ML20136C178

Vol 1 of Transcript of 851105 Meeting W/Util in Granbury,Tx Re Facility Program Plan.Pp 1-122

ML20136C178
Person / Time
Site:	Comanche Peak
Issue date:	11/05/1985
From:	NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
To:
Shared Package
ML20136C157	List: ML20136C153 ML20136C167 ML20136C178
References
NUDOCS 8601030173
Download: ML20136C178 (122)

Text

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I TUGCO MEETING WITH NRC 2

CPRT Monthly Status 3

November 5-6, 1985 4

Tuesday, November 5,1985 5

Granbury, Texas 6

This meeting commenced at 1:30 p.m.

7 8

9 a

.10 11 1

12 VOLUltE I 13 14 15 16 s

17 IS e

19 i.I 20 8

21 2

22 23 21 25 Taken by:

Carmen Gooden, CSR, RPR November 5-6, 1985 5601030173 B51202

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wasna m eusec% c PDR y reoie

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PRES M :

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2 Vince Noonan John L. Hansel NRC ERC i

3 Annette Vietti-Cook Ron Klause 4

NRC Stone and Webster 5

Larry Shao M. J. Wise NRC WAI/CPRT-RTL 6

Jose Calvo John Nevshamal 7

NRC NRC/ Consultant 8

Bernard Soffell, Larry Chandler Battelle (NRC consultant)

NRC/OELD 9

Jim Milhoan Don Landers 10 NRC T61edyne i

11 Tom Westerman David Jeng NRC NRC j

12 Ed Tomlinson Terry Tyler 13 NRC CPRT Program Director 14 John Beck Wm. S. Eggeling TUGCO/SRT Ropes & Gray j

15 John Guibert Fred Leverenz

, I 16 CPRT/SRT I 8 Battelle (NRC Consultant) 17 John French

,f CPRT/SRT Don Lurie 18 NRC Tony Buhl

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19 CPRT/SRT Cindy Early

!j NRC 20 W. G. Counsil TUGCO Loren Stanley i,

21 NRC/ Consultant t

Howard Levin 2

22 CPRT/RTL i

Jim Gagliardo NRC 23 John Honekamp TERA Richard Bachmann 24 NRC/OELD 25 l

3 E. J. Siskin 1

Max Yost Stone & Webster NRC Consultant (EG&G) 2 David Garlington RLCA 3

Southern Engineering i

C. M. Jan 4

Jack Redding Gibbs & Hill TUGCO 5

A. M. Reiter R. A. Wooldridge Gibbs & Hill Worsham, Forsythe, Sampels 6

& Wooldridge J. D. Christensen 7

ERC S. S. Palmer 8

TUGCO W. E. Nyer Nyer, Inc.

9 Steve Karpyak TUGCO A. B. Scott 10 TUGCO Edgar J. Hee R. L. Cloud Assoc.

David Real 11 Dallas Morning News 12 David Fiorelli Texas Utilities John Finneran I

13 TUGCO W. F. Sullivan 14 Stone and. Webster Doug Timmins TERA Dennis Alexander 15 S&W/ERC i

16 Jim Bailey I

17 TMPA

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A. A. Patterson 1

I 18 Stone and Webster (ERC) sj 19 V. A. Hoffman i

Stone and Webster (ERC) r 20 Tom Gosdin 21 TUGCO 3

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22 G. L. Madson i

NRC 23 C. Hale 24 NRC j

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PROCEEDINGS

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2 MS. VIETTI-COOK:

My name is Annette Vietti-Cook, 3

and I'm the Project Manager for Comanche Peak with the 4

NRC.

Our director today is unable to make the meeting, 5

and he will be here tomorrow for the Applicant's 6

presentation.

7 This afternoon's public meeting is to provide the 8

NRC Staff an opportunity to describe the Staff activities 9

which they performed and the review of the Applicant's 10 Comanche Peak Response Team Program Plan.

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11 Our first presenter will be Josa Calvo, and he will 12 provide a brief overview of the Staff review of the 13 Program Plan and then discuss the status of the 14 activities in the Constraction Adequacy Programs.

15 The NRC Staff members will support this discussion -- Bernie Soffell and Ed Tomlinson -- by 16 e

17 describing the review in the specific areas of

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18 electrical, mechanical and structural.

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l 19 Tom Westerman from Region 4 will be presenting Staff I

i i 20 activities thac are being performed on site, and Jim

,a 21 Milhoan of Inspection Enforcement will provide a s

4 22 discussion of the activities being performed in the 23 review of the Design Adequacy Program.

21 Larry Shao is our last presenter, and he'll be 23 describing those activities that the Staff has performed l

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1 in the review of the Ebasco and Stone and Webster

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2 efforts.

3 So if you don't have any opening comments, we can

,f get started.

5 MR. BECK:

Go ahead.

6 MR. CALVO:

This is an overview of Staff review of 7

the CPRT Program.

What I'm trying to list here is the 8

Staff summary, everything that has been going on up to 9

now in the Comanche Peak project from the standpoint of 10 what the Staff has done or what all the parties have 11 submitted to the Staff and the Staff needs to consider.

12 The first thing that we have here-is a Staff summary j {

evaluation, and, as you know, we have 11 major concerns 13 14 which are identified.

15 The next item following that one is the Staff 2

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16 prepared detailed evaluation comments, and I wrote those i

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i 17 down in accordance with design construction and testing,

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Operational Readiness.

There were about 151 design e'

j 21 comments, 117 construction comments.

Those include 22 mainly here DSAPS and here is the ISAP's and also the 1

i 23 Self-Initiated Review.

21 With regard to the comments that we got from CASE

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and GAP, is about 83 programmatic comments and one i

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voluminous comment on welding ~.

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2 The ASLB also joined everybody with the comments.

3 They came out with 11 programmatic comments.

4 CYGNA came up with 184 comments, and mixed, mostly 5

of design.

5 If I'm to summarize everything that we've done up to 7

now, we've got some significant concerns at this time.

8 From both construction and design are the centerpieces of-9 those two programs, the homogeneous construction 10 activities and homogeneous design activities.

11 Also, one thing that is tied to both of those is an 12 auditable trail..It is our intention with this 13 construction activities to establish the methodology of 14 how those activities had been put together, the 15 instrumentation for establishing homogeneity.

It is the 16 Staff's intention to review, to audit some of those 3

i 17 activities to determine whether the methodology is j

18 consistent from one to the other.

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19 We must establish an auditable trail.

It is not ii 20 only important to us, it is important to everybody else i !

21 who follows to scrutinize what the Applicant has done, 2

22 what the NRC has approved, so at least we can have an 23 open communication so everybody will know what actually 23 went in reaching our final conclusion.

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23 Pending initial reviews -- and this may have been l

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7 4

I updated to now -- is the umbrella QA/QC.

I don't know

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2 whether we have received that one yet or not, but that's 3

still pending.

4 Let me go through the next one.

This is the 5

Construction Adequacy Review Program again.

The 6

resources that we are presently using to approve the 7

Program Plan, mostly the Program Plan, we had about six 8

NRC Staff,'and we've got about 13 consultants.

As you 9

see, they come from national labs, some from companies, 10 and some private consultants.

11 I want to spend some time on this one because this i

j 12 one is going to show the Staff perception of the

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Construction Adequacy Review Program, how the Staff looks 14 at the Construction Adequacy Review Program.

15 Now, from external source issues, these are the 4

-16 issues that started the whole thing.

A sample of that i

17 was, for instance, SSER No. 11, QA/QC.

That by itself

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18 has created a self-Initiated Review.

So in order to put

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your arms around all these external source issues and all 1

i 20 the Self-Initiated Reviews, a Self-Initiated Review it s

2r was perceived that it was.riecessary to encompass all i f 22 these external source issues.

So that thing was created 23 for that purpose.

21 We believe that the Self-Initiated Review is a P.

23 substantial effort, and we have estimated that there will A

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i be something about 500, 1,000 reinspections that need to

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2 ba done.

But it is still a very small percentage of all 3

the total number of reinspections that can be done, 4

possibly at the Comanche Peak Station.

5 The Staff believes that the Self-Initiated Review 6

can bound the generic implications, not only by past but i

7 also by future ones, and any future external source l

8 issues.

9 We're hoping that the main objective, the way the

.10 staff perceives the Self-Initiated Review it's going to 11 do, is it's going to bring it into focus and open any 12 significant' generic problems for installation of the 13 Comanche Peak.

14 I also believe that it will be a significant --

15 contribute to the overall final Staff conclusion of the 16 original source of the plant.

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17 Again, what is depicted in here is homogeneous

' i 18-construction activities, and we know we have about 27 i- $

19 populations, and I'm picking up one~of these_ populations l i 20 and call it "X" to illustrate what I'm going to say next.

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21 The way we look at this we've got a population that's l

22 made up of construction activities or work processes.

23 And what I'm presenting.here is what the Staff has done 28 for the last three or four weeks, how we went about 23 reviewing the homogeneity of those work processes or

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construction activities.

So this is just what we did.

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2 The first thing we did, we went to the, for the 3

given construction activity trying to determine whether 4

there was homogeneity in design in that particular 5

construction activity.

We went where they call a 6

homogeneity engineering level. -We looked at the 7

procedures.

We looked at the purchase specifications, 8

all the things in there for a particular population of 9

equipment, and we constructed what you may call some main 10 general attributes, hardware documentation.

11 Then we went further to the next level, and we said, 12 Well, the Craft personnel in here, they are not supposed 13 to discover documents.

It must be something that the

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14 Craft personnel is supposed to do to support an 15 installation for the particular items for this 16 population.

So we went to the vendor drawings and i

17 equipment packages, and we went through there and j

18 evaluated'for some selected populations where the 1 ;

19 requirements, where the installation requirements, were 5i 20 the same for all the equipment associated with this t

21 particular construction activity or work process.

Thac's 22 how the Staff went about ascertaining very fine, where 23 they agree with the establishment of the homogeneity 21 population.

25 One thing that we found out in discussing this with i

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the Young Hansel people was -- and I'd like to make that

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2 one, bring it to your attention, because when I finish 3

this up, we're going to establish lines of communication, 4

and I'd like to establish the basis for them at this 5

time -- was, if for any reason, when you have some 6

different requirements and those requirements, they are 7

supposedly different, and you say, Well, the reason we 8

are combining them into homogeneous construction activity 9

is because the same Craft performed, did this particular 10 requirement, with this equipment, the same for this 11 equipment as for the other one.

It was done by the same i

12 Craft, and then we will accept that argument only on the r

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basis that you will provide documented evidence that 14 surely it was the Craft, that'it was certified, but not 15 only that, that it did the actual equipment, the actual 16 installation of that equipment.

If that docu=ented 8

l-i 17 evidence is not there, there is no reason to argue any j

18 further, and we should establish another basis to reach a l

A 19 conclusion of homogeneity.

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20 Another argument that it will not appear that we i

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21 have wasted a lot of time and appear that we will not l

l 22 entertain anymore the fact that it was done on~ plywood.

23 We will not accept that. argument in the future when we 24 analyze the homogeneity population.

25 Let me go back to the previous slide.

Wait a

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minute -- I didn't quite finish with this one.

So in

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2 this particular population happens to be electrical one, 3

this activity, for instance, could be free pulling, this 4

can be pulling, and this can be termination.

And so if 5

it would be pulling by itself, we accept that as 6

homogeneous when it's one design activity, the same 7

attribute; pulling would be the same thing, they got the 8

attributes, and so far it's off.

If we found out that 9

there appears to be that it was no homogeneity in some of 10 the work activities, then another must begin right here 11 for that purpose.

12 To give you an idea how the samples are selected for 13 the work construction activities, the work processes, if 14 I've got activity 1, 2 and 3 -- this one, this one, and 15 here -- and I select, for instance, it happened to be the 16 same thing that you selected, TUGCO selected, 60 i

h 17 equipment items for one, if our 60 equipment items that i

18 are selected for this activity, 40 of them happen to have 19 some attributes that pertain to this one and 20 out of

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i 20 the 60 have the same attributes that correspond to this i

e 21 one, you set it up on the plan and you put the C

22 scaffolding to do it, you actually will be killing three 2.1 birds with one stone insofar as having all these l

l equipment items in there.

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23 Now, when you come to this activity right here, you t

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fill it with No.1 because you took care of all the 60;

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2 and when you come to No. 2, you are going to give 40, so 3

all you got is.20 more to go, and when you get to -- in 4

this case you happen to find out of those 20 you selected 5

20 of those also have some of the same attributes that go 6

to activity No. 3.

So when you go to activity No. 3, 7

you've finished with 1 and 2 because you got your 60, 8

quarter, and the only thing that is left is 20, 40, plus 9

20 more to give you the 60.

But when you count the 10 actual number of the equipment items used in the 60, 60 11 and 180, you only use the 60, 20, 20 and 100.

So 12 depending upon how the equipment that you selected 13 originally happened to include the attributes pertaining to the activity is how many items you happen to sample 14 15 for'that given population.

16 Now, keep in mind, if we truly believe in the l-17 concept of homogeneity and you accept the fact that j

18 you've got homogeneity here to some kind of original f

level, then it doesn't make any difference whether'you 19 i

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20 review one item or whether you review -- you have a 21 choice, reviewing one or reviewing 100 percent.

But even s

22 if you accept the fact that you want to review 100 t

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percent, even if you embark yourself on that effort, the

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question always comes that you truly cannot review or 2

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inspect 100 percent because you find out the equipment is i

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inaccessible.

Even with the thought in your mind that

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2 you want to do as many as you can, you, at the end when 3

you finish, you have to reach a conclusion.

What is my l

4 inference basically?

On as many as accessible, what 5

inference is made to the ones I had not been able to be 6

accessible to?

So somewhere between one and 100 percent.

7 I guess the Young Hansel program for the Design 8

Adequacy Review Program selects a number system.

Now, 4

9 whether it is random' statistic sample or not, it's a 10 good -- the way the Staff perceives it, it happens to be 11 a good mechanism to select the original initial sample 12 and also sets up a good criteria to tell you what one J

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13 must do when you find failures or rejections in the first 14 sample.

It also says the overall criteria, how many i

15 failures you expect to have before you go through an 16 overall review of the whole populations.

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17 So the Staff at this time neither accepts nor j

18 rejects the sampling of the 95 in using the statistical

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19 basis sample as that is going to provide some random I

20 selections of equipment on the plan and establish a good 21 mechanism with a good criteria for expanding the samples s

i 22 and for finally coming up to an overall sample depending 23 on the failures by reviewing the whole population.

l I guess the other thing I want to talk about is what' 23 e

all the information is that's availaole to the Staff, in 23 l

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addition to the effort for the self-initiated to reach

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2 the overall\\ reasonable assurance.

So we've got external 3'

' source issues that trigger the Self-Initiated Review.

TheSelf-Initiated Review establishes the mechanism for 4

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selecting the first group of items, establishes criteria

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6 for expanding the selection and establishes for the i

7 criteria to tell what to do in case you find too many 8

failures on the sample.

9 So that's an input to the overall information 10 available to the Staff, so at the end I come out with a reason,able assurance about the adequacy of this plan.

11 We've got the inspection report of the Site Inspection 12 13 Team.

We've got the Construction Assessment Team.

We've 14 got a special Review Team.

We've'got a Resident 15 Inspector Report.

I go on down the line here, and also keep in mind that I've also got to pick up original 16 i

17 testing.

I de a lot of testing through the plan.

Also, j

18 for the last three years I also got a technical apecification surveillance and testing for the plant.

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,The Staff is; going to look at the good.

It's' going

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. 2t to look at the bad.

It's' going to look at the ugly.

And t

i 22 that, combined with the Self-Initiated Review, the Staff is going to come out with overall reasonable assurance.

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TheS,haff'isalsogoingtolook--whateveryoucome 25

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' 23 up with on the assessment of these things -- is going to i

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look at the corrective actions, what are the corrective

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'2 actions, what is accomplished, find out what was learned 3

from those corrective actions.

We considered the Self-4 Initiated Review a fairly substantial effort, but only 5

the Staff considers it an input in addition to this one 6

to come up with the overall reasonable assurance at the 7

end.

8 Now, I cannot say -- talking about the statistical 9

one, the Staff will accept the statistical random sample i

10 on some cases where the Staff feels comfortable with 11 homogeneity can be truly established.

To a certain, 12 maybe not true, but to a certain extent.

Samples of 13 that, I think you found those in the ISAP's as concerned

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with the SSER No. 7, I think having to do with the 14 15 terminations compared against drawings.

With true 16 homogeneity then, the statistical random sample, it will i

17 have some' meaning and' the Staff will use that one as

-l 18 another input to reach overall reasonable assurance.

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19 Also, the staff will use the humility results of

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'k 20 all -- brought'up from -- from the standpoint of this

'l Self-Initiated Review the humility results that it had 1

22 been highlighted in all the disciplines.

It is not a 23 single discipline by.itself that tells you something.

It 24 is the combination of all the disciplines toward the end 23 result.

That put together also will be a significant

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input, that it will be factored into the reasonable i(

2 assurance.

3 Keep in mind that always there's going to be that 4

isolated case.

It's going to be a case that somebody had 5

forgotten about, but we hope that it's only going to be 6

an isolated case.

And also we hope if it's an isolated 7

case that_it is revealed sometime after all this is 8

finished.

Keep in mind that we've also got redundant.

9 independence.

So it is a very low probability that we 10 find a problem on one piece of equipment and also find 11 the same thing on another piece of equipment.

12 So this is-the Staff parception.

This is the way 13 the Staff sees and is going to use the Construction 14 Adequacy Review Plan and is going to put it together in a 15 package so at the end, we finally reach a conclusion 16 about the reasonable assurance for this plan.

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17 Now, before I go to the next slide, I want to offer ij 18 a challenge to the Senior Review Team.

We had, as I 19 think I indicated before, one of the centerpieces of the i

20 Construction Adequacy Review Plan.

Our audits indicated

..i 21 that it was -- also the raw material was there, the 22 documentation was there.

A very significant part of it, 23 j it was the justification of how all these attributes were 21.

put together to come up with this reasonable homogeneity.

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l So the challenge that I'm offering to the Senior Review 25 F

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17

'l Team and also to Young Hansel, who I think is doing that

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2 right now, is going through these narratives, 3

establishing the justification that shows the original 4

homogeneity.

When they are finished, we will come here t

5 one more time and we will review the contents of this 6

package.

We audit three or four more to make us feel l

7 comfortable, and then from that point on we are ready to S

write our SER on the particular subject.

That's the 9

challenge I offer to the Senior Review Team.

10 Let me tell you what we have done.

We have had some audits with the Construction Adequacy Review Team October 11 I

12 9 and 10, 1985; audits October 16 and 17, 1985; and i

13 and es October 28 through 31.

Following me is going to be some independent reviews of what actually happened i

14 15 during those audits. _In the electrical, Mr. Ed Tomlinson l

16 will talk about, give you an overview of what is the l

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17 Paper trail, what is the documentation available, used by the Staff and used by the Program Plan people, to

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19 establish homogeneity.

i 20 Then mechanical and civil / structural, I understand t

21 they're going to be combined together.

I understand that t

22 rebar is not yet ready.

It was late arriving from the l

plant, so Bernie Soffell from Columbus, Ohio, will be 23 33 !

taking care of this.

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Now, let me give you a little quick view of what 1

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we're finding so far, a summary of preliminary findings.

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2 Hardware populations cat'egories evaluatio'n is almost i

3 complete.

We look like 27.plus or minus more hardware.

4 I think we're very close to reaching a conclusion.

It 5

appears that for all practical purposes concept of the 6

categories appears to be approaching an acceptable point.

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7 The evaluation of homogeneity of construction activities i

S is not yet completed.

We're hoping that after a11'these 9

narratives are done, we come over here and we finally t

10 look at them.

I'm looking into the future and based on 11 what we see, it's going to increase in construction b

12 activities, it'll be more than a 70 that is specified at 13 this time.

And one thing, another point, is that we have

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4 14 to have a better auditable trail.

15 Now, future activities:

possible one more audit after auditable trail is established for all homogeneous 16 i 1 17 construction activities, preparation of audit reports,

' j 18 review of the responses to Staff questions, and 4

19 i

preparation of SER on the CPRT Construction Adequacy 3

20 Program Plan.

i l 2 The next slide that I have, it's nothing related to l

21 23 the Program Plan, but it has some impact on the Program f

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23 Plan because those are external source issues.

I give I

you just a little preview of what is coming.

Insofar as

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23 the electrical instrumentation allegations, SSER No.'7 I

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_.. _, _, _. _. _. _...., _ _ _ ~ _ _ _.... _ -. - - _... _ _ _.. _ _ _,. _,...

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I was issued sometime back.

Now, we have in here

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2 additional allegations that we are continually evaluating i

3 every day and we had found some of them that we felt i

4 required - that were not encompassed by our umbrella of 5

the generic boundary that we put around it.

l 6

We found that the Category 1 Electrical Cable 7

Terminations, we found two new allegations.

One had to 8

do with wire undersized that had to do with fire 9

protection cabinets that is under evaluation.

We may 10 have some actions, but we're not quite sure at this time.

11 We're still evaluating.

12 We are evaluating another allegation about splices.

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We feel that we've already covered that subject and no 14 further action is required.

i Now, with regard to Category 5, Electrical Non-13 Confor=ance Report Activities, we've got a new allegation 16 i

17 having to do with class one meters.

It's under i

is evaluation.

I believe it was Juanita Ellis that brought i ;

19 it to our attention some time back.

It appears at this

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20 time based on preliminary evaluations that it has some I i 21 merit and there will be some action required.

We'll know l

l more in a couple of weeks when we issue the SER.

22 23 There were three previous allegations, new I

., 3 informaticn, cable penetration seal.

We're looking at 25 it.

No action required.

It could not be substantiated.

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Traceability of "Q" items.

No action required.

It

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2 could not be substantiated.

3 Rework on terminal block.

We looked at it and we 4

feel it has no merit.

I'm sorry -- we looked at it, and 5

that one is still under evaluation.

There is some 6

procedural problem that has not quite been established, 7

so that may or may not -- it's a 50/50 that it may 8

require some action.

9 Category 7, Electrical Cable Installation.

One 10 previous allegation, new information.

Improper training i

11 of cables, no action required.

We checked it already and 12 we found out that it didn't agree with information 13

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provided by the alleger.

14 Category 9, Electrical Inspection Reports, 15 Inspection Removal Notices and In-Process Inspections.

16 One new allegation.

It has to do with the electrical 17 inspection repor?. were incomplete and improperly filed in i i 18 the vault.

No action required.

We found out we have no s'

19 problems with that one.

It could not be substantiated.

ii 20 i That completes my presentation.

I hope that I

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21 talked slow enough but I may have not.

t If anybody has any questions, I'd be happy to 22 l

entertain them at this time.

j 33 3:

I guess the next person to follow me is Ed.

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l 2.5,

MR. TOALINSON:

I'm going to discuss very briefly i

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what the Staff did on site visits on the 9th and 10th of

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2 October and the 28th to the 31st of October.

3 On the 9th and the 10th we looked at what was 4

available, and we have documentation for this 5

Construction Adequacy Program and made some comments and 6-requested that the Utility provide more information and 7

set a date to come back on the week.of the 28th to review 8

in more detail some specific populations.

9 The purpose'of the trip on the 28th was to review 10 the documentation associated with the Construction II Adequacy Program to determine that there was 12 documentation applicable to each population, that the 13 documentation was arranged in an auditable-manner; that is, that would allow a detail review of the development 14 of population, work activities, attrimutes and acceptance 15 16 criteria.

Thirdly, that the documentation include the i

17 rationale for determining homogeneity and the rationale j

18 for deletion of any specific attributes should that occur i

19 in the sampling.

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E 20 The activity centered around a general discussion of i

the documentation organization with the Applicants, and 21 z'

I 22 then the review of th1 documentation for populations 23 shown later on in the slides.

33 In the general discussion of all populations, the l

23 documentation included the definition of a population l

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boundary.

That, in general, is all safety-related

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2 systems and components (Unit 1, Unit 2, and Common) for l

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3 which installation is complete.

The documentation also 4

includes che sources for population sampling lists, and 5 ?

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~that is basically TUGCO and Contractor Management System 6

for specifications, drawings and equipment schedules.

4 7

Now, that's condensing it.

That's a fairly large list of

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8 documents actually when you get right down to it, but 9

those are the types of documents that we use in 10 establishing the population lists.

11 Now, in establishing the homogeneity of the work 12 process, we use the erection specifications by the 4

13 contractor, installation procedures, industry codes and 14 standards, and vendor instructions.

When we found a similarity in these things within a given work process, 15 this was the basis then for the homogeneity of that work 16 i !

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17 process.

Also, the TUGCO qualification for the j

18 inspection and test personnel; that is to say, all the t

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19 test personnel associated with that particular work I

s 20 process have to be trained and certified for that i

particular area in order to maintain homogeneity.

23 i

We next discussed then the attribute applicability,

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22 and the documentation. includes a des'cription of the l

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23 attributes.

It talks about acceptability of the attributes and what happens if in the sampling from the 3

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population list we come up with an item or attributes

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2 which are not acceptable, you cannot inspect it.

There 3

is a discussion of the frequency of the attributes, that

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is, how many times they are sampled.

And what will 4

5 happen, once again, it's because of a problem in the 6

accessibility, the frequency of the attributes sampling I

7

-is not reached, or the desired number is not reached.

8 Then finally, we have justification for attribute 9

exclusions once again, in case we have a problem up in 10 here.

11 Each package for each population should include 4

12 quality instructions, and within these quality

'{

13 instructions you have a reinspection checklist, a

14 documentation review checklist, accept / reject criteria.

There is also a reinspection / document review package 15 16 which includes the quality instructions, sa=ple list and 17 drawings.

And these are drawings applicable to the l

18 Particular population.

19 Now, after we had this general discussion and the i

li 20 Staff -- the group that I was working with -- reviewed 21 four electrical populations, we apparently left one off 22 the list here.

Included in this was instrumentation.

23 Findings and observations at the conclusion of our' l

2 review during that week were that very definitely there 23 is an auditable documentation trail associated with each

24 1

of the populations.

We found that methodology for

(

2 establishing the homogeneity of the work process appears 3

to be sound.

There's quite a bit of flexibility in it 4

because it provides for the expansion of the work process 5

and/or attributes, should it be required in order to 6

insure that we have homogeneity.

By that I mean that if 7

we -- for instance, in cable terminations -- if we find 8

that it's our view that 6.9KV terminations and 9

thermalcouple terminations are not the same, even'though 10 termination is a work process.

But the way the program 11 is set up, we can expand the attributes within the area 12 of terminations to include specific samplings for the 13 various types of terminations, and therefore we can 14 maintain homogeneity.

15 As of right now, our review is not complete.

There 16 are some more populations that are not covered, plus the i

17 Staff's, because we are not complete, our staff does not j

15 have an evaluation at this time.

But as Jose put it, we 4

19 will be having that at a later date, i:i 20 All the populations that we reviewed during that l

21 week -- and that's these three plus the instrumentation 1

22 l that I left out -- had the same basic documentation 2.1 package.

That is the package that I reviewed on the 23 first three slides.

All of those things were included in n

each population package, and as I indicated before, it I

25 1

does make up a very evenly auditable trail.

(

2 That concludes my pre:entation.

Are there any 3

questions that anybody would like to ask?

4 MS. GARDE:

I have a few questions.

What I 5

understood was that you looked at four populations --

6 MR. TOMLINSON:

That's correct.

7 MS. GARDE:

-- and you looked at the entire package 8

for those populations; is that correct?

9 MR. TOMLINSON:

Yes.

10 MS. GARDE:

Did this include just procedures and 11 forms or was it a completed package?

12 MR. TOMLINSON:

Would you define, please, what you 13 mean by a completed package?

I'm not sure I understand 14 what you mean.

15 MS. GARDE:

Each of the packages have quality 16 instructions and the reinspection document review i

17 package.

i 18 MR. TOMLINSON:

Yes.

19 MS, GARDE:

For the populations that you've covered, i

20 were you looking at reinspection checklists which have 21 been accomplished already?

22 l MR. TOMLINSON:

No.

I 23 !

MS. GARDE:

Because these were the procedures --

I I

2 MR. TOMLINSON:

We're looking at the documentation 23 that was available to determine what was included in it, I

i I

26 I

what references were included in it.

For instance, in

(

2 each of these packages there are procedures listed.

We 3

did not look at the procedures themselves.

We did look 4

at some sample checklists, yes, so we have not gone over 5

-- we have not done a complete review of the actual 6

inspections that have been done.

I'm not sure that's 7

within our purview anyway.

8 MR. CALVO:

What we're trying to do is, we're trying 9

to determine homogeneity, so we go through every 10 documentation that is needed to reach that conclusion.

11 How you go from there to implement it later we have not 12 touched upon.

That was outside our scope of activity.

13 MS. GARDE:

That was one of my questions.

14 You said the review is not complete, and all 15 Populations were not covered.

Has there been a Staff 16 decision whether or not all populations will be covered j

17 before approval is given?

l IS MR. CALVO:

We will establish the methodology used 19 to establish homogeneity.

We will assure that the I

i 20 auditable trail is there, that the narrative, the listing 21 of the attributes, the justification of what to use, and we're going to review enough of them to challenge their 22 methodology, determine whether they had done the right 23 21 job.

Trying to go to the detail that they go to, that i

I 25 will take a tremendous amount of time, because there are l

t

4

^

27 I

vendor drawings, vendor installations, vendors

(

2 everything, but we want to make sure that the auditable 3

trail -- we're going to go deep enough with enough of 4

them in main discipline so we know that it's there.

Keep 5

in mind that all the NRC does is auditing.

We audit the 6

Program Plan, and we want to be sure that the methodology 7

is there to make this a self-propelled thing.

As new S

things are learned, it moves by itself.

We don't have to 9

be on top of the Utility all the time.

We want to be 10 sure chat they themselves do what they are supposed to 11 do, that the methodology is in place to do it.

12 MS. GARDE:

So the program approval is going to be i

e 13 1 (

based on your looking at selected packages to determine 14 if the homogeneity is being put together in a way that j

15 you're comfortable with.

~

i I

16 MR. CALVO:

We're going to look at 'he structure of c

i 17 the plant, and we want the structure there to accomplish l

ts what the objective of the Program is.

~

19 -

MS. GARDE:

I have some more questions on that, but a

20 I'll hold them until later.

21 MR. TOMLINSON:

Bernie Soffell will talk to you on i

22 the mechanical area.

I 23 MR. SOFFELL:

My name is Bernie Soffell.

I'm with 21 1 the Battelle Columbus Laboratories.

I'm a member of the Mechanical Review Team, but I will be addressing both the l

23

28 1

mechanical and the civil / structural areas this afternoon.

(

2 Both areas are about in the same status of review.

3 There is a thread of continuity to any of these 4

presentations.

I'm going to focus on the mechanit:a1 and 5

civil / structural areas, as I indicated, but you need to 6

remember what Jose said and also what Ed just stated, 7

because the philosophy, if you will, the mechanisms of 8

the Staff's activities are very similar in the mechanical 9

and civil / structural areas as Ed just reported in the 10 electrical, and generically ac Jose already discussed.

11 In the mechanical area the following hardware 12 categories have been developed to represent the 13

{

mechanical areas, and we have reviewed to some extent 14 each of these as of this point in time.

We have looked 15 at at least the population descriptions for each.

To give you a feel for the population sizes, they 16

{

17 range in size from 8 items in the field fabricated tank l

16 area to something greater than 60,000 items in the pipe 19 weld slab materials.

I a

20 In the civil / structural area there is a similar i

t 21 division or categorization for civil and for structural.

22 I should point out that there is one population omitted 2.1 from this.

We should have one entitled equipment gi l supports.

Our review -- and Jose showed something Jimilar to this -- but our review really is working our 23

29 1

way down through this chart, if you will.

We started out

(

2 by looking at the categories, if you will, to make a 3

determination as to whether they totally encompassed 4

civil / structural activities or mechanical activities, and 5

are appropriately divided.

6 Once that is done, we then work our way down into 7

the work process area, and I will take you through an 8

example of one of the mechanical items to illustrate 9

better what is shown here in flow chart form.

Once we 10 work our way down through the work process level, we will then examine the attributes associated with each work 11 1

l 12 process, and we will make a determination as to whether 13

{

those attributes, the number of attributes, whether they 1

14 accurately describe the work process.

I should point out that in our review, again by way 15 16 of illustration, we may look at, for example, a Brown and

}

17 Root procedure at the work process level.

It may tell

[

is you how to install something or -- okay -- how to install

=

19 an item.

In the case of certain equipment, that

}!

20 procedure may make reference to a vendor instruction or t

21 specification, in which case, in order to evaluation the 22 attributes, you have to go down to another level.

You 2;I have to then look at a number of these vendor i

i

.y ;

instructions or specifications.

I This has a little bit more meaning if we take a look

'S t

30 1

at an example, and if you recall from the mechanical --

(

2 the first slide I showed you -- mechanical equipment 3

installation, the mechanical equipment installation is 4

one of the populations, and it involves three work 4

5 processes:

setting, anchoring, and for the case of 6

rotating equipment, alignment.

Bere is a good example of 7

where work processes -- a good example of what I perceive 8

goes into the establishment of the work processes.

9 Alignment conceivably could have been incorporated within 10 setting, and not distinguished between rotating or 11 passive heat anchangers, that type of equipment.

But 12 necause there is some special alignment that goes into r

13 installing rotating equipment, this was established as a N

14 separate work process.

And then there are attributes 15 associated with each of these work processes.

For 9

16 example, in the case of setting, there is the orientation 17 of the item of equipment, its levelness, its location, l

13 elevation.

In the case of anchoring, there is the 19 engagement of, for example, a threaded connection, the k

20 tightness.

And then in the case of alignment, there is

!i i l :

21 angular alignment, parallel alignment.

i !

i 22 so these are the kinds of things we are looking at i

i 23 as we dig down into the. implementation of this Program, 23 and it's the type of thing we look at when we look at the 23 vendor instructions or when we look at the TUGC0

~

~

31 1

instructions for installation equipment.

(

2 To date we have examined 6 examples of equipment 3

installations.

We have done this for the purpose of 4

establishing the perfectness of the work process 5

divisions and the attributes.

6 What is the status of our review?

To date we have 7

reviewed the population descriptions for all the 8

categories within the mechanical and the civil / structural 9

disciplines.

We have reviewed the work process breakdown 10 for each population, and we have reviewed sample 11 inspection packages and installation procedures to assess 12 work process homogeneity.

We have not gone down in each r

13 of these populations.

Mechanical equipment is one that I

(

14 can think of that has been addressed.

Welding has been 15 addressed.

Heating, ventilating and air conditioning has 16 been addressed.

And we're gradually working our way down

}

17 through this.

We have not reviewed any, the results of l

IS any inspections, or documentation reviewe.

We have also 19 reviewed the attributes of the work processes for their 20 applicability to the work process.

m 21 What do we see as the results of these activities?

22 Well, I have to say there's the possibility of some 23 additional populations that I think Jose alluded to, that gi as we dig into these reviews, there are some things that 25 we feel we'd like to see, we may like to see more focus

32 I

brought to.

There's a possibility also of additional

([

2 work processes and the addition of work process 3

attributes, and we, on an as-you-go basis, are discussing 4

those.

And as the implementation progresses, we may see 5

changes in any of these areas at any level.

(

6 Now, the goal obviously is by the time the packages 7

are completed and the reinspection is completed, that we 8

have agreement on the populations work process 9

categorization and the attributes.

10 That concludes my presentation.

I'll be happy to 11 answer any questions.

12 MR. CALV0:

I'd like to make some concluding 13 remarks.

The reason that today we took the lead --

{

i 14 instead of waiting for the Utility to come first and see 15 what they had to say and then we come second so we know 1

16 how to respond to what they've said -- the reason we took l

17 the lead is you've been telling us about the Program l

15 Plans, you been telling us about the Program Plans 19 action.

I feel that it is about time for us to tell fou oi 20 how we perceive how your Program Plan works.

l'oW, we go t

23 on the basis of what we told you that we would be 22 proceeding.

We've got to write evaluations.

We've got 2.1 to march ahead.

If we're wrong, you are proceeding on j

23 your own risk, because when we get to the end if you 23 don't tell us that we misunderstood, that's not the way

l 13 I

it is, then we're going to have to do things at the end

!l 2

different.

So I just wanted to make that concluding

]

3 remark.

If you see something wrong here, please, later 4

on tell us what is wrong and let's clarify it.

i 5

MR. WESTERMAN:

Tom Westerman, Region IV.

I'm the 6

Chief of the Region IV Grcup on Site.

I want to talk a a

j 7

little bit about the expansion program that we have under 8

way at Comanche Peak.

There is a normal program which is 1

9 the routine IE NRC program that's performed at all 1

10 Utilities.

The II Manual Chapter 2512's are standard.

j 11 Construction Inspection Program, we are essentially in 12 that program loaking at' Unit 2, since Unit 1, as far as

!j (

13 that program is concerned, has been completed.

We are s

f 14 following up on the issues that still remain open in the 15 2512 program in Unit 1.

We're about 50 percent into the 16 inspection of that program in Unit 2.

We also have the I

.{}

17 preoperational test program, IE Manual Chapter 2513.

!l l th That has essentially been completed on Unit 1.

We're

)

19 following up on the issues that still remain open there, a

20 We will be looking at that program again on Unit 2.

t t

21 2512, which is part of the testing program, we are t

22 starting to initiate the early parts of that on Unit 1.

23 The other kinds of. things that we look at, we look 21 at the IE Bulletins, Circulars, Information Notices, 2,

Actions.

We look at a part of the NRR Generic Letters

34 I

follow ups, and as I have mentioned, we have a number of

(

2 open previous inspection items which we are following up.

3 A large part of our effort is included in the 4

implementation of the CPRT Action Plan.

As a matter of 5

fact, I'll skip down here and show we have 10 Region IV 6 l personnel assigned to the Comanche Peak and 13 7

contractors.

We have approximately in the neighborhood 8

of 15 inspectors that are looking at the implementation 9

of the CPRT Program.

10 We also have the allegations that are the new ones 11 since September.

We also looked at some allegations that 12 are directed to CPRT.

They indicated the manpower at

{

Comanche Peak is in the neighborhood of 20 to 23 folks.

13 14 It's going to vary as time goes and the schedule is l

15 completed.

16 This is the organization as we have it today.

I i

}

17 report to the Division Director in Region IV for reactor ll 18 safety and projects, who in turn reports to the Regional f

19 Administrator, Region IV.

We have direct interface lineg i

a 20 with the Director of the Comanche Project, Mr. Noonan.

21 We also direct interface with the Office of Inspection

.t 22 Enforcement.

The Office of Inspection Enforcement, among 41 other things, performed.an overview as to the Program 21 that we're implementing at Comanche Peak.

23 I have also in my organization an individual who's l

l t

35 1

looking at allegations and Safeteam activities.

I have

(

2 an individual who is looking~at our project status to 3

make sure that we're keeping current status on our 4

inspection program.

5 I have a group leader assigned on site.

We have 6

reporting to him the Operations Senior Resident 7

Inspector, and there's also a second Operations Resident 8

Inspector under this group here.

We're looking at, of 9

course, the pre-op start-up testing and a part of the 10 testing program that comes out from the ISAP's.

11 I have a Construction Resident Inspector at Comanche 12 Peak.

He's basically looking at the 2512 Program on Unit

{'

13 2 and following up on the other open inspection issues 14 that have been there from the past.

15 I have a QA/QC Issues Team Leader assigned.

I have 16 a Civil / Mechanical Team Leader assigned, and an

{

17 Electrical Team Leader.

This group here is basically g

18 looking at the CPRT Program Plan implementation, and, of 19 course, contractor persormel are assigned as needed under ii 20 these folks.

21 I thought I would show a little bit in detail as to 22 what we're doing with our inspection of the CPRT Program.

l 1

23 We have a group under our QA/QC program who looks into I

gi the overall QA/QC Program, review and audit functions.

i We have done such things within that group as look at t

2.3 l

J 36 1

their objectivity reviews,.look at inspector

}(

2 qualification of those ERC individuals that are i

f 3

performing inspections and other assorted related i

4 activities.. We are looking at the impleme,ntation of the j

5 ISAP Program.

We are looking at the ISAP's as they are 6

presently being presented to Staff.

We will follow any i

7 changes that come to the ISAP's as we go along.

We do, 8

as a part of this, witness the inspections of hardware 1

9 that are done as a part of the ISAP's, as well as in our i

10 inspection program.

We will verify that each of the 11 actions called on the ISAP are being implemented.

]

12 We do this -- for example, the witness of hardware 13

{

inspection is a sample type that we're not -- we are l

14 auditing, we're not trying to look at 100 percent of all l

1 15 inspections performed.

i l

16 We will verify resolutions, corrective actions in 1

17 regard to deviations coming out of the IJAP's, and that i j is again is an audit-type program.

And we're also looking i

i*^

19 at the Final Results Report which come from the ISAP's j f 20 when it's completed.

We'll verify that the ISAP's, the 21 Result's Report, reflects the actions that we're taking on

. t i

. n.

the ISAP's.

l l

23 We have a program looking at -- and a large part of l

l gg our area is into this ISAP's VII.C which is a OA 1

l 23 construction Adequacy Program.

We're presently i

i

. _ _ -. _, _ _ _ ~. _ _.. _ _ _, _ _ _ - _ _.

._._,._-_.,._.__..-_-.____._._..,u..,._,_...--

.L

37 1

witnessin,g something over 10 percent of all inspections

(

2 of hardware being performed.

Inspectors are following 3

right along with the team.

They have already looked at 4

the procedures and whatever that are being followed.

5 They're auditing the overall part of that.

They are also 6

coming along behind the NRC inspectors and looking 7

independently at something right now in the neighborhood 8

of 5 percent of all inspections after they have already 9

been completed to see if our findings concur with theirs.

10 We are independently inspecting documentation that's 11 being looked at under the NRC Program, as well as verify 12 resolutions, corrective actions, regarding deviations.

13 We'll verify the final results of these.

14 Also as a part of normal construction, we will look 15 at site modifications that come out of some of these 16 other programs, such as esble tray supports, conduit i

17 supports or pipe supports.

We have done two inspections j

18 of cable tray support modifications, and we are also 19 assisting in the on-site engineering walkdowns as i

20 required.

We have had at our disposal other folks to

.j 21 assist us.

We have had, for example, Region I NDE folks

1. r 22 down to do some independent inspections of such things as 23 pipe support as-built inspections, cable tray as-built 21 inspections, and those are all part of our on-going 25 program.

38 j

1 I guess the end product of what we're doing will be l([

2 a monthly report.

It will be issued as a combine of all 3

inspection efforts as done by the Region IV group.

Other i

4 inspections not performed directly under the direction of j

5 the Region IV -- that's in regard to site -- will be 9

6 issued separately.

These are such things as emergency l

7 planning, health fitness organisations, and that type of 8

inspections.

We plan to take enforcement action on an 9

inspection-by-inspection basis.

They will come out as 10 part of the inspection report as they're issued.

The inspection report for. August has been issued.

11 j

12 In that report we had one violation, failure to write a

(

13 nonconformance report for conditions that were identified i A j.

14 outside of the particular inspection plan that was being i

j 15 performed.

We also issued two deviations.

We had 2 i

16 unresolved items and 36 open items,in the first report.

}

17 our second inspection report for september is in i

ll 13 type and, of course, our third report is in preparation.

lI 19 Do we have any questions?

1 I i 20 MS. GARDE:

On the first page you said that you were i !

21 working on implementation.

Inspections being performed

{

i l

22 include implementation of the CPRT Program Action Plan.

I 23 MR. WESTERMA!!

Yes, ma'am, as relates to the i

23 ;

Comanche Peak site.

23 l MS. CARDE:

What revision are you using?

(

l

39 1

MR., WESTERMAN:

It's the Revision 2, it's the

(

2 current plan.

3 MS. GARDE:

Would you please explain how the 4

allegations review is being done on the safeteam 5

allegations and who's doing it?

6 MR. WESTERMAN:

There has been an inspectior. done of 7

the Safeteam allegation that was a joint team done by 8

Region 4.

There were NRR headquarters personnel on that, 9

as well as IE headquarters personnel on that team.

10 MS. GARDE:

OI?

11 MR. WESTERMAN:

OI also assisted in that.

12 MS. GARDE:

Who is the Region 4 person that's in 13 charge of that program?

14 MR. WESTERMAN:

Glen Madson.

15 MS. VIETTI-COOK:

We have not issued the 16 inspection --

j 17 MR. WESTERMAN:

That report is yet to be issued.

l 18 MS. GARDE:

Now, you described the position of

~

19 project status.

What is that position?

}

s 20 MR. WESTERMAN:

That's an individual who's strictly 21 keeping track of -- I've got, for example, status of 22 where the ISAP's are or how far we are in our inspection 2,1 program on the example in the ISAP's, so we know what our l

21 current status is.

23 MS. CARDE:

Does that have anything to do with, or i

i

40 1

is it coordinated at all with the CASE load forecast

(

2 panel?

3 MR. WESTERMAN:

No, that's strictly information for 4

our own internal management so we know where we are.

5 MS. GARDE:

You have listed five different 6

positions.

Who is the group leader?

7 MR. WESTERMAN:

Ian Barnes.

8 MS. GARDE:

And who is the QA/QC Issues Team Leader?

9 MR. WESTERMAN:

Cliff Hale.

10 MS. GARDE:

Now, on the second to last page of the 11 handout, you said that the ISAP's, or the inspections 12 that you were doing on the CPRT Program implementation, 13 was a sample program.

14 MR. WESTERMAN:

Yes, ma'am.

15 MS. GARDE:

In auditing the program.

16 MR. WESTERMAN:

Right.

[

17 MS. GARDE:

What percentage of the completed work

[

18 are you looking at?

19 MR. WESTERMAN:

That's hard for me to -- we Ii 20 looked -- for example, we looked at one ISAP, the double I

21 skewed welds.

We looked at about 10 percent of the 22 completed inspections on other skewed welds.

But that's 2;j j not all that we will do under that specific ISAP.

We 21 will look at the other things that have to be completed as part of the ISAP'3, including the writing of reports t

f 41 1

of what's transpired before it has accurately been

(

2 portrayed in that Results Report.

We'll look at the 3

deviations and corrective actions that come out, that are 4

identified as a result of that ISAP.

We'll look at their 5

evaluations of generic implications.

6 MS. GARDE:

I don't understand what you're saying.

7 Are you saying that you're going to do a complete audit 8

of one particular ISAP, or are you just going to be 9

randomly --

10 MR. WESTERMAN:

We will do a 100 percent look at the 11 ISAP.

Within the ISAP where they do like a hardware 12 inspection, we will look at a percentage of those 13 inspections.

14 MS. GARDE:

You use the term " verify resolutions" 15 and " verify Results Reports."

What's the methodology 16 that you're going to be using to verify that?

17 MR. WESTERMAN:

Look at the actual records that are i

18 in the files on site to see that the kinds of things that 19 are described to be complete have been completed as far i

20 as the ISAP --

t 21 MS. GARDE:

Are you matching that with a walkdown?

i 22 MR. WESTERMAN:

Walkdown?

I don't know what you 23 mean by --

l MS. GARDE:

Are you going to go back and look at the y;

1 25 actual inspection, review any of these inspections?

l l

l

i 42

- 1 1

MR. WESTERMAN:

We are witnessing some of their

(

2 inspections on the ISAP's, which means we are essentially

)

3 doing the same inspection that they are along with them.

4 It's much more expedient for us to go along and witness 5

that.

6 MS. GARDE:.But you can't tell me what percentage of 7

those you're doing.

8 MR. WESTERMAN:

We have not set a percentage.

9 MS. GARDE:

Of those that you are not witnessing, 10 are you only doing --

11 MR. WESTERMAN:

Part of the problem is some of the 12 things had already been done before we got into this.

13 That's the reason I can't tell you that we're looking --

14 on every ISAP we're going to look at a percentage of the 15 inspections performed.

Some of these things were done 16 before we got there.

We will follow along behind and i

17 look at what was done, what inspections were performed, j

18 to see what action, whether we go out and independently 19 inspect further into that.

I 20 MS. GARDE:

Do you have an actual Program Plan 2

'I !

21 that's telling you.as your Region 4 effort what you're ji 22 going to do?

I mean, is there a document at Region 4 23 that tells that?

2-1 i

MR. WESTERMAN:

Yes, ma'am.

33 MS. GARDE:

Have you been auditing the pipe support l

t

~

43 1

reinspection?

(

2 MR. WESTERMAN:

We audited the pipe support 3

reinspection indirectly.

We had the Region 1 folks come in and actually go out and look at a sample of pipe 4

5 supports to see what the as-built condition was of those 6

supports, how they matched the as-built drawings.

7 MS. GARDE:

One last question.

When do you expect 8

the inspection report to be out:on the inspection done on 9

the Safeteam allegations?

10 MR. WESTERMAN:

I can say it's probably momentarily, 11 within probably the next four weeks.

12 MR. MILHOAN:

I'm Jim Milhoan.

I'm the Chief, 13 Licensing Section, Quality Assurance Branch of the Office 14 of Inspection Enforcement.

My section is responsible for 15 the NRC Integrated Design Inspection Program, as well as 16 overview of the Applicant's' Independent Design 17 Verification Program.

I'm here today to describe the IS Process by which the NRC Staff'will evaluate the Comanche 19 Peak Design Adequacy Review Team implementation of the i

20 Design Adequacy Program.

21 Prior to getting into that, I'd like to show a i

slide, briefly, on the background of the Design Adequacy 22 23 Program. EIt's one portion of the Comanche Peak Response i

24 Team Program Plan.

It contains three functional' elements which have been previously described in a public meeting:

23

..-,_._.--...w..

44 the external source issues evaluation and resolution, the I

l

(

2 self-initiated evaluation, the root cause and generic 3

implications evaluations.

4 The key to the Design Adequacy Program is the third-5 party review by the Design Adequacy Review Team which 6

reports to the Comanche Peak Response Team.

The Project 7

still remains responsible for execution of design bases 8

analyses and designs, the collection of information for 9

use by the Design' Adequacy Review Team, and the 10 implementation of corrective action.

11 The Design Adequacy Review Team structure is in five 12 key elements:

The civil / structural discipline, the piping and supports discipline, the mechanical systems 13 14 and components, electrical and instrumentation and 15 controls, and the last element, programmatic and generic 16 implications evaluation.

l 17 The Office of Inspection Enforcement will be

~

IS responsible for evaluation of the implementation of the

'i 19 Design Adequacy Program.

IE interfaces with the Director 8

of the NRC Comanche Peak Task Force in carrying out its i

20 t-21 responsibilities.

i 22 The next slide shows the steps that we intend to t

i 23 carry out to perform our evaluation of implementation of l

l 21 the Design Adequacy Program.

We have reviewed and i

l commented on the Program Plan and the discipline, 25 l

t

45 l'

specific action plans; and those comments were part of

([

2 the Vince Noonan letter to the Applicant.

3 We will conduct inspections covering Design Adequacy 4

Program reviewer qualifications, scope selection process 5

and the inspection checklists.

6 We will conduct inspections of the Design Adequacy 7

Review Team bnplementation of the Program Plan.

In this, 8

we will review the checklists used by the Design Adequacy i

9 Review Program Plan to assure the breadth and depth of 10 review are consistent with the Program Plan.

11 We will also confirm that the review is, like I said, being conducted in accordance with the Design 12 13 Adequacy Program Plan, and we will independently review

{

14 sone of the same calculations that are being reviewed by 15 the Design Adequacy Review Team.

The results of our reviews will be documented in Inspection Reports.

16 li 17 We'll also review the Design Adequacy Review Team lll 18 reports.. Activities will include selected reviews and l

19 inspections as follows:

We will determine if the design i*

discrepancies which have been identified by the Design i

20

{f Adequacy Review Teams are included in the reports.

We'll 21 22 make an assessment of the classification and evaluation of the identified discrepancies with respect to Safety 23 l

21 Significance, root causes, generic implications and

~

25 cor:ective actions.

We'll also make an assessment of the

(

46 I

resolutions of the discrepancies, including corrective

(

2 actions.

3 We'll look at how the team handled the generic 4

implications of the design discrepancies.

We'll also 5

review a sample of the background information which 6

supports the report to make sure that the report is 7

adequately supported by documented evidence.

8 Another important aspect is our verification of the 9

implementation of corrective actions.

We will document 10 those in an inspection report or an SSER input.

11 The Staff has organized its Review Team to parallel 12 the Design Adequacy Review Team, with one exception, that 13

{

exception being in the programmatic and generic 14 implications area.

That area' will be handled under our 15 IE Team Leader as a disciplinary' effort of all team 16 members.

I 17 The next slide, please.

The next slide shows an.

j IS organization chart for our evaluation of the I-impicmentation of the Design Adequacy Program.

We have a 19 i

20 team _ leader that reports to me, and our management

, i 21 interfaces with the Director of the Comanche Peak Task i

22 Force.

We have the four discipline areas with a 23 discipline leader identified in each of the areas.

All of our discipline leaders have commercial nuclear power 2-1 25 plant design experience, as well as the majority of the i

47 1

Team Leaders.

Nine of the Team Leaders have been on NRC

(

2 integrated design inspections or the IDDT Evaluation 3

Teams.

4 With respect to status of current activities, as I i

5 have indicated, we have reviewed and commented on the 4

6 Program Plan.

We are reviewing the methodology of the 7

Phase 3 Scope Development Process, and some of our 8

members have participated in site walkdowns related to 9

cable tray and conduit supports the week of October 7.

10 Other team members will be scheduled for site walkdowns 11 as they occur.

All team members have been to Bethesda 12 and have been briefed on'the Program Plan and are 13 reviewing the issues associated with it.

14 Last week we did conduct our inspection of the DAP I

15 reviewer qualification, scope selection process and.the 16 inspection checklists.

The results of that team h

17 l

inspection will be documented-in an inspection report, j

is With respect to future activities, we plan on

!1 19 inspecting the implementation of the Design Attitude s

i 20 Program once sufficient activities are_in process to =ake 1

21 a meaningful evaluation.

We'd expect that to be at_about l

E 22 the one-third point in the implementation of the Design 23 Adequacy Review Program.

As you can see, our activities l

24 in this area are not as far along as the other areas because the reviews have not been begun by the Design 25 i i

i

48 u

1 Adequacy Review Team.

(

2 That ends my presentation.

3 MS. GARDE:

Most of your comments are addressing 4

things that you're planning on doing in the future, and i.4 5

your last comment explained why.

When you do the 6

verification of the implementation of corrective action, 7

are you going to be using these people for the actual 8

field inspections, or are you going to be utilizing 9

Region 4?

10 MR. MILHOAN:

With respect to the design work, we'll 11 be using those team members.

Those team members have.the 12 design. experience necessary for review of the Design 13 Adequacy Review Team activities.

14 MS. GARDE:

Now, you said that you have reviewed the 15 reviewer qualifications, scope selection process and 16 inspection checklists, and that that would be provided in i

i 17 an Inspection Report.

Do you have an idea when that.

[

18 Inspection Report will be available?

19-MR. MILHOAN:

Where Team Leaders stayed back to 3'

i 20 write the report now, I would expect that llt would be

~!

21 available probably within four weeks.

It's dependent i

l 22 upon the current process.

23 MS, GARDE:

Do you.have -- I asked this of 24 Mr. Westerman -- but do you have a written plan of this l

in a lot more detail in terms of what you're going to do, 25 l

l

49-I how you're going to do it?

(

2 MR. MILHOAN:

There is an IE Management Plan that 3

has been supplied to Vince Hoonan.

4 MS. GARDE: -Thank you.

5 MS. VIETTI-COOK:

Larry, before you get started, why 6

don't we give the Reporter a break.

7 (A short break was taken.)

8 MR. SHAO:

My name is' Larry Shao.

I'm the Deputy 9

Director of the Division of Engineering Analysis.

I've 10 been drafted to be the Test Crew Leader on civil, 11 structural and mechanical piping.

12 Today I'm going to talk about two major subjects, 13 the reanalysis and requalification efforts of the piping 14 j

and pipe support and cable tray supports and conduit 15 supports.

l 16 We first cover the piping and pipe supports.

The i

17 Applicant is spending a lot of manpower on the reanalysis

\\ j 18 and requalification effort, I think in the amount of -

1 about four hundred man years, maybe because many concerns 19 i

20 have been identified by different parties such as the h

21 Intervenors, CYGNA, ASLB and the'NRC Staff in the design i

22 analysis of piping and pipe supports.

23 Stone and Webster have been contracted to do the reanalysis, and TERA is responsible for third-party 24 25 review.

~

50 1

NRC has a Piping and Pipe Support Review Team.

We

(

2 have three NRC members:

Myself, Dave Terao and John 3

Fair.

Dave Terao is the Lead Engineer.

We have many 4

expert consultants in this area.

From Teledyne we have 5

Don Landers and Bob Hookway.

From ETEC we have Paul 6

Chin.

From Engineering Analysis Service we have Vic 7

Ferraini and Bob Masterson.

8 All the consultants and NRC Staff have extensive 9

experience in piping and pipe support design for many 10 years.

11 The objective of this review and of this audit is to 12 make sure that the scope and the implementation of the 1

13 reanalysis effort is adequate.

The Staff intends to 14 perform regular audits of the Stone and Webster effort 15 with regard to scope, procedure and methodology.

We will 16 perform walkdown reviews, design reviews and also review i

17 hardware modifications.

[

IS So far we have reviewed and commented on the CPRT 19 Program Plan, and the comments are in Book 1 and Book 2.

! ii 20 We have also reviewed the draft CPP Number 5, which i

21 is our Field Walk Procedure.

We have made an audit of i

22 the Stone and Webster as-built verification walkdown, and i

i 23 we did that audit during the week of September 23rd, 1

7 2-1 We also have performed an audit of the draft procedure on the CPP-8, which is an engineering walkdown.

23 f

e v-,-..-,

nyr.

, -.a,

-m,-

e w.n-.n v.

,----,.--m

~.w--,v n -,r, e

,n..n.

I 51 1

-The engineering walkdown vill take place sometime in

(

2 November, and the Staff intends to perform the walkdown 3

together with Stone and Webster in certain areas.

4 We had several audit meetings at the. site and in the l

5 New York office.

6 So far as relates to this as-built verification 7

walkdown, the Staff sampled approximately ten porcent of 8

the Stone and Webster as-built walkdown for each of the 9

four attributes.

The four attributes are valve location,

.10 pipe support location, pipe support functions and valve 11 and support orientation.

12 The Staff found no significant deviations related to e

13 the three attributes.

The three attributes are valve

'(

l 14 location, support type and support location.

15 For the support and valve orientation, the Staff i

l 16 also confirmed the finding by Stone and Webster that

(

i 17 several supports and valve orientations exceeded their j

18 tolerance.

The corrective action by TUGCO is found to be 19 adequate.

I 20 In the last meeting the Staff also commented that as 21.

we got to other attributes, that 79 Bulletin, 79-14, E

22 should also be covered by other walkdowns to make sure 23 all the attributes in 79-14 are properly addressed.

r i

21 The Staff had to make an audit of the draft 33 procedure for engineering walkdown.

The engineering l

s

52 1

walkdown would take place in November, which is this

(

2 month; the Staff intends to make a walkdown on 3

November 14.

4 4

We looked at the procedure and we found the 5

procedure is adequate related to the interaction between 6

the piping and pipe supports which could potentially 7

impact the design and analysis.

8 After Stone and Webster issues the report, the Staff 9

will review the final report covering this walkdown.

10 These are general comments on what the Staff found.

The Staff has found that Stone and Webster has completed 2

11 t

12 so-called foundation work related to reanalysis and

(

13 requalification efforts.

s I

14 So far, all the concerns by the Intervenors, ASLB, CYGNA and the NRC Staff have been treated seriously by 15 16 Stone and Webster.

i i

i i

s f

a 17 Based on the review so far, we feel Stcne and j

is Webster. piping and pipe support seem to be a major step

.~

19 in the right direction to resolve all the technical i

i i

20 l

issues that have been raised by different parties.

=

l oj The Staff will continue to closely monitor the Stone

\\

i l

22 and Webster effort to make sure implementation is 23 properly done.

24 These are the near term efforts.

We will review the pipe stress analysis for as-built ASME Class 2 and Class k

25 t

53 1

3 piping systems.

We're going to look at the design

(

2 criteria for~ pipe stress and pipe support, and we're 3

going to look at the small bore piping.

These procedures 4

will.be available in the near future.

We anticipate the 5

engineering walkdown in November, and we wiil audit pipe 6

stress analysis ar soon as it's available.

7 I'm done with piping and pipe supports.

Any 8

questions 'n that?

o 9

MS. GARDE:

The only comment that I want to make is 10 that this is Mrs. Ellis' area, and she was not able to 11 come today.

I will tell her about this this evening, and i

12 if she's able to come tomorrow, I'm sure she'll have 13 comments.

If not, she said that she would put them in

' (r 14 writing after she reviewed the transcript.

15 MR. SHAO:

The is the cable tray support and conduit 16 support effort.

This is also a major effort on the part l j 17 of the Applicants in the amount of 800 man years.

Many 2

i is concerns have been identified in the design analysis of i*

19 cable tray and conduit supports.

Ebasco has been

'I 20 contracted to perform reanalysis and requalifications, and TERA is responsible for the third-party overview.

j 21 i

22 Again, we have a team of NRC members and consultants 4

23 to review the cable tray support and conduit supports.

I The NRC members are myself, Dave Jeng and Ron Lipinski.

24 25 Dave Jeng is the lead' engineer in this effort.

We have

f

_m 54 i

I consultants from Teledyne, Battelle National Labs, EAS

(

2 and Battelle Columbus -- Mr. Soffell and his company.

3 The objective again is to make sure the scope and 4

the implementation of the requalification effort is 5

adequate.

6 Wa will perform regular audits of the TUGCO effort 7

with regard'to scope; procedure and methodology; we will i

8 perform walkdowns; we will review testings; witness 9

testings; we will perform design reviews; and also review 10 hardware modifications.

11 We have reviewed and commented on the cable tray and 12 conduit support program as described in the Program Plan.

f' 13 We have had several site inspections and audit

(

i 14 discussions with the CPRT Project Staff and their 15 consultants.

We have observed on-site conduit support I

i 16 tests.

We have had several discussions with the TUGCO i

i 17 and Ebasco Design Verification Staff in your office.

We j

18 are in the process of reviewing their conduit and cable 19 tray test specifications.

=

Ij 20 Two on-site tests were observed.

One is our single s

21 conduit with a single strap.

The other one is our i

22 junction-box.

We found that in both tests the failure loads exceeded the minimum specified design loads.

23 21 We have participated in two plant inspection trips 23 to observe cable tray and conduit supports.

We have

= - - -.

55 I

performed audit discussions with TUGCO project on cable

(

2 tray and conduit support related to methodology, 3

acceptance criteria,' basis for sampling and tests, f

4 We also provided some preliminary comments about 5

adequacy of scope, a sampling basis and analysis details.

6 We also discussed the dynamic analysis methodology, 7

especially in the area of damping, modeling and the load 8

combination areas.

9 This is a long list of specifications we are in the 10 process of reviewing.

I'm not going into a detailed 11 discussion of them, but we are in-the process of 12 reviewing these specifications.

13

{

We are also reviewing these specifications related 14 to the conduit support.

We will review these as-built u5 procedure for developing as-built drawings.

We will 16 sample as-built drawings to make sure they are right 17 against the construction.

We're going to review the j

18 design verification procedures.

We will sample some

~ i 19 analyses and check against the procedures used.

We will i

'E 20 also perform a few walkdowns to verify implementation of t

2 21 modifications.

22 In the conduit support area we're also going to 23 review the as-built drawing, which is being developed.

1 23 We will sample as-built drawing and check it against the 23 construction.

We'll review the sampling and analysis y __ _-_

56 I

procedure, and we'll sample some analyses and check

(

2 against the procedure used.

We'll also review their 3

modifications.

4 These are in the testing area.

ANCO is doing some 5

cable tray support testing, and CCL is doing conduit 6

support testing.

We will review their testing 7

procedures.

We will visit the testing site to inspect 8

and witness their tests, and trips are planned in 9

November and December.

We will review their test

.10 reports.

11 I think this is the status of what the Staff has to 12 do.

i 13 MS. GARDE:

I have some questions.

There is an

{

14 awful lot of reference to discussions and on-site inspections, and I'd like to go through them and have you 15 l

l 16 tell me when these were, whether they were public

{

17 meetings, whether they were during your site visits or at j

18 some other time.

Can you look at Page 3 of your Staff a'

19 Reviews completed?

li 20 MR. SHAO:

These are many audit-type discussions.

2 21 MS. GARDE:

All right.

When you say " audit-type 22 discussions," are you' talking about during your on-site

(

23 visits?

3.g MR. SHAO:

During on-site visits, talking to the l

25,

Staff --

I

. _ =

)

57

_ j 1

MS. GARDE:

Can you identify when these were?

(

2 MR. SHAO:

That.was sometime in September --

3 MR. JSNG:

The most recent was October 7.

4 NS. GARDE:

You did all of these on the 5

October 7th --

l 6

MR. JENG:

No, there was one --

7 hR. SHAO:

We made a trip in --

8 MR. JENG:

-- September.

I've got to check the 9

exact date of the first one.

I would like to comment to 4

10 you on the first one to date.

11 MS. GARDE:

Okay.

And than the rest?

When was the j

12 discussion with TUGCO and Ebasco Design in the Ebasco 13 Design office?

14 MR. SHAO:

That was a week from last Friday -- when 15 was that meeting?

It was a week from coming Friday -- a i

16 week from last Friday.

17 MS. GARDE:

And then on -- I think it's the fifth i

j 18 Page -- On-Site Inspection and Audit Discussion,

" Participated in two plant inspection trips..."

Were 19 k

i 20 those the inspection trips in October?

21 MR. SHAO:

No, it was September.

22 MR. JENG:

These are the same dates as the --

23 MS. GARLE:

Okay..Now, you said, "Provided Staff 21 comments.about the adequacy of. scope, analysis details 3

and sampling basis.'

Was that in the form of an exit 2

58 I

interview?

k 2

MR. SHAO:

These were very informal.

3 MS. GARDE:

At the end of these inspections?

4 4

MR. SHAO:

After we gave them some preliminary 5

comments, because they don't have a feeling -- we only 6

would comment on their procedure.

7 i

MS. GARDE:

On the Planned Staff Efforts, the last

~

8

~

three pages, you say " Review as-built" -- I think it's 9

"as-built procedures" --

10 MR. SHAO:

What it means is there's procedure 11 they're going to -- they're making as-built drawings from 12 construction, so we're looking at a procedure how to --

13

{

MS. GARDE:

The procedures that they're following to 14 make the as-built drawings.

15 MR. SHAO:

Yes.

1 16 MS. GARDE:

And have you done that yet?

h 17 MR. S3AO:

We are in the process.

We had a meeting

[

18 a week ago and we intend to send some more people.

19 MS, GARDE:

What percentage of -- I assume this is i

i 20 an audit-type function --

j 21 MR. SHAO:

Yes, audit-type function.

1:

22 MS. GARDE:

you know what percentage of the

(

23 as-built drawings for the procedures that you're going to

'i 21 look at?

25 MR. SHAO:.We are going to look at all, but try to 1

i 1

l 59 1

understand the general procedures; but we will not look

(

2 at every drawing.

The procedures, we will look at all.

- 3 MS. GARDE:

You'll look at all the procedures.

4

.MR. SHAO:

Yes, all the procedures.

5 MS. GARDE:

Who is doing this review?

Is it your 6

team?

7 MR. SHAO:

My team, yes.

The second group, that 8

team of people.

9 MS. VIETTI-COOK:

The Staff has completed their 10 presentations, and these are the activities that the 11 Staff has been performing in the review of the Program 12 Plan.

As Jose said, this is where the Staff perceives r

13 they are on our review of the Program Plan, and if for

(

14 some reason you heard something here that might not be 15 correct, please correct us in your presentations.

16 Before I turn it over to you, John, and your s

j 17 presentations, I'm going to ask Billie if she has any j

IS overall comments that she'd like to make on the Staff 19 review.

I 20 MS. GARDE:

Just a few, and as Mrs. Ellis is not g

here, these obviously don't include any that she might' j

21 ;

s 22 have after I share these things with her.

23 i First of all, I want to make it very clear that CASE 21 has not changed their position that a 100 percent I

l 23 l reinspection is necessary.

And,. Jose, we can debate all 1

l t

l 60 I

day that you can't really do 100 percent because they're

(

2 not 100 percent accessible, but we feel that any type of 3

sampiiny program is going to have flaws.

We've talked 4

about this before, but I want to make it very clear that 5

we're not going to be comfortable with the cutbacks that 6

you've done from 100 percent to some varia*. ion of a 7

random sample, or by a sample approach, un.til we've been 8

able to see the checklists and the elements of the 9

homogeneity classes that you nave approved.

We have 10 asked for these things in discovery from the Applicant 11 and under the Freedom of Information Act from the Staff, 12 but I want to reiterate on the record that we want to sit r

13 down, we want to look at the attribute checklists, which

(

14 in my opinion are the most important cornerstone of 15 whether this program is going to be successful.

And we're willing to do that almost under any conditions, 16 i

i 17 whether it's at the site, we makes them available in the j

is office in Dallas, or whether the Staff makes them 19 available.

Until we're able to sit down and look at I

20 those things, we're not going to be able to have enough h'

information to agree or not agree with you intelligently 21 r

22 on your conclusions.

23 Those are the only main comments, overall comments, 24 that,I have at this time.

33 MS. VIETTI-COOK:

John, I think it's your meeting L

l

61 J

I now.

(

2 MR. BECK:

Thank you, Annette.

3 I'd like to start out by introducing a couple of new 4

members to the Comanche Peak Response Team effort that 5

we've added since our last public meeting.

6 Because of the level of effort required of the 7

Senior Review Team and the depth of involvement that we 1

8 have set forth for this body, we found it necessary to 9

add expertise, and have convinced Mr. Warren Nyer to join 10 us as a member of the Senior Review Team.

Warren may be 11 known to many of the Staff members because of his many i

12 years of experience in the nuclear industry, which l

13

{

started back when he was much younger than he is today as i

14 an assistant to Enrico Fermi back in the late '30's.

15 Subsequent to that -- what I assume was a very pleasant i

16 experience; a rigorous one, too, I'm sure -- Warren spent i

i 17 a considerable number of years in executive technical

. }

is management positions at the National Reactor Testing

~

19 Station in Idaho.

He was associated with suc'n projects e

[i 20 as LOFT and SPRT and many other reactor testing a

23 activities.

22 Subsequent to that activity, Watren served as a 23 technical member of the Atomic Safety and Licensing Board 21 Panel.

l 25 For the past 12 years he has served in a consulting l

l

62 I

capacity to the nuclear utility industry in the technical

(

2 and managerial field.

3 We consider ourselves quite fortunate to have him 4

join our team and look forward to his intense involvement 5

over the coming months.

6 I might add that because of the work load associated 7

with the SRT's involvement and process, we're considerin'g 8

a further addition to this body, and we'll have more to 9

say to you on that subject later.

10 The second announcement with regard to CPRT third-l 11 party personnel has to do with Mr. Martin Jones.

Martin, j

12 due to extremely pressing family obligations with a l

13

{

family business, has notified us that he's simply unable 14 to continue in an intensive effort such as we're embarked 15 upon.

16 When we initially contacted Martin with regard to i

17 the CPRT, the length of time required for his services

[

18 w4s substantially less than, in fact, that which he has

~

{

19 given us; and he got to the point where he simply cannot i

i 20 continue at the level of effort required to get the job i

21 done.

l 22 He will be available to us and to a gentleman whom I 23 will introduce in a moment for consultation purposes'and, 24 if necessary, for appearances in the public in the 25 future.

We'll deal with that.on an as-needed basis.

\\

63 1

The gentleman we have selected to fill in for Martin

(

2 Jones as the Review Team Leader associated with the TRT 3

ICAP issues is Mr. John Malanda.

John has over 18 years 4

of experience in the field of electrical and project 5

engineering.

That experience has been primarily with 6

architect / engineers, Ebasco and Burns and Rowe, and 7

associated with utility nuclear project.

8 Due to Mr. Malanda's having just joined the CPRT and 9

being in the initial stages of his review of the 10 electrical TRT ISAP's, we would like to ask your 11 indulgence in deferring a status report, if you will, in 12 that area until our next meeting in December, and we will r

13

(

have a complete up-to-date status report at that point.

14 MR. EANSEL:

I have handouts.

'I do not have enough.

15 There will be more available in the morning.

I'm going 16 to address right now where we stand on the various issue i

17 plans.

'j IS Very quickly, let me walk through a couple of

~

19 charts.

Most of you have seen this in the CPRT Program s

20

. Plan.

We have made two minor changes.

This used to be a

21 labeled " Procedures and Project Assurance."

We have l

t relabeled that as " Procedures and Quality Assurance,"

k 22 23 really performing the same type of function, but we have 21 increased the activity in that area in an overview of our 23 activity.

i

<~

L f

i 64 I

This particular box was always in place, but we did

(

2 not show it on the chart.

We have an ERC corporate 3

quality assurance effort program and personnel, and they 4

act as an overview on myself and our team from a t

5 corporate standpoint, and do conduct audits.

I think 6

it's notable at this point also to point out that in i

7 addition to these two changes, from a QA standpoint --

8 it's not shown on the chart -- but we have implemented 9

within the organization, when appropriate, some quality j

10 checkers to be sure that things Te done in accordance 11 with procedures.

It's self-check and self-evaluation.

12 Again, I think most of you are familiar with the 13 schedule.

Very briefly, -- and not spending a lot of

{

14 time on it -- the top line addresses the external source i

issues for both programmatic and hardware issue plans.

15 16 Some of those are dependent upon the VII.C efforts, and i

17 we'll not be able to close those out until we finish that 1

i

!.i is area.

[

19 Below that, we're talking about the Self-Initiated l

i 20 Program, the first bar talking about the package 21 preparation and release.

We are well on our way with i

22 that.

We anticipate finishing those sometime in

~

j 23 December.

i l

The inspection and documentation reviews are also 24 i

l

. >5 progressing.

Right now we anticipate completing the

4 65 2

I inspection by the end of January.

i

(

2 We've also started evaluating the deviation reports 3

that come out of her< to determine if there are any 4

Safety Significant deviations, and also how to evaluate 5

those in terms of root causes and generic implications.

6 The preparation of final reports, we have some that we're 7

beginning to pull together the final pieces of data to 8

start performing the reports.

9 Manpower:

We're pretty well on line with the 10 planned manpower.

It's quite a rapid wrap-up.

The 11 reason for this is that we did not get started as early i

12 as we had anticipated in terms of the inspections, and 13

{

the primary differences here are in engineering personnel j

I4 to evaluate the deviations reports.

15 Again, most of you have seen the issue plans that 16 are in the CPRT program that's been released.

I'm only I

i l

I going to address status and any preliminary findings, so 17

[

is I will not go over issues and the approach unless you 19 choose to back up.

i i

20 In terms of looking at inspector qualifications, you 1

21 l recall that was broken into three phases.

The first i

c Phase was to do a review by the TUGCO Audit Group.

22 The second phase was aimed at a review by a special 23 evaluation team to reconcile any differences, and if they 24 25 failed to pass this gate, they went into Phase 3, and we

i l

66 I

actually went into reinspections.

(

2 We are close to -- we finished Phase 1, Phase 2, and 3

we are now in the process of reconciling all the 4

information we have on those reviews.

That 5

reconciliation will be completed this month and turned 6

over to the projects.

We have completed some 7

inspections, and there are some more that are going into 8

there.

This is an on-going process.

9 Preliminary Findings:

We have found in some cases J

10 where the inspector qualifications were not in accordance j

11 with procedural requirements at the time of 12 j

certification.

In those cases, they've gone into here, i{

and we'll reinspect.

I3 14 In looking at I.D.2, which was a review of the 15

]

- testing and certification procedures, we have completed 16 j

Phase 1, which is a review'of those procedures.

On Phase 17 j

2, we have provided those comments to the Project.

Those

'V I

18 procedures have been revised, and we have agreed with t

j 19 those procedures, and we're now looking at the daughter

f 20 procedures to be sure that they are consistent.

So the i

l1, 21 primary procedures are in place and functioning.

We're 8

!A 22 starting to look at, through surveillance and audits, I

23 looking at the implementation.

I 24 Our preliminary finding is that the written program i

f i

25 did not provide adequate control for examining inspection l

l l

t

67 1

personnel.

(

2 Material Traceability Issue Plan VII.A.l.

This'

~

3 particular issue plan dealt with a 1981 ASME survey, and 4

the TRT felt that that should have been a reportable 5

item.

We have completed our review of that survey and 6

all documentation, all events leading up to that survey 7

and subsequent action.

We're also looking at all the l

8 procedures and the systems that are in place for assuring 9

that material traceability is, in fact, there.

That 2

10 review is about 75 percent complete.

II We also are piggy-backing on some other issue 12 plans for. data as it's collected during those inspections 13 and documentation reviews concerning material 14 traceability.

We'll take the data from those with the 15 material that we've gathered in this one and draw our

~

16 conclusions.

[

17 Preliminary Findings.

It's our opinion that the i

18 Brown and Root practices at the time of that survey did i

I i

19 not constitute a loss of material traceability as was i

r 20 stated by the TRT.

We found good practices, good 21 procedures and good documentation.

7 22 Based upon this finding, we do not feel it was a 23 reportable item under 50.55E.

t 21 In looking at VII.A.2 dealing with nonconformance, 1

I corrective action and 50.55E reports, the status, we have 23 i

68 I

spent a lot of time reviewing all of the various NCR

(

2 procedures and forms, regardless of what the format, for 3

reporting nonconformances.

We're.about 75 percent 4

complete there.

We're also looking at the corrective j

5 action system that is in place, and also trending, and 6

we've just gotten started on that; in fact, this piece of 7

business first, followed by here, and then by the i

I 8

reportability issue.

9 So far, we found that the control of the 10 disposition / correction of nonconforming items is i

11 acceptable; however, there are some minor improvements 12 for efficiency only that'can be made.

I want to clarify

,f 13 the point.

The records are there, the process is there, i \\.

14 it's traceable, and it's adequate.. It can be improved t

15 through procedures, but the documentation is there.

+

{

f 16 Corrective action procedures on non-ASME type of i

l[

17 concerns was revised in August 1985.

Improvements were I

i 18 made in that procedure; we are now assessing j

19 implementation of that procedure.

We have found that the

i f

j 20 ASME procedures for corrective action are adequate.

21 VII.A.3 on Document Control:

This one we're i

i?

i

D 22 collecting data.from two other issue plans, the~one on t

t 23 III.D, which deals with three operational testing, and j

21 ;

from VII.C on all the populations that we inspect l

25 hardware on there.

We have talked to the other Review l

t i

__,._..__-,,_.__m

........._______....._.--,_~.._,_.,-,....-_-----,,....-m..m____y.

69 1

Team leaders, and we're evaluating the results of III.D

(

2 T'is data will begin to come in piecemeal as we h

now.

3 complete those inspections and documentation review.

4 To date we feel that the document control 5

inadequacies had no adverse effect on testing programs.

6

^

We see no problems in this area to date.

7 VII.A.4, the Audit Program:

We have completed the 8

document review of the PSAR, both preliminary and final; 9

the TUGCO QA program; the CPSES QA plan; and implementing 10 procedures.

They have been completed and we've looked at 11 about 75 percent of the files on audits and auditor 12 personnel qualifications.

13 To date it's our opinion -- although not final --

14 that the written program was not completely in-accordance with the requirements at that time as specified in the 15 l

16 FSAR, ANSI-45.2.12.

We're still open ended on j

17 implementation.

t Is VII.A.5, Management Assessment:

This has been

~

Aj 19 somewhat on the back burner due to the press of other I

20 issues.

We have gathered some material from INPO, 21 looking to others in terms of what is considered within Ii 22 the industry to be an acceptable program.

We have no 23 conclusions to date.

23 The Exit Interview System, VII.A 6:

We did talk to 25 and interviewed the Ombudsman before he left, and'we L

r----

.-g

,-,m

g

.(

s.

70 l

reviewed his procedures and his files and have reviewed x

(

2 the Safeteam procedures.

We indicate these are complete, 3

and we're watching the Safeteam on-going process.- We're 4

also gathering input from other plants within the

~

5 industry that we feel probably have, or are considered to

~

6 have, successful programs; and we've made no conclusions

.[

7 to date.

8 VII.A.7, Houseke'eping and System Cleanliness:

We

'59 did' find in looking at'the reactor vessel cleanliness --

10 that review has been completed - we did find that the 11 verification and the cleanliness approach, the swipes, 12 was adequate.'. That met or exceeded the specification i

13 requirements.

't 14 i

In looking at the procedures, we have completed that f

15 review,.and we find that both past and current procedures

,2 16 for housekeeping and cleanliness are adequate.

17 i

The surveillance of.those procedures and of those i !

l 18 activities, however, we feel were inadequate and not i

19 totally up to speed.

t 20-MR. CALVO:

The thing that crosses my mind, going to

!r 7

21

, the issue -- these a e the issues < coming up for NCR i

4 22 VII.11, right?

In this case, what were the actions on 23 the issues?

As stated right there?

24 l MR. HANSEL:

These came right out of the letters and l -

25 '-

' out of the SSER's.

l h

l s

\\

71 MR. CALVO:

But were they put that way with a

(

2 question mark or as an action to you saying you're --

3 MR. HANSEL:

This was basically the approach that we 4

took.

Were they adequate?

Were they there?

Were they 5

in existence?

Were they being implemented?

But it's 6

basically right out of the letters that we received, plus 7

the SSER's.

8 MR. CALVO:

But the part I'm failing to see, what 9

the SSER'll said about this particular one.

10 MR. HANSEL:

In this particular one there were 11 concerns, and I don't know if it came from SSER 11 --

12 probably 8 -- that talked about the adequacy of the swipe 13 test and evaluation of the reactor vessel.

In SSER 11 14 there were other concerns about housekeeping and control 15 and protection of equipment, snubbers, threads --

l 16 MR. CALVO:

But those thing were based on some

( l 17 review of the TRT.

The review indicated that they found 1

i IS some problems in those areas.

Now you're coming along i

, j 19 now and you're saying based on what else I'm doing, l

i l

20 r

you're saying whatever the-CRT found before, it could 21 only have been isolated case.

That's the way I'm looking l

?

5 22 l at it.

Or are you also saying whatever the TRT looked at 23 !

before, doesn't mean anything?

21 ;

MR. HANSEL:

In this particular case, we found f

evidence in the files and in' review of the procedures, 25 1

l

i

~

72 1

both Westinghouse and Gibbs & Hill and the on-site

(

2 procedures, that there were adequate provisions in place i

3 for the swipe test reactor vessel.

We have also taken and reviewed'all procedures for housekeeping and 4

5 protection of equipment on-site ~during construction 6

operations.

We found that the procedures were good, but 7

the surveillance and the oversight of trase.was not 8

adequate.

9 MR. CALVO:

I guess the general question that I'm 10 having ist How do you reconcile your findings with the 11 TRT findings if they disagree with each other?

12 MR. HANSEL:

We're going to have to sit down and 13 talk.

We'll show you what we found, show you our 14 documentation -

15 MR. SHAO:

The TRT has to review this whether they g

16 agree with it or they don't agree with it.

17 MR. GUIBERT:

Jose, maybe I can help you a little 18 bit.

On the reactor vessel swiping thing, I don't have s

, j 19 the numbers exactly right but the specifications call for

(!

! r 20 two swipes of the vessel, and apparently that's what the 21 TRT looked at.

The documentation in the files I've been 4

a 0

2 22 told indicates -- I can't remember whether it was four or 23 eight' swipes were actually taken, which is considered to i

l be an adequate number of swipes for that, plus a number 24 23 l of swipes were also taken on the coolant piping, as I

L

~

73 I

well -- there may be some disconnects --

(

2 MR. CALVO:

That kind of rationale --

3 MR. HANSEL:

We need to sit down with you --

4 MR. SHAO:

The TRT needs to sit down with you, and 5

whatever you find --

6 MR. CALVO:

I'm just hoping that not only sitting 7

down, you're going to come up with a report --

8 MR. HANS EL:*

Yes, on each of these issue plans there

~

9 l

will be a Results Report --

10 MR. CALVO:

-- to tell you how to reconcile the 11 difference?

12 MR. HANSEL:

Yes, what did we find, what did we i

13

[

review, and how did we draw our conclusions, and the 14 supporting documentation to back that up.

We can sit 15 with you then and show you what we found versus what you i

l 16 found.

[

17 MR. CALVO:

All right.

s IS MR. HANSEL:

That process has to take place.

These t

i j

19 are preliminary, but pretty well finished.

f 20 MR. BECK:

John, excuse me.

If I could also point 21 out, Jose, that those are preliminary findings.

The SRT, S

2 22 although we've been involved in'the process from time to 23 time, have not reviewed.a report to the SRT.

Until that i

24 happens, it's still preliminary as far as we're 25 concerned.

74 I

MR. SHAO:

So far everything is preliminary, so

.({

2 whatever you do, you have not looked at the.TRT report.

3 So far you have worked independently, right?

4 MR.' BECK:

That's correct.

5 MR. HANSEL:

These are my preliminary findings and 6

conclusions.

As John indicated, they have not been 7

discussed with the SRT yet.

We're still wrapping up our i

8 evaluation and getting the authorization to write our 9

report.

10 MR. CALVO:

Keep in mind that, again, you are 11 proceeding at your own risk again, because we have not 4

12 reviewed all the ISAP's, we cannot approve all the i

13 IsApe s.

14 MR. HANSEL:

I understand.

l 15 MR. CALVO:

We're waiting for your comment for those l

i 16 so that we can come up with some decisions.

t 8

l 17 MK. HANSEL:

We understand that, and we may end up i

18 going back an'd'doing something a little differen't, or j

i 19 maybe we may have gone too far.

We understand, f

3 i

8

'I 20 The Fuel Pool Liner Documentation, ISAP VII.A.8:

i1, 21 Again we have completed a review of about 60 out of 300 i

22 travelers and a preliminary review of the related weld

{

23 material issue records.for those, and we have no findings l

24 to date.

We're really just getting started in this i

i 25 particular area.

l

'l

75 1

MR. SHAO:

This is in both NCR 10 and 11?

' (

2 MR. HANSEL:

Yes.

I beileve you're right on both of 3

them.

4 On-site Fabrication, VII.B.1:

We have looked at 5

about 75 percent of the procedures and documentation and 6

the records associated with the various fabrication 7

shops.

In this particular area we had to question 8

dealing with:

Were fabrication controls for piping and 9

subassembles and component supports adequate to assure 10 use of qualified process procedures and maintenance of 11 material identification?

We've been through about 75 12 percent of~those various procedures.

There are several

(

shops involved, and we have no conclusions to state at 13 14 this time.

I 15 Valve Disassembly, VII.B.2:

This was the one where i

16 we had the potential disassembly of valve parts.

We have 17 completed our inspections.

Through a combined sample of a sample of the TRT valves, plus a random sample of all 18 19 valves, we ended up looking at 101 valves.

Those are.

t 20 completed.

Out of that, we found no construction i

21 deficiencies.

i We did find four valves out of the total-

[

where there was not documentation to indicate that 22 that j

23 reversal took place.

On.two of those, they both came out I

of the same lot; I

therefore, it was okay to interchange

.,4

.,3 them, and no problem.

On the other two, in talking with l

t

76

~

l 1

the valve manufacturer, be it for a 150-pound valve or a' I

o 2

300-pound valve, the casting, the thickness and the 3

t manufacturing processes are identical.

It doesn't make 4

any difference if they're reversed, anyway.

Therefore, 5

we determined that they were not reclassified as a 6

construction deficiency.

7 MR. CALVO:

How do you reconcile the difference that 8

TRT found something wrong and you found -- how do you 9

reconcile the difference?

10 MR. HANSEL:

We found through the records that TRT 11 did not take this properly -- I don't think they went far 12 enough in their communication with the project to find 13 the documentation.

We found documentation on 97 out of 14 101.

We had to go look for it,.but it was there.

I 15 forget the acronym, but it's like equipment transfer that 16 !

was signed off.

j 17 On the other four, we did not find that documentation, but the reversal was perfectly okay from 18 19 an engineering standpoi.

3rd construction standpoint.

20 So there's really no impact on construction itself.

21 VII.B.3, Pipe Support Inspections:

This is where we're looking at the hardware deviations on QC-accepted 22 1

23 and installed pipe supports, and looking at deviations l

for welds, support identification, locking devices and so 21 25 forth.

These were primarily in Room 77N.

Those 1

77

=

1 inspections cre about 90 percent complete.

What we have

(,

2 found on those supports in Room 77N pretty well agree 3

with what the TRT found, very close agreement.

4 3re have found what we will classify as one 5

construction deficiency in that area, and that was for a 6

missing cotter pin in a support.

We'll talk about that 7

in more detail tomorrow.

The project responded 8

Lunediately and has agreed to take on a correction j

9 program to inspect'for those.

1 10 MR. SHAO:

How do you qualify this inspection effort 11 with the Stone and Webster inspection effort?

12 MR. HANSEL:

We're looking at the adequacy of 13

{'

construction as compared to what Stone and Webster is i

14 looking at.

15 MR. SHAO:

I realize that.

Stone and Webster also i

16 !

has the so-called verification walkdown and generic 8

i t-walkdown.

You have conflicting analysis. 'Are they 1

1 IS related?

19 MR. HANSEL:

Anything that we find is provided through the Project to Stone and Webster, so they're 20 21

. knowledgeable of what we find.

They're knowledgeable of

. i i

22 what we find.

If they were to find something in their 23 walkdown that indicates improper construction, then that l

f information would come to me.

.y ;

I 25 i MR. SHAO:

My question is:

If we find something

i L

r 78

_ l I

wrong, we expect an analysis, t

(

2 MR. HANSEb:

We have not yet, and as I say, they 3

receive input on everything that we find.

F 4

VII.B.4, on the Hiltis:

Here there were allegations 5

of embedment, improper depth, verification of torque, 6

minimum edge distance and skewed bolts.

We're doing most 7

of these inspections through the self-initiated program 8

i under VII.C, and in those populations about 65 percent of 9

the inspection on hiltis bolts are complete.

i i

10 We are daveloping, and soon will have a discussion t

11 with the Project, a procedure and a sampling process for r

12 verifying torque on a sample of hilti bolts.

13

(

On all these inspections to date, we found nothing l

14

'that causes great concern, no adverse trends.

15 On the Electrical Raceway Support Inspections, 2'

16 VII.B.5, we're concentrating primarily on conduits.

t The i

other has been turned to Ebasco and we are coordinating 17 s

1!

gg t

attributes with them -- have coordinated attributes.

On

]

2j 19 conduits we have about 33 percent of the inspections

-I i

20 complete, and we have found no construction deficiencies 21 to date.

'o

?

2 That's the end of my presentation on the ISAP's 22 23 external source issue.

24 MS, VIETTI-COOK:

May I ask a question about your i

employee concerns with the reporting system, the ISAP i

25 t

- -. =

79 I

with regard to that?

On the Ombudsman /Safeteam you said

(

2 you looked at the procedures.

Are you going to be 3

looking at the files and, you know, resolve the concern 4

at any great depth if you don't feel you agree with it or 5

anything like that?

6 MR. HANSEL:

We don't plan to get into that level of 7

detail.

We're looking at the procedure and the system in 8

place for employees, for exit interviews, and somebody to 9

go to if they have a concern.

We did satisfy ourselves 10 that there was a smooth transition from the Ombudsman to 11 the Safeteam and that those records were transferred over 12 and that that transfer was crisp.

We have not gotten 13 into doing evaluations as to the adequacy of those 14 evaluations; just that there is a system in place, it 15 works, it functions.

16 MS, VIETTI-COOK:

And you don't plan on doing any at

[

17 this point?

i I

18 MR. HANSEL:

No.

19 MR. BECK:

1 I might add, Annette, that safety issue lI 20 that bears any relationship whatsoever to CTRT activity, 21 whether it be in Mr. Hansel's area or anyone elses, is 3

f '2 immediately fed into the system as soon as it comes out, 22 23 so there's a constant linkage in that regard.

j 24 MR. SHAO:

How do you handle this?

You have the l

ISAP's for all these SSER's by TRT.

25 How do you handle I

1 80 m

~I Appendix P of SSER No. 117

(

2 MR. HANSEL:

The question is How do we handle 3

Appendix P of SSER 117 We have, and are maintaining, a 4

matrix of all external source issues, regardless of where 5

they come from, including SSER 11 and Appendix P.

The i

6 input on each of those has been given to the Issue 7

Coordinators for the various issue plans and for VII.C l

8 populations.

So they are aware of the external source i

9 issue, and.in our evaluations, be it inspection, 10 documentation reviews, procedure reviews, interviews, or 11 whatever, we're evaluating thosa; and they will be i

12 addressed when we complete our final report.

So we have 13 an accounting system.

We' keep track of all external 14 source issues and which issue plan are they being looked i

i 15 at --

16 MR. SHAO:

But Appendix P is independent of other if 17 external issues --

{

18 MR. BANSEL:

But it's a combination.

It includes t

. j 19 all -- if you came up through SSER VII through XI.

It's f

i t

E 20 a combination of all of those.

t 21 l MR, SHAO:

I don't think you can do it that way, g

,?

!3 22 because, let's say, the inspection area you have fAve 4

23 l separate issues, but in.the meantime you work on these l

i j

five issues.

In the meantime, you have maybe another 15

[

l 23 l

l 25 in Appendix P.

These 15 have nothing to do with the t

81 1

other five issues.

({

2 MR. EANSEL:

I can take the ones.in Appendix P --

3 and I have -- individually and I will indicate and have a 4

record system as to where I'm evaluating that item out of 5

Appendix P.

6 Let me say it again.

You take all external source 7

issues, be it from the SSER, the letters that preceded 8

them, the DAP, SET, the other issues.

We have a record 9

of all of those.

We also have a tracking system of where, in which issue plan that specific item is being 10 11 worked.

Appendix P is a repeat of many of those, but where there's something new, we're looking at it as well, 12

(

13 there's a record system, too --

4 i \\

14 MR. SHAO:

I'm talking about something new, 15 something not covered by an external issue.

What do you I

16 do about that?

4 I

g-MR. HANSEL:

If something new comes in today or 18 tomorrow --

i i

19 MR. SHAO:

No, no.

Not something new.

I have, I

20 let's say, external source issue here.

Assume Appendix P fall within the explanation -- assume you don't fall in 21 Ii the explanation.

What do you do with that?

Assume 22 23 Appendix P issue does not fall within the --

MR. HANSEL:

Oh, if it',s something new, then I may 1

have to write a new issue plan, if it's something new 25

~

82

_ i I

that I can't fit under one umbrella.

I would prepare an

(

2 issue plan.

3 MR. SHAO:

But a lot you cannot fit in --

4 MR. CALVO But, Larry, I think you can argue that 5

the SSER No. 11 in essence initiate the self-initiated 6

review - in essence.

Any external source issue by 7

itself can very well trigger a self-initiated review.

8 Be's saying the combination on the ISAP's and whatever is i

9 in the self-initiated review, that is covered.

And it's 1

10 up to us to determine whether the thing has been covered, 11 Appendix P included.

12 MR. SHAO:

I can give an example.

It's not covered.

13 MR. HANSEL:

I think if we were to sit long enough 14 and look at Appendix P, I can show you where that's being 15 worked by an issue plan, and show you how it's being

{

16 addressed on a case-by-case basis.

[

17 MR. SHAO:

I'm not convinced.

Maybe I'm missing 5:

18 something.

}

3 19 MR. CALVO Maybe the next audit we come to, we can

}r 20 touch that point.

23 MR. SHAO:

You'll have to show it to me.

i MR. HANSEL:

I think we ought to sit and look at it.

22 i

23 Any other questions?

l 24 MR. CALVO I've got one general question.

We gave 25 you so many questions about ISAP's sometime back, and r

t

+

83 I

again, we got the' answers; but I'm looking between.

If

(

2 what you're doing from our comments that you felt our 3

comments have merit, you have already incorporated what

]

4 you're doing in the implementation.

1 5

MR. HANSEL:

We have all the comments. 'We've 6

discussed them.

I have indicated what changes need to be 7

made in each of our issue plans and have discussed those i

8 with the se'nior Review Team.

And in a lot of cases we're 9

moving on.

Each of those have been reviewed, and I've 10 looked at the impact and went back to the Senior Review 11 Team and said, "I think I need to do this."

12 MR. CALVO:

The other one I have has to do with the 13 ISAP's electrical inspectors.

That's the one that I've

]

14 got to come up with something.

You said that you went l

15 through all the records and you found some problems, and i

4 j2 16 if I remember correctly, the ISAP said you must ascertain 17 the safety impact, not impact to the safety of the plans, t

18 How do you handle that?

When you found that there was 4

19 something wrong with the inspector because of lack of I

4 t

20 qualifications or whatever, how you vent from there to i

21 Put it back into this self-initiated review into the

! 5 other ISAP's.

How that message was conveyed.

Did you go oo l

l 23 and review everything that inspee: tor did in there and l

[

determine what was inspected and justify --

23 23 i MR. HANSEL:

Let me answer that in two pieces.

t

l i

84 i

i I

Let's say that we found this inspector and we found that 2

his record file does not have adequate documentation, say 3

that he was certifiable.

We're going out and inspecting 4

some of his initial work to the same c:iteria that he 5

inspected to.

From that, we're making a judgment.

Based 6

apon the decisions that he made on the hardware, does it 7

appear that he was certifiable, even though the 4

8 documentation didn't reflect it?

If that fails, we go 9

for more hardware.

And we keep going until we're 10 satisfied that we've either said he's okay or we've done

)

11 everything he did.

In one case I've gone all the way.

12 MR. CALVO:

So you concentrated on that particular 13 inspect'or, and you don't throw this into the big bin of I

14 the VII.C.

{

15 MR. HANSEL:

Not yet.

Now, VII.C will also give me 1i.

i j

16 a test of tit hardware by the work process. If I start to i

r 17 see any problems there,'then I may want to go look at i

v, i

i IS what I found in inspector certification.

If I find li'g 19 problems in the inspector certif', cations that indicate

E 20 I

that ther6's a trend I don't like, I may want to go do I

I 21 something different in VII.C.

I'm not there yet.

I

i. I.

!k 22 MR. CALVO:

So you hit from both sides.

I l'

.,3 MR. SOFFELL:

To follow up on Larry's point, what l

I've heard you say -- My understanding of Appendix P --

21 I

2.5 concerning Larry's and your response, is that you've I

i i

85 I

identified, you have developed a matrix or a list of all

(

2 issues, including those in Appendix P, and some of those 3

Appendix P items may be resolved by certain external 4

source issue plans.

Some may be resolved by certain 5

aspects of the self-initiated plan,'and then any that 6

aren't encompassed by any of those, you would develop a 7

separate issue plan for.

8 MR. HANSEL:

If I see a need to, I will go do so.

9 Some other type of investigation, maybe it's another 10 issue plan.

11 MR. SHAO:

Let's say there's a table there.

Every 12 2 tem on that table you can find a home for.

13 MR. HANSEL:

Yes.

14 MR. CALVO:

Is not in essence Appendix P challenging 15 the adacuacy of the QA/QC impler.entation program?

Ir

{

j 16 essence, that's what you did?

l

[

17 MR. HANSEL:

It's certainly a good --

L

{

s 18' MR. CALVO:

That's what you did, from our g.j 19 standpoint.

On a system-wide basis.

So it was mostly j

f l

20 the OA/QC implementation of this plan, so anything else I

.that is done in trying to prove that either that was the 21

(

[

8 1

i 22 case or that was not the case.

And your scif-initiated l

l t

review is a mechanism to provide an input to that, 23 plus all that ISAP that came from 11 saying that all the 21 t

i 23 others. contribute to make P.

t_

r f

=

1 1,

86 e

I DUL. HANSEL:

Exactly.

MR. SHAO:

Would that be a difficult job?

If you 3

have a cable here, say, a cable item here is an itam in 4

ISAP so-and-so and an item in self-initiated program, can 5

you sometimes itemize this, or --

6 MR. HANSEL:

Our matrix of all external source

[

7 issues, Larry, is about that thick --

O MR. SHAO:

Including Appendix P7 9

MR. BANSEL:

Yes.

10 MR. SHAO:

You can say Appendis P --

l 11 MR. HANSEL:

We looked at it as'an external source.

12 A lot of the items in Appandix P are repeat of something i

! (

13 in another ESER.

We will combine those --

\\

14 l

MR. SHAO:

But a lot them are not.

i 15 MR. HANSEL:

That's correct.

We've looked at each i

1 l

l 16 of those to see where we're covering it.

It's an

\\

n i

li 4xternal lasue to me.

I have to resolve it one way or 7

i i

8 18 the other before I'm finished.

-i I

19 Any other questions?

I i

f 20 i4R. WESTERMAN:

Is this matrix going to come out in 21 some future revision of the Plan?

I t, ?.

22 MR. HANSEL:

It changes all'the time.

It's there.

t f

23 When we're finished, I'll produce it.

It's available for l

l t

21 l review now, but it changes evtry day; not every day, but l

25 quite often.

As new documentation come in, be it from i

1 k

i 67 1

CYGNA, ASLB, Region IV, whatever, it gets updated and

(

2 input in that matrix, so it changes quite often.

It's a 3

working document.

4 MR. WESTERMAN:

I just asked the question because if 5

Larry, for example, saw that matrix, it might make it 6

very clear to him what all has been included.

7 MR. HANSEL:

I think Jose had a good point.

When 8

they come out for an audit, I'd like to sit and go l

9 through that process.

10 Ma. CALVO I'm not worried about missing anything.

11 I'm worried about whether we got instructions in the 12 Program Plan to accomplish anything, that you have it 13 right now or somebody can throw you in the future.

If 14 that structure is not there, then we're in trouble.

If

-15 it's there, I don't care whether it's SSER No. 11, 12 or 1

l 16 any other SSER the Staff is going to throw at you as long 8

17 as you've got the structure --

j l

1 s

15 MR. HANSEL:

The structure --

i 19 MR. CALVO:

1

-- and when you fit this up in the l r 20 review, you're going to come up with new issues that 21 don't become issues in themselves but they've got to be i

applied into the system.

So your structure must be 22 23 there.

i 24 MR. HANSEL:

The structure is there.

The procedures i

25 are there.

If the design adequacy folks find something i

L

88

\\

l that I need to be concerned about, it may well generate a

(

2 new issue plan.

3 MR. CALVO:

I'm going to repeat it because, again, 4

I'm trying to understand what you have.

As long as I 5

understand it, then I can proceed.

6 MR. HANSEL:

Any other questions?

7 MR. BECK:

John, before you leave -- Billie, I'd 8

like to offer you the opportunity'to ask questions of 9

clarification of what Mr. Hansel and others will say 10 today and tomorrow.

It's not an open discovery forum, 11 but, please, if you have clarification questions, feel 12 free to ask them.

13 MS. GARDE:

Mr. Hansel, on the discussion of the 14 electrical inspectors training problems, I didn't 15 completely understand the discussion in terms of what j

16 happens with the root cause or the generic basis for --

l 17 you're going over what you've done once you've identified i

the electrical inspector who's not properly trained.

At

-i a

18 l

3 19 what point do you identify the root cause of that i

i I

20 problem?

21 !

MR. HANSEL:

After I've done enough reviews.

It's

?

l 3

32 )

difficult to draw that conclusion on one inspector, and I 1

i 23 don't know what the magic number is --

I 1

21 l MS. GARDE:

But you don't have to find out what was 23 the root cause of that one inspector's problem?

L.

l

89 1

MR. HANSEL:' Yes --

(

2 MS. GARDE ' And you make that conclusion?

3 MR. HANSEL:

Yes, and I have those.

The person did 4

not have a high school education maybe, as required.

I 5

have that on an individual basis.

The person did not 6

pass a GED test --

7 MS. GARDE:

Maybe I'm not articulating myself.

8 There's some reason that problem got through the system 9

unidentified, that that person was out in the field doing 10 inspections and he should not have been.

What I don't 11 understand in your answer was:

At what point in your 12 review do you make a determination as to how he got 13 through the system?

14 MR. HANSEL:

We're very close to being able to do 15 that.

I would do that after I finish all my reviews of I

16 those folders, t

17 MS. GARDE:

Of all the inspectors?

gg MR. HANSEL:

Of all the electrical, both current and 5j 19 historical, and all other current inspectors.

Ir 20 MS. GARDE:

I don't want to seem dense here, but it 21 seems to me you're going backwards, finding out how i

someone got through the system, that that's a fairly-23 l

23 discrete piece of information, and that once you 1

l

,3 i

determine that piece of information on a particular 25 inspector who was unqualified, you're going to have an L

a

i 90 1

answer to the question.of how this guy got out in the

(

2 field.

Am I incorrect?

3 MR. HANSEL:- No, and we pretty well know that right 4

now.

But we're going through all the folders on each 5

individual to determine, first, what might be out there in the field we need to concentrate on, and as we go 7

through that process, I will formulate my final opinion 8

as to what the root cause was.

I think we have some 9

general ideas right now.

I'm not ready to state them 10 yet.

s 11 MS. GARDE:

Let me go back also to Larry's 12 question --

13

{

MR. HANSEL:

You have to realize the process, 14 Billie.

We're looking at a lot of records, and you see 15 things and you ask yourself, How did this happen?

Until l

16 I finish that review process, I don't want to jump out

[

17 and draw conclusions that are inappropriate.

I wast to i

a 18 finish that process.

That's what we're doing.

19 MS. GARDE:

I But presumedly at the end of your r

20 looking at all of the QC inspector qualification problems you're going to come up with a set of reasons why at some 21 i

j1 22 point between '76 and '84 there were unqualified 23 inspectors in the field, and that list could be a lot of l

21 reasons, one reason --

25 MR. HA!!SEL:

Exactly, and it will also talk about l

~

91 I

what are the generic implications of that and what kind

(

2 of corrective action needs to be taken, if it's not 3

already been taken.

4 MS. GARDE:

And that kind of conclusion is going to 5

come at the end of the process?

6 MR. HANJEL:

That will be in our Results Report when 7

we finish, yes.

8 MS. GARDE:

Okay.

Larry, I'm going to take a stab 9

at your question.

The question that I have in my mind -

10 and if it's not correct, I think it's what you were 11 trying to ask -- if Appendix P reaches certain 12 conclusions based on what the TRT saw, you are_looking at 13 what the TRT found in reaching different conclusions in 14 some cases.

15 MR. HANSEL:

Some cases.

l

~

l 16 MS. GARDE:

And in some cases you're reaching the 17 same conclusions.

Okay.

Then -- Larry, I'm not sure if 18 this is what you're asking -- are you going to look 1

19 y

independently at the conclusions reached in Appendix P7 i

t 20 Are you going to take that as a --

I 21 MR. HANSEL:

I'm taking Appendix P -- if there is an 2

22 issue there, I'm taxing that as an indication of, quote, 23 a problem, something that should be evaluated.

I'm not 21 really letting what the TRT did influence my thinking.

t 25 I'm looking to seer Was it real?

Is it there?

What's i

l t

92 1

the impact?

(

2 MS. GARDEs So conclusions reached in Appendix P by 3

the NRC.are not necessarily going to appear on your 4

matrix as discrete issues.

5 MR. HANSEL:

I have it reported in code form what 6

they determined, but again, it's just one piece of info.

7 MR. BECK:

Thank you, John.

8 I'd like to revert back to at least our schedule of 9

appearances and ask Monty Wise to cover the status update 10 of the testing issues and specific action plans.

11 First, let's take a break for the Reporter.

12 (A short break was taken.)

13 MR. BECK:

I'd like to turn the gavel over just a 14 moment to Bill Counsil, who has an introduction to make.

15 MR. COUNSIL:

Since John was able to make some l

16 introductions earlier, now I have two new members; one

[

17 older member in a new position oc my staff and a new i

s 18 member on my staff.

Austin B. Scott is here in the room, 19 in the back.

He's our new Vice President of Nuclear Ir 20 Operations, and I hope that most of you will get the I

opportunity to talk to him when we break here and i

21 i

I 22 introduce yourself to him.

I'm sure he'll be seeing much l

23 of you for the next year or so.

I think most of you 24 realize that Austin is a retired Rear Admiral in the l

United States Navy.

His latest duty station was 23 L

I 93 1

Commander, Submarine Forces, Pacific Fleet; twenty-five

(

2 years in Navy nuclear power.

I think one of the things 3

about Austin that you'll enjoy -- for those of you in the 4

room who are Texans -- is that Austin is a native Texan, 5

unlike me.

He's a graduate of Rice University.

6 The other one I want to indicate is our ex-Manager 7

of Nuclear Operations, Jim Kuykendall.

Jim has been 8

promoted to a vice president, reporting to me, and he'll 9

be helping me with many of the administrative duties thac 10 I have, as well as a broad range of technical duties.

11 So, if nothing else, give him your congratulations today, 12 if you would.

13 MR. BFCK:

Thank you, Bill.

14 Monty, would you like to proceed with the testing 15 status?

{

16 MR. WISE:

The handout that you have there for l

17 testing has two sets of slides, copies of the slides.

18 one is the longer version -- it's on the front -- and the i

19 y

other is the shorter version on the back.

I brought the i

20 two types, depending upon the type of questions that are 21 being asked.

I think I better use the longer version 1

because I think it provides the information that people 22 g

2.1 seem to be needing at this session.

I t

This is an update on the ISAP for the testing 24 25 program.

The first is III.A.1, llot Functional Testing i

94 I

1 Data Package.

I might just say that the issues as you

(

2 see them on these slides are summarized' issues in most 3

cases, because the actual issues are long and I tried to 4

Pare them down into a few words.

Hopefully I haven't 5

changed the intent or meaning of the issue.

6 The issue in this case was that the preoperational 7

test objectives were not all met in the preoperational 8

hot functional test data packages that the TRT reviewed.

9 The status of the implementation of the action plan is 10 that the data package reevaluations as specified in the 11 action plan have all been completed, these reevaluations 12 were done primarily by the Joint Test Gcoup, and that it has the responsibility to review test data packages from 13 14 the preoperational test program.

15 The reevaluation criteria that was used to

]

16 reevaluate the data packages has been incorporated into a

t the appropriate start-up administrative procedure.

The g-l ASLB questioned one of the preoperational tests, as noted gg 19 there, 1CP-PT-02-02, which tested the 118 VAC RPS i

r 20 inverters.

They had some questions regarding the meeting l

21 of the acceptance criteria as specified in the test i 4 1

i 22 ;

procedure, and the fact that it had been approved, g

{

reviewed and approved, by the Joint Test Group.

23 g

The data that was in the test package did exceed the lacceptancecriteria,andweareintheprocessof

.,a.

95 I

evaluating the safety significance of this deviation.

(

2 Simultaneously, we are doing what we can regarding 3

paring the results of the report.

Before we can finish 4

up the results, we have to complete the evaluation 02-02 5

preop and factor that into the significance of the 6

findings of the ISAP.

7 The next ISAP is III.A.2, Joint Test Group approval 8

of test data.

The issue here was that the SSAR was not 9

clear regarding review and approval of deferred to preoperational test data.

It didn't specifically say 11 what review group at the site did review and approve the 12 data.

13 The FSAR was amended to clarify that the Station 14 Operation Review Committee (00RC) is responsible for 15 review and approval of the deferred preoperational test

{

16 results.

There are tests that can't be, for some reason 8

17 or another -- plant conditions, usually -

performed by is the start-up group.

They must be made a part of the 1

19 initial start-up program that plant staff is responsible y

ir 20 for.

21 We evaluated the administrative procedures governing l,!

j 1 22 this -- these were primarily the plant staff'and.

i l

23 administrative procedures -- and found that they were I

l 23 adequate.

They were not unclear, as the FSAR was.

The 2.5 plant staff, or the project plant staff, had interpreted I

L

--p 96 1

the requirements correctly and had made the

[(

2 administrative procedures correct accordingly.

In this 3

case the Results Report had been prepared and submitted 4

to the SRT for their review and, hopefully, approval.

5 In this case we do not feel that there was a 6

deviation.

It was a matter of clarifying the words in 7

the FSAR to make sure that anyone who reads it 8

understands who has that responsibility.

9 III.A.3, Technical Specification for Deferred Tests.

10 The issue is Plant conditions required for some 11 deferred preoperational tests might not be compatible 12 with technical specification limiting conditions.

The

,{

TRT was concerned that preop tests, or part of the preop 13 14 tests, might need to be deferred into the initial start 15 up of the program, after the plant receives its license I

16 and comes under the technical specification requirements.

l?

17 1.nd system operability would be difficult to achieve in i

is accordance with the technical specification requirements, 19 making it necessary to go back to the NRC for the b

20 requests for deviations from the technical specifications 21 as written.

I 22 The intent by the start-up and plant staff was j

l included in Revision 0 and 1 of this action plan.

This 23 i

21 is also spelled out in the administrative procedures for I

25 start up and plant staff.

l' I

i 97

\\

1 SSER No. 7 stated the issue was no longer a concern,

(

2 based on the information that was included in actual 3

plans.

4 In the September 30, 1985, NRC evaluation that we 5

recently received, there were no comments pertaining to 6

this action plan, so it is assumed that the issue is 7

potentially closed, based on the SRT's final review and f

8 concurrence.

i.

9 III.A.4 is Traceability of Test Equipment.

The 10 issue in this case is that measurement instruments, or as f

11 we abbreviated, M&TE, was not traceable to the marked 12 location in the specific test that they were looking at, 13

{

and that the test was the thermal expansion test that was 14 performed during hot functional tests as the plant 15 systems were taken up to, close to operating temperatura 1

's 16 and pressure for that testing phase.

ll 17 We evaluated the commitments and the administrative 18 requirements for M&TE traceability.

We evaluated the 19 test data package in question.

We evaluated other start-i,i t

20 up test procedures and data packages to see if there were 1

21 any other problems as noted in this package.

We i

1, i t evaluated representative plant operations administrative 22 i

l and test procedures, and we're in the process of 23 21 preparing the results of the report.

25 In ur evaluation of the commitments and the i

i

98 1

administrative requirements ir; this case, we found that i.(

2 there is no actual requirement for the degree of 3

traceability that was noted in the TRT issue.

We've f

4 discussed this with the TRT that's on site, and we've i

5 come to the conclusion -- I have come to the 6

conclusion -- that there are t,wo places in the 7

administrative procedure where'the M&TE requirements are i

8 spelled out.

One is for prerequisite testing, which is 9

the initial construction testing, and the other called 10 out is for preoperational testing.

11 For prerequisite testing it's clear that the METE i

12 information is to be included on the data sheets.

In

(

13 other words', the M&TE information is to be correlated 14 back, or traceable te, the actual monitored location in 15 the data that,was taken.

16

,.The preoperational test, because of the type of I

17 testing that's involved there in many cases, the e

18 procedure says that the M&TE information can either be in

'3 l

j 19 the data package or on the data sheet.

And in the case t

! I 20 of this procedure in question here, the M&TE information 21 l

was actually'in the data package when the TRT looked at 3

3 22 it.

There was a deviation from the test procedure, in 23 that the test engineer substituted M&TE calibration 1

24 information for the information that was to be on a table i

25 included in the procedure.

The administrative I

e

99 1

requirement is that-if you do change the procedure like

(

2 this, you have to initiate the process, a test procedure 3

deviation, and get it approved in accordance with 4

administrative requirements.

This hadn't been done when 5

the TRT looked at th'is, so it was a deviation at that 6

time from the administrative procedure requirements.

But 7

the test package did contain the METE information that.

8 was required by the administrative procedure 9

requirements.

10 As I mentioned here, we did look at other data 11 packages in conjunction with the III.A.1 data package 12 review.

We found that all the'other data packages we e

13 looked at, which is a total of 27, contained the proper

(

14 METE information, and it was handled in accordance with 15 administrative procedure requirements.

}

16 III.B, Conduct of CILRT.

CILRT is the Containment 17 Integrated Leak Rate Test.

The issue in this case, the i

18 test was performed with penetrations, and prior NRC ij 19 approval was not obtained.

Leak rate calculations l'

I 20 performed using ANSI /ANS 56.8-1981.

FSAR specified ANSI 21 N45.4-1972.

TRT felt there was a potential here for S

I I

22 other deviations from FSAR commitments.

23 When this was brought out by the TRT, it was

{

2-1 referred to NRR.

NRR ovaluated the test methods that 25 were used and had teen previously submitted to them by

.,...., ~

100 1

TUGCO.

NRR found that the test methods that were used

(

2 were satisfactory.

They concurred with the methods and 3

the results, and this was noted in SSER's 6 and 7.

Six 4

pertained to the isolated penetrations, and r.even then 5

talked about the ANSI standards.

The FFA?. Wap emended to 6

correct the discrepancy. 'The test package was reviewed 7

for other deviations, and no other deviations were found

~

8 in the test package.

9 In conjunction with III.A.1, the test packages that 10 were evaluated for deviations from the FSAR commitments, 11 and none were found during that evaluation.

12 Start-up administrative controls were evaluated, and 13 I feel that that is the crux of the problem in this case.

There were really deficient administrative requirements 14 for assuring that the FSAR is maintained in current.and 15 1

.I 16 proper condition and maintained updated..

i I

17 Start-up Administrative Procedure No. 14 was revised 8

to up' grade and include that specific requirement..

18

~

19 I reviewed other project' groups, plant operations i

c 20 and initial start up groups and so forth for procedures and found that they'do have proper controls for assuring 21 3i that the FSAR is maintainina the current 22 condition.

(

l l

23 III.C, Prerequisite. Testing.

There were two issues i

24 in this case.

The first issue was that the test support

-i personnel -- and in most cases these are Craft personnel 25 ;

i

-,J

+

r 101 I

that are trained and they're' qualified to assist the

({

2

-start-up testing engineers -- were signing the 3

verifications and initial conditions for prerequisite 4

tests that had been achieved prior to the performance of

~

5 the test.

6 The other issue was that a management memorandum was 7

issued to clarify procedural requirements regarding this 8

matter, and the procedure in this case, CP-SAP-21, was 9

not subsequently revised.

The start-up administrative 10 procedures allow start-up management to issue a temporary 11 memo to clarify.or to change a procedure, as long as this 12 procedure goes through a formal review and change process 13 in the time and manner.

14 In this case the status is that the subject memo up 15 here was rescinded.

All the memos, all the current l

16 memos, that were in the start-up file were reviewed for 17 similar situations, and none were found.

When I say i

i 18

" current memos," there were a few memos that had been 5

j 19 deleted sometime back and could not really be found, so

[

Z 20 they were not current.

21 All of the prerequisite test results were evaluated

?

b 22 to-determine the impact on subsequent testing, and there

~23 1.

was no impact on subsequent testing found to exist.

i 24 l We interviewed a number of testing personnel to j

' ~

25 determine from them why this situation, the test support l

I I

I

102 1

personnel signing off on initial conditions, was handled

(

2 as it was.

The interview showed that this process, where 3

qualified test support personnel were allowed by the 4

system test engineers to sign off the initial conditions, had taken place since the start up of the testing.

This 5

6 is satisfactory from a technical standpoint, as long as 7

the test personnel are qualified to verify for a 8

particular prerequisite test.

I 9

There are some prerequisite tests, such as pump to checkout, valve alignment and things like that, that the 11 systems test engineers must verify and sign off 12 themselves.

In our investigation we found that this was 13 the case.

The Craft personnel were only allowed to sign 14 off on initial conditions on those 1rerequisite tests 15 where they were qualified to check out the initial I

16 conditions.

6 I

g7 A Results Report is being prepared in this case.

[

t 18 The last ISAP testing is preoperational testing.

ii 19 There were two issues, again, in this case.

First was i

.that system test engineers were required to ootain design 20 t

21' change information on their own initiative, as opposed to 1';

having it brought or having it.done for them by design 22 23 control personnel, for instance.

The other issue was that there was a potential for 24 25 adverse impact on testing due to the document control i

t

. _. ~. _. _

.. _ _, _ _ ~ _ _

1

~

103 m

I l

system problems, and these problems were primarily

(

identified in SSER 11 of the QA/QC TRT investigation.

3 The status of this is that we evaluated the l

administrative controls and methods, both in start up and 4

5 in document control, and found the present procedures, 6

methods of control, were appropriate and adequate.

They 7

had been improved considerably within the last year or 8

year and a half, but we found they are adequate, and the 9

results of the rest of their investigation here, I think, 10 would confirm that.

11 We interviewed start up and document control 12 personnel to determine, first of all, how they felt about 13 the present situation and how the particular start-up l

14 people found it to be suiting their requirements.-

15 Start-up and Administrative Procedures 7 and 21 were f

16 revised or upgraded to provide additional guidance in the 17 case of SAP-7, and additional documentation, design 1

i 2

18 l

documentation, was properly incorporated into procedure l

l j 19 in SAP-21.

These procedure changes were considered not ir l

20 to be essential, they were augmenting.

l i

21 For the second issue we developed and implemented as

?

t l5 22 spelled out in the action plan a fairly extensive i

l l

l 23 sampling and evaluation program, looking at all of the 24 design changes that could have impacted on the testing 25 programs.

We looked at both prerequisite and I

i

104 1

preoperational testing, even though the TRT seemed to

(

2 only maybe be concerned with preoperational testing.

We 3

felt that it was really the thing to do to look at both

~~

4 prerequisite and preoperational testing.

We completed 5

that and the Results Report is in the process of being 6

prepared.

7 As I said, we felt that the methods were adequate.

8 We did not find any cases of adverse impact of document 9

control problems on the testing program.

10 MR. CALVO You look at some ISAP's that, in my 11 opinion, appear to be of a minor nature.

Did you reach 12 an overall conclusion about the preoperational testing of 13 the Comanche Peak steam electric station?

Tn your original conclusion you went through enough procedures, 14 through enough documentation, that you have developed a i

15

{

warm feeling about how the preoperational testing was 16 I

17 conducted, or were you limited only to the ISAP's?

i IS MR. WISE:

No, I think that we have looked at enough 5j 19 of the testing programs to assure me that the

!r 20 prerequisite and preoperational testing program was 21 certainly adequate.

It did a good job of what it was

!li intended to do.

22 23 MR. CALVO:

But you say that some considerable f

improvements were made in the past year, past two years.

24 25 Why you made some improvements, I missed that point.

I

105 1

MR. WISE:

In the document control.

One of the main

{

things that was done was the creation of the satellites, 2

3 ths document control satellites, and there is one 4

satellite serving the start-up organization alone, and 4

the document control people in these satellites do 5

Perform a number of services for the start-up 6

organization to assure that they have the updated design 7

information right in their area at all times.

8 That's the' 9

main thing that's happened.

i 10 The responsiveness of document control to start-up requirements -- the start up probably has as much or more gi juice for design documents and design changes as anyone 12 as far as the broad spectrum of design changes.

13 And from what we see, we feel that presently document control is i

14 providing those services and in a very good fashion.

15 i

i 16 MR. CALVO:

In essence, as a result of going through 3

I this ISAP's, you pretty much look into all the procedures g-l that govern the operational testing.

You have not left i

IS i

19 anyone out.

aj MR. WISE

I don't think so.

i 20 MS. GARDE:

I In a number of the ISAP's that you g

talked about today, you said the Results Report has been 8"

• 23 "Y '"

" #9 E E*#"

MR. WISE:

Just one.

III.A.2 is the only Results Report'that has been submitted to the SRT.

The remainder

.-,----..,7.-,,r-,-r,

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106 1

are --

(

2 MS. GARDE:

Preparing results.

You're still working 3

on them.

4 MR. WISE:

Yes.

5 MS. GARDE:

When the Results Report is issued, will 6

it contain the basis of the conclusions that you have on 7

the view graph?

8 MR. WISE:

Yes.

My intent -- and I think that's the 9

intent in the Program Plan -- is that the results will 10 stand alone and substantiate the -

11 MS. GARDE:

On III.A.4 when you said -- at one point 12 you said that you evaluated 27 other start-up change 13 procedures and data packages; is that correct?

14 MR. WISE:

Yes.

15 MS. GARDE:

07 III.B you said you' looked at other l

16 project groups, administrative controls and procedures, lf 17 and found them adequate.

How many other groups did you 5

=

18 look at -- or procedures did you look at?

1. j 19 MR. WISE:

It was essentially everyone who had l3 i

20 something to do with the FSAR, who might have a need or l,

21 see a need to question the condition of the FSAR.

In

$li other words, TUGCO Engineering, Brown and Root, L

22 23 Westinghouse, QA Group and Licensing Group in Dallas, and i

I 24 the Plant Staff Operation's group.

25 MS. GARDE:

Will those all be listed in the Results

107 i

1 Report?

(

2 MR. WISE:

Yes.

3 MS GARDE:

On III.C you said, when you were talking.

4 about the review of the current memos, you said a few 5

memos had been deleted and could not be found.

Are you 6

saying.that you know of the existence of other memos but 7

you have never seen them?

8 MR. WISE:

There were eight memos out of 700 and.

9 something that could not -- in other words, the piece of 10 paper could not be resurrected.

There were titles in 11 four of those cases.

In looking at the titles, they had 12 nothing to do with the procedures.

On the other four, 13 nothing could be found pertaining to those memos.

At 14 this point they dida't exist that we could find.

15.

MS. GARDE:

Were they memos that put out 2

16 instructions to STE's?

t 17 MR. WISE:

None that we saw.

We could find the

! j 18 titles of four, and they were not.

19 MS. GARDE:

You~just don't know anything about them.

3

}

20 MR. WISE:

The titles were not -- the other four we 21 could not find the titles nor the papers at all.

As I

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l

!i 22 i say, they.had been deleted.

Those four, I don't know i

f.what the subjects of them were.

23 24 MS. GARDE:

That's all.

L 25 MR. BECK:

At your pleasure, we can have Mr.

l i

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m -_,,

108 1

Honekamp give his update and status of civil / structural

((

2 and mechanical and miscellaneous ISAP's.

I'd like to get 3

that out of the way so he can go to work tomorrow morning 4

at the site, if that's okay with you-all.

S' MR. HONEKAMPt My name is John Honekamp.

I'm the 6

TRT Issues Manager for civil / structural / mechanical and 7

miscellaneous CRT issues.

I report to Howard Levin, who 8

is the Review Team Leader for that area.

9 What I'm going to do is run through quickly each of 10 the 13 issues that TERA has responsibility for, the first

~

11 one being conduit supports, Issue I.C.

If you remember

'12 from the action plan, there are basically two parts to 13 that TRT issue.

The first was an as-built and seismic 14 analysis of two samples of two inch and under conduit The second part was a damage assessment based on 15 runs.

l 16 the results of that analysis, i

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17 Where we stand today is that the as-built and i

E 18 seismic analysis of both samples are complete.

We're in t

, i 19 the process of doing the interaction evaluation and i

t I 20 damage assessment.

There has been a program change in l

l 21 that a test program has been added in this area, and the l i i

22 purpose of that test program is to confirm some 23 assumptiens, primarily in the area of stiffness, that l

were made in the procesa ot doing the seismic analysis.

24 23 That's where ue stand on I,C.

I

r 109 1

The next issue, II.A, which deals with the case

(

2 where some reenforcing steel was added to a rebar Phase 2 3

drawing that was not included in the pour for the reactor 4

cavity.

5 The activities included in the action plan are 6

pretty much the completed milestones that you see here.

7 The first item is analysis of the as-built condition of 8

that reactor cavity wall.

That analysis has been 9

completed and verified by the third party.

10 There were two separate reviews in the action plant 11 a review of the NCR for all : hose cases, documented 12 cases, where rebar was omitted, or where there was

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13 indication of' a problem of major embedment.

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14 We also did rebar reviews looking for the case where 15 there might have been a pour made where the placement of

-l 16 the embed was not in accordance with the latest current 3

17 effective design documents for that particular embedment.

l i

E IS These pour card reviews are complete.

The procedure

!j 19 review is complete.

There were no program changes, and i

t 20 we're in the-final evaluation state on that ISAP.

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21 l Concrete Compression Strength.

The issue in this

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I 2

22 l case dealt with the allegation of falsification of l

concrete cylinder data.

The ISAP itself was structured 23 l

I 24 l to define the concre':e that was poured in safety-related l

I i

25 Category 1 structure in the time frame at issue, and then

110 I

to select another time frame in that same general area 4

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2 that was outside the time frame of issue, and identify

.3 the concrete that was poured in that time frame and some 4

control concrete, and perform Schmidt hammer tests.

That 5

work has been comp 3 eted.

The statistical analysis of the 6

resulta has been completed.

There were no program 7

changes, and we're in the final evaluation for that ISAP.

~

8 MR. SOFFELL:

When you say "no program changes,'

9

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does that mean you've reached a conclusion?

10 MR. HONEKAMP:

That means that we've completed the 11 work, and that we feel that we can draw our conclusion 4

i 12 without making any changes to the structure of the l f-13 program.

We don't have to enlarge the program.

We're

,N 14 still cleaning up and finishing our_ final evaluation, but I

15 we found nothing that would cause us to expand the

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16 program.

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17 Issue II.C, which dealt with the maintenance of air

! i l 5 18 gap between concrete structures, the seismic air gap, the 5

19 completed milestones. include the as-built inspection of f i 20 all the building-to-building seismic gaps, our procedure 21 review and the removal of debriu from what are called 5

l! 2 22 single wall gaps, which basically are readily accessible

(

• 3 gaps.

That has been completed.

l i

8 In the area of program changes, as a result of this 24 i

/

25 i review and the review that I'll talk about later which i

i

111 2

1 deals with critical spaces, we identified an additional

(

2 gap that was not included in the original ISAP, and 3

that's the gap between the containment and the 4

containment's internal structure.

We're in the process 5

of inspecting that gap now.

6 The other thing that's going on is removal of debris 7

from the double wall gaps, widening of gaps where they 8

are less than required by the design analysis, and then 9

there will be a final inspection confirmed that the 10 debris are removed and the gaps are now adequate.

That inspection will be overviewed by a third party.

11 12 MR. SHAO:

Essentially, you will remove all the r

13

(

debris, maintain the gap.

You don't change the seismic I4 analysis.

15 MR. HONEKAMP:

The plan is to remove all the debris l

16 right now, Larry.

It has been removed from single wall 5

17 gaps.

It has not yet been removed from double wall gaps, e

l 1 l i is The project plan is to remove it all.

If they don't

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19 succeed, there will be some evaluation required.

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20 MR. SHAO:

I read somewhere there was some concrete t

within the gaps being removed.

21 l s

MR. HONEKAMP:

Yes, that's being removed.

22 23 l MR. SHAO:

So you don't have to change your seismic l

4 analysis.

3 23 MR. HONEKAMP:

That's the intent.

_ ~.. - -

112 Issue II.D, which deals with the seismic design of I

({

2 control room ceiling elements.

Again, there were two 3

parts to this particular issue.

One dealt with the 4

control room ceiling itself, and the other dealt with a 5

verification of the damage study, which deals with the 6

seismic two-over-one type interactions.

7 Thu status at this point is that the existing 8

ceiling has been removed and a new ceiling has been 9

designed.

The third party is now in the process of 10 reviewing the new control room ceiling design.

There 11 were no program changes, and we're following still along 12 the existing ISAP's revision that you reviewed.

The 13

(

damage study verification is in progress.

14 MR. SHAO:

The last item covered the whole plant.

15 MR. HONEKAMP:

Yes.

It focuses on the Unit 1 Damaga l

{

Study because that's what's been implemented.

The 16 17 program is the same for Unit 1 and Unit 2, so we looked i!

IS at the program and as fa.e as the inspections and so 19 forth, we're focusing on Unit 1.

l 20 MR. SHAO:

Have you found any proolems so far?

21 MR. HONIKAMP:

In this area?

e'

,i MR. SHAO:

Yes.

22 j

I 23 MR. HONEKAMP:

Yes,.there have seen some areas that l

24 were n t included, architectural features that were not addressed, which, if you remember,_was part of the TRT 25 j

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~

113 1

issue, asking whether all the architectural features had

((

2 been --

3 MR. SHAO:

Aside from architectural-features, do you 4

'have.any other structures, components --

5 MR. HONEKAMP:

Have there been any other problems?

6 MR. SHAO:

Yeah, like yesterday semebody mentioned 7

about the --

8 MR. HONEKAME:

I'm just thinking a minute, Larry.

j 9

No, can't think of any problems other than 10 architectural features review.

11 MR. BECK:

Larry, that question is one of scope, whecher or not those types of interactions were included 12 f

13 in --

N 14 MR. SHAO:

Maybe I should rephrase my other 15 question.

Are you looking at anything beyond l

i 16 arch!.tectural features?

I 17 MR. HONEKAMP:

Yes.

We've looksd at the methodology e

Y l

1 18 that thsy used, for example, for considering piping, non-l i

g I

seismically supported pipe, and conduit -- well, not 19 20 conduit; conduit was addressed separately under I.C.

I'd say the broad scope of the Comanche Peak damage study 21 8

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progrcm, which includes the things in addition to 22 23 architectural features..

i 33 MR.'5HAO:

So you will assess damage studies.

l 25 MR. HONEKAM?:

The entire scope of the damage study

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program is looked at.

The only problem areas that I can

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2 recall, Howard, at the moment were in the architectural 3

features area.

Basically what we're seeing is that the

~

4 items that were in the program appear to be addressed.

5 The items that were not in the progrcm, we've encountered 6

some problems.

7 TRT Issue II.3, which dealt with allegations of 8

unauthorized cutting of.rebar in the fuel handling i

9 building.

We've completed the procedure review.

We've 10 completed the review of all rebar cut requests that were issued for the installation of hilti bolts, trying to 12 identify those cases where there was a possibility of 13 cutting an unauthorized bar.

14 In every case where we concluded there was a 15 possibility to make an unauthorized cut, we. performed an l

16 ultrisonic inspection to determine the actual length of

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17 the bolt installed, anG for six cases w'a concluded that i!

IS the bolt was long enough, that if the second bar is lined 5j 19 up underneath it, it's possible it could beg it could Ir 20 have been cute We have completed the'cnalysic of the 21 structural significance df those potential cuts and

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i 22 concluded that basical'ly there is no structural j

i 23 significance at this time.

I l.

I 24 Now, program changes, there are two things.

One, 25 conducting these reviews, it was determined that there

~

115 1

are shear lugs that have been added to a number of pipe

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2 support base plates, and the method by which the shear 3

lugs were installed creates the possibility of a

unauthorized rebar cuts.

We're in the process now of 5

identifying all the casee where shear lugs were 6

installed, and once we've identified all these cases, we 7

basically repeat this process, the same process that was 8

used for examining hilti bolt installations.

9 The other thing that came out of the review was that 10 the ISAP is structured based'on using the rebar cut 11 request log as the identification mechanism for 12 authorization to cut rebar.

The actual enginaering f

13 directions that authorized cutting rebar are CMC's and N

14 DCA's.

In the process of doing the reviews, we realize that the cut requests log came into existence in late '80 15 g

16 basically, although prior to that time CMC's and DCA's

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17 were issued to authorize cutting of rebar, which is in

'ii 18 accordance with our procedures.

It's just that our 5j 19 original basis for assuming that we had them all there 20 was not correct, so we've expanded this review to identify all civil / structural C1C's and DCA's that were 21

['s 22 issued prior to January of '81 that authorized cutting j

i 23 rebar for.those bolts.

3 That review is going on now and, of course, the 3

remaining on-going activities are that shear lug review 25 a

116 I

and this CMC /DCA review.

Once we complete that, we go

(

2 back through the same process that I described earlier.

3 Issue V.A, Mechanical Areas, which deals with the 4

inspection of what the TRT characterizes as Type 2. skewed 5

welds in NF supports.

We have completed the reinspection 6

of the sample of 60 pipe supports containing piping 7

skewed welds, and we have completed the procedure review.

8 There are no program changes, and we're in the process.of 9

evaluating the results of the inspection.

10 Issue V.B, which deals with the improper shortening 11 of anchor bolts in steam generator upper lateral 12 supports.

This hasn't changed much since probably the 13 last time you saw it.

The inspection of 120 of the 144 l

14 bolts in Unit 1, including bolt holes, is completed.

In 15 the process of doing the inspection and starting the DAP l

16 reviews, we ran into a problem in the design of the

[

17 embedment itself, and at the moment the DAP is-involved i!

18 in the -- I should.say Gibbs & Hill is involved in the ij 19 reanalysis of both the upper and lower lateral supports, l l Z

20 and the DAP in parentheses means that there's an overview l

21 there.

.ti 22 l Based on the results of that reanalysis, we will i

23 then complete the inspection of those bolts, depending on what the new predicating requirements turn out to be.

I 24 25 The other activities that are ongoing now -- if you

117 1

remember the ISAP calls for two other bolt populations to

{

2 be examined, the concept being to look at connections 3

that were similar to the steam generator upper lateral.

4 One population that was selected in the ISAP was Richmond 5

inserts that are used for ASME pipe supports, and the 6

other population is-basically other drill and tap blind i

7 hole type civil / structural-type connections.

These 8

populations have been defined, and we're in the process 9

of selecting samples.

10 There was a records review that was associated with 11 the fabrication installation record for the steam 12 generator upper lateral support.

We have compleced a 13

(

significant portion of that, but it's still ongoing and e

14 the procedure review that deals with the process by which critical parameters related to bolt joints are inspected 15 i

16 and documented.

3

[

17 So those are the activities basically that remain.

si 18 Issue V.C deals with the design considerations for 5j 19 piping systems thr.t have a seismic transition.

The last i

I 20 version of this action plan basically acknowledged the l

21 l existence of the Stone and Webster piping support

,i l

i 22 i reanalysis program.

What this ISAP now has done is completed the identification of all the linings that have 23 a seismic transition, and that identification has been 2-8 25 parsed to Stone and Webster and to the DAP under this

118 1

DSAP IX, where the actual activities that would be

}{

2 required to resolve the TRT questions will take place in 3

the Stone and Webster program.

They will not take place 4

under V.C.

5 MR. SOFFELL:

Will there be a report on V.C?

6 MR. BONEKAMF Yes, but it will basically be, if you 7

will, a coenitment tracking report.

We will draw no 8

conclusions under V.C.

We'll just say this is how we 9

packaged this information up and sent it over.

If you 10 want to find out what happened to Issue V.C, it's kind of a road map to get over to the Stone and Webster program, 11 12 and that program and DSAP IX will report the results.

If 13 Issue V.D, which is plug welds.

We have completed

~

ik the reinspsetion of the cable tray supports, and as we 14 stand there, we're completing the reinspection of the 15

j ASME pipe supports for the presence of plug welds.

There 16 i

17 was another activity in the ISAP that dealt with the 5

l' evaluation of the DCA that authorized plug welding and gg i p,j 19 cable tray support.

We have completed our evaluation of i

3 20 that DCA.

Again, there are no program changes.

The work was completed in accordance with the ISAP, and we're in

[

~

the p,rocess of evaluating results.

c 22 23 Issue V.E, which deals with the installation of main 24 steam pipes.

The analysis of both Loop 1 and Loop 4 in

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05 l Unit 1, that'is, the analysis of the main steam pipa lift t

t l

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l t

119 u

I events, which is what this issue deals with, that has

(

2 been completed.

The review of the construction practices 3

related to the use of temporary pipe supports has been 4

c6mpleted, and there are no program changes.

We're in 5

the final phases of evaluating the results.

6 MR. SHAO:

The stresses are very low, right?

7 M2. HONEKAMP:

They're all within allowables.

4 8

KR. SHAO:

You mean allowable or very low?

9 MR. HONEKAMP:

There are a couple that are close to 10 allowables.

They're well within 11 This is Issue VI.A under the miscellaneous category.

12 This first one deals with the gap betiween the reactor 13

(

pressure vessel reflective insulation and.the biological N

{

14 shield wall.

There were a number of activities in this 15 ISAP.

Two of them, the review of the test results from 16 l

Unit 1 and the analysis for Unit 2 for cooling flow in I

17 that annulus, the third party has completed the review, ii IS and-we've also completed our procedure review that deals i

19 with the maintenance of critical spaces.

3:

20 There are no program changes.

The major activities i

21 I l

g left are a review of the sample of non-safety-related

[

I s

22 design changes for their potential impact on safety-23 related components, and the second item is the review of l

critical spaces and the reinspection.

This review is 21 25 substantially done, and that's what identified that one I

4

-120 1

gap batween the reactor bu'ilding containment and the

(

2 internal structure.

We're about to start with 3

reinspection.

4 And the last of the TRT issues in my area, VI.B, the 5

polar crane shimming.

We have completed the record 6

review and rail motion tests, that is, the testing to j

7 determine what's causing, or at least the forces involved

{

8 in, the rail motion.

9 Again at this point, there are no program changes.

j 10 The major activities that remain are the girder seat l

f inspe.ction and a general inspection of the remainder of 11 12 the support system, and a review of the design 13 modification that's in progress by the Project to l

i 14 eliminate rail motion.

15 That's all I nave.

1

!j 16 MS. GARDE:

Am I correct in assuming that the i

'[

i 17 categary that said " program changes, none," does not mean f

'2 ii 1

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18 that there were no deficiencies or identified deviations t

'j 19 that you found?

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I 20 !

MR. HONEKAMP:

It means, Billie, that we have been l

21 l implementing the program basically right as stated in the

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'5 I

action. plan, except where I said what the changes are.

{

22 23 Rev 2 of the Program Plan, that's been issued.

I 24 MS. GARDE:

But you didn't answer my question.

i j

25 MR. HONEKAMP Would you restate the question again?

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121 1

MS. GARDE:

Your format says there was no program

(}

2 changes as a result of any of the work that you've done 3

on these areas.

4 MR. HONEKAMP Well, there are some that we've 5

discussed.

6 MS. GARDE:

Generally, there's no program changes?

7 MR. HONEKAMP:

That's true.

8 MS. GARDE:

That conclusion does not mean that there 9

were no discovered deviations or deficiencies.

10 MR. 3ONEKAMP:

That's correct.

11 MS. GARDE:

If you had written up a report and said j

12 there was so many deficiencies, so many identified if 13 defects or whatever, that's not included in the --

I (;

14 MR. HONEKAMP:

That does not include the preliminary f

{

15 results, that's true.

I 16 MS. GARDE:

Now, when you say that the evaluation of 17 results is ongoing, does that mean that you're preparing

~

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18 your Results' Report sent to the SRT?

Ij 19 MR. HONEKAMP:

In some cases, yes; in some cases h

20 we're still doing analysis.

We haven't gotten to

[

t 33 actually writing the report.

I i

)

33 MS. GARDE:

But you've done enough analysis to t

7 23 conclude that there are no program changes, j

(

t MR. HONEKAMP:

That we can finish the program as

.j4 25 implemented, that's true.

t I

122 I

MS. GARDE:

So when the Results Reports come out,

(

2' there will be a lot more meat on it.

3 MR. HONEKAMP:

Of course.

This is a status report.

4 MS. GARDE:

Thank you.

5 MS. VIETTI-COOK:

I think you've worn us cown.

0 MR. BECK:

Well, given that, I'm tempted to 7

i continue.

However, we'll adjourn until 8:30 tomorrow 8

morning.

9 (The meeting was adjourned at 10 5:30, to be resumed Wednesday, 11 November 6, at 8:30 a.m.)

12 1

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