell me who prepared 11 that?
12 A
I prepared that.
It was recovered from the BCAP 13 file.
It's my analysis of the findings that occurred during j, -
')
14 the support reverification program.
15 0
All right.
And those are your comments that 16 appear in the right-hand column?
17 A
That's correct.
18 Q
Mr. Shevlin, I am referring to the-documents 19 that you reviewed that your counsel made available to you, 20 and I would like you, if you can, to help me identify some 21 of these, please.
22 Who prepared the document that you described as
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22
(-)
(,,
1 Summation, E453 and 454?
2 A
I don't know.
It would have been someone in the 3-CSR Assistant Director's Office, probably.
4 Q
And who is the CSR Assistant Director?
5 A
Mr. Byers.
6 Q
Is that Bob Byers?
7 A
Yes.
8 0
How was it made available to you?
9 A
It is part of the BCAP file.
10 0
Who is Mr.
M.A.
clinton?
11 A
He was my immediate supervisor during the BCAP.
12 O
And what was Mr. Clinton's position?
s 13 A
His BCAP title was inspection supervisor, and he rU 14 is a contract employee with Daniel International Corporation.
15 Q
Is he currently employed at the Braidwood site?
16 A
He is currently employed as the Director of 17 Quality Services, Daniel International Corporation, 18 Greenville, South' Carolina.
19 Q
Is he still at the Braidwood site?
20 A
No, he is not.
21 Q
He is in Greenville?
22 A
Greenville.
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23 1
Q The memorandum, Clinton to Byers, January 22, 1985, 2
BCAP memo 530, with attachments E458 and following, was 3
that prepared by Mr.'Clinton?
4 A
It is signed by Mr. Clinton.
5 Q
Do you know whether he prepared it or not?
6 A
It is just an internal office memo advising 7
Byers what we were doing at the moment.
8 O
Did you have occasion to prepare memos for Mr.
9 Cinton?
10 A
For his signature?
11 Q
Yes.
12 A
No.
13 Q
So as far as you know, he prepared it himself?
14 A
Yes.
15 0
All right.
That appears to be workpapers, one 16 entitled " Piping Support Reverification Plan, Analysis of I'7 New Observations by Attribute versus Population," pag' 18 E466 and 467.
Do you know who prepared that document ~r 19 A
It was prepared by people working under my 20 control.
21 0
Can you identify who those people are, please?
22 A
I can't tell you for sure who prepared that one.
4 24 j
1 Q
Well, who worked under your control onthis x
2 task, or on the task of the analysis of the reverification 3
observations?
d A
David R. Walker.
5 Q
Who is Mr. Walker?
6 A
Walker is a certified lead quality inspector 7
who works for Daniel.
8 Q
A BCAP inspector?
9 A
He was a BCAP man.
10 0
Who else?
11 A
Howard M.
Sigrest.
12 Q
How do you spell it?
13 A
S-i-g-r-e-s-t.
V,
\\'
3d Q
All right.
And who is Mr. Sigrest?
15 A
Certified lead quality inspector sdda Daniel 16 working for BCAP.
17 Q
Were either of these gentlemen BCAP inspectors 18 who were performing the inspection work that was the subject 19 of the reverification?
20 A
They were performing special duties during that 21 reverification.
They didn't actually do any of the 22 reverifications.
O V
I
,__.--m
25 Did they do any of the initial BCAP inspections 1
Q 2
that were the subject of the reverification?
3 A
Probably.
4 Q
They are among the BCAP inspectors who were under 5
your supervision?
6 A
Correct.
Walker probably did.
Sigrest may 7
have.
8 Q
Okay.
They were BCAP inspectors in the mechanical 9
area, mechanical welding area?
10 A
Correct.
11 Toward the end of the end of the plan, I used 12 some of those guys to help just tabulate the information on 13 those spread sheets and things.
14 0
All right.
15 I am looking at a stack of papers that begins 16 with E483.
It's a BCAP observation record, Mr. Shevlin.
17 MR. STEPTOE:
Could you read that number again?
18 Excuse me.
19 MR. GUILD:
Sure.
It's E483 and following 20 pages through 507.
21 BY MR. GUILD:
22 O
Can you identify some of the names on this, please, for me, Mr. Shevlin?
It's difficult to read, but under
,- ~
' s_/
26
.(
\\,
-)
1 Block ll, Prepared By?
2 A
That is Frances Irene Starr, Frances with an 3
a e,a 4
0 Who is Ms. Starr?
5 A
BCAP inspector.
6 Q
In the mechanical welding area?
7 A
Correct.
8 Do you want them all?
9 Q
No, sir.
Let me just have that back.
Some I 10 can make out and some I can't.
11 Mr. Sigrest on the bottom, is that his name?
12 A
That's correct.
13 is Q
And that is your signature, Mr. Shevlin?
(d' 14 A
That's correct.
15 O
E486 in Block 11, Prepared by?
16 A
Gary J.
Sutton, a BCAP inspector.
17 Q
Also a mechanical welding inspector?
Is A
All of them are in mechanical welding.
19 O
And there is a line on that same page, E486, 20 that says "I concur" with initials, j
21 A
Sutton.
22 O
E494 in the Block 11, Prepared by?
i
!O r
_ ~. _
1
?7
'-s 1
A~
Thomas R. Young, a BCAP inspector.
2 Q
E495, Block ll?
3 A
Frances I~Starr, BCAP inspector.
4 Q
E500, Elock 11, please?
l 5
A Phil S. Jones, BCAP inspector.
6 Q
Document numbered E715 and 16 appears to be from 7
Mr. Clinton to -- I can't make it out.
8 A
I did not use that.
9 Q
Is that Mr. Clinton's handwriting?
Can you to identify that?
11 A
Yes.
12 Q
E717 and 18, titled " Reverification Plan."
Whose.
j'"x 13 handwriting is that?
Iq~~' )
14 A
I wrote that.
IS Q
And 719.
Is that your handwriting?
16 A
- yes, 4
17 0
720?
i 18 A
It's not mine.
19 Q
Is that Mr. Clinton's, if you know?
20 A
I don't think I can say for sure.
21 Q
Mr. Shevlin, have you had occasion to review 22 the affidavits by Mr. Smith and Mr. Kaushal that were filed 4
h a
O
..._.n.
.,. _ =
l 28
.s 1
in support of the Company's Motion for Summary Disposition 2
along with your own?
3 A
Yes, I have.
4
.Q Mr. Smith in his affidavit page 18 refers to 5
a performance evaluation program employed for use with the 6
reinspectors, the BCAP QA overview inspectors.
Are you 7
aware of that evaluation program?
8 A
No.
9 0
Was there an evaluation program for the BCAP 10 inspectors that you supervised?
11 A
Yes, there was.
That's pretty well described in 12 my affidavit.
r 's 13 0
All right.
14 And documents that you identified earlier,-E724 15 through E729, are they the product of the evaluation 16 program for your inspectors?
17 A
They are a partial product of it.
2 18 0
What else is there that is a product of that 19 evaluation program?
20 A
Certification examination.
21 Q
Was there an industrial psychologist involved 22 in the design or implementation of the evaluation program a
\\~)
4
[
. - ~., - - -
29
)
i for your inspectors?
2 A
I don't know.
3 Q
Mr. Smith describes an involvement of an 4
industrial psychologist in the design of what he identifies 5
as the performance evaluation program that was employed for 6
the BCAP QA inspectors.
7 Do you know whether there was any comparable 8
program for the BCAP inspectors that you supervised?
9 A
Not to my knowledge.
10 0
More particularly, Mr. Smith describes a program it in which an industrial psychologist was involved, which he 12 describes as initiated to determine the extent to which an
- 3 overinspector would agree or disagree with the initial 14 inspection results of the original inspector. Again, that's is page 18 of Mr. Smith's affidavit.
16 Was there any comparable program that you are aware 17 of for your inspectors,ter the BCAP inspectors that you is supervised?
19 A
No.
20 0
Looking at E724, the employee evaluation for one 21 of your inspectors -- this is one of your inspector 9, is it 22 not?
i
30 n
1 A
Correct.
h 2
Q Under the " Remarks" section, the notation of a 3
component identification, one or more component identifica-4 tions.
What is the significance of the notation in the 5
" Remarks" section?
6 A
It's a number of component support inspections 7
that this individual performed, and then at my direction a i
8 lead quality inspector went out and reinspected them.
9 Q
Why was that?
10 A
In this particular case because a question had 11 come up about some of this person's work during the CAT.
12 Q
A question by whom?
irw 13 A
The CAT inspector.
k_
Id Q
By an NRC CAT inspector?
15 A
Correct.
16 0
With respect to those specific components?
17 A
No.
is Q
What is the significance of the identification 19 of those specific components?
20 A
They are randomly selected pieces of work that 21 the individual did.
22 O
Is that a part of the reverification program?
O
I 31
,/ -
(/
1 A
No.
They are part of a follow-up action that 2
is described in my affidavit.
3 Q
After the reverification program?
4 A
That particular item has nothing to do with the 5
support reverification program.
6 0
All right.
7 Well, a follow-up to what, then, Mr. Shevlin?
8 A
It's a follow-up -- that particular individual 9
is one that was involved in the CAT finding on the piping 10 configuration.
After I was satisfied with the resolution 11 of the piping configuration, I directed two lead inspectors 12 to separately and independently go out and look at some more 13 of this person's work.
14 O
All right.
And instead of in the piping configu-15 ration area, you looked in the component support area.
16 A
Specifically, configuration, which is the same 17 ID.
18 Q
But configuration of supports instead of piping?
19 A
Configuration of whatever the inspector happened l
20 to be looking at.
21 Q
By the inspector, you mean the subject of the 22 review by the lead?
O
32
'w -)
-r 1
A No, by what the inspector was working on.
2 Q
The original inspector?
3 A
Correct.
The original inspector would be 4
assigned a piece of work and then randomly the lead 5
inspectors would pick up some of that work and go back out 6
and look at it, overinspect.
7 O
And you directed the lead to do that?
8 A
Correct.
They were designees or delegated.
9 Q
And did you direct the leads to look at a specific 10 type of work?
11 A
Specifically, to go after that inspector's work 12 on configurations, which would include dimensional verifi-13 cations, location orientations and such as that.
r"'s 14 Q
Did you ask him to look at configuration other 15 than piping configurations for that inspector?
16 A
I asked them to look at several of the next 17 pieces of work that that employee had completed.
As it 18 happened, as it turned out, the next several pieces of work 19 happened to be piping supports rather than piping.
20 Q
You didn't specify the type of work, though, just 21 the next work that he did?
22 A
The next work.
I specified the type of informa-tion or the type attribute or the type of operation.
33
( )
1 Q
And that was configuration?
2 A
Configurations, dimensions.
3 O
And were there any adverse findings by the lead's 4
overinspection?
5 A
No.
6 Q
There appeared to be six separate employee 7
evalutions, five other than the ones we have just 8
spoken of, and were each of those inspectors subject to an 9
overinspection by a lead at your direction?
10 MR. STEPTOE:
Objection.
May I see that for a 11 moment, Bob?
12 (Discussion off the record.)
13 MR. STEPTOE:
On the record.
p_.
(x /
14 Mr. Guild, my problem is that on those forms, 15 some inspectors are listed more than once, and I'm afraid 16 that your question implies that there were six inspectors 17 that were overinspected.
18 MR. GUILD:
Oh, I didn't mean to misstate it.
19 I stand corrected.
20 BY MR. GUILD:
21 Q
Let me see if I can clarify.
Maybe you can help 22 me clarify it, Mr. Shevlin.
There are six evaluation forms,
,. m
34 (D
's /
1 and it appears that they do cover several forms-for the 2
same individual.
I see an inspector P.J.T.
You use the 3
initials to identify these inspectors in your testimony, do 4
you not?
Are the initials that appear in your testimony --
5 A
In my testimony?
I don't remember using any 6
initials.
7 Q
Well, perhaps it was Mr. Smith's, but there are 8
references to inspectors.
I am just trying to use the same 9
form of reference that was employed. If it wasn't in yours, 10 it was in one of the other affidavits.
11 This is an inspector, Pam J. Thompson, and 12 that's the inspector who is the subject of the overview by 13 the lead at your direction.
14 A
Correct.
15 0
And for that inspector, which appears on E724, 16 there is -- and E727, another employee evaluation listing 17 the same inspector.
18 Why is there more than one?
19 A
I asked that an effort be made that more'than one 20 lead inspector do it.
I think you will find that the lead 21 inspector doing.the overinspection is not the same person 22 in each case.
t 35 O
k_)
1 Q
All right.
And 724 appears to be Mr.
is it 2
Norris?
3 A
Right.
4 4
Q And 727 is Mr. Norris again.
5 A
Okay.
4 6
Q Are those two separate overinspections?
7 A
Yes.
8 Q
By the same lead, though.
9 A
Yes.
I had two guys doing that.
10 0
The second document, E725, is Mr. Jones, the 11 inspector, and the evaluator is Mr. Sigrest?
12 A
Yes.
f'~*-
13 MR. STEPTOE:
It's Mrs. Jones.
(Q' /
14 MR. GUILD:
Mrs. Jones.
15 Phil S. Jones?
16 MR. STEPTOE:
Oh, I'm sorry.
I have confused 17 this whole thing. I'm sorry.
18 BY MR. GUILD:
19 Q
Phil Jones, by Mr. Sigrest, and then the 726 is 20 Phil Jones by Mr. Norris; yes?
21 A
Yes.
22 Q
728, Phil Jones by Mr. Sigrest.
i
-_+y.-
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,._,.-,,,_._...y..
,,______.-,__--_-__--.___-.___s_,
4 36 f~s l
I i
%_/
1 A
Right.
2 0
729, Phil Jones by Mr. Norris.
J 3
A Right.
4 BY MR. GUILD:
5 Q
Mr. Shevlin, the series of documents that begin 6
with E483 and the following documents, they appear to be 7
BCAP observation records, and I believe you stated that 8
some of these were records of the observations resulting from 9
the reverification program?
10 A
I believe so.
l 11 Q
Now, there appear -- the documents are headed 12 "BCAP Observation Record," page'1 of 3, and suggest that 13 rx there are additional pages to the BCAP observation record 14 form?
Is that correct?
2 and 3?
15 A
Well, partially correct.
The page numbering 16 system is part of a format.
Page 1 was always prepared 17 by the inspection group.
Pages 2 and 3 were never prepared is by the inspection group.
They were subsequent actions.
19 Q
All right.
20 E483 is page 1 of 3, as is 484, 495, 486, 487, L
21 489, 490, 491, 492; 493 happens to be page 2 of 3, and that 22 bears the title at the top that says, " Evaluation and O
r
7 37 1
Determination of Validity."
2
.By-whom is that portion of the observation 3
record prepared?
4 A
That portion was prepared by the Engineering 5
Department.
6 0
Whose Engineering Department?
7 A
BECAP's?
r 8
Q There appear a series of initials on this page 9
E493, page 2 of 3 of the BCAP o'bservation record.
Do you 10 know who that is?
It appears to be initials "BWG."
lb A
I don't remember. It's.not anyone from the 12 inspection group.
13 Q
All right.
(s_sJ 14 Who are the engineering people that perform the 15 evaluation and determination of validity, the BCAP observa-16 tions?
17 A
I don't think I understand?-
18 Q
Well, who are they employed by?-
- 19 A
Primarily they were employed by Stone & Webster.
20 0
Were there any Sargent & Lundy people performing 21 evaluations and determinations of validity?-
9 22 A
I don't know.
4 d
O
38 im()
1 Q
You are not aware of any?
2 A
Not in the areas that I dealt with, I don't 3
remember any.
4 Q
Was Stone & Webster under contract to Edison to 5
perform the engineering evaluations of validity for BCAP
-o observations?
7 A
Yes, they were part of the BCAP organization.
8-Q How many Stone & Webster people were doing that 9
Work?
10 A
I don't know.
A' fairly large number.
11 Q
More than ten?
12 A
Yes.
13 Q
How about in the welding and mechanical area?
. (O
'\\_ /
14 A
Our engineers were primarily Stone & Webster.
15 0
Yes.
And how many Stone & Webster people in the 16 welding and mechanical area that performed the evaluations 17 and determinations of validity?
18 A
I don't know.
19 Q
Do you have an estimate?
More than ten?
20 A
Yes.
Way more ten.
21 Q
More than 100?
22 A
No.
4
.- f;i s_
39 Ci
(_s/
1 Q
Somewhere between 10 and 100?
2 A
Yes.
It was a fairly large number.
There were 3
a number of groups, sub-organizations.
4 Q
And all of them did evaluations, BECAP observations 5
for validity?
-6 A
Within their own area of interest.
7 Q
All right.
8 This is not a real good copy, Mr. Shevlin, but 9
this page 2 of 3, that is, E493, appears to accompany page 10 1 that precedes it, and it appears to be observation No.
11 CSR-1-M-3, and the rest is blocked out, but there is a 12 package number under it which appears to be 008. Would that
<~g 13 be the BCAP observation number?
'.)
~'
14 A
The package number is the BCAP package, which is 15 traceable to a discrete item.
That number is also the-root i
16 of the BCAP observation number.
17 Q
Can you tell what the observation number is in the 18 document that I am showing you?
That is E492.
19
~
A Not from that copy.
20 0
Are there more digits than there are in the package 21 number?
22 A
It is the 97eh a number, suffixed by another number, 1, 2,
3 sew m {
- ly.
~ (D v
,, ~.. -....
40 t'
\\
1 0
The page 2 for that observation reflects a 2
determination that that's a valid observation, and then 3
below that appear to be the initials "BWG."
Would that be d
the person who made the evaluation?
5 A
Yes.
6 Q
And you don't know who that is, by name?
7 A
Not by those initials.
8 O
Will you describe the process of determining 9
the validity of a BCAP observation?
10 A
It was a number of steps.
When the inspector 11 prepared the observation, either myself or one of my desig-12 nated lead inspectors reviewed it to determine its 13 suitability for further processing.
If it was determined s -)
14 suitable, it would go to the engineering group.
They would 15 review it for validity, validity meaning that the 16 observation described was, in fact, a violation or a failure 17 to comply with the inspection instructions given to the 18 inspector.
19 And item could be deemed invalid by the engineering 20 group coming up with additional information.
For example, 21 if the instructions said everything shall be painted green 22 and we found something painted red, we would prepare an O
O w
,,---,--.---,-----,.---a.-
g-
.-,e
41
('*h
(,)
1 observation.
The engineer, then, might say, ah, but here 2
is something that came out that the architect engineer 3
issued or something that changed that requirement, and therefore, what you found is acceptable, your observation 4
5 is not valid.
6 If they determine that our observation is not 7
valid, it had to be returned to us for our concurrence.
8 0
Whose concurrence, Mr. Shevlin?
9 A
Inspection.
Generally the original inspector.
10 If he was not available, then it was my responsibility.
11 0
Did the BCAP procedure specify that the original 12 inspector concur or have an opportunity for concurrence in 13 validation of an observation?
/-
'ss>
14 A
If it was valid.
15 Q
And did the procedure specify that in the 16 absence of his availability, that would be your task?
17 A
His immediate supervisor.
Yes, that was clearly is defined in the procedures.
19 0
How do you use the term " suitability" that you 20 employ when you describe your review of the observation that 21 was written by your inspector?
22 A
My general approach there was an outright
-comparison of the requirement against the finding to assure O
42 1
that the inspector was not reporting something that did, in 2
fact, meet the criteria he was given up front.
So, unlike 3
the engineering evaluation, my evaluation was straightfor-4 ward.
Yes, what is written here does violate these 5
instructions.
6 0
Well, in your example about the green and red 7
paint --
8 A
I would have made that observation suitable 9
because the instruction in my had says everything has got 10 to be green. I did not pursue it any further to see if 11 there was some other document that made it all okay.
That 12 wasn't my business.
13 Q
Even if you knew that there was another document?
4 14 A
It didn't make any difference.
It wasn't 15 part of my inspection package.
I would have made it 16 suitable.
I'7 0
Well, how is the judgment that there was some 18 further direction that said that, yes, a color was 19 acceptable -- gremi or red, or red or green, whichever was 20 the case in your example -- how was that an engineering 21 evaluation?
22 A
They were responsible to assure that what we wrote up was, in fact, a deficient item. They were responsible to go research all of the deficiency documents
43
,O
\\s /
1 or design changes or what have you'that might make that 2
item unique instead of part of the general population.
3 Q
Well, in your example, shouldn't any change 4
in the specifications, such as an instruction by Sargent &
5 Lundy that a green was acceptable or red was acceptable,.
6 shouldn't that have been included in the package that was
~7 used by your inspector?
8 A
If it was known up front, it would have been.
9 Q
Known up front by whom?
10 A
By the engineer who prepared the package.
11 Q
Shouldn't that engineer have made sure that the 112 BCAP inspection was to a current revision of the drawing or es -
13 specification?
%"'/
3d A
No.
It was to the revision at x date.
Subsequent 15 developments might have changed the requirement for that as 16 a discrete item as opposed to the rest of the population.
17 Q
Well, let's be clear, then. BCAP'was inspecting 18 to requirements as of a particular date?
19 A
The physical inspection, yes.
20 Q
As opposed to current specifications.
21 A
That was a subsequent step.
22 Q
And that subsequent step, determining whether-a n-s.
44
/'N.
- (,)
I I
failure to meet historic acceptance criteria was, nonethe-2 less, acceptable given subsequent revisions to those 3
acceptance criteria, that was made by the engineering d
evaluation of validity?
5 A
Correct.
6 MR. STEPTOE:
Objection.
I'm sorry.
I couldn't 7
follow the question.
8 MR. GUILD:
I think the witness followed it.
9 BY MR. GUILD 10 Q
Is that an accurate statement?
11 MR. STEPTOE:
Well, I couldn't follow it.
12 Would you read back the question, please?
13 (The reporter read the record as requested.)
,-s
's j Id MR. GUILD:
Mr. Steptoe, do you have an 15 objection?
16 MR. STEPTOE:
No.
17 BY MR. GUILD:
18 Q
You heard the question the first time and it was 19 reread, and your answer is still yes, that was correct?
20 A
Yes.
21 Q
Did the BCAP procedure, Mr.Shevlin, specify your 22 role in making suitability determination?
v
45
. (\\
\\,/
1 A
Yes.
2 Q
Did it use that term, " suitability"?
3 A
Yes.
4 Q
Did it define the term?
5 A
I don't remember.
6 Q
Can you give me a reference?
Do you recall the 7
procedure citation describing your role in making a suita-8 bility review?
It will not be held against you if you cannot 9
recite chapter and verse, Mr. Shevlin.
10 A
It could have been either of a number of 11 procedures.
There was a procedure that dealt exclusively 12 with processing observations.
There was a procedure that 13 dealt with performance of inspections. It may have turned up k-\\'
14 in either of those. I don't remember.which.
l 15 Q
How about the procedure as it detailed the i
16 Concurrence of the original inspector in the validity 17 determination by the engineering people?
18 MR. STEPTOE:
Objection.
Is your question can 19 he identify that procedure?
20 BY MR. GUILD:
21 Q
Sure.
Yes.
Can you do that?
22 A
I think it is in the observation procedure.
\\_
y y
,.-r
-__.----m
.7._,.
-.,g-_..-
46
,a(,)
1 Q
What is the practice if the original inspector 2
declines to concur in the invalidation determination?
3 A
That was provided for procedurally.
4 Q
In the observation processing procedure?
5 A
I don't remember.
I am not prepared with this 6
much time elapsed to state what provision was in what 7
procedure.
It has been too long.
8 O
All right, sir.
9 A
I do know that it was in the procedure manual.
io O
All right.
And what did the procedure manual specify in the event that the original inspector declined to 11 12 concur in the invalidation?
13 MR. STEPTOE: I will impose a general relevance l(A~ /
14 objection.
I'm not instructing the witness not to answer, 15 but I think this is far afield from the contention without 4
to some sort of foundation that that occurred in this case.
I:7 BY MR. GUILD:
18 Q
Can you try to answer the question?
19 A
Would you repeat it, please?
20 0
Sure.
~
21 What did the procedure call for in the event the 22 original inspector declined to concur in the invalidation of i'
/
l 47
\\_e)
'I his observation?
2 A
Some series of tiered evaluations, with the-3 ultirate decision by the director, I think.
4 Q
And the director of BCAP, Mr. Kaushal?
5 A
Yes.
I believe that's what it said.
6 Q
And the procedure also provided the same process 7
in the event your inspector was unavailable and it was you 8
that declined to concur?
9 MR. STEPTOE:
Objection.
Lack of foundation.
10 THE WITNESS:
We are getting too far into the 11 specific procedure requirements, which I have not looked at 12 in quite some time.
13 C"-
BY MR. GUILD:
Id Q
Okay.
Just tell me that if you do'n't recall.
15 A
I'm not able to-quote what is in the BCAP 16 procedures at this time.
17 O
All right.
18 Did you ever decline to concur in an invalidation 19 determination?
20 MR. STEPTOE: Continuing objection to re)_vance and 21 lack of foundation.
22 THE WITNESS: I don't remember.
O
48 O(,,)
1 BY MR. GUILD:
2 Q
Did any of your inspectors ever decline to 3
concur in an invalidation determination?
d A
Not that I recall.
5
-MR.
STEPTOE: Was your question directed -- I
'6 didn't mean to interrupt the witness' answer.
7 Was your question directed to an observation and 8
validation made in connection with the reverification of 9
pipe supports and restraints which are the subject of the 10 witness' affidavit?
Il MR. GUILD:
It was a general question.
12 BY MR. GUILD:
I3 g-O And the answer was you don't recall?
Id A
I don't remember it happening.
15 0
Would you have known about such an action if it 16 had occurred?
17 A
Yes.
18 Q
Do you know whether it ever occurred, whether a 19 BCAP inspector ever declined to concur in an invalidation 20 datermination?
21 MR. STEPTOE:
Objection.
At this point we are 22 really going far afield, not only from the contention but V
49
/m
' k,)
I from the agreement that you had with Mr. Gallo that you 2
would limit your questioning to the subject of the 3
witness' affidavit.
This witness did not come prepared to 4
talk about BCAP program in general, nor did I come prepared 5
to represent him in the deposition in which things like this 6
would be gone into.
7 MR. GUILD:
All he has to do is answer yes or no 8
if he does or doesn't, and I would like an answer to the 9
question.
10 MR. STEPTOE: So is your representation that you will move on after that and not go on?
11 12 MR. GUILD:
I don't know what the answer is, Mr.
7-13 Steptoe, but I believe that the matter is obviously relevant.
k'~g) 14 It is relevant to just not this contention; it is relevant 15 to the quality assurance contention generally. I am to entitled to ask the question, and I would~like the answer 17 of the witness.
18 MR. STEPTOE:
Mr. Guild, do you deny that you had 19 an agreement with Mr. Gallo?
20 MR. GUILD: I don't want to get into a fight with 21 you about.it.
My time is valuable.
I intend to press on 22 and get the deposition done as quickly as possible. But my
50
)
1 notice of deposition asked the witness to be prepared to 2
respond generally on the subject of quality assurance at 3
Braidwood.
The obvious focus of the examination is on the 4
subject of his affidavit, but I don't waive any right to 5
ask what is an obviously relevant question.
6 If you want to instruct your witness not to 7
answer the question, I would be more than happy to take it i
8 to the Chairman and get it resolved. I just think that if you intend to interpose objections on what are obviously 9
10 unsupportable, narrow grounds of relevance, then perhaps the 11 most efficient thing to do is to get a Board decision on 12 the question.
13 I think you will find, Mr. Steptoe, that the 14 practice in these depositions has been to recognize that 15 the rules of the Commission permit discovery deposition 16 questions that are Calculated to lead to the identification l'7 of relevant evidence, and I represent to you that the last 18 question certainly was designed to do that.
19 MR. STEPTOE:
I have no difficulty about 20 discovery which is intended to elicit information relevant 21 to the quality assurance contention; however, I asked you 22 a question, whether you deny that you had an agreement with 6
Mr. Gallo that the questioning in these depositions would be limited to the subject matter of the deponent's affidavit.
51
/'(
1 MR. GUILD:
And I am not going to be cross 2
examined by you, Mr. Steptoe.
3 MR. STEPTOE: Do you refuse to admit or deny that 4
you had such an agreement?
5 MR. GUILD:
I am not going to be cross-examined 6
by you, sir, on that subject or anything else. Mr. Gallo's 7
agreement with me about the circumstances of conducting these 8
j depositions will speak for itself.
The notice of depositions 9
j speaks for itself.
I am not going to fight with you about 10 it.
11 Now, if you think that your position is such i
12 that you want to instruct your witness not to answer the 13 question, please do so and let's move on, but I don't want 7g x--)
'~
id to get into any kind of acrimony with you, Mr. Steptoe, on 15 that subject.
Please don't bait me, please don't cross-16 examine me on this point.
17 If you think that the question is improper and 18 feel comfortable instructing your witness not to a nswer, 19 plese do, and let's just move on.
20 MR. STEPTOE:
Let me just state for the record 21 that my understanding from Mr. Gallo was that he had an 22 agreement with you that these depositions would be limited to i
- O i
.,,em-,
--n--
---~ --,+ ~ -
~w
52 O
i,)
I the subject matter of the witness' affidavit.
Now, I 2
have not interposed an objection to questions that seemed 3
to me to be within the parameters of that subject matter, and indeed, we have gone beyond that, but there has been 4
5 no showing of a foundation that this question, the pending 6
question, is directed towards either the affidavit or 7
Contention 12J, and I did not prepare myself or prepare the witness to go through open-ended discovery in this case about the
'8 9
results of the BCAP report.
10 I am aware that the Notice of Deposition did 11 state that the deposition shall be on the subject of the 12 witness' knowledge of the quality assurance deficiencies 13 at the Braidwood Nuclear Power Station alleged in Intervenors'
\\--
14 amended quality assurance contention.
However, I subse-15 quently spoke with Mr. Gallo, who told me specifically that to you had an agreement and understanding.
On that basis, on the basis of an understanding which you, for reasons which l'7 18 are beyond me, refuse to discuss, I am going to instruct 19 this witness not to -- I am going to advise this witness that 20 he is not required to answer your question.
21 I am delighted to take this up in front of the 22 Board, and then you can tell the Board what your understanding i
O
53 of your agreement with Mr. Gallo is.
And I find --
1 2
MR. GUILD:
Mr. Steptoe, if you would just tone 3
down the voice.
There is no need to raise your voice to me.
If you would just ask me what your agreement was, I would be 4
5 happy to tell you, but I am not going to be cross-examined 6
by you, sir. I am not going to be treated like I am obligated to respond to what is just a tactless and arrogant 7
8 approach to trying to resolve a matter in dispute.
9 There is no need to fight about this. Now, if 10 you would like to know what the nature of the agreement is, I will be happy to tell you, but I'm not going to be 11 12 cross-examined by you, sir, or anybody else.
13 MR. STEPTOE:
Well, I certainly was not trying --
14 MR. GUILD:
Now, do you want to instruct your witness not to answer the question and trouble the Chairman 15 16 with resolving this dispute, or do you want to be civil about 17 it?
If you would like to be civil about it, I wi)1 be happy 18 to try, but you are trying to be provocative and there is 19 no need for it.
20 MR. STEPTOE:
I don't think I'm trying to bait you.
21 I don't think I'm trying to be provocative.
I don't think 22 I am being uncivil.
I don't think I have been raising my r~S l
4
54
()
1 voice unduly, certainly no more than you.
2 MR. GUILD:
Only in response to you, sir.
3
. Now, do you want to know what -the agreement is?
4 Do you want to get down to that. or do you want to haggle, 5
for purposes that are unclear to me?
6 MR. STEPTOE:
I do want to know what the agreement 7
is, and you are refusing to answer.
8 MR. GUILD:
No, sir.
You didn't ask me.
If you 9
would just ask me, I would tell you.
But I am not going to 10 be cross-examined by you and I'm not going to be compelled 11 to respond to questions with yes or no answers.
I'm not 12 under oath and I'm not testifying here, sir.
13 Mr. Gallo, who is well known for transgressing 14 agreements in this proceeding, is hardly in a position to 15 be dictating terms to me on'this subject.
16 MS. CHAN:
Mr. Guild, perhaps you can just --
17 MR. GUILD:
The fact of the matter -- excuse me, 18 Ms. Chan.
The fact of the matter is Joe Gallo asked me: How 19 much do I have to prepare for these depositions, Bob; do I 20 have to be prepared to answer -- to have my witnesses 21 respond to general discovery on the quality assurance 22 contention?
I said: Joe, I have got a Tuesday, February 18th O
55
,m deadline to respond to your motions for summary disposition; x-1 2
as much as I would like to ask the bulk of my discovery 3
questions of the witnesses between now and then, I simply do 4
not have the time to do that, and I can assure you that I 5
am going to do the best I can to focus on the subjects 6
which are the summary disposition questions.
I told him just 7
that, or words to that effect.
8 I signed nothing in blood, and my notice speaks 9
for itself.
All right?
10 Now, if that is troubling to you, sir, and you 11 don't wish to have your witness respond to questions, l
12 including the pending one, please tell him not to answer the
. ~s question and we will go to the Board with that.
/
13
-]
14 I tried to accommodate your colleague in the 15 face of a notice that you have in front of you, sir, by 16 trying to give him some informal representation about what 17 the scope of my examination would be.
I entered no agree-18 ment with Mr. Gallo, and it, frankly, sticks in my craw that 19 someone from Isham, Lincoln & Beale would have the gall to 20 try to suggest to me that honoring agreements is a matter of 21 question on my part, a firm that I represent to you has not 22 demonstrated a.particularly sound track record of honoring G
i 56 l
(O) 1 agreements in this proceeding with this counsel.
2 Now, I hope, Mr. Steptoe, that you don't intend 3
to enter on to the tradition that your colleagues have established in this proceeding in that regard, but the fact 4
5 of the matter is the notice speaks for itself. I told you 6
what I represented to Mr. Gallo, and I represent the same j
7 thing to you, sir.
I don't believe the question I last i
asked him in any respect transgresses any understanding, a
9 agreement or representation I have with your colleague, Mr.
10 Gallo.
11 Any further questions?
12 MR. STEPTOE:
Ms. Chan, did you have something l
13 to say?
gO) l a
t
%s /
14 MS. CHAN:
I was just going to suggest that the is notice of deposition says that the inquiry will be into the 16 information which serves as the basis for the witness' 17 affidavit in support of Applicant's December 21, 1985 Motion for Summary Disposition, and that any subsequent 18 discussions that you might have had, Mr. Guild, with Mr.
19 1
20 Gallo I assume would not have broadened that notice.
21 MR. GUILD:
Ms. Chan, I appreciate your effort J
22 to help, if that's what it was, but you neglected to read the part that you initially read of the notice of deposition 1
i O 1
1 57
)
1
-which very clearly states that it's on the subject of his 2
knowledge of quality assurance at the Braidwood facility.
3 Mr. Steptoe, do we have a problem?
4 MR. STEPTOE:
Yes, I think we do have a problem.
5 I don't intend to respond to your statements about my firm o
or my co-counsel, but I reject them.
I am instructing the 7
witness or advising the witness that he need not answer the 8
question that is pending.
However, I want to make it 9
absolutely clear that you may pursue questions, for example, 10 whether there were any -- questions reasonably related to 11 Contention 12J or the subject matter of his affidavit.
12 For example, you may ask him, and I have no 13 objection, whether there were any observations compiled dur-k Id ing the course of the reverification program which were 15 subsequently deemed to be invalid, and of those, whether 16 there were any which a witness -- which the original 17 inspector refused to concur in.
All of that is perfectly 18 legitimate inquiry.
But the open-ended inquiry which you 19 seem preparing to embark upon seems to me to be beyond the 20 scope of the representation and understanding you had with 21 Mr. Gallo.
22 MR. GUILD:
The simple question that is pending
\\
58
(}
is whether he is aware of any instance where there has been
\\ et I
a failure to concur in BCAP observation invalidation.
MR. STEPTOE:
Yes, sir, and I believe --
3 MR. GUILD:
And you believe that is an objection-e able question?
That is your position, sir?
MR. STEPTOE:
Without limitation to the subject 6
matter of the reverification program?
7
- MR. GUILD
The witness has stated that he 8
cannot recall to the series of questions that preceded that.
9 Now, I believe I am entitled to an answer whether he has 10 any knowledge there has ever been a failure to concur in a 11 BCAP invalidation decision.
12 If you want to stick by that and instruct your
)
witness not to answer that question, let's be absolutely
/
- ~
ls clear.
That is the question.
I am trying to probe the 15 witness' knowledge.
16 MR. STEPTOE:
That's correct. I am advising him 17 that he need not answer that question, but a more limited 18 question certainly would be appropriate.
19 MR. GUILD:
There is no reason in the world why 20 I need to limit my questions to satisfy this scope notion 21 that you have.
I am entitled to know whether he has any 22 knowledge on that subject.
3 c
I O
l 59 l
1 Mr. Steptoe, where are you coming from on that?
2 MR. STEPTOE:
You can notice up his deposition a
again and we will have time to prepare for it, but having been misled by your representation to Mr. Gallo, I am not 4
5 going to see you run roughshod over me simply because you --
6 MR. GUILD:
Let's go off the record.
7 (Discussion off the record.)
j 8
MR. GUILD:
Back on the record.
9 Just to be clear, the record should be reflect to that the documents that Mr. Shevlin identified that were 11 provided by his counsel, beginning with E453 and, not i
12 necessarily consecutively, but ending with E730, should be 13 included in what has been marked as Group Deposition Exhibit "w
14 2 to his deposition.
15 Mr. Steptoc. on the basis of your position that 16 you stated and your instructions to the witness not to 1-7 respond to my last question or series of questions, I intend is to recess the deposition at this point.
i 19 MR. STEPTOE:
Before you do, sir, your first 20 statement was documents E453 through E730 shculd be a
21 included as exhibits to the deposition?
4 22 MR. GUILD:
The last number was 730, yes.
i 4
f 4
' O
_ _ _. - ~ _..,.,. _ _ _.. _ _ _ _. _ _ _.. _... _ _ _.. _.
60
-A
(.
1 They are not necessarily consecutive.
That just happens to 2
be the bottom of the stack of paper that the witness went 3
through.
4 MR. STEPTOE:
Okay.
Now, you will recall.that 5
the witness did not indicate that all of those documents s
6 were used as the basis for his affidavit, and we earlier 7
had an agreement that I was going to go through and pick 8
out the ones that he had not identified and remove them 9
from the stapled packages.
10 Do you still want me to do that?
11 MR. GUILD:
Yes, please.
The record should 12 reflect the documents that he identified, and those are 13
^}
the only ones that I intend to have included in the Id Deposition Exhibit 2.
i 15 MR. STEPTOE:
Now, as for your intent to recess 16 the deposition, that is your prerogative, of course.
I want 1-17 to make it clear that I am not interposing any objection i
18 to discovery during this deposition of any facts which are 19 relevant to his affidavit, the scope of Contention 12J.
20 If you want to limit your pending question or try to 21 establish a foundation, any foundation,between that and the 4
22 scope of Contenticn 12J or Mr. Shevlin's affidavit, that is e
OV 4
61 s\\
l fine.
2 MR. GUILD:
I would --
t 3
MR. STEPTOE:
Excuse me. Let me just finish one d
more thing.
I'm sorry.
5 I understood your line of inquiry to be an 6
open-ended inquiry into BCAP procedures in general and BCAP 7
observations in general rather than something confined to 8
the subject matter of his affidavit and your representation 4
]
9 or agreement with Mr. Gallo.
10 MR. GUILD:
I think our positions are clear, and 11 I disagree with yours, sir, and stand by mine, and 1
j 12 represent to you that the questions I have posed that you 13 fw have instructed him not to answer are relevant to the subject I
id matter noticed, the subject matter of his affidavit, and are 15 within the scope of any agreement that I have with your 16 colleague, Mr. Gallo.
37 MR. STEPTOE:
Well, if you will explain torme is how it is relevant to his affidavit, I will be glad to 19 withdraw my objection.
20 MR. GUILD:
I have done stated all I need state, 21 Mr. Steptoe, and I don't intend to debate the matter with 22 you any further.
For my part, the deposition is recessed I
62 iY/
1 at-this point.
2 MS. CHAN:
The Staff has no questions.
.3 MR. STEPTOE:
I would like to take ten minutes 4
to talk with the witness and see whether redirect is 5
appropriate at this time.
6 (Recess.)
7 EXAMINATION 8
BY MR. STEPTOE:
9 Q
Mr. Shevlin, referring to pages 26 and 27 of 10 your affidavit, you discussed the results of the reverifica-11 tion program for supports and restraints.
I believe, as 12 corrected, you referred to 21 new observations were issued g}
13 against a population of 160 supports.
%J 14 Do you follow where I am reading from?
15 A
Yes.
16 Q
How many of those observations were valid and I:7 invalid?
Is A
Probably about half and half.
19 0
Okay.
20 In determining the results of the reverification 21 program for your purposes, what was the relevance of the 22 determination of validity or invalidity?
O
63
/7
(_)
1 A
None.
2 Q
Did you know whether those observations were 3
valid or invalid when you analyzed those 21 observations?
4 A
No.
5 Q
Did you know whether those observations were 6
valid or invalid when you made your recommendation to your 7
superiors as to whether BCAP inspections of pipe suppors 8
and restraints could continue?
9 A
No.
10 0
Why didn't you know whether those observations 11 were valid or invalid?
12
.A I didn't see it as being relevant to what I was fs doing. The validity determination came later, and what we 13 14 were trying to find out here was based on the instructions 15 in hand, had the inspector doneshat he was supposed to do or 16 had he not?
I'7 So the fact that it may later turn invalid based 18 on something that we didn't know about at the time of the 19 inspection really shouldn't have entered into it.
20 Q
Do you know whether any of the 21 new observations 21 which resulted from the reverification program for supports 22 and restraints were later invalidated and the original O
64 1
inspector contested that determination?
2 A
No.
I mean yes, I do know.
No, there was no 3
contest.
4 Q
Do you know why Exhibit Nos. E483 through
-- I 5
need to see them, excuse mc
-- through E507 do not in 6
general contain pages 2 and 3 of the BCAP observation 7
record form?
8 A
Depending on what point they were obtained or 9
removed from the system for copying, they may not have 10 supposed to have been.
Pages 2 and 3 were not used by the 11 inspector.
If the inspector needed additional room to write 12 or to provide a picture or something, he would have made an 13 attachment to page 1.
,g N-)
L 14 Page 2 was then'used by the BCAP engineer, and 15 page 3 was then used by the architect engineer.
Normally 16 we would never receive a copy of it.
We didn't need it for 17 anything.
18 0
Why did you order an overinspection of Mr. Jones' 19 work?.
20 A
Because some of the findings -- some of the CAT 21 team findings were on work that Mr. Jones had done.
22 Q
What are the similarities or differences between
65 i
i configuration inspections of piping and configuration 2
inspections of pipe supports?
3 A
Not a lot.
The idea is dimenFion, location, orientation in relationship between the parts, angles, 4
5 slopes.
In that respect, there is probably not an appreciable difference in inspecting the configuration 6
7 of anything versus anything.
8 Q
Do you have an opinion as to the relevance of 9
the results of overinspections, configuration inspections of 10 pipe supports and restraints in assessing the ability of an inspector to perform configuration inspections of piping?
11 12 A
In this case, the case of the overinspection 13 sheets we hhve seen, the relevance is clear in that the 14 interest was is this inspector paying close and careful 15 attention to what she is doing in her configuration 16 inspections?
That was the object, not the object of trying to find out whether a given piece of hardware was any good.
17 18 The object was trying to find out is this inspector going 19 out here and paying attention to what she is doing or not, 20 or what he is doing or not.
21 Q
Do you have an opinion as to whether the~BCAP 22 inspectors who performed the reverification program inspec-tions of work which had initially been inspected by BCAP n
G
- m+
66 g-
\\~-
1 inspectors were likely to agree or disagree with the 2
resulte of the original inspections?
3 A
Well, there is no opinion to that.
They didn't 4
know the results of the original inspections.
Therebas no 5
opportunity to agree or disagree.
It was as if it were a 6
brand new inspection.
7 Q
Were the BCAP inspectors who performed those 8
reinspections the same BCAP inspectors who performed the 9
original inspections?
10 A
No.
11 MR. GUILD:
Asked and answered.
12 MR. STEPTOE:
By whom?
fs 13 MR. JUILD:
By you. It's in his own document, and k3~-)
14 there is really no necessity for you asking questions that 15 are already asked in the man's own affidavit, Mr. Steptoe.
16 MR. STEPTOE: I am not sure whether the witness' 17 answer --
you got the witness' answer?
18 THE REPORTER:
Yes, I got the witness' answer.
19 MR. STEPTOE:
That concludes my redirect.
20 FURTHER EXAMINATION 21 BY MR. GUILD:
22 O
When did you find that there were 21 observations s.
O
67 7s
"\\,
I resulting from the reverification and not 20?
2 MR. GUILD:
Do you have something to say?
3 MR. STEPTOE:
Well, it seems to me outside the 4
scope of redirect, but if you want to continue with this 5
deposition whether than recess it, that's fine.
6 MR. GUILD:
No, sir.
You raised the point.
I 7
believe it is in the scope of redirect.
8 BY MR. GUILD:
O Would you answer the question, please?
10 A
The little spread sheet that showed 20 was wrong, 11 and I found it to be wrong by studying my own analysis of 12 the individual observations.
I just noticed, hey, this is 13 g
s, not 20,.it's 21.
')
t Id Q
Was it an arithmetic error?
15 A
Or a transposition.
Arithmetic or a transposition.
16 Q
Do you know?
17 A
No.
That sheet was made,by who, I don't know 18 when, a long time ago.
I got it out of the files.
I' O
And when did you identify that error?
20 A
Recently. Since I prepared my affidavit.
21 O
When were the determinations of validity or 22 invalidity made for the observations t hat were identified 4
6
68 i
I during the course of the reverification program?
2 A
Well, as we finished the inspections, the 3
reinspections, we turned the packages and the new observa-4 tions to Engineering, and then their validity determination 5
would start.
So it was after we finished, on a package-by-6 package basis as opposed to the whole thing.
The validity 7
determination would start on an item-by-item basis after we 8
finished the inspections.
9 Q
For any item, was the invalidation or validition 10 determination made before you reported on the results of the 11 reverification program?
12 A
Possibly. It's possible.
13 0
In which instances?
14 A
I don't know. I don't know that it was or it was 15 not. I'm saying by the system under which we were working, 16 that possibly might have happened.
It may not have, too.
17 I don't know.
18 O
And those' determinations of validity or invalidity 19 came back to you or to the original inspector for concurrence 20 after the decision was made, after the determination of 21 validity or invalidity was made?
22 A
Yes.
,[
~.
69
(
s
-(_j 1
Q And so you would have had knowledge of what the 2
decision was on validity or invalidity at that point?
3 A
Yes.
4 Q
Is the counting error that you corrected, Mr.
5 Shevlin, the change to "8"
from "7" and "13" for "12" in 6
the totals, related'to the error in counting observations 7
in 214207 8
A I'm sorry. I don't think I understand.
9 Q
Okay.
You made corrections at the outset of 10 your deposition, and if you want me to --
11 A
No, I know the correction you are talking about.
12 O
All right.
Is there a relationship between 13 those corrections, the numbers "8" and "13",
and the (s,g) 14 correction of the total observations 21420?
Is it the 15 same error?
16 A
Yes.
Yes.
This document --
!?
O You have to identify it for the record so we all 18 know what you are talking about.
'19 A
E515 and its subsequent pages is a description of 20 the new observations found.
21 O
Yes, sir.
22 A
There are 21 items on there.
The corrected s
r h
70
("%
(ssl 1
document miscounts the "21" here to "20."
It's just a 2
tabulation, a quick graph type thing for someone to look at.
3 The real information is here.
4 Q
And that is the source of the same -- the same 5
error led to the correction of the totals, "13" for "12,"
6 and "8"
for "7."
7 A
Yes.
8 MR. GUILD:
That's all I have.
9 MR. STEPTOE:
May I have 30 seconds outside with 10 the witness, please?
11 (Recess.)
12 FURTHER EXAMINATION 13 BY MR. STEPTOE:
7s
(-;
14 0
I believe Mr. Guild asked you about when you heard back if an observation is valid or invalid, Mr.
15 16 Shevlin.
Did you receive notice when an observation was l'7 determined to be valid?
18 A
No.
19 0
When did you receive notice of the disposition 20 of a BCAP observation by Engineering?
21 A
Only if it was invalid.
22 MR. STEPTOE:
I have no further questions.
4 l
- ,a
~
\\-,)
71 (m
r i
\\./
1 FURTHER EXAMINATION 2
BY MR. GUILD:
3 O
And half of the reverification observations, by 4
your testimony, approximately, were determined invalid?
5 A
That's a guess, but yes, somewhere in that neigh-6 borhood, over a period of time.
7 0
Do you know which ones were determined invalid?
8 A
No.
9 Q
Is it reflected in the documents that you 10 produced today?
11 A
It is reflected in the BCAP files.
12 O
But not the documents you produced today?
Unless
/~N 13 there is a page 2 of 3 for the observation --
14 A
That's exactly where it would be.
15 Q
I only found one page 2 of 3.
16 A
Yes.
These were apparently recovered from the 17 system and copied with the other documents that were 18 assembled in my office such as this before Engineering even 19 got their hands on them, and that's why you don't have those 20 pages 2 and 3.
But during subsequent processing, they would 21 have been added.
22 O
Why, then, was the one page 2 of 3 that was 4
b
72 im
(_)
included in the documents reflective of a' determination i
2 that the observation was valid?
3 A
I have no idea.
4 0
That shouldn't have -- you shouldn't have gotten 5
that second page back if, as a matter of course, you never 6
received anything other than invalid determinations; correct?
7 A
I normally wouldn't have gotten that, that's 8
true.
You see, I don't know at what point this reproduction 9
was made.
10 Q
The copies of the documents?
11 A
Yes.
It could have been anywhere. They could 12 have been done in the engineer's office just as he started
/~N 13 to work on them. I have no idea.
' "s]
14 0
Or there could have been attached pages 2 and 3 15 that reflected a decision on validity that just didn't get 16 Copied.
17 MR. STEPTOE: I will object.
18 BY MR. GUILD:
19 Q
Do you know whether there were pages 2 and 3 that 20 were include that just simply were not copied?
21 A
I really don't know.
22 MR. GUILD:
All right.
That's all I have.
O
73 r
-( y.
}
I MR. STEPTOE:
I am prepared to continue if you 2
would like to continue, Mr. Guild.
3 MR. GUILD:
I would, but I would like to continue and pursue the line of questioning that you instructed the 4
5 witness not to respond to, among other things.
6 MR. STEPTOE: Well, if you would like to go into 7
the other things, Mr. Guild, I am here. We are ready to go 8
now.
9 MR. GUILD:
I would like to conduct the to deposition the way I would like to conduct the deposition, 11 Mr. Steptoe, and you have instructed the witness not to 12 answer the line of questioning, and I have reached the 13 determination to recess the deposition.
Af~T
'\\_,/
Id (Whereupon, at 12:40 p.m. the taking of the 15 deposition was concluded.)
16 17 18 19 20 21 22
i 74
~
o( )
(.\\s /
i CERTIFICATE OF NOTARY PUBLIC 2
3 I, Suzanne B. Young, the officer before whom 4
the foregoing deposition was taken, pages 1 through 74, 5
do hereby certify that the witness whose testimony appears 0
in the foregoing deposition was duly sworn by me; that the 7
testimony of said witness was taken by me and thereafter 8
reduced to typewriting by me or under my direction; that 9
said deposition is a true record of the testimony given by 10 the witness; that I am neither counsel for, related te nor 7-~
.V
'11 employed by any of the parties to the action in which this 12 deposition was taken; and further, that I am not a relative II or employee of any attorney'or counsel employed by the W
parties hereto, nor financially or otherwise interested in 15 the outcome of the action.
16 17
,/'/
j
}g L Lf.d4 u us -,,
M4W l
' SDZANNE'B. YOUNG I
19 Notary Public in and for the District of Columbia gg 21 22 My Commission expires:
(n u di /{ /9/f i
l
g-1/30/86 LJ UNITED STATES OF AMERICA 4 4,g NUCLEAR REGULATORY COMMISSION j
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:
)
)
COMMONWEALTH EDISON COMPANY
)
Docket No. 50-456
)
50-457 (Braidwood Nuclear Power
)
Station, Units 1 and 2)
)
NOTICE OF DEPOSITION F Pursuant to 10 C.F.R.
$2.740(a), Intervenors Rorem, et al.
/7 hereby give notice that they shall take the depositions of the V
following witnesses, who are employees of Commonwealth Edison Company or its contractors: James W. Geiseke; Kenneth T.
Kostal; Edward M. Shevlin; George Orlov and Thomas E. Quaka.
The depositions shall commence on Wednesday, February 12, 1986, at 10:00 A.M.,
and shall cont ue thereafter until completed, at the offices of Isham, Lincoln and Beale, Three First National Plaza, Chicago, Illinois; or at such time and place between l
February 12-14, 1986 as the parties may agree.
The depositions shall be taken before a certified court reporter, and shall be on the subject of the witnesses' knowledge of the quality I
assurance deficiencies at the Braidwood nuclear power station alleged in Intervenors' Amended Quality Assurance Contention.
O
. The deponents shall bring with them all documents in their possession, or subj ect to their control, which are the basis for the witnesses' affidavit in support of Applicant's December 20, 1985, Motion For Summary Disposition.
DATED:
January 30, 1986 Submitted by, sh Robert Guild f
O One of the Attorneys for v
Intervenors Rorem, et al.
l L
Douglass W. Cassel i
Robert Guild Timothy W. Wright, III 109 North Dearborn Suite 1300 Chicago, Illinois 60602 (312) 641-5570 t
1O
h 1/30/86 n
v UNITED STATES OF AMERICA NUCLEAR REGUIATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:
)
)
COMMONWEALTH EDISON COMPAUY
)
Docket No. 50-456
)
50-457 (Braidwood Nuclear Power
)
Station, Units 1 and 2)
)
CERTIFICATE OF SERVICE I hereby certify that I have served copies of Intervenors al. Notice of Depositions on each party listed on Rorem, et
()
the attached Service List by having said copies placed in envelopes, properly addressed and postaged (first class) and deposited in the U.S. mail at 109 North
Dearborn,
Chicago, Illinois 60602, on this 30th day of January, 1986; except that NRC Staff Counsel Mr. Traby was served via Federal Express overnight delivery and Mr. Stahl, counsel for Edison, was served by messenger on Friday, January 31, 1986.
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BRAIDWOOD SERVICE LIST 50-456/50-457 OL lierbert Grossman Elaine Chan, Esq.
Chairman and Administrative Judge NRC Staff Counsel Atomic Safety and Licensing Board U.S.
Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington D.C.
20555 Washington D.C.
20555 Dr. A. Dixon Callihan Administrative Judge Joseph Gallo, Esq.
102 Oak Lane Isham, Lincoln & Beale Oak Ridge, TN 37830 Suite 840 1120 Connecticut Avenue N.W.
Dr. Richard F. Cole Washington D.C.
20036 Administrative Judge Atomic Safety and Licensing Board Docketing & Service Section U.S. Nuclear Regulatory Commission Office of the Secretary Washington D.C.
20555 U.S. Nuclear Regulatory Commission Rebecca J. Lauer, Esq.
Washington D.C.
20555
,s I
Isham, Lincoln & Beale
\\s Three First National Plaza Atomic Safety and Licensing l
Chicago, IL 60602 Board Panel l
U.S. Nuclear Regulatory Ms. Bridget Little Rorem Commission 117 North Linden Street Washington D.C.
20555 Essex, IL 60935 Atomic Safety and Licensing C. Allen Bock, Esq.
Appeal Board Panel P.O. Box 342 U.S. Nuclear Regulatory Urbana, IL 61801 Commiss ion Washington D.C.
20555 Thomas J. Gordon, Esq.
l Waller, Evans & Gordon Michael I. Miller, Esq.
2503 South Neil Isham, Lincoln & Beale Champaign, IL 61820 Three First National Plaza Chicago, IL 60602 Lorraine Creek Route 1, Box 182 Manteno, IL 60950 1
Region III U.S. Nuclear Regulatory Commission Office of Inspection & Enforcement 799 Roosevelt Road
N (b
Glen Ellyn, IL 60137 l
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page 1 of 2 SUtemTION on January 18, 1985 CSR Mechanical / Welding inspection activities were suspended in the piping support populations predicated upon MRC CAT concerns.
Actions taken and results achieved are as follows:
1.
A Reverification Plan was developed by the BCAp Level III Mechanical Inspector and approved by the BCAP CSR Inspection Supervisor on January 19, 1985. The plan contains definitive actions to be executed and special checklists to document the reverification results. These checklists included a special instruction for reverification of each of the four (4) areas of interest.
A separate checklist was prepared for each of the three affected support populations to provide appropriate references to the applicable approved BCAP checklist instruction in all cases.
The Reverification Plan, including checklists, are enclosed as Exhibit
- C."
2.
Prior to performing the reverification, each inspector was instructed in the objectives and methods outlined in the plan, the attributes to be reverified, and the specific instructions applicable to each attribute.
Attendance rosters are enclosed as Exhibit "D."
3.
Control measures were established to assure that no inspector was tasked to reverify his own previously performed inspection. A log which lists O
each CSR Package ntanber, the name of the original inspector and the name of the reverification inspector is enclosed as Exhibit "E.*
4.
The inspectors who performed the reverification were provided only with the applicable drawings, instructions and special checklists. They were thus aware of neither the results of the original inspections or the identities of the original inspectors.
NOTE:
Prior to implementing this plar, two CAT findings were reverified by the original inspectors. The inspectors concurred with the CAT findings, and issued observation Records I-M-02-054-3 and I-M-03-008-4.
These observations were treated under this plan as new observations, and are included in all resultant statistics.
The two supports were also independently reverified as described
{
in paragraph 3 and 4 above.
1' l
5.
Findings made by the reverification inspectors were entered on the special checklists. A specially designated team of certified (Lead) Quality Inspectors were tasked to determine the validity of each finding. This was done by reexamination of the hardware items and/or comparison with the approved BCAP accept / reject criteria outlined in the applicable instructions in Exhibit "H" and were processed as follows:
O Ea000453 (1680J) l
Page 2 of 2 a.
Where the finding was determined to be valid, an Observation Record i
was initiated in accordance with Procedure BCAP-06.
j b.
Where the finding was determined to be invalid, the reverification inspector was shown, to his/her satisfaction, the reason for the determination. The justification for a determination of invalidity j
was entered on the special checklist and signed by the Certified Lead l
Inspector. As evidence of concurrence, the reverification inspector initialed the entry.
c.
The plan provided for processing of contested new observations. No invalidation of findings were contested.
d.
One Observation Record was initiated, and later closed by the Level III Mechanical Inspector as not suitable for further processing, with the concurrence of the reverification inspector, Observation Records initiated as a result of this plan are being e.
processed in accordance with 3 CAP-06.
Copies are enclosed as Exhibit "F.*
6.
Copies of the checklists used to implement this plan are enclosed under separate cover as Exhibit "G.*
7.
SCAP CSR reinspection package doctaments affected were corrected to incorporate the new observations initiated as a results of this plan.
8.
Analysis of the results of implementing this plan are enclosed as follows.
Program analysis by group Exhibit H
' Evaluation of new observations Exhibit I Conclusica:
Based upon the number of new observations (23) versus the total attributes reverified (640) the results indicate a 96.8% inspection accuracy rate. In addition no significant deficiencies were identified during the reverification plan which had not been previously identified.
All questionable areas of concern were thoroughly addressed through taplementation of this plan.
Predicated on the results of the assessment / reverification plan, we consider l
the MRC CRT Team concerns to be effectively resolved.
- O 1
E.3000454 (1680J)
Jcnucry 22. 1985 BCAP Memo 8 530 0
TO:
R. L. Byers FROM:
M. A. Clinton
SUBJECT:
CAT Concerns with BCAP Reinspections of Piping Supports As discussed on 1/18/85, we have initiated an internal reverification program to address the CAT concerns and questions related to the Task Force reinspections in the piping support area. The reverification program is focused on four areas of concern which are summarized in Attachment I.
Rvaluation of each of these four areas of concern and the fact that they were revealed in a relatively small number of reinspection packages (5) led to a conclusion to reverify the affected attribute areas for the 160 piping support packages completed through 1/18/85. The 160 completed packages are distributed in the random sample portion of three populations in the following porportions:
M-002 Large Bore Pipe Supports (Rigid) - 50 completed.
O M-003 Large Bore Pipe Supports (Non-Rigid) - 51 completed.
M-006 Small Bore Pipe Suppports - 59 completed The Mechanical / Welding Level III Inspector was assigned to develop a Reverification Plan to cover the areas of CAT concern and to obtain my concurrence prior to beginning any inspector reverification activity. The draft plan was reviewed orf 1/19/85 and approval to begin implementation was also given on 1/19/85. The resultant Reverification Plan and implementing checklists and feras for recording reinspection results are presented in.
We are performing the reverificatico program on a priority basis and expect to have a majority of the reverification activities completed by 1/25/85.
There will be a small number of piping supports in restricted access areas and there may not be completed by 1/25/85; however, these should not materially affect the results to be available by 1/25/85.
I will keep you informed of the progress of this program on a regular i
basis.
M. A. Clinton Eno00458 0828J
Page 1 of 1 O
Areas of Question or Concern 1.
Cat Inspector identified that a 6" angle iron stiffener specified on the drawing and the Bill of Material ses not installed. BCAP Inspector had reported this piece inaccessible for verification in the checklist Remarks column, due to its parent in place beam being boxed in.
(M-003-032) 2.
CAT Inspector identified that the shelf bracket angle irons for the supplementary steel on one support were not the specified size or weight. BCAP Inspector failed to transcribe this observation from his notes to the reinspection documentation.
(M-003-008) 3.
CAT Inspector identified that a welded attachraent to in-place steel on one support was incorrectly located. -8 CAP Inspector failed to identify this discrepancy.
(M-002-054)
O 4.
CAT Inspector was concerned that instructions did not provide for verifying specified location of support attachments to supplementary steel (Generic) o l
I l
O E0000459 0828J
Page 1 of 2 O
Reverification Plan 1.
Checklists to provide for reverification of the characteristics identical to or similar to the areas of concern are to be developed by the BCAP Mechanical Level III Inspector, and approved by the Inspection Supervisor.
2.
Inspectors involved in the reverification are to be provided with instructions to assure a complete and uniform understanding of the attribute areas to be reverified. Specific training on the use of the reverification checklist and applicable CSR instructions will be provided.
3.
Control measures are to be established to assure that no inspector will be tasked to reverify his/her own work.
O The inspector performing a reverification is not to be provided with 4.
the results of the original inspection. He/she will be furnished with the applicable drawings, instructions and the reverification checklist. The reverification inspector will not be made aware of the identity of the original BCAP inspector.
5.
observations made by the reverification inspectors will be compared with the results of the original inspections by a team of specially 1
designated inspectors. Where an observation is made during reverification which was not made during the original inspection, a Certified Lead Quality Inspector (Mechanical) will reexamine the subject characteristic to determine the validity of the new observation. If valid, the new cbservation will be processed in accordance with current BCAP procedurec.
If the new observation is determined by the certified Lead Quality Inspector to be invalid, the reverification inspector will be shown, to his satisfaction, the reason for the determination of invalidity. The reverification inspector's ackncneledgment of invalidity will be documented on the reverification checklist.
Contested new observations will be processed in accordance with current BCAP procedures.
O Eco30460
Attachmsnt 2 Page 2 of 2 O
v 6.
Results of the reverification will be analyzed to determine individual inspector or group deficiencies. In the event that such deficiencies become apparent, appropriate instruction or training will be developed, submitted to BCAP Management for approval, and presented to the inspectors. At the time of decision that additional training is indicated, further support inspections by individuals or by group will be discontinued until such training has been completed.
7.
Support inspection attributes outside ti.e scope of the NRC CAT questions and concerns are not addressed by this plan.
8.
Documents controlled by BCAP procedures initiated or corrected as a result of this plan will be processed and retained in accordance with the applicable procedures.
l 9.
Checklists, notes or other documents initiated as a result of this plan but not controlled by BCAP procedures will be processed and retained as directed by BCAP Management.
Forms to impleme,nt this Plan are attached.
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O o o REVERIFKATION OF CSR SUPPORT REINSPLCT/0W PUFFLAT/0N LRREE 130RE MON - RIGID PIPE SUP!' ORT 3 SIPMWT NG BR PAL AA0. INSPEGEO BY REMWIREDBY RDD/D0AMK OBSEMATAWDESCRIPTlowiMRwr Na iM5010%35 Kl0 L5R-D m-3-0fi P7T PST NOME IC\\l070115 ele L5R L-m 3-G50 F T_S TR1 NOME ltvol.014S Klc C5R. T: m-3 D31 PSS PTT NONE 105090025 Fl% CSE I.-m bM PST GI5 NONE IFW 110255 El0 LSR 1-m-3 -6U PIT PSI limEM5:0N OUT OF WKRNCE. (St - P m 033 -3 ICVD200'lV RIF tst 1-m DE PST GT5 NCNE inF03DRV KlF tst.1-m 0% GTS PTT NOME ltV030093 eld ot-T. m Dyl TR1 GTS NONE itV090Nes KIC L5E m 0 33 PST TR1 NONE IC5 0109BC IlE C501-m 3 640 TR9 PST NONE ISI130335 YlB L5R-I-m-3-091 HWN FLS NONE 1 SIch009Y RI'. CSE-L m 043 GIS PST VENDOR FflBKKmEO 11mEml0M. CSR-I.- m Oil -4, ICVW10'11V KIC CsE-L m 049 HmS PTT m1AOimLNT m 91f9. bTEEL OllT 6FTOL. LSE-1-m 3-044-3 )R109D015 Kl F C5DL-m-3-095 TRY Pai IMOVilLT W-3lTPE IN51 RUED. CSE-1-m MS _3 )FWO90NS RIE tst-L-m-3-06 TRN PTT NONE { )R9Of.013V RID cst-L m 691 PTT P5T NONE '15Il%0B35 IIR L5R m 00 P3 T GTS NONE \\510t\\ D0~1S Tit LSR-U m-3 Of1 FIS PS3 NONC \\ STORD23V Rit CSR-I-m 3-BSI FIS TRN "t" DimEMSIDN 6N ClllmP. CSE m-3-05 I-9 1FW0hDMS tib L5R-U m-3 051 TRM GT5 NONE IRH020(n15 110 L3E-T: m-3-b51 HWN TRM NONE ICCD70TlV KlC tbR-L m-3 655 Hm3 PST NONE thF 090lW Kl B C5R I: m 0% GIS F I.5 n.0. m. chm FL KT. L5R-T-m 3 -05fe - 3 s-w on m a
J ~ O O O REVERIF/ CATION OF CSR SUPPORT RE/NSPECT/0W PDF#LAT/0N 1.n mE BORE NON-R)GID PIPE SUPPORES OJ49tr NG d R Pfle,AM. INSMCTED BY REV97/NEDBY hDD/MNRL OBSERVAMNDFXRIPr/0NfATFEl97 ND 1RCl30ftt3 RIE CSETrm-3-057 P IT TRN , NONE. ICN 0le 00%S RI D CSR-I-m 3-OSS P7T GT5 NONE It5'200115 RfC. CSR-L-m-3-Olc0 PST FIS NOME 1CV03015S ElC CSR.-Te m 0(,i TRN PTT NONE 1EVD1002S Ril4 CSR-1-m obl PSJ Pd1 NONt? 'j ? I ! ') 9 6 C k d
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9 DCAP OBSF4TICW BBC00tD Page 1 of 3
- 1. 08SERVATION hfo.r r t
2 PART 1 CeSERVATION IDDiTIFICATION & DESCRIPTICW 2 ptSCRIPTIQW OF ITEM (Bquipment. Material, Component, Procedure):l3. FACKAct beo, i,c. -p sge
- e t a tw s tec' S, = m ;nt et ss o t/ 2 clE. 2 'Xv2. 'j%
1
- 4. SYSTEM (if h r.):
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- 5. CHECKLIST / ITEM bfC w.T-m 2.ss
- 6. WIT 1 l
l UNIT 2 lhl COPMON O l l ,[%" 8 yn
- 8. Bl.EMDC
- 9. OBSERVED DURING:
l l Procedure Revi blReinspection g g laplementatior. %l CSR l l RPSR l,,, l RSCAP ~ I'VI'* I_l Docurnenta-g gon y,yg,, l-l Other
- 10. DESCRIPT AW: OF OBSERVATION:
l - E,$E G\\15._ ".va Tr MJ.M, L d' 4 '."J NT S') tIRISa-c, T6* MM,.it.- R'i -\\"ut- ? S W TTt _G % E IfM. %dWA. 74 Vr s P-\\ Q% vic w __ _~_' 1_ G u *f T s 0'-4M.'C T 5s. h i t '.l V Z ". A O _E. T o M G Q. ? 0. .i_ ?._ _.m L & c,f E.T d-4. T G tn-% T St.F._ C.:, Jr t % TN-a. _t ;.% twt. */t' Yt.& GPJE1ENO uPd V4D b E. t"Nh, \\'N' W4 NbTLMI EmMM O_WucT tone WI VBTvo_ bmTMesi Fe_ A stob heug.wy wr Woui_ VMt\\T K71.*, GEf*','iu FW" \\'55 ( %%R0 H.\\. ~)ct) - St r% j )vs L'.u., C'.R.7.L t m %* % '/n ; T_t.G. T - in N %,1", on 1. PREPARED BY: o ,;,c7s m R.yc a '552'Ti\\t-9 SM6 67 22, \\S'JS $ G sienature Da I PART 2 ceSERVATIN CLARITY, CCIEL,tTEWESS, AND ACCVRACY REVIEW 12.MT3/CLARIFICAT15: / '.- J s N e' n! ~~ l' t I?ct n A Ps' W ~'L cl' >> v) 74 JLM 'l I? e l'os usc n i n A S ra A4.1 C&O4Q. 7"M /' 8 * $~d/'Al" 7' ~ I]' T"M M'**' 'l S74 4 4 M e. ?>d 4w7My Adsve' s?LMet*.CE 7Nd Ese is Wa>r Su oindl'c A M /.".ATWCL SActEJJM, he /J Ccesco. 7N' E4'% Adc.i R ? ica T v l' ~W.- Ec.e Co af.' n. G /3 _fc, N e e 3 Ka $: er:.* < f M S /MA/42 WW Cc,Wtut O i 13.5UITABL.E FOR FURTMER PROCESSI)fG: 14. I pY I /I l vo l - gj ): J <- l Bienatur( Det I l l ,33 9,3 aCAP Form D6-1 (Rev. 5) E0000483 1
DCAP OBSEPVATION RECORD Page 1 of 3
- 1. OBSERVATION WO.3.7 '_- IT 3 _" -
PART 1 OBSERVATION IDEh'TIFICATION & DESCRIPTION 2 DESCRIPTION OF ITEM (E p:'ent, Material, Component. Procedure):l3. PACKAGE Wo. r: ? S I "': ; 7i D d. fT.
- lM ii R T / C.
( <_ t _ n'.. ' -
- 4. SYSTEM (if known):
p
- 5. CHECKLIST /ITD'. W3
( M ! rr,. 2 ',3 f _
- 6. UNIT 1 Ml UNIT 2 l
l COMMON 0 l l SE #3CE R W3 -.,.. .e_
- 8. E;.EMEN-
- 9. OBSERVED DURING:
l ,l Procedure Revi-M Reinspection Iz;:l e.en t a t i:. g g $l CSR l l RPSR l_l RSCAP Documenta-V g g g g tion Review
- 10. DESCRIPTION OF OBSERVATION:
1 iFF t SCA 1R biu. W tTLULEA I,'ITU\\W %3tWTi.5 A T( R1%- YJ.' T e s usy_,. 3 s 'c a_I T e sui e %1 vA N.t C.50% DCW t nN T x(t Tt. E i r_ t-t its 2%, hw t._,'mt MiiLos 0.tTuc * ' W GW Yv P'i.r.L LWSLti' Tcl *s CD$u'L h 5il - vtuttA Qvtu b\\mtG\\tm MI. TTT GEWIL_ TIG O S [ToB\\M.1 MSM W DA s ti/2 t.am. CDiLGU MTU S~la - \\w 'a@, TLEM Tu \\n "ilf ts, p* *.X - l{. PREPARED BY: A W"PMGR k.h31.ON LEblV MS ' 3 ', 'b '- 9 hW DI O, sianature Det 9 *-L/' \\;c G S V U PART 2 OBSERVATION CLARITY, COMPL.ETENESS, AND ACCURACY REVIEV
- 12. COMMENTS /CLARIPICATION:
ANA// i
- 13. SUITABLE FOR FURTHER PROCESSING:
g/ 14.REVIEVE 3: lsu I I ~/ L s /j Aad siendurv E0000484 l 0353J-2 3 CAP Poru 06-1 (Rev. 5) 6
acAP OBS pVnTION RECORD v Page 1 of 3 1
- 1. OBSERVATION NO.CSE ~ D' :-$ -
PART 1 OBSERVATION IDENTIP1 CATION & DESCRIPTION 2 DESCRIPTION OF ITDi(E\\_uiYnT ent. Material,CYmn n.Frocedure):l3. PACKAGE NO. nent i,.r%i Er.: Mc "E s D.e s m - t t/t
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4.srST&. (if known): 5. E .m g g.), c_ k7,) ,gISTIT
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COMMON 0 l l YI8ERVICEF y-
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- 9. OBSERVED DURING:
g l Pr W m R M t><1 Reinspection Implementa:ic. g @ CSR l l RPSR l_l RSOAP I'VI'# l - l Documenta- -l Other tion Review
- 10. DESCRIPTION OF OBSERVATION:
- 0. LAMP D IMFtd90fd5 DA AYR~ MQTZ34 VEdDDR CATAlrY, kTOAL DIMEtJSiOMS
!O s nm = w,e stem = am w REG.VI RED Bluf MSI A rd 5 51 3/g ", <:;m a :. Vz" x 2 '/t h (,FOR C IG 7 i t d ;,F 4 2l t ) A MD A LLo bA t3 LE M[*D i GOB @TUTl60 nG. Firm ROI /Rol 617A 3 7 itanatste Da j PART 2 OBSERVATION CLARITY, CEETDfESS, AND ACCURACY REVIEW )
- 12. COMMENTS /C1 ARIFICATION:
A/e#E 1 i
- 13. SUITABLE FOR FURTHER PROCESSING:
g 1 EV ygg Sien"atur( Datt ,3, y,, aCAr Form 06-1 (Rev. 5) g i
007 OBSE M flati ABCOsp Page 1 et 3 ~ 1
- 1. OSSERVATital go.BT 1 m 2 o' DAJtt 1 CSSEWAT10bi IDEWTIFICAT1 Cal & B**MIPTItal 3 pts 31PT10bi 0F ITEM (Squipment, Material,0caponent, Procedure):l3 PAcxAgg 30.
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- 4. SYSTEM (if krmd:
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- 10. DESCRIPTION OF CSSDVATICW:
A tll 5 tz E -I G RIANfl L ( 3 *A 4 Ta*A SA ~ ) INSTRlL ED. A 2llN silE-I GRIN (E Yz"X 4 % ~ E ' s.")-h GA-IS E AllED MK ON BDm. MEAR SK.LET ~ 3
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DCM' OBSEPVnTION RECORD Page 1 of 3 O
- l. OBSERVTTION No./* M -Z w.p.
PAF T 1 OPSEF ATION 1DENTIFICAT10N & DESCRIPTION 2 DESCRIPTION OF ITEM (Equipment, Material. component, Procedure):l3. PACKAGE NO. M i Sx OL O Et'R k Doer-- P e pp 509 FC R-T-AT-I-N-D o G
- 4. SYSTEM (if known):
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- 6. WIT 3 lgl WIT 2 l
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- 9. OBSERVED DURING:
g g p, K l Reinspection g g laplementati l l CSR l l RPSR l l RSCAP l Docu.menta-tion Review l l Other l
- 10. DESCR1F710N OF OESERVATION:
JWN$l0Y hllT[W $fkAA)/I[ ((AAlf D)MFA/D6AM Do A)nr A1ATM WAbbnf AThW FARED BY: l A U N db7ffA) Y Y Y b 7 g1 PART 2 OBSERVATION CLARITY, Cot:PLETENESS, AND ACCURACY REVIEW
- 12. COMMENTS / CLAP 7 FICATION:
,114MI { l l 13.5U17ABLE FOR FURTHER PROCESSING: } ,ggg l MO l_ - l Sten &ture# D. Fm ( eV. 5) 0353J-2 E0000,487
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- 1. OBSERVATION NO._L5i. fr 2
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- 4. SYSTEM (if ILnown): p.
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- 6. UNIT 1 M UNIT 2 l
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- 10. DESCRIPTION OF OBSERVATION:
$Y ADM /7Tm A>n 4 /s DAt's in f1) AS,^ A smx.)D,4pD i $3/710 SOA OS011)l/$ A $l6 hll. A1 7/EE A(.} M 7')))( r s i A <memJKD aAmp NAS AEFA) /Kra0 ME'JS$, j
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- 12. COMMENTS / CLARIFICATION:
A/d#E l l l O l 13.5VITABLE P'* FURTHER PROCESSING: 14 I g gq g Bienatur / e i l o3530-2 DCAP Porn 06-1.(Rev. 5) E0000489 I n
O V DCAP OBSDV> TION RECVRD Page 1 of 3
- 1. OBSERVATION WO.CM
- fr - : w. - PART 1 OBSERVATION IDEWTIFICATION & DESCRIPTION 2 DESCRIPTION OF ITDi(E3uipent. Material, Component Procedure):l3. PACKAGE NO. .rq,J Ect t.; _j-y; pg ;rp.7 g q.,. g ,y . g.,,,. 4.SYSTD'. (if known): g
- 5. CHECKl.IST/ITD'. WO.
3t fr-2 / ~ M . SU r SEWIDE RE
- 6. WIT 1 l
l WIT 2 I COPOON 0 l l
- 8. E; EF.Eh" 9.OBSDVED DURIW:
g [ N Reinspection Imp l e::e n t a : 1o.. g g N CSR l l RPSR l,, l RSCAP Documenta-I'VA'" I tion Review l l Other 10.As > o s ts co p Pn95-D R A W I f0C, OfM F:r TE D T n DESCRIPTION OF OBSERVATION: f rd B f c AT r:. AM prD n ifl o M A L Ex MOT h M vF frE; 6 - h T U R rd (4 0 L K t c= \\l27d DDL CATR LlX, %W> f dA T4 AT Q OOT Q+no I D f% E I K3ST%lJ ED o d car u Gi oG Af: nn: rne w AOr K1 F /W:e ic osT r UsT:- RorTioNS 12pon ilaG TMr~ fu t i TE Ms ou t M E. 5 o FPD12s' BG t j <;,TPO oN T 74 F:- RAM j""EU
- Signatufe Det PART 2 OBSERVATION CLARITY, COMPLETDIESS AND ACCURACY REVIEV
- 12. COMMENTS / CLARIFICATION:
AGAM O
- 13. SUITABLE FOR FURTHER PROCESSIE:
14.R IEVE gg g .~ % Am /-41~ a g g g sienatur/ Date 0353J-2 DCAP Forn 06-1 -(Rev. S)
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- 1. 00$DVhT100i bio._Id I T i 1.* - -
DART 1 GBSERVATION IDDrf1PICATION & DESCRIPT!W 2 DgSGIFTION OF ITpj(qup-en,t.h, L%.:.~i"it: ICES L~.Ma t e r ia l. Ctepone n t. Pr oc ed u r e Lc.:. 1 ? '.i
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S. CNBCK1.137/ ITEM 900. 4 l ' ' " _ -...:, 3 I* 8UPPO*T 888V3CI 8'
- 6. WIT 1 @
UNIT 2 l-l CceecW 0 l-l ~ too. c : s. + - A,. s-
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,.0.Servso DunlNG: l_l Procedure Revis - @ teinspection Implementatior. g g ~ l l 3 Csn I_l RPsn l_l as:AP - Doc menta-gg gg tion Review i
- 10. DESCRIPTION OF OBSERVAT10k':
} E. L CF W A T C n' '. Cat.t Mr A .Y ' t. St. AEE R /.5 En.R v TE EE !*.;TCLLEC. C } C C *.; G tv b i: Tub:LY ZhiTC:..i: ) M -.A SfunKlure ' T l 3 i l PART 2 CBSERVATIChi CLARITY, COIFLETEWESS. AlfD ACCURACY REVIEW 12.u.- 6dTS/CLA31PIchT1Caf: A/04// a p 13.su1TAsta rom FURTHER PROCES$1tfG: g g' 14.BEVIEWED gg -/L1 '_'~ m sierfatursf mate
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DCAP OBSERVATION RECW D Page 1 of 3 f3 U
- l. CBSERVATION No._Cff./.h? J c l PAE T 1 OBSER/ATION IDENTIF] CATION & DESCRIPTION 2 DESCRIPTION OF ITEM (Qulpment Mater al,Cceponent,Procedy j
leses Sol A/* 4 f A 4 S e p. O -/c$e3cz.AL/ fff-c ff./.st). 3. e e
- 4. SYSTEM (if kno.in):
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- 5. CHECKLIST /ITEP c 3J' / 4 3 e r ( )
- 6. UNIT 1 ld UNIT 2 l
l COMP.ON O l l I[$#IC
- 4. ELEMENT 9.OBSERWD DURING:
g l M Reinspection g Implementat g l d CSR l-l RPSK l l RSCAP Docu.enta-I- ! tion Review l l Other
- 10. DESCR1F710N OF OBSERVATION:
&_WA %,l\\e f AhnelrtIo l re ll> k r fr "y 4 E 4t ') c '-l ] 6, o e l<s a, f i r,3 fo //d /3f y 3 72 X 3 Ya, ' ' o - & "4 &. {1 _ i](m /o en @, ll e /A s he o :a l ev. I s fr N k 3"X 5A o'-I' 1 G.
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k s<e. aa y, x.s x3 x e - i vm.. D BY: Venature o FART 2 OBSERVATION CLARITY, COMPLETENESS, AND ACCURACY REVIEW
- 12. COMMENTS /CLARTFICATION:
Mo>I l
- 13. SUITABLE FOR FURTHER PROCESSING:
14 BY: gg g 81'enature t i 93W-2 BCAP Porn 06-1 (Rev. S) .E0000492 l
ScAP DesEWATION pretso O Page 2 of 3
- 15. CBSERVATION po, C 5 / J d? f.h, PAP 7 3 EVALVATION & D M IWATION OF VALID)TY
- 36. RVALVATION ll.DETEAMINATION OF VALIDITY:
a, A f / t' 1 e [ /l o O l tr e * //e d l, l IWALID An erd nrm ufe rr, Ar Vle ued g ad D frund /o Ae c /r a, n, r e m,r4 /s ard n,, e > > a n. + e. / /$ 6 (Pr V& f/O tA 99 N t f f 2+f/11 PY lc bp. \\/d lrd beSed eN en f e die U n l' fA s.$srors,) od 2o A/dv s s > r e s h1 nd rleA s c h/. TA, r r vie ns is a < c.exJue frJ /A O Q cc n ro.lo.>,e r sai fl ,D rere d p H A C A f - O L. P e nf d crfst /s 4.1. 3. ^ $b)N l-l$-[f 18.EVAWATION & DETEltMlW SY: Sienature 3
- 19. ACKNOWLEDGED BY:
- 20. REVIEWED BY:
- 21. APPROVED BY:
O Sienature Date Il Bienature Detel Bienature D4 SCAP Porn 06-1 (Rev. 5) 0353J-2 E0000493
DCAP OBSDVATIN RBCes_n Page 1 of 3
- 1. OeSERynfloW tso. T T 17 2..'
l PART 1 OBSERVATION IDDfTIFICATIN & DESCRIPTION 2 DESCRIPTION OF IT m(Bquipment. Material, nt, Procedure):l3. PACKAGE eso. o u :. eg, .v t-c.;.g s tx:..- . :cuy: y.v g-n - -. rr : _ e
- 4. SYSTEM (if known):
- 5. CHECKLIST /ITm aso
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- 6. WIT 1 M
UNIT 2 l[l COPMON 0 l[l I*[8 r.-
- 8. ELEMDn 9.otSERVED DURING:
-g_l Procedure Revii @ teinspection g Imple=entation g-Dooment a-Review CSR l l RPSR l_l RSCAP gg g-l Other tion Review
- 10. DESCRIPTION OF OBSERVATION:
p, m 9 5. g d.m f.. n / '- / Fw [n m L
- q. c s i. d +.
% / 'm v n y/ a J.;} ~. - ~ ~ + :s 7 n:- O / ,+y j 23 ~ Stefathre Det PART 2 CBSERVATION CLARITY, COMPLETENESS, AND ACCURACY REVIEW 12.w - m a s/ CLARIFICATION: A varinturecd E's' W h e *C %EJac r Diree-iad 70 fr o-7Jg'$r Bk.) w e.c.*< ss O-o 3 "our o s rot.cne-c.xs 12 xces n w a, so,rkas ga.c ss <- s o TotseAu 200 /1 VstrocM l l
- 13. SUITABLE FOR FURTHER PROCESSIssG:
7
- 14. REVIEWED BY:
O%$ /-24-t Sienature Date E0000494 BCAP Porn 06-1 (Rev. 5) 9353J-2
p) DCAP OBS D VAtioN RE M RD x Page 1 of 3
- 1. OBSERVATION No.r$E ' a t ~. ~
PART 1 ossERVATI0W IDENTIFICATION & DESCRIPTION 2 DESCRIPTION OF ITEM (Equipeent. Material. component, Procedure):l3. PACKAGE NO. fti 2:r:
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t,, e m i s-s t,x t s T.1. rr 3. ; - 4.SysT&. (if known):
- 5. CHECKLIST /IT &. po.
c-CEr._.m.3, n /2
- 6. UNIT 1 N
UNIT 2 l l COMMON 0 l l ~ SER CE RE;
- 8. EL&.F.C 9.OBSERIE.D DURING:
l l Procedure Review N Reinspection Implementatior. g~g ~ N CSR l l RPSR l,,_, l RSCAP Documenta-I"1" l_I ggen,,yg,,I l Other
- 10. DESCRIPTION OF OBSERVATION:
,.s r__~_ 1 6 4.i ? P _ O N Tr \\d 6 T r.' r %.~
- SWW C m' C.C. N WL 70 '.nl Bs-JU_
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- WT.63C&5 W.WLD Mib'-3A S It.IV. 'i'G '/r M5Bw 6 i sienature Date t'O S" W T M E PART 2 otSERVATION CLARITY, COMPLETENESS, AND ACCURACY REVIEW
- 12. COMMENTS / CLARIFICATION:
A/81/d'
- 13. SUITABLE POR FURTHER PROCESSING:
14 I 3 ygg sieniture/ Date 0353J-2 BCAP Poru 06-1 (R W. 5) E0000495
r., a u -a-a a. -n-- J M CSR ~: -M -3. - C.\\1 -1 At t a chtten , Page tof ) un,;w O l_ J_. sn i v Tmtv_ i w, s wt,ve T m i I L_ <~ / \\ \\ P\\E QA%f W i \\ / /. ~ M._ l ift.- :: O E0000496 ,r ,--,,,n
BCAP OBSDVATION RECORD Page I of 3
- 1. OBSERVATION NO.C32 I-(T. 3 L 1
PART I OBSEFVATION IDENTIFICATION & DESCRIPTION 2 DESCRIPTION OF ITEM (Equi,peent. Material. component, Procedure): 13. PACKAGE NO. 1,F E E EIE f.:'. r.', ' O C - E S #M C5 DM t m-I R - 0 2 C 9'. h-St _.rr-3.c-- ..SYSTD'. (if known): qp
- 5. CHECKL1ST/ ITEM W
( $ I '. re. 3. ',n,
- 6. UN1T 1 d UNIT 2 l_
l COMMON 0 l_l I.,.$..E WICE po
- 8. ELDtENT
- 9. OBSERVED DURING:
g g pg M Reinspection Implementatio g g M CSR l l RPSR l_l RSCAP - Doewnenta-g g g g tion Review
- 10. DESCRIPT10N OF OBSERVATION:
A0/7) /'AUS CDL A /1322'/ 7, f/FM 3) A /LM14/ a}As 25p)) jyg of 77tE W8x/7 DAAS7'JAJC, C/?/26R /Al Sf6 U - Sff AAiv2AfrAJ7~ / ARED BY: n u r m a u -a7; o m a u ,,,.a%;"%p PART 2 OBSERVATION CLARITY, COMPLETENESS, AND ACCURACY REVIEW
- 12. COMMENTS /CL.ARIPICATION:
NoA/#' O
- 12. e1TA LE OR PvRTxER >RoCESS1 e:
l1 > M 1 d: <.REV1EVEe m Signature De t. 035M-2 BCAP Porn 06-1 (Rev. 5) E0000497
C S '. - I - M 0 21 - l Attache.ent), Page) ofl 1 ) ,4 _ AcrumL. MCA50tEMCWf 3 as secocaM " J' 'WOUc a#rc DRNiuc. f I f ~n 1 84 i i, i. i i e i l' gl I ' il .s
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- 4. SYSTEM (if known):
- 5. CMECKLIST/ITp3 Wo R's' C4I 1-m i-Cil i -
- 6. WIT 1 S WIT 2 l
l CCP90W 0 l l I 8E","CI I r, n. S. ELEKDIT 9.0tSERVED DURING: l-l Procedure Revi @ Reinspection Implementation I I teview @ CSR l_l RPSR l l RSCAP Doc 1menta-g g g g tion Review
- 10. DESCRIPTION OF OBSDVATION:
TCA " Ot t..:. m F P.E 7 5 ' 's ', : Si Y "
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- 13. SUITABLE FOR FURTHER PROCESSIWG:
14 g g Siedatu/e Det BCAP Forn 06-1 (Rev. 5) E0000499 -2
m bCAP OBSERVATION RECORD \\ Page 1 of 3
- 1. OBSERVATION WOfl ' F 2 1-2 PAJtt 1 OBSEPVATION IDENTIFICATION E. DESCRIPTION 2 DESCRIPTION OF ITEM (Equip: sci ~ent. Material. Component. Procedure):i3. PACKAGE NO.
fe.- " U to:t. 16 ' 3 I.i.a. L )/.
- P I T. 'e *. '" k E-H e mg.,. s.- 7 9.
- 4. SYSTEM (if kn:vn):
s-
- 5. CHECKLIST /IT&.1 2 1...n 7.c..
- 6. WIT 1 M
UNIT 2 l l COMPCN O l l .S T SEWICE
- 8. ELEF.ENT
- 9. OBSERVED DURIW:
l l Pr d u Ro b d Reinspection - g Imp l e.e.t a t ic g N CSR l l RPSR l_l RSCAP Docur.enta-g g g tion Review
- 10. DESCRIPTION OF OBSERVATION: C D6Cf4 /O Uf /O(4T/OL/ Of [gfjggg PMTE5 PER VEUDOE CAD 7 LOG 95
/5 Vv' F/OM T4E &/D W 7Ne OtKwfL AH970LY, &EIN3 PET /]N /E Ldf[N!K FUTf1 M( LOCArgD ti' );Cfn T/.:5 EL D W T) E CMLAEL 4.5 F/VoLY. DiftMi/UD lil1LMLL7 (W.~ /1][Qdl'I(Al MCliAA. l Sic M ure t e PART 2 OBSERVATION CIARITY, CCMLETENESS, AND ACCVRACT REVIEW 12.COMMEWTS/CIARIFICATION: A/wE l l l
- 13. SUITABLE POR FURTHER PROCESSIE:
14 I ygg gg Siendturef De I I""' 03530-2 gD000500
O EVASDVATION BBCCRD Page 1 of 3.
- 1. OsSERVAT1oW po. 6 ~ W i.'--
PART 1 OBSERVATION IDENTIFICATION & DESCRIPTICW 2 DESCRIPTIoW or ITEM (Equipment, Material,Ctaponent Procedure):l3. PACKAGE Wo. ts.: nti e*.-
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At _ r i. %,
- 6. WIT 1 N UNIT 2 l
l CorpoW 0 l[l $I 8ff
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- 8. ELEMDIT
- 9. OBSERVED DURIW3:
l_l Procedure Revi @ Reinspection Implementation g g b CSR l l RPS% l l RSCAP ~ I'VI'" l Documenta-tion Review ! - l Oth l
- 10. DESCRIPTION OF OBSERVATION:
b) ME NS IOM 6MOllM FROM 4 AF14 m To 4 of: Ron 15 3.52 3/g " AcroAL D i meE Ms I ON> i s 3 ' I O V." 2 O ~ '# M " M~~ Sienatut4 De FART 2 CBSEEVATICW CLARITY, COMPLETEWESS AND ACCURACY REVIEW 12.CopperFS/CUJtIPICATICW: A/ME O
- 13. SUITABLE FOR PURTHER PROCESSING:
14.R M l_d / A. _ ad M3 BienaturV De t.
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035 > 2 E0000501
DCAP OBSEPVATION RECORD Page 1 of 3
- 1. OBSERVATION WO. bi !-O ',' f f.,
PART I OBSERVATION IDENTIFICATION & DESCRIPTION 2 DESCRIPTION OF ITEM (Equi,peent. Material,C nent, Procedure):l3.PACKAGENO. LFI~C Lf r4 t,,*;. I G gg p t.: h f > 7,7 (A;X.s iFw!=I:(;5 0. tg(. rr.1-C -
- 4. SYSTEM (if known):
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- 5. CHEOKLIST/ ITEM NO CS R.'. M 1 t L 5 / 3
- 6. UNIT 1 M
UNIT 2 l l COMMON 0 l l JjEWICE R
- 8. ELEMEh'!
- 9. OBSERVED DURING:
l l Procedure Revi M 1 Reinspection Implementation g M CSR l l RPSR l l RSCAP Docurnenta-g g tion Review
- 10. DESCRIPTION OF OBSERVATION:
/ TEM : N ls / Y- /L /C !)( C D // ? /T A;O CS$$Y l d o 7 / 'S'1 ena t t#e Det PART 2 OBSERVATICH CLARITY, COMPLETENESS, P.WD ACCURACY REVIEW
- 12. COMMENTS / CLARIFICATION:
A/C# O
- 13. SUITABLE FOR FURTHER PROCESSING:
g3 g 14 I -_ + w pte siena'turer cate 035u-2 eCAP Poru 06-1 (Rev. 5) E0000502 +
O-pCAP OBSDVATION BBCORD Page 1 of 3
- 1. CBSERVAT1oW too. 's- -. S' ? " - -
PART 1 OBSUVATION IDDf71FICATICW & DESCDIPTION 2 DESCRIPTION OF ITEM (Equipeent Material.componentaProc.gourg-),e:l3. PACKAGE 3s0.
- S.
Sc_ s 5. t. iG
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- 6. UNIT 1 kl UNIT 2 l
l CopMON 0 l.,,,,,,. l I.;87I3 84
- 8. ELEMDIT 9.08 SERVED DURING:
l_l Procedure Revien Z_ Reinspection Taplementation g g [i<,,,3 CSR l_l RPSR l_l RSCAP Doement a-gg gg tion Review
- 10. DESCRIPTION OF OBSERVATICW:
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- 13. SUITABLE FOR PURTHER PROCESSIIIG:
g 1.1 s br / K-sianature ' Date 1
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O BCAP OBSERVhfl0W BBCORD Page 1 of 3 t
- 1. CSSERVATION Wo.L 9 ?_ rr 2.
PART 1 OBSERVATION IDENTIFICATI0W & DESCRIPTION 2 DESCRIPTION OF ITEM (Equipment. Material Ccaponent, Procedure):l3. PACKAGE No. .,ct M E E t? ' ~'i ~. P E 5'52 5 Ed '* M : P ~ 2 - CM '.' R'O CSC I fr 3-Cr_ 4.srsTEM (if ILnown):
- 5. CH3CKLisT/ ITEM >
F.- a t.q.sy. 3., -
- 6. WIT 1 M UNIT 2 l_l CONOW 0 l
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- 9. OBSERVED DURING:
l ,_l Procedure Res @ Reinspection Implementatic g g @ CsR l.__ l RPsR lZI ascAP g , Doomenta-g, (( tion Review
- 10. DESCRIPTION OF OBSERVATICW:
'INTRUOM 3.t BT C5R-1-Itd,MN t 1%SE WkTtMOSTYM MTDC GTTk1IN3%.YUis.de 3 MT. THE 5ects. P6%1DDO:51D 6%"TVE. Liu 7 tis'.TIL45 CMW). iDR<u3v,% ctti ITin* 6 (1tLO Ks:a i % w_Mu e MWm F chT sir wis %i 1, tn M w% nn. MW.vu 3 M%%4 Wh\\hMtt A Gs kCtTt GE hc 5/3' ktW76 MTL %WD 'IMiku2D.3Ji.
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- 13. SUITABLE FOR FURTHER PROCESSING:
' ~/' 14.REV1 / ,.2 Sienature' De " ' "'I I' 'I e35u-2 E0000504
i 1 SCAPESDVM10R JMED O. Page 1 of 3
- 1. OSSERVATION Wo.: ~. W e
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- AGE No.
5 c c., E: r J ! - - s t.z. : r,. y_ r_ c r. t1 c., .,v..,.:-
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- 5. CH.2C_KL!sT/IT,E.,M no.
gr.. p_, _. n..,
- 6. UNIT 1 W UNIT 2 l.,,_, l COPMON 0 l.,.,__ l NI f, RE 1
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- 9. OBSERVED DURING:
-ll Procedure Revie bl Reinspection Implementation gg [xl CSR l l RPSR l-l RSCAP Review Doement a-l _l tion Review l l Other
- 10. DESCRIPTION OF OBSERVATION:
'a ' DIIVE h3tth Ih PELD 15 / /. DCit&to A'ECu *RES I *!r. : ' : ~. L .%>- c, c q__. t /
- 4..g a* q DE 'A':. - A Uht.G = F12!!OPC, L NE "' d:1 9 1thature Det PART 2 OBSERVATICW CLARITY, COMPLRTEWESS, AND ACCURACT REVIEW 12.CopMENTS/CLARIFICATICW:
A/OA/8 13.BUITABLE FOR PURTHER PROCESSING: 14.R R: g g 's .e4 4 /- 25"- i SiendturV Date 03533-2 " ' ~1 I"* '3 E0000505
' """^ " "'c= " CD Page 1 of 3
- 1. OBSERVATION WO.CLf ! /T /
PART 1 OBSERVATION IDENTIFICATION & DESCRIPTION 2 DESCRIPTION OF ITEM (Equiptent, Material, Component, Procedure): 13. PACKAGE NO. 5,rf.P! L Tcri P:q $J Fic t '5 b).L S m 1.1'Eiu' D i t 'e. C SE T. t r. 6. n -
- 4. SYSTEM (if known): gI
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l c 5 0 ?_. m. 4. c 3, *
- 6. UNIT 1 N UNIT 2 l
l COMMON 0 l l
- 7. SUPPORT SERVICE No. t.r.
- 8. ELEMENT
- 9. OBSERVED DURING:
l l Procedure Res l)2$3 Reinspection Impler,entatic g g M CSR l l RPSR l_l RSCAP Docurnenta-g g g g tion Review
- 10. DESCRIPTION OF OBSERVATION:
EL? / MCu/PEC1 IK F
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- 13. SUITABLE POR FURTHER PROCESSING:
- 14. REVIEWED R
._Al a k. g g g Sienat'ure Da* 0353J-2 BCAP Porn 06-1.(Rev. 5) E00005t 6
PCAP DBSDVhfl0W BBCORD Page 1 of 3 1
- 1. CSSpVATION Wo.D7 _ m..~ '-
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- 4. SYSTEM (if kncwn):
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- 5. CHECKLIST /ITzn No.
CM _ T. 5-M w
- 6. WIT 1 C>
CSRZML [ STIM *4 (Hit' U5T /NJTAU(11MS.
k /. OV/-3085, /ND/V/buAL MST/UCT/M 70EKNINS/EODC kM1 GMHMtARVE 7b NM6EE IVXJEARWOE) Ftt'Mb Duk/N& 7NE REVER/fKATKW: latDtfIRELEMimENA. E.B 70 m TM77AF/NAIN& MJ ARR/AU7ANE T0 /#1Matx 7ECHM&ME, 7NAT F/NNNfs MS D/XU15Eh /NDETAll 4)/7N 7HE RBk3V1/All /NNV/bORL. ERCN /NLGVEb /N1/ECTQt LMDEASTANb5 7NE NATUAE ANb DETA/t3 LY TM bYJE/AAC13 Ays THE 17ZHNMUE DBLE/1MOTEo TO AfEVENT MG2/EME.
- 2. CW/ 3/ B58 A 6At2bo.SESS/M Ut3 PRESENTGb BY MYJELT 7D A60V/bE FEf.WCK M l
THE KElX.75 M7NL MVER/fKATA3V. 7K SMT/fK 1.E77EA AWb M7EN7lY/M /WCK-1 E/17 /NS74tr770V1 lufAE 2VXUSSEb /NDETR/L. 720 CSR FAf/ MEAS kKK M AW-ENMME. Au Gt/EST/MS ENSEA /tXML RNViMb 70 R)Y S4T4 FACT /6N ANA TRATar 7M /NS!lt70tS. l'
- 3. I AM CtWF/MNT THAT A (2 EAR Mb (M/h3f/1 (MMAS7RMN6. 07NE REM /AEMNT1
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- O E0000523
N & oNo w o co j TRAINING SESSION p% c i*e-s-a c e sN-1.x-3 ' Date; i v.es O )ect; m-r.x.2. ouration:
- a.,
<mmm - z,-c m.- BADGE PRINT FULL NAME N O. DEPT. SIGNATURE Bi //, Mse v 2 s-o-1a( 18 CAP D10% -- d Seu A% sir-r*.esr-and WW/d 1-v c ,, / v he
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c.e-Pcge I cf 1 O Areas of guestion or concern 1. Cat Inspector identified that a 6* angle iron stiffener specified on the drawing and the Bill of Material ses not installed. BCAP Inspector had reported this piece inaccessible for verification in the checklist Remarks coltaan, due to its parent in place beam being boxed in. (M-003-032) 2. CAT Inspector identified that the shelf bracket angle irons for the supplementary steel on one support were not the specified size or weight. SCAP Inspector failed to transcribe this observation from his notes to the reinspection doctamentation. (M-003-008) - 3. CAT Inspector identified that a welded attachment to in-place steel on one support was incorrectly located. BCAP Inspector failed to identify this discrepancy. (M-002-054) 4. CAT Inspector was concerned that instructions did not provide for verifying specified location of support attachments to supplementary steel (Generic) e i O 0828J E0000527
t. *- t " P ". 51" Attachsint 2 Page } of 2 ' O Reverification plan i 1. Checklists to provide for reverification of the characteristics identical to or similar to the areas of concern are to be developed by the BCAP Mechanical Level III Inspector, and approved by the Inspection Supervisor. i 2. Inspectors involved in the reverification are to be provided with instructions to assure a complete and uniform understanding of the attribute areas to be reverified. Specific training on the use of the reverification checklist and applicable CSR instructions will be provided. 3. Control measures are to be established to assure that no inspector 1 will be tasked to reverify his/her own work. ~ 4. The inspector performing a reverification is not to be provided with O the results of the original inspection. He/she will be furnished with the applicable drawings, instructions and the reverification checklist. The reverification inspector will not be made aware of the identity of the original BCAP inspector. i observations mad [ by the reverification inspectors will be compared l 5. l with the results of the original inspections by a team of specially designated inspectors. Where an observation is made during reverification which was not made during the original inspection, a certified Lead Quality inspector (Mechanical) will reexamine the subject characteristic to determine the validity of the new observation. If valid, the new observation will be processed in accordance with current BCAP procedures. If the new observation is determined by the Certified Lead Quality inspector to be invalid, the reverification inspector will be shown, to his satisfaction, the reason for the determination of invalidity. The reverification inspector's acknowledgment of invalidity will be doctamented on the reverification checklist. Contested new observations will be processed in accordance with current BCAP procedures. O l E4000528 0828J 1
~- 'ge, g .. o. g3r i ~ Attcchment 2 Pcg2 2 cf 2 4 ' O 6. Results of the reverification will be analyzed to determine individual inspector or group deficiencies. In the event that such deficiencies become apparent, appropriate instruction or training will be developed, submitted to BCAP Management for approval, and presented to the inspectors. At the time of decision that additional training is indicated, further support inspections by individuals or by group will be discontinued until such training has been completed. 't. Support inspection attributes outside the scope of the NHC CAT questions and concerns are not addressed by this plan. 4 8. Documents controlled by BCAP procedures initiated or corrected as a result of this plan will be processed and retained in accordance with the applicable procedures. 9. Checklists, notes or cther documents initiated as a result of this plan but not controlled by BCAP procedures will be processed and j retained as directed by BCAP Management. Forms to implement this Plan are attached. o l l l O 0828a E0000529 l i
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6cM rw o m o 87f AC H M E vr 4 OV January 31, 1985 BCAP Memo #593 TO: R. L. Byers FROM: G. M. Orlov
SUBJECT:
Observations resulting from Pipe Support Verification Plan The additional observations generated as a result of the BCAP Pipe Support Reverification Plan have been reviewed. It is apparent from this review that the BCAP inspections should, for future inspections, continue to verify dimensions of vendor supplied " catalog" items,that constitute hanger assemblies in the manner in which these verifications ~ vere perfomed during the " Reverification" activities. This action will provide assurance that pipe support components are installed in accordance j vith the specified design and will address questions identified by o the CAT. kN G. M. Orlov 4 BCAP Assistant Director GM0/jan ec: N. Kaushal M. Clinton BCAP File QG 69.60.3 O 1 E0000536
bCAP (nf M 0 5f ~7 1 hvMHm L cr 5' O Date: /Xd5 l To: HliNZO EL/M704f FROM: Ed Shevlin SUB3ECT: ESfI-MZ > CSR-Im.L ESEI/Ihc l'NEfk037 /M1TAUCTIMS. /. M/-3045. /ND/V/ burl Mf71U(7/M TOEKNINSPECIDC hM1 GMNfilARVL Tb HM6El ZVXJEMNC/L3 F0(Mo Duk/N& 7NE REVELIFKATAW: MatCAEIREllM/MENA-Eb 70 )t%/ TMTAFMA/Mu WR1 ARE/407ANL 70 /NJ/EC/M 7ECNN/GLE, 7 HAT F/NNNfr /LMJ D/Xu15Eh /NDETAll kMTN THE RBKW1/ ALE /NNV/blML. ERCH lNLO'VEo /NJ/ECTM UNDERSTANb3 7HE NATUAL ANb DE7R/l3 & TK Mr/EPAKY.o Mo THE TECHN/GUE X7M EllND/Eb TO MEVENT RfAR/EME.
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9 O Date: //249 To: MENlo (Uh70N FROM: Ed Shevlin
SUBJECT:
NRC CAT T/N3/N6.5
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i l'ORRECTED CDPY- /EM 5 Date: / //dr i tos N)EN2O Cl/NTM i FROM: Ed Shevlin
SUBJECT:
NRC CAT f/NDINGS l. M /5X 0&MSK. NRC F2tWA A NELAE.A BCAM AWArNMENT.5)G
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s EMPLOYEE EVALUATION fem Z TNoM' Sori mADaE e 5t2 74 63% LtvEL M uAnE Enter (S) for Satisfactory or (U) for Unsatisfactory EVALUATION DATE: _ /"/8-86 on applicable line: (1) Knowledge of Procedures, OVERALL RATINO (Check one): Specifications, Codes, and Standards 1 SATISFACTOf'.Y (2) Knowledge of duties S UNSATISFACTORY (3) Performance of duties s (4) Recuracy of reporting duties 5 O LIST SPECIFIC PROBLEMS NDdC NC *Jos. Cs e-I-M os, o34, coa,., pegr,,a A.as Co M Fb uo NT IJ8 MC MS' ous REMARKE-C s 32-1-M - c3 - OS 7. C 5 P-I-M -oz - o 33. c s e r-M -oc - c; 44. D a/M ids pec 7po a.3T s ha t knm 6 4 NWC CAT &go,g (,5 EVALUATOR S TITLE /E#6 O//N/I//4/5//<T04 EMPLOYEE SIGNATURE /Af771 NM 47' DATE /-/S -# I ~ V ~- V 1 0 0043J E0000724
O EMPLOYEE EVALUATION NAME ! 0-S BADGE 8 f2I'80-f0STLEVEL 7 Enter (S) for Satisfactory or (U) for Unsatisfactory EVALUATION DATE: /- /f-/[ on applicable line: (1) Knowledge of Procedures. 'OVERALL RATING (Check one): Specifications. Codes, and Standards 5 SATISFACTORY v (2) Knowledge of duties d UNSATISFACTORY (3) Performance of duties 5 (4) Accuracy of reporting duties 5 LIST SPECIFIC PROBLEMS NONI lwfM/MADaW f 8MUfM7 b/ff4MAest lYS. Ab. fS/.7-A-6/-O& REMPRKS Q'l.~7A5}9t*7d, W/#f//AffD EV #At-CAY f/Nb/un f. EVALUATOR, 2--s / TITLE
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9 O EMPLOYEE EVALUATION NAME // 3-JOM/0 BADGE e 523.&.SeSp g,gygt 7 Enter (S) for Satisfactory cr (U) for Unsatisfactory EVALUATION DATE: /- '8'85 on applicable line: (1) Knowledge of Procedures. OVERALL RATING (Check one): Specifications. Codes, and Standards .5 SATISFACTORY (2) Knowledge of duties S UNSATISFACTORY (3) Performance of duties S (4) Accuracy of reporting duties S LIST SPECIFIC PROBLDiS OM8 w r.c,arn rios.' nac CoM."cs% 7 DwMa'.yesvs fkG dos. C:r-7-F1 oc -o % REMARKS CSP-I-M-c3 oc 4 RHO Cs F 1-M- 0 6 -02 6-o vtw wspec he d s Tursanre-D 8 'l N2C cpi ~ fir'DiWG ~3 l EVALUATOR M'T / TITLEI4B [o'We7/ /M54#4c h DATE / f~ J-EMPLOYEE SIGNATUREa i / i / i I l l O E3000'726 00433
d EMPLOYEE EVALUATION alAME 8N I 4M'50 A/ BADGE 3 5 2 74 6384. LEVEL _ ll Enter (S) for Satisfactory or (U) for Unsatisfactory EVALUATION DATE: _ /-/5-8.5 en applicable line: (1) Knowledge of Procedures. OVERALL RATING (Check one): Specifications, codes, and Standards 5 SATISFACTORY 12) Knowledge of duties _5 UNSATISFACTORY (3) Performance of duties s (4) Accuracy of reporting duties S T-IST SPECIFIC PROBLEMS NDdC g a,,w ec,,a u o con % c.~T De Ma avoe A:G an. c.:se-I-m.oc aq, -EnnnnS c s u-t-n - os - os 7. c s e-x-m -os - 0 33 c ae r-n -oc. - o 4 A. O wn ins pec Tw a.:sh ha t uren 64 Nec CAT Racis c, s. ~. N LUATOR TITLE /E#O O//N/I//4/5/h704 _. rriPLOYEE SIGNATURE /N9ff t*77,7/7 N [#~ D?.TE /-/SO/I l l O , V ~ *
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EMPLOYEE EVALUATION BLAME S BADGE # flI'80*f0STLEVEL 1 Enter (S) for Satisfactory or (U) for Unsatisfactory EVALUATION DATE: /- /f-(( on applicable line: (1) Knowledge of Procedures. ~ OVERALL RATING (Check one): Specifications. Codes, and Standards I SATISFACTORY v (2) Knowledge of duties S UNSATISFACTORY (3) Performance of duties 5 (4) Accuracy of reporting duties S O LIST SPECIFIC PROBLEMS NON/ i REMARKS AEK/124&aW l 8#UfM7 SJ1fAMAest SYS Ab. fS/-I-A-64-06 Aw/.7AMJWry 9%iWeVsFFD 20146 24Y f/Nbmnf. EVALUATOR .2 - - er Mre / TITLE ed JA,jhp 7 l EMPLOYEE SIGNATUR A M# DATE / J 85~ ~ / / \\ r O E00007?s co433 ,_.__-_.,_.--._.,________,____r___.___,.-
1 l O e EMPLOYEE EVALUATION IIAME /A 6-40' ' BADGE e S U.go.9 59 LEVEL f Enter (5) for Satisfactory or (U) for Unsatisfactory EVALUATION DATE: /-45-8 5 on applicable line: (1) Knowledge of Procedures. OVERALL RATINO (Check one): Specifications Codes, and Standards 5 SATISFACTORY (2) Knowledge of duties .5 UNSATISFACTORY (3) Performance of duties S (4) Accuracy of reporting duties 5 O LIST SPECIFIC PROBLEMS OM# coaric,veo rio,.' nac CoMPes'ex 7 DiNrn'stosus fcG. Mcs. cw.y.M-ot -c t's, EEMARKS CSP-I-M-45 oo4 AND C5 P I-M- 0 6 -02 8. O L 't? /NSPt-c7 sed sitMaleVfD 8 Y N I? C CAT ~ f/h'Dir'G ~3 EVALUATOR U / TITLElI#O 8v4/r7/ /N5/d' &> , M/ EMPLOYEE SIGNATURE DATE / f~ r- / I lO tocoor.2 l 0043J
1 ~. f. O 1 Date: /.//A5 1 I TO: MENZO llAYTOY FROM: Ed Shevlin SUB3ECT: /MECN/ WE/) /MSPEt'TM6129M(LUMz /. NK (MRIN1PECTJM1 FOR DECEMBER.'NO Ot4CITA3VS at tthWERNS. L NfC (AT FINSNGS: THE BffEZENCES RETuMEN BCAP RNA CAT /NSPECT/M KJtXM - h K A E B K t4EEb. i i 5 SOHC Snt/1. BatL PIMNG ANA INSTRIMENT TibNG POPlXAT/06 UllBE ttNSWEb. .O
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