ML20244A872
| ML20244A872 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/03/1984 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| Shared Package | |
| ML20097F079 | List:
|
| References | |
| FOIA-84-487 NUDOCS 8906120174 | |
| Download: ML20244A872 (49) | |
Text
{{#Wiki_filter:I 9ytMplTQ} jf* (( D"" ^ 7 ~" 'V[k 1-I UNITED STAFIS OFMSalCA MCCLEAS REGULATORY C049tISSION f ,l (n the matter of: TEXAS UTILITIES ELECTRIC COMPANY, et al Decket No. 50-445-2 50-446-2 (Comanche Peak Steam Electric Station, Units 1 & 2) 4 b 0 j lf' [ ~ /q Deposition of:. Rfghard E c Camp '. S ~ - VOL'JNE ;.IIg ':_ IN CAMERA' 1 (Lasamen:' Glen' Rose,. ? exas' Pap:. 76,212-76,25 8 T [,j ,4 y[Dete: Friday, ' August' 3, l1984' f .py;< .g;; 4 [.. Information in this record was delete ~ ~ in accordance with Freedom of information 1upfW-S31s da % eun"
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l l 76,212 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 2 j l 3 l BEFORE THE ATOMIC SAFETY & LICENSING BOARD I 4 l l s ! In the Matter of: l 6 VOLUME 2 TEXAS UTILITIES ELECTRIC 7 COMPANY, et al. Docket Nos. 50-445 50-446 8 (Comanche Peak Steam Electric Station, Units 1 and 2) 9 10 I" (2 11 Glen Rose Motor Inn } Highway 67 & FM Road 201 10 12 Glen Rose, Texas l> 13 (Z August 3, 1984 ltu \\ 14 lx l> 15 l Deposition of: RICHARD E. CAMP f called for examination by counsel for the Applicants l 16 17 l taken before Margaret K. Schneider, Court Reporter, j i t' 18 beginning at 1:15 i p.m., pursuant to agreement. { 19 I i 21 I ( u I l i 23 1 i i f 24 l k l 25 I l - - - - - ' ^ ^ - - - ' - - - - -'
76,213. .1 APPEARANCES: 2 For the Applicants, Texas Utilities Electric Company, et al: 3 BRUCE DOWNEY, ESQUIRE _4 MARK L.'DAVIDSON, ESQUIRE.- Bishop, Liberman, Cook, Purcell & Reynolds 5 '1200 Seventeenth Street, Northwest Washington, D.C. _20036-6 For the Nuclear Regulatory Commission Staff: 1-7- GEARY S. MIZUNO, ESQUIRE 8 Office of the Executive Legal Director-U.S. Nuclear' Regulatory, Commission 9 Washington, D.C. 20555 10 For the Intervenor, Citizens Association for-Sound Energy: 11 ANTHONY Z.'ROISMAN, ESQUIRE 12 BILLIE GARDE, LAW CLERK Trial Lawyers for Public Justice, P.C. 13 2000 P Street, Northwest, Suite '611 Washington, D.C. 20036 14 2 15 I I [ 16 'l j e 17 j i i 1B i_ 'l l-19 l ~ i I 21 4, 22 23 24 b 25 ____.____.m_______
76,214 1 INDEX 2 WITNESS DIRECT CROSS REDIRECT RECROSS 3 Richard E. Camp 76,215 (Resumed) 4 5 6 7 8 9 10 11 12 13 _E _X.H_ _I _B _I.T_ _S 14 NUMBER FOR IDENTIFICATION i j 15 (None.) $j 16 e 17 5 l 18 i i 19 1 i 20 2 21 5 22 23 24 t,' 25
1s 76,215 1. P_ R O C E E_ D,I N_ G S_~ 2-1:15'p.m. 3 MR. DOWNEY: This.is.the resumption of'the: deposition of Mr._ Camp, which was began yesterday or.the; 4 5 day before. 6-I'm Bruce lDowney. I'll be substituting for Mark'Davidson in this deposition' representing the Applicant.j_ 7K 8_ Also1present inithis deposition;from'the 9 NRC Staff is Geary Mizuno. 'And'for:the Intervenor CASE,. 10 Anthony Roisman' and Billy Garde. 11 Because-of the unusual ~ time constraints-12 proposed by this proceeding,'we're going through the unusual 13 procedure'of substituting. counsel during the deposition. 14 Both Ms. Garde and Mr. Roisman attended portions of-Mr.. .j 15 Camp's direct-testimony. I attended none but, nevertheless, } } 16 will represent Mr. Camp in this portion of the deposition. ~ 17 t Whereupon, t l 18 RICHARD E.-CAMP i ) 19 the Deponent herein, having previously been duly sworn, a 20 was examined and testified further on his oath as follows: ~ 21 CROSS-EXAMINATION 22 BY.MR. ROISMAN: i l 23 4 Mr. Camp, at the very beginning of your 24 deposition, you discussed the issue of -- involving 25 and the dispute with Mr. Powers. Do you remember i ^-- -
76,216 that event? 1 2 A Yes, sir. 3 0 Now at the time that that event arose, had-4 you given any instruction to the people who worked under-5 you, the STE's who worked under you, to, encourage them to 6 get as many SWA's together and worked on with respect to 7 a particular part of a system as possible? 8 A I'm not quite sure I understand what you're 9 asking. 10 0 Okay. Let me try to approach it from a 11 different way. Had you seen or been made aware of a 12 problem in that certain systems on which SWA's were being 13 performed, or having the SWA's performed one after the 14 other, each time requiring that the system be taken out 15 of commission, be repaired, put back in commission and l 16 then quickly thereafter taken down again for another SWA? 17 Was that a problem that you had become aware of? i I 18 A Yes, sir. tI { 19 O And did you take some steps or recommend i l 2 to your employees that they take some steps to try to 21 reduce the extent of that problem? 22 A Yes, sir, I had. L 23 0 And was one of those steps to encourage 24 them to try to get all of the SWA's, if reasonably possible, 25 I together and addressed at one time so that the system I I l
76,217 could go down just once and be fully repaired and then put 1 2 back? 3 A Yes, sir. I had given that instruction. 4 0 The event that involved Mr. Powers and Mr. q isittruethatif{ position on the 5 u s s 6 merits been correct; that is, that there was a nonconform-i 7 ing cor.dition caused by the presence of the conduit within 8 less than three feet of the bottom of the ladder tray that 9 was carrying the cables, that there would have been a need 10 to do a second SWA at sometime in the future when that 11 nonconforming condition was confirmed? 12 A That's correct. 13 g And if that issue could have been resolved 14 promptly, would it then have been preferable to have had, l 15 if an SWA had to be done for that, to have that SWA and o \\ 16 the SWA about which and Mr. Powers were having [ 17 their dispute resolved at the same time? l 5 18 ! A Are you referring to holding that SWA that i s 19 they had a dispute over until the problem was resolved { j i i 20 and a future SWA generated? I 21 A Well, what I'm saying is, if the problem 22 that they were arguing about, whether ES-100 and Reg Guide l I 23 1.75, if that problem had been resolved immediately that j j 24 day or the next day, such that it was determined that 1 1 l 25 ] there was a need for a second SWA to be issued, would it I i i i I
76,218 1 .have been preferable to have had.the resolution and get: 2 the two SWA's resolved at the same time? 3 . MR. DOWNEY: Are you asking Mr. Camp R 4 hypothetically.if this'were.- - 5 MR. ROISMAN: :Yes,:that's right.- 6 .A Presuming that the resolution did create t. 7 additional work - : 8 g. Yes. 9 A -- that would certainly be the more effi-10 cient way to do it. /- n 11 Q So that if~at the time raised ' t2 the potential problem with the ladder tray and the proximity 13 of the conduit, if the engineering involved could have 14 immediately said, "Yes, you 're right. We need to do another 15 SWA," then per your instructions to your people, the. Ij 16 preferable thing would have been'to get that quick answer f 17 and do the.two repairs simultaneously,-is-that correct? 5 j 18 A No. My-instruction to my people was to 4 i j 19 accumulate known outstanding work and try to schedule that i i 20 work to be done all at the same time.. That was dealing 21 with known work.- 22 g All right. At the' time that -- what'did 'i 23 you -- strike the "At the time that " 24 What did you contemplate-in that. policy 25 would occur if one of your STE's, when' called over'to
76,319 l i 1 examine a system where an SWA had already been written, 2 noticed a condition which they thought clearly would warrant 3 a second SWA? Was it your instruction to them that they 4 should go ahead and authorize the first SWA or that'they 5 should bring to the attention of the appropriate engineering 6 personnel that they thought a second SWA ought to be 7 written? 8 A We've never considered that situation in 9 Aay of our instructions on accumulating work for single 10 outages, for one outage to do the work. We-never considered 11 that. ] 12 g Do y'. have a policy with regard to that 13 problem, if it should arise? 14 MR. DOWNEY: Objection. He just testified 15 he didn't have, if I understand his testimony correctly. 3 y 16 The objection would be that it was asked and answered. o 17 A Maybe I don't nnd'rstand the question. 3 I 18 O All right. I 'll withdraw that. l 2 i f 19 Did you instruct your'employeer. to encourage ij 20 the persons who they dealt with to present all their SWA's [ 21 at one time, if possible? ~ i I 22 A No. I encouraged the construction people 23 involved in generating startup work authorizations to, 24 as rapidly as possible, issue SWA's on every known work l 25 item that they had identified. a 1
76,220 1 My people were not in the -- not generally 2 in that process of generation of SWA's. It depended upon 3 the construction organization to issue work authorizations. 4 0 But.what did you want or erpect your people 5 to do if they saw what they believed was a clear nonconform-6 ing condition in an area where they were just about to sign 7 off on an SWA for another nonconforming condition in that 8 area? What did you want them to do if they saw that? 9 A Well -- 10 MR. DOWNEY: Objection. He's testified-11 that he didn't contemplate that situation. 12 A Well, the instructions to my startup 13 engineers relative to nonconforming conditions, if they 14 identify one, is to write a nonconformance report. ) 15 G At that time? 16 A That's the procedure required. 17 0 And would you expect them at the same time i { 18 to sign the pending SWA and have that work go ahead? i 19 A If it was disassociated with the nonconform-j 20 ance report, that's correct. 21 G What do you mean by " disassociated"? Do I } 22 you meen that they weren'* linked or they weren't in the l I 23 same area? i i 24 A If it wasn't on the same device, component, { J 25 cable, conduit, piece of equipment. ) i I I
76 221-1- G. In your~ judgment, would.this -- going % to-2: the particular place"where .,and Mr. Powers.had r-F .3- , their ' dispute, would. that -- if 1believed that ' 4-a nonconforming - condition existed with regardito' the tray 5 table's proximity touth'e conduit,_would'that be-one where' 6 he should sign the SWA and go ahead and write the NCR?. 7 -A-If.he believed that he was aware of a 8 nonconforming' condition in--the plant, he was obligated to 9 immediately write.a nonconformance report. 10 g And should he:have also-immediatelyfsigned 11 the SWA for the other pieceiof repair in_this particular 12 place? 13 A He is obligated to. authorize work that is 14 already on, identified as a nonconforming condition or a i 15 1 deficiency, when it's appropriate.to take the system down I [ 16 to do that, 17 j But that was my question..In this particu-a 18 lar instance, if he had written the NCR,1would it have } 19 j been appropriate to take the' system down.to the other SWA? j i L 20 A Yes, sir. It was already.a nonconforming { 21 condition. 1 i 22 4 On the Monday after the dispute between 23 and Mr. Powers, ILbelieve you testified that (- you called the meeting and-that , Mr.. Powers, 24 N 25 yourself, Mr. Popplewell, and I believe a couple of other -) 1 l 1 1 4
1 76,222 l' People attended, is'that correct?- 2 'A That's correct. 3 0-And at-that meeting, I b'elieve you said you 4 did most of the talking, is that correct?' 5 A. Yes,' sir. 7,,, t 6. 0 1md did you tell. -at'that: time .- o that you expected him.toLact essentially.-- that'you. .7 8 expected him to act'in a. professional manner 1and.not.have loud verbal disputes with'other people onithe jobsite?. 9 10 A' Yes,. sir. 31 g. Did you consider that_to be in the nature n n 12 of a reprimand to 13 A well, I'm not sure what you mean by " nature le of a reprimand." .j. 15 g Well, on the plant side at least in other. 3j 16 organizations, there's a term that you call ~" counselling," l 17 where -- 1 i 18 A Uh-huh. i, 19 0 -- the employer or immediate supervisor _. I j m sits down with an employee and counselling seemsL o be a t b' .21 euphemism to say, explains to.them-why what they-did was i 22 . improper and why they should;-- what.it was they.should 23 have done and counseled them, "You'd better do that from 24 now on." 25 Would you call it - is that what you were L______m__ __________________.___._._____._._-____m__.
i 1 l 76,223 1 doing, in effect, with 1 ,J 2 A No. :ILthink that-at our meeting on Friday,- 3
- I counselled him.
At our. meeting on Saturday,.I' reprimanded 4 him. And at a meeting _on Monday, the objective was to have 5 a clear understanding of.what engineering responsibilities 6 were.and[startup's responsibilities were, in that the' 7 conduct that had been exhibited previously to that was 8 unacceptable. 9 I did noticonsider that a direct reprimand 'to of him,'but.I' feel like I-had already done tha't. -l I 11 O All right. But you were indicating then 12 that you thought what he'd done was wrong, is that correct?' i 13 A Yes, sir. l 14 j G .And why did you feel'it was inappropriate I ~ 15 to do that in front of other people, particularly other l* i 16 people who were, if you will, on the other side of the a dispute? w 17 ; 5 18 A Well, I didn't feel l'ike it was important j i. to do that in front of other people, The purpose of the 19 a i j 20 meeting was to clear the air more than anything.else,'nct l l { 21 to reprimand anybody, just so everybody understood that .I l i i i i Z2 that kind of behavior is not acceptable. i o 23 I think.I testified that I don't believe.I. r 24 said that directly to ~4 25 I said it to the group as a whole in terms of "how are
I 76,224 1 we expected to conduct our business?" 2 O But isn't it true that it wasn't your 3 business to make that' statement to Mr. Powers? 4 A Well, since it wasn't in the form of a 1 5 reprimand, I do feel like that. i 6 O Did Mr. Powers' supervisor make a similar 7 statement at the meeting? 8 A Yes, sir, he did. 9 O And did you understand that he, too, was 10 addressing everybody in the meeting and not just his own 11 employee? 12 A That's the way I took it. 13 O And in your judgment, it was good management practice to call the two protagonists together, if you 14 I 15 would, and have each of their supervisors state their view 3j 16 of this matter as it reflected on their conduct? f 17 A Do I think it's good management practice? i l 18 G
- Yes, i
f 19 A I'll say it's effective. 1 5 j i j 20 0 Effective in what way? { 21 A That all the participants of the event hear 1 { 22 the same words at the same time. And if they have any 23 problem or concern with the policy or the attitude of I 24 the manager or supervisor, they had that opportunity to 20 take exception to it. 8 I m____________.-
76,225 1 MR. ROISMAN:
- Okay, I have no further 2
questions for the piece that I heard. Ms. Garde will now 3 enter the ring. 4 (Laughte r. ) 5 MR. DAVIDSON: Enter the lists, if you will, 6 Mr. Roisman. 7 MR. DOWNEY: As I observed at the outset of 8 this resumption of the deposition, in light of the time 9 constraints of all the parties, we 'll follow an unusual to practice of substituting counsel during the cross-examination. 11 And in mind with that agreement, Ms. Garde will now cross-12 examine Mr. Camp on the portion of his direct testimony 13 that she heard. 14 BY MS. GARDE: h 15 G Mr. Camp, you are to be complimented for b i j 16 putting up with this -- i { 17 A Thank you, i; 18 0 -- somewhat confused last several days of tI i 19 A long, long month for all of these attorneys and one small f a j 20 law clerk. 4 2 21 You testified yesterday about your review { 22 of the Gibbs & Hill January 23rd letter, which I believe 23 is Camp Exhibit 4. Do you remember the testimony on that 24 document, sir? 25 A Yes, sir. Oh, excuse me. Yes, ma'am.
76,226' D~ 1: G ~ That's;okay. Everything is starting to get 21 a little muddled. 3 My notes have'an entry.on your comment-that 4 ~ you didn't review this in detail because your background ~ 5 was in mechanical, not electrical ~ area. Is'that an. 6' accurate reading.of my. notes? 7 A-No, not relative to this document, I don',t 8 think. 9 G Could'you--- could you please correct the 10 record:and respond to the' question, specifically.about when 11 you reviewed that document? 'At what level of detail.did 12 you use when you responded.that' document, reviewing that: 13 document? 14 A I had previously re' viewed ~the letter..that 15 was transmitted to engineering, which explained the concern 16 with the possible conflict'between'ES-100 and Reg Guide-3'l 17 1.75. 1 18 At that' time, I reviewed the. applicable-t 2 i 19 documents -- tj 20 'O Uh-huh. { 21 A -- referenced by the letter. 7 ) I 22 O Uh-huh. [ 23 A And I. formed-an opinion of that'upon 24 receipt.of this letter from engineering.. In response, -. 'I ' 25 reviewed only the letter and not any other documents and-4 ,t..
76,227 I basically came to the conclusion that the reasoning 1 behind engineering's explanation of the requirements in 2 3-ES-100, as they relate to Reg Guide 1.75, were reasonable and that they generally -- in general matched my previous 4 5 assessment. 6 0 What was the basis of the conclusion that I I 7 you just described that you reached? 8 MR. DOWNEY: Objection. I think he stated 9 the basis very clearly in his answer to your previous ' 10 question. Go ahead. 11 A Well, the basis of that final opinion that 12 I had was. based upon the letter from Gibbs & Hill, this 13 Exhibit 4. 14 O All right. It's at that point in my notes 5 15 that I have the -- that explanation is consistent with 5 [ 16 what my notes say you said yesterday. It's at that point a 17 that my notes indicate that there was some discussion of i l 18 your background in mechanical as not -- and this is my i h 19 characterization - "second-guessing" the answer or the 5 j 20 letter from Gibbs & Hill. Do you recall that? 21 A Yes, I remember saying that. I think it { 22 was in regard to the review of the whole issue after it was 23 transmitted to engineering in my review of our -- our 24 transmittal to engineering. 25 0 Uh-huh. All right. That clarifies my 4
76,228; 1 question.- Okay. 2 MR. DOWNEY: Off the-record'just:one second. 3 (Discussion'off the record.) 4 MS. GARDE: Let's--go back on the' record. 5 .BY MS. GARDE: 6 O Mr.,; amp,,you recounted'an incident yesterday 7 in which you were called to the resident. NRC inspector's 8 office regarding a matter involving a' quality control .9 inspector:and -a 10 And I bel'ieve' you. testified that 1Mr. ' Tolson: 11 was at that meeting, yourself, and the resident inspector. 12 Was the quality control inspector also at that meeting? 13 A Yes, he was. 14 0 Do you remember the name of that quality-15 control inspector? t .i:l 16 A I cannot recall his nameLri'ght off. [ 17 1 O It was a man? 3 l l =i { 18 A Yes, ma'am. i i 19 0 Were there any'other people at that' meeting? i M A No, just myself, Ron'Tolson, the QC r 21 inspector and the NRC resident -inspector, Bob Taylor. .j cj j 22 O Did anyone ask you at that meeting to talk 'J 23 to Mr. Boyce Grier about this incident? - 24 A No. l q 25 0 Let me show you again ' Exhibit Number. 6 from-t l l I _a
l-76,229 1 this. deposition. 1Do you recognize - that?; 2 A Yes, ma'am.. I do. 3 0 Is that. -- does. that exhibit deal with the 4. . problem with the WestinghouseLinverter failure?; 5 A' Yes, ma'am. It does. 6 4 In your opinion, sir,.was the failure of 7-those inverters a' potentially serious. problem - at the time 8= that memo was written?. Did you considerait a:potentially' 9 serious problem? 10 A 'Potentially serious in'what. terms?: 11 4 Let me rephrase my question. Are the 12 inverters. discussed in this memo andrin the entire series 13 of documents, the Westinghouse documents, in usefor in 14 operation prior to the plant going into operation?; 15 A Did you say "are they in use"? ' { 16 0
- Yes, o
l 17 A Yes, ma'am. .1 l 18 0 Will they be in use while the plant is t { 19 operating? ij M A Yes, ma'am. [ 21 O Are they part of a safety-related system?. I 22 A .Yes, ma'am. 23 0 Is it necessary for them to work during. j 24-operation? .i 25 A I'm not familiar with the safety analysis. 1 i C_1 i
l 1 76;230 1 0 ~Okay.- By " safety analysis, " you 're : referring 2 to failure analysis? 3-A' Yes, ma'am. 4-g- When?that problem, an'd by.:"that' problem," I mean in.the.' failure;of'the' inverters, came.to your '5. 6 attention and you were' reviewing the documentation involved 7-V in' that in the initial stages,-did you consider that failure 8 of those. particular. inverters to -be serious. to the use of' 9 those. inverters at other plants? 10 - MR. DOWNEY:. Objection. So.far_as.I know, 11 there 's nothing' to suggest. this witness knew whether, they 12 were in use'at'other plants. Perhaps the direct examination 13 reflects otherwise, I don't know, but I--'wil~l '~ object andL 14 ask you to establish a. foundation for the question. 15 BY MS. GARDE: j - 3 -{ 16 0 Mr. Camp, yesterday ~I believe..there was e; 17 testimony about these particular. inverters.and this incident 2 j 18 ultimately resulting in a ~50.55(e) report. Do'you recall. i 19 that? 5.j - 20 A Yes, ma'am. 21 0 To the best of your recollection, did that.- [ 22 50.55(e) report have implications generic.for all~ inverters 23 of this model? 24 MR. DOWNEY: Objection. If he knows.about.-- 25 -MS. GARDE: If he knows.
--*m 76,231 1 A Would you repeat the question? I'm sorry. 2 I've lost connection with it. 3 g All right. When this problem ultimately 4 resulted :Un the 50.55(e) report, which was some months after 5 the identification of the problem, are you aware of whether or not Westinghouse informed the owners or the recipients 6 7 of other inverters of this type? 8 A I'm not aware of that, no. 9 O Are you' aware of whether'or not the 50.55(e) 1 10 report addressed the generic problems of these inverters?- 11 MR. DOWNEY: Objection. There's nothing-12 here that I -- that I see that suggests there was a generic 13 problem. And so-I think that your question assumes facts 1 j 14 that aren't in evidence -- 5 15 MS. GARDE: Uh-huh, 8 l 16 MR. DOWNEY: -- as did your second from the o l 17 last question. I'd like my objection to go back to that s l IB question to make sure that it's the witness, not Ms. Garde, r who's testifying. ( 19 5j 20 MR. ROISMAN: It shows how unfamiliar you { 21 are with direct. j 22 MR. DOWNEY: As I noted earlier, Mr. Roisman, 23 I'm substituting for other counsel. 24 MS. GARDE: All right. After consultation j 25 with Mr. Roisman, I'll withdraw that last question. l t L____________-_______--
= - _ _ _ _ _. q j i ~76,232-i 1 And that elf.minates two'more questions, Mr. 2 Downey. 1 3- ~MR. DOWNEY: Thank you, Mr. Roisman. 1 4 (Laughter.) 5 MR. ROISMAN: Any time, anything for-6: efficiency.- i 7 BY MS.-GARDE: 8 _O
- Now, Mr. Davidson asked you a question q Lf r.
.9 yesterday regarding telling you or,'not telling: s 10 you -- I believe.the question was, "Do_.you recall:if. 11 ever told you of whether or not he had contacted 12 GAP?" And.the time frame!that was discussed was the 13 January, mid-January time frame. _.Do you recall that l question? 14 f 2 15 MR. DAVIDSON: Ms. Garde, it so happens I've aj 16 come into the room and I heard you ask.the question. 17 Actually, it wasn't mid-January. I said mid-December to' i f mid-January. l 18 r Ij 19 MS. GARDE: .I. stand corrected. I M l MR. - DAVIDSON : ;All I did'was ask the I l 5 21 ' witness whether he had been advised-that- -lhad. l~ l 5 22 contacted GAP sometime between the-middle of December and !l 23 the middle of January. . 24 MS. GARDE: By h 4 25 MR. DAVIDSON: -Whether he had been told by i .t .g ,1
Y - 76;233 y That's right.- 1 2 MS. GARDE: Yes, yes. 3 BY MS. GARDii:: 4 O. Do you recall that question, Mr. Camp?: .5 ~ A. Yes, ma'am. 6 g Do you recall'if at anytime during: 7 employment,. including and up to the day of his. 8 termination,- if he ever told' you of! whether or not -he. had 9 had any contact with GAP? ~10 A. - Do I remember if he told me? 11 0 Uh-huh. 12 A. Is that your question? 13 0 Yes. 14 A. Yes', I remember - I. would remember if hed i [ 15 told me. 3 ( 16 4 Did he tell you that? 17 A.- He never told -. discussed with me any i 18 contacts with GAP. r I 19 O Any contact with the NRC, other.than that Ij 20 documer.ted in the memorandum? ~ 21 MR. DOWNEY: Are you referring to his { 22 contacting Region-'S on -- 23 MS. GARDE: Yes. 24 MR. DOWNEY: -- December.'16th?- 25 MS. GARDE: Yes. m
76,234 1 A He never made me aware of any other contact, 2 other than that contact with. Region 5. 3; O. Now you testified yesterday'at_a timeperiod ] 4- . prior to' tn ling you about1his decision.to' 5 leave Comanche Peak,; that you were going (through !a decision 6' process about which. employees should be -- names should be. 7 submitted for unlimited or unescorted' access ~to the plant.- 8 Do-you recall your testimony in that area? 9 A Yes, ma'am, I do recall. 10 Do you. recall 'our testimony saying"that' y 11 you were, concerned that you would not' feel comfortable'about a- . ') 12 recommending for ; thatLhe'have-unlimited, J ~ 13 unescorted access to the plant? 14 A Would you repeat the question? b 15 g Yes. } Do you. recall testifying in that line } 16 of questioning, that you would be concerned that you would 17 not feel comfortable recommending-to have f 18 unlimited, unescorted access to the plant? l E d 1 19 A My recollection of my testimony was that.I. ij 20 was becoming more concerned about his behavior-and that { 21 if that behavior continued, I would be' concerned about [- { 22 authorizing b4.m -- recommending him for unescorted access-23 .into the plant security boundary. 24 g Did you ever have to submit the list of' 25 names -- let me put this -- let me rephrase the question. t a___-_____
c 76,235. -1 During the timeperiod thatj was 2 an employee of yours, did:it come -- did you have to submit 3 the~ list-of names that you were discussing in this line of-4 . t'estimony? 5 A Not/during the time frame that he'was-6 employed with -- with Impell Corporation or at the project. 7 O So you never had to make that' final decision. 8 A No' I had not,
- e. -
q-9 O' .Now, when [ informed you that ' he-10 was leaving Comanche' Peak, I~believe your.testimcnjiis.that 11 you. asked him if he had'found-another job. He i'ndicated he 12 had an offer but wasn't sure'he was going to accept it-at'. 13 that time, my. notes-reflect.your~ testimony as.,Do_you 14 recall that? A Yes, I do. 3 [ d j 16 0 Wereyouconcernedenoughabout[_ 17 behavior that at the time he told you that'he was going i j 18 to accept another job, you would have felt. obligated to 19 notify a future-employer? i j N MR. DOWNEY: Objection. -1 I 21 MR. DAVIDSON: Objection. I 22 MR. DOWNEY: It's=beyond the scope of the t 23 direct examination'. 'i 24 MR. DAVIDSON: My point was actually that 25 Ms. Garde's -- 1 l
76,236-1 MS. GARDE: Let me heariyou both,syour 2 points. c. 3 MR. DAVIDSON: -- statement of.your'testi-4 . mony:was, when-he told you he was going to accept another. 5 job. And'I.think the testimony was-that he told you'he 6 was thinking about taking another job but --< 7 MS. GARDE: Yes.. 8 'MR. DAVIDSON:. -- he hadn't decided to do 9 so yet. 10 MS. GARDE: That's what_my notes say, and if..- 11 I didn't sayfthat,-I stand corrected. 12 Now, Mr. Downey, wh'at's your objection?- 13 - MR. =.DOWNEY :.My objection'is that'that line 14 of questioning about contacts with future employers, and 15 that's not part of the' direct examination.. As you know, [ 16 g has filed a separate legal action against at 17 least one company and.perhaps Mr.. Camp's employer:, and i { 18 we've deliberately refrained from that;line of questions i i 19 to keep these proceedings separate, i 2 And we see--that as beyond the scope of what's 2-21 necessary for this case, and I'll object on relevance. M grounds and on tb7. grounds that it's beyond the scope of' 23 the direct examination. 24 MS.' GARDE: Mr. - Downey, let me,-- 25 MR. DOWNEY: And, in addition, Mr. Davidson's s
i 76,237 grounds that youfmischaracterized his testimony.- 1 2-MS. GARDE:--Okay. Well, I think we've taken~ 3 care of Mr. Davidson'sfobjection as to mischaracterization;. 4 . I think IJproperly characterized it the first time.. 'AndDift
- 5 I-misstated it the'second_ time, I apologize and stand
'6 corrected. 7' As to the relevancy grounds,.I'm not" 8 ~ attempting to probe beyond the direct testimony and am not 9- ~ interested in.gettingfinto any of the dealings-about( ,) employment-oremploymentbeyondhis-leaving 1 10 11 Comanche Peak. .12 I am interested'in'the concern - the level 13 of concern-that this. witness had:about"what-he_ regarded -3 14 as[ behavior problem. 1 j 15 MR. DOWNEY: I have -- j 16 MR. DAVIDSON: I think that's a legitimate l 17 line of inquiry.. i f 18 ' MS. GARDE: Thank you. l i 19 BY MS GARDE: 1 i i 20 0 Now, back to you, Mr. Camp. Can you answer- .j 21 that question? I' 22 A Could you repeat that?. 23 O Do you want_me to repeat that question?? 24 .A With all' of the exchange, I'm-not sure-I- [- 25 ' understand the question. 4 -.,_.__m_.__________..m
t 76,238 1 0. Okay.' Fine. You testified about the. 2 concern you were having, but you never - 'I believe your 3 . testimony is that: you never faced the situation where Lyou1 .- 1 -4. had to either decide 1to place on the list'or 5 . decide not to place him on.the list. 6 A That's correct. 7 71 Q And that's because ftold.you that 8 he was' leaving, is that correct?' 9 A- -That's correct. 10 0 Now, were you concerned enough about his 11 . behavior problem,'asfyou perceived it,. to: feel that you 12 needed to contact.a future employer?. 13 MR.JDOWNEY: You'might ask him if-he knew-14 who his future employer was. } 15 MS. GARDE: I-think he testified that-he ] 16 'didn't. 17 BY MS. GARDE: i f-18 0 You didn't know who~~your --~his future i !j 19 employer was. Or that -- i, i 20 .MR. DAVIDSON: I think he testified that m 1 L .7 21 ,ldid not tell him. i ) i-22 MS. GA90E: Right. I i 23-I A All of you'are. correct.. I:did not'under- .) 24 stand who he was going to work for. 25 0 And I'm not interested in that testimony. 1 i .i i ^' I
L 76,239 i 1 MR. DAVIDSON: That's not the question she's 2 asked. l 1 3 A In answer'to your question, no. 4 MS. GARDE: Let me consult with Mr. Roisman. 5 (Pause.) 6 MR. ROISMAN: Okay. We're switching again 7 for this last -- 8 MR. DOWNEY: Mr. Camp, I will apologise to 9 you. This is a very unusual deposition. I appreciate your 10 tolerance. 11 MR. ROISMAN: And I'm going to have to ask 12 one additional indulgence. I need to ask him a question 13 that may, in fact, be asked and answered. 14 MR. DOWNEY: Ask all of us who were there 15 j out of'the room and nobody will know to object. ] 16 BY MR. ROISMAN: 17 O Did you make an' independent evaluation of 5 { 18 own as to the proper resolution of a dispute between( l <3 j 19 and Mr. Powers over ES-100 on one hand and Reg ij K) Guide 1.75 on the other, prior to your receipt of what [ 21 has been marked as Camp Exhibit 4, which is the Gibbs & Hill f 22 letter? I 23 ' A Now that I see Exhibit 4, would you ask the 24 question again? 25 0 Yeah. What I'm trying to point out is, did
76,240 1 you make an independent evaluation on your own of whether 2 you thought that Mr. Powers' reading of ES-100 and Reg Guide q 3 1.75 was correct or whetherL reading of it was 4 correct? 5 By " independent," I mean did you, yourself, 6 go out and convince yourself, or did you decide to accept 7 the evaluation of somebody else with regard to it? 8 MR. DOWNEY: Objection. 9 MR. DAVIDSON: I think that's been asked and 10 answered. 11 MR. ROISMAN: I already conceded it was i 12 going to be asked and answered, but I wasn't here when 13 the -- 14 MR. DOWNEY: Well, let him ask the question. 15 MR. DAVIDSON: I'm sorry. Please go ahead, 3j 16 Mr. Roisman. 17 A Yes, sir, i i 18 0 All right. And when you did that, did you ) 19 look, yourself, at ES-100 on the one hand and Reg Guide i 20 1.75 on the other? 21 A Yes, sir, I did. i 22 g Did you focus on any particular language in 23 ES-130 when you did that? 24 MR. DOWNEY: If you recall. Mi A I'm not sure I understand what you mean by l
76,241 1 " focusing on any particular. language." 2 0 Well, is there some particular language 3 which you would point to in ES-100 and-say,' "Here is the. 4 part of ES-100'that I was looking at in trying~to answer 5 this-question"? 6 A Well, there's a distinct difference inithe ' 7' language used:for this, what I.think'is the intended 8 application.- That is,. in Reg Guide 1.75, they discuss not 9 conduits but enclosed raceways. And ES-100 specifically. 10 - talks about conduits.- 11 .So there is a difference in the terminology 12 used. 13 4 Can I infer from.that that your looking'at 14 Reg Guide 1.75 and at ES-100,.youLdid not find anything.in 15 Reg Guide.l.75 that exclusively ' authorized theluse of the I 16 conduit'in lieu of two-covered cable-trays for the one inch C j 17 separation? 5 f. 18 MR. DOWNEY: I'm going to object.because I'm 19 not sure I understand the question, ij 20 A If.you consider that a conduit is an I l 21 acceptable barrier... I 22 MR. DAVIDSON: I'm sorry. I doa't think you 23 finished your answer, Mr. Camp. 24 0 If you consider that a conduit is an 25 acceptable barrier, then are you saying that Reg Guide' l
T 76,242 d 1 1.75 explicitly ~did authorize-or.that it did no't-exp1'icitly 2 authorize? 1 3 A . Well, RegfGuide l.75 provides. examples of 4 acceptable measures to comply with NRC' requirements. 5 g-Correct., 6 A. Acceptable other. methods'-- other' methods 7. are acceptable as-long as'they meet the intent and.' spirit 8 of 1.75.. 9, O Right. What I'm asking now,.is there an 1(F explicit - authorization in Regi Guide 1.75 for the -conduit - 11 to be'used as the barrier to separate what is uncovered. 12 ' ' wire from covered' wire? 13 MR.- DAVIDSON: Mr. Roisman,:do'you think it 14 would help the witness if he'were allowed to'look at. Reg. ~ 15' Guide 1.75?- l' 16 MR. ROISMAN:. Sure, yes,-let him.x I'm Cj. 17 delighted he's got it. I { 18 MR. DAVIDSON: Whenjyou raise that question 'l f 19 because I have a copy. d j 20-MR. ROISMAN:- Good. That's' fine. {. 21 MR. DAVIDSON: And perhapscyou might tell j. 22' 1 him what you mean by " explicit."' i' E MR. ROISMAN: 'Yes.. I'mean -- 24 MR. DAVIDSON:.You mean~ it has to ' use the 25 word." conduit," or it could use its equivalent? In other -_-_--L_.__
l 76,243 1 words,.its engineering - - 2 MR. ROISMAN: All right. 3 BY MR. ROISMAN: 4 4 Let's start first with, is there any drawing in Reg Guide 1.75 which shows a separation of one inch 5 6 between an -- cables. running through a ladder bottom tray 7 and cables running through a conduit? 8 A No. 9 Q Secondly, is there any language in Reg Guide 10 1.75 that says that the separation between wire running 11 through a conduit on the one hand -- 12 MR. ROISMAN: Just a moment, Mr. Davidson. 13 That would be testifying for him. 14 0 -- running through Reg Guide'-- excuse me -- 2 15 running through a conduit on the one hand and through a 16 ladder cable tray on the other, can be one inch? Is there f 3 l 17 any language that says that in Reg Guide 1.75? i g l 18 A .I Reg Guide 1.75, to my knowledge and without l i 19 further review, does not reference directly to the word g 20 " conduit." 21 g All right. Do you believe -- 22 A Nor does it endorse conduit as an acceptable 23 barrier. I 24 G Nor does it endorse it? I I i 25 A. No, sir. 'l ~ l i l
'l 76,244 i 1 0 Now,'do you believe-that there is language in Reg Guide 1.75 that says that if there is an acceptable 2 3 barrier, then the distance between the cables can be one I 4 inch? 5 A Yes, sir. I 6 0 .Would you look at Reg Guide 1.75 and see if 1 7. you can find the language that you believe says that? 8 A In paragraph 1. -- 5.1.4, the last paragraph 9 of the section, I think addresses that subject. 10 0 All right. Would you read the language in 11 that paragraph that in your judgment addresses that? 12 A "Where plant arrangements preclude maintain-13 ing the minimum separation distance, the redundant circuits should be run in solid enclosed raceways 14 5 15 that qualify as barriers, or other barriers should Ij 16 be provided between redundant circuits. The minimum 17 distance between these redundant enclosed raceways s 18 and between barriers and raceways should be one t 19 inch." r ij 20 0 Okay. Now the first sentence.that you read 21 has an "or" in it. It gives two options, is that correct? i I 22 A Yes, sir. 23 g I'm sorry. I think it's actually the 24 second sentence, but you know the one that I'm referring to. 2 A It's in the first one, i 4
76,245 1 MR. DAVIDSON: I think you were right, tte 2 first one. 3 MR. ROISMAN: Okay. 4 BY MR. ROISMAN: 5 0 Which of the options that fits our situation 6 that was the subject of'th( Powers dispute? v 7 MR. DAVIDSON: Or if both do. 8 (Pause.) 9 A Well, I agree.- I think possibly both do. 10 0 All right. Explain to me, locking at the 11 first half before you get to the "or." Does.that sentence 12 describe a situation that you think fits a conduit? 13 Does it define -- do you believe a conduit 14 would fit the definition of the first half of the sentence 15 before you get to the "or"? lj 16 A Yes, sir. I would consider a conduit a s 17 solid, enclosed raceway. Yes, sir. I f j 18 1 0 Good. All right. Now, is it your under-l 2 ? 19 standing of that sentence that it intends to say that both ? 2 of the redundant circuits should be in solid, enclesed { 21 raceways? 1 I 22 A I refuse to answer that question. It's not ) 23 my -- not my professional line. The requirements of this 24 Reg Guide have been applied to ES-100 by the architect-1 l engineer, reinforced by site engineering. That is their i 25 i i 1-l 1 l _ _ _ - _ L
76,246 i l job, and I do not intend to further try to interpret the 1 2 requirements. 3 0 And so, your knowledge and ability to cvaluate the -- who was right and who was wrong about the 4 i 5 Reg Ouide 1.75 and ES-100 dispute stops right at this point 6 where my question was, is that correct? 7 A I formed an opinion. The final disposition 8 of that request and understanding of the compliance of 9 ES-100 with Reg Guide 1.75 was made by engineering, not to myself. 11 G What I'm trying to understand is when did you stop having an independent opinion and when did you 12 13 start to rely upon the opinion of somebody else. And what I'm trying to find out is, did you stop having an indepen-14 ) 15 dent opinion when you reached the question of whether the ) 16 sentence, the portion of the sentence we're now focusing e 17 on requires that both sets of redundant circuits be i; 18 enclosed in -- be in enclosed raceways? t! { 19 MR. DA7IDSON: Mr. Roisman, could you resume E j 20 your seat and not lean over the table at the witness? 21 MR. ROISMAN: I'm leaning over it so that i 22 I can -- I'm sorry. I'm doing it because I can't see -- 23 MR. DAVIDSON: We 'll supply -- we 'll supply 24 you -- 25 MR. ROISMAN: -- see the --
l 76,247 1 MR. DAVIDSON: -- with a copy of the - of 2 the document, but I really think you should not lean over 3 the table towards the witness and stand over him and ask 4 the questions. 5 MR. ROISMAN: I would like the record to 6 show that I was in no way intending to do that, and I was l 7 only doing it for the purpose to make sure he and I were 8 talking about the same words. 9 MR. DAVIDSON: I understand, Mr. Roisman, 10 what your intent may have been. All I'm saying is that 11 you should resume your seat and ask your questions from the 12 other side of the table, rather than standing over the la witness and looking at him from above, two inches from his 14 l face. h 15 Now if you want to repeat the question, I'm } 16 sure the witness will be happy to provide you with an e; 17 answer. i i 18 BY MR. ROISMAN: I 2 19 0 Mr. Camp, I'm just trying to find out where s 20 you stopped exercising independent judgment about the 21 meaning of Reg Guide 1.75 and where you started to rely i 22 upon the judgments of others, who you felt had more quali-1 1 23 fications. 24 And I'm focusing now on the first half of 25 the sentence that we've been talking about and asking, did l _ _ _ _ _ _ _ _ _ _ _ _ - _ - - - = - - - - - - - - - - -
76,248 1 you rely upon the judgment of others.in order:.to determine 2 whether the first half of that' sentence in Reg Guide 1.75' 3 required -- excuse.me -- that each redundant circuit be in 4 its own enclosed raceway? ~ 5 MR. DAVIDSON: Mr..Roisman, I'think you've 6 confused two: separate lines.of. questioning. Initially, you 7-asked'him, did he make his own independent. judgment. ~He 8-did. 9 But the question about whether or not.the 10 ultimate ' resolution of the problem, he relied upon those: .11 people most knowledgeable,-who had the responsibility at 12-the site, which was engineering, to resolve it, is yet 13 another and different situation. 14 And I don't think you can run the'two 2 2 15 together because I think it's confusing to the witness. I { 16 MR..ROISMAN: I am not running them together. j 17 All I'm asking him is, not the ultimate: resolution at all. 1 l 18 I'm'askire him about when~he fo ed his f 19 judgment about who was right and who was wrong -- 5j M MR. DAVIDSON: What did he---- { 21 MR. ROISMAN: -- and we got to=the point } 22 of deciding whether or not you needed'tn have each redundant 23 circuit in its own enclosed raceway. Did he rely upon his 24 own. evaluation of that. language, or did he rely upon the 25 evaluation of somebody else. L _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ _ _ _ - - - - - - - - - -. _
76,249 1 MR. DAVIDSON: Well, that's a fair question. 2 MR. ROISMAN: That's the question. I know 3 it's a fair question. 4 MR. DAVIDSON: I appreciate the clarification 5 MR. ROISMAN: That's why I asked it. 6 MR. DAVIDSON: I appreciate the clarification 7 BY MR. ROISMAN: 8 0 Mr. Camp? 9 A I'm not sure I understand what the clarifica-10 tion is. 11 O You've testified that you made an independent 12 evaluation as to whether you thought Mr. Camp or Mr. Powers 13 was correct about this dispute. 14 And I've asked you to tell me if you looked 15 at Reg Guide 1.75 and ES-100 to do that, and you've told } 16 me you did, f 17 And now I've asked you what portion of Reg { 18 Guide 1.75 did you look at, and now you've told me that. j 19 And now I'm asking you, looking at that i 20 portion of it, what did you understand the particular sub-j 21 portion that we're focusing on now, the first half of the I 22 sentence, to mean. And you gave me a partial answer. 23 You said that you understood that it would 24 cover a conduit, that a conduit would be an enclosed 25 raceway.
76,250 1 You then went a next step, and I' asked'you, 2' . did 'you read that sentence to mean that both of the redun-3 dant circuits had to be in enclosed raceways. -4 And you said,-I believe, "I refuse to answer 5 that question because that's not.my expertise. It's 6 somebody else's." 7 Now what I'm trying to get'you to'tell'me 8 is, when you were evaluating who was right.and who was 9 wrong in.the dispute between Mr. Powers and ' ~ -~J 10 did you not fonn -- did you 'fonn:-- let's put it that way.- 11 Did you form any independent judgment as 12 to.whether or not you neededLto have both redundant circuits 13 enclosed in -- both redundant' circuits in' enclosed raceways? i 14 i A I did not make that determination, no. i 15 t 0 Okay. And you relied upon somebody else's-2 l 16 judgment with regard. to that during the time of the Powers-a es 17-tdispute, is that correct?. I' 3[ 18 A I relied upon somebody'else's judgment to y -[ 19 respond to the whole issue -- not individual phrases-ij' 2 contained within the. Reg Guide. } 0 But you have no' opinion. 'You don't. feel 21 i 22 confident to express. ar opinion on the question of whether - i 1 23 the redundant circuits'must both be in enclosed raceways, 24 is that correct? I 25 A That's correct. _______..___-___1---._---------
-76,'251 1 0 .Now looking'-- 2 MR. MIZUNO: 'JustLa moment. It is now after. 3:00 o' clock.by about -- I'm sorry;- 2:00 o' clock by about-3 4' seven' minutes., I -- Staff'has to: leave,at~this point. 5 MR. ROISMAN: All.right. 6 MR. MIZUNO: I'd likefto go off the record. 7-to clear something.up1withDthe Reporter, and I guessLI-8 would like to.know beforefwe go'off-the. record how long. 9 your cross-examination is going to'take -- till 2:30? 10 MR. ROISMAN: ~No, probably'another -- 11 depending - I have a couple of more' questions, maximum.~ It 12 depends -on whether 'the attorneys ? for ' the. utilityrfeel that . questions are proper and-the witness isiable to answer them, 13 - 14 or whether we have to argue about it. O; 15 That's what I've got left. { 16 MR. MIZUNO': The Staff 1has~some cross ' ) } 17 examination of Mr. Camp. And we! reserve its hight to'ask i 5 l 18 cross-examination =at a future time. I*s I 19 MR. DOWNEY: Since you --
- {
i 'I -j 20 MR. ROISMAN: If I finish-my cross -- { i 21 MR. MIZUNO: Okay. l I 22 MR. DOWNEY: You will receive a transcript 23 prior to the resumption of the deposition, which you can-24 use in formulating.your questions. And so I take'it on 25 that basis --
76;252 1 MR. MIZUNO: Okay. 2 MR. DOWNEY: -- you'll permit us to continue 3 and conclude Mr. Roisman's' examination today. 4 MR..MIZUNO: Yes, yes.. That is correct. 5- 'Maywe_go off;the record?1 6
- MR. DOWNEY:
Yes. 7: (Discussion off'.the record.) 8 MR. MIZUNO: Staff counsel notes that$it :is 9 'now leaving, and we'll reserve its right to conduct its-10 cross-examination at another time. 11 MR. ROISMAN: For the record, have_a nice 12 trip. 13 MR. MIZUNO: Thank you. 14 MR. DOWNEY: So'long, Geary.. ~ 2 15 BY MR. ROISMAN: 16 0 Now, Mr. Camp, I'd'like to look at the ~\\ 0l 17 second half of the sentence. You'll notice in the-second
- )
-i j 18 half of the sentence after the word "or" appears the word i 19 "other" and then " barriers. " g t j' N What is your understanding'of what an other 21 barrier is? 7
- )
22 A. Other barriers, I think, are specified -- i i 23 other adequate barriers are.specified by.the engineer in 24 ES-100. And I'm not familiar with.their -- with the 3 specific paragraphs of ES-100 that discusses those barriers' .{ i l 1 j ____:_-=-
l 76,253 or installations of electrical equipment. 1 2 G I meant only in Reg Guide 1.75. Do you have 3 an opinion of what you think is meant in Reg Guide 1.75 4 by the phrase."or other barriers"? 5 A Well, it shows in the figures, tray' covers. 6 And so, I would assume that would be "other barrier". 7 g Would it be your understanding that if a I 8 tray cover separated two redundant systems, just a single 9 tray cover separated the two redundant systems, that the 10 systems could be within one inch of each other. Is that 11 your reading of the drawings? 12 MR. DAVIDSON: Is that his reading of the 13 drawings or is that his reading of Reg Guide 1.75? 14 MR. ROISMAN: No, no. He'd said it was 15 in the drawings, so I'm asking about the drawings. } } 16 BY MR. ROISMAN: 17 0 Is that your reading of the drawings? i l 18 MR. DAVIDSON: I don't think he said it was I i i 19 in the drawings. f 20 A I said that it depicts a tray cover on a ~ 21 tray. And so I would assume that because it's shown that ( 3 4 22 that is an "other barrier." ) 23 0 And my question to you is, could, in your 24 judgment, do you find anything in the drawing -- in the .] 25 drawings that are attached there that shows two redundant l l i 1 1 I L _ ______________ ________
76,254 f I systems separated by a single tray cover and only one inch 2 apart? i i 3 A There is a figure that -- Figure 5.1 that ) ~ 4 shows a -- two independent trays, tradn A and bradn B, 5 separated by one inch. One of the ' trays' is a solid tray 6 and.the other is a solid tray cover, and it allows one inch. 7 g But in that case, you have the equivalent 8 of two barriers, is that correct? 9 A That's, in fact, correct, yes. 10 0 Is it your understanding of the-portion of 11 the sentence that we were looking at, that if there were 12 only one of those barriers; that is, either the solid tray 13 bottom on the trada A or the tray cover on tradn B, that the 14 distance could still be one inch? 15 A That if you removed one of those covers 16 that it could still be one inch? O 17 0 Yes. ai l 18 A That's -- yes, sir, with another barrier i 19 in between. ij m G I'm sorry. Assuming no other barrier, J i 21 assuming no other barrier, could you have it with only one 1 22 inch? In other words, you remove either the tray lid on J 2 the bottom or.the tray bottom on the top, could you then 3 24 continue to have them separated by only one inch? l 25 A It would be my opinion that that would be i l l i i m____
76,255 .h 1 unacceptable. 2 G .And that the other' barrier would have to be 3 something between!the now uncovered train and the covered-4 l train, is that' correct?- 5 A-That's correct.. 6~ -G. .Do you see'anything-in~ Reg Guide 1.75 that ~ '7-
- indicates to~you in the drawing'or in-the language that the 8
other barrier, as:used in the. sentence'thatlwe'were focusing 9' t our attention on,'could be a: conduit' covering only one of' 10 two o'f~the redundant. trains?- 11 A. Are you asking me that if a conduit would 12 be an acceptable barrier? 13 0 Do~you see something in 1.75 that indicates 14 that it would qualify: as one of the "other barriers"? h 15 A. ' Nothing other than the fact that it' refers 3 [ 16 to " solid-enclosed raceway." 'And>a conduitlis a raceway. f 17 Gl All right. :But that's in the'first half. I E 18 of this sentence. I'm looking'now at the portion of the-t i j. 19 sentence after the "or" where I-believe-you have testified i [ 20 that a' conduit is a solid enclosed raceway. 21 Now I'm looking for "other barriers ~." My' l 22 question to you is what, if anything,'do you find in Reg. 23 Guide 1.75 that would -- strike that. 24 What, if anything, did you find in Reg Guide 25 1.75 that would indicate.to you that the conduit could be s I
76,256 1 one of those "other barriers"? 2 MR. DAVIDSON: Do you understand the question, 3 Mr. Camp? 4 THE WITNESS: I don't understand it. 5 MR. DAVIDSON: He's not asking you whether 6 a conduit can be a barrier or is another barrier. He's 7 asking you where in here,'if you can find one. When I 8 say "in here," in Reg Guide 1.75, you can find some support, 9 explanation, explicit statement that a conduit is an;"other 10 barrier." 11 That's what he's asking you, I think. 12 BY MR. ROISMAN: 13 G That's right. And I'm particularly focusing 1 I 14 on the words "other barrier." ) h 15 MR. DAVIDSON: So you -- if you need to, I 1 ] 16 you should look through -- 1 1 3 l 17 A Other than solid enclosed raceways -~ ) i { 18 MR. DAVIDSON: Right. He's already accepted i 19 that you've said that a conduit is a solid enclosed raceway, i i j 20 Now he wants to know, because you said that 21 both of those would qualify. 22 THE WITNESS: Is there anything else? l 23 MR. DAVIDSON: Is there anything else? And 24 you said, I take it, you think a conduit is a barrier. And 25 the question is -- is not that, although if that's not true 6 m. ______________.m_
l 76,257 1 please tell me. 2 What he's asking you is not whether'it's a 3 barrier, because I assume that's correct, but where in this 4 Reg Guide 1.75 you can find a conduit designed -- defined 5 as such a barrier, if anywhere. 6 And you may want to look through the entire 7 thing, but that's up to you. That's the question, I'think. 8 Isn't-that right, Mr. Roisman? 9 MR. ROISMAN: That's correct. 10 BY MR. ROISMAN: 11 g And I don't want to preclude, nor am I 12 intending to, that I'm -- that, Mr. Camp, you cannot say 13 to me what you said to me before '-- that I'm not going to 14 answer that because I'm outside your expertise. 2 15 I just want to know to the best of your a 16 ability the answer to the question ~I've asked. O; 17 A Well, I guess -- 1 l 18 MR. DAVIDSON: Do you want him to -- tI i 19 A l'm still a little confused as to what the j 20 question is. I'm sorry. [ 21 g Well, you have the phrase in the Reg Guide, { 22 "or other barriere," and we're looking at that phrase. 23 A Yes. I 24 0 And my question to you is, do you find l l 25 anything in the Reg Guide that tells you that the phrase 1
76,258 "or other barriers" -- not the word " barrier," but the phrase 1 "or other barriers" is intended to include or does include 2 3 conduits? 4 MR. DAVIDSON: Mr. Camp, are you -- 5 A Do I think that means " conduits"? 6 g Not do you think it does. _Do you find-any 7 support in the Reg Guide for whatever belief you have about 8 that? 9 A No. 10 MR. ROISMAN: I have no further questions. 11 I'm sorry. I went beyond two'. 12 MR. DOWNEY: Why don't we just adjourn until 13 after Mr. Mizuno has his cross, rather than have another j 14 redirect and possible a third direct examination. e 15 MR. ROISMAN: Agreed. + j 16 MR. DAVIDSON: A wise course, i j j 17 MR. DOWNEY: We're off the record. 1 3 l { 18 (Whereupon, at 2:20 p.m. the deposition was i i 19 adjourned.) i r t 3 s ^ ~ 21 7 1 22 23 Richard E. Camp, Deponent 24 25 i I C_____.____
CERTfFZCATE OF PROCEEDINGS 1 This is to certify'that the. attached proceedings before the-l 2 NRC COMMISSION 3 In the maeter of: ~ TEXAS ELECTRIC-UTILITIES-COMPANY,'et al d (Deponent: Richard E. Camp) ' Vol. 2 Date of Proceeding:
- August <3, 1984 1
5 Place-of Proceeding: Glen-Rose, Texas 6 were held as herein appears, and;that.thisJis the original _ I 7 transcript for the file ~ of the Commission. 8 9 l Margaret K. Schneider I 10 Official Reporter - Typed 11 L k/ 13 Off (J al. Reporter - Signature 14 15 16 17 l I 18 19 20 21 1 22 l l 23 8 24 l i l 25 TAYLOL ASSOCIATES REGISTERED PROFESSIONAL REPORTERS NORFOLK. VIRGINIA 4 -. _}}