ML20214D609
| ML20214D609 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 10/07/1986 |
| From: | Gardner AFFILIATION NOT ASSIGNED |
| To: | |
| References | |
| OL-A-129, NUDOCS 8705210395 | |
| Download: ML20214D609 (7) | |
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instances where they include that on the same form.
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Q What's a triple X designation?
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A A triple X would be for an observation identif'al.in
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4 an item that is not clearly part of a defined populati.e... n 5
defined sample of the population.
6 Q
And is that a designation that indicates that the 7
item is beyond the scope of BCAP?
8 A
It could.
9 Q
Is there a procedure that governs when a triple X l
10 description of an observation is to be used?
11 A
I don't remember.
I know we talked about it at 12 length, and I agreed to its concept and its implementation.
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13 That was sufficient for me.
14 Q
Let me ask you generally, Mr. Gardner, did you ever
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15 identify any instances of failures to comply with BCAP
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16 procedures as an item of noncompliance?
17 A-I would do that if, in fact, the failure to comply l
l 18 would have resulted in a violation to a standard or to a l
19 clearly defined requirement delineated in some standard or 20 some document other than the BCAP procedure.
21 As somebody has stated, I'm sure, a number of times, 22 the BCAP was not a requirement for the Licensee.
They
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developed the procedures that implemented the BCAP.
We did 2
not put in a document that required every one of those 3
. procedures to be adhered to.
4 I expected them to generally be adhered to, but I 5
also expected the program to follow thIe basic tenets of their 6
original submittal that we received before the program began.
7 Q
You didn't inspect, then, to the BCAP program 8
procedures to establish compliance with those specific 9
procedures?
10 A
Ch, I didn't say I didn't.
I just said I didn't 11 cite, okay.
I would make some recommendations to the Licensee 12 if I saw that there was a requirement for an initial here and 13 they weren't doing it, something like that.
14 But I would cite, again, if they were' violating one 15 of the 10 CFR requirements, whatever; in fact, I did cite them 16 a number of times.
17 In one case -- well, in each case, you have them in 18 front of you in my records -- in one case, they did not have a 19 quality assurance inspector perform site orientation as 20 required by their procedures before he did a review of BCAP 21 work activities or BCAP procedures.
That was a procedure 22 requirement, and it also to me was a standard requirement for h
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any QA inspection.
2 Q
I think what I'm focusing on is Appendix B to 10 3
CFR Part 50, one of the quality assurance criteria requires 4
that the Licensee comply with instructions, procedures, and 5
drawings that govern its quality assurance program.
6 A
Right.
7 Q
With respect to your BCAP inspection activities, you 8
didn't cite the BCAP for instances of failure to comply with 9
BCAP program procedures?
10 A
Well, let me say, I did not find any clear 11 indications where they did.
There were a couple of 12 administrative things that they might have done, like, for 13 instance, as I said, forget to initial a form where the 14 procedure indicted that they should initial it, minor 15 administrative things, because there were a number of 16 procedures that were administrative and only pertained to BCAP 17 and how you handle documentation, who the person is 18 responsible for disseminating documents or what that person's 19 responsibility is for.
You can see that in the BCAP-06 20 procedure.
21 There are a number of clerks who have responsibility 22 for making sure that documents go to this person first and i
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that person second, things like that.
I mean, in a wide interpretation of Appendix B, you can say that if they don't 2
4 3
do that, that's a citation.
But that is not my -- in my 4
opinion, they're not worthy of a citation.
5 Q
Well, I'm just trying to understand your previous 6
testimony.
What is the actual scope of what your inspection 7
activities were?
8 Did you assure compliance with all BCAP procedural 9
requirements in the implementation of the BCAP program?
10 A
-I assured that BCAP was conducted, as required by 11 their procedures, okay, using -- but again, I had my own-12 interpretation of which procedures I was going to track.
For
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13 example, BCAP-06 was an important procedure.
But I did not 14 follow where all the administrative parts of that procedure 15 were required.
16 I did follow every aspect of termination of 17 validity, whether it was done properly, whether the right 18 people did it, et cetera, et cetera.
I was trying to clarify, 19 because I thought you were asking me, every time I saw them 20 violate any BCAP procedure, I would give them an item of f
21 noncompliance, and no, I would not.
T 22 But it would have to be an administrative type he i
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method or whatever.
If it was essential to the BCAP to be 2
performed according to that procedure, then I think the record 3
indicates that.I was quick to cite.
4 Q
Did you cite them for any violations of BCAP 5
procedures?
6 A
Yes.
As I stated, I gave you an example of the QA 7
inspector, who was required to have performed site orientation 8
before he reviewed some documents, and, in fact, he had not.
9 Q
You cited to the BCAP procedure for that?
10 A
Yes, I did.
11 Q
Any other instances?
12 A
Well, I cited the 37 observations that were 13 invalidated.
I didn't quote a BCAP procedure, but, in 14 essence, I was citing to a BCAP procedure.
15 The failure to write an observation, that can be 16 construed to be a point at which the Licensee didn't follow 17 procedure.
18 Q
Did you cite to that?
19 A
I cited to Criterion 16.
20 Q
Did you cite to the BCAP procedure?
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'21 A
No.
I think I cited to the criterion 16.
22 Q
I heard your testimony earlier, Mr. Gardner, and I t
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was trying to clarify it.
2 You view generally that your inspection standard 3
under BCAP to be the preexisting Edison regulatory 4
commitments; did I understand you correctly to say that?
5 A
That was the base document that we, as our agency, 6
understood the BCAP was going to be run in accordance with.
7 Q
Okay.
And that was because the agency dion't view 8
,BCAP as a regulatory requirement but as a Licensee action 9
supplementary to regulatory requirements?
I'm not trying to 10 put words in your mouth, but to summarize what I understood.
11 A
Well, we understood that the Licensee was going to 12 conduct the BCAP.
13 Q
R.ight.
l 14 A
They presented to us a document that outlined the 15 process of the BCAP.
We reviewed that, and we had an 16 understanding as to what the BCAP was going to be.
I think 17 you will remember, we discussed the comments that the NRC had 18 uade to that document.
So we had an underst.nding going into 19 the BCAP what the BCAP was suppr3*d to do.
It was supposed to 20 identify design-significan'. 6 01 sencies, if they existed.
21 That's the point that I followed, obviously.
And I
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22 also made sure that the procedures adequately implemented that E
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program document.
I di.d that.
I was reviewing the first
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revision to the procedures very closely,.and BCAP-06 was one 3
procedure that I, among other people, required a revision of, 4
because I didn't think it properly fit the program document.
5 So I had comments on every one of their procedures.
6 We had meetings on every one of their procedures.
7 Now once I was sure as to how the procedure was 8
stated and that it conformed to the program document, I 9
followed the programmatic aspects.
If I saw a deficiency, 10 then I would cite that, if I saw a deficiency, but I was 11 trying to say, I was not in the mode of following all the 12 nuances of every procedure to determine complete compliance to 13 the procedure.
14 It'was impossible for me to do that and at the same 15 time observe the overall big picture of BCAP.
16 MR. GUILD:
Off the record for a second.
17
[ Discussion off the record.)
18
[Whereupon, at 1:05 o' clock, p.m.,
the taking of the 19 deposition was recessed, to reconvene at 2:00 o' clock, p.m.,
20 this same day.]
21 22
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