ML20215H739

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Forwards Testimony of Jm Dominique,Pg Kosieniak & If Dewald Re Custody of Weld Test Coupons.Guild Requested to Stipulate Admissibility of Applicant Exhibit 5 & to Waive cross- Examination.Related Correspondence
ML20215H739
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 10/21/1986
From: Thornton P
ISHAM, LINCOLN & BEALE
To: Callihan A, Cole R, Grossman H
Atomic Safety and Licensing Board Panel
Shared Package
ML20215H743 List:
References
CON-#486-1239 OL, NUDOCS 8610240126
Download: ML20215H739 (2)


Text

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ISHAM, LINCOLN & BEALE r N, CO RE5PONDENCR" ,,

, COUNSELORS AT LAW ,"

00CKETED USNRC THREE FIRST NATIONAL PLAZA CH'CAGO, ILLINOIS 60602 -

ROSE T .

X 2-5288 WILilAM G BEALE. 1885-1923 312 558-5500 SV ME R 11ft0 UOP5ECTICUT AVENUE N W.

October 21, 1986 ZC P 'J ,,,d%EN C_20036 202 833-9730

' cah*",?MW Mr. Herbert Grossman, Esq. Dr. . Richard F. Cole Chairman Administrative Law Judge Administrative Law Judge Atomic Safety and Licensing Atomic Safety and Licensing Board' Board United States Nuclear United States Nuclear Regulatory Commission Regulatory Commission Washington, DC 20555 Washington, DC 20555 Dr. A. Dixon Callihan Administrative Law Judge 102 Oak Lane Oak Ridge, TN 37830

Dear Administrative Judges:

Please find enclosed copies of the testimony of Jeffrey Michael Dominique, of Paul G. Kosieniak, and of Irving F. DeWald. . Copies of these documents are being-served on all the parties today.

'The testimony of Messrs. Kosieniak and Dominique establishes that the coupons used by Mr. Puckett for his mock practical ~ examination on August 22, 1984 were the same coupons reviewed by Mr. Vannier in his testimony presented in this case on June 5, 1986. Mr. Vannier testified that in December 1984 he had taken custody of the weld coupons used for his testimony. (Tr. 3080.) He stated that he and Mr.

Kosieniak had gone to Comstock and picked up the coupons from someone in Comstock's training department. (Id,. ) Mr.

Kosieniak will testify that on only one occasion, in late 1984 or early 1985, did he go with Mr. Vannier to Comstock to pick up weld coupons. Mr. Kosieniak will also testify that on that occasion Mr. Dominique of Comstcck gave them the coupons which Mr. Vannier identified during his testimony in this case. Mr. Dominique will testify that he was present 06102401h PDR ADO h o PDR56 g3

s 9

October 21, 1986

  • Page 2 during Mr. Puckett's exam on August 22, 1984 and that the coupons identified in Mr. Vannier's testimony were the ones used by Mr. Puckett for his exam. Mr. Dominique will also testify that he had custody of them from the date of Mr.

Puckett's examination until the day he gave them to Mr.

Kosieniak and another gentleman from Sargent & Lundy.

As regards Applicant's Exhibit 5, Mr. Dominique will testify that that is a copy of Mr. Puckett's mock practical exam and that the printing is Mr. Puckett's. Mr.

Dominique will also testify that,- after Mr. Puckett completed the examination, Mr. Dominique took the examination up and laid it on the part of Mr. DeWald's desk reserved for such examinations. Mr. DeWald will testify that he found the test laying in the tray on his desk which was used for receiving training documents. He will also testify that he graded the examination on August 26, 1984 using red ink and that the written comments in red ink on the exam are his.

All three pieces of testimony are straightforward and provide ample foundation for the admissibility of the weld coupons identified by Mr. Vannier on June 5, 1986 as well as for Applicant's Exhibit 5 and finally for the testimony of Mr. Vannier given on June 5, 1986. Accordingly, I am asking Mr. Guild, by copy of this letter, to stipulate to the admissibility of Applicant's Exhibit 5, the weld coupons and Mr. Vannier's testimony in this' case. Additionally, to conserve hearing time and to avoid further inconvenience for these witnesses, I am asking Mr. Guild and the Staff, by copy of this letter, to waive cross-examination of these witnesses.

Respectfully, Peter Thornton PT:sn Enclosures  !

cc: See Attached Service List 1

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