ML20149E419
| ML20149E419 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/14/1987 |
| From: | Hansel J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20149A806 | List: |
| References | |
| FOIA-88-37 OL, NUDOCS 8802110043 | |
| Download: ML20149E419 (128) | |
Text
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-. _ . . - _ . ....-_ i 1
1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
/ BEFORE THE 2
ATOMIC SAFETY AND' LICENSING BOARD i 3
)
IN THE MATTER OF:
- ) DOCKET NOS. 50-445-OL 4
) 50-446-OL 5 TEXAS UTILITIES GENERATING) l COMPANY, ET AL ) l
)
6 (COMANCHE PEAK ST E Ali f ELECTRIC STATION, U ?lI T S 1 )
) J 7 AND 2)
TenMS-31 A)1 1
10 ORAL DEPOSITION
> OF 11 12 JOHN HANSEL
- e
/ Volume I 13 14 15 16 ANSWERS AND DEPOSITION of JOHN HANSEL, 17 taken at the instance of the Intervenor CASE on 18 the 14th day of October, 1987, in the above styled 19 and numbered cause at the offices of Worsham, 20 Fornythe, Sampels & Wooldridge, located at 2001 21 Bryan Tower, suite 3200, in the City of Dallas 22 County of Dallas and State of Texas before David Jackson, CM, RPR c Certified Shorthand Reporter 23 B.
24 in and"for the S ta t e of Texas pursuant to the 25 agreement hereinafter set forth: . , 1 i l
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i G802110043 000120 PDR FOIA WILLIAMSG8-37 PDR UNITED AMERICAN REPORTING SERVICES, I !! C .
Dallas, Texas (214) 855-5300 ,
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APPEARANCES:
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3 APPEARING- FOR CITIZENS F.SSOCIATION-FOR SOUND '
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-TRIAL LA)4 YE RS FOR . P UB L,I C JUSTICE "
5 Attorney's at Law.
3424 North Marcos/ Lane , '
6 Appleton,,$41sconsiN,5r9 Q ,
By:_Moj B il 1ig Gar,d( r ,, N ,-
7 ,;r , s s . 8 JUANITA E L.L IS , PR ES ID ENT J ER R Y ELL'IS *
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1426 South Polk 'i ,
9 Dallas, Texas 7 5 2 2 4 , ,' ' ,e 10 APPEARING FOR TEXAS UTIL5 TIES GENERATING COMPAN Y:
11 ROPES & GRAY ,
7 Attorneys at Law ,
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12 225 F ra nklin S tree t Boston, Massachusetts 02110 /- -
13 Byi Mr. W illiam S . E gg el'i/n g 14 ROPES & GRAY ,
Attorneys at Law ^
15 1001 Twenty-S,econd Street.s N.W.
Wcshington, D. C. 20037 16 By: Mr. Robert J,,, S till ma n ,
'Mr. Dav id jta'r tla nd 17 WORSHAM, FON ES YTHE , SAMPE'LS & WOOLDRJDGE Attorneys'at Law r 18 s' 2001 Bryan Tower, Sbite 3200 19 Dallas, T e x a s '15,2 01 - 216 8 ' "'
' By: Mr. Robert A. {9celdridge 20 .
FOR THE NUCLEAR RE GUL ATCR'Y' CbMMIS ,LS IO N :
23
,n JANICE E. MOORE ,e ;
22 O f f ice of the Executive L e,0 a l Director Uni ted' S ta tes Neclea'l Regulatory Commission 23 Washington, D. C. 20555 24 . ,
25 J
UNITED AMENICAN R t7. 'O R T I N G SERVICES, INC.
D a l l a tt , Texas (214) 855-5300
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JOHN HANSEL, 2 the witness hereinbefore named, being first duly 3 cautioned and sworn to testify tho' truth the whole 4 truth and nothing.but the truth, testified on his 5 oath as follows:
6 DIRECT EXAMINATION 7 B Y MS . G ARDE :
8 O. Mr. Hansel, my name is B il l ie Garde and 9 I'm an attorney representing the Citizens 10 Associa tion' f or Sound Ene rgy. They're the i
11 intervenor in the.
12 L i ce n s in g proceeding regarding Comanche 13 Pea k . With me is Mrs. Ellis and Jerry Ellis. I 14 believe you've met all of us before?
15 A. Yes.
16 MS. GARDE: Before we get started, 17 Mr. Eggeling, do you want to identify the people 18 on y ou r team? Maybe go around the room.
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19 MR. EGGELING: Yes. Robert i
20 Stillman is not in the room at the moment, but 21 will be j oining us in a moment. W il l be in the 22 chair to my right. And David Martland, i
23 M-a-r-t-1-a-n-d, is in the chair to his right.
I 24 From time to time Mr. Robert Wooldridge may join
'25 us. k4e've convened in his o f f i ce s and he's the UNITED AMERICAN REPORTING SERVICES, INC.
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4 1 host, but I don't know exactly when or f or how 2 long.
MS . GARDE: And Janice, do you want 3
4 to identify yourself on the record?
MS . MOORE: My name is Janice 5
6 Moore, and I'm counsel for the NRC staff.
MS . GARDE: For the record, this is 7
8 a first of a series of depositions that was 9 noticed last fall by CASE on an issue on the 10 adequa cy of the CPRT pr o g ra m plan, which is the 11 subject of this deposition. Between the time this 12 deposition was noticed and today, many things have 13 happened, and I want to bring the record up to 14 date with first the notice of deposition and the 15 subpoena duces tecum, then a stipulation that was 16 entered into between the a ppli ca n t s and CASE regarding any disputes regarding documents. So 17 18 let me first, Mr. Eggeling, I don't have a signed copy of the deposition - no t i ce of deposition and 19 20 subpoena. I don't have one signed by the Judge.
MR. EGGELING: Yes.
21 22 MS. GARDE: So I haven't marked 23 this one for attachment to the record, but I do 24 have a copy of the notice of deposition.
25 (Deposition Exhibit No. 1 UNITED A!iERICAN R E PO R.T I N G SERVICLS, INC.
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1 (was marked for iden t i f i ca t ion .
2 0.- (BY MS. GARDE) A nd - I would-like to ask Nr.-Hansel if he's ever seen what's been markedhas~
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3 4 Exhibit 1 before?
o S A.- I don't believe so.
6 O. ti r . Hansel, d id you bring any. documents 7 with you to this deposition?
8 A. Yes'.
, - e, 9 0 All right. And did you produ ce - th em at 10 the request of counsel based on an oral 11 description of what you should bring with you?-
l l 12 A. No.
13 0 All right. Did you bring any documents 14 at request of counsel?
15 A, No.
16 Q. I would like to ask you t o' read over 17 l'x h i b i t 1, piease, and tell me if you have 18 documents that are re spons iv e to that notice of 19 deposition and subpoena?
20 A. All that I have with me is revision 4 to 21 the Comanche Peak response team pr o g ra m plan and 22 certain a ppe nd i ce s .
23 O. And you brought tha t on you r own 24 volition?
25 A. Yes.
UNITED AMERICAN REPORTING SERVICEE, INC.
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I 6
1 0. All right. Thank you.
2 MS . GARDE: I would like to draw 3 the attention of the appli cants ' stipulation that 4 was entered into by Mr. Gad and myself th e end of 5 January, beginning of February, 1987, regarding 6 the production of documents.- I would like to make 7 it part of th e deposition.
8 1 intend to proceed, but in the event 9 that th e r e are documents that are referenced that 10 I believe should have been produced and were not 11 claimed to not have been produ ced , protective 12 order was sought. I will move later for those d
13 production.
14 MR. EGGELING: Could you read the 15 last of that back to me I let myself be 16 distracted. I apologisc.
17 (Record read ba ck ) .
18 MR. EGGELING: Perhaps, I wasn't 19 dist ra cted after all. I'm sorry, Ms. Garde, I 20 don't really understand. G iv e me a moment to read 21 the stipulation again.
22 MS. GARDE: Uh-huh.
23 MR. EGGELING: As I unde: Land it, 24 Ms. Garde, you are b a s i ca l l y noting that you 25 intend to rely upon the stipulation and its UNITED AMERICAN REPORTING SERVICES, INC.
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7 1 provision that you would not be precluded from 2 seeking to compel the production of any documents 3 which you maintain were probably responsive to th e 4 original notices and which you maintain have not 5 been~ produced.
6 MS. GARDE: Mr. Hansel said he 7 didn't b ri ng any documents to the deposition so 8 I'm going to have to rely on that. So if th a t 's 9 what you're asking; Yes. I disagree with how 10 you've prepared Mr. Hansel. By not having him 11 b ri ng depositions and by not having him rea d th e 12 notice of deposition and identify those documents 13 which were responsive. I anti cipa ted that Mr.
14 Hansel would have been prepared for this 15 deposition, would have gone through his files.
16 You would have made determinations on things that 17 you th ou g h t were under the scope of the issues and objections that you raised last f a l l. regarding 18 overly burdensome, protected, et cetera. I did 19 20 not expect to come to the deposition and find that 21 Mr. Hansel had brought nothing with him and hadn't 22 even read his notice of deposition. So I'm not going to wait for him to do that. I hope that he 23 24 has most of the answers in his head, but should he 25 have to rely on a document, and it wasn't UNITED AMERICAN REPORTING SERVICES, INC.
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8 1 protected, it isn't privileged, and it should have 2 been nere, then I'r going to have to go to the h>cw r d to move for its production. I will just 3
4 have to see how it goes.
MR. EGG EL ING : W el l , I think I 5
6 understand y ou , and I think all you are reflecting 7 is what was in the stipulation, and if tha t 's what If 8 you're reficcting, that's sa tisf a ctory to me.
9 you th i nk you're saying something that's beyond 10 the stipulation -
MS. GARDE: I just said th a t , Mr.
11 12 Eggeling. The stipulation does not excuse you from having your witnesses produce documents. It 13 14 does not excuse you from not preparing your 15 witnesses for the deposition. That is what I'm I want to proceed. Mr. Hansel, I'm sure, 16 saying.
17 he is going to be r e s pon s iv e , and I maybe don't 18 even need the documents, but at this point, I'm a 19 little taken back that he hasn't read th e notice 20 of deposition and he didn't bring any documents.
21 So I'm not saying simply what's in the 22 stipulation. That stipulation does not excuse you 23 from preparing him for deposition.
MR. EGGELING: Well, as I know of 24 .
25 no obligation to prepare him withir ^ the definition l
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"' < 1 you're trying to use -- again, I don't know what The. stipulation is the stipulation. We 2 Eto say.
intend to comply with it. We have complied with 3
I f you would like to mark it, that's fine.
4 it.
MS . GARDE: Yeah, would you mark 5
6 this as Exhibit 2, please?
7 (Deposition Exhibit No. 2 8 (was marked for i d e n t i f i ca t i on .
9 MS . GARDE: I would also like th i s 10 marked as Exhibit 3, an unsigned copy-of the 11 subpoena for Mr. Hansel.
12 (Deposition Exhibit No. 3 13 (was marked for iden t i f i ca tion .
(BY MS. GARDE) Mr. Hansel, have you 14 0.
15 ever seen the subpoena cither signed or unsigned?
16 A. When was this issued?
17 Q. Last fall.
18 A. I may have. It's been some time and I 19 vaguely recall it, but Thank you. All right. Mr. Hansel, I'm 20 0.
21 going to ask you questions regarding the CPRT 22 prog ra m plan, your involvement in it, how it 23 works, and the purpose of those questions is for 24 CASE to be able to ma ke a determination on the
'2 5 adequacy of the CPRT to resolve the questions on UNITED AMERICAN RE PO RTI NG SERVICES, INC.
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(214) 855-5300
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10 1 quality' assurance..
2 This is not a deposition which_is trying 3 to t r i ck y ou . I'm not trying to lead you astray.
4 I need information, and that's the purpose of-5 th i s .
If you don't understand'a question, if 6
7 my question is compli ca ted as my statement was 8 before, I apologize. I'm a little tired and I am 9 nursing a cold.
10 So please just ask me to restate the_ l 11 question. Don't try to rea ch to-understand th e 12 answer. If you want to talk to you r at torney, you 13 need to talk to him for any reason whatsoever, I 14 would ask th a t you finish the question th a t' you're Ib in the middle of and then you can go in the hall 16 or I will leave if you're the only ones in the 17 room.
18 You've had your deposition ta ken before, 19 haven't you?
20 A. yes.
21 Q. Do you have any questions on my 22 instructions?
23 A. No.
24 0. Now, Mr. Hansel, would you please state
- 25 for the record a brief statement of your UNITED AMERICAN REPOR,INGT SERVICES, INC. '
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-- 1 1 s 1 educational 1 background?
2 A.- I received a bachelor.of science degree 3 from Rawlins College, W in t e r , Park Florida with a 4 ma j or -in ma thema ti cs and science in'1965.
5 Prior to that time,_I had attended 6 I nd ia na S ta te Tea che rs College for approximately 7 two yea rs , where.I had extensive study in 8 ma th ema ti cs , physics and chemistry, and.somewhere 9 in the early or late 50's, I also attended 10 University of Cincinnati and studied el e ct ri ca l 11 engineering for a brief period. In 1971 I 12 received a master of science degree in systems 13 management from the Florida Institute of 14 Technology at Melbourne, Florida.
15 Q. Have you attended any professional 16 schools or received any professional ce rti f i ca te s 17 above and beyond your college a cademic background?
18 A. I'm a registered certified quality 19 engineer with the American Society for Qual.ity 20 Control and also a registered professional l
21 engineer in the state of California as a quality 22 engincor.
23 0. Is that th e only state you're registered 24 in?
. . I 25 A. Yes.
UNITED AMERICAN REPORTING SERVICES, INC.
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12 1 0. Now, in terms of you r employment 2 background, going back ten years, in the 3 mi d- 19 7 0 's , what were you doing?
A. In the mi d- 19 7 0 's -- well, let me 4
5 address that from the ea rly 7 0 's up until 1974, I 6 was -- at Cape Canaveral where I was the Director 7 of Quality Reliability and Systems Safety on the 8 Appollo space craft in the second stage of the 9 Saturn V missile.
10 '74 to '79 I was director of Qua l i t y 11 R el ia b il i t y and Safety for Rockwell International 12 on the spa ce shuttle O rb it e r vehicle.
13 0. Was that in Florida?
t 14 A. Palmdale, Calif ornia .
15 197 9 to ' 84 I was in Oakridge, Tennessee 16 cmployed by System D ev e l opme n t Corporation, and I 17 was project director of a support co n t ra c t to the 18 Department of Energy for the gas centrifuge 19 enrichment u ra n iura project.
20 From '7- - or ' 84 to the present, I 21 have been employed by ERC International, that's 22 Evaluation Research Corporation International.
23 O. Do you own ERC?
24 A. No.
25 O. Are you its president?
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m 13 1 A. I'm president of a subs id ia ry company of 2 ERC.
3 O. And what is that?
4 A. Systems Integration and Management 5 Corporation.
6 O. And how is ERC organized?
7 A. I don't know what you mean.
8 Q. Okay. You sa id you ' re pa r t of a 9 subs id ia ry. Is ERC like a parent co r po ra t i on ?
10 Are there other sub s i d ia ry companies?
11 A. ERC International is a holding company 12 organized into four groups and then within those 13 groups there are sub s i d ia ry companies.
14 Q. Okay. And is Systems International a 15 group or is it a sub-pa rt ?
16 A. A subsidiary.
17 O. Okay. And since you went to work for l 18 ERC, have you done other nuclear re-inspection l
l 19 p r o g ra m s other than your work at Comanche Pea k ?
20 A. Yes.
21 0 And was that at B ra dew ood ?
22 A. Yes.
23 O. Besides you r work at B ra dew ood , did you 24 work on any other re-inspection p rog rams ?
25 A. I did some effort at Bryon as an UNITED AMERICAN REPCRTING SERVICES, INC.
Emilasn Texas (214) 855-5300
14 1 independent consultant in - between j obs .
2 O. You mean between the breeder reactor and 3 when you went to work for Systems International 4 and Management Corporation?
5 A. It was not the b'reeder rea ctor.
6 O. All right.
There's a correction. Alould you restate-7 A.
8 your question, please?
9 0 Okay. I want to understand the time 10 period when you said in between jobs. I want to 11 understand between what jobs?
12 A. In between my employment with System 13 D ev e l op s..e n t Corporation and ERC International.
14 0. Okay. So Byron, B radewood and Comanche 15 Peak have been the only nuclear rea ctor projects 16 you've worked on?
17 A. No. I al so worked on Dia blo Canyon .
18 0. And did you work at Diablo Canyon in the 19 1980's?
20 A. Yes.
21 O. All right. And would you briefly q ll 22 describe what the work you did at D ia bl o Canyon 23 was?
24 . A. I was asked to conduct a review of their 25 hi s t or i cal OA/OC program and draw conclusions UNITED AMERICAN REPORTING SERVICES, INC.
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15 1 concerning its adequacy and'how it might have
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2 related to the quote, s o- ca l l e d , mirror image 3 problem, close quote.
4 There was one other project that I 5 worked on. I worked as a consultant to the Kemny-6 C'ommission on-Three M il e Island.
? Q. Have you ever worked for any other 8 cont ra ct or s in the nuclear industry?
9 A. No.
10 0. Who was your employer at B ra dewood ?
11 A. FRC International.
12 Q. And ERC's contract was with who?
13 A. Commonwealth Edison Company.
14 0. Was that the same for Byron?
15 A. Byron, I contracted with them directly.
16 Q. With Commonwealth Edison?
17 A. Yes.
1 IB Q. And was your contract --
l 19 A. Well, let me correct that.
20 That was with the attorneys.
21 C. So you were an expert?
22 A. Yes.
23 0. Okay. Did you testify in that 24 proceeding? -
25 A. Yes, on Byron.
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-1 0. On Diablo Canyon, did you work for the ,
2 con t ra ct or or the utility or Bechtcl?
3 A. Worked for the utility.
.4 0 TG&E7 5 A. Yes.
6 0 How did you first learn- of the potential 7 for a contract at Texas Utilities Comanche Pea k 8 plant?
9 A. I was contacted by J oh n Beck.
10 0. And when Mr. Beck contacted you, did be 11 -- well, strike that.
12 When was tha t contact made?
13 A. As best I can recall, it was just about 14 three yea rs ago this month, i
j 15 O. And when Mr. Beck contacted you, what 16 did he explain to you was the problem that he was 17 interested in you r se rv i ce s for?
18 A. His first contact was merely to ask me 19 to come down and meet with him to discuss Comanche 20 Pea k .
21 0 And did you do that?
22 A. Yes.
23 0. Did you come alone or were there others 24 from ERC that came with you?
25 A. I was alone.
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R I 17 l 1 0. - And when you met with him, was he 2 'alone? Or did you meet with others from Texas 3 Utilities?
4 A. There were others.
5 O. And do you . remember who they were?
6 A. Mr. Clements and Mr.-Fyker.
7 O. And what did they tell you?
8 A. They briefly explained to me what they 9 know at th a t time concerning the findings of the 10 NRC te chni ca l review team.
11 (Interruption).
12 MR. EGGELING: Go ahead and finish 13 the answer.
14 MS . GARDE: May we proceed?
15 MR. EGGELING: Yes.
16 O. (BY MS. GARDE) Would you p i ck up your 17 answer where you Icft off? Do you need me to 18 repea t the question?
19 A. If you would, please.
20 0. I'm asking you what th e y told you at the 21 meeting with them, your first meeting?
22 A. The discussion included what they knew 23 at th a t time concerning the findings of the NRC's
. 24 technical review team, a bit of history about the project in terms of schedule and prior 25 UNITED AMERICAN R E PO RT I N G SERVICES, INC.
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18' j 1 activities. As I recall, we al so discussed the 2 Comanche Peak response team as it stood at that. t 3 time-including information_as to how it was 4 organized and what evaluations or investigations 5 had been conducted up to that .?oint in time. ,
6 O. Did you review the CPRT that they were 7 telling you about? Did you review the document?
l 0 A. No. There were no documents sh ow n to me ;
t 9 on that pa rti cula r day , as I recall. i 10 0. Was it y ou r understanding that the CPRT 11 was operating at tha t time? That it was actually l l
12 a functional program? ;
13 A. I got the impression that it had been 14 formulated. It was still in the early stages'of 15 development, ,
16 Q. And how long a meeting was that?
17 A. I would estimate two and a half to three 18 hours. I flew in and out th e same day so it ,
i 19 wasn't too long of a meeting. ;
f 20 Q. Did you go to the plant at tha t meeting?
I 21 A. No. i i
22 0. A t' the end of that meeting, did they i 23 offer you employment to work on the CPRT pr og ra m l f
I 24 plan? !
l t 25 A. No talked about it, and I ind i ca ted that i t
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,3 19 1 I wanted to.know more about the program and meet 2 some.of the people, read some of the documentation.
3 before I made a commitment.
4 -0. And did you take that next step?
5 A. Yes.
6 O. And when was that?
A. I don't recall exactly. It would have 7
8 been early November, la te October or early 9 November of '84.
10 O. And you came back down to Texas?
11 A. Yes.
12 O. And at th a t time you were located in 13 Virginia?
14 A. Yes.
15 O. And when you came back down in late 16 O ctober or early November, did you go to the 17 Comanche Peak site?
18 A. Yes.
! 19 0. And how long were you there?
20 A. Again, I don't recall exactly, but it 21 seemed to me like it was probably three or four 22 days.
23 O. And at that time did you review what was l
24 in existence as the CPRT program plan?
25 A. Yes.
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~20 1 Q. And did you ment with individual s who 2 :were working with the pro g ra m plan?
3 A. Yes.
4 0. And you met with Mr. Beck again?
5 A. I don't believe that Mr. Beck was at the 6 site that week.
7 Q. Did you meet with Mr. Ron Tolson?
8 A. I believe so.
9 O. .Did you meet with Mr. Tony Vega?
10 A. Yes.
11 O. Did you meet with Dick Camp?
12 A. No.
13 Q. Did you meet with Mr. Tom B ra nd t ?
14 A. I believe so, but I'm not certain.
15 C. Do you remember any of the other 16 ind iv idual s that you met with at th e site?
17 A. Mr. Clements was there, J oh n M e r r i t t .
18 O. Mr. David Chapman?
19 A. No.
20 Q. John Finneran?
21 A. No.
22 0. Did you meet with anyone from the design 23 area?
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- A. I don't think so. I don't recall anyone 25 in the design section -- of course,'I didn't UNITTD AMERICAN REPORTING SERVICES, INC.
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21 1 really -- it was a new organization and I didn't 2 really know who all the players were and where 3 they fit, but those names I knew who they are now,
,' 4 and I don't recall meeting with anybody from the 5 design side.
6 O. Did you meet with anyone from CYGNA?
7 A. No.
8 Q. Now, while you were at the site -- on your first trip to the site what -- what did you 9
10 review? What did you look at?
11 A. I reviewed the organizational chart for 12 th e CPRT.
13 0. And do you know what revision that was?
, 14 A. No. I reviewed the program pla n tha t 15 was in existence at that time.
16 Q. And you don't know what revision that 17 was either?
18 A. No, but I suspect it was the first one.
MR. EGCELING: I don't want you to 19 20 guess. Answer only if you know.
21 MS , GARDE: Just a moment.
22 Counsel, I would like to show the witness a copy 9
23 of Rev. O which is dated October 8th, 1984. It 4
- 24. has a few markings from me on a page or two. I 25 don't know if you will object to that. I don't --
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1 they're probably indecipherable -- and ask if this-was the plan that he looked-at. I'm going to let 2
3 your. lawyer look at it first. ,
MR. EGGELING: Ms. Garde, I'm no 4
5 more abic to certify that every word or ph rase in 6 here is, in fact, Rev. O, than the witness be. If 7 you could tell me what you propose to do with this 8 and how you propose to memorialize it, I am sure 9 we can work something out.
10 MS. GARDE: I would like to direct his attention to the O chart which you just [
11 :
12 flipped past and ask if that was the O chart that was in pla c e that he just referred to. And if ;
13 .
4 14 those were the people that he recalled reviewing.
15 That's the only document -- ,
16 !!R . EGGELING: You want to show him ,
17 this specif ic piece of paper? ,
18 MS. GARDE: But I want him to know i 19 and y ou to know tha t it came from this revision ;
c 20 which is Rev. O. ;
} t 21 MR. EGGELING: Why don't we plan to 22 mark what it is and have that made a copy, and we ;
won't have to worry about whether, in f a ct, it is .
23 24 Rev. O.
?
! 25 MS. GARDE: That's fine.
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23 1 MR. EGGELING: I'm sure it is. I 2 don't distrust you r representation, but since I 3 have no way to check it, I want this to be simple, 4
MS, GARDE: Mr. Hansel, I would 5 like to have y ou look over this document.
6 MR. EGGELING: You want to have the 7 reporter put a sticker and it all and pull it 8 out?
9 MS . GARDE: Yeah.
10 (Deposition Exhibit No. 4 11 (was marked for i den t i f i ca t ion.
12 O. (B Y MS . GARDE) I t's been ma rked as 13 Exhibit 4 to the deposition, and ask if this is 14 the o cha rt that you just made reference to that 15 you remember reviewing?
16 A. It's been sometime, but it -
it 17 certainly appears to be what I can best recall 18 from that meeting to say; Yes.
19 MR. EGGELING: Ms. Garde does not want you to guess about answers. If you recall 20 what it is, be sure and tell her. If you don't 21 22 recall, tell her that. These are either/or 23 questions.
MS. GARDE: Okay. With the 24 qualifiers in you r answer, I'm going to put this 25 UNITED AMERICAN REPORTING SERVICES, INC.
a' '," *nvac (714) R55-5300
24 1 in your deposition. I-will- represent for the 2 record that it came from my copy of Rev. O of the 3 pro g ram plan dated october 8th, 1984, wh i ch I 4 received from Texas Utilities.
5 !!R . EGGELING: And just'so it's-6 clear, I have no way of confirming or disputing 7 that, but I'm sure Ms. Garde is representing 8 accurately her understanding. If at some point, 9 its genesis becomes material, we'll worry about 10 th a t th e n .
11 0. (B Y MS . GARDE) All right. tiow , besides 12 reviewing the documents and meeting with the 13 ind iv idu al s that you've named, did you meet with 14 other ind iv idu al s on that trip?
15 A. I met other people. I don't re call any 16 what you might classify as a meeting.
17 0. okay. And in reviewing the documents, 18 did you review other documents besides the pro g ra m 19 plan that you were provided with?
20 A. Yes.
21 0. And do you remember wl.a t th o s e documents 22 were?
23 A. As best I can r v .:a there was a July 24 letter from the NRC that cov- led some of th e i r 25 f i nd ing s .
UNITFD AMERICAN REPORTING SERVICES, INC.
Dallas. Texas (214! P5 5-53 00
25- j t
1 Q. Do you recall if that was the report of ,
s 2 th e specia). review team. signed letter, signed by ,
3 Mrs. Ippolito? ;
4 A. I don't recall.
5 'O. Okay. Was it more than a regular l 6 inspection report tha t you reviewed? f 7 A. What do you mean by inspection report? i
< 8 Q. You're familiar with regular NRC i
~
9 inspection reports?
t 10 A. Yes.
11 Q. Okay. Was the report that you reviewed f
12 a regular NRC inspection report?
13 A. No. ;
14 Q. And wha t other documents did you review?
15 A. I don't recall specifically. !
i 16 Q. Were you provided a copy of any ,
I 17 documents from IN PC the site?
i 18 A. No. ,
t 19 Q. Were you provided copies of the audit or
- 20 any audits by the management analysis company?
i
)
21 A. No.
I 22 Q. Were you provided or did you review r
, 23 audits of any other type by outside of TUEC j 24 auditors?
l i 25 A. No. ;
- l. i l l I !
UNITED AMERICAN REPORTING SERVICES, INC. f Dallas. Texas (214) 855-5300 l
26 1 O. Did you review a document entitled the 2 L obb i r. Report?
4
- 3 A. No.
4 0. Did you review the NCR log?
i l 5 A. No.
6 0. Did you review any trending analysis?
a 7 A. No.
8 Q. Did you review any other NRC inspection
'l 9 reports?
)
10 A. No.
11 MR. EGGELING: Other than what?
5 12 MS . GARDE: Thank you for that 13 cla ri f i ca t ion.
14 Q. Did you review any-regular NRC 1
15 inspection reports other than the one you've just
! 16 identified that you reviewed?
l i 17 A. No.
18 0. Did you review copies of any of the i
19 Atomic Safety and L i ce n s in g Boa rd de cisions i
20 re g a r d in g Comancho Peak?
f 21 A. No.
l 22 0. S pe cif icall y , did you review the 23 December 1983 decision of the board on quality 24 asturance for design issues?
I i 25 A. No.
UNITED AMERICAN REPORTING SERVICES, INC.
"*11a* Tavan (214) 855-5300
i.
27 4 1 Q. Did you review any. documents regarding l
'I 2 th e harrassment and intimidation docket?
3 A. No. i 4 0. Did you review any of the prepared j 5 testimony or delivered testimony of any individual l
- 6 in regards to the licensing hearings?
i 7 A. No. !
1 8 0. Did you do a walk-down of th e site? Did
,! 9 you do any inspections, walk-down inspections? ,
10 A. I did not do an inspection. I took a 4
t
- 11 tour of th e f a cility.
12 0. And during that tour of th e f a cility,
', 13 did you identify any conditions that_you ,
s considered to be non-conforming co nd i t i o n s under j
'4 t
15 your understanding of the NRC regulations? '
i ,
16 A. No. ,
i i 17 C. And did you have a tour guide for that ,
4 4
18 tour?
1 4
19 A. Yes.
L Who was that?
20 Q.
i 4 21 A. I believe it was John Merritt and one of !
22 his people who I can't recall.
1
].
23 0. Now after -- strike that.
i 24 other than, reviewing the docecents and i I
1 -
25 talhing to the ind iv idual s that you've identified,
' I i
4 4
t ,
l (
~ SERVICES, INC. l l UNITED AMERICAN REPORTING !
Dallac, Texas (214) 855-5300 !
28 1 others whose names you don't remember, what else<
2 did you do during those three days in your 3 overview of ti' e Comanche Pea k site?
4 A. 'tha t 's a bou t it.
5 O. During that visit, did you make a 6 decision on whether or not you would proceed to >
7 assist Texas Utilities with Comanche Pea k ?
8 A. Yes.
9 Q. And you informed Texas Utilities 10 of ficials of that?
11 A. Yes.
12 O. And who did you inform?
13 A. It was Mr. Cicments and the cont ra ct .
14 personnel.
15 Q. Was a cont ra ct entered into during that 16 trip between you rs el f and Texas Utilities?
17 A. Yes.
18 O. And did it define the scope of your 19 duties?
20 A. At tna t time, yes.
21 O. And could you briefly state what they 22 were, to the best of you r recollection?
23 A. I believe, and it's been some time, that ,
24 I was asked if I would be the review team leader 25 for QA/OC and to assume responsibility for, issue UNITED A"ERICAN REPORTING SERVICES, INC,
- "ae Tavan (214) 855-5300
29 1 specif ic action plan 1D1 and 1D2.
2 0. And the scope of the cont ra ct was 3 limited to-the level of involvement that you've 4 just described?
5 .A. Yes.
6 0. Okay. Now --
7 A. As best I can recall.
8 0. Uh-huh. How soon after that trip to 9 Comanche Peak did you, in f a ct, assign another i
10 employee besides you rs el f from ERC to start 11 working on Comanche Pea k ?
i' 12 A. As I recall, it was late November or 13 very early December.
14 0. And who was that person?
15 A. Jim Young.
16 0. Was that th e only one or did you add 17 more than one person at tha t time?
18 A. He was the first one to join ce and then 19 we added others as required.
20 0, okay. After the addition of Mr. Young.
21 how soon after that assignment did other 22 ind iv idu al s start to come onto your project?
- 3 A. It was mid to late December,
, 24 0 11 ow , following the visit at which you 25 entered into the first cont r a ct with Texas i
i UllITED AMERICA!J R E PC RT I t'G SERVICES. I ll C .
n '$-- mavne (7141 955-5100
p:_; --
30~
1 Utilities'regarding thel CPRT, how soon after that 2 time period did the contract expand in scope?.
3 MR.;EGGELING: Let me j us t - first: --
'4 first cont ra ct ?
5 MS. GARDE: Right.
6 MR. EGGELING: Assuming there was 7 more than one?
8 MS . GARDE: I'm assuming there's 9 more than.one. I'm assuming the scope has-10 expanded.
11 MR. EGGELING: Which might or might 12 not be another contract. Let me get it cl ea r .
13 You haven't asked whether there was more than one 14 con tra ct .
s 15 MS. GARDE: Let me go back.
16 Q. (BY MS. GARDE) You entered into a
~7 con t ra ct with Texas Utilities during the trip that 18 you just described?
19 A. Yes.
20 Q. Did there come a time when that cont ra ct 21 was amended?
22 A. Yes.
l 23 Q. Okay. And was it expanded?
i l 24 A. Yes, i
l-25 Q. Hov soon after the first co n t ra ct th a t l
UNITED AMERICAN REPORTING SERVICES, INC.
Dallac, Texas (214) 855-5300
+
3 31 1 you entered into was there a change or an 2 amendment to that cont ra ct ?
3 A. I'm not totally positive, but.I.believe 4 it was in February of '85.
5 O. Now, between November of '84 and 6 Feb rua ry of '85, was there any other co n t ra ct s 7 that you were doing work under other than the one 8 that you have described? Was there any-second 9 cont ra ct ?
10 MR. EGGELING: With TU or Comanche 11 Pea k ?
12 MS. GARDE: W ith TU.
13 MR. EGGELING: Not --
4 14 MS. GARDE: Regarding Comanche 15 Pea k .
16 A. Not with Comanche Peak, no.
17 0. So all -
18 A. Let me correct that.
19 O. Okay.
20 A. S till under the same cont ra ct , we were 21 asked to do some other small amount of inspection 22 work on s o m e' cable tray hangers.
23 Q. And th a t was an amendment to the first 24 cont ra ct 7 A. There was no of f i cial amendment. We 25 UNITED AMERICAN REPORTING SERVICES, INC.
Dallas, Texas (214) 855-5300
32 1 just were asked to.do it --
provide some 2 inspectors.
3 0. Did th e firs t cont ra ct incorporate a ra te of-pay for inspectors so that the re was it 4
5 wasn't ne ce s sa ry to e x p c .i d the contra ct ?
6 A. I don't re ca l l .
7 Q. Okay. Now, on.the'first co nt ra ct -
8 between the la te November '84 and February '85, 9 did you enter into a contract with B row n & Root.
10 regarding Comanche Pea k ?
11 A. No.
12 Q. Did you enter into a contract with S tone 13 & Webster re ga r d in g Comanche Peak?
14 A. No.
15 0 All the work y ou were doing at Comanche 16 Peak was covered under the contract th a t you've 17 just' discussed?
18 A. Yes.
19 0 All right. Were you hired at the . time 20 as an expert witness for the licensing proceeding?
21 A. No.
22 Q. Now, in February of 1985 was the 23 co nt ra ct expanded?
24 A. Yes.
~
25 O. Was there an entirely new contract UNITED AMERICAN REPORTING SERVI 6sS, INC.
. _ _ . _ _ ._ __ ._. nallas Teyan (214) 65S-5300
. ~ . .
. . . = =
' 33' l . written? or was it an expansion of th e old.one, 2 the first one?
3 A. An expansion.
4 Q. And what was the scope of the work 5 an t i cipa ted under the expanded' contract?
6 A. I don't recall the specifics, but we had 7 expanded th e number of issue specif ic action plans 8 and it included th o s e .
9 Q. Included what? .
10 7o The new action plans that were 11 identified ea rly 1985.
12 Q. Did you write th e new ISAPS?
13 A. I pa r t i cipa ted in their writing, yes.
14 Q. Did you have anything -to -do with DS A PS ?
15 A. No. i 16 Q. Who was the author of the IS A PS , the new 17 ISAPS that you were working to?
18 A. ISAPS?
19 O. IS APS .
20 A. ISAPS. Either myself or the issue 21 coordinator who we had assigned to them.
22 Q. Did you participate in rewriting the 23 first CPRT program plan? ?
_24 A. No.
25 O. Do you know who wrote th e c o c o t.d version
~'
UNITED AMERICAN REPORTING SERVICES, INC.
. - - - -- "-M ar_Savaf. . , I?14) 955-5300 __,,
34
, 1 of th e CPRT?
2 A. No. I suspect'--
3 MR. EGGELING: No.
MS. GARDE: Don't tell me what you 4
5 suspect.
6 tiR . EGGELING: She-doesn't want 7 suspicion. She wants to know what you know.
8 Q. (BY MS. GARDE) Did you provide any 9 input into the preparation of th e second revision 10 of the CPRT? S trike that.
11 Mr. Hansel, is it your understanding 12 that the first issued revision of th e CPRT i s ,
13 Rev. 07 14 A. I don't know that specifically.
15 O. Okay.
!!S . GARDE: Because of the way the 16 17 revisions are numbered, counsel, I'm going to try 18 real -- very precisely to ma ke a proper reference to the correct revision, as I understand it. If 19 20 y ou r witness or you do not understand which 21 version I'm referring to, please ask me to clarify 22 tha t .
MR. EGGELING: I will certainly 23 24 endeavor to do so, thank you.
MS. GARDE: All right.
25 UNITED AMERICAN R E PO R.T I NG SERVICES, INC.
g nallan. Texas m n (214) 855-5300 m- --
av -
'35 1 Q. (3Y MS, GARDEl- -The change to'the CPRT 2 tha t - came after Rev. O o r ' t h' e first- issuance of 3 the CPRT, you ' re telling me you didn't write that 4 change; isn't th a t correct?
'S A. Correct.
6 Q. And you did not pa r t i cipa te in the 7 preparation of th a t revision; is that correct?
8 A. Correct.
9 Q. Were you consulted about the preparation 10 of 'tha t revision?
11 A. Yes.
12 Q. And who co n sul te d you about th e 13 preparation of th a t revision?
14 A. Members of the senior review team.
15 Q. Mr. Beck?
16 A. I don't recall spe cif i ca l l y .
17 Q. Were you asked by members of the CPRT 18 review team whether or not you had an opinion on 19 the removal of certain management of ficial s that i 20 were cu r r en t ly review team leaders?
21 MR. EGGELING: S top a minute.
22 MS . GARDE: It's a "yes" or "no" 23 question.
l
. 24 MR. EGGELING: I understand, but I 25 th i nk if you get the question back you may sec l
l c
UNITED AMERICAN REPORTING SERVICES, INC.
Dallas, Texas (214) 855-5300
36 1 that you misspoke.
2 MS. GARDE: Let me try again. I r
3 don't want to confuse you.
4 MR. EGGELING: You asked something 5 about th e CPRT review team. I'm not sure what you 6 were talking about.
7 MS. GARDE: I meant the SRT.
8 MR. EGGELING: I thought so.
9 MS. GARDE: All right.
10 C. ( B Y MS . GARDE) Were you asked by the 11 SRT on whether you had an opinion on the removal 12 of certain individuals who were currently review 13 team leaders?
14 A. No.
15 O. You were not asked that?
16 A. No.
17 C. What'were you asked about?
18 MR. EGGELING: You're assuming he 19 was asked something.
20 MS. GARDE: I asked if he was 21 con sul te d . He said; Yes.
22 MR. EGGELING: He sa id consulted.
23 He didn't say asked. I just want to be sure I 24 understand the foundation of y ou r -- what you were 25 referring to.
UNITED AMERICAN REPORTING SERVICES, INC.
Dallas, Texas (214) 855-5300
37 E' i i:
1 THE WITNESS: When -- I would like
. 2 to ask a point of clarification. When was the 3 next revision released?
4 MS . GARDE: W ell .
5 MR. EGGELING: A specific date?
s 6 THE WITNES S : Approximate time 7 frame.
8 MS. GARDE: Off the record.
9 (Off the record discussion).
10 MS. GARDE: Back on th e record.
11 MR. EGGELING: Yes. There was a 12 question pending. Mrs. Hansel, would you like to 13 have it read back?
14 THE WITNESS: Please.
15 MS. GARDE: Can you read the last 16 question, David?
17 (Record read back).
18 A. Without knowing which revision and what 19 date, I don't -- I ca n ' t help you.
20 Q. All right. Mr. Hansel, let me d ra w y ou r 21 attention to January 8th, 1985. Do you recall the 22 NRC issuing a letter to Texas Utilities regarding 23 utility assurance problems at the plant?
24 A. Yes.
25 O. Okay. The time of your meeting with the UNITED AMERICAN REPORTING SERVICES, INC.
Dallas, Texas (214) 855-5300
a 38
. -1 SRT that'I'm trying to. inquire about, had that 2 letter been' issued?
3 A. I don't re ca l l .
4 0. S o y ou don't know if it was before or 5 after that letter?
6 A. No.
7 Q. All right. How did.you learn that the 8 January 8th letter had been issued?
9 A. I was g iv e n a ~ copy.
10 Q. By who?
11 A. I don't recall.
12 Q. Were you at a meeting at the Nuclear 13 R egu l a to ry Commission several weeks later, I 14 believe January 14 th or 15th, regarding that 15 letter?
16 A. I believe so.
17 Q. At the time that the January 8th, 1985 18 NaC letter came to you r attention, did you have 19 further discussions with Texas Utilities regarding 20 the scope of the work that ERC was doing at th e 21 site?
22 A. Yes.
23 O. Okay. Who did you talk to?
i l ,
24 A. I don't re call specifically.
l 25 O. When the con t ra c t was amended in UNITED AMERICAN REPORTING SERVICES, INC.
Dallas, Texas (214) 855-5300
. 39 1 . February of 1985 between Texas Utilities and ERC, 2 did it. include rewriting the CPRT pro g ra m plan to 3 be responsive to th e January 8th, 1985 NRC letter?
4 A. No.
5 O. Did it make reference in any way to 6 being responsive to the January-8th, 1985 NRC 7 letter?
8 A. I don't recall.
9 Q. What did it expand you r du ties to 10 include?
11 A. New IS APS were identified as a result of 12 the January 8th letter and some of th os e were 13 placed under my re s pon s ib il i ty .
14 O. The new IS APS tha t you're referring to, 15 was one of them 7 C?
16 A. No.
17 0. After January --
Feb rua ry 1985 and the 18 expansion of the con t ra ct which included 19 additional IS APS , when was the next change in your i
i
! 20 con t ra ct ?
A. I don't recall exactly.
21 22 Q. Do you recall specific ch a n g e s in your l
23 contract to deal with IS A P 7C?
l l 24 A. No.
25 O. At what point did 7C become part of you r l
UNITED AMERICAN REPCRTING SERVICES, INC.
Dallas, Texas (214) 855-5300
q h, 40 1 duties?
2 A. When it was first released..
3 Q. Do you remember when that was?
4 A. No.
5 O. Did you write it?
6 A. A major portion of it.
7 Q. Did you write the changes in the CPRT 8 itself that in cl ud ed discussing the expansion of 9 the CPRT to include 7C?
10 MR. E Gr. EL ING : Did he write some 11 sort of changes to a CPRT p r og ra m?
12 MS. GARDE: The CPRT itself. The 13 p r o g ra m plan itself, right.
14 MR. EGGELING: I understand.
15 MS . GARDE: I was asking him if he 16 wrote 7 C. He wrote 7C. I wanted to know if he 17 wrote the prog ra m plan also, the changes in the 18 program plan.
19 A. I ascisted and pa r ti cipa ted in that.
20 Q. And who did you assist in doing that?
21 A. The senior review team.
22 Q. And who on the senior review team had 23 re s pon s ib il i t y for preparation of the new CPRT 24 p ro g ra m plan?
25 A. It was a collective effort.
UNITED AMERICAN REPORTING SERVICES, INC.
Dallas, Texas (214) 855-5300
+
41:
1 O. Did it have a -principal author?
2 A. No.
3 Q. In wha t way were you included in the 4 development of the CPRT p ro g ra m plan?
5 MR. EGGELING: You're talking this 6 specific revision --
. 7 MS. GARDE: This revision.
8 MR. EGGELING: --
of th e program 9 plan that included --
10 MS. GARDE: 7C.
11 MR. EGGELING: --
7C as a new b
12 ISAP?
13 MS . GARDE: Uh-huh.
i 14 A. In various meetings and discussions to 15 formulate the plan and the methodology.
16 O. Plan and methodology for what?
! 17 A. For the Comanche Peak response team 18 p ro g ra m plan.
i 19 Q. Okay. Your answer isn't sp e c i f i cal ly 20 going b a ck to 7 C.
21 A. No, because 7 C is one piece of the total 22 program plan.
l 23 Q. Mr. Hansel, I assume --
I understand l
I, 24 from you r testimony that up until the work on the 25 p rog ra m plan that included 7C, you did not assist UNITED AMERICAN REPORTING SERVICES, INC.
Dallas, Texas (214) 855-5300
42 1 or pa r ti cipa te in the development of any earlier 2 revisions-of the CPRT, is that a correct 3 understanding of your testimony?
4 A. Yes.
5 0. When you refer to IS AP 7C, are you 6 including the quality of construction prog ra m in 7 its entirety?
8 A. As defined by the released pr o g ra m plan, 9 yes.
10 Q. I'm referring to the program plan at th e 11 time, so the quality of construction program was 12 covered in its entirety by 7C at the --
when 7C 13 was first issued; is that correct?
14 MR. EGGELING: Is this a question 15 about what th e document says? Or a question about 16 what his role was? I think you've lost me here in 17 terms of what we're trying to tie down.
18 MS. GARDE: I want to understand in 19 the ea rl y stages of 7C if there was an y th ing other 20 than 7 C that was referred to or known as the 21 quality of construction p r o g ra m . Or if, when I 22 read 7C, I'm reading the entirety of th e effort he 23 was involved in.
24 MR. SGGELING: The question is; 25 Does 7C, as written at tha t time, reflect UNITED AMERICAN REPORTING SERVICES, INC.
Dallas, Texas (214) 855-5300 2
43 1 everything he'was doing at th a t time in that area.
2 MS. GARDE: In the qu'ality of
.3 construction pro g ra m .
4 MR. EGGELING: The assumption.about 5 a quality of cons truction program is that th e re is 6 some p ro g ra m independent of 7C. You keep calling 7 it th e program as though it had --
that's not 8 quite what th e assumption is.
9 MS. GARDE: No, that question isn't 10 --
that assumption is not suppose to be included 11 in the question.
12 MR. EGGELING: That's what I 13 thought.
14 MS. GARDE: Okay. Let me start 15 with quality of construction.
16 0. (BY MS. GARDE) What is the quality of 17 construction program?
18 A. ISAP 7C.
19 0. Okay. Is the quality of construction 20 p ro g ra m completely bounded by 7 C?
21 A. Yes, as defined by the pro g ra m plan.
22 0. Thank you. Now, following the issuance 23 of the revision that included 7C, did you have 24 another expansion of you r co n t'r a c t with TUEC?
25 A. I don't recall.
UNITED AMERICAN REPORTING SERVICES, I N C ,.
Dallas, Texas (214) 855-5300
44 1 0. How many people did you have working at 2 the plant in April of 1985?
3 A. I don't re call .
4 Q. I don't want you to guess, but I would 5 ~1ike to know if we're talking about more than 6 three or less than 100?
7 MR. EGGELING: Is your question 8 confined to people on site or people working on 9 the --
10 MS. GARDE: People working on 11 Comanche Peak whether in the Virginia office, any 12 other office or the site.
13 A. It's more than three and less than 100.
14 0. We're going to be here a long time, i 15 All right. Is it more than 70 and less 16 than 100?
l 17 A. I don't re call .
18 0 You just don't have any idea?
l 19 A. You want me to estimate?
20 MR. EGGELING: No, she wants to 21 know what you know.
l 22 A. I really don't recall.
l l ;; Q. How many people do you have there now?
24 MR. EGGELING: There, being the 25 same question, any location?
UNITED AMERICAN REPORTING SERVICES, INC.
Dallas, Texas (214) 855-5300
45 1 MS. GARDE: Any loca tion working on 2 Comanche Peak.
3 A. There's approximately 100.
4 Q. Is now, at th i s time, the most people 5 you 've ever had working on Comanche Peak?
6 ~A. No.
7 Q. At the height, do you know how many 8 people you had working at Comanche Peak, at the 9 height of your personnel -- w..ployees?
10 A. Yes.
11 Q. What was that?
I 12 A. It was approx ima tely 320.
13 Q. All right. And when win that?
4 14 A. Let's see, the early spring of '87.
15 Q. Does the quality of construction pro g ra m 16 --
strike that.
17 Did the quality of construction p ro g ra m ,
18 7 C, itself get revised?
19 A. I don't believe it's ever been revised, l
t 20 but I'm not positive.
21 Q. All right. And the quality of 22 construction p ro g ra m incorporates numerous 23 specific inspection procedures, doesn't it?
24 A. Yes.
25 Q. And those are referred to as quality UNITED AMERICAN REPORTING SERVICES, INC.
Dallas, Texas (214) 855-5300
4 46 1 instructions?
2 A. Yes.
3 Q. Or CPP's; is that correct?
4 A.- 'You asked about inspection pr'ocddures?
5 Q. Yes.
6 A. They are quality instructions.
7 Q. Yes, okay. And then there also are 8 CPP's?
9 A. Yes.
10 Q. CPP's?
11 A. Yes.
12 Q. Is that correct?
13 And they're pa r t of the quality of 14 construction p ro g ra m , are they not?
15 A. Yes.
16 Q. Okay. And have either the CPP's or the 17 OI's been revised after the quality of 18 construction program was finalized?
19 A. What do you mean "finalized"?
20 Q. I asked you if th e quality of i '
l 21 construction p ro g ra m has boon revised. You said l
22 you didn't believe that it had been revised. Now, l
23 I'm asking you if its components, the quality 1 .
24 instructions and the CPP's have been revised?
I 25 A. Yes.
l UNITED AMERICAN REPORTING SERVICES, INC.
Dallas, Texas (214) 855-5300
m ._
t .
47 1 Q. To the best of your knowledge, has CASE 2 been provided with copies of all of th o s e 3 revisions?
4 A. I believe so.
5 Q. What is the purpose of the quality 6 construction aspect of the CPRT?
7 A. I would refer you back to the program 8 plan.
9 Q. Which pr o g ra m plan?
10 A. The Comanche Pea k response team program 11 plan.
12 Q. Okay. Any special revision?
13 A. Any revision that has been --
where it 14 has been included, the --
we've made ce r ta i n tha t 15 any th ing we've done has been included throughout 16 all revisions.
17 Q. Does the quality of construction p ro g ra m 18 intend to make a statement on whether or not all
- 19 deficiencies at the plant have been identified?
20 A. No.
21 Q. Does the quality of construction p ro g ra m 22 intend to make a statement on whether all 23 deficiencies at th e plant have been corrected?
24 -
A. No.
25 Q. Does the quality of construction program UNITED AMERICAN REPORTING SERVICES, INC.
Dellas, Texas (214) 855-5300
' f, 48 1 intend to make a statement on whether all 2 deficiencies ider.tified by or th rou gh the q u a l'i t y 3 of construction program'have been corrected?
4 You look confused? You want me to go-5 back?
6 A. No.
7 0. Do you understand my question?
8 MR. EGGELING: Pardon me.
9 THE WITNESS: Yeah, off the 10 record.
11 (Conference).
l
, 12 MR. EGGELING: Let's hear the 13 question back.
14 (Record read back).
15 MR. EGGELING: If I understand it 16 right, the witness isn't following whether you are 17 continuing to confine you r ques tion to-the 18 boundaries of 7 C.
19 MS. GARDE: At this time I am.
20 MR. EGGELING: As opposed to the 21 p r o g ra m plan in general and the various tendencies l 22 of the other things th a t will eval ua te and 23 inte g ra te all the findings and conclusions.
24 MS. CARDE: If my --
my question is l . 25 bounded within 7C at this time. Okay. If it's l
{
\
UNITED AMERICAN REPORTING SERVICES, INC.
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49 1 not possible to answer the question without having 2 me expand th a t scope, I will do that.
3 MR. EGGELING: If the question is; p
4 when --
5 MS . GARDE: All the identified --
6 MR. EGGELING: -- when 7C, when 7C 7 results are published, will it contain the 8 statement you have described. I think he can 9 answer that question. Is that right?
10 MS. GARDE: W ell --
11 THE WITNESS: Depends on what she 1
j 12 means by " co r r e c t e d " .
13 MS. GARDE: Okay. Let me go back
[ 14 because I didn't ask him about results before so 15 I'm separating tha t. Let me go back.
16 Q. (BY MS . GARDE) Within the quality of 17 construction program itself, inspections and 18 reviews are being done, aren't they?
19 A. Yes.
l L 20 Q. And those inspections or document l
l 21 reviews are producing deficiency paper, are they l
l 22 not?
23 NR. EGGELING: Is th a t going to be i
24 you r def ined term or his? L e t s find out '
l l 25 MS. GARDE: Okay. He was ready to i
UNITED AMERICAN R E PO R.T I NG SERVICES, INC. ~
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-50 1 answer that question and_ycu didn't object. I 2 don'.t want to confuse him. If he has --
3 MR. EGGELING: He may be unaware 4 that th e lawyers have significant' differences of 5 opinion about what deficiency paper means. I want 6 you to define what it means, so we're sure that 7 his answer means whatever it means, or let him 8 define it, I don't ca re wh i ch .
9 MS. GARDE: My question goes to the' -
10 deficiency forms that you -- or ERC deviation 11 deficiency forms. I'm not sure what they are 12 called --
singic sheets.
13 MR. EGGELING: You define what 14 you're talking about.
15 A. Inspections and reviews produced 16 deviation reports.
17 Q. All right.
18 A. Some of th o s e may become construction 19 deficiencies in accordance with Appendix E of th e
- 20 pr o g ra m plan.
21 Q. Right. And you also --
you, I mean your 22 people, also identify out of scope observations;
, 23 isn't th a t correct?
I ,
24 A. Yes.
25 Q. All right. At the time that 7C is l
l UNITED AMERICAN REPORTING SERVICES, INC.
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L 51 1 finished, will those obser- --
ou t of scope 2 observations, deficiencies and deviations all be 3 resolved?
4 A. What do you mean by "resolved"?
5 Q. W il l you have a piece of paper in your 6 file that closes out tha t concern?
7 A. We will have in our files copies of all 8 the deviations, deficiencies and out of scope 9 observations. We also have information concerning 10 or identifying what NCR's by number were prepared 11 by the project for those conditions. Where we 12 have construction deficiencies or adverse trends 13 or unclassified trends or unclassified deviations 14 that resulted from a review of those deviations in 15 accordance with Appendix E, we will have throuah 16 the CPRT records identif ica tion of wha t actions 17 the project plans to take.
18 Q. Will you, ERC, perform follow-up
{ 19 inspections or audits to determine whether the i
i 20 project, in f a ct, resolved the defi iency, 21 deviation or out of scope ob s erva tion ?
22 MR. EGGELING: In each and every 23 case?
24 MS . GARDE: In ea ch and every cape.
25 A. The requirements for overviewing the UNITED AMERICAN REPORTING SERVICES, INC.
Dallas, Texas (214) 855-5300
52 1 project corrective actions as identified in 2 revision 4 of the program plan, and I think 3 spe cif i ca ll y , in Appendix H, but don't hold me to 4 that.
5 O. Okay. Tha t may have answered my 6 question. I won't know unless I look at Appendix 7 H.
8 (Off the record discussion).
9 Q. (BY MS. GARDE) My question to you at 10 this point goes to the inspections or audits of 11 the Texas Utilities corrective a ction. Okay.
12 You've referred me to revision 4, possibly 13 Appendix H. All right. I want to know from your 14 own knowledge of the plan, okay, what you know 15 right now, what follow th rough is rRC going to do?
16 A. Off the record, 17 (Conference).
18 A. Appendix --
revision 4 of the program 19 plan and Appendix H assigns a responsibility for 20 determining the type of overview or over 21 inspection or audits to the CPRT project director, 22 and he determines the approach to be ta ken . We 23 provide personnel resources to him to accomplish 24 that ta s k . And that process is ca l l e d out in 25 revision 4 of t'h o program plan and Appendix H.
UNITED AMERICAN REPORTING SERVICES, INC.
Dallas, Texas (214) 855-5300
53 1 Q. Okay. I want to know, Mr. Hansel, if 2 you, in y ou r position at ERC, your role is with 3 ERC, is going to go back to the identified
.I 4 deficiencies, deviations and out of scope 5 observations, if you personally and those under 6 you r immed ia te direction and control, not under 7 the CPRT project director, and make a 8 determination on whether or not the corrective 9 action was followed up?
10 MR. EGGELING: I don't und er s ta nd 11 why you think he hasn't answered tha t question, i
12 and therefore, I'm very confused.
13 MS. GARDE: It's a very simple i 14 question. He keeps referring me back to Appendix 15 H. I don't want to know what Appendix H says. I 16 don't want to know what the CPRT project 17 director's responsibility is. I want to know what 18 he is going to do.
19 MR. EGGELING: Wha teve r Appendix H f
20 tells him to do.
I 21 MS. GARDE: He's not the CPRT j 22 project director.
l 23 MR. EGGELING: Tha t 's right, but 24 what he sa id was , he would provide bodies and a
~
25 CPRT project director.
UNITED AMERICAN REPORTING SERVICES, INC.
Dallas, Texas (214) 855-5300
54 1 MS. GARDE: I understood his 2 answer. I'm not questioning you.- This isn't 3 legal argument. This is discovery. I want to 4 know the answer to my question. Now, if it's 5 confusing, I will restate it.
6 MR. EGGELING: It is very 7 confusing.
8 MS. GARDE: I will restate it.
9 MR. EGGELING: Because I believe 10 he's answered that. That's why I'm confused.
11 MS. GARDE: All right. I will 12 restate it.
13 Q. (BY MS. GARDE) Mr. Hansel, you 14 testified that under the quality of construction 15 pro g ra m , there is going to be an ident if i ca tion of 16 deficiencies, deviations and out of scope 17 observations, do you recall that testimony?
18 A. I didn't say it quite like that, but I 19 identified the kinds of paper that will be 20 produced, yes.
21 O. All right. And those types of papers, 4
22 if you will, go to the project with some sort of 23 recommendation for corrective action; isn't tha t 24 correct? -
25 A. Not totally.
UNITED AMERICAN REPGRTING SERVICES, INC.
Dallas, Texas (214) 855-5300
55 1 .O. .All right. Please correct th a t 2 assumption.
3 A. We do not give them a recommendation on i
4 deviations or out of scope observations.
5 O. You just give them th e identified 6 deficiency or deviation or out of scope 7 observations?
8 A. The identified deviation as described in 9 Appendix E.
10- Q. Okay. Now, at tha t point when an out of 11 scope observation or a deviation leaves the i
12 quality of construction prc a ra m and goes to the 13 project, are you, meaning you, ERC, going to do a 14 follow-up on what happened to that out of scope 15 observation or deviation?
16 A. No.
17 C. All right. That is going to be done by 18 the project if it is done at all; is that correct?
19 A. Yes.
20 0. All right. That's what I wanted to 21 know, i 22 All right. I think we can ta ke a break 23 now, then.
24 (Recess t a k'e n ) .
25 MS. GARDE: R ea dy ?
UNITED AMERICAN R E PO F,TI NG SERVICES, INC.
- Dallas, Texas (214) 855-5300
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[ 56 l.
1 THE WITNESS: Yes.
2 0. ( B Y MS . ' GARDE) Okay. I'm going to 3 change the focus of my questions for awhile, Mr.
I 4 Hansel, to 7 C and the quality ot construction 5 p ro g ra m as it exists now, not trying to put you 6 back in a historical time frame of what existed at 7 a previous time.
8 MR. EGGELING: The last series of 9 questions before the break were present time, 10 weren't they?
11 MS. GARDE: Yeah.
. 12 MR. EGGELING: We didn't 13 misunderstand each other with this --
14 MS. GARDE: No, I understood that 15 his answers were that 7C hadn't been changed, but 16 I'm putting a break right now. Forget historical 17 stuff.
18 MR. EGGELING: Let's see if we 19 understand what you're doing as we go forward, i 20 MS. GARDE: Okay.
t 21 0. ( B Y MS . GARDE) The 7 C quality of 22 construction p ro g ra m is going to produce final 23 reports; isn't th a t correct?
24 A. Yes.
~
25 O. Okuy. And what are the final reports UNITED AMERICAN REPORTING SERVICES, INC.
Dallas, Texas (214) 855-5300
57 1 that are going to be produced out of 7 C?
2 A. There will be a report for ea ch 3 population of hardware and a summary report.
4 O. And the summary report, is that the 5 collective evaluation report?
6 A. No.
7 O. Is that th e collective s i gni f i ca n ce 8 report?
9 A. No.
10 0. Okay. Would you describe then what is 11 the summary report tha t is going to be produced?
12 A. It's still in development, but it will 13 summarize the data from each of the populations 14 and to broader categories such as civil s t ru c tu ra l 15 supports, el e ct ri ca l . And I --
that's what I 16 re ca ll right now. It's in its development stage.
17 Q. You refer to a report for ea ch 18 population. How many populations are there tha t l { 19 will have a separate report?
l l
20 A. 32.
I 21 O. And how were these groupings arrived at?
22 A. Groupings of what?
l 23 Q. How were the populations established?
24 You don't understand my question?
25 A. No.
l UNITED AMERICAN REPORTING SERVICES, INC.
Dallas, Texas (214) 855-5300
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'd '
1 t- 58-1 Q. Okay. . What are the populations?.
2 A. I ca n ' t recall them all specifically, 3 but they're identified'in ISAP 7C.
4 Q. Okay. Do you have ISAP 7C with you in
-5 revision 47 6 A. No. I didn't bring the IS A PS .
L 7 MS. GARDE: O f f- the record.
o' ,
8 (Off the record discussion).
9 MS. GARDE: Let's go on.
10 Q. (BY.MS. GARDE) I don't have the IS APS 11 either Mr. Hansel.
12 When you say that th ey ' re listed in 7C 13 and they're the 32 that are listed in 7C, are
- 14 these the homogeneous groups that the NRC has 15 already looked at? Or is this something 16 different?
17 A. It's the sane that th e NRC looked at.
18 Q. Now, these 32 populations --
19 A. Let me back up.
20 Q. Yes.
~
A. And straighten you out. ,
~I I
. Okay.
L -
You said groups.
. , All right.
25 A. They' looked at our populations and they UNITED AMERICAN REPORTING SERVICES, INC.
Da11as. Texas (214) 855-530'
.59 1 looked at those in1 groupings of th os e that would 2 affect civil construction, electrical 3 construction, supports and mechanical. Sc there 4 are 4. groupings of which the 32 populations fits 5 into.
6 Q. All right. So of the 32 populations, 7 the grouping'is 47 8 A. Yes.
9 0. The 32 populations that make up 7C, do 10 they incorporate all of th e accessible hardware at 11 the site?
I 12 A. All safety related accessible hardware, 13 0. Within the 32 popu?ations, within ea ch 14 one of the 32 populations, is there 100 percent 15 re-inspection done of ea ch population of all 16 accessibic sa f e ty related hardware?
17 MR. EGGELING: Could I hear the 18 question back?
l '! 19 (Record read back).
20 MR. EGGELING: I'm sorry, Ms.
i 21 Garde, I'm not able to understand that question.
22 There's a population --
l 23 MS. GARDE: Okay, for each
, 24 population. Looking at each one separately.
25 Within each population, do you understand that UNITED AMERICAN R E PO R TI NG SERVICES, INC.
Dallas, Texas (214) 855-5300
x - - -
60
.i 1 designation?
2 A. Yes.
3 0. Take any one of them or each one 4 separately, does -- strike-that.
5 Is there a 100 percent inspection 6 performed'of all accessible sa f ety related 7 hardware components?
8 A. No.
9- O. Is it a sampling inspection of all 10 safety related accessible components?
11 A. Yes.
12 O. And is the sampling that is done for 13 each population explained or defined in the CPRT 14 program plan which is publicly available?
15 A. Yes.
16 O. Taking one population, when ERC 17 conducted its actual inspections, were those 18 inspections always done by ERC inspectors?
19 A. Yes.
i 20 O. Were any personnel hired by ERC which 21 had previously been quality control inspectors or 22 craft employed at the site?
l 23 A. No.
24 0. Were all of the inspectors used to de 25 the inspections qualified to ERC inspection i
UNITED AMERICAN REPORTING SEPVICES, INC.
. Dallas, Texas (214) 855-5300
61 b standards?
^
1 2 A. Yes. W e ll ,- what do you mean by 3 "standards"?
4 0. Check' lists, okay. S ta nda rds , I'm 5 meaning qua l i f i ca t ion certifications, the 6 inspection check lists, the procedures that they 7 were supposed to follow to do the inspections.
8 MR. EGGELING: Are we qualifying 9 inspectors or are we talking about --
10 MS. GARDE: Inspectors.
11 MR. EGGELING: --
full 12 inspections?
I 4- 13 MS. GAPDE: Inspectors. Inspectors
, 14 qualified to do the work that they did to ERC 15 procedures, check lists, inspections pro cedu re s .
4 16 MR. EGGELING: Do you fellow the 4
( 17 question?
l 18 THE WITNESS: Yeah.
i l i 19 MR. EGGELING: Can you ar.:wer it?
i t
20 A. I need to expand, but I can answer it.
21 our inspectors were all certified to l 22 ANSI N 45.2.6 as interp . eted by the E0g gu id e and i
23 ERC corporate procedu..s 24 0. Within ea ch one of th e 32 populations, 25 was there an expansion criteria to. lowed which
^
l UNITED AMERICAN REPOR. TING SERVICES, INC.
- Dallas, Texas (214) 855-5300
62 l 1 would expand the a ctual number-of inspections 2 performed on sa f ety rela ted accessible components l 3 in the ev en t of the identification of a l 4 deficiency?
- )
5 THE WITNESS: Can I hear the 1
6 question back?
7 (Record read back). l 8 MR. EGGELING: Just so we're clear, 9 we've slipped off a little bit. I don't think you 10 did it, intentionally.
11 MS. GARDE: If he' understands the 12 question, I want him to answer.
l 13 MR. EGGELING: We'll get to that in l
14 a minute. May I finish? The questions are 15 beginning to look backwards, expansion criteria 16 followed as opposed to inspection criteria to be I l
17 followed. The purpose of the deposition is to try l
( 18 to 1cok at the adequacy of this plan. And we're l 19 slipping slightly over into what happened in the !
, i l
20 past. The results of which aren't out yet. Am I
! t 21 correct in believing that was not intentional and 22 I don't have to ob j e c t to that each time it 23 happens? That, in f a ct , what you meant to say l l
i 24 was: Are there expcnsion criteria in the plan i
~
25 which are intended to do how ever you want to UNITED AMERICAtl REPORTING SERVICES, INC. l Dallas, Texas (214) 855-5300 l
A
$M,'E 63 1 phrase it?
2 MS. GARDE: We can be in this 3 fairyland of retrospective things that are already
~
4 finished. I'm not trying to get limitation from 5 him'. I want to understand the program. But the 6 notion that we're going to have this_ thing
.7 completely in a va cuum is just ridiculous. It's 8 been done and I expect him to tell me if it's been 9 donc differently than what th i s plan sa y s it's 10 been done.
11 MR. EGGELING: Well, you can expect i
12 what you want. Make you r questions clear. If you 13 are trying to look backwards, I'm going to be e 14 forced to put in an objection. I don't think 15 that's what you intended, at least at th i s stage 16 of the deposition.
17 C. (BY MS. GARDE) Do you understand the 18 question, Mr. Hansel?
19 A. No.
20 0. All right. Would you please explain 21 what is the actual number of hardware components 22 that was intended to be looked at in each of the 23 32 population areas first time around?
24 A. Appendix D specifies how we draw our 25 samples. The number of samples drawn is in UNITED AMERICAN REPORTING SERVICES, INC.
Dallas, Texas (214) 855-5300
64 4
1 accordance with Appendix D and what th o s e 2 individual numbers are, I don't have them here 3 today.
4 O. What is the number 60 mean in terms of 5 Appendix D in terms of actual inspections?
6 A. Again, I would refer you to Appendix D, 7 but that's the sample size.
8 Q. All right. And at what point does the 9 sample size get expanded?
10 A. Appendix D again addresses that and what 11 the screen is, is identified in Appendix D.
i 1
12 0. Did you participate in writing the 13 sampling pro g ra m ?
i
, 14 A. What do you mean by the sampling 15 pro g ra ta?
16 C. Appendix D? Did you participate in i
17 writing App e nd i:, D?
18 A. No.
- 19 O. Who did?
I 20 A. I don't know spe cif i cally . Doctor l
21 Webster pa rti cipa ted.
l l
I 22 Q. Is it the intention of th e quality of i 23 construction pro g ra m , the report for each
. 24 population to rea ch a conclusion about whether or l 25 not th e re a r e a'ny undetected or uncorrected l
UNITED AMERICAN REPORTING SERVICES, INC.
Dallas, Texas (214) 855-5300 L ^
r
[ 65 t ,
1 deficiencies within ea ch population? -
2 A. That report is in preparation now, and I 3 don't recall if we plan to make a statement on a 4 population by population basis.
5 O. Is the report that is described in 7C, 6 that;is envisioned by 7 C, going to rea ch a 7 statement about the existence of undetected or 8 uncorrected deficiencies within each population 9 oven if those words aren't used?
10 A. The program plan ard ISAP 7C requires us 11 to draw certain conclusions and without second i
, 12 guessing what th o s e are, I would refer you back to 13 the program plan and the ISAP.
l 14 Q. Does 7 C, as envisioned and described in 15 the program plan, intend to make a statement on 4
16 whether the quality control, quality assurance l
17 p r o g ra m initially implemented at Comanche Peak l 18 functioned correctly within each of the 32 l
l 19 populations?
I 20 THE WITNESS: Could I hear that i 21 read back, please?
l 22 (Record read back).
23 A. No.
I 24 .
Q. Where deficiencies have been identified 25 in ea ch of the 32 populations, dces'the quality of l
UNITED AMERICAN REPORTING SERVICES, INC.
7 Dallas, Texas (214) 855-5300
66 1 construction program intend to pursue the cause of 2 those identified deficiencies?
3 A. If you're referring to construction 4 deficiencies, yes.
S 0. What about deviations?
6 A. Not on a one by one basis.
7 Q. On what basis?
8 A. Through trend analysis.
9 Q. And will the trend analysis results he 10 included in the r talts report on 7 C?
11 A. Yes.
12 0. And what about out of scope i
13 observations?
14 A. In terms of what?
15 Q. W il l out of scope observations be 16 referred to in the final report and snelyzed to
. 17 d e t e c.m i n e why it occurred? Why the problem l
i 18 identified occurred?
19 A. I'm not certain.
20 Q. Okay. Do you know whether or not out of 21 scope observations will be trended and whether 22 that will be reported in 7C?
r e
l 23 A. I don't believe so. ;
{
24 O. Mr. Hanset, do you review on a regular i
~ 25 basis ERC deviation reports?
l h
UNITED AMERICAN REPORTING SERVICES, INC. I Dallas, Texas (214) 855-5300 ;
67 o s ,.
- 1 A. What.do you'mean by "regular basis"?
2 0. Do you personally review or audit- them ,
.3 -in the course of your work?
4 A. I see a lot of-deviations. I do not 5 review all deviations.
6 0. I'm going to show you a pa ck a g e of 7 material that was provided by Texas Utilities in 8 accordance with the in-process inspection 9 production. And I just want to ask you a couple 10 of questions about th e ERC paper in this pa ck a ge .
11 MS. GARDE: These are th e o r e t i ca l f
12 questions, Counsel, if you want to look it over 13 before you let him look at it, j 14 MR. EGGELING: Are there pa r t i cu la r 15 pa ges I should look at?
16 MS. GARDE: The ERC deviation 17 papers and then there's a CPPO 25 document at the l
18 end.
19 (Deposition Exhibits No. 5-6 20 (wore marked for identification.
21 C. (BY MS. GARDE) Just a minute, Mr.
22 Hansel, I'm going to show you a copy of a document 23 that's been marked Exhibit 6. It's got, I 24 believe, what is your s i g n a t u r'c on the bottom of 25 it. You might want to show it to your' counsel and UNITED AMERICAN RE PO RTI NG SERVICES, INC.
- Dallas, Texas (214) 855-5300
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- n. 68 1 let him look at it. It comes from the sa me stack 2 of ma te rial s on inspector certifications that 3 Exhibit 5 did, but it's a different deficiency 4 report.
5 Is that your signature on the bottom of 6 the pa ge ?
7 A. Yes.
8 0. Okay. Do you recall reviewing that 9 document?
10 A. Yes.
11 Q. Okay. The type of form that Exhibit 6 12 is, is this an ERC form?
13 A. Yes.
14 Q. And is this the type of report th a t 7C 15 will be producing regarding the 32 populations, i
16 ca ch of the 32 populations?
17 A. No.
18 0. Could you explain to me how this form is 19 used within 7C?
20 A. This pa r t i cu la r form is just one of many 21 forms that record data including the evalu- --
22 involved in the evaluation of a population. The 23 results report on the population will take all the 24 data from all the various forms and compile it 25 into a written report.
UNITED AMERICAN REPORTING SERVICES. INC.
Dallas, Texas (214) 855-5300
69 1 Q. All right. Now, the form tha t is 2 exhibit C, and just for clarification, I will 3 identify it by date of Feb rua ry 2nd, 1987. Yeah, 4 the number is OA/0C dash PDR' dash 45 Rev. 1. In 5 the upper right-hand corner there's a DR number.
, 6 Does that go to a specific deficiency 7 report? I'm asking if that is what tha t form is.
8 MR. EGGELING: May we cla rif y. you r 9 question to reflect Exhibit 6, I believe you 10 ca id "C."
11 MS. GARDE: Oh, I'm sorry. Exhibit 12 6, 13 MR. EGGELING: Tha t 's all right.
i 14 Go ahead.
15 MS. GARDE: That's different.
16 O. (BY MS. GARDE) Okay, right now I'm just 17 asking you if this is --
if the number in the 18 upper right-hand corner in Exhibit 6 is an
{ 19 identification number that puts it with a pa ck a g e I
20 of materials in a deficiency report?
21 A. Yes. Except I want to straighten out 22 terminology again. A deviation report.
23 Q. All right. This is --
this DR is a 24 deficiency report number?
25 A. Deviation report number.
UNITED AMERICAN REPORTING SERVICES, INC.
Dallas, Texas (214) 855-5300
70 1 Q. Okay. I'm confused because it came from
< 2 a stack of ma te rial I got from Texas Utilities 3 rubber band together behind a deficiency report 4 which has the same number on it.
5 A. May I go off the record for a second?
6 (Conference).
7 MS . GARDE: Can he put that all on S the record?
9 MR. EGGELING: Yeah.
10 MS . GARDE: Okay. I think at this 11 time, I think we better mark th e second s ta ck of 12 papers as Exhibit 7.
l 13 (Deposition Exhibit No. 7 4
, 14 (was marked for identification.
15 O. (BY MS. GARDE) Mr. Hansel, would you 16 explain, please, the tra ck of papers that you 17 started to refer to while we were off the record 18 and why this DR number is a deviation number 19 instead of a deficiency number on Exhibit 6?
20 A. Here we go.
l l
- 21 During the evaluations in accordance 22 with the requirements of 7 C, an inspector will 23 identify a deviation from requirements in
, 24 accorddnce with Appendix E.
25 O. And on what form does he do that?
l i
=
l UNITED AMERICAN R E PO R TI NG SERVICES, I li C .
l Dallas, Texas (214) 855-5300
'71 1 A. I'm looking for a form number.
2 The form is called the Comanche Peak 3 response' team ERC deviation report paren, DR, 4 paren.
5 That report goco to the project, and in 6 th i s pa r t i cu l a r case, and I want to indicate why 7 I'm saying this particular case, anything 8 involving a question concerning inspector 9 ce r t i f i ca tion was sont to the issue coordinator 10 for 1D1, ISAP 1D1. They then did an evaluation in 11 accordance with the guidelines of ISAP 1D1 and 12 they determined that that deviation, as written, 13 constitute a -- constituted a OA/0C p ro g ra m i 14 det i cie ncy in accordance with Appendix E of the 15 program plan. Then it was entered onto another l 16 form for review.
17 0. By Texas Utilities?
18 A. No. By ERC personnel.
19 0. So the deficiency form that is marked as
! 20 Exhibit 7, the front pa ge of Exhibit 7, it's a
! 21 single sheet, is that the deficiency report that t
i 22 was prepared for ERC review?
23 A. No.
24 -
O. What is the form that was prepared for i
- 25 ERC review?
UNITED AMERICAN REPORTING SERVICES, INC.
Dallas, Texas (214) 855-5300
72 1 A. Exhibit 6.
2 0. Okay. Does Texas Utilities receive a 3 copy of. Exhibit 67 4 A. Yes. After I have reviewed it.
5 O. And that is your signature on the bottom 6 of Exhibit 6?
7 A. Yes.
8 Q. All right. Then what happens to it?
9 A. Exhibit 6?
10 Q. Exhibit 6 is the next step; is that 11 correct?
12 A. Yes.
13 0. The last step before it goes to Texas 14 Utilities is that correct?
15 A. Yes. At that point in time it's been 16 dispositioned by myself.
17 0. All right. Does it come off of --
18 strike that.
19 Do you keep a log of the forms, the 4
20 deviation reports similar to Hansel 6?
21 A. Yes.
22 Q. Okay. Do you have a process by which 23 you close out the things on that log?
24 A. Yes. .
~ 25 '.
O Oke,. Wha t generates a close-out UNITED AMERICAN REPORTING SERVICES, INC.
Dallas, Texas (214) 855-5300
r 73 1 action?
2 A. When we have declared something to be a 3 Q A/ OC pro g ra ma ti c. deficiency in accordance with 4 Appendix E, the project is required to respond to 5 me with their statement of what their plans are to 6 fix that deficiency. And that's in writing. It's 7 then my action to review that and discuss it with 8 the senior review team. Once we agree with it, 9 with their proposed corrective a ction, then we 10 respond back to the project.
11 C. And on what forms do those l 12 communi ca tions ta ke pla ce ?
1 13 A. It has been in two different forms.
I 14 There have been letters and there have been TU s- 15 electric CARS, corrective a ction requests.
! 16 0. Now, will the results report tha t you 17 prepare inc1' e reference to the letters and th e i
18 CARS for e a e ., instance where you generated a l
l 19 deviation report?
! 20 A. I don't think so, but the --
but tha t 21 information wd.11 be in the files.
22 0. Yo'. me a n the results reports file?
23 A. Yes.
l 24 O. But it won't necessa'rily be referenced i ,
25 in the results report?
l UNITED AMERICAN REPORTIliG SERVICES, INC. '
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74 s.
1 A. Correct.
-2 Q. Now, the deviation -- or excuse me, 3 strike that.
4 The deficiency report which has the 5 marking on it of Hansel Exhibit 7.
6 MR. EGGELING: It's only the first 7 page of that.
8 MS. GARDE: The first page the 9 single page, okay.
10 Q. Is this generated by ERC or site 11 personnel?
i 12 A. Project personnel.
13 O. All right. And do you have anything to 14 do with the preparation of that deficiency report 15 form?
16 A. No.
17 0. Do you make any evaluation of whether 18 the deficiency report form accurately contains the 19 information that you've identified on an ERC il 20 deviation report?
21 A. No.
22 Q. Do you know what th e purpose of th e 23 de f i cie ncy report is?
24 A. I would, again, refer you to project 25 procedures, but it's pretty obvious from the form UNITED AMERICAN REPORTING SERVICES, INC.
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75 1 that it's how to get that problem fixed.
. 2 0. Are you aware on whether or not th i s 3 deficiency report would also result in an NCR?
4 MR. EGGELING: Invariably?
5 MS. GARDE: Ever.
6 0. Do you know whether or not the project 7 would generate an NCR as well as a deficiency 8 report?
9 A. They have a procedure that defines that 10 review process. I'm not f amilia r with the 11 details.
12 0. Now, in your reviewing the proposed 13 disposition of the deviation report by the 14 project, do you make an evaluation on whether or 15 not the i nd iv idu al s involved with the disposition 16 had a n y th in g to do with causing the problem in the 17 first pla ce ? Do you include that?
15 THE WITNESS: Would you read that 19 back, please?
l 20 (Record read back).
MR. EGGELING: This document, 21 22 right?
MS . GARDE: I'm asking this as a 23 24 generic question. He can look at this if that 25 helps him.
UNITED AMERICAN REPORTING SERVICES, INC.
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76 1 A. Again, I think we have a case of apples ,
2 and oranges.
3 0. All right.
4 A. Let me straigten the fruit basket out.
5 I do not review their disposition of all 6 deviations.
7 c. All right.
8 A. Only those that are classified in 6
9 accordance with Appendix C as d e f i cie nc ie s ,
10 *dverse trends and so forth.
11 0 What is there that isn't in that 12 category- What deviations would you not review?
13 A. Deviations that do not result in a 14 construction deficiency, an adverse trend, an 15 unclassified trend, an unclassified deviation or a 16 OA/0C prog rama ti c de f i cie ncy .
17 0. And are there any?
18 MR. EGGELING: Conceptually.
19 0. Are there any that don't fall into one 20 of th o s e categories?
21 A. Yes.
22 0. And do they have their own category?
23 A. They remain as a deviation in accordance 24 with Appendix E.
25 O. And you don't review what happens to UNITED AMERICAN REPORTING SERVICES, INC.
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- 1 those?
l 2 A. No.
3 Q. Are they logged on y ou r -- are they 4 logged on your. log as being an ERC deviation?
5 A. Yes.
6 0.- Do-they remain oper on your log?
7 A. We receive feedback from the project as 8 to what NCR or deficiency report was written by l 9 the proj ect to review that deviation.
10 Q. To resolve it or review it?
11 A. To review it and resolve it. l 12 0 So you get a number back?
13 A. Yes.
! 14 Q. But you don't get the disposition back?
-15 A. No.
16 O. Okay. Between the categories that you l 17 have just discussed, how many fall into the h
'O latter? The last group that you've just i 19 discussed? Per cen ta ge ?
MR. EGGELING: You're discussing --
20 21 the question is implementation, what are th e I
i 22 recults to date?
MS. GARDE: No, I want to know how, 23 generally, the way we're talking about here in 24
- I 25 terms of that fall into the last category.
' UNITED AMERICAN REPORTING SERVICES, INw. i Dallas, Texas (214) 855-5300 ]
78
-1 don't care if it's 20 percent or 80 percent. I 2 just' wanted to have a sense of how many fall into 3 that category. If it's a small number, I'm not 4 going to pursue that, but that doesn't come up 5 clear through this program plan at all.
6 NR. EGGELING: The question is; 7 Whether he can answer what percentage grouping 8 description of any sort are going to fall into 9 that category based upon the prog ram plan . Wha t 10 one can conceive of at the time the pro g ra m plan 11 was drafted. He may certainly answer the -
12 question. If th e question is What are the 13 results to date of the inspections actually done 14 and the categories into which those results have 15 fallen, that's an implementation question _to which 16 I object.
17 0. ( B Y MS . GARDE) All right. I want you 18 to mark that question. >
- 19 MS. GARDE
- I assume you're I i 20 directing him not to answer it.
21 MR. EGGELING: If you're going to :
22 stick with the question that deals with the I 23 results, yes, they're in the process. You will 24 have it very shortly,.
~2 5 MS. GARDE: I want the record to )
UNITED AMERICAN REPORTING SERVICES, INC.
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79 1 reflect tha t I think that's a gross abuse of this
'2 process, 'Mr. Eggeling.
3 MR. EGGELING: Ms. Garde, you have 4 a free record if you can explain to me how the 5 results that --
6 MS . GARDE: I don't want to take my 7 time _and money to do that.
8 MR. EGGELING: If you can explain 9 to me how the ' resul ts deal with any aspects of the 10 th eo re t i ca l a ccu ra cy of the plan, I will be happy 11 to reconsider my in s t.r u c t i on .
12 MS. GARDE: I'm not going to take 13 Mr. Hansel's time and my time and Mrs. Ellis's 14 money to have that argument with you on the 15 record. I will have it with the board, 16 0. (BY MS. GARDE) All right. Mr. Hansel, 17 on the resolution of the deviations that you have 18 discussed, do you re ce !.v e back actual copics of j 19 the dispositions?
! Again I 20 A. --
21 O. Do you understand my question?
22 A. Yes, but I have to say again, it's not s 23 deviations.
24 Q. Okay. I'm looking at Hansel 6. It's a 25 deviation report, all right. If I'm not UNITED AMERICAN REPORTING SERVICES, INC. .
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e
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80 I understanding somothing, I want to understand it.
2 Tha t 's part of'the purpose of this deposition 3 because if I understand it, I may not have some 4 'dif f i cul ties or-problems, and I don't want to have 5 problems tha t are ina ccu ra te .
6 I understand that th i s is a deviation 7 toport and that this deviation report and others 8 like this as Hansel 6 goes to the project. That 9 you koop a log of those. That you review the ,
in project's resolution in some manner for each of ,
11 the deviation reports that are generated, is that 12 a correct un d e r s t a nd i r.g ?
13 A. No.
14 C. All right. Then correct my 15 understanding.
16 A. If th i s remains as a devia tion in 17 accordance with Appendix E --
18 0. Uh-huh.
19 A. -- it does not go to the project. If it 20 gets upgraded to a deficiency, which th i s one did,
.i 21 CA/OC programa ti c def iciency, then yes, I receive 22 a response back and review that response.
23 0. All right. Now, the deviations that do
- 24 not get upg ra ded to a deficiency, what happens to ,
25 them? !
l t
UNITED AMERICAN RE PO RTING SERVICES, INC. !
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^
1 A. They're given to the project and they 2 generate their own internal paperwork to review 3 -and resolve those deviations.
4 Q. And do you ever review that?
5 A. Not_on a case by case basis.
6 0. Do you audit it?
7 A. No.
8 0. You have no responsibility for auditing 9 the results of the --
those deviations?
10 A. That's correct.
11 C. So whatever conclusion 7C comes to does j
12 not include any reviUw of the resolution of 13 devia tions : is that correct?
-! 14 A. As defined by Appendix E, that's 15 correct.
! 16 0. Okay. Now, who decides to upg ra do 17 something to a deficiency?
- 18. A. That's my decision along with personnel 19 who perform the evaluation of individual 20 conditions.
I 21 0. And does that include the safety 22 significance evaluations?
23 A. Yes.
24 . Q. And who performs the safety significance 25 evaluation?
UNITED AMERICAN REPORTING SERVICES. INC.
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1 A. It's done-by S tone and Webster personnel
't
. 2 who-are on contract to ERC.
3 0. What f a ctors go into your decision to j 4 decide if a deviation is going to become a 5 deficiency?
6 A. We evaluate that condition in accordance 7 with the definitions in Appendix E.
8 Q. Now, you recently pa rti cipa ted in an 9 inspection by the Nuclear Regulatory Commission 10 that looked into the safety significance 11 ovaluation, didn't you?
12 A. What do you mean "pa rt i cipa ted "?
13 0. NRC reviewed the sa f e ty significance 14 ovaluation parts of the ERC pro g ra m . didn't they?
15 A. Yes.
16 0. And they disa greed with some of the 17 pra ct i ce s that you were following, didn't they?
18 A. Yes.
- 19 O. Now, I'm going to show you --
I don't 20 intend to mark this at this time unless you want 21 me to, Mr. Eggeling. I'm going to show you a 22 public document. It's an inspection report dated 23 August 31st, 1987. It's inspection report 8704.
24 And I want to ask you, Mr. Hansel, if this is the
'25 NRC inspection that you just referred to?
1 UNITED AMERICAN RE PO R T I NG SERVICES, INC.
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- - _ . . _ _ _ . _ _ _ _ . . . _ _ _ _ _ _ _ . -s I
- n 83 L 1 MR. EGGELING: Why don't we mark 2 it, and then let me try to clarify my 3 understanding of you r ques tion
.- 4 (Deposition Exhibit No. 8 5 (was marked for identification.
6 MR. EGGELING: Ms. Garde, just so I i
7 understand, you r question to Mr. Hansel is whether I
8 Deposition Exhibit 8 comprises a report of an 9 inspection to which you were referring in you r 10 previous two questions to him?
11 MS. GARDE: Yes.
I MR. EGGELING: Review that and see 12 13 if that --
if the two of you are congruent on the 14 same inspection, 15 A. Yes.
16 Q. All right. Now, that inspection report 17 refers to an audit report from April of 1986; 18 isn't that correct? .
19 MR. EGGELING: You want to address 1
20 him to some pa r t i cu l a r portion of the --
i 21 MS. GARDE: Yeah, I'm going to give 22 him the a tta chment.
23 MR. EGGELING: Where is the
. 24 reference in here? This is ovcr 50 pages.
~
25 MS, GARDE: I thought he had it in UNITED AMERICAN REPORTING SERVICES, INC.
- Dallas, Texas '(214) 855-5300 J
84 1 front-df him. Do you have it'in front of you, the
.2 ' reference.to the audit, yes. It's on page 4.
3 MR. EGGELING: I'm lost. What was 4 the question?
5 MS . G AR DE : I asked him if the 6 inspection report, in f a ct, referred to an audit 7 report. That audit was done in 1986. April and 8 May. It says tha t right on the top -- right on 9 the line --
10 MR. EGGELING: You see the words 11 "audit report" there anywhere?
12 THE WITNESS: No.
13 MR. EGGELING: It's not th e re .
14 T!!E WITNESS: That's a trip report.
15 MR. EGGELING: There's no words 16 "audit. report".
17 MS. GARDE: Pine. I will show it 18 to you in the next exhibit, audit report. I'm i 19 just trying to do this one at a time so it doesn't l 20 get confusing.
t i 21 MR. EGGELING: That's exactly what l
22 I'm trying to do.
23 MS. GARDE: All right. Can we mark 24 this next one?
25 (Deposition Exhibit No. 9 -
l l U l~ :D AMERICAN REPORTING SERVICES. INC.
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[ ,
.85-1 (was marked for i d en t i f i ca t i o n .
2 MS. GARDE: So --
3 Q. ( B Y MS . GARDE) Okay. Mr. Hansel, I'm 4 now going to show you Exhibit 9, and I will 5 represent for the record it was an at ta chment, the 6 only a t ta chment to 8704. It's a publi c document .-
7 I d ra w your attention to the second page i
8 of the stapled exhibit entitled; Audit report 9 safety significance ev al ua tion audit CPSES site 10 4/28 to 5/1/86.
11 I want to know, Mr. Hansel, if this is i
12 the audit report, as you understand it, that led 13 to the finding in inspection report 8704? Look at 14 that one.
15 MR. EGGELING: Two different things 16 happening. First, let's see between the three of 17 us, if we can get a clear record.
18 MS. GARDE: Well, let --
I think he 19 understands it.
l 20 MR. EGGELING: I certainly don't.
l lI l ! 21 Reference 4 refers to a trip report. That's the 1
i 22 exact words, and I'm sorry Deposition Exhibit 8, j 23 on the third line of the first full pa ra gra ph --
24 the documents you've marked as Deposition Exhibit 25 8, the first line which you keep not reading sa y s UNITED AMERICAN R E PO RTI NG SERVICES, INC.
Dallas, Texas (214) 855-5300
86 1 Trip report.
'2 MS . GARDE: Fine. Trip report, 3 audit report. It's the same document.
4 MR. EGGELING: Tha t 's fine. I'm 5 trying to get the record st9aight between us. He 6 can determine whether he thinks those are the 7 same.
8 The second question that was in you r 9 question, which I simply don't understand, is 10 whether it generated the finding, and I don't know 11 if there's one finding, 20 findings or 100 12 findings here. I ask you to be a little more 13 specif ic about what you're trying to get him to 14 discuss.
15 MS. GARDE: All right. Let him do 16 it one at a tin.e.
17 O. ( B Y MS . GARDE) W il l you look at the 18 trip report, audit report, and determine in you r
- 19 own mind if the trip report, audit report, that is 20 marked as Exhibit 9 is the source of th e l
21 information that is referred to on pa ges 3 and 4 22 of the inspection report 87047 We'll ta k e it from 23 there.
24 A '. I can only a dd re s s --
ind i ca t e that
! 25 based upon dates, since Exhibit 8 -- upon dates of !
i UNITED AMERICAN REPORTING SERVICES, INC. ;
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- k.
.1 the Teledyne Services-letter as being the same 4:
- 2 between Exhibit 8 and Exhibit 9. And tha t the 3 dates of the trip report are the sa me . I don't 4 know if it's the basis --
if Exhibit 9 is the 5 basis for Exhibit 8 or not.
6 0. All right. Mr.-Hansel, when the trip 7 occurred in April and May of 1986, were you 8 present at the time that Mr. Landers was there at 9 the site?
10 A. I was in at least one meeting with Mr.
- 11 Landers.
I
{, 12 O. Were you at the exit interview on Mr.
i 13 Landers' findings?
i 14 A. As I recall, I missed the exit 15 interview, and this report does not show me as 16 being present at the exit interview.
l l 17 MR. EGGELING: This report meaning 18 Deposition Exhibit 8.
19 THE WITNESS: Exhibit 8.
I 20 O. (BY MS. GARDE) And did you have someone 21 from ERC tha t was at th e exit interview?
22 A. Yes.
23 O. And who wa's that?
24 -
A. Well, there are a number of ERC 2S personnel here. The one most -- who reports UNITED AMERICAN REPORTING SERVICES, INC.
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! -1 closest to me is Mr. B ra b i s o n .
. 2 0 And do you recall Mr. Brabison briefing 3 you about Mr. Landers' exit interview?
'h 4 A. Yes, i
5 O. And do you recall when you received th a t 6 b ri e f i n g ?
, 7 A. No.
8 0. Do you know-what was the date of the 9 exit interview?
10 A. No. Not without referring to the 11 exhibit.
12 0. All right. The exhibit sa y s March 3rd, 13 1987 exit interview. Eased on you r own knowledge, 14 does that sound approximately the time period that 15 !! r . Brabison talked to you about that?
16 A. I -- again, it's been a long time ago.
17 It was very close to that period, yes. To that 18 date.
19 0. All right. It wasn't immediately after
- i 20 Mr. Landers' visit in '86 is that correct?
21 A. I also received a briefing -- in fact, I 22 attended a debriefing from th e NRC and Toledyne 23 before they departed in 1986.
24, O. And at thq time of that debriefing, was 25 anyon'c else from you r staf f with you?
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1 A.- Yes.
2 Q. And who was that?
3 A. Mr. B ra b i s on , Mr. M il l e r .
4 Q. Anyone el se ?
5 A. I know there were others, but-I can't 6 recall.who they were.
7 Q. All right. At that debriefing -- strike 8 that.
9 Let me ask you this: Who do you 're call 10 was there from the NRC and Teledyne? Was Mr.
11 Landers there?
12 A. Mr. Landers was there. Mr. Earnes from 13 the NRC. Mr. Wagner from the NRC. Those are the 14 ones that I remember.
15 Q. All right. After that meeting, did you l
L 16 make cha ng es in the safety s i gn i f i ca n ce eval ua tion 17 p ro g ra m ?
l 18 A. Yes.
19 Q. And where are those changes reflected?
l i
20 A. I don't recall if we made any changes to 21 CPP's or not. I'm fairly certain that th e r e is 22 internal correspondence concerning the approach to r
23 be taken.
24 Q. And what was the dif'f o rence in the 25 approach that was ta ken following Mr. Landers' UNITED AMERICAN REPORTING SERVICES, INC. '
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- ;-1 90 1 deb ri e f in g than what was previously_ ongoing?
2 A. The main emphasis was placed on 3 requiring additional review to assure that our 4 reports were self-explanatory. The issues were 5 not so much te chni ca l in nature as they were how 6 wo stated the problem or stated an evaluation.
7 Q. So you r understanding of th a t meeting 8 and the changes that you were required to make
. 9 went to descriptions of how you described 10 prob 1 cms, not to substance?
11 A. Primarily, how things were --
how issues 12 or problems were described or eval ua tion 13 techniques were described.
14 There were also some issues surf a ced 15 that were of substance.
16 O. And the issues that su rf a ced that were 17 of substance, how, in the -- where in the pro g ra m 18' plan is there a requirement for those findings by 19 Tcledyne to be reported?
20 A. Reported to who?
21 O. Well, publicly. How would CASE know 22 about that? How would the board know about those 23 findings by 1 coking at the completed results 24 report?
~
25 A. You won't. That's NRC correspondence. .
UNITED AMERICAN REPORTING SERVICES. INC.
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1 0. Okay. That.-- tha t answer makes me ,
2 think tha t you didn't understand my question.
3 You had a meeting with Mr. Landers ~and '
4 people from th e NRC. They gave you comments on 5 implementation of you r sa f ety significance 6 evaluation aspect, all right?
7 I want to know how those findings by the 8 NRC will su rf a ce in you r program report. Not the 9 NRC's correspondence. How will I know at the 10 end --
'let's say I never read that NRC report or 11 it never made it to an NRC report. How would I '
h 12 know by reading y ou r program plan at the end of .
13 it, the results reports, all of the information 14 that is going to be published, that there was such 15 a finding and that you took steps to resolve that 16 problem?
r 17 A. Okay.
18 O. Or those problems?
- 19 MR. EGGELING
- Finding, you mean 20 whatever --
l
[
21 MS. GARDE: What Tolodyne found.
22 MR. EGGELING: W ha t evd. r general i
i 23 advice Teledyne gave as they left, not th e formal ;
24 findings the NRC eventually reached.
I 25 MS. GARDE: Not the f or.na l l l
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'I :1 findings.
i
.- 2 MR. EGGELING: ,I'm not sure that's ,
3 total --
- l 4 MS. GARDE: Not the - formal I
5 findings.
6 A. We internally wrote our own ERC 7 corrective a ct ion request or report involving this-8 and took a number of actions that are described in 9 that CAR. And those reports will be given to you 10 upon completion of the pro g ra m .
11 C. Arc the --
is the procedure for writing
} 12 an ERC CAR part of the materials that have boon
)
13 provided publ i cly ? i 14 A. I believe so. It's either in a CPP or 15 it's in one of our ERC corporate quality .
i 16 documents, and I don't know if you received the 3
s
. 17 latter.
18 Q. Does the CPRT work being done by ERC --
19 strike that. ,
20 Is the work done by ERC in the quality j 21 of construction program governed by 10 CFR 50
?
22 Appendix B7 l 23 MR. EGGELING: What do you mean by [
l . 24 "governed by"? I I
i 25 'MS . GARDE: Does he understand my l
) -
t l
UNI 7ED AMERICAN R E PO R TI NG SERVICES. INC.
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93 1 question?
2 MR. EGGELING: Let's start with 3 whether I do, so I can decide whether I-want to 4 ma ke a n objection, then we'll see whether he'does, 5 okay?
6 MS. GARDE: Wha t are you asking 7 me?
8 MR. EGGELING: Do you --
the first 9 question ist What do you mean by "governed." If 10 you can ' t define that, then I'm going to ask 11 ~ whether you mean governed in the sense of a legal 12 conclusion. If you do, of course, I'm going to 13 object because he's not a lawyer. I'm going to 14 tell him not to answer it.
15 If you mean something else, tell me what 16 it is, and I will know whether he can answer it.
17 MS. GARDE: A man has spent his 18 cntire career in quality a s su ra n ce /qua l i t y 19 control. I'm asking if the program he wrote for l
I 20 this plant is being done a ccording to 10 CFR 50 21 Appendix B, as he has written it. I don't want to 22 know legal conclusion. I want to know as he has 23 written it and as he has done it and as I should 24 rea d it and understand it.
l l 25 MR. EGGELING: Your question is in i
i l
l UNITED AMERICAN REPORTING SERVICES, INC.
I Dallas, Texas (214) 855-5300 t -
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=
94 W*
, _1 his professional opinion?
2 MS. GARDE: No, I want to know not 3- 3 in his opinion, I want to know in the way the 4 program was written. Was it written to 10 CFR 50
'l 5 Appendix B.
6 He understands my question.
7 MR. EGGELING: I'm trying to. Do
- 8 you mind?
9 Is the question whether --
is the 10 p ro g ra m as it has been written consistent with 10 11 CFR part 50 as he understands that?
12 MS. GARDE: Tha t 's not what I
, 13 sa id. I didn't say " co ns i s t e n t " .
, 14 MR. EGGELING: Well, you said
- 15 "conform" which is a legal conclusion --
10 CFR 16 part 50 is a legal conclusion.
17 MS. GARDE: I want to know if the 18 pro g ra m that he wrote was written to, is governed 19 by, however you want to describe it, 10 CFR 50 i
l
- } 20 Appendix B. Did he use --
21 MR. EGGELING: I want to describe 22 it "consistent with".
i l 23 MS. CARDE: Did he use 10 CFR 50 24 Appendf.x B when he wrote the program plan?
i
'25 You can answer that MR. EGGELING:
f UNITED AMERICAN R E PO R T I N G SERVICES, INC.
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[ 95 1 '
1 question I'm sure. Tha t 's no t a legal question.
2 A. Yes.
3 Q. Thank you. And when you used the
.4 program -- when you wrote the program plan and you 5 used 10 CFR 50 Appendix B, what internal audit 6 system did you put in place to insure that 7 internal problems with implomentation woro 8 identified and corrected as envisioned by 10 CFR 9 50 Appendix B?
10 A. That's defined in our corporate 11 management plan which is a pa r t of Appendix G to 12 the CPRT program plan and also-in our procedures.
13 We have corporate audits with certified auditors.
14 Q. Mrs. Ellis, who is a co-counsel in this 15 case wants me to cla ri f y and I think it's 16 appropriato. Is the corporato auditors for ERC 17 answerabic to ERC separate and apart from the full 18 Texas Utilities personnel?
19 A. Yes.
20 O. Okay. And are those audits going to be 21 made availabic at the conclusion of 7C?
22 A. It's my understanding that that 23 information will be made available at the 24 conclusion of our effort.
25 O. And what plan is in pla ce to respond to UNITED AMERICAN REPORTING SERVICES, INC, Dallas, Texas (214) 855-5300
56
, 11 findings such as Teledyne's,-that resulted in
.' 2 changes -to the program plan? Io that also covered 3 by Appendix G7
-j 4 A. I think we've got, again, several things 5 mixed up.
J 6 0. I ask you to cla ri f y them. You r -
, 7 cl a r i f i ca t ions have been very helpful.
t
' 8 A.- Appendix G covers the entire process of
-l 9 how the CPRT conducts its business to insure that 10 we do it in an orderly form and that we audit 4
11 ourscivos and so forth. Without going through all 12 of the detail s of Appendix G.
13 If a problem is reported through the NRC 14 to TU Electric and it has impli ca tions on ou r 15 pro g ra m , we're informod of it and we will take
, 16 corrective a ction and that arrective a ction will i 17 be in our re co rds , our files.
I 18 0. Is that the conclusion of your 19 cl a r i f i ca t ion ?
20 A. Yes.
21 0. I wanted to know what your program has 22 in pla ce to insure that prob 1 cms that you didn't i
! 23 identify, that someone el se identified, are not 24 repeated and are tracted and trended.
l 25 THE WITNESS: Can you read the l
I I
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l Dallas, Texas (214) 855-5300
4 97.
o 1 question back for me?
2 (Record read back).
3 A. There-is a t ra ck in g mechanism within TU l
i 4 Electric to-keep t ra ck of and tra ct to closure NRC ;
5 f ind ing s . _ The overview quality team who also i 6 audited my-operation or our operation also'has a
- 7 t ra ck ing list. And I believe that that covers all l
8 outsido sources.
9 0. All ri gh t . In October 1985 there was a 10 stop' work order put on ERC work, wasn't there?
L 11 A. Yes --
l 12 C. By the NRC?
i 13 A. No, that was a scif-imposed stop work, l 4
i 14 as I recall.
, 15 O. Okay. Fine, I'll accept tha t l 16 cl a ri f i ca t ion . [
17 With that clarification, it is a f a ct i 18 that in O ctober 1985 there was a stop work order ,
i 19 on ERC work, wasn't there?
j 20 A. An internally scif-imposed stop work, 1
1 21 yes. j i
22 0. All right. And that internally [
23 self-imposed stop work order resulted from a 24 finding by the NRC of prob 1 cms within ERC's work, l T
f 25 didn't it? i i
UNITED AMERICAN REPORTING SERVICES, INC, Dallas, Texas (214) 855-5300 .
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e
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.1.
96 l 1 A. Yes.
t 2 -Q. ERC did not find the problems in October 1
l
[ 3 1985, did they? !
i 4 A. I don't know what probicms you ' re 5 talking about.
6 Q. Well, you tell me what the problems were 7 in 1905 that resulted in the stop workLorder?
8 A. No.found some very minor inconsistencies 9 'in inspection recults between ERC inspectors and 10 NRC inspectors.
11 0. And you found those after the NRC went 12 out and did a follow inspection to you r inspectors.
a
- 13 using your check lists; isn't tha t correct?
14 A. Yes.
15 O. Okay. Now, at Bradewood a s in. il a r 16 occurence happened, didn't it?
i 17 A. I don't re call .
- 18 0. Okay. At th e B ra d ewood proj ect, isn't 19 it true that region three inspectors using ERC
, 20 check lists conducted an inspection, a follow-up 21 inspection, found problems and issued a major 22 inspection report about ERC's work at B ra d ew ood l 23 which required work to be redone?
- 24 A. I'm not aware of it. And ERC did not 25 have the inspedtors at B ra d ewood .
q UNITED AMERICAN REPORTING SERVICES, INC.
Dallas, Texas (214) 655-5300
s 99 1 Q. -Al1~right. I don't have the inspection 2 report with me r.o w . I will bring it if we= don't 3 finish your'doposition tomorrow because I'm sure 4 you know exactly-what-I'm talking about. I don't 5 want to trick you. This isn't a trick question.
6 I want you to understand where my question is 7 coming from. I'll skip tha t now at B ra dewood and 8 I will come back to it tomorrow or Friday, 9 whenever we pi ck up with you again.
10 So I want to now jump back to the 11 Teledyne inspection. When Telodyno did the trip 12 report and th e y identified the problems, had ERC 13 identified the problems that Teledyne did?
14 A. I think you have to define "problems" 4 15 for me.
16 0. You define "problems".
17 A. No, you define "problems".
18 0. All right. Teledyne made certain 19 findings as written up in their trip report.
l i For exampic, on page three of the 20 21 exhibit there is the statement; Following a 22 discussion on piping related problems, that says.
23 My concern is why wasn't the information in the 24 letter incorporated onto a revision to the d ra wing l
25 and why didn't this document be come 'a deviation i
UNITED AMERICAN R E PO R T I NG SERVICES, INC.
l Dallas, Texas (214) 855-5300 t .
!- 100-1 report. Okay. This is an example of a question 2 raised by Mr. Landers in his report, isn't it?
3 A. Yes.
4 Q. Okay. Now, this issue that Mr. Landers.
5 identified was not of concern to you, was it?
6 A. Again, I don't know where you're coming 7 from. You call it a problem now. It's an issue 8
8 and you ' re a sk ing me if -- if I was concerned i- ,
9 about it. I guess -- I don't know where you ' re 10 at.
11 0. All right. I apologize if I'm being 12 confusing.
13 Teledyne's report raises concerns about 14 the implementa tion of the ERC effort at the site 15 is that true?
l 16 A. Yes.
i 17 0. All right. The concerns that the 18 Teledyne report ra i se s were not concerns that were 19 identified by you r corpora te auditors ; is that 20 correct?
21 A. That's correct.
l l
22 0. All right. Now, I want to know why 23 those concerna were not identified by you r 24 corporate auditors. ,
'25 '.
A I think there are two reasona. One is UNITED AMERICAN RE PO R T I NG SERVICES, INC.
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101 1 when Mr. Landers and his team came in, they had 2 not reviewed our procedures as to how we would 3 conduct these eval ua tions.
4 0. What evaluations?
5 A. Safety significance evaluations.
6 And some of their concerns ' came about as 7 a result of tha t lack of knowledge. The second 8 set came ou t of what was, in my opinion, 9 differences in how engineers analyze problems.
10 Not --
you will not always get two engineers to 11 take the same eval ua tion approa ch, so we had 12 questions in terms of that kind of difference.
13 There was a third ca tegory. I will 14 apologize, I said initially two. There was a 15 third category where they found some minor errors 16 in cal cula tions and also, I suppose, in the 17 approa ch . I don't recall the specifics of all 18 their findings.
- 19 0. Now, you testified ea rlier that you made 20 changes as a result of th e information that was 21 shared with you from Mr. Landers at th e end of his 22 visit, do you re ca l l that testirony?
23 A. Yes.
24 0. Okay. What changes 'were they?
25 A. We called in some other senior people UNITED AMENICAN R E PO R.T I N G SERVICES, INC.'
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s 102 l 1 from Stone and Webster and conducted our own 2 internal review of all safety significance 3 evaluations that had been conducted up to that 3
4 point in time to determine if we needed to do any 5 rework or improvements, make any improvements on-i 6 any of th os e . We re-trained and discussed th e 7 issue with the personnel involved and without 8 going ba ck and checking to see what changes we may 9 have made to procedures, I cannot be more 10 specific. There were some changes in terms of 11 levels of review, of results. I can ' t re cal l the 12 specifics.
13 0. Okay. Who were the senior people from 14 Stone and Webster?
15 A. The team was headed up by Mr. Bert Shair 16 and I cannot recall the names of the other 17 personnel assigned.
18 0. How do you spell his last name?
19 A. S-h-a-i-r.
20 0. And what procedures did they use to 21 conduct the internal review?
22 A. That's all identified in a plan of 23 a ct ion that was attached to our corrective action 24 record and I do not recall the specifics of it.
25 O. All right. The CAR that you're UNITED AMERICAN REPORTING SERVICES, INC.
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103 1 referring . to is a corrective a ction request?
i 2 A. Yes.
3 O. And those are ERC correctivo action 4 requests?
5 A. Yes.
6 0. And at some point it 's you r testimony 7 you bclieve'that all those corrective action 8 reports will be.made publi c when the results of l 9 your work is complete?
10 A. Yes.
11 Q. All right. Why was Mr. Monty Wise 12 removed or did he --
or why did he Icave as 13 electrical review team leader?
14 A. I do not know, but he was not the 15 cicetrical review team leader, 16 0. All right. Was he testing?
! 17 A. Testing.
18 Q. Yea h . And you didn't have anything to
- 19 do with that?
20 A. No.
21 0. At th e time that the NRC issued SSER 13, 22 was there any changes made to the quality of 23 construction pro g ra m?
24 A. You're referring to 7 C?
25 Q. Yes.
UNITED AMERICAN REPORTING SERVICES, INC.
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LO4 1 A. -I don't believe so.
2 0. The co11cetive eval ua tion report th a t i s' 3 going to be published, would you briefly describe 4 the components of the co11cetivo evaluation 5 prog ra m? ' Do you know what I meant by the 6 collectivo evaluation report?
7 A. Yes.
8 0. Okay. I want to understand and you can 9 make reference to the program plan if --
and do it 10 that way. I want to understand what are the 11 components of the pro g ra m that results in the 4
12 co11 c e t iv e evaluation report.
13 A. Do you want to know general headings or
. 14 types of information that would be in that 15 report? Is that what you want?
16 0. Well, are you responsible for preparing 17 the coll e c tiv e evaluation report?
18 A. Part of it.
19 0. What part are you responsibic for
' preparing?
20 21 A. Tha t will deal with the adequa cy of the 22 OA/0C prog ra m.
23 0. All right. As to that pa r t of the
- 24 collective eva l ua t ion report that you are 25 responsible for', what information are you going to UN1TED AMERICAN REPORTING SERVICES, INC.
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105 1 rely on in reaching you r conclusions?
2 A. Data from all of the IS APS . All IS A */S 3 including 7C and those conducted by other review i
4 team icaders. That will include knowl edge of all 5 of our findings as ident.ified in Appendix E. And 6 knowledge of their recauses and any generic 7 impli ca tion s .
8 0. We were discussing before deviations 9 that didn't make it to deficiencies. Do those 10 deviations get considered?
11 A. Yes.
12 C. How?
13 A. If they resulted in a trend as 14 identified in Appendix E. I'm sorry to keep 15 referring back to that, but that's --
that's the 16 screen.
17 Q. And what about out of scope le observations?
19 A. If any of those resulted in a finding as l
20 identified in Appendix E, yes.
21 0. Now, does the co11 c e t ive evaluation 22 report get prepa red bef ore the site corrective 23 a ctions have been considered?
24 . A. No.
25 O. So the collective evaluation report UNITED AMERICAN REPORTING SERVICES, INC.
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106 f 1 considers -- strike that.
l 2 Where a' deviation has been elevated to a 3 deficiency report or an NCR and resolved in any 1
-l. 4 .ay, w whether it's use as is, design change or cut
, 5 it out and redo it, whatever the disposition is, 6 is it still considered in the collective F 7 cvaluation report?
8 A. Again, I have to go back. You lumped in 9 NCR's and -- into that combination of findings.
10 0. Uh-huh.
11 A. Appendix H -- I'm sorry, Appendix E 12 requires the project to respond back to us on 13 findings which are construction deficiencies, the 14 adverse trends, the unclassified trends, the 15 things that are called out in Appendix E. They 1 16 will be addressed in the collective evaluation 17 report.
18 0. What about UCR's?
l 19 A. Not unless they were resulted from one 20 of the findings.
21 c. Okay. We were using as an example 22 earlier regarding inspector ce r ti f i ca tions . So 23 that I understand this, I would like to go back to 24 this example. ,
'75 Hansel Exhibit 6 was a deviation report UNITED AMERICAN REPORTING SERVICES. INC.
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107 1 which resulted in a deficiei.cy being identified 2 is that correct?
3 A. Yes. A deficiency in accordance with 4 Appendix E.
5 O. Ri9nt. And did it also result in a 6- non-conformance report being written?
7 A. Nood to do more cla ri f i ca t ion.
8 0. Picace do because I'm missing something.
9 A. Ack your question again.
10 0. All right.
11 MR. EGGELING: It results in an NCR i
! 12 being written.
13 0. Did the ueviation report that you signed 14 on its way to the project result in a 15 non-conformanco report?
16 A. No, but it resulted in a pic co of paper 17 that's equivalent to a non- conf ormance report 10 within the TU system.
19 Q. Did it result in a correctivo a ction 20 report?
21 A. Yes.
22 0. Was this -- did this one, in f a ct , end 23 up as a CAR?
24 A. Yes.
25 O. Okay. When the coll ec t iv e evaluation UNITED AMERICAN REPORTING SERVICES, I N C ,.
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t, t 108 I 1 report is written, and I review that collective 2 evaluation report. will I see the results of your 3 findings as evidenced on Hansel Exhibit 6 in the 4 co11cetivo evaluation report?
5 A. Yes.
6 0. How will it be in there?
7 A. In this pa rticular case, which is 8 Exhibit 6, it will be addressed in the critorion 9 of Appendix D that would --
th a t deals with 10 inspector co rt if i ca tion. And I believe that tha t 11 is in critorion 10.
12 0. Of Appendix B7 13 A. Yes.
14 0. 10 CFR Appendix B?
15 A. Yos.
16 0. Okay. My understanding of your answer 17 is inconsistent with my understand 1og of a
'18 previous answer, so I'm going to have to ask some 19 clarifying questions.
20 I understood you to testify before that 21 the co 11 c e t iv e ovaluation report is not going to 22 include information that goes into the project NCR 23 process. That it will only include the 24 information that are findings, deviations, that 25 are not -- unclassified trends, it will only -
UNITED AMERICAN REPORTING SEEVICES, INC.
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109
. 1 include that information. But now I understand 2 that it's going to include this information that 3 is NCR or CAR information. Is the collective
, 4 evaluation report comprehensive for all 5 deficiencies, deviations and out of scope 6 observations found by ERC?
7 MS. GARDE: Simple question. I 8 just was trying to explain.
9 MR. EGGELING: The question doesn't 10 flow in the --
11 THE WITNESS: It's not a simple 12 question.
13 MR. EGGELING: You set up two 14 things then you asked a question that didn't 15 follow from cither one, if I understand it.
16 MS. GARDE: All right. Let me --
17 THE WITNESS : I think it's --
18 O. (L>Y MS. GARDC) I want to understand 19 what are the components of the collective I 20 cvaluation report. I do not understand by reading 21 the program plan and by your answers what the 22 collective evaluation report is coing to include.
23 I'm trying to understand that.
24 (Conference).
25 MR. FGGELING: Why don't you just UNITED AMERICAN REPORTING SERVICES. INC.
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- 1 try coing o f f _ th e record and tell me again what i 2 you r. 'probl em is.
3 MS. GARDEs- Off the record.
. 4 (Off-the record discussion)..
5 MS. GARDE: Let's go back on the 6 record.
7 Following an off the record discussion, 8 Mr. Hansel has g ra ciously agreed to repeat 'is 9 cl a r i f i ca t i on of what is going to be in the 10 collective eval ua tion report.
11 A. All deviations go two routes. One route 12 is directly to the project who, in turn, will ,
13 write a non- --
a picco of non-con f orman ce 14 paperwork on a one for one basis.
15 The other path that it takes, it's then 16 evaluated by our sa f e ty significance eval ua tion 17 group firar "ney ma k e a determination if it fits 18 th e screen for a construction deficiency as 19 identified in Appendix E. If it doesn't, then all 20 deviations in that population are then looked at 21 and reviewed to determine if they constitute a 22 trend. If th e y constitute a trend, we then look 23 to see if they fit the definition of an adverse
'4 trend in accordance with Appendix E or if they fit 1
25 the definition'of an unclassified trend in l
t l
UNITED AMtRICAN REPORTING SERVICES, INC.
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111 e Appendix 1 E.
2 Also consider to see if they fit the
, 3 definition of an~ unclassified deviation in 4 accordance with Appendix E..
5 All of those will th e n be discussed in 6 the collective eval ua tion report.
7 Q. Okay. Are the " th o s e " that you just 8 referred to all inclusive of tLe deviations that 9 was the sou r ce for what went to the proj ect and 10 what went to safety s igni f i ca n ce evaluation group?
11 Is it comprehensive?
12 A. All deviations are considered, but they 13 may not constitute a trend or one of the
., 14 classifications that I just gave you.
15 O. And if they don't constitute a trend or 16 on' . the classifications that you just gave me, 17 are they considered or referred to in the 18 collective evaluation report?
l 19 MR. EGGELING: Which question do 20 you want an answer to?
21 MS. GARDE: I thought it was one 22 question.
23 MR. EGGELING: "Consider" or 24 "referred to" is quito different. Tha t 's a 25 distinction he's clea rly drawing.
UNITED AMERICAN RE PO RTI NG SERVICES, INC.
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112 1 Q. Are they considered in the collective
!. 2 evaluation report?~
3 A. Define "considered" for me.
4 Q. They're considered --
all deviations are 5 considered in the process that you've just 6 described. If they don't n.a k e it to one of these 7 cla s s i f i ca t ions , do they not appear in the 8 collective evaluation report?
9 A. They will not appear in the collective 10 cvaluation report. They're all in our files, but 11 they will not appear in a collective eval ua tion f
12 report.
13 Q. And the classification is all done by 14 the SSEG people?
15 A. The SSEG people do the review for safety 16 significance. The engineer responsible for the 17 population and his lead engineer and the 18 supervisor of that group do the trending analysis.
19 And then they collaborate as required 20 with personnel from the safety s i gn i f i ca n ce 21 ovaluation group.
22 Q. And these engineers, are they site 23 engineers or ERC engineers?
24 A. They're ERC or our subcontractors.
25 '.O And the process that you just described UNITED AMERICAN REPORTING SERVICES, INC.
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113 1 is contained in the quality instructions and CPP's I
~2 that have been avail -- made available to CASE; is 3 that correct?.
4 A '. Yes.
5 O. All right.
6 MS. GARDE: I think it's a good 7 time to take a break.
8 (Recess taken).
9 Q. (BY MS. GARDE) Mr. Hansel, we're 10 resuming after a' break and we're just going to go 11 for about another half hour today, and I'm going 12 to ask you a line of questions that I think can be 13 finished in that time period and start with you 14 tomorrow morning. I hope I'm done with you 15 tomorrow morning in about an hour and a half to 16 two hours.
17 A. Fine.
18 Q. I asked you at the beginning of the 19 deposition on --
when you first came to the site l
20 whether or not Texas Utilities provided for you to 21 review a list of documents that included the MAC 22 Report, an INPO audit, a document entitled; The l 23 Lobbin Report. Do you recall me asking about l
24 whether or not you had been pr'ovided those 25 documents at the beginning of you r interface with
(
UNITED AMERICAN REPORTING SERVICES, INC.
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r 114 1 Texas Utilities?
, 2 -A. Yes.
3 0. Okay. Your testimony as I recall it was' 4 th a t -- at that time at th e first meetxng you were 5 .not provided those documents nor were-you provided 6 with those documents at the first site meeting.
7 Since that time have you been provided a 8 copy of audits or reviews performed by Texas 9 Utilities? I will get to the other ones in a 10 minute. Quality assurance audits?
11 A. Yes, i
12 0. Okay. Your answer was very hesitant.
13 And that won't reficct on the transcript so I want 14 to probe why you sound hesitant.
15 Let me ask this question; Have y7u 16 reviewed all of the annual Texas Utilities quality 17 assurance audits?
18 A. I have not personally. My personnel J
19 have.
20 0. Has ERC done that?
21 A. Yes.
22 Q. And in performing that review of the 23 audits, did you follow procedures set forth in the 24 various ISAPS?
25 A. Yes.
UNITED AMERICAN REPORTING SERVICES, INC.
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,. 115 1 Q. And will the results of y ou r review of 2 th o s e audits be included in.the results reports.
3 -that either have been issued or will be issued?
4 A. Yes.
5 I would like to clarify, either in the 6 results report or in the files.
7 0. Have you personally or has someone under 8 you r control or direction reviewed ex te rnal audits 9 starting with the management analysis company's 10 audits?'
11 A. Yes.
I 12 0. And has you r review of that audit been 1
13 incorporated into the results reports or the i 14 working files of the CPRT?
15 A. I believe so.
16 Q. Have you reviewed or have people under 17 your direction and control reviewed the Lobbin 18 Report?
l 19 A. Yes.
I 20 0. And is your answer the same as to 21 whether you r review of that will be contained in 22 the results reports or the working files?
l 23 A. Yes.
24 Q. Have you reviewed any audits by Cresap, l
l 25 McCormick & Paget?
i l
l UNITED AMERICAN REPCRTING SERVICES, INC.
l Dallas, Texas (214) 855-5300
4 116-1 A. I don't believe'so.
2 Q. Have you reviewed any'prudency' audits?
- 3 A. No.
4 Q. Were'you made aware of any?
5 .A. No.
6 0. Have you reviewed --
7 A. Well, I need to cl a ri f y that.
8 0. All right.
9 A. Only by reference in correspondence that 10 I get from the --
from the board or from the 11 attorneys.
12 0. Have you reviewed audits done of either 13 Brown & Root or Texas Utilities quality assurance 14 department by ASMI or ANSI?
15 A. Not total reports, but portions of 16 reports.
17 C. Who provided you the portions?
18 A. Brown & Root, i
l 19 0. Have you reviewed any of the a-n-i --
l 20 authorized nuclear inspectors audits or reports?
21 A. Again, only portions.
22 0. And who provided you those portions?
23 A. Brown & Root personnel.
. 24 0 ." Did you perform any audits of Brown &
l 25 Root's quality' assurance program in their Houston l-l -
L UNITED AMERICAN RE PO RTING SERVICES, INC.
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117 1 of f-i ce in regards to Comanche Peak?
2 A. No.
3 O. Did ERC. conduct any audits outside of 4 the CPRT work that it was cont ra ct e d to do?
5 A. No.
6 Q. _Did ERC provide any. review or evaluation 7 other than described in the program plan of the 8 corrective a ctions taken by Texas Utilities on 9 unidentified deviations, deficiencies or 10 non-conforming conditions?
11 A. No.
12 Q. Did ERC review any other evaluations 13 that I have not identified similar to the MAC 14 audit or the Lobbin Report from an external source 15 in consideration of the quality control or quality 16 assurance issues regarding Comanche Peak?
17 A. We reviewed those documents that 18 contained what we call external source issues tha t i 19 are identified in the pro g ra m plan.
I 20 0. Okay. When you says external source 21 issues identified in the pr o g ra m plan, you're 22 referring to the TRT -- the NRC reports and 23 information that went first to the TRT and then to 24 Texas Utilities?
25 A. No. Let me refer you to the program UNITED AMERICAN REPORTING SERVICES, INC.
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118 1 p l a n', I think is the best way to do this.
2 ~It's on page 1 of 49 of the pro g ra m 3 plan, revision 4 in the 4 th pa ra g ra ph . And it' 4 identifies the types of documents that were ,
5 included as ex te rnal sou r ce issues or reviewed'for 6 cxternal source issues.
7 Q. And does that definition incorporate the 8 ones that I have just asked you about spe cif i cally 9 as well as NRC documents?
10 A. It doesn't call those out specifically, 11 but it does include the NRC documents. I do not 12 believe that the specific documents that you've 13 mentioned like MAC and Lobbin Reports are called 14 out spe ci f i cally .
15 Q. I don't recall them being identified 16 spe cif i cally either. That's why they're on the 17 list to ask you. I know that there is definitions 18 of external source issues in the program plan.
19 A. They're called out --
the better list of 20 the ones that I was involved with are in 21 Appendix B.
22 Q. Okay.
23 A. On page 4 of 17 of revision 4.
l 24 O. All right..
'25 A. And it does include the MAC Report, l
UNITED AMERICAN REPORTING SERVICES, INC.
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k 119 1 Lobbin Report --
2 Q. Great. Can I look-at those? All 3 right. One of the --
one of the items identified 4 'is the ASLB proceedings. When you reviewed the-5 AS LB proceedings, did you review something that 6 the attorneys prepared for you to review? Or did 7 you review any actual documents?
8 A. I wish the first were true, but I read 9 most of the ASLB proceedings.
10 Q. Did you read cases, proposed findings of 11 fact and conclusions of law about the Wash Doyle l
- 12 allegations, 8/22/ 83?
I 13 A. I believe so, I'm not positive.
. 14 Q. Did you read the proposed findings of 15 f a ct and -- on harrassment, intimidation?
16 A. I read a summarization on harrassment, 17 intimidation from the lawyers.
18 0. Did you read the EG&G reports?
19 A. I have, yes. You ' re referring to the --
20 0. Harrassment and intimidation?
I 21 A. There were two panel reports.
22 0. Two panel reports?
23 A. Yes, I read those.
24 Q. Now, when you re v i e w~e d all of those 25 documents, were you reviewing them to find issues UNITED AMERICAN R E PO R ,T I NG SERVICES, INC. *
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4 120-1 to further investigate? Were you screening them 2 to pull out issues,that needed to be pursued?
3 A. Yes.
4 Q. Did you review them for any other 5 purpose?
6 A. Yes.
7 Q. And what was the other purpose?
8 A. Primarily for history, background type 9 information, what work had been accomplished 10 previously, by who, the results. General 11 information.
I 12 0. Some of the documents that we've been 13 discussing, specifically, the MAC Report, the 14 Lobbin Report reach conclusions about certain 15 inadequa cie s in the program at Comanche Peak. Did 16 you read th e s e reports to see if you agreed or 17 disa greed with the conclusory statements?
18 A. No.
19 Q. Okay. Did you consider their 20 conclusions or did you try to start from scra t ch 21 and exclude their conclusions?
22 A. We s ta r t ed from s cra t ch , really, in our 23 evaluations.
24 O. Did you review NRC inspection reports?
25 A. Yes, from January 1985 forward until .
UNITED AMERICAN R E PO R T I!;G SERVICES, INC.
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121 1 now. I :think , yes.
2 0.- The CPRT contains the phrase and I'm 3 looking at it .for reference, revision three page 4 13 of 45-of the program - plan principles. The 5 following; the CPRT will not perform inspection 6 cal cula tion s or designs of record.for CPSES. Are 7 you familiar with tha t statement?
8 A. Yes.
9 Q. What does that statement mean?
10 A. That we --
I think it's pretty 11 self-explanatory. Ne are here to conduct an 12 independent assessment and not to do TU Electric's 13 work. We're not the constructor or the designer 14 of record. We're not responsible for that plant.
P 15 O. . When you identify a deviation, is it 16 you r understanding and belief that that 17 id en t i f i ca t ion document becomes pa r t of th e 18 permanent record regarding tha t component or that 19 process?
20 A. And then the information from the 21 deviation gets transferred onto a piece of 22 non-conformance reporting form within the TU 23 system and they becomo a part of the records, yes.
~
24 C. So the ERC paper does not becomo part of 25 the permanent plant records?
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.- i.
122 1 A. I'm not.certain whether they - I'm sure
. '2 they retain it. I don't know whether they're 3 keeping them together.or'how they're maintained, 4 but I wouldLalmost bet ' tha t they have them.-
5 -MR. EGGELING: This might be a good 6 stopping point.
7 MS. GARDE: I think th a t 's a' good 8 stopping point.
9 (Recess taken).
10 31 12 13 ,
14 ,
15 1 16 ,
17 18 19
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123 1 CORRECTIONS AND SIGNATURE 2 PAGE LINE CORRECTIOM REASON FOR CH AIJG E 3
SEE ATTACHED.
4 5
6 7
8 9
10 I, JOHN HANSEL, have read the foregoing 11 deposition and hereby affix my signature that same 12 is true and correct, except as noted herein. .
l
' 13 14 OHN HANSEL ~\
15 16 >
/
17 18 SUBSCRIDED AMD SWORM to before me this the 1987. U
19 ____h_____ day of _ g_g _eq __ _E_
20 22 29&_
.OTARY PUBL C ID A!:D FOR Til E STATE OF TEXAS 23 24 My commission expires: _[ _ ] _Y O
~
25 UNITED AMERICAN REPORTING SERVICES, INC.
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r t
ERRATA SHEET f John Hansel Ii
( Volume I (October 14, 1987)
Page (line) Correction 11(2) Correct "Rawlins" to "Rollins" Correct "Winter, Park" 11(3) to "Winter Park,"
Insert commas after "Quality" 12(7) and "Reliability" 12(8) Correct "Appollo" to "Apollo" 12(10), (11) Insert commas after "Quality" and "Reliability" 12(12) Correct "Orbiter" to "orbiter" Correct "Oakridge" to "Oak 12(15)
Ridge" 13(21) and (23), 14(14), Correct "Bradewood" to
{ 15(10), 98(15), (18), "Braidwood" (22) and (25), 99(7)
Correct "Bryon" to "Byron" 13(25)
Correct "Kemny" to 15 (5) "Kemeny" 16(4) Correct "TG&E" to "PG&E" Correct "Fyker" to "Fikar" 17(6) 21(3) Correct "knew" to "know" 22(6) Correct "witness be" to "witness can be" Correct "any" to "anything" 24(15) 29(1) Correct "1D1 and 1D2" to "I.d.1 and I.d.2" 37(12) Correct "Mrs." to "Mr."
f 37(23) , Correct "utility" to "quality" M .
,k-*
- Page (line) Correction
( 39(15), (23) and (25), Correct "7C" to "VII.c" 40(9) and (16),-41(10) .
(11), (20), (21) and (25),
42(5), (12), (19),-(20)
'(22) and (25), 43(6), (18),
(20) and (23), 45(18),
48(18) and (25), 49(6),
50(25), 56(4), (15) and (21), 57(1), 58(3), (4),
(12) and (13), 59(9),
65(5), (6), (10) and (14),
66(10) and (22), 68(14) and (19), 70(22), 81(11),
95(21), 103(24), 105(3) 41(17-18), 47(10-11) Correct "Comanche Peak response team program plan" to "Comanche Peak Response Team Program Plan" 43(21), 47(7-8), 48(21) Correct "program plan" 50(20), 52(2), (18-19) to "Program Plan" '
and (25), 60(14), 65(10),
(13) and (15), 71(15), .
78(5), (9) and (10),
l 95(12), 96(2), 104(9),
109(21), 117(7), (19) and *
(21), 117 (25)-118(1),
118(2-3) and (18), 121(4) 47(15-16) Change to read "we've made '
certain that anything that we've done has been in accordance with the latest revision. In other words, when we complete our effort we will have complied with all requirements in effect at the time of completion (currently Revision 4).
52(1) Correct "as" to "are" I
68(20-22) Correct to read "This particular form is just one of many forms that record data in the evaluation ,
of a population".
Correct "response team" 71(3) to "Response Team"
/
71(10) and (11) Cetrect "1D1" to "I.d.1" l
l l
, 9
--,- - - , . . , ,~ , - , , - - - . - - - e, - ,
< - Page'(line) ' Correction
('
- 73(15)- ,
Correct "electric" to "Electric".
76(9) Correct "Appendix C" to "Appendix ~E" 88(1),!(2) and Correct "Brabison" to-(15), 89(3)= "Brabazon" 92(7), 103(1),-(3),- Correct "corrective action
- (4), (7), and.(8) request" to "Corrective Action Request (CAR)"
97(4) Correct "tract to" to "track.
to" 97(5) Correct "overview quality team" to."Overview Quality.
Team" 105(6) Correct "recauses" to "root causes" 116(14) Correct-"ASMI" to "ASME" 119(11) Correct "Wash" to "Walsh"
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7~ ,
124 1 . STATE OF TEXAS )
2 COUNTY OF DALLAS -)
-3 4 I, David B. Jackson, RPR, Certified Shorthand 5 Reporter in and for the S ta te of Texas, do hereby.
6 certify that, pursuant to the agreement 7 hereinbefore set forth, there came before me on 8 the 14 th day of O ct ob e r , A. D., 1987, at the 9 offices of Worsham, For s y th e , Sampels &
10 Wooldridge, Dallas, Texas, the following named
, 11 person to-wit: JOHN HANSEL, who was by-me, L
I.
12 pursuant to agreement of the pa r t ie s , duly sworn 13 to testify the truth and nothing but the truth of I
14 his knowledge touching and concerning the matters 15 in controversy in this cause; and that he was 16 thereupon examined upon his oath and his 17 examination reduced to writing under my 18 supervision; tha t the deposition is a true record
! 191 of the testimony given by the witness, same to be l
20 sworn to and subscribed by said witness before any l
21 Notary Public, pursuant to the agreement of 22 parties.
i 23 l
l 24 I further certify that I am neither attorney l 25 or counsel for, nor related to or employed by, any l
l l
l UNITED AMERICAN REPORTING SERVICES, INC.
Dallas, _ Texas (214) 055-5300 .
X 125 1 ~ of the pa rt ie s to th'e a ction in which this 2 deposition is taken, and'further that I am not a 3 relative or employee of any attorney or counsel 4 employed by th e pa r t ie s hereto, or f i na n c ia ll y 5 interested in the action.
- 6 I
7 In witness whereof, I have hereunto set my 8 hand and affixed my seal this 29th day of O ct ob e r ,
9 A.D., 1987.
10
. 11 Commission Expires:
1 1 December 31, 1988 - . /
! 13 CSR No. 67 2 ,,,, ,3A [,[ g g h _,,___
DAVID"B. JACK N, RPR, CM, CSR i 14 IN AND FOR THE S' TATE OF TEXAS 2414 N. Akard, Suite 600 15 Dallas, Texas 75201 (214) 855-5300 16
]
17 18 l 19 l 20 f 21 22 23 24 25 UNITED AMERICAN REPORTING SERVICES, INC.
D a'11 a s , Texas (214) 855-5300,
.