ML20094R102
| ML20094R102 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 08/17/1984 |
| From: | Stokes C COMMONWEALTH EDISON CO. |
| To: | |
| Shared Package | |
| ML20094R063 | List: |
| References | |
| OL, NUDOCS 8408200458 | |
| Download: ML20094R102 (175) | |
Text
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.J _J:02.^1CE UllITED STATES OF A?IERICA tiUCLEAR REGULATORY CO;1'.cISkf/fD BEFORE T:iE ATO!'IC SAFETY .'dID LICE;ISI;!G BOA _7.D
'84 /fD 20 tif :19 In the matter of: .
CO'0:01TFEALTH EDISUN CO:IPANY, : Docket ros. 50- 454 OL
. 50 -455 OL Byron Nuclear Power Station, :
(Units 1 and 2) :
- _ _ _ _ _ _ _ _ _ _ .. _ _x 51st Floor Conference Room Isham, Lincoln & Beale Three First !!ational 1-laza Chicago, Illincis 60602 Friday, August 17, 1984 DEPOSITICII OP:
CIIARLES CLEVELA !D STOEES VOLUME II Ann Riley & Associates Court Reporters
. 1625 i St., N.W.
Suite 1004 Washington, D.C. 20006 (202) 293-3950 8408200458 840824 PDR ADOCK 05000454 m T PDR 50<3
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'd : '1 VOLUMN.II:
12 UNITED STATES OF-AMERICA
-3 . NUCLEAR REGULATORY COMMISSION od BEFORE THE ATOMIC SAFETY'AND LICENSING BOARD 15 - - _ _ _ _ _ _ _ .. _ _ _ _ _ _ _ _x
- 6 In the matter of: :
7 COMMONWEALTH : EDISON ' COMPANY, : Docket Nos. 50-454 OL-
- 50-455 OL
' 8 (Byron Nuclear Power Station, :
Units.1 and 2) :
9 :
_ _ _ _ _ _ _ _ _ _ _ _ _ .. _ _ _x .
10 51st Floor Conference Room 11 Isham, Lincoln & Beale
' Three First National Plaza 12 Chicago, Illinois 60602 Priday,' August 17, 1984 13 O 14 DEPOSITION OF.
t 15- CHARLES CLEVELAND STOKES, 16 called for examination by counsel'for the Applicant, 17 Commonwealth Edison Company, pursuant to notice and
- 18 agreement of counsel, in the offices of Ishan , Lincoln &
19 Beale, commencing at approximately
, 9:45 o' clock, a.m.,
20 before ANN RILEY, a Notary Public and court reporter.
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1 . APPEARANCES OF'. COUNSEL:
2 For the' App _licant Commonwealth! Edison Company:
3 JOSEPH ~GALLO, ESQUIRE MICHAEL.GOLDFEIN,' ESQUIRE 4 Isham,--Lincoln & Deale 1120 Connecticut ~ Avenue, Northwest 5 Washington, DaC. 20036 6 For the Nuclear Regulatory Commission Staff:
7 _ STEPHEN H. LEWIS, ESQUIRE
~ Office of the Executive Legal Director 8 U.S., Nuclear Regulatory Commission Washington, D.C. 20555 9
For the Joint Intervenors:
10 DOUGLASS CASSEL, JR., ESQUIRE & TIMOTHY WRIGHT, ESQ, 11 Business and Professional People for the Public Interest 12 109 North Dearborn Street Chicago, Illinois 60602 13 f)
'\. ja 15 16 ALSO APPEARING:
17 Robert Hooks 18 Lou Del George 19 James Muffett 20 21 22 s
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CHARLES: CLEVELAND 5 STOKES Mr. Wright 4 6 - Mr. Gallo "7
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~ ~mgcl-ll 'l P'R C E E D I li-G S 2 This is-the second deposition of MR. GALLO:
3 Mr. Charles Stokes, being' scheduled in accordance with' d
-the agreement of.the parties, and I think we will refer 5 to'this deposition officially as the second deposition 6
of Mr.. Charles Stokes'.
7 Whereupon, 8' CIIARLES CLEVELAND STOKES, 9 was called as a witness and, having been first duly sworn, 30 was examined and testified as follows:
11
~ MR . GALLO: Mr. Cassel, you have some corrections, 12 or Mr. Wright, do you have some corrections you want to 13 make to the testimony?
73
\-) Id MR. WRIGHT: Yes, we do.
15 EXAMINATION 16 BY MR. WRIGIIT:
17 Turn to page 4 of your prefiled testimony. Do Q
18 you have any corrections to page 4?
19 A Yes, I do.'
20 Q And-what'are those corrections?
21 g -- In roughly the middle of.the top question, it 22 says in myireview, I have reworked a' number of engineering
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5 mgc -2 calculations. It should state, "In my review, I have 2
reworked aspects of a number of engineering calculations.
MR. GALLO: Wait a minute. I missed that.
4 What line are you talking about on page 4?
5 THE WITNESS: It's roughly the middle of the page.
MR. CASSEL: It's the twelfth line, Jim. We're 7
on page 4, line 12.
THE WITNESS: That should be " aspects of a 9
number of engineering calculations."
BY MR. WRIGHT:
11 Q Now, Mr. Stokes, why are you making these 12 corrections?
'~x A Because the documentation I reviewed, I only 14 had parts of the calculations. I did not have the entire 15 calculation to review, and therefore I only reviewed 16 aspects of the calculations.
I7 Q Okay, Mr. Stokes, do you have any corrections
'8 on page 10 of your prefiled testimony?
'9 A Yes, I do.
20 Q And what are those corrections?
21 A It's the bottom of the second paragraph of 22 question -- or Answer 12. "The result would be an e
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I-allowableistress larger than allowe'd by code," rather than 2
"the, higher" --Lit would~be higher, but it's also' clearer.
- 3 MR. GALLO: Do you want to repeat that d
correction?.
.5 THE WITNESS: "The result would be an-alowable 6
-stress larger than-allowed by code."
I BY HR. WRIGHT:
8 Q Now, Mr. Stokes, why are you making that 9 '
correction?- -
10
.A- Well, the. answer as stated is. correct, but it's II not precise enough. It's more correct with the change 12 that's made.
' I3 Okay. Now, Mr. Stokes, do you have any corrections Q
' Id on page 26?
15 A Yes.
16 0 And.what are those corrections?
17 A Well, after:the 200 -- after the KL/R in the I8 first paragraph, and the 300, the foot and feet should 19 be canceled. Ther200 do's J e not have a units term.
20 MR. GALLO: I didn't understand the correction.
21 Do you want to -~ just tell us what the correction is.
22 THE WITNESS: KL/R is 200, period -- exceeded 9
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2 MR. GALLO: So you have deleted " feet" from the
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-third line, and you've deleted " feet" from the fifth line; -
'd- ~is that it?
5 .THE WITNESS: And " foot" on.the third line at 6 the end.
-7 . MR. GALLO: Oh, okay.
8 BY MR. WRIGHT:
'9 Q- Now, again,.; Mr. Stokes, why have you made. _
10 these corrections?'
11 A As I said,.the factor'is unitless. This section 12 of the testimony was typed up at my direction, but 13 inadvertently overlooked.. It was handled by my attorneys, O 14 and undoubtedly there was a misunderstanding as to that 15 section of the testimony.
f 16 Q Are there any other ' corrections that you have to 17 make to your testimony?.,
18 A , No. c 19 MR. WRIGIIT: Okay, Joe, I think that ends our.
20 portion. s 21 EXAMINATION ,
22 BY MR. GALLO:
23 Q Mr. . Stokes, would you state your full name and v
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%>.mgcl-5 1 business address for the record?-
2 'A lit's Charles-Cleveland Stokes. As I have stated i '3 earlier, I have no- specific business address. I use my 4 permanent res'idence address:as such -- Route 1, Box 223, S . Cottonwood, Alabama.
6 Q And is the' organization-you are with-called' 7 .P-S Associates?
8 -MR. WRIGHT:' Joe, let me just ask a-question 9 before we proceed with this. A lot of the information 10 we've gone into in'the first deposition, and to that extent, 11 Lit's repetitive, and if we're just seeking a little 12 background information to get us started, I think.that's
,, 13 contained in the first deposition.
k-) 14 If.there's-any othernreason for these questions, 15 I would like some type'of an explanation.
16 MR. GALLO:- Well,- I.just want to affirm that 17 P-S Associates operates out of-the address he just gave me.
18 I don't know if that's in the first deposition or not.
19 MR. WRIGHT: I think it is.
20 MR. GALLO: Well, I'd like to get an answer to 21 the question, in any event.
22 THE WITNESS: The question is if P-S Associates 1
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2- MR. GALLO: Ye's, I know.
-3 BY MR. GALLO:
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.Q But'is'that the name of'your. organization, that' 5 you're with,'as-indicated in Answer 2 toLyour testimony?
6 A I am a member of P-S Associates, or that is an 7 ' organization which I belong-to,-yes.
8 Q. All right. Well,.'does P-S-Associates have a 9 business address?
10 A No, End-l 11- Q' Your testimony says.that you graduated _from 12 Auburn University,in 1975 with a BCE degree. What do
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13 -those letters stand.for?. '
.O 14 A Bachelor of Civil Engineering.
15 0.' Was that a.four-year curriculum at Auburn?
16 .A It' was. ,
17 0 And..if-<I. understand your testimony, this is your 18 only engineering degree?
19 A It is.
20 Q Did you take any course work at Auburn in the 21 field of structural dynamics?
22 A I did.
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..1 :Q What was that.. course work?
- 2 A I took structural mechanics, dynamics, strength
- 3 - of' materials, stedl-design, concrete design;--
4 ~Q _ Wait-a minute. Wait a minute. You're going too
. 'S fast.
6 ~ You say you took' structural dynamics? '
7 MR. .CASSEL: No. Ile said structural mechanics.
8 Then_'he said' dynamics.
9 BY MR. GALLO:
10 0 ' I'm sorry I interrupted you, but go a little 11- slower. ,
12 A Structural mechanLics," dynamics, as an ME. course.
13 Q.-,
- Okay.
14 A' Strength f materials. 'Three different courses 15 in structural analysis. One of the final courses in that t6 area was structural analysis. The first two were subparts 17 of structural analysis.
18 Q Can you remember what those were?
19 A Not specifically, no. They were involved with 20 - structural design, but leading up to structural analysis 21 as a whole, and then structural steel design, concrete 22 design, foundation design as a structure, and I consider a
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' #mgc2-2 ' course which might be-excluded from structures per se, 2
but applicable to structures, soi]' analysis and a soil 3
stabilization' course.
-Q Now'I take it.that these are the names of 5
individual courses that you took while you were enrolled.
6 in Engineering School at Auburn; is that correct?
7 A. Yes, the three-that I listed as a group in 8
structural analysis, I didn't break down to names, but the rest of the course names per se.
30 Q. But you are telling me that in the structural
' analysis area, you took three courses, the last being 12 structural analysis? ,
I3 A' Yes.' '
'd Q Now you say you took a course called " Dynamics,"
15 and what did that involve?
16 A It was an ME course in dynamic loading, dynamic 37 forces and the use of those forces in calculations and 18 stresses.
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I' O And involving what design?
20
.A Anything -- structural, aerospace, any mechanical 21 component, machinery -- any item.
22 Q so this course work -- this particular course was a 4
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3 ~Q Mechanical dynamics?. ;
4 A. -Yes.
5 .0 Did you take any course work .in seismic analysis?-
'6 -A No.
7 Q Now I've_got a series of questions I want to ask.
- 8 .you about your work experience.
9 Based ~on'my-review of.your testimony, it appears .
that-you worked 'for two and a half years as a draftsman
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12 'MR.' WRIGHT: Obj dction~. Joe', this is the T
13 second part of the' testimony.- In the first part, these
.O 14 questions were asked and answered, and that's the basis of 15 my objection.
16 MR. GALLO: Okay. Objection noted.
17 MR. CASSEL: Well, I-think we may go farther than 18 that, Joe. Is there a need to go -- you know, this 19 material -- his resume was available at the first l
20 deposition. All these things were listed. I forget whether 21 it was you or !!ike that asked this series of questions 22 about this whole area.
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-4 mgc2 1 MR. GALLO: Well, the1 resume was made available 2
just prior to the deposition starting last time.
3 Mike' Miller took the. deposition, and it was an illegible d ~
copy-for the most part. I don't recall that these 5
questions were' asked just in the way I am'about to ask 6
them. In any event, I want to ask them, unless you are.
7 going to instruct the witness not to answer them.
8 You can object on whatever grounds you see fit, 9 but I want.to ask the questions, and-I expect answers. -
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, 3 10 A Well, IlmayLwant to instruct the
, MR.lCASSEL:
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II witness not to go over again the same ground that was gone 12
-over before. It's unusual, as you know, to make a witness 13 r- available for a second deposition in a case. We are doing i
N- y4 it here, because he now has prefiled testimony.
15 MR. GALLO: Well, I guess we're going to get-in 16 an argument , then. What do you mean, it's unusual, 17 because the unusual circumstances stem from.the fact that la you weren't prepared and able to go forward at the time 19 the schedule was set by the Board, due to the fact that 20 you just couldn't get your witnesses together and-get it 21 done. The understanding was that we would have a second 22 deposition; isn't that right?
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() 'mgc2-5'1- -MR'.lCASSEL: The understanding ~was:that we would 2 makeshimEavailable for a second deposition,, based on his 3 prefiled testimony, which~was the reason.--
4 MR. GALLO: 'And I am'asking questions from-his 5 prefiled testimony.- ,
.'4 6 I'm sorry. Go ahead.
7 : MR. CASSEL;. If you have-a particular area or-l >[
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8 point that'you think was'not sufficiently addressed in-9 the first deposition - we. don't want to be unreasonable, to but I don't $hink any of us want to sit here and spend the 11 .same two hours that Mike spent the first time.
12 To the extent that resume was-illegible,
, 13 Charles explained the answers in the first deposition.
'~ I4 MR. GALLO: Well, be that as it may,-these are 15 the questions I want to ask and as I believe it's 16 appropriate to ask them, and you will just have to take 17- whatever action you think is necessary.
18 MR. CASSEL: Well, let me tell you what our 19 position is. Our position is, if you can give us a 20 particular reasons why you need to go over this same 21 territory again, a particulhr line of inquiry you want
.22 to pursue that wasn't pursued before, we'll entertain that.
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' ; m'gc2-6 But otherwise we will instruct the witness not to answer a whole' series of questions about his resume, which was 3
. extensively answer.ed in the.las't deposition.
d 2 Mii. GALLOi .:Well, I don't-think I'have to S
justify ~'and; establish a reason why I want to conduct this ,
6 line. Iithink'is s an;appropri te'line, and I. intend
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7 to ask the questions.
8 MR'.'CASSEL: Well, I'm' telling you right now,
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we will. instruct the witness not to answer any questions .
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'about his work background, unless you can state a II specific reason how this goes beyond the first deposition 12 or --
I3 MR. GALLO: I don't have that burden. You have 14 that burden. My recollection is, I have a. question here, 15 "What is a detailer?" That question wasn't asked, and to y,m about to ask it.
I7 MR. CASSEL: All right. Well, we'll listen to
'8 them one by one.
I9 MR. GALLO: All right.
20 BY MR. GALLO:
21 0 Let me start again with the question prior to 22 tha,t , time. -- am I reading your testimony correctly,.
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16 T._/ ~iA m g2 7- 1 Mr. . Stokes'-- that you worked for two and.a half years 2 for Southern. Services as a draftsman and detailer,
- 3. .approximately?- '
4 MR. CASSEL: I am going to. object to that
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S question;and1 instruct the.Nitness notx to answer that. That 6 was'specifically asked andl answered at the last deposition.
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7 MR.'GALLO:' You:are instructing the witness-8 not to answer?'
9 MR. CASSEL:. That's right.
10 BY MR. GALLO:
11 0' .Mr. Stokes, what is a detailer?1 12 'A A detailer is one who has responsibility for
~
13 doing certain aspects of a design. He does do design O' 14 work, but he's a member of the drafting department.
15 Typically he would be considered a designer in the drafting 16 department, rather than a draftsman.
17 0 Do I understand, then, a detailer is a higher 18 level of competence than~a draftsman in the order at 19 Southern Services?
20 A Yes.
21 0 All right. So the draftsman, then -- what 22 .
were your duties as a draftsman for Southern Services?
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W 17 k-/.m gc2-8 1 A Well,.as a' draftsman, I did neat line 2 reinforcing drawings ~for concrete, neat line drawings for 3 structsral steel.', I did,the rebar takeoffs, figured the i .i .
4 splice lengths" required for embedment, and I'did do some 5
detailing as a;draftsperson,.-in that I detailed rebar s
6 around' openings, expansions. I detailed molded Connections.
7' Q All right. I'm sorry tc interrupt, but I want ;
8 to try to get the record clear.
9 My question was limited to draftsman. I'm 10 going to ask you about detailing, but I have some 11 follow-up questions about your duties as a draftsman, 12 based on the terms you just used in your answer.
13 When you said you did neat line drawings for 14 concrete and structural steel, what does " neat line 15 drawing" mean?
16 A It's the line diagram showing the extremities 17 of the concrete in the poured condition, locations of 18 openings. It shows embedded items, placements, locations, 19 the item numbers, the slope on the concrete for drainage.
20 0 These are all noted on the drawings?
21 A Yes.
22 O What kind of drawings would these be?
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2 0 hey 1are called neat line drawings?
3
- A The specific title.
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Q And'what are,they u5ed for?
5 A Building the rebarsupporting_ structures, forming 6
the' concrete, decking the pit if it's below ground, grading 7
for pouring the concrete, all --
a 0- And what are rebar takeoffs?
,A A rebar takeoff is a listing of~the steel'
'O straight lengths, bent pieces, the necessary pins Il
" required to form the piece. It lists the tonnage, the 12
- sizes of steel, the tonnage per size. It may list a 33 few other items, but that's basically it -- the strength-Id of the' steel required in'the rebar.
15 0 What kind of structures were involved with these 16 particular drawings that you were working on?
17 A I worked on both fossil facilities and nuclear
'8
< facilities -- neat line drawings and robar drawings, l'
O Can you be a little more specific as to what 20 elements of these facilities you were involved with in 21 this work? Take the fossil first.
22 A Well, over the timeframe that I was doing this I
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- 3 A -It's the" Miller steam plant. It's.a fossil
- d. . plant. It's called Miller steam plant, but it's a fossil 5 - plant.
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6 I worked on pool boxes, miscellaneous outdoor- ,
7 structures on'Farley nuclear. plant.
8 Can you identify one of those structures for me?
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9 :You' called'it an outdoor structure. ,
30 A Well, one of the type things I' worked on was 11 the pumproom, the box. It was --
12 The pumproom box?
Q 13 A Yes.
O Id 0 Did this involve safety-related equipment, do 15 you know?
l 16 A Yes, it did.
i i End 2 17 0 Explain to me the difference, then, between 18 a draftsman and a detailer.
19 A Well, a draftsman typically may do some detail
- 20 functions, whereas a detailer, that's classified'a 21 detailer, specifically does nothing but detail functions.
22 Our designers at Southern Services when I was r- ,
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as a draftsperson, . I was not just a draftsperson, in that 3
I was there as a co-op, and engineer co-op, and so I was d
allowed to do detailing functions that normally.the 5
designer would do as training in the co-op funct' ion.
6 0 Can you explain to me what that program was?
7 I am referring to the engineer co-op program.
8 A The program is set up, allows.a student to attend college one semester or one quarter and then work 10 with the company. The work in the company is geared towards 33 what he will be doing upon his completion. In other words, 12
-he'll be working in the same aspect as his degree would 13 be -- civil engineering. It would be in functions -- the
'd duties he would be assigned would be functions that would 15 be important to make that person, that graduate, a better 16 engineer upon graduation, knowing what should go in a 17 drawing, neat line, reinforcing, how to detail rebar, is detail molded connections, draft a document - necessary
'9 training for an engineer after graduation, in that if he 20 was to review that document, he should first have done it 21 to know what was on it.
22 The tasks varied from semester to semester. As I O
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'mgc3-2 said, every'other semester I was in school, and every other 2 semester I was'at work. I was rotated around-the various 3 departments from the concreta fossil, structural' steel
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' department, to nuclear concrete and nuclear steel department.
5 - That's the way Southern Services is set up.
6 So if I understand your testimony, you worked
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- 7' one semester and didn't go to school and then went to l.
8 school the next semester-but didn't work?
9 Did I understand that correctly?
10 A I didn't go to school, but I was going to school 11 for my degree, and while-I was co-oping I took courses 12 l at Birmingham, the University of Birmingham, an extension r
13 of Alabama, at night.
Id 0 Were these engineering courses?
15 A yes, l
16 0 Well, just for my information, when did you then 37 first enroll at Auburn?
18 A I transferred to Auburn in the fall of --- let's 39 see, I believe I went in early -- the fall of '70.
20 I would have to look back at records. I attended a l
21 junior college before I went to Auburn.
22 l 0 What junior college did you attend?
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.in Dothan, Alabama.
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Q .How many years were you there?
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~A It's more like quarters,-but roughly four,.I 5
think.
6 0 Four: quarters?
7
.A Yes.
8 ~
Q Then you transferred to Auburn from out of'that school?
IO A Yes.
'I
'O Did you transfer directly into the Auburn 12 Engineering School?
13 A No, I didn't. !
14 0 Can you explain why not?
15 A Well, when I first started college, I started to in aerospace engineering. The aerospace had roughly 37 20,000 men laid off one year after I was in school. I also is was sick. It changed my aspects toward life and what I l'
felt I wanted to do with my life.
20 I attended a drafting department course at 21 George C. Wallace for six months. As a result, I decided 22 I'd'be an architect. I transferred to Auburn in the r
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- mgc3-4 1 architectural department. In the late fall of '70 or '71, 2 I'm not sure.
3 I see. So you essentially started out afresh Q
4 in either the fall of '70 or '71 at Auburn, is that it?
5 A Not exactly. All the course work I had taken 6 for aerospace was more atvanced than the course work for i
7 the architectural department. The courses applied, though, 8 in the case of technical electives in the architectural 9 curriculum, and what that did was it upset my schedule.
10 and to counter that upset, I took courses in the building 11 technology curriculum and was working on a double degree.
12 Q I see. Now after you graduated in May of '75, 13 you became an assistant engineer at Southern Services; 7s
( I
14 is that correct?
15 A yes.
1,6 Q Your testimony indicates that you designed 17 outdoor structures on the Miller steam plant. What were 18 those outdoor structures?
19 A Right after I graduated, I worked on the ash 20 trench system, which was a system of structures. It was 21 primarily a trench, concrete canal. It also involved 22 road structures which were in compliance with ASSIIO.
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(_) mgc3-5 -1 Q .With what?.
J 2 A. Bridges, basically. (.
3 Q .rWhat was the term you just used?
4 A ASSHO.
5 0' Spell that, please.
6 A. It's ASSHO -- A S S H O (spelling acronym), I 7 believe.'.It's'American--thatbayevenbean' incorrect e one. It's' basically the Highway Department code 9 requirements.
4 10 / 0 For the state of Alabama?
11 A Yes. And I think the federal government f
12 requirements were met. t
( '
13' - O All right. I'm sorry I interrupted you. You O 14 said t!!at you were involved in the design of a concreto 7
15 canal trench system and road work?
16 A Yes,-the road work. I also did piers and i 3
17 abuttments for a pipe bridge that spanned a creek. I did is the concrete piers and abuttments for a bridge for trucks :.
19 which. carried wet fly-ash to the storage pond or damp 20 area. I basically handled structures at various locations !
21 along the piping system from that point on to the storage 22 facility, supporting structures, kick blocks for that '
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_______.__.__.___..____________.______.___m__.__ _ _ _ . - . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ ___.___ - _ _ _ _ _ _
b 25
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! t l mgc3-6 ' I system. I designed'the abuttments and piers for a 2 rail coal-unloading bridge that spanned.that tunnel or that 3 trench for the coal-unloader at the plant, d I_ designed a roadway to facilitate transportation 5 of the wet fly-ash trucks from the transfer point from 6 where,the ash was separated from the slurry, so that the 7 trucks could cross the bridge to this storage facility.
a without making a very sharp turn.
P 9 I worked on makeup water lines offsite, thrust ,
10 blocks, cut-and-fill drainage, and other things. There 11 was many other things I did.
i 12 Q Let's return to the concrete canal or trench 13 system. What exactly were your design responsibilities O 14 there?
15 A It was designed to withstand side loading from 16 soil and water pressure, large cranes sitting next to 1/ this structure, surcharge from trucks, because many of the I 18 canals ran right next to the road structures. On top of 19 that, it was designed for these large soil-moving machinery ,
! 20 loads as surcharge.
21 Q Did you do all the design work yourself?
22 A I did it, and it was checked by another; engineer.
J N O
26
- mgc3-7 1 0 ' But you were the principal engineer in charge 2 of this design; is that --
3 A Yes.
w 4 _Then in -- ands I take it again, all these items Q
5 you enumerated involved structures associated wi'th the 6
Miller steam plant, correct, $he ones you just --
7 A The ones I just, yes, yes.
8 Then in July of '78, if I understand your testimony Q
- correctly, you were promoted to an engineer classification 10 called Engineer Roman II?
11 MR. CASSEL: Wait a minute.
12 THE WITNESS: This is my resume, and it's coming
, 13 off my testimony, but it's a little bit different.
V Id MR. CASSEL: I want to check your resume, though.
15 It's from your testimony, page 10. I just wanted to see 16 if it was on your resume.
17 THE WITNESS: Well, the thing with my resume --
18 okay. ,
19 MR. GALLO: Do you have the question?
20 THE WITNESS: Would you repeat it?
21 BY MR. GALLO:
22 Were you promoted to an engineer classification, Q
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' D[YDmg63 , I RomanLII, in July of 70.while;you were working at 3 .2 ' Southern Services'?.
.3 ~A~ 'Yes.-
4 _
MR. GALLO:: Can'I.,go off'the record?
- 5 (Discus'sion:off the. record.)' .
i 6 MR. GALLO:_.Let's go b'ack on the record. s L 7 (Discussion off the record.~)
-BU-2.End-3 8 .MR. GALLO: All^right, let's'go on the record.'
9 BY MR. GALLO: , l 10 Q Mr.. Stokes, during the' time that you were working
~
11 Lat Southern Services as'an: Engineer' Classification Roman 12 Numeral II, you indicate-in your-testimony that you
. . 13- performed what-is called NRC 79-02 analyses.- Just what
- O. 14 is that~ type of analysis?-
-Well, actually it was NRC Bulletin 79-02 and
~
15 A 16 79-14 analyses. It's analyses to meet the requirements
_ 17 of those two bulletins. 79-02 is anchor bolts, I believe,
- - 18 specifically anchor bolts, and 79-14 was baseplate-19 The analysis primarily required-a complete reanalysis 20 ofLstructurss.
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- 21- .0 ,1 gSo the-recordfis not confused, tell me what
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type ,.;of.,
- 22 analysis,you did with respect'to 79-14.
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5 J~mgc4-1 'l 'A I performed-STRUDL calculations, the structural 2 steel stiffness calculations, stress calculations, 3 calculations on,the plates.
4 ,Q What was the purpose of these calculations?
5 A To ensure that components were within. code o allowables.
7 And is the component we're talking about the Q
8 baseplate?
9 A It was primarily geared to the baseplates, but 10 as I said, we redid the entire structure for this work.
11 Q When you use the term " entire structure," what 12 are you talking-about?
13 A It covered every component from the point of
14
-attachment to the pipe down to the plate and the bolts.
15 We reverified the entire structure. The attachment 16 hardware that was purchased was reverified. The load 17- capacity, the stiffness, the flexibility of the system 18 was reverified in com'plete, in effect, in performing 19 these calculations, which were:specifically bolts.and 20 . plates. We' redid the entire work that had been done.-
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- 21. Now where were these plates.and' bolts located?
22 A In the Farley nuclear power plant.
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'-^ mgc4-2l O Was-it in the turbine building or the containment 2
-building or where?
3- A- 'The stuff'I worked on was containment,-main 4 steam, all over'the auxiliary building. Predominantly 5 all I worked on was containment. A lot of this stuff 6 was Westinghouse's original scope that we redid ourselves.
7 Westinghouse kept the whip restraints. I don't remember 8 wo'rking on any whip restraints during that time, although 9 I think. I did do some field work for Westinghouse as-to H) determining-whether or not something would workifor~them.
11~ What was the purpose of these baseplates?
Q I2 A Baseplates were the transferring load mechanism 13 between the structure and the bolts to the concrete Id structure or supporting structure.
15 Q So on the one end you had the building structure 16 Were the embedded;in the and at-the other, the baseplates.
17 concrete for the building structure; is that it?
l 18 A The ones thht were embedded in concrete were
' 19 not part of this program. 79-02 limite'd the work'to those 20 with expansion type anchors,'I believe.
21 We.'re1 talking 79-142now?
Q ,
22 A Yes.
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- mgc4-3 Q And the' baseplates,'what is attached to the 2 ~
baseplates? You told me one end is the-structure. What 3
is attached.on the other end?
! A There's nothing. -It sits on concrete.
5
-Q What are they used for?
6
.A To transfer load to the concrete.
7
.O What component sits on th'e baseplate, if any?
8 A The structure that's~ attached to the-plate, 9
small-bore, large-bore piping systems, HVAC, electrical
. 10 conduit structures. Primarily.this work that I worked on I
here was all~large and small-bore piping systems.
12 Q. All right. I guess that was the source of'the 13 p confusion. When you use the term " structure," you are Q '#
referring to both the building and the equipment components; 15 is that right?
16 A It i~s'both;the-structures, yes. One is --- I 17 l use structure," if it's the overall building structure 18 as a structure,;and'I use " piping' su'pport structure" as
'9 a struc'ure.
t HVAC supporting steel is a structure and 20 electrical conduit supporting ~st' eel, all the way including
~
21 the building is all one continuous structure, as far as I 22 am concerned, if that clarifies what I was trying to say.
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-# mgc4 Q Now what'did you do, what type of analysis did 2
you preform under I&E Bulletin'79-02?
3 A. Well, they were mixed. Both functions-were-
_ performed at the same time. I verified that the anchor 5
bolts were acceptable, that the loads being transferred 6-to them through these plates from'_the structure. I verified 7 ^
that the concrete could take the load'from these anchor 8
bolts.
9 Q All right. You testified that you redesigned
'O the precipitators structural steel on the Miller steam- ,
' plant. Can you tell me what a precipitator is?
12 A Well, I said when I was co-op,.I worked onuthe I3' ash trench system. That system primarily originated from Id the precipitator.- The precipitator is an electrostatic 15 precipitator'.s -All the smoke and exhaust from the plant 16 went through' the precipitators before going to the stacks.
'7 The precipitators electrost'atically removed the fly-ash
~
18 particulates down to a certain criteria. It'was rinsed or 4
'9 transferred'to water, a slurry system, which was actually 20 pumped from the precipitator area out to the storage 21
- facility. It's a very large machine, very large.
22 Q You indicate that you were involved in the design-y.
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- 3- 'm'gc4-5. 1 of-the struc'tural steel aspects of the precipitator. Can 2
- you explain'to me what_thoseLaspects were?-
3 A Well, basically like I said, the;precipitator is-
-4 I'll give you some dimensions.
a large structure. It's-5 maybe 400 feet' tall. It's 400 feet high, 200 wide, 400.long.
6 It's large enough'for a football field, roughly. The
'7 structural steel then is like a very large building. It's 8 built to enclose all the equipment and support it for 9 this --
10 Q- That's all right. Did you do the design work' 31 for the structural steel?
12 A The initial design work was done by someone else.
13 Q And w' hat' design work'did you do?
' 14 A Well, when'I~was assigned to the project, they 15 wanted to enclose the roof. >They. wanted:to put a crane 16 on top'of the'roo'f to remove cert'ain very heavy objects.
17 They didn' t.want- to bring around one of these 'oig- boom 18 cranes to lift things off every time, and so they-were 39 wanting to add a crane on it. fly job was to redo the 20 structural steel analysis for the frame to determine the 21 loads from this new support, the new structure, to design 22 it for the' wind loads at the plant. It had to be designed p.-
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-and atLthefsame time.I'had to determine the. locations on d
the.precipitatortitself.that we could. attach this structure,
-5 because ' the structural steel itself. did 'not .cg> up to -that
. q w; 6 level. The top.two 40' feet.or so.was precipitatorrentirely.
7 There was no' structural steel there.
8: And I had to-' review the precipitator drawings 9 to determine where it could support the loads I was 10 ; talking:about putting on it. I spent some time in doing 11 that analysis.
^
12 g: What code didjyou-design to?
13 A The structural. steel was designed to the AISC
.O. . 14 Code.- STRUDL was used, asfhad.neeh,us'ed in the original
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15 analysis. The STRUDL design code check was used to-16 facilitate verifying.that each; member was capable of taking 17 the stresses. In STRUDL, the termal loads from the 18 expansion were used to force the frame to stretch. It1wasL 19- used on the analysis of the roof to force the side members 20 to expand outward against the bolts"which were attached 21 to the precipitator.
22 The reason for-it was the precipitator grew out,-
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3 It. displaced the frame, and the frame was verified for 4 the loads, and'the connections were designed to take thato
'S load component at the precipitator location.
6 Q STRUDL is S T R U D L (sp'elling) ?
7 _A. Yes.
8 Q ThaU s a computer code?
9 A Yes.
io Q And,this is.what you.were talking about, applying n this computer code in the design work you did?
12 A -.Yes.
,, 13 Q Were you involved in the, development of the 14 computer code?
15 A No .-
16 Q This design analysis for the structural steel 17 on the precipitator that you performed, did it involve is any seismic analysis that you performed?
pg A Not on the precipitator at Miller, no.
20 Q_ You also testified that you performed some-design 21 work involving structural steel of the coal conveyors 22 for a fossil plant called Scherer, SCHERER (spelling).
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_ i 'Can you explain to me what your design 2 responsibilities were in that effort?
.3 A To' design the structural steel again.. It was a
.4 conveyor system that'went from the building, which was 5 . roughly a couple of hundred. feet off the ground level.- The 6 system went from that grade, transferred - .it was a slope 7 -structure, went down to grade. It was a series of. vents e and towers in between to support the ends of these frames.
9 It, too, was enclosed. .
10 Q Was STRUDL used on that work?
11 A- <
No, it wasn't.
12 0 .Was' any computer- code: used for assistance in that m . 13 work?
14 A Not'in the steel design, no.
15 Q Did the steel design for this conveyor involve 16 any seismic analysis?
17 A Not on the fosil plant; no, it didn't .
la Q Then your testimony indicates that you left 19 Southern Services in May 1980, and you went to work for-20 Bechtel. And you testimony indicates that you performed 21 analyses for Bechtel. Again, they're called 79-02'and 22 79-14 analyses.
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-I-assume -- and correct me, if I'm wrong -- that 2 these are the same as the ones we just' finished discussing 3 thas you performed with Southern Services; is that correct?
4 A They were similar in the respect that they were 5 79-02'and'79-14, but Bechtel had their.own requirements 6
for meeting those bulletins, which differed,from the 7'
requirements of Southern Services, so they were different.
8 Q But theLI&E Bulletins were the same.
9
.A, Yes.
10 Now as-I understand-your testimony, you left Q .
II Bechts1~in October of '80, and as I understand'it, you 12 went to work for Nuclear Services then; is that correct?
13 A Yes.' That's --
Id You indicate that you-worked on Zimmer. What Q
15 was the nature of your work on Zimmer?
16 A Reverification, I believe, primarily. The 17 structure was already there. We reanalyzed the entire 18 structure, the pipe supports.
19 Q You're going to have to help now. What kind 20 of structures?
21 A Pipe-supports, the work that-Quadrex was working 22 on for Sargent & Lundy was geared to the small-bore piping
37 i 3-
'/ mge4-10 1 systems predominantly. There was some large-bore worke 2
given to us to do.
3 I also did pipe stress calculations in relation 4
to that work.
5 Now we're talking Zimmer, right?
Q 6 A I was -- Well, Quadrex, in the office, Yes.
7 they had decided,tofform a special team that could do pipe 8 stress and pipe support calculations to resolve several 9 systems.in the field.- It s'eemed several lines had been 10 run at some distance from any supporting structure, and 11 it was very. difficult for the stress group to decide where 12 to put supporting steel, because they primarily didn't have 13 hanger background, and in any case, I was part of the g~ ., .
() _
14 special team that was taught in-house pipe support and 15 pipe stress design and then sent to the field.
16 Q I see. Now you have to bear with me because 17 I don't understand this engineering analysis very well.
18 When you did these small-bore piping and pipe 19 stress analyses, just how did you perform these 20 calculations? Did you develop the loads, or were those 21 loads given to you by someone else? I'm trying to pinpoint 22 just exactly what your responsibility was.
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did that'for us in the work we were doing on Zimmer at 4 Later, I became sort Quadrex was.another Quadrex group.
5 :of a part of that group and part of the' pipe stress group.
- 6 And for part of -Lths work, I generated my own pipe stress 7 -loads a d did the analysis.of the structure, but for the 8 most'part,Ait was just me-taking-loads that were given 9 to me and designing the_ structure or reverifying the 10 structure for'adequa'cy.
l' Q How did you accomplish that? Can you explain.to.
12 me how you' accomplished that?
13 A f- It was the use-of hand calculations and computer Id analysis.
15 0 And what kinds of loads'were furnished to you?
16 What kinds of-loads are we talking about? Static loads, 17 dynamic loads, which one?
18 A Both.
19 Did it include seismic loads, too?
Q 20 A yes, 21 What computer code was involved?
Q 22 A I believe-in doing the computer analysis, a program i
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- 2' relying on' memory of the-system they used, but I believe 3
. i t' w a s .P I P S Y S_. - ,
4- PcI'P S~YL (spelli g)?
Q 5 .A Yes.
End-4' 6- S / Y SE(spelling) .
MR." LEWIS.: 4 i
'7 Nha't did you say it-was?
~
MR.~ GALLO: Excuse me'?
8 MR. MUFFETT: - P I~ P : S LY S (spelling).
9 BY MR. GALLO:
") Q Were you involved in the development of this Il particular computer. code?
12 A Oh, no.
13 Q- Your testimony indicates that you were assigned
(-)
Id to LaSalle. Did you actually'do any work for Quadrex on 15 LaSalle?
16 A- Yes, I did.
37 Q And what was that work?
~ 18 A Computer analysis.
19 Q You'll have to elaborate more.
20 A Piping systems, pipe supports.
21 Q The same sort of work you just described for 22 Zimmer?
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5- /;mgc5-1 I- A Yes. I was primarily running SAGS, computer 2 runs on' structures.
3 Q' Wh'at was.the-name~ofethis code?
d SAGS - .S A G.S (spelling).
A, 5
O- And'Nhat function did.this computer code serve?
6 A It's similar to STRUDL. It generated stress 7
levels.
8 Did you work on the development of this code?
Q 9 A No..
10 Was your work similar then to Zimmer? You were Q
11 given loads, and then you calculated -- determined whether 12 or not the pipe supports were' adequate to meet those loads?
13- A .Yes. That part of it, I was given' loads, yes.
,c4 14 Did you do any.other work at LaSalle besides Q
15 analyzing pipe supports?
16 A No.
17 Q After you left Zimmer -- I'm sorry -- strike that.
18 After you left Quadrex, you wentito work for 19 Lawrence Livermore Laboratory, correct?
20 A Yes.
21 - Your testimony indicates that you were a stress Q ,
22 analyst on the injector to the advanced test accelerator?
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A. On'the advanced' test accelerator.
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-2 Q WhatJ is'the-advanced'-test accelerator?
3 AJ Y Basically it's a particle beam injector, but I
~
don'tithink I should get-intb t'he ram $fications of how it 4
5 : works or anything, because it's part of the Department
- 6 of Energy's research contract wYth the. lab, and I do believe
~
7
~ I' signed an agreement to the effect_that I wouldn't:really 8 .g o ' beyond what' I :think I've listed in my resume or in this
~9
' document'in any discussion of what I'did.
10~
Q: Well, was it classif3'd defense work?
~
II
- A I was asked if I had ever been rated as a defense 12 security rating. I'm not aware that it's banned.
13 w Q Well, I've asked the question poorly. Did your 14 work on the advanced test accelerator involve classified 15 3 - work?
16 A In some respects, yes.
17 Q Was the'research work classified that was involved
'I8 with this particular facility?
19 A I don't think the research is' classified, because 20 it's been= listed in a lot of magazines.
21 That's what I thought.
Q 22 A' The work'I did on the design of the instrument
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.They'ye got'some discus'sion as"tofhow'it works, but not a ., .. , s . . ..
~3 to ths knowledge level that I hold.
4 Well,1can you tell me what the' advanced test Q '
t ,
5 accelerator does? What'is its function?
6 M R '. CASSEL: Before you answer that - . Joe, --
7 I've said it already.
THE WITNESS: I did.' -
8 It's a. particle accelerator. The injector-create's the 9 particles that are --
10 BY MIL GALLO:
" Q Is it involved in the research of high-energy 12 physics?
13
. f- A Yes, anong other things.
- k_ - Id Q Now your testimony indicates that you were the 15 test analyst on the injector to this machine. What is 16 the injector?
17 MR. CASSEL: I'm just concerned about getting 18 into any areas that may be --
19 (The witness and counsel confer.)
20 THE WITNESS: I'm not going to go beyond what 21 I've already said. It created the particles that were 22 injected -- electrons, protons. I mean, I'm not going to
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4-If you want to know more about how'it works, 5
I suggest you call the lab and-ask them for a tour.
6 BY MP.. GALLO:
7 0 .Do you'know how it works?
8 A Yes, I do. Most definitely.
O Now you indicate in your testimony that you'were 10 a stress analyst.. Just what did your job responsibilities
. involve as a stress analyst?.
l 12 MR. CASSEL: To :the extent ~ you can say without 13 breaching any confidentiality.
)
THE WITNESS: Well, there:was a mechanical-15 designer who'~did basic layouts for the components.
~
It 16 was also a group project by Physics'and other groups for 17 So initially there was'some~ drawing
~
the component shapes.
la made up of a component. I analyzed that drawing, . shape, 19 object, for the loads that would be exerted onLit'from 20 the machine ~-- electrical, mechanical, pressure, vacuum, lack of-pressure,-radiation, seismic load. I analyzed 22 that component for every possible load that could be applied
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.2 BElMR.-GALLO:
3 Q Did you define those loads, or were they given d
to you by.some other group?'
5 A. I defined those-loads predominantly. I was given 6
the magnitude of the electrical ' field that would be 7
~
exerted on them by the Electrical Department. The Physics 8
Department specified certain other criteria that they had 9
to comply with, but I generated the loads myself.
30 Q And did you generate the seismic loads.yourself, II too?
12 A Yes, I3 How did you do that?
Q O Id MR. CASSEL: Are we getting into a confidential 35 area with that question?
16 THE WITNESS: No. It's a UBC, at the University 17 of California --
IO MR. GALLO: I would like to state for the record I'
that it's my belief that what we're talking about is a 20 part of the Department of Energy's high-energy physics 21 program, which is unclassified, and the only thing one has 22 to concern oneself about is whether or not it involves
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4 MR. CASSEL: I have no reason to agree or disagree 5 with your belief, Joe. I'm not familiar with the program.
6 I'm only concerned that I want the witness to be very 7 careful that he doesn't go beyond any agreement that he may 8 have signed, whether it's based on proprietary or security 9 or whatever. He's not charged with knowing what the basis 10 for the agreement was.
11 MR. GALLO: Let's establish that for the record.
12 BY MR. GALLO:
- 13 Q Did you sign some kind of agreement when you left i
14 LLL?
15 A I think I signed some when I started at LLL.
16 Q What was the nature of the agreement?
17 A It had to do with drawings, calculations, 18 references to this instrument. No removal, taking nothing 19 with me. I don't believe I -- I'm not sure if it stated 20 I shouldn't discuss it.
21 Q Do you remember whether or not it was a 22 confidentiality agreement that barred you from talking n;
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-2 A At this moment, no, I can't say that it barred 3 me from discussing-it. It's on my resume.
d All right.
Q
-5 A But I don't think they want me to-sit down and 6 draw the parts out and build -- you know, show you how -
~7
,to build one yourself. If that's what you mean by 8 confidential, I think they want me to keep it'in my head.
9 I don't think they'd want; Russia knowing how they built 10 theirs, if that's what you mean. I think that's confidential, il yes.
12 Q Well, Mr. Stokes, do you or do you not know 13 whether the work you were involved with was classified?
O 14 I submit to you that --
15 A It wasn't classified as top security classified, 16 if that's what you re getting at.
17 Was it classified as restricted data?
Q 18 A It was restricted, yes.
19 It was restricted data, as that term is used by Q
20 the Department of Energy?
21 A I don't know what you're saying, "by the 22 Department of Energy. I was working for the lab, and it w.
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'/ Lmgc5-8. was' restricted.as.to how the lab could use it.when I left.
2 the lab.
" 3 Now you;say you signed this-agreement when you Q'
d took the' job at the lab. Did you sign another one-when 5 you left the lab?
~6 .A I'm not aware. .I don't remember signing one, no.
7 Do you have a copy of this' agreement?.
-Q 8 A No.
9 Let's get back to the definition of ;
0 .All right.
10 the seismic loads for the ' stress analyses you'did. I asked-il you the question how you' performed --- how you determined 12 or defined the seismic loads that you;used'in'your 13- analysis. Can you tell me that?
f~s.
U. I4 A I consulted the UBC, the Uniform Building Code, 15 .which is used in California to discuss the seismic loadings.
16 So you went to the Uniform Building-Code. And Q
37 didLit have a load value that you took out of the code-18 and used.in your analyses?
19 A It had equations for deriving the loads.
20 Q And that was the load.that you used, then, in-21 your analysis or -- strike that.
22 That was the load that was used in your stress rw n:
O .
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2 A7 I may have: factored the' load myself,,but --
~3
!(T What'do you mean by " factored the load?"
d'
.A 'I'may'h' ave a'dded an' additional. margin or:sadety 5 ._factdr'offmylown to'the load re. ting'to ensure that the
- ~
N component's integrity would not-be damaged.
- 7
, Q. .Do you' remember whether or not'you did?
At this time,:I can't say;Nor sure, no.
8 A -
9 After you left' Lawrence Livermore Laboratory,
.Q 10 y'ou.went to work for Reactors Control,* Incorporated.
" 11
'According to.your' testimony, you worked on control rod 12 design systems'for Grand Gulf.
o 13 MR. CASSEL: Control rod drive systems, I think Id it says, Joe, not design systems.
15 MR. GALLO: You're correct. Let me restate the 16 question.
I7 BY MR. GALLO:
18 Q What was the nature of your work with respect 19 to the control-rod drive system that you'workedeon at1 Grand:
20 Gulf?
21 g .I was hired as an~ interface between the Hanger 22 Group, which .was handling the -- the Hanger Group was RCI.
. 7 D
- O s
49
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' # mgc5210
' 1
.They.had in-house personnel doing hangers. . I was an 2 . interface with the Piping Analysis' Group, which was being 3 done -- or I was contracted to a firm that all I know is d I was hired to perform' field functions by an acronym, ECHO.
5 for those two groups, and primarily to interface b'etween 6 the two groups as to whether'or not'a support could or 7 could not be built at'a location as affecting stress to a the pipe and as to whether or not, from a hanger analysis 9 approach, could or could not be built.
10 My background in both stress and supports was 11 the primary reason for me being given that position. I 12 resolved problems when Stress requested a hanger that 13 couldn't go where they wanted it because of hang'er
,f-b 14 configuration problems, by suggesting different locations, 115 based on my stress analysis background,.which would be 16 accepted on a point-blank basis.
t 17 4- I was responsible for verifying the system's 18 flexibility, that the surge from the pressure suppression 19 pool, deflection of.the slab it sat on, could be taken i
20 without jeopardizing the system.
21 I was responsible for verification that there 22 is no non-safety-related system or component within the l
e 4 .
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vicinityyaf_those Class I lines which would inte'rfere 2 ~
with that'line in a seismicJevent. I basically was like 3
the mother to-that system. I did a lot of: things to ensure 4
its. integrity.-
Q Now if I.' understand what you just told me, 6
you a re talking about supports for piping systems; is that 7
correct?
8
'A It's'the_ control rods,~their piping systems.
9 They're three-quarter, one, two-inch lines, inch and a half-
'IO lines that control the drive-line's. I don't remember if
" they-have water or air. It seems like they were water-12 filled. Water was used as the hydraulic medium in that 13 plant.
O Id Q And these piping systems, are they located inside D
containment?
16 A Yes.
17 Q And if I understand your function, if a support, ,
- I8 piping support, was required to be installed at a certain-19 location and there was something in the way, an 20 obstruction, and it couldn't be located there, then it was 21 your job to make a recommendat' ion as to where it might be 22 '
BU3 located?
g
51 J w
'A '~] ' mgc 5 1 A Th'at was one:of my functions.
2 O How did you go about making that determination?
3 A I relied 1on the years I've spent in engineering,
'd
.the. training,.the knowledgeI I've gained.
5-0 Did you conduct any kind of analysis to determine 6
.that~you'had selected the right location?
7 ~
A It was based.primarily-onfexperience, background 8
knowledge of the system operation. I basically -- basically pipe systems are an intuitive analysis approach. If 10 you've got a restraint on'one-end,-the pipe is thermally II growing somewhere, it has to grow to the other end. If 12 it's restrained on two ends, you have to have sufficient I3 r offset'to allow it to-deflect at both locations.
D] Id There's many aspects--to making that kind of a 15 determination, but basically it was walking the system 16 down, looking at it, looking at h'ow it was restrained, 37 looking at its attributes, how it was designed initially,
'8 getting a feel for how it moved when it's heated cnr
" exposed to certain load displacements of certain types, 20 and then making a decision.. And they wanted someone who 21 had enought experience to make that decision and suggest i' that location andLnot:have it turned down, not have to do i
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- 'it.three or four dozenetimes. They wanted it one' time and 2 one time only.-
3 0' Well', afher you located or determined the location
~
4 for a particular pipe support,-did_you do an analysis to.
"v 5 determine whether or.not it would withstand the loads it
- 6. would~see?
7 A 'I didn't do the analysis. ECHO was responsible 8 for doing the. computer analysis.
9 Q Another organization did it?
10 A- Yes.
11 Q Now you indicated to me that aside from siting
~2 1 these hangers or pipe: supports, you did other things while
' 13 you were involved with the control rod-drive system at
.O 14 Grand Gulf. What was another thing?
15 A We walked the existing support structures down, 16 as-built them, sent those back to the home office for 17 computer input code generation, verified- span lengths 18- between supports. I walked the system. We verified the 4
19 system and documented it.
20 Q You determined.that the as-built condition was g
21 consistent with.theidesign;-isithat"--
. %. i 22 A No . - We generated our own drawings. We didn't 2 '
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care.what was'on th'e original design._
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W e as-built it-2 as.it was1there, period, irregardless of what was there
'3 on the original design.
4 So you, recorded the as-built condition on drawings Q
5' and sent1those to your.home-office?
6 1 Yes.
[End'5- 7- Q Did.you have any other job responsibilities 8 besides the two we just mentioned?
9 A I worked with the Hanger Group in suggesting: 'that-10 certain loads'be placed on different hangers, by requesting- -
11 that Stress not hang a support in a certain location.
12- I also assisted the Hanger Group in suggesting 13 ways' of design that they could do in the field, based
- 3
14 on constraints of construction which-the office wasn't 15 knowledgeable of.
16 I generated ECNs eventually, Engineering Change 17 Not' ices, modifying the structural steel on the supports to 18 the configurations necessary to comply with both the ,
19 2 Stress Group requirements and Hanger requirements, and they 20 were issued from..the field' and,I worked with the 21 Construction Department, because in many cases some of the 22 stuff'we wantedcto do, I had to'get their inputs because a-b
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3 Department,~because they.were working on other parts of;the it nystiemsiwe-;were assigned to.
'd.
5 '
-I:said I was-primarily working.-in the.. control 6
l.
rod driv'e-. system. I also assisted other engineers in 7'
'other' groups which-were working all throughout'the Reactor
- 8 Controls' work.- I resolved' interferences.on drainage lines.
-9 that were jeopar izing the systems. -Quite a few.other 10 ~
functions..
'I I-Q- Now you left Reactor Controls, Incorporated,-and v *, .
. 12 then went to work for Bechtel and was' assigned.to.the
' 13 Diablo: Canyon plant; is that-correct?
-O Id A I was assigned to the Diablo plant when I went 15 with Bechtel, yes. ActuaIly it was with PG&E.
16 Q- Di,d'you do'the.same kind of-support work.you've 17 just described . for Grand Gulf and Diablo Canyon?
18 A" 'No. .I" performed calculations-similar to what 19 IL did in tlie 'o'ffice, as well ar i i>viding the'same functions .
20 which'I provided?at Grand Oc?5, f r the most part.
21 Q What ca'lculationte in tuo office are you referring 22 '
.to? _
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U mgc6-21 -1 -A' - Computer analysis,' hand analysis, pipe [ analysis.
2,
.. -Q These were analyses'of the supports to determine 3
whether~or notithey could: withstand the' loads that-had d
been' determine'd?
5
.A Yes.
.6
-g: . Did-you' define'these loads, or were they 7
-furnished _to you by others?
8 A- - In some cases I; determined-the loads, as.I hadL
- at'Zimmer;for the-Zimmer' plant.
IO- Q What loads did you determine?
II
{ A. Piping loads.
- 12 Q What loads on the piping? Did you determine the
'I3 static loads?-
V Id A Static, thermal, thermal accident, seismic.
75 Ydu deterinined the, seismic?
0 16 - , MR. CASSEL: Had you finished your answer:to
~
'7 that question?' -
4 18 THE WITNESS: Yes.
" BY;MRI;GALLO_: ,
20 Q -- For Diablo Canyon, is it my understanding that ,
21 you defined the seismicfloads for the piping systems that 22
.you were' involved with?
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55 (J mgc6-3 1 A .I derived the seismic loads for some of the 2 systems, yes. I didn't say all of them.
3 Q How did you do it for the ones that you did do it 4 for?
5 A How did I do it?
6 Q Yes.
7 A I determined the location in the plant of the 8 system. The system was within a certain span requirement 9 which dictated the flexibility of the system and frequency, 10 used the seismic acceleration curves for that particular 11 area of the plant to determine the acceleration of that 1 12 component, based on its frequency or damping factors for 13 the structures attached, and then applied the accelerations p,,
t
' ') 14 for the structure, generated the seismic forces.
15 Q Now did you develop the seismic acceleration 16 curve yourself?
17 A No.
18 Q Who did that?
19 A I believe they were generated by a company called 20 Blume & Associates.
21 Q BLUME (spelling)?
22 A I saw that frequently on the forms, yes.
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Ib/ mgc6-4' 'I .Q. 'Did-you develop the: accelerations for the
\ '2 . building itself?.
3 A - No . -
d That was furnished-to you by others?
- Q 5 A .Ye s .
6 So I' understand you.took this'information or:
Q 7 of documents that were furnished to you!and then conducted-8 the seismic calculations;'is that correct?
9 A Yes.
10 0 Now, Mr. Stokes, in your: work experience, have il you ever perf rmed a structural dynamic analysis of_a-12-reinforced c,oncrete, building?
13 A Yes.
fq '
?us/ 14 Q1 ~ And.can you tell me what building you performed c .. . .
15 that Anal'ysis for? "
16 A I believe it.had to do.with the. structure'that 17- was supporting the injector at the lab. I did some work-s 18 on the review of that building. i 19 0 Well, did you do it or -- yes or no?
20 A I didn't do the original design of that-building, 21 no.
22 g 1 guess I'm confused by your answer. Are you
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. telling.me-.that'while.you were working at. Lawrence 2 -Livermore~. Lab that,youcperformed thel structural dynamic-
-3 analysis on a. reinforced concrete building?-
d'
'A' Not -at -:the ' lab, not on the building per se..
5 On.th'e components'that I'was working on,'which were= steel, 6 and'-they came off the concrete,-so I had to do'some
-7 analysis, - butLit wasn' t ' directly related to the building ---
8 the design.
'9 .Have.you ever performed any dynamic modeling on Q-
'l0 a reinforced concrete-structure?-
~l1 A I--.have, performed; computer'modeling for dynamic 12 load cases of concrete and steel at various times, yes.-
l .
13 0, Now I'm talking'abdut rei'nforced-concrete-
^
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e
~
is A Yes~.
16 0 You saidLyou did computer modeling?
17 A Yes.
{
18
- Q Could you identify what type of modeling you -
c.
j- 19 are referring to?
e 20 A Well, a computer model for seismic could be a 21 very detailed analysis of the' structure itself. If it was 22 .a column, it could be simply a stick model, a cantilever.
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mgc6 16 1 stick model. 'All you'need is to generate a displacement 2- and-check the frequency of it.: You don't really need 3
.a' computer model for. simple cantilever. . You can do it by d
. hand. calculations.
E5' For a complex structure, boxed structure,
~
.6 something with shear walls and reinforcings of.different 7
natures and shapes, you could do- it simplistically- using a
a hand. analysis, but to. get a much better feel for what's
'9 happening, a computer-analysis,would be required.
^
10 Have.you ever done*that?
Q 11
. A' -~ Yes.
12 Q Where'did you.do'that?.
- 13
' A I did some work at Southern Serv ices before C) Id I ever started working-as a' consultant.
15 0 So while you were at Southern Services, you did 16 some dynamic modeling of a reinforced concrete structure?
17 A Yes.
18 0 Now could you tell me when this occurred?
~
39 A Not specifically, no.
20 Can you identify the structure?
Q
' 21 A The actual item? Not at'this time. I've done 22 an awful' lot of' things over the years.
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59 1
I
-' mgc6-7 Q But you're sure you've done dynamic modeling 2 of a reinforced concrete structure?
3 A Yes. And steel structures.
4 Do you consider yourself an expert in the field Q
5 of structural engineering?
6- A You'd have to' define " expert." I'm sorry.
~
7 I don't consider myself an expert in my term of the 8 knowledge of the word " expert." I'm not sure that if I 9 lived to be a hundred and I continued to work in the field, 30 I'll ever consider myself an expert. Some other people 11 might consider-me an expert, based on my knowledge of what 12 I've done and background. But to be real honest, I don't 13 consider myself an expert at~anything. I'm not sure f~s is !
Id that there is such a thing, if you want to know the truth 35 of the matter.
16 MR. CASSEL: What was the field that you 17 identified just then, Joe, in your question?
18 MR. GALLO: Structural engineering.
39 BY MR. GALLO:
20 Can you tell me what NRC Reg Guide 1.60 is?
Q 21 A 1.60?
22 Yes.
Q
.[ \,
~
\.
60 mgc6-8 1 A Not right off the top of my head.
2 Q Have you finished your answer?
3 A Yes.
4 Q Does the term " rock site" mean anything to you?
5 A Rock site? SITE (spelling)?
6 Q Yes, 7 A The'two words mean something to me, and as used 8 in conjunction, they mean something to me, yes.
9 0 Can you tell ne what they mean to you?
10 A It means the site is rocky, I would assume, 11 rather than being sandy or some other structure.
12 Q Have you ever been involved in determining the x 13 seismic response spectra for a reinforced concrete 14 structure?
15 A For determining the spectra? No.
16 Q For any kind of structure?
17 A I've never done any spectra generation.
18 Q Do you know what the SSE for Byron is?
19 A Safe shutdown earthquake is what SSE stands for 20 in most places.
21 Q Yes.
22 A Do I know what it is specifically?
1 .--
61
,m,
=f r .-
' :s_/ mgc6-9 1~ Q Do you know what the g value is?
2 A. 'Not right;off the top of my head.
3 Q Do you know what it is for the operating basis 14 earthquake?-
5- A No,,fnot right off the top of my. head.
6 G All right', Mr. Sto'es, k we're going to make-7 Mr. Cassel happy. ;We're going to get off your professional 8 qualifications.. * <
, , , .s.
9 MR. GALLO: Let's take a short break.-
10 (Recess.)
, End 6 11 MR. GALLO: Let's go back on the record.
12 BY MR' GALLO:
13 0 I have a series of questions I want to ask you O
~ 14 about ! your testimony, Mr. Stokes,-but first I want'to make 15 sure that I understand the thrust of the testimony. I am i 16 going to characterize it, and you please correct me if 17 I'm wrong.
18 Does your testimony raise questions concerning 19 the general design- criterion assumptions used by Sargent &
20 Lunder in the design of the Bryon plant?
21 A That's the whole question?
22 O Yes.
3 4
O. AM
(- l l
62 I l
l mgc7-1 'l A Raise questions about?
2 Do you want me to repeat the question for O Yes.
3 you?
4 A' I believe my testimony is that I have questions 5 about -- not raise questions about. I have questions about.
6 .You have questions about the general design Q
7 criterion assumptions used by-S&L with respect to the a design of the Byron plant?
9 A Yes. Yes, some of them.
10 Well, you are questioning generally the adequacy Q
11 of the design assumptions and design criteria, as you have 12 explained it in your testimony; is that correct?
13 gm A Yes.
L] Id Would I also be correct in concluding that Q
15 because, in your judgment, inadequacies exist with respect 16 to the design criteria and assumptions used by Sargent &
37 Lundy, that you believe an independent design review should is be conducted at Byron?
19 A At this time, that's my belief; yes, sir.
20 Q All right. In Answer 10 of your testimony, 21 you refer to a design document, and I believe it's clearly 22 a Sargent & Lundy design document.
Jr f%
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4- 63 I
mgc7-2 Can you tell me what your understanding is of 2
the purpose of that document? -
3 A The purpose of that document, as explained in d
that document, I believe was that it would be the working 5
document for the' Engineering. Department, developing the FSAR 6
requiremen'st into a working document to be applied, but that 7
it would not exceed the FSAR-requirements nor change any 8
of the FSAR requirements, that it was to be specifically 9
a document geared to meeting the FSAR requirements for the 10 design of the plant.
'I Q Is that the general design document, then, that 12 was used at Byron, as you understand it?
13 A Yes.
~
Q Now you point to several shortcomings, as you've 5
said, in this document in your testimony. I have a series 16 of questions with respect to those. .
17 On page 9, what you identify as Point 1, you I8 refer to a mistake that occurs in the formula, Section 12.2.4.
39 Can you tell me what type of design work is-covered by .
20 Section 12.2.4?
21 A Yes. The area is subgrade walls in structures.
22 I believe that's the section. When I read this, I should
~~ - , -
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64 l
l mgc7-31 1 stats, Section 12 has,a specific. title, and I wasn't
-2 looking at the' title.so much,/but the' formula applies to,_
3 I believe, a subgrade wall.
4 Q This would ,lx3 the designof.' concrete structures-
- 3. >
5 :below~ grade; is that~ correct?
6 A Yes.-
7 Q Now do you know what contractor at the Byron a site did the work involving the pouring of the concrete 9 for these structures governed by Section 12.2.4?
10 A Not really. o I d'n't.
11 Q And to your knowledge, you_just don't know who 12 did this work; is that correct?
,_s 13 A- I know who did the design work, S&L. I don't 14 know what contractor actually built'those structures in the is field or all the structures, if it was one contractor or 16 multiple contractors, if that's what you're looking for.
17 0 All right. Turning the page, you refer in is Answer 12 to Section 19.5.d. Do you know what design 19 work this particular section concerns?
20 MR. CASSEL: Objection. It's answered right 21 there in the answer, to the extent the witness knows.
'22 THE WITNESS: Yes.
1Y L
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i L/ mgc7-4 iL T BY - MR.',- GALLO :.
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L2' 0,* [Well,isitinvolved--ismyunderstanding 3 .correc't'that!itiinv1Yestheconcretedurbinefoundation?
. < y .
- 4 A .Yes.
5 .O' And;are you-concerned.with~the torsional stresses 6- 'to that foundation?
7 A I am concerned with the equation, and that is 8 concerning the torsional stresses,~so yes.
9 ~ Do you know whether or not -this is safety- related Q
10 work?
11 A- The turbine foundation?
17 Q Yes.
13 A I believe it is safety-related, but I can't O 14- guarantee that at this time.
. 15 Q But.you believe it is?
16 A yes, 17 Q Do you know what contractor at the Byron site 18 did this work?
19 A Again, I don't know who would have built.the 20 turbine pedestals themselves, no.
21 The bottom of -- the last paragraph in your.
Q 22 Answer 12, you refer to Section 32.3.2, and you state that O
h 66 s, t r
Q_ 5 this s,ection relates.toiburied;. <,:piping.-
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2 Could.you?' definel better'for me what you mean by 3 buried' pipe?. . c*',
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4 A Section 32 is concerned with buried piping. That's 5 piping that's had a hole dug for'it, and dirt or' gravel 6 Or-some. kind'of fill material placed on' top of it. I don't
'1 believe that section covered buried piping in'the relation 8 that it was' encased in concrete, but I'd have to review 9 the sectionLto-get any more specific.
10 Q Do you know whether or not this buried piping 11 covered by this section involved safety-related work?
12 A Not~specifically,lno.
13 Q Does that mean you don't know, or it doesn't O# . 14 involve safety-related work?
15 A I can't say. Some of the things I raised here 16 were not safety-related. I simply went through the -
37' procedures and pulled out. things which were questionable.
18 from just visual contact, and then I reviewed it in~a 39 document to ensure that it was incorrect. I never intended 20 here to be strictly safety-related items. This item 21 could be safety-related. There are some systems that may 22 be, just like I said --
O
S-I '67 -
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(s->l mgc7-65 'l Q" But at-the moment, houjustdon'tknow?
2 A> No,' sir. . Specific knowledge, no.
3 Do you know who the contractor was who installed Q'
d the buried piping covered by this section?
5' A No, I don't.
6 0 LNow you refer.again to buried piping in Answer.14, 7 and you also refer to the section'that covers this buried 8 piping, 32.4.2. Is this the same type of buried piping 9 covered by the previous section that we just finished 10 discussing?
11 A 1It's in Section 32. I would assume it's the-'same,
.12 yes.
13 Do you.know whether or not this piping is Q
id safety-related?
15 A I m afraid I don't,'no.
16 Do you know who the contractor was who installed Q
37 this buried piping?
18 A No, not at this time.
39 0 Mr. Stokes, I think perhaps in' Answer 14 there 20 may be another typographical error. Is the reference 21 to " Attachment 1," should that be " Attachment 2."
{
22 A In 14?
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'-Jbgc7-7'- 1 Q Answer.14. '
2 MR.'CASSEL:- The next'to the last line-there.
3 THE WITNESS: Yes, it should. (Yes, Attachment 2, d
not 1..:1.:is my resume. :I'm sorry about that.
5
.BY.MR. GALLO:
6 0 /Now in this. sentence-it refers to what we've 7
now corrected.to be Attachment 2. You' refer to otherf 8 . apparent' errors that are listed on the attachment. I am 9 ~
just getting Attachment 2 out for my own use.
.First of all, did you prepare this document?
11 A Yes, I did.
12 Q Now are you suggesting'by your' testimony thati 13 r- beyond-the items that you've already testified to in your 14
' testimony -- and I think you've numbered.them 1 through 6 --
Mi that-these other items also represent errors or' deficiencies to in the-design criteria used by'Sargent & Lundy?
17 A Some do. Some were placed on this list-as HI being-the'section that caused me the concern about others.
19 So in some respects, it is -- the other things are 20 deficiencies, errors, oversights, whatever you-would like 21 to term them, but some of the things are - 'well, for 22 instance, take the fifth one down, Section 18.1.l'on 4
I I
! 4
._ . _1__ __1 _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ _ _ _ . _ _ . _ _ _ . _ _ _ _ _ . _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .
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. . 1 s-69 6 6
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-(,) mgc7-8 _1 Attachment 2.
2 MR. CASSEL:- That's the fifth one down on page
- 3 2 of Attachment ,
-4 THE WITNESS: :Yes. Section 18.1.1. It.says, S' :"All' design assumptions, methods, references and materials 6 shall be defined for-each area of design using standard t 7 calculational summary sheets." .That, in itself, is not a an error, not_a deficiency. - If anything, it's what should 9 have been done. Other listings here indicate that wasn't 10 done in all cases, or other aspects of my testimony state 11 that.it wasn't done.
12 BY MR. GALLO:.
13 Q All right. Let's take that one. What other 14 aspects of your testimony indicate that this wasn't- .
15 done?-
16 A Well, in my deposition earlier, I stated there 4 17 was a phone conversation that was not documented. Specifically is in my testimony at this state, it_would be, on these 19 items listed here --
20 Q In Attachment 27 21 A In Attachment 2.
j- .
22 O Can you tell me what item that.is?
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,- <, 70 g/~Y k 'mgc7-9. 1 A- Well, these are all the S&L procedures.
2 I'm.sorry. There won't be any here, because 11 the things I'm discussing here would be in'the calculations.
4 That would have to;be a listing of the calculational 5 ' deficiencies instead of the S&L procedural --
6 O Are theSe Calculational procedures you just
~
7 referred to, are they contained in your testimony ?
8~ A At the moment, I think I didn't raise any. 'I 9 think I omitted them. I can't remember a specific example 10 where I did mention any calculations. I know in my haste 11 to do this, I may have just simply omitted things that I had
. 12 initially. planned to put in my testimony.
13 'There are others beyond what's.in my testimony.
,O 14 MR. GALLO: All right. This is a good break 15 point ^for me. Why don't we just break for the noon lunch 16 and come back-at one o' clock?
17 MR. CASSEL: Fine.
-18 MR. GALLO: Okay.
19 (Whereupon, at 11:50 a.m. , the taking of the 20 deposition was recessed, to reconvene at 1:00 p.m. this 21 same day. )
22
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_-________=__________-___-_________________________________-----___-_-___---__
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71 i
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1 AFTERNOON SESSION
.2 .(1:10 p.m.)
'3' Whereupon, 4 CHARLES CLEVELAND. STOKES ,
5 resumed the stand and,'having been previously duly 1 sworn, 6 was examined and testified further as follows:
7 EXAMINATION - (CONTINUED) 8 BY MR. GALLO:
9 0 Mr.~ Stokes, referring to Answer 15, does 10 Section 34.2 deal with the general subject of the 11 installation'of embedded plates?
12- A I'm not sure if that's the overall topic for 34.
13 1 would assume it was,-the way the rest of the document
' - 14 was structured.
15 0 All right. What are these plates embedded in?~
- 16 A The plates are not embedded. They're -- well, 17 they're recessed in concrete when it's potted. The 18 attachments on the back of the plate are embedded in 19 the concrete. Studs are embedded in concrete.
20 0 What are the plates used for?
21 A Attaching various components in the plant to 22 the foundation.
- Q t
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72
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. x,) mgc8-2 i Q- Do you know what contractor installed these 2 plates at the Byron site?
3_ A- No,,I don't.
4 Q In your-Answer No. 17, you say that you saw a 5
12-inch'line that had a strut to the embed plate on the 6 wall. Can you tell me 'what 12-inch line you are' referring 7 to?.
8 A 'This'was the Saturday that_I come in to the NRC 9 Judges, and it was -- we' stopped at this location, and to it was pointed out and discussed in thorough detail. 'I ti attempted to write down the line number, and I did write 12 down a number, but I don't believe I have it with me. I 13 didn't put it in the statement because I felt it was
- 14 obvious to enough people that were present that-day that 15 I wouldn't have to have it, and I'm not sure the num'er 16 I had would be valid for the line anyway.
17 Q Do you know what kind of line it was?
18 A I don't remember what system it was on, no.
pp Q Where was it in the plant?
20 A You're asking the wrong person. I wasn't leading 21 the trip. It was in the auxiliary building, I believe, 22 but not having a lot of familiarity with the plant, I couldn't
~
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_ _ _ _ _ , . . _ _ _ ._ _ ~
73 Omgc8-3 1 say, because I wasn't -- I was led, so to speak, to the 2 point, and that's all I can say.
3 What type of strut was it?
Q 4
A I don't know who made it, if that's what you mean.
5 Just a steel beam?
Q 6 A Well, it was made out of a combination of pipe, 7
a couple of swivel connections, a threaded section, some 8 nuts, I believe. There was a pipe clamp, an end bracket 9 for attaching it to the steel, a pin.
30 You say in your Answer 17, in the third sentence, Q
11 you' indicate that if there were a large load on the strut, 12 then you could conceive of a problem.
<. 13 Do you know whether or not there was, in fact, 14 a large load calculated for that particular strut?
15 A No, I don't. I base that statement on the fact to that the large strut would not have been required, had it 17 not been such a large load. They could have used a much 18 smaller strut to take the load, and I based it on my 19 previous knowledge of how large the strut was and the 20 load ratings for various components, and estimated the 21 load for that structure based on that.
22 You say you estimated the loading for that O
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74 1
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structure?
'2 A 'ye3, 3
0 'And what was that estimate? 15 to 20 kips?
4 A Yes. I would guess the load would have been 5 that magnitude or more.
6 And this observation is based solely on your Q
7
~
~ visual observation of this strut?
8 A That and-the pipe, how big the pipe was and the 9- location to the elbow which was very close'by. Various 10
~
factors. But I was very -- I tried to be on the ,
4 11 conservative side of that estimate.-
12 0 Did you see other examples such as this when-13 .you toured the plant?
14 A I didn't actually get to tour the plant in the 15 way that.I like to say it, and for that reason, I didn't 16 see any more on the tour that I was on that day, no.
17 I'd like to add a few lines to that. The tour is was~a quite fast-paced tour, just watching where I was 39 walking and trying to keep up with the group required my 20 utmost attention. I tried to get the tour slowed down, 21 so that I could actually sort of stroll along and look 22 outside of along where I was standing. That was not
- . ~ ,
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75 v./ mgc8-5 'i c 'possible.
2- ;It appeared-that the tour was structured more 3 -for the Judges, and that they wanted to keep it.at a very 4 fast _ pace for them.- For that reason, I didn't see any more.
~
5 Q The tour-that you're referring to is the one that 6 the Judges requested be conducted for them during the 7 hearings.at the last session?
8 A Yes.
9 Let's assume that your visual observation is Q_
10 correct, that the load on this particular strut and baseplate 11 appears to be 15 to 20 kips. Do you know whether or not 12 that particular strut and baseplate -- embed plate, I should 13 say -- could withstand the safe shutdown earthquake for
'O 14 Byron at the load that you. estimated?
15 A On my past experience, if that's the load, the 16 anchor bolts embedded in the concrete would pull out if 17 the concrete or the allowable stresses would be exceeded at 18 that point, at some point below that, even if they were 19 immediately under itior.off to'one end of it, and I would 20 say, based on my experience, that I would question that 21 particular embed gapability:of-taking that load, yes.-
22 Q Do'you know whether or not the safe shutdown 4 A u
r 76 mgc8-6 1 earthquake for' Byron could generate that load at that 2 point?
3 A No, I've not done enough research to determine d that.
5 Q Let's refer to Attachment 3. Before we do that, 6 I have another question I want to ask you about your 7 Answer 17.
8 Do you know -- again referring you to the 9 strut and embed plate that you observed in the field --
10 do you know what the type or the size of the studs were on 11 the back of the plate for that particular location?
12 A In relation to the section that we discussed g3 13 _ earlier, 30 -- under the embed loading plat design section,
( )
'"' 14 which I can't seem to find at the moment --
[
15 0 34.2.
l j 16 A Yes, I believe that's it.
17 It appeared to me that in the structural analysis, 18 there is only one size. bolting used for a specific width 19 plate. They used three-quarter-inch plate of nine inch 20 width. They put studs on it in a particular pattern at 21 a particular spacing. There was no variance in that, 22 according to the criteria. There is a six-inch plate that l
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Ad mgc8-7 I wasahalfinchthrick,andthestudpatternonitwas 2 varied, but what was on the nine-inch piste,' it was 3
staggered from one(side ~to the other. There was a specific
- size stud used on-that plate,-and according to.the criteria, 5
both type plates were designed for.the exact same loads, 6
10 and-12 kips, I believe.
I
-Q So.'you are assuming that the studs around the-8 plate --
A Were exactl'y as the criteria require them to be IO for the width of that plate, yes.
lI And that's based on your reading of the Q
12 Criterion, Section 34.2?
13 Not seeing a calculation, just seeing the A Yes.
Id criteria.
IS All right. Now let's try Attachment 3.
0 16 Now did you write this document, at least the 37 first page of Attachment 3?
18 A I prepared it, yes, sir.
" Q .All right. And the balance of the page that is 20 3, where did they come from?
Attachment 21 y believe they were prepared by me or typed from 3
22 a document and prepared by me.
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'# mgc8-8 Q Are you sure?
2 A Oh,-wait a minute. No. .It' app' ears to be-a --
3 oh, it's copies of a document,'DC-ST-03-BY/BR. Those are d
the. specific sections that are referenced ~in the document.
5 on Att achment '3 ' that I've noted. It shows exactly -how 6
they're stated', listed and so forth.
'7 Q Now looking at the first sheet of Attachment 3, a
you've got various section. numbers' listed in the next to the 9
lefthand margin, and then thera are statements' appearing 10 after each section number.
' What is the significance of these statements?
12 Perhaps I'll let you take them one at a time for you to I3 answer them adequately.
Id A Well, .the significance'to me -- in some cases IS I spelled it'out, like, "Section 37.2. No definitive 16 statement that torsional stresses should be checked."
17 If you,look at.Section 37.2,;it says these
'8 eccentricities can cause torsional shear and warping I'
eccentricities. .Now it lets you-know that they are 20 concerned about this, because they state it, and the 21 problem with it is, there's no definitive statement as to 22 how you should approach this torsional shear and warping u
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II ,
79 mgc8-9 1 stresses or whether or not you should check for it. It just 2 says these can cause problems.
3 Q Do you think this statement should contain that 4 statement?
5 A This one or subsections of this, which the later 6 Sections, if you look at 37.2.1.g.2.C, 37.2.1.g.3.C, all 7 the C's seem to be torsional analysis not required, so they 8 did address it. They said you don't have to address it, 9 basically is what the bottomline came to -- the total 10 section.
11 Q So did that cause you.r,ome concern, then?
12 A Yes, it did.
,3 13 Q What is your concern?
( i 14 A That they were neglected.
15 Q They should have been considered; is that right?
"lo A' They.should have been considered as to the level 17 of critica1 ness,as to the allowable stresses that they 18 could have affected.
10 Q LookAng at the second item on the first page 20 of Attachment 3, you indicato a statement that says, 2f " Deflection and rotation of primary structural steel 22 ignoredsin deflection check," and then there's in
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s 80
'(M s ) mgc8-10 1 parentheses a question mark, and'then the words, " Members 2 . with pinned ends."
3 What does that mean? What did you intend by 4 .this question mark?
5 A It's a question mark. It's a' question to myself.
6 This was-made up to. flag things to me. Everything on here, 7 was a question. If you want'to know the truth of the 8 matter, in most. respects one way or the other, in this 9 particular case, I already knew what it was, because I just-10 wanted to have it there for future reference. But in any.
11 case, the question, " Members with pinned ends," indicates 12 that I questioned whether the absolute ignoring of 13 deflection was valid for members with pinned end connections, i O 14 primarily structural steel. That's what the section is 15 addressing.fPinned end'. connections cannot take any 16 deflection and rotation in the torsional aspect of the 17 word, and the absolute: omission of any deflection check, is omitted to check whether the member could even take that 19 kind of loading, and the end connections would have been 20 the place to check. I have seen pin-connected members that 21 have to be modified to fully-welded moment connections 22 because the torsional loadings were so great. The thing g.
s-O
l 81
> mgc8-ll I failed with pin connections.
2
,Q Did you determine this to be a problem at Byron?
3 A- It's in the criteria. It indicates a problem could exist at Byron. But no, I haven't been able to visit 5'-
the plant often enough.or,enough magnitude to review enough 6
supports and end-connected' members to determine whether or not they exist and it is a problem.
8 Q Have you' concluded that the fact that the 9
deflection check is ignored, as you characterize it, in 10 Section 37.2.1.f, does that constitue a design inadequacy,
' in your opinion?. ,
12 A It does, if they had at'tachments to pin-connected l3 em beams. They_could cause.rotatioh:of that beam.
\. ) j4 0 Well, is or isn't it a. design inadequacy. Can't 15 you tell from looking at the design document?
16 MR. CASSEL: Objection. Asked and answered.
II He just answered the identical question.
18 MR. GALLO: No. He said "if,' and that's not 19 giving me an answer to the question. In any event, I was 20 not satisfied.
21 THE WITNESS: If there are no rotational forces 22 applied to pin-connected beams, then, no, there is no problem.
3
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mgc8-12. l The problem is, .th'at was completely ignored in any review ,
2 ' program, an d there .could be rotational loads. to beams with 3 - - pin connections. And in answer to that question, it would d be a problem.
5 BY MR. GALLO:
6 0 All right. Well, let's identify what kind of 7 problem we're. talking about. Are we talking about a design 8 problem or a hardware. problem at this point?
9 A It would be both. It would be a design problem, 10 because it is' oversight o,f; design. It would be a hardware 11 problem, , because it would affect the hardware. '
12 Q Sofif I.?look at parag'raph' ,(f) on the third page 13 of Attachment 3, based on what'you'just testified, I can lg g L\_)' Id conclude that,you'believe this statement in paragraph (f) 15 constitutes a design deficiency, because it says that-the l' 16 deflection and rotation of primary struct ral steel framing 17 may be ignored?
f 18 A That's right. I believe. I was sort of-
' 19 reading when you said that.
.End8 20 MR. CASSEL: Would you like to have the question 21 reread?
22 THE WITNESS: I would like to have~it reread, d
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1 because.I was reading Section;37 to see what the title 2 of Section 37 was about.
3 MR. GALLO: I'll restate the question.
- 4 THE WITNESS: 37.2.1 is written against Section (f),
5 and it~says, " Safety-related Hangers." That's the main.
6 category that (f) is attached to.
7 Now there's a main category for 37 as a whole,-
8 but because chat specific section was written against 9 safety-related. hangers'.'I'do-have
, a safety problem with 10 that statement being in that section, but I would still Il like to' read: the" question you, stated 5that I answered to 12 while I was reading it.
13 MR. ~ GALLO: 'I'll restate the quest' ion.
14 BY MR. GALLO:
,15 You believe that Section (f) appearing on the third 0
16 page of Attachment 3 contains a design deficiency. because l'7 -it permit --
18 MR. CASSEL: Design sufficiency?
19 MR. GALLO: Deficiency -- because it permits 20 deflection and rotation of the primary structural steel r 21 framing to be ignored? ,
22 THE WITNESS: Yes. I would say it is an' oversight.
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84 1 The components should have been checked. The components
' ' mgc9-2
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2 should have been verified that didn't have pin connections 3 or could take those kind of loadings, irregardless of d whether they ignored the displacement or rotation in their 5 displacement of the support point, which is the piping.
6 BY MR. GALLO:
7 O So the design statement is incorrect as written?
8 A It's not sufficiend as written.
9 0 All right. Now is,this -particular item referred 30 to anywhere in your testimony?
11 A Section (f)?
12 O Yes. The one we have been just talking about.
x 13 A 37.2.l? Yes, it's Attachment 3, second item.
/ i
%,J 14 Section 37.2.1.f, " Deflection and rotation of primary is structural steel ignored in deflection check. Question 16 members with pinned ends." That's the section we're 37 discussing.
18 Q And where in your -- here it is.
39 Then I am to interpret that each of these --
20 strike that.
21 Am I to interpret that each of these items 22 listed on the first page of Attachment 3 set forth what L
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N f
s 85-3, I 1-mgc9-3 you believe to be a' design deficiency in the sections 2.
findicated?
3 A. The way it's stated, it's a design deficiency, d yes. ,
5 Each and every one of them?
Q
'6 A No. One of them isfnot. 37.2.1.g.2.C.
7 Wait a minute. Don't go too fast now.
Q 8 A It,'.s:the sixth.one'do'wn,from-the top. It says, s
9 " Torsion' included here. Question logic." That's the only 10 one I know of that'I' remember-does include torsion, and I 11 ' put down a comme'nt, " Question logic." 'I simply am 12 - questioning why they put it in one section. They omitted 13 it in infinitely more sections, when in reality, it is Id my experience in design that if'I tried to memorize this 15 document and design something, I would remember all the-
.16 times torsion is to be ignored. -I would never-remember that 37 one section where it's supposed to be' included.
18 But you consider that section to.be adequate, then?
Q-19 That's why you pointed this out for me?
20 Yes, that says it:should be included. I consider A:
21 that adequate.
22 Q Are there any others, or are-they all examples
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~2 'A ~Let's see._ '37.2.l'.g.5. Based on_that one line,
.3 I-don't find that a deficiency, but-the subsections of-it make that one(line a very questionable item still.
~
4 5 36.2.'l.g.5'says,." Exact analysis must be 6 ~ perNormed for loads ~ greater than 20 kips." I questioned what it,would'do-for loads less tha'n 20 kips,-but then
~
7 8 the ABC' breakdown at the end of 3'7.2.1.g.5, if you limit 9 'it to the first three under t! hat se ation,_it says, " Assume
~
1 0 all masses lumped at shear center. Axial self-weight may
- 11. be ignored._ Torsional analysis not required." So it-12 appears to me that they liked 20-kips, to include torsion, x 13 you don't include self-weight, you don't include.the V 14 eccentricities of joints, but above-20 you do.
)
15 Now if that indeed is what was done, I have no 16 -question about above 20. kips, but I have a question for 17 everything below 20 kips.
is You see what'I'm saying?
19 Q Do you believe, then, that the Section 37.2.1.g.5 4
20 is deficient because it doesn't address what should be 21 done below 20 kips?
22 A Well, it says it should be_ ignored,~ from what I
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ignored,.basedonith5-5,.'C(torsionanalysisnotrequired.
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0- Based >on(your review; do you find 1thisEsection
, 5 and its sbbsections, A,~B and .
C,, adequate for loads greater
- 7 /,, - -
- than-20 kips?- *v -
- 4 7- 'A 'If.they.indeed do,an exact analysis, yes.
8
- Doty'ou' havd any, information that : indicates that .
~
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1 9
- they have not done
- an exact. analysis ~in this area?
") A. Some, yes- .
Il LQ Can you b'e more. specific. What'information-do
. 12 you.have?
13 -A Well, in my review SEISHANG1 documentation in f
.t 14 Sargent & Lundy's office,'the program:itself omits these. ;
15 things,Eand'you don't have to -- there's no way to do an 1,
l 16- exact analysis using SEISHANG:from what I' gathered. The 1 7 ' program itself is written to ignore these things. Without i
Mi further review, I am not going to say that it does in all
~
icases, but there was'some comment that it could as-built i-20 a hanger -- you could do an as-built analysis. In that 4
21 - case, maybe it does include.them, but from right this 22 minute, I question whether SEISHANG, the way it's. written, if OS r
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2' O L Wha $'s the name oftthis code you're_ referring t
3 to?
- 'd'
- A- SEISHANG,1S E:I S H AjNeG.(spelling). It's
, 5 a-prog' ram in Sargent'&.Lundy's'proprie'tary group which 6 -13 used to runLIIVAC piping, electrical' conduit, and many 7
other structures.
8 .And to your knowledge, that code.was developed Q
9 using, among other' things, the design criterion represented 10 by SectionL37.2.l'.g.5?
11 MR. CASSEL: Objection. l'You said'" code." IE
- 12' think you mean program.
4 13 MR. GALLO: S'a m e 1 t h i n g , isn't it? Isn't a code-3
'~' 14
. and a-program the same thing? You and I are communicating 15 that way.
16 THE WITNESS: I consider.a code different from 17 this. This is criteria that's set up by the company.
18 BY MR. GALLO:
19 Q I'm not sure I could-~ pronounce it.-
l 20 A I was. going to agree with your question anyway,.
21 because1it sounded to me like you --
l 22 O Well,;1et-me ask you, we have now confused the-c, h.
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record. I;ain referring' .to ;the" SEISHANG code.
'u. 2 JL . The computer code.
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3 ;And my'que'stion:was',* based.on your evaluation of.
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4 this code, is it your understanding that it is based on, 5 among other: things, the' design criterion represented by 6~ Section 37.2.1.g.5?
7 A Is SEISHANG written to comply with this? Is 8 that --
9 Q Yes. Is it based on that section?
10 A SEISHANG,is used for safety-related components.
11 That would imply that from Section 3'7.2.1 from the previous 12 page, that it was safety-related hangers, and the fact'that 13 this section is written for' safety-related hangers and I 14 SEISHANG performs safety-related hangers, knowing what I 15 read in'the review of SEISHANG,-I would have at the moment 16 a lot of questions concerning whether it meets this section 17 at all or any of these sections here.
18 But based on your review of the code, tit's Q
19 supposed to meet this section; is that correct?
20 A From what I gathered, it'should have met the 21 requirements for' safety-related components, if it was used 22 to do safety-related, which it was, according1to the idP H
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2 Q , .Wha$ does' th'isi. code'i mode'1?;
3 The' structures, A
d Q. For'what' purpose?
5 A . Determining stresses.
6 For what loads?
.Q-7 A- The input loads.
8 0 For what_ forces?
9 A Loads from the piping. If there's piping 10 That's from the HVAC. If HVAC's attached-attached'to it.
Il to-it. Loads from conduit.if conduit is attached.to it.
12 O What kind.of dynamic loads are we talkingLabout?
13 A Seismic.
{s
(' Id These are the seismic-loads?
Q 15 A Yes.
16 Q So-that the SEISHANG computer code is the code 17 that models the ground motion through the building to the 18 various hangers; is that correct?
19 A No.
20 No?
Q 21 A The only thing I know SEISHANG does is, it 22 has curves or tables in it as a data base. It computes, r$
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- d. e l- .I guess,Othe?frSqencyofdhe'struc'tureanddeterminesthe i 2c accelerationLfrom,those; curves, just like you would going i ,
into-the, tables yoursel'f.' It doesn't.model and do the
~ '
3 whole'analysisifrom generation' point to generation point.
5 ~
lIt takes input that's already been generated and-.uses it.
A Q And-you say you evaluated-the input data.to this 7
code-during your review in'-Sargent & Lundy's office?-
8 ~
A Evaluated thecinput data 1to this code?. I' read 9
the documentation as to.what;was required for input. I
'U didn't read through1that.as much as I read'through.the
" ' documentation and assumptions of how it worked.- In other 12 words, the programmer's. intent, tlie way he. set.it up to-13 function. . It-doe'sn't matter what you put into it later. '
0 'd Those primary assumptions tha't he put into it at the r
15 ~
beginning of the write-up govern everything that's.ever M
done by it. You.can't overwrite it. You can't improve
'7 on it unless you change the computer code. Those assumptions
.18 are' written in that code.
O~ These are what? The mathematical equations that 20 form a part of1the program?
21 Af The equations that he would use would have been 22 written into it. The assumptions might have also been
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c 2 CanLyou identify for me one-assumption that you
.Q 3
- reviewed?
d A 'Well,1one-thing the documentation said was 5-omitted was, it said'that. strut members were designed as 6
pinned-end truss members. That-would state that there-is 7
nothing but.an axial compressive load.placed on a strut 8
member. There is no account for moments, no rotation or
.whatever of.the. joint. There didn't appear-any lateral 30 shear or horizontal shear, and it's strictly the' axial II or compressive-loads. And-that indicates that they didn't 12 include the eccentricity of the joint or the torsional
'3 effects or1any.of that.
( -
id Q As required by this'section of the criteria that 15 you have referenced here in Attachment 3?
16 A Yes, right.. 37.
I7 Q Let's see if I can summarize. I want to be' fair.
18 As I understand it, the first page of
" Attachment 3 are examples, are statements of design i 20 deficiencies, with the exception of one section, and it's 21 37.2.1.g.2.C. The rest are statements of design 22 sufficiency -- I'm sorry -- design deficiencies for one L.
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reason or another?
2 MR. CASSEL: Just to be clear, you were going 3 down that list, Charlie, in answer to his earlier 4 question. Have you reached the bottom of th e list?
5 THE WITNESS: Yes. The only question was the 6 "above 20 kips" section. That should be omitted if they 7 did an exact analysis above 20. I didn't intend to -- if 8 they did an exact analysis, I have no question about that 9 statement.
10 MR. GALLO: Let's go off the record for a minute.
11 (Discussion off the record.)
End 9 12 BY MR. GALLO:
BU 13 Q Attachment 4. Now if I locate your Answer 20, 14 which appears on page 13 of your testimony, you indicate 15 that you have other concerns with the Sargent & Lundy 16 design criteria, and these concerns are listed in 17 Attachment 4.
18 Now are these -- and you at one point call them 19 potential problem areas -- my question is, have you 20 determined whether or not these matters listed on 2i Attachment 4 are design deficiencies or design inadequacies?
22 MR. CASSEL: Objection. That's answered in
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\I '1J Answers 20,LJoe.. It says right there, "
I.have questions
- 2' -which have'not been resolved."
3 BY MR. GALLO:
d Q So'these are-unresolved concerns on your part,
,- 5 ' Mr ' Stokes?
-6 A- Yes. AsJ fa'r as'I can ---yes.
'7 Let's look at Q Now let's-turn to-Attachment 4.
- 8. Can you tell me just what that item is?
.the first item.--
9 A' .W ell,.in. reviewing the documents, I had a 10 procedure I went through. I read everything.several times.
II In this case, this particular letter was an NRC letter-to 12 Commonwealth Edison, and on page 9, there's an Item No. 3, 13 and-under that item they'are discussing cable splicing.
' Id
'And in:this particular document they're discussing end-line i 15 splices.
146
- And the question here, to me, came from another 17
' document concerning a butt connector review program that 18 I was familiar with. In reviewing the documents in the '
39 butt. connector. program, they were supposed to review 100 20 percent of the butt connectors.
21 p Q Let me interrupt-you for a minute, and I'll let 22 you continue.
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~ re you telling me now what this item on page 9,
, .. 2 No. 3, is-about, orchave you changed'the subject?
- l.- 3 ' A' - Yes. No, . no' . I'm telling you.why I put that d
down here.
5 0 -All right.- Go-ahead.
6 A .In reading the butt connector program, it was 7
not. obvious that the problem was addressed as.to crimp
~
8 connectors'versus a soldered type connection or I-joint.
9 '
In butt l connectors, the whole write-up that I had seen was 10 about the' crimp connectors, whether or not it had been 31 crimped by the right ' tool or whether or not there was 12 enough pressure on it and stuff.
13 Well, I have enough background with electrical
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~
stuff to know that end-line splices are equally made 15
, with crimp connectors, and the thing that seemed to appear 16 here to me is, the end-line splices were being omitted 37 because they were not butt connectors, and to me, end-line 38 splices or crimp connectors are as critical in this 19 butt review program as the. butt review program stuff they 20 reviewed.
21 They omitted -- the program-should have been a 22 crimp connector faulty installation review program, which J
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- N '. I 2 connectors, butt connectors, and any other kind of 3 connector.
4 But the: crimp' connector, in this one letter,ito me, 5 led a question of whether they-even looked at end-line 6
splices or anything.
7 Q- Now you say the'end-line splices were omitted, a Who are you and you_ refer to "they" omitted them.
9 referring to?
10 A' I said it appears they were omitted.
11 Q You mean the NRC omitted these? -
12 A .W ell, they were omitted by CECO or whoever 13~ was to do this 100 percent review of butt connectors.
fs i
id The whole problem was not butt connectors; it was crimp 15 connectors, and the program should have been 100 percent 16 review of crimp connectors, not butt connectors. And had 17 that been-the case, there would have been some end-lin'e 18 crimp connectors in the program.
i 19 None of the documentation I read -- and I mean 20 none of it -- came flat out and said end-line splices 21 were included because they're crimp' connectors.
22 And so my conclusion ~is, none of the end-line
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Q Now wha't was'th'e purpose of the NRC letter that
~
-d you referred-to, the ene dated.May 31, 1983?
. 5 -A I can't remember.
6 0 You can't remember that?' Did it deal with an 7 item of noncompliance?
8 A It seems-like it was. They were several
~
9 documents that I reviewed, and more than likely, it was 10 an inspection report of a noncompliance' item. Yes, that's 11 one thing.
12 Q But you don't recall right now?
13 A No, I can't tell you for sure.
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'5
# Id Do you. recall whether or not it dealt with Q
15 end-line splices or not?
c 16 A That particular write-up of'that document did --
17 was written about an end-line' splice penetration. I can't 18 remember exactly what the discussion was or, at this 19 moment, if it was explained.
20 Q And this one letter triggered this entire concern-21 that you have just described?
22 A There's another letter, I believe.
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(st 1 Q Can you' remember where that-is, what letter that 2 was?
3 A No't at the moment.- 'I'd have to look back through 4 most of-the. letters that I looked at, but it was listed 5 in another document as'being a. problem, too.
6 Q? .Do you remember.that' document?
7' A Or it was written about also -- no, Iican't-
~
8 remember'the letter number or the date of the letter or 9 any' thing at this moment. If you would wish-it, I can' ,
10 determine that.
11- Q- No, that's all right. Did you attempt to gather 12 all the documentation that might exist on this question 13 by asking-Sargent & Lundy for it or Commonwealth Edison?
(~s s
'~! 14 A In the production of documents, we've asked 15 for everything that's has been ever written on:this plant, 16 I believe, in~ relation to the review program, and I 17 .believe they've-supplied everything that's possible to be is supplied. But if that's not the case, maybe I should make 19 the request now that any additional information be given 20 me on this subject.
21 Q The time for discovery is past, Mr. Stokes.- But 22 you made a statement in your previous testimony that in.all e- ,
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the documentation..that you looked'at, you didn't see this--
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-1 2 matter addressed anyplace', the matter of -- is'it in-splices 3 or en'd'-splices?
4 A- End splices.
5 I'N' or E N D (spelling) ?
Q 6 A E N D- (spelling) .
7 End splices addressed anywhere.. And I'm trying Q.
a to determine ---
9- MR. CASSELi Wait a minute. That's not what he 10 said, Joe.
11 THE WITNESS: Could you refer me to where you're 12 getting this from?
13 BY MR. GALLO:
f Id I'd written a note while you were testifying 3 Q 15 about son.ething that was omitted from a program as being 16 end splices; is that correct?
17 A I said there were end-line splices, as far as 18 I.could tell, in the butt review program -- were omitted.
39 There was a butt review program,.as.far as the documentation 20 There was supposed to be 100 percent review of 7.ve seen.
21 butt connectors. ,
22 You mean butt splices?
Q 6
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'"' I A Butt splices.
2 Q I see. And you saw documentation on this 3
question?
A On butt splices or butt connectors. I didn't 5
see any on end-line splices.
6 Q And it's the end-line splices you're concerned 7
about. Okay.
8 A I'm concerned about crimp connectors, period.
9 They could be end-line, butt or wherever located. That's-10 not my concern. It's review of crimp connectors.
II Q All right. And I guess what I've lost the thread 12 of is whether you have not seen any documentation on butt I3
(~~. splices or end-line splices or both.
( /
Id A I've seen lots of letters on reviewing butt 15 connectors or butt splices. I've seen a few, I think, NRC 16 inspection comments about faulty end-line splices at I7 penetrations. End-line splices don't necessarily exist
'8 at all penetrations. They exist end line, wherever they 19 want to splice a cable. For that reason, the addressments 20 or letters I've seen only address certain connectors in that 21 ~
end-line splice category. At tenetrations, they did not 22 address the end-line splices totally as to crimp problems.
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7 . ._.
U I Q- .Buti you 1cannot- identify right now any correspondence 2
that'you specifically have'in mind?-
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3
.A -Other than-this one letter on butt end-line splices.- That's~the only one I have written down'here at
~
4 5 the moment. There was another one .or :two, - I remember. I
- 6. didn't want to write down redundancy when I was doing'this.
7 .I'm sorry. I was attempting not to --
8
-Q Let me ask you'this ques' tion. Did this letter 9 of May.31, 1983, from the'NRC specifically address a- -
10 problem with end-line splicing, or did it just trigger a 11-memory response in your head that caused ~you to.say, "Aha, 12 here's a potential problem," as you've explained it here.
13 A Well, it addressed a problem with that particular O 14 type of one, NRC-363 with an end-line splice at the 15 penetration. That one is addressed by that letter. Now --
16 Q Does-the letter raise the --
17 MR.'CASSEL: Let.him answer the question.
18 THE WITNESS: It did raise.-- it didn't raise 19 something I'm familiar.-with._. It raises something that 20 everyone here should be hamiliar with'.
~
21 After-reading the butt connector letter-22 documentation, the whole butt letter or butt splice issue
-23 is not butt splices; it's crimp connectors. All you have A
v
102
- I to-do is read all that' documentation, then read through 2 all the other stuff, and you see that end-line splices 3 are -- they come in very sporadically with being deficiencies 4 at penetrations, but you don't see any documentation as 5 to end-line splice connectors.
6 BY MR. GALLO:
7 Q Did this letter address that point?
8 A I-don't believe it addressed the totality, 9 except at penetrations. I think it was specific 10 penetrations, but I can't give you a more definitive 11 statement. I'd have to' pull the letter out and reread it 12 again.
13 All right. The next item deals with another
-~
Q
] Id NRC letter, 15 A Yes.-
16 Q And do you remember, was this the letter 17 referring to a -- well, I guess you've indicated for me 18 right in the title, it referred.to 'het integrated design 19 inspection; is that correct?
20 A That was on the letter, and;that's where --
21 so it was integrated design inspection program, yes.
22 Q And this particular letter deals with the s 'fk
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.1 activities of-Sargent & Lundy?
~
2 A 'Yes, among others, but primarily Sargent & Lundy 3 -beca'use the - .if you; read paragraph 2 or page 2, the
'd 'second paragraph, this write-up was a discussion _of an 5 Inspection done as to calculations concerning, I believe, 6 the auxiliary feedwater pump motor evaluation, environmental 7 evaluation, .and the write-up was concerning Sargent & Lundy's 8 analysis of the environmental acceptablity of this room 9 for the pump and its environment, because it seems this !
10 pump was critical to the safe shutdown.
11 And the question with this that came up to me 12 was, they discussed everything in the calc, but they
- 13 relied on an assumption. It.was that HVAC could take the 14 heat load, which they'probably~did a calc on that, but --
15 Q W$o_isJ"the'y."?
16 JMR. CASSEL: Let him finish the question. You 17 can ask>that; question whencheLeompletes his answer, Joe, 18 but he's entitled to give you an answer. If it's ambiguous, 19 you are entitled-to ask him what hei means, but don't keep 2C interrupting.
21 MR. GALLO: The record is getting confused.
22 I want a clear delineation of what is in the letter versus
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'~3 MR. CASSEL: -You can get that clear delineation
- 4- Jby-asking one question at a time, Joe, but it's just. basic
_3 - courtesy,lamong other things, to let the witness. finish ~
6- his answer.
7 MR. GALLO: I think'I'm entitled to just get
~
8 an answer _to the question. I've been pretty lenient in 9 letting him ramble on. But I think here is the time to 10 draw the line.
33 THE WITNESS: Well, I'm sorry.
12 BY MR. GALLO:
~
13 Q Let's look at the next item. T his again is ~an ja NRC letter dated Ju'ne--6, ~ 1984, and you refer t'o page 12, paragraph 31 15 4
16 A ' YG S - -
i7 0 And you talk about the failure of cables is attrributable to elongation of~ cable installation. What pp was the nature of this problem?
A 20 It appears they had over exceeded the cable 21 pull and tension load in this letter, and they had attempted' 22 to verify the adequacy of the installation, because they
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\_) 1 wanted to re-pull' the cable and put it in some oth'er place.
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2 Undoubtedly theylhad removed it or something.
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3 The documentation I received was very brief so --
4 but the whole thing was, they sent a piece of the cable 5 back to-Okonite to test. It had passed the same test' 6 before being'sent to the plant. In.Okonite's write-up, 7 they state, as a result, in this letter,- that they attribute 8 the failure of the. cable to elongation of cable insulation,
~9 .because it failed the test the second time.
10 Q Mr. Stokes, aren't these first four items where 11 you refer to NRC letters merely matters that have'been 12 identified by the NRC Staff'through Region III,andLremedied 13 by Commonwealth Edison in response to the NRC Staff?
O 14 A. . The Staff.has raised these questions to some 15 extent. -Whether or not the solution has been completely 1-6 documented and is acceptable.is another question that I 17 can't answer,,because I haven't, as you say, seen everything.
18 I'm only one person. I haven't had the time to read 19 absolutely everything. I don't have a -- I don't have a 20 limitless brain. But in any. case,-that question is still 21 a question to me from other documents.. That document.
22 doesn't state specifically that that one was corrected.
23- 0 Aren't you just piggybacking your concern to the W~
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2, A Let's say.I'm not'piggybacking; I'm asking 3 concerning questions that they may not have addressed, and
~
4
- if they had, then there would be no question as to'what 5 I'm asking.
6 Now who is "they"? -
Q 7 A The NRC. Now I mean if:they' addressed everything 8 that I would like addressed, you can say it's piggybacking'.
9 'And what is your judgment on'that? Have they Q-H3 addressed everything,you'd like.?to address in these letters?
~ +
11 A I ' don ' t' know. , >
12
-Q. pYou don't know?. All right.
13 What'is! this fifth' item that talks'about --
14 starts out, " Review of Drawing 6E-0-3393E"? What is that i .
End 10 15 item?
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.i A It's a Sargent & Lundy document. That's the
[2' drawing number of it.
3 ~Q Now this'is a potential-concern. What is the
~
4 nature of.the concern?
~
5 .A There is a load table on this.- It's very
< 6 briefly described. There's a load table on -- these 7 documents are concerning steel conduit installation and a design.
9 Anyway, there is a load table'.for steel conduit 10 op .this document. It's specifically called out, load table,.
ii steel conduit.
12 I compared that load table with the load table 13 for steel conduit in the unistrut catalogue, which I had, D
\- .i4 which statement at the bottom st'ated it was in compliance 15 wish the '71 version of the National Electrical Code. The 16 numbersffor the weights in that table in the unistrut 17 catalogue;were larger than-th " numbers in the table of is Sargent & Lundy's drawing. The -- this may be. answered, and i9 I'll go a' head and throw this in.
20 In the Sargent & Lundy docum,entation, they 21 stated they used an '83 National Electrical Code. If in the 22 '83 version,'which I haven't had time to look, the loads are S
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r I[ .i what is'in this table,-'and all the components listed in this
-2 . table or the weights for those components were purchased I
! '- 3 . irt compliance with the ' 83 Electrical Code, .-I wouldn ' t U
4 have any question with'this if those things happened.
5 But the problem with this, as far as I see.it, 6 is unless the '83 version lists the same load table values,
! 7 -Sargent & Lundy's values appear to be below what the National 8 Electrical Code requires. Now --
9 Q llave you made this comparison?
ni A Yeah, I compared.the tables.
ii O So you compared the tabic in the unistrut
! 12 catalogue with the table shown on this drawing?
33 A Yes.
I /\
~
Q And you concluded that the load' table on the i4
~ ~
15 drawing is inadequate because it doesn't coincide with the
~
16 unistrut catalogue table?' '
l 37 A I didn't decide that it was inadequate. I said la if the table was per'the '83 code, and the '83 code is-p, identical to the table, then I only have one other question.
20 That would be whether or not the components put in the plant l -21 were por the '83 code instead of the '71, when purchased.
l 22 I can' t -- beyond that I'm saying it's a question. There's a
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2 O Then you don't know whether'or not this table is 3' -in the '83 code?. >
d A Well, if>it wasJin the '81, I would. presuppose
.5 it's in the83,-but I don't know for"sure it's in the
~
'.83.
6 MR. CASSEL: You said it ,was in the '81. 'You 7
mean in'the '717 8
THE WITNESS: Thet'71.
BY MR. GALLO: '
IO '
-O What's the last item on the page? It refers to II an EPRI document.
12
~
A The same' document ,could have been listed up with I3 3' the butt splices or the end line -- not that, pulling, the
.) Id . ..
cable pulling, thesthird one down,' elongation.
15 I just happen to maybe think it could be weird 16 thatIwasreadingthisNPRI' document, but I was looking II through the EPRI document to.see.at one time what was is relevant for some other work I was doing as a reference I9 source, and I happened to' read this one section concerning 20 cable section lengths. And']:he thing that keyed my mind
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21 here, and I remembered, was tlie factNthat there are three 22 stress modes which cable is subjected to during elongation:
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~- / I Tension and elongation, torsion and side-wall (bearing) 2 pressure and bends.
3 And then later when I was reading the documentation d'
on cable pulling, this same article.and memory came back, 5 and_I pulled it out to make sure that it was stating what I 6 remembered.
7 This article is not a problem itself because it a addresses factors that should have been addressed in pulling 9 The equations determining safe pulling loads and so cable.
H3 forth. This section is here to go back to the elongation Il program and cable overtensioning, pulling overtensioning, 12 which is a fairly substantial problem at Byron, as I under-
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s_ t was told that, one, they.were reviewing certain things
.. 2 inspectedLin the' plant. NDE is something that can.be 3' reinspected'bygdoing another NDE exam.
4 When I raised this with Sargent s Lund, I believe
~
5 cm a Wednesday some number of . weeks ago, I was told in that 6- meeting NDE exams were'never in question in the reverification 7 and were omitted.
8 In reviewing all the documentation _on PTL,-
9 includingthe'reinspectionbehort, I find that PTL was so responsible for all NDE exams, but,they had the worst 11 failure-or' worst inspector qualification record --
12 0 Mr. Stokes, you-are rambling now.
13 A Well, I'm sorry.
- 14 Q The question that I asked you was what was the 15 nature of the potential concern that you had in the second i6 item, and I repeat, it says minimum pipe wall thickness 17 not met. Repair performed.
18 Now what is the concern or potential concern that 19 statement represents?
20 A It has two:
21 One, the repair performed, if it was part of the.
l 22 reinspection program, would have been significant from
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p 2- The fact _that Sargent & Lundy made the statement' 3 thatithere was nothing sa'fety or design-significant reviewed
~
4 in.this program is contradicted-by this line_here in,some-
- 5. respect.
6 .Q A11/right. .-
7 .A' Beyond that,,=it zexpands the question of whether 8 NDE as atwhole'should have_.been questioned as an attribute 9 when'I-was told it was'omitted.-
~
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10 O' All right. If I understood your testimony just.
11 now, you arejsuggesting that thetfact that this minimum 12 pipe wall thickness was repaired contradicts the Sargent &
E 13 Lundy testimony that none of the reinspection program O 14 discrepancies had design significance; is that correct?
15 A Well, it does to me if, as I said, that repair 16 was performed due to an inspection during the reinspection 17 . program.
18 Q What discrepancy are we talking about here?
19 A I'd have to thumb back through severa1' documents.
20 There's several where they repaired stuff. They're NDE 21 re ports , I didn't write the numbers down. If you'd like
! 22 those at a future date, I can give them later, but I don't F
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~1 3 know them right off-the top of'my head.
There's-three or
-2 four, maybe more than that.
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3 -Q .We'll accept the proposition that certain of 4 the discrepancies-were repaired _that were.the' subject --
'S let me state that again.
6 We'll1 ac'ceptithe proposition'that certain of 7' the discrepancies that were subject to the Sargent & Lundy 8 evaluation were~in" fact repaired I th' ink we can agree on
- i 9 that.
10 A Oh,'We can? Okay. <Thank you.
11 Q My question is, is it your testimony-that since 12 they were' prepared -- repaired, rather, that meant that
,_, 13 the Sargent & Lundy testimony-indicating that none.of the
'\- 14 discrepancies including those repaired, had design is significance was contradictory?
16 A If they didn't have design. significance, ..
I-17 wouldn't have repaired it. There is a definite question is there.
19 Q So you think there is a correlation between 20 design significance and repair?
21 A Well, I've got a question about.why they were 22 repairing it, if it's not design-significant or safety-
?
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\I 1 significant. Otherwise, why go to~ the expense of fixing it, 2 if it's capable of taking the design-loads?
3 O Maybe I misunderstood your prior testimony, but.
d
. I thought you,were1saying that the fact that it was repaired' 5 indicated definitely that 'this' was a contradiction in the .
6' ' Sargent,& Lundy position?. . . ,
7 MR. UliIGilT: . Objection,4 Joe.- I think that was 8 _ your testimony. .
9 MR. GALLO: Well, he'will correct me if I'm 10 wrong.
Il THE WITNESS: I don't_'think I said definitely.
12 anything in this whole testimony so far that I can say 13 beyond a doubt that it says anything. I am saying that it 14 cast a question of what Sargent & Lundy has said.
15 BY MR. GALLO:
16 0 All right. .If your prior testimony was that it 17 did definitely cast doubt, you are now changing that?
18 MR. CASSEL: Objection. That's --
39 THE WITNESS: It still casts doubt, but if it 20 definitely casts doubt, I'll change that.
21 BY MR. GALLO:
22 O Okay. Fair enough.
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'11-10 q
'l~h t/ 1 What is this' item on computer printouts by 2 inspector for Hunter-Corporation?
3' A Oh,' boy. There's.a bunch of' computer printouts 4 that I. reviewed and I have copies of, even though I didn't really want them mysel{. .But;they are listed by inspector.
5 .
6 .The inspector numbers here are' listed. The document ID 7
number is what is shown onjthe-documents._ Those things 8 appear to be the ' work ~that the inspector did on a 9 computerized basis. It listed what was reinspected,.what to was inaccessible, what was not accessible. There was 11 quite a few things.on it.
12 The thing that -- I initially didn't even care 13 to look at them, and I finally reviewed them primarily for
(' -
14 what was inaccessible, and that is why that's listed here.
15 For instance, the first inspector says 16 inaccessible due to a lot of retrofit on feedwater system.
I'7 Now in reviewing the Hatfield work on ASNE qualified 18 components --
19 Q I thought this was Hunter.
20 A Hunter. Okay, Hunter. Yeah, Hunter was ASME.
21 In the documentation that I reviewed, I think it was 22 BRP-1 or something like that, the calculations that Mr.
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117 11-11
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'~ ' Branch testified:to concerning a~ review of_ASME and' piping,
- 2 Hunter. system stuff,'that; documentation, when I reviewed.it 3
'only included two feedwater system problems.
This' documentation all' owed-me to compare the
-5 l actual problem with what's on this list of feedwater stuff-
-6 that this guy'.wasIlisting'as inaccessible. The two that 7
were reviewed in the-49 or so that were reviewed did not 8
include any of this feedwater stuff that was inaccessible 9
here due'to retrofit.
'O The other thing is, this retrofit was not clear
" if it was being retrofitted right that minute, or if it had 12 been retrofitted since inspected, and that interfered with 33 the reinspection from the original inspector. That was not
'd clear. That one thing is not really -- is a question, 15 because I. wonder about that feedwater stuff that was not to reviewed.
37 The third one --
'8 Q I'm sorry, I was just going to --
'9 A The third one is obvious. I highlighted the 20 word " cleanliness" and " hydro test." Hydro test is a very 21 limited timeframe as affecting anything. You can 22 reschedule an inspection three weeks after the hydro or a week p-'9 L
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118 11-12 e ,
K/ 1- before the-hydro.c It is simply a scheduling problem when 2 you let;hpdro' interfere with an accessibility of an item, f e. '
3- Ljust hydro. , [ - ,
4 Cleanl'ine ss . The word " cleanliness" -implies 5 that it's filthy,.-you;can't visually see it or inspect it.
6 There.is a category'that was omitted from.the inspection 7 -called housekeeping, and I assume housekeeping is an ongoing 8 practice of keeping things clean. But to make something 9 inaccessible because it's so filthy, when_you could go-
-10 out and clean it, if that's indeed the way this was written, 11 says why did they not look at this? It's not reasonable 12 -for them to say it's filthy, we won't look at it.
13 Q Let me.ask you --
(
14 A The fourth one, the same thing. ~
15 Q I'll let you go to the fourth one in a minute.
16 But do you have these documents that you've 17 referred to here?
18 A Yes, I've'got the whole file. They're stamped.
19 They were Xeroxed by Mr. Gayley before giving them to me.
20 Your office should have a copy.
21 Q These are the accurate numbers for these things 22 here?
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119 11-13.
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\J 1 A . Ye s . - I double-checked them since this was 2 done. ,
end 11 3 4
5 6
7-8 9
10 11 12 13 14 15 16 r
17 18 19 20 l 21 22 O
1 m
-120
- 12:11
,A
'2
'- 1
, Q- _This list of items, then, is a series of
.2 : potential concerns on~your part?'
3- A' It's concerns concerning the: attributes associated 4 with'the review, yes.- _They are notfall-inclusive, I should 5 state, too. I only' listed _four here. fit would_have been a 6 quite -lot longer list. I tried to list the'different 7 categories like hot functional, cleanliness,-hydro. I e didn't try to redo those over and over for different 9 inspectors..
10 There were other inspectors with cleanliness 11 problems.
bu-6 12 MR. GALLO: Can we go off the record for a 13 minute?
.O 14 (Di7cussion off the record.)
15 BY MR. GALLO:
16 Q Mr. Stokes, I believe I interrupted you. You 17 were about to address this item in the middle of the 18 page that starts out Table 38.2-1. Where did that table 19 come from?
20 A You didn't interrupt me. I wasn't --
21 MR. WRIGHT: Objection, Joe. I think you 22 interrupted him when he was going to the fourth part. I don't think he actually got onto that point yet.
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- 2. : Inspector' 1313, which' was . the third inspector ' for hot
-3' functional.
'4 -
MR.-GALLO:
5 Q You mentioned cleanliness.. I thought you had
~
o' = covered.that point.
7 A ~I-didn't cover hot functional. Hot functional e and hydro were:quite-similar, but they were listed as two 9 different problems with inaccessibility. It can be - JI:
10 mean.there's hot functional going on the other day when we 11 toured the plant. It was warm, but not impossible to 12 perform an inspection, I don't believe, just because of this 13 statement,' hot functional, without a much more definitive 14 statement,that casts that question, yes.
IS Q All right. Now turning to the item that starts 16 out Table 38.2-1, what document'is that table from?
17 A I believe it is from'the first document which is we were discussing, the main Sargent & Lundy criteria.
19 Structural project design criteria, Byron-Braidwood. It's 20 the only document, to my memory,.that-went up to 38. It 21 actually, I think, went a little bit beyond 38.
22 O The next line refers to -- the next three lines 1
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122
. 12-3
/~h i) 't - start out -- well, indeed, if.you look at the rest of the' 2 page,.each line seems to start out "omitted."
3 A. Yes.
4 0 'What does that mean?
5 'A- Just that.
6 Q Omitted from what?
7 A All procedurals that I reviewed, everything that-8 was given to me, supplied to me, there was absolutely no 9 section, no drawing, no nothing concerning through-bolt to ' design criteria. There was no-flare bevel or bevel weld 11 radius tube steel specified.
12 In other words, there was no table as to what the 13 . radius would be for the design team to use for various tube 14 sizes. There was omitted no as-building, 10 percent over-15 stress factor, and I limit that.
I 16 Now there was one document that covered that. It l
l 17 was -- this one line was not in the main' criteria. It was 18 not in the DC-ST-03-BY/BR document. There was a proprietary 19 document that I was allowed to review that included 20 several comments on both 10 percent overstress, zero percent 21 overstress, 33 percent overstress, and actual -- just --
22 you.could fail;one' member every so often of a certain type comment. But'at the moment I can't give you that document's number.
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123 12-4 F
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(,) i- 0 So what you are telling me'is that where 2 - "omitted" appears, the subject that you describe is not
~
3 : covered in any of the documents you reviewed, wit'h the r
4 exception that you just noted?
5 A 'Yes, that's true. ~It wasn't in anything I saw.
L
.6 0 You indicate that there was nothing on flare 7 bevel welds and bevel -- I'm sorry, flare bevel-weld radius 8 and tube steel?
9 A I said there was no procedure.
10 0 I see.
ij A Design criteria procedure --
12 0 Go ahead, what is Attachment 77 13 A Well, that's probably.one I included for another b
(_- i4 point, and I was just fixing to -- yes. I'm not sure just is what that is. It's like I said -- or if I didn't say it, 16 I'll say it now, it's marked safety-related, it's got no 37 calc number, no revision. It's not reviewed, not approved, is it has no client, no project, project number. This thing is pp -- was almost, as far as I can tell, untraceable. But it 20 had -- and this copy is as terrible as my copy had. In 21 comparing several sheets of this thing, I was able to 22 determine this number at the top, the 117.57. It's something
?,
1 4
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12-5 124 I
STD 117.57. I couldn' t even determine who prepared it. If 2 you can read that, boy, I could use you.
3 I could determine on secondary pages what --
4 who did it. It's got Shenean as the preparer. Still not 5 reviewed and not approved, but here he finally did stick in 6 something that helped me a little. It wa- CECO, Byron-7 Braidwood, and some numbers.
8 I still have not really found out anything about 9 this document. It's concerning weld reviews. It's obvious 10 from the write-up -- undercut -- boy, that looks like 11 reinspection stuff. You've got the 10 percent reduction, 12 you've got undercut and different sketches, and what really 13 caught my attention when I got through this document was it s
(' I 14 gets over and it didn't even have a page number. It has a 15 nice picture of tubing intersecting plate, and it calls out to the weld symbol for the tube-to-plate weld, R(E) with a bevel 17 weld.
18 What really caught my attention, after talking 19 to Sargent & Lundy that Wednesday several weeks ago was the 20 next page con'cerning' flare bevel groove welds, and it appears 21 that whoever prepared this did some research, and it states 22 typical field measurements indicate.the actual radius is between T and 2.5 T, where T is the tube wall thickness.
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'125 12-6 Therefore the design assumption of R equals 2 T, an 2
offective throat equal to 5/16ths R per AWS D-1.1 is not-3 applicable.
4 Now, that states everything in a nutshell as 5
far as I am concerned. I, on Wednesday discussed an 0
allegation which I raised at Diablo, and I had absolutely 7
no proof that it would go anywhere where, and all of a sudden a
I was reading through this documentation and dumped in my lap was a flat-out statement by somebody at Sargent & Lundy 10 stating that their design assumption of R equal 2 T is not applicable to this work, and that there is T-radius steel in 12 the plant.
I3 g) They make that statement, but they don't sign it.
NJ 14 I guess it was Shenean.
15 But, in any case, this thing in fact did all the 16 research that I needed, that I wanted to do in the field. I wanted to measure stuff when I got my field trip, if I ever 18 got one that I could go on when I wasn't too busy.
This document did all my review work. It says 20 flat-out everything that's been assumed by Sargent & Lundy, 21 if it was based on their design assumption of R equal 2 T is 22 not applicable to Byron. Now --
A *
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(_,l ' -i O. Okay, are you finished?-
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2 A Yeah, I think that's plenty.
3 0 So I guess based on your testimony, this whole a question of flare bevel weld was not'omitted from the 5 documentation you looked at?
6 A It was not -- I said it was omitted from 7 procedures, criteria.
g Q And this doesn't qualify as any of that, Attachment 9 7 I'm referring to?
30 A No, it doesn't, because I don't know if this ii thing has been' destroyed by -- well, I know it wasn't 12 destroyed, because they gave me a copy of it somehow. But i3 what it' does tell me, because it's not reviewed and not ja approved, that somebody' undoubtedly didn't ever want to use 15 this thing.
16 But, then, on the other hand, the stuff that j7 follows the flare bevel stuff on thin plate sheet welding, 18 D-1.381, and the' transverse loading on the weld calce, it
.iq appeared in the calculations I saw,'they used these numbers 20 as the'capa'ities c for the wolds'wNich says they should have.
21 been reviewed.and approved. But it wasn't.
22 So I've got a contradictory attitude here. I've O
1
.. -_ _ = _ - . . - - - - _ _ - - - - . - _ _ _ _ _ _ - - - - - _ _ _ _ _ _ - - _ _ _ _ _ - _ - _ - - _ _ _ _ _ - . _ _ _ _ _ _
127 12-8 _.
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1-got-numbers being used out of this document without it 2 being final'ized'and approved or anything, and then I've got 3 on the other hand stuff that would have been.very useful in
- -expanding, if anything, the review to all these joints 5 that-this guy is making the statement are in question, and
'6 7.ve never seen anything expanding the review to these 7
~ joints.- Softhat's where I stand.
8 0' All right..
9
?cnd'12 10 11 l2 13 14 15 16 17 18 19 20 21 22
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. ,g s \~/ - 1 MR. GALLO: Can we go.of the record for a'
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2 moment? ,
3 (Discussion off the-record.)
d I BY MR. GALLO: l 5 Let's refer to Attachment ' 6, Mr. Stokes, in the Q
6 -- well, you tell me what' Attachment 6 is. The first.page ,
7 is a page of a letter to Mr. Reed of Commonwealth Edison 8
dated January 30, 1984, and what is the second page?
9 A If you note, It's a letter out of this document.
H) the first page is F-1 and the second page is F-13. I 11 didn't even feel we should Xerox this at all and supply it 12 as an attachment, because I felt'all NRC letters and 13 transmissions would be acceptable as -- in evidence ~ already.
O 14 In any case, we did Xerox the first page just to 15 show that it links it to the page on 11 with the F' number 16 coding system.
17 So the second page of Attachment 6 is '---
Q H3 3 A Attachment 6, 'it's that letter containing ---
19 it's an inspection report, basically, is what that letter was 20 on.
4 21 So page F-137-Q 22 A Uh-huh.
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<13-2 , . s - _ 129 p
L - (.f 't Q I see., ,
2 A There was an inspection report.
3 ~Q If I turn to page F-13, really your second-4 sheet of Attachment 6, and I look-under the item that 'you 5- have " starred, 'there is- a reference to a drawing detail 6 _ called DV-164. And if I look in the finding, there is a 7 reference to DV-162.
8 A Uh-huh.
9 Q Do you understand this to mean that what is at to issue here is the drawing detail DV-162?
11 A No, the allegation reads in quotes:
12 " General surveillance of this project 13 illustrates that approximately 90 percent of the B welds O 14 on that drawing are 1/8th undersize where tube steel has is been used. In most cases this represents a 40 percent to decrease in size and 55 percent in strength."
17 It was obvious to me by reading that ---maybe .
18 incorrectly -- that they were discussing flare bevel welds 19 on tubing which someone had made an allegation against the 20 flare bevels being undersized 1/8th of an inch, which is 21 quite similar to the allegation I raised at Diablo Canyon 22 - in the relation of quarter inch fillet welds and requested --
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, s or.notifillet, flare bevel was expected, and only 1/8th was
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2 installed.
'3' O Do you know whether or not there's a drawing 4- detail called DV-1647
.5 LA No, I'm not even familiar with what.DV-164 or 162 y 6 or anything is. It wasn't in part ---it wasn't in the
.7 document. >
8 Q It's my understanding then that you just assumed 9 that the welding involving the tube steel in this allegation 10 was flare bevel type welding; is that correct?
11 A I did, yes. I may have incorrectly. That 12 would be-the same quote, almost identical.
13 0 Mr. Stokes, I'm going to show you a drawing O.
\/ 14 prepared by Sargent & Lundy which has on it drawing detail 15 DV-162. We have marked the area for you.
16 MR. CASSEL: Did you say this was 164 or 162?
17 but. GALLO: 162.
18 BY MR. GALLO:
19 0 It's -- where Ls the drawing number on this thing?
20 MR.. HOOKS: Right here.
21 BY MR. GALLO:
22 Q This is Drawing No. 6E-O-3292. Is that right?
5 .-
7_
<.13-4 ,
- 4 131 1
A_ 4 i MR. HOOKS: Yes.
t 2 BY MR. GALLO:
3 O And on this drawing is detail DV-162. I' wonder, 4 Mr.' Stokes,.if you can take the NRC description of the-B 5 weld that they are talking about and look at the drawing 6 ~ detail DV-162 and tell me whether or not the weld-shown 7 'as the B weld'is the. flare bevel weld or a fillet weld.
8 A The B weld here is a fillet, which wouldn't 9 apply to a flare bevel, no. So, thank you.
10 0 Did that change your reliance on this Attachment 6 11 for purposes of your answer?
12 A Well, it could be extracted from the documentation.
13 as far as I'm concerned. If I had presupposed that the O 14 allegation was tube steel, flare bevel welds was the issue is here, if that's the -- since you've shown me that it's not, 16 it's obvious that I'm raising the issue for myself, as per 17 the attachment after this, 7.
i is Q All right.
19 A I thought it had already been raised. I'm sorry.
L 20 It's something new.
21 Q Let's turn to your Answer 29. It's on page 20.
22 If I understand this answer, Mr. Stokes, you L
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I 132 I 13-5 1 have questions on calculations and assumptions found in 2 Calculation Book 19.1.2, and then your subsequent 3 questions and answers that appear deal with, by my count, 4 four of those items.
5 Let me make it easy for you. By my comparison, 6 you have not addressed Section 19, pages 1 through 5, and 7 Section 21, page 113 and my first question is -- maybe you 8 want a change to check that out to see whether my evaluation 9 is correct?
10 A I think I sort of looked through it the other 11 night, and I noticed that what you are saying is true. I 12 didn't --
,_ 13 0 Well, are there problems in Section 19, pages 14 1 through 5, and Section 21, page 113?
15 A I believe there are, yes. I think I checked out 16 all the numbers per a list that I had.
17 0 But they're not included in your testimony?
18 A In haste -- I'm sorry, I didn't include 19 absolutely everything that I found. I intend, and I had 20 planned on supplying a list to both Ceco and the NRC at 21 some point when I get it completely finalized. I'd like to 22 be abic to strike some of the things before I give it to
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Ek/ I - them.- But this list, as I have said already,'or will state, 2 is not absolutely everything. In some. haste.there's been a 3 few things omitted. I stated that, I think, a little earlier
-d 'in relation to.the -- I don't think I included the document 5 on the telephone conversat' ion that'was not documented.
6 There was a'few others that now that I'm thinking 7 back along the calculational' side of things, I didn't 8 include in haste, but they weren't technical as much as 9 documentational issues that are QA-oriented. So. . .
30 Q Now, as I understand, the item-that you referred 11 to in your Answer 30, . is this a -- first of all, did this 12 involve a discrepancy that was detected during the course 13 of the Byron reinspection program?
O 14 MR. CASSEL: I'm sorry,~ Joe, you said Answer 30 15 we're now on?
16 MR. GALLO: Yes.
17 THE WITNESS: Was it detected during the Byron 18 reinspection program?
19 BY MR. GALLO:
20 0 Is this a discrepancy that was detected during 21 the Byron reinspection program?
22 A Well, the weld inspection sheets that I reviewed, m
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13-7 134 1 which were supplied here, they were in Section 2.1, page 5, 2 I believe. Yes. And the calc was actually in Section 4.1, 3 page 7 to 11.
4 According to those documents, this was reinspected 5 in connection with'PTL's scope of work.
6 0 Did the calculation that you reviewed -- was that 7 an evaluation of the discrepancy by Sargent & Lundy?
8 A Yes. These documents, all the calc books, are 9 Sargent & Lundy's, by the way.
10 0 Do you know what contractor at the site -- I 11 mean what Byron contractor -- let me strike that and start 12 again.
7_s 13 Do you know what contractor doing the work at
! .)
14 the Byron Station produced this particular weld?
15 A Produced it? No. Whose scope it came under in to the review? PTL.
17 Q PTL did the inspection; is that correct?
18 A Yes. Well, it was in their scope of the review 19 program. I don't know who actually did the weld to start 20 with.
21 Q PTL didn't do any welding; isn't that true?
22 A They inspected stuff, though.
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!.w/ .1 Q- All right. If I'were-to ask you this same series-2 of questions with respect to Answers 31, 32 and'33, would 3 '3~ you in; essence'give me the same answers? Namely,'.that~
4 : there~are discrepancies detected during the reinspection 5 l program, but you don't know which contractor produced _the-6 welds?.
7- A That's true,'I don't. I just know they were,in _
8 PTL's scope .of .the reinspection program, which is what I was.
9 supposed to review.
10 MR. GALLO: Well, we just saved perhaps 10 minutes.
11- I just.got a poke.
12 (Laughter.)
13 (Pause.)
O 14 BY MR. GALLO:
15 0 Turning to your very last answer in your 16 testimony, this document you refer to, Drawing '6E-3393B, 17 is that a Sargent & Lundy drasing used for design purposes?
18 A Yes, I believe it was design installation --
19 initial design.
20 Q Do you know for what component?
21 A Category:1 conduit supports. There's a series 22 of these drawings. This is the only one I listed, but the 4
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A_,L 1 whole' package, which was supplied to me, is 6E-3393A, it went almos* through the alphabet. It missed several letters 3 at the end and then came b'ack AA and BB, I believe, if my 4 memory serves me correct. It was quite a substantial 5 package of drawings on this particular --
6 O On page 26 of your testimony, you. refer to the 7 unistrut catalogue. Is it your understanding that Sargent 8 &.Lundy uses the design tables that are contained in the 9 unistrut catalogue for design purposes?
10 A It's not my understanding. It's sort of obvious 11 from the questions'I raised concerning KL/R that they may 12 have used unistrut, .8 for the K factor, which would make
-l 13 quite a substantial change in the table that I was looking 14 at, and the correctness of it for end connections..
15 And so whether or not they used it specifically, to I can't say, but it appeared that they may have relied very 17 heavily in the unistrut catalogue on the .8 factor, and 18 possibly the KL/R is listed for that factor, instead of 19 doing their own analysis of KL/R for the actual conditions l 20 in this table.
21 That was the explanation I reasoned out on my 22 own, but I can't go beyond that.-
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, (_/ 14 1 -A Not specifically. .That was'in relation to the-2 ' field trip that ' I went' on with the Judges. In that trip, 3 the first-thing that I -- we was looking at electrical 4 stuff, and the first thing-they carried us to was all these s' tray' supports that were-extremely long off the ceiling, 6 and I remember.asking one of the CECO people -- I think it
,7 was, how long one of these members was, because I wasn't a sure I'could estimate it halfway decently, and he said, 1
9 " Eighteen feet."
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l 10 I' don't wcnt to interrupt you, but I thought we were' talking about conduit supports in these answers on
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11 12 page 26. , . .
l-13 A Well, these are conduits in HVAC -- not HVAC --
0 14 cable trays are conduit--supports.
That's what we.were is looking at in the field, a lot of cable tray supports,
'16 GXtremely'long members off the ceiling. If-I said HVAC, 17 I'm sorry. The same-supports, by the documents I saw, is could have HVAC as well as cable trays on the same 1
'19 structure. And if I said just strictly HVAC, I'm sorry. 'I 20 There.would have been a combination of those two, maybe 21 just one or.the-other. -The ones we saw in the field that 22 I'm specifically referring to in that statement -- I believe a
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'> ul4.-2 1 11'were' cable trays, but I can't say for sure. 'They didn't 2' - have any HVAC on them.
3 0 Now I'm confused by your testimony. On-page 26, 4 you say that you reviewed many designs that exceeded the 5 .200 factor. And what I'm confused about is whether you 6 actually reviewed documents that exceeded this factor, or 7 it was based on your tour with the Judges that day and 8 you observed these: during; your tour.
BU7 9 A Some of both. 'The documents'that I start.out with, 10 the table indicates that the table-is incorrect. That
~
11 indicates that many' supports designed by that table would 12 be, in effect, incorrect.
13 On visiting the field, to continue, in
~O 14 extrapolating this, I visually saw many that exceeded-and 15 complied with this table. I actually saw them. .They were 16 shown to me, and they fit that table exactly.
17 On top of.that, in the calculations which I have 18 reviewed, which were towards the weld's end, which-only 19 was one very minor part of these things,-there was 20 reference by sketches of the configuration in the structure.
21 You can say I presupposed that many of those structures 22 are shown with the in excess of 200 KL/R, because in 22
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(-)14-3 l' many cases the lengths of these members were not indicated, 2 and I'd have to.actually compare, if I knew the hanger 3 number, back to the drawings.: It's a very difficult thing 4 for me to try to trace all.this stuff'back and forth. All.
5 I can say is, I reviewed those three things, and the same 6 problem is obvious in-all three,--'the field trip,.the
-7 document, add in thd cal $ulations.
8 0 =3 Let me see if I follow you. Based on your 9 review of the--. table:that is discussed on page 25 of your 10 . testimony, you conclude that'the table is inadequa'te,'and 11 then based on your field trip with the Judges, you actually 12 observed designs where the factor of 200 was exceeded.
13 Is that a fair statement?
f-
- 14 A In my opinion, I saw stuff. I didn't need a.
15 tapemeasure and a ladder to get up and do a real detailed 16 dimensional check. But just off of judgment, I would say 17 they exceed well over 200.
18 Q All right. Are you familiar with the testimony 19 -- of Ernest Branch?
20 A I have read Mr. Branch's testimony, yes.
21 Q Are you aware that he evaluated 49. discrepancies 22- involving ASME welds?
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( l.mgc14-4 1 'A- Yes, I~ referred to that earlier in my statement
.2 when I was talking about thin wall.
3 Q Did you review any of those calculations during 4 your. review at Sargent & Lundy?
5 A- Many didn't have calculations. I've got the
-6 document'which_was given'to.-me. Maybe it's not complete, 7 but there,'s/three documents given to me -- BRP-l', BRP-l (a )
-8 and another do'cumbnt, I.th, ink 'BRP
/ i 3. . I won't gurantee 9 that'last one',.but it's a listing of all those things 10 . reviewed.
11 In many cases, they were simply stated; " Accept-12 able," with no calc.at all.
13 0 We're talking about the 49 ASME welds?
(-#) 14 A Yes, yes. There was a-little pipe wall thinness l
15 calculation. I don't think that part was in the calc, 16 though, the pipe wall thinness. But they referred to the 17 thickness requirements and what was calculated as being 18 the requirement. I wasn't sure there was an actual-19 document where they sat down and said the thickness and 20 the pressure and all this stuff, and they came up with a 21 number. I didn't'see that, no.
22 Q It's Mr. Branch's testimony that 49 ASME walds,
.1.
I
'.-9
142 I which were detected with discrepancies during the 14-5
'2 reinspection program, were evaluated for their design 3 significance, and that none had design significance.
d And I am.asking if you, in your review at 5 Sargent & Lundy, looked at any of those evaluations?
6 A I looked at;those.three. documents, and they 7
were --
8 Were those-evaluations in'there, in those three Q
9 documents, to your' knowledge?
10 A I can't say it was completely there. There was 11 an evaluation in there, yes, as well as the entire listing 12 of all of the welds.
13 Do you know whether the evaluations that Mr. Branch
) Q (J
L 14 was referring to are the.same as what you reviewed?
15 A I have no way of knowing what Mr. Branch reviewed.
16 He's never supplied me with a list of what he actually 17 If I made a statement on what he reviewed, looked at.
18 I would have to presuppose that -- make an assumption on 19 that basis, and I'm sorry, I can't do that.
20 So you don't know whether you reviewed the'49 Q
21 ASME discrepant weld evaluations that Branch testified to 22 or not?
N
.,f
.,?
.]43
.s.
i 1 14-6
-1 MR.. WRIGHT: Objection. . I think that's answered 2 in--:his Answer-36.
3 Ti!EWITNESSi,ghe-documentwascoveringthe49-4 ASME.. }f there si 49'more, what can I say?
e 5 BY, MR,. f GALLO : ,
s I'm'talkiEg'about"the ones that Mr.. Branch 6
No.
7 testified to'. ; '
c i - <
.8 A- .Again," he only testified to 49 ASMEcwelds. This 9 . document ~specifically addresses 49 ASME welds. Unless to there's more.than 49 and more than one document, I have 11 no'-- you know,' I.can only say I assume this document 12 covers the same 49 he reviewed.
.- 13 0 This is~not a trick question, Mr. Stokes. It's-
% i4
~
my understanding thatito meet your request.for a review 15 of documents, that Sargent & Lundy made available, among 16 other documents, all the calculational books that:. dealt i:7 lwith these 49 discrepant welds, and I'm just asking is- whether or not you reviewed those.
19 A If they did, then I reviewed them, at least in 20 -their office on a very quick scan-type-basis, and-I believe
- 21 the document that I've got a copy of,'these 49, is the 22- entire package, but --
a
- ?
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b
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.144' l i.
\ 'mgc114-7'l Q. Did1you note any deficiencies in those
.2 -evaluationsb ' -
3 ~ gj Did I mentionfany in this. testimony? I don't' r . ,
d.
believe I did. - ILthink.there is affew comments I had 5 . cx1 them that may have been something th'at I felt was n'ot 6 that important. The 49-I looNed at, there was -- yes, 7 was. I'll back up.
there 8 The question before 37, the one you omitted, 9 discusses whether any Sargent & Lundy. calculations for.the 10 reinspection program had caused concern, and I list BRP-1, 11 okay?. So I answered it in that question. There's two 12 welds, 62 and 63'which were accepted, despite the fact that 13 .the accuracy of the gauges supplied for measuring the welds-(~')
'~ 14 was only 1/64th of an inch.
15 The actual numbers shown in this cale indicate 16 that this thing fails, period. The only way they got it 17 over was they used the 1/64th accuracy to say, "Well, we is assume this gauge was out of tolerance, and we boost it 19 over." So that. caused concern. But that was related to 20 weld gauges used in inspecting.
21- Other than that, in those two, I can't remember 22 any more.
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\-[ mgc14-8 l' Q Go ahead. I'm'sorry. '
2' Doesn' t this comment on the top of page' 25 'go to the' quest on of.'the0 adequacy Of the inspection, as opposed
~
3 d :to the adequacyiof-Sargent & Lundy's discrepancy evaluation?
It cannot go td:both.1
^
,5 It goes to-the adequacy of A
6 the inspection, in that the-gauges in question here, 7 -the documentation that I saw, letters from the supplier --
F 8' his own comments'are,."These gauges are only gen'eral 9 . quality accuracy, and if you need a more accurate gauge. -
H) then you'should use-something else, specifically machine 11 shop type gauges."
12 So it goes.to as to what equipment was supplied 13 to these guys to do the calculations to determine the ld accuracy or validity of'these errors,'and'thenlitigoes is to the assumptions'on Sargent'& Lundp's part to get these 16 things out of any significant level category, instead 17 of assuming that the gauge was above tolerance that was
~
18 used to measure it on the one hand, and below tolerance 19 on the other! hand -- 1/64th and 1/64th, which would have 20 been 1/32nd, and added that to their difference -- would 21 have been even more out of scope. Now --
l 22 0 You think they -- let me see if I understand what.
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- 1 - you're telling?me. 'You're, telling me that.the dimension
~
2 of the discrepancy was understated in this instance?
3 A ItDcould have: been.
4 0 'And that therefore this adversely affected the 5 evaluation of;these two. weld discrepancies performed by 6 Sargent & Lundy?
7 A It~could affect not-only those, but many. When you have only an accuracy of.1/6*th of an inch, and'that's
-8
~9 plus or minus accuracy, and-you arbitrarily assume that '
10 everything you. measure is; perfect, with that you're --
'll if'you use the exact same gauge-from here to here to here 12 to here to here in every evaluation 't hat was evaluated
~
13 in the'very first place, then you can say, "Well, this O 14 gauge is inaccurate, but the inaccuracy is identical to 15 what was used at the beginning, so the determination has 16 no effect." But when the inaccuracy of the gauge is not 17 consistently applied to the same location of measurement, a
18 then you have a plus with a minus, a plus plus, or a i
19 .minus minus.
20 'In the worst case, this plus minus,.that's using 21 a low tolerance, say, at.the end, undersize with an 22 oversize at the beginning, you get two unconservative1 3
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2 g. 311[right. 'L'e t me ' a s} you this question.
3' - Were-Welds ll-A and 33 -- I think those-are
'd the shorthand' terms that I can use -- referred to at the 5 top of page 25'of your testimony, were those designated 6 as' discrepant welds?
' 7 A They were in this batch of discrepant ASME welds 8
~
which were reviewed by Sargent & Lundy in BRP-1, yes.
9 And did you check those particular evaluations Q
H3 to determine whether or not Sargent & Lundy. performed them 11 adequately?-
12 A Well, from BRP-1, the evaluation appeared to be 13 inadequate.
14
_Q Based on this criticism?
15 A Yes.
16 Any- other reason why it might be inadequate?
Q r
j.
17 A Not'to my knowledge. I didn't see_any pipe wall -
18 thickness calculations in this package.
19 All right. -That's two our of the 49. Did you-Q 20 find any inadequacies in Sargent & Lundy's evaluation of
~
21 the'other 47 ASME weld discrepancies?
End.14 22 s+
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\/ I' A I don't believe so. As.I said, there may be other 2 minor problems I saw with those, because they were 3 assumptions, primarily. That's one of the problems. The 4 problem I saw with'a lot of this is they assumed'there was 5 no problem, if- you want to get down to the bottom line.
~6 There's a whole bunch of that in everything I've seen, and 7 that's assuming that whatever is there is okay, flat, 8 right off the beginning. They never did a calc, they didn't .
9 do no load comparisons, nothing. It was-just assumed.okay.
10 Now that's a problem as far as I see it,'
11 across the board. A problem is a problem. If you'want to 12 know the truth.
13 Other than that -- and I'd say that makes up h, 14 half of the 49 or more.
15 Q Now what was the nature of-the ASME weld 16 evaluations performed by Sargent & Lundy? What did they do?
17 A Well, from what I could determine from this 18 document, the nature of the problems primarily were 19 insufficient weld thickness.' It appeared they had done a 20 calculation to determine minimum pipe wall thickness. . That 21 was not part of.the package, and I assumed maybe-the guy 22 just did it on a rough sheet of paper. As far as I know,-I f
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- 15-2'- 149
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N! I didn't get any.of that documentation either. Otherwise --
2 Didn't they evaluate-the.effect of the O
3 discrepancy on the pipe?
d A They evaluated pipe wall thickness required by - :
5- what was there. They made.a statement.
6 Didn't they conduct a calculation to determine Q
7 whether or not the wall thickness'was adequate?
8 -A I just said they compared the calculated wall-9 thickness with what was there. I didn't see no calc in I0 this document.
II Q You didn't see any. calculation?
12 A No.
13 So you think they just eyeballed it and guessed?
f S Q
('.)
~
id A No, I don't know. I assume the guy did-a 15 calculation somewhere else and included it in this document.
16 I didn't seesit so I' don't have any -- had I seen the calc, 17 I would not have the sufficient documentation to question 18 the. pressure,: theLtempe'rature'J and a lot of other factors 39 that would have went into it.
20 There's no way I can~ draw a conclusion beyond 21 what I'm stating, because to do the detailed type review 22 you're asking is, first I would have to run the pipe analysis s
e
. . _ . , n . _ , . , . , . , - - n., . , . , ~ - - n , . --,
i 150 15-3=
- \
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. (_) 1 .myself, after rewalking the entire system to determine its 2 adequacy from that standpoint.
3 0 I'm only asking if you checked the Sargent &
4 Lundy calculation.
5 A I checked what I saw and what -- I can't go 6 beyond what's in BRP-1, 1-A, 3. On the ASME stuff, that's 7 the only documents I saw, I have knowledge of, that 8 discussed ASME issues.
'9 Q Now Mr. Branch also testified with respect to 10 his evaluation of certain discrepancies involving what are 11 called in the reinspection program objective attributes of 12 Hunter. Did you review any of those evaluations?
13 A Ye s .- I've got a document that says objective
~O 14 attributes of Hunter, as far as~I know. Parts of it, I'll 15' say that. I've got' copies of parts of that document.
16 Q 'Did that document address the so-called hardware
- 17. discrepancies;for the' objective attributes for Hunter, do 18 you know?
19 A I can't remember exactly what was in those 20 documents, whether it was just strictly welds. I-think it i
21 was primarily welds, from what I can remember. Whether it 22 was hardware, I can't be specific. I consider everything l
{
LO l
'1 5 - 41 151 s
I hardware, structures, attachments.' I would assume so.
2 0 Are you familiar with the testimony of Richard 3 French?
A
-4 .Yes.
-5 Q Now, Mr.. French's testimony addresses various 6 reinspection attributes'for Hatfield, and they are called' 7 in the reinspection program objective attributes.
8 Did you review any documentation involving 9 the discrepancies noted during the reinspection program of 10 these attributes?
11 A Hatfield?
12 Q Yes.
13 A Yes,' I've got copies again of excerpts out of
~
14 Hatfield' books.
15 0 All right. I.may be unclear in my question.
16 I'm really referring toSargent &'Lundy evaluation of 17 the design significance of the-discrepancies noted in the
~~
18 Hatfield objective attributes.
19 Did you review any of those Sargent & Lundy 20 evaluations?
21 A Yes, I think I did, but I'd have to consult 3 22 with everything that I've got. But just off the top of my 4
Z
. J
152 115-51 b 1 , head, I.have-documents on Hatfield, PTL and Hunter.
I can't 2 say I had both objective and subjective in both categories.
3 I tried to. pull. parts of documents supplied to me.
4 One of the documents which was sort of in question,
~
5 I believe, in.the hearings under~McLaughlin's testimony, 6 came'out was Mr. McLaughlin --
7 Q I'm just talking French now. We're talking a ' objective attributes'for.Hatfield-French testimony.
9 A' I would say-I've sein it. I can't really be to specific.
11 Q Can you tell.me if you recall, if you note any 12 disagreement:with any'of the Sargent & Lundy evaluations of 13 the discrepancies that are categorized under.the objective
/'
\ 14 attributes for Hatfield? $
15 A Mr. French's testimony to Hatfield concerns 16 cable ~ support trays, and I have got quite a few concerns 17 with the Hatfield calculations on those issues, yes. If is you'd be more specific about what was in the document, i9 whether it was cable tray or whatnot. I can remember that, 20 because that's primarily what I was looking at, was the body.
! 21 Many'didn't have right across the top "this is Hatfield."
22 It had Book 119-2. You had to go back to an index'to find 1
[h w
- 15-6 153 kI 1 out'who in the"he111it appliedto,.-and~it~varie'd from one-2~ little'section to another.
3- 'I remember-looking at plenty of calculations d- 'on conduitland HVAC supports that I have a whole bunch ~of
~
~
5 Lquestions about, yes. I didn't' include those here,.I'm sorry. .
~
6 MR. WRIGHT: ' Joe, how long do you intend'to'go.
7 to' finish h'im?
8 MR. GALLO:' I probably can finish up in.about 15 9 minutes.
10 MR. *[ WRIGHT: Okay.
11- '.THE WITNESS:. But,'yes, there's a lot.ofLthings 12 in th'atg category.
- f. '
+
BY MR.' ' GALLO:
13 '
O 14 .Q Did you review any of the AWS weld calculations 15- performed ~bysSargent!& Lundy with respect to the evaluation ~
16 of discrepancies of Hatfield and Hunter AWS welds?
17 A Yes, quite a few. That's primarily the review.
18 program, was welds. There was very few things outside of 19 welding that was in question from what I saw. A'few beam 20 connections,.which were again welding;-a few bolted 21 connections; anchor bolts.
22 0 .Did you review any of the Sargent & Lundy l
i L
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15 154
'l evaluations of th'e 356 Hatfield AWS welds testified to by
- 2 McLaughlin?
3 A Again, I don't h' ave a list of what Mr. McLaughlin 4 included in his 356 to' compare it to the documentation I 5 have. But just going on what was supplied to me and:what I
, 6 have seen, I would assume that I've at least looked at part 7 of the 356 Mr.~ McLaughlin testified to, yes.
8 Q Again, do you recall any disagreement with those 9 evaluations that you --
10 A I'm sure there's got to be a few in there. I 11 had disagr'e ements with quite a few .cif .his calculations, but I 12 didn't'h' ave e'nough time to include absolutely every calc r
13 that I looked at, that I had a question on.
14 The other thing is I didn't have time to go back 15 and redo a lot of the cales that I had done preliminary stuff to on and had a question over to verify that I was correct.
17 And so I omitted stuff like that. I'm sorry, I --
18 Q You don' t have to apologize. That's not needed.
19 So you're telling me you noted disagreement with 20 certain of the Sargent & Lundy evaluations of the 356 21 llatfield AWS welds, but you didn't note those in your 22 testimony that you filed in this case; is that correct?
l s_-
15-8 155
,'d 1 A- That's correct. I didn't have time. I'm sorry.
2 (Pause.)
end 15 3 J
5 6
7 8
9 s
10 11 12 13 14 15 t
16 17 18 19 20 21 22
- 16 16-1 156 s
1 Q All right. Page 4 of your testimony, Mr. Stokes.
1 You've -- are you on page 4?
? A Yes.
4 I'm looking at the sentence that you corrected Q
5 in response to a question from Mr. Wright. You say you 6 reworked the aspects of a number of engineering calculations.
7 Are these hand calculations that you performed yourself?
8 A Well, no, I said in my review I reworked aspects 9 of a number--when I reviewed some of these calculations I 10 was just talking about, I performed rough cales on sticky
~
11 tab sheets which I stuck right on the calc itself for future 12 reference. I have not had time to go back and look at my 7.,, 13 calculations or the other calculation.
I \
\ ,) 14 Q What does the term " rework' mean here?
15 A I used it like rework as far as reinspection, 1-6 re-evaluate, requalify. It's Sargent & Lundy's work, it's 17 the work they did, as far as qualifying the safety 18 significance, design significance of the joint.
19 Q Did you run an independent calculation yourself 20 when you did this, or do Stokes calculations exist? That's 21 my question.
22 A There's notes on sticky tabs that exist, yes.
i ,/
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.16-2 -157-
) 1 Those are not, if you want to say' Stokes calculations.
2 --They are rough calculations. In other words, I used those 3 :to draw the conclusion that there was possible error in what.
~
4 had--been done in.-that aspect of the calc. They're not --
5 as.ifar'as Stokes calculations, I have'an engineering ~ paper 6 that.I do a.dalc ~on and it's a very formal type thing.
7 :MR.,GALLO: Can'we.get copies of what hs's-
~
u 8 referringjto?! ( , i , ?,.
9 MR. .CASSEL: Do you have those here in: town,
- ~
10 Charlie, the' sticky-tabs?
i- 11 THE WITNESS: I don't think I-have all of them, no.
12 MR. CASSEL: IX) you have any-of them?
+
. 13 THE WITNESS: I.'d have to look through. 'There
~
14 are boxes of' stuff'.- I can't say.
15 MR. CASSEL: Could~you do that over the weekend?
I 16 THE WITNESS: Yeah, I can do it, because-I 17 planned on redoing some of those, anyway, just to verify.it 18 for the hearing, and so if you'd like, I could give-you copies i
7 19 of not only the sticky. tabs, but written up what I ' find out 20 over the weekend.
21 MR. GALLO: No , I'm just looking for what you've 22 already done. I'm not asking you to do additional work.
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(_)_ i THE' WITNESS: Well, I'm going to.
2 MR. CASSEL: He's going to, anyway.
3 THE WITNESS: See,;I'ye committed to it on my own
<- 4 4 4 so you won' t .be Esking ' for anytliing.
c >
_'MR.-CASSEL:c.We'll:be_ happy to supply as many of' S-6 the sticky tabs as ' Charlie can find ove'r the weekend. Do
~
7 you want-us to,just give.them to you at the hearing in.
8 Rockford, or'give them to you at the office on Monday?.
9 MR. GALLO: No, Monday would be fine.
n) MR. CASSEL: But are you going to be here-at n the office on Monday?
. 12 MR. LEWIS: Could you copy us on the sticky tabs, 13 if possible?
ja MR. CASSEL: The question is, do you want them 15 here or in Rockford?
16 MR. GALLO: We'll get them at the hearing in j7 Rockford.
ig (Discussion off the record.)
j9 MR. GALLO: All right, let's go back on the 20 record.
21 During the off-the-record conversation, Mr.
22 Cassel agreed to have'Mr. Stokes furnish the sticky tabs and l
D J l
p
i 16-4 159 ij s i the underlying documents referred to in our earlier colloquy 2 at the hearing to commence on Monday morning -- or Monday 3 afternoon.
4 MR. CASSEL: To.the extent they are physically 5 here in Chicago. If any of them are physically in California, 6 we won't have them by Monday.
THE WITNESS: -We won't have them at all, because 7
a some of the stuff when I pulled it to Xerox it, just to make 9 these attachments, I removed the sticky tabs. I didn't put io them back on. They're still on the Xerox machine. And when I i 11 got through, I didn't want to go through it, and I threw them 12 away.
13 MR. GALLO: To the extent they exist here in
<,_ T
'J 14 Chicago.
15 (Discussion off the record.)
16 BY MR. GALLO:
i7 Q One last question. I believe this gets us back is to the course work you took at Auburn.
19 A Okay.
20 Q I believe I asked you whether or not you took a 21 dynamics course and you said you did.
22 A Yes.
l LJ
f16-5 160 g
$ 1 0- Is dhis a required coitrse'or an elective?
2
^
A It was;. required at Auburn. At some schools it 3 .would probably have-been' elective. The BCE curriculum per
- d se hasimanyjmuch'more' technical hequirements in the program 5 than a B.S. in Civil would, m . .
6 Q I1 see..
7 A But it was a required course.
8 ~Q Now did this required course concerning dynamics, 9 did that deal with structural dynamics?.
10 A Yes, it did . Vibration, motors, bodies in-space, 11 quite a few different aspects of ' dynamic properties of 12 structures.
13 Q Did it deal with the dynamics of structures O 14 like reinforced concrete structures -- not steel structures, 15 concrete structures?
16 A The course was more' geared not to the designing 17 of concrete'and its vibration, but the kinetic energy la transfer dynamic equilibrium states associated with that 19 movement which would apply to any material based on its 20 properties.
21 Q Do you remember what year at engineering school 22 this course was offered? First year, second year?
r i
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,16-6. 161 Y /
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"Id: 't- A'- No,-it was:- 'what' year out'of'the curriculum, I 2 can't say!at'the moment. ~
.I think it was the third year,
-3 junior 11evel.1 sThe problem,.with'me,casJI'v.e already' stated, 4 .is ILwas in architecture and then transferred to civil, and 5 I'was a juni'ortalinost- Oh'en I .'shar'ted the . engineering.
~
I was ---
6 '.you know,'I.-- for me', it was.a junior level course, or above.
-7 MR. GALLO: That's all the questions'I have.
8 MR'. . LEWIS: We want to take a short break and see 9 .if We have anything. Five minutes, 10 (Recess.)
end 16' 11 12 13 O 14 15 16 17 18 19 20 21 22 i
i A
s .;
162 I
( )'17-1 1 EXAMINATION 2 BY MR. LEWIS:
3 0 We just have a few loose ends we wanted to tie 4 up. Mr. Gallo has been so effective that I find myself 5 left with little.
6 MR. GALLO: I'm going to let you go first next 7 time.
8 MR. CASSEL: Mr. Lewis is one of your finest 9 Staff members.
10 BY MR. LEWIS:
11 Q Mr. Stokes, I'd like you to look at Attachment 2-F 12 to your-testimony. 2-F is simply a one-page excerpt from
,, 13 the Sargent & Lundy design document that we've been talking l l
\# 14 about.
15 Have you located it?
16 A Oh, yes. Okay.
17 Q I'd like to direct your attention to the last is sentence on that page which reads, "A separate embedded 19 plate design shall be made where applied loads exceed the 20 capacity of the grid plate."
21 A Yes, I see that. I read that earlier.
22 Q You testified earlier that you were concerned
- J
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- 3 163 l
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(_/ 17-2. I about the loadn thatx might be exerted on embed plates, and
'2 I belie've you were talking about struts or~other members.
3 'A kes. ,
4 Q,' iben you read this sentence at the bottom of 5 2-F, did that indicate to you that the type of analysis 6 that you felt should be done would, in fact, be done where 7 applied loads exceed the capacity of the grid plate?
8 A - If the person was aware of that one line, 9 my experie'nce in this' whole little narrative here on embed to plates, that plates typically are designed for use without 11' knowledge of what's going to go there in many cases. The i
12 fac5 that the thing was on the plate indicated two things
,_ 13 from visual. There was a fairly large weld to the embed
( )
14 plate which had, you could tell, heated the concrete on 15 the edge. The attachment was as wide as the. plate almost, 16 which the plate had to be a six-inch plate. There was a 17 problem with overheating of that half-inch plate, because is it appeared they had put on quits substantial fillet 19 weld, and then on top of that, you tad a very sizeable 20 attachment for the width of the plate, and whether or not 21 this calculation indicates that it should be redone before 22 you attach it, and the' guy who did that analysis or did that a
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164 A;
k/ ) Ll7-3' 1
-support was aware of this at the moment, I'm sort of in 2 question whether'that analysis was performed for that l 3- particular one.
4 But -- is that clear?
~
5- Q Well, to some extent. Let me ask you this. In
~
6 other words, if I correctly understand you, you are 7' ' concerned that maybe the person who would do this 8 calculation perhaps would not be aware of this provision?
9 Is that part of what you.--
10 A. Yes. And the calc's book size'is almost of,the il book,.in the early part of the book, there was a series of
+
12 written documents such as what is attached here to my 13 testimony, explaining assumptions, what's relevant, what's s
34 not relevant, such as the undercut discussion. It's 15 obvious to me that in this review it was likely they hired to people such as myself without any prior Sargent'& Lundy 17 experience to do with the work, because I heard there had 18 been a layoff some fews months ago before the review was .
19 required, and the people may not have had this document, i
20 the criteria document. In other words, it may have. existed, 23 but it was something they weren't exposed to due to'the.
22 rush of doing these recalculations.
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people1 who did these evaluations in some cases did'not-3 know what's'in-this cr'iteria, and that was obvious byjother 4 a Ql t r . ,
's things' other than 'just' ti?t.is.- .
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5' .g- l7.m sorry.' I didn't mean.to cut you off.
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6
.A I know. (I'was' going i to quitJwith that. ' N 7
-Q Well, assuming that these Sargent & ~Lundy -- the 8
~ individual who would'do this calculation was aware of this
'$ . indtruction,.would it'then' address the. concern that you -
, - 10 p.7' i ,,
. hadt raised?a '
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_7 lI;I 3 -A 'If he was! aware.of'the instruction and evaluated ig ss 12 it, bh'ed s on-that line,,it would change that, yes.
- I3 Q' Now'if'Eyou could look'at Attachment'10 to your
.()
Id testimony, theithir'd pagd of.that excerpt'from the 1983 1
15 NRC annual report, -- -
16 , Oh',1 yes.
A1 37 Q -- the discussion of water hammer.
18 A 'I' remember.that"very well.
39 There is a statement"under " Water Hammer" which
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.20 . says, "The frequency of occurrence," meaning occurrence 21 of the water. hammer, " incidence is low, and damage has 22 generally.been limited to piping supports."
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k / ~17-5 1 Is that' statement-the source of'your statement --
2 I don't have.the exact answer 1in your testimony, but in 3
your testimony, you speak'of piping. supports as being j
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d' subjected to fatigue, stress.
5 .A. I quoted that'last-line almost in detail in one 1
- 6 -of the answers. I can't remember each one. l 7
.Q- Is it Answer.26? ~Yes, your testimony on page'18 8 in Answer 26 states that you refer to the NRC annual 9 report.
10 A Yes.
-11
-Q And you refer to the: excerpt on water hammer, 12 and you say there that the NRC report speaks of water 13 hammer, and then you say, "
A condition that causes
.n' 14 fatigue loading." '
15 A Yes.
16 Q What was the basis for your assertion that 17 piping supports are affected by fatigue leading?
18 A They are affected by dynamic loading. -Water 39 hammer is the dynamic loading. Seisdic loading is 20 dynamic. I've been in some operating plants, you know, 21 that the pipe -- fluid runs through it and it vibrates 22 from one side of the support to~the other, rattling quite
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' noisily. .That load reversal is just that -- load 2-reversal. 'The fact it hits one side and-hits-the-other.
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side is an, operational load reversal.-
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,Q Is that what:you meant when you said fatigue:
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. loading?.
6 A Part'of'it.
Cycling time. It would be over.40
'7 years significant. 'You'd have to' sit there and count how 4
8 many times'a.second'it changes and-then multiply it over-9~ a.few years. But water hammer is part of that,'.too. You
,10 have to take into account how many times a year. You can a
11 estimate' valve closures are going to occur.and these other 12 issues that will cause the extreme magnitude of loading 13 that water hammer causes.
.I .
I4 For instance, when I was at-Southern Services, 15 in my earlier discussion of what I was doing, I said I 16 worked on the makeup water lines offsite from Miller steam 17 plant. In doing those thrust blocks that I alluded.to, 18 I.had to consult with the ASME department expert on water 19 hammer. He told me that I had to design for the lines 20 for approximately ten times what the design load was to 21 account for water hammer loads, they were that much larger.
22 I, instead'of doing that, after I tried to redo W
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m/ 1 the' analysis to get supports that would take the loads 2 for these 24-inch lines -- when I found I had an extreme 3- problem with designing something for that magnitude of 4- load, I' looked at the. piping analysis layout drawings, 5 and I found out that there was potential for a surge tank.
6 Now one of the courses that no one' asked me about 7 here is pipe flow theory and fluid flow theory. I took 8 courses in that, too, by the way. And I'm aware that 9 another alternative between designing for loads is to put 10 a suppression tank on it or a surge tank or a few other 11 little goodies that can take out that load.
12 Well, it just so seems that they have this tank 13 potential, but they didn't want to use it. They were
/,s) 14 keeping it as an ace in the hole, and I negotiated to have 15 the loads reduced, based on that surge tank and have 16 it installed, rather than have them design thrust loads l'7 and then have them put the tank in'later.
18 So from that respect, I'm quite familiar with 19 piping thrust loads, water hammer, and jet impingment and End 17 20 a lot of other stuff.
21 Q Mr. Stokes, do you'know what position the NRC 22 has taken? There is a reference in the annual report that I'T ts' l
-169
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-1 1 .. .
1(J8-1l 11- 'you referred to doing your report, do you know whether-
- 2 the NRC has required any. hardware changes as-a result.of ---
3 A Yes. .According:to-the' article, their _
4 crequiring changing:of valves to reduce closure. times 5 was part-of it. I don't remember anything else,-but that-6 was the one' thing?I-remember-from it, and that'with.some 7 - certain systems rather than maybe the entire plant.
p 8 *
- Q. < But focusing on:1suppgrts oh. hangers,: because 9 that wastwhat your Answer 26 was-one'--
10 - A- It concerns stresses to hangers. .Yes, specifically 11 'the bolting-aspects.
12- -Q Right. Do you know whether or not'the'NRC 13 has required any changes-to hanger supports-as a result 14 of water hammer considerations?
15 A _ Changing of supports? Could you-clarify that 16 for'me?- Specifically what kind of changes?
17 Q Whether or not, as a result of --
18 A _Are you talking about_an'I&E Bulletin maybe?
19 Q Well, it could haveJbeen, I suppose' by:an,I&E 20 Bulleting.
21 _A~ Oh,~ boy. -
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22' MR.' WRIGHT: Ste'e,'can v I ask you-to restate 1that
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2 MR. .' LEWIS : -I'll be happyftr.
3
'BY MR.-LEWIS:
+
4- _
'O _IX) you know whether or'not as~a result of the S-
~inve'stigation of water hammer currents in nuclear power plants,..which,is discussed:in thistexcerpt from the annual-7' report, the NRC'has required any changes or. redesigns to 8
be done to pipe hangers because of the' concern over the 9
loads imposed by the water hammer phenomenon?
A 'I'm not aware of.them requiring any changes in 11' the design of.the hangers as a result. The' thing I'm aware 12 of is the valve change closure ~ time.
13 MR. LEWIS: Thank you. That's all I have.
- / ja EXAMINATION 15 BY MR. CASSEL:
16 0 Charlie, just a few questions on redirect..
17 Do you recall Mr. Gallo asking you this morning 18 .
about whether your-testimony raised concerns about the 19 design adequacy of Byron?
20 ~ ~
A Yes,;I remember,that question.
21 Q Does your testimony also raise concerns other 22 than the' design adequacy?
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. l. J ' 1 A .Yes, it does e.
- 2 .Q Do'you recall Mr.-Gallo also asking you whether 3
~
your testimony recommended an independent design review?
d A Yes.
- 5 Q. And are you aware of the fact that -Bechtel has 6
been Conducting-an independent design. review.for Byron?-
7 A
, Recently I became aware, yes.
8 Q Have the resultsaof that review been supplied 9
to you or,1to^your knowledge,'been supplied to Intervenors 30 in this case?
11 -A No, it's not been supplied, to.my knowledge,-to 12 anyone including myself.
d 13 0 Does your testimony also recommend an independent
+
14 review.of the safety-significance of the discrepancies.
15 found in the reinspection program?
16 .A :Yes. My_ testimony is: geared to everything that's 1:7 been done in the" reinspection' program, from the verification
~18 aspects'of the program to-the design calculations, the
~
19 safety-significant aspects, all: areas.4 20 MR , CASSEL: I have no further questions.
21 MR. GALLO: I have no~ questions.
22 s
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172 I
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' (Whereupon, at 3:50 p.m., the taking of 2 the deposition was concluded.)
3 4
5 (Witness' signature waived, 6 pursuant to agreement.)
7 8
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. 173
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_ j STATE' OF MA AND :
^
2 COUNTY OF MONTGOMERY::
3 4 I, ANN RILEY, a Notary Public in and -for 5 . Montgomery County, Maryland do hereby_ certify that'I 6 reported the deposition _of CHARLES CLEVELAND ' STOKES,-the 7 witness herein.
-8 I further certify.that the foregoing 172 pages 9
contains a true and accurate transcription of the answers 10 given to the questions herein asked.
11 12 I further certify that said transcription was 33 - done either by me or under my personal supervision.
14 I further certify that I have~no interest,-
15
.; financial or otherwise, in the outcome of this litigation .
4 16 3.
37 Given under my hand and seal of office this is 17th day of nugust, 1984.
19
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20 Ann RileyF 4 21 My Commission Expires:
4 22 July 1, 1986
.s 5
4, 3
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