ML20024A013
| ML20024A013 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 05/21/1983 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML16340D378 | List: |
| References | |
| NUDOCS 8306150281 | |
| Download: ML20024A013 (92) | |
Text
., - -
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION J
In the matter of:
DIAELO C.i':?C:-
p Docket No. 50-275 DISCUSSION OF IDVP AUDIT OF d'
DCNPP-1 CONSTRUCTION QUALITY ASSUPANCE i
l.
i Location:
Boston, Yassachusetts Pages:
1 - 90 Date:
Saturday, 21 May 1983 9
L
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TAYLOE ASSOCIATES Coun Reponers m sinco.w.sm m 8306150281 830610 WnMapa D C M PDR ADOCK 05000275 coa :9M950 p
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1 UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
DISCUSSION OF IDVP AUDIT OF DCNPP-1 4
CONSTRUCTION QUALITY ASSURANCE 5
6 Conference Room 321 Logan Hilton Hotel 7
Logan Airport Boston, Massachusetts 8
Saturday, May 21, 1983 9
le The NRC-IDVP meeting convened, pursuant to 11 notice, at 9:30 a.m.
12 NRC Staff Present:
13 f
H.
SCHIERLING, Presiding 14 J.
SPRAUL L.
CHANDLER 15 T.
BISHOP 16 Teledyne Staff Present:
17 J. CRAGIN 18 J. FLAHERTY W.
COOPER 19 L.
NORIEGA 20 Stone and Webster Staff Present:
21 i
F.
SESTAK l
22 C.
LUNDIN S.
BARANOW 23 C. RICHARDSON E. ERLANDSON 24 D.
IVES l
F.
BEARHAM 25 TAYLOE ASSOCIATES l
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PG&E Staff Present:
2 B.
NORTON 3
S.
SKIDMORE J. MANNING 4
R.
ETZLER R/ TWIDDY 5
6 Bechtel Staff Present:
7 C.
DICK H.
FRIEND 8
P.
MASON 9
Westinghouse Staff Present:
le W.
GAUGLOFF D.
ALEXANDER 11 On Behalf of the State of California:
12 R. HUBBARD 13 14 15 16 17 18 19 20 21 22 23 9
24 25 TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1904 Washington, D.C. 20006 (202) 293-3950
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MR. SCHIERLING:
Good morning.
3 My name is Hans Schierling.
I am with the NRC.
4 We meet here together today for a meeting to discuss 5
construction quality assurance.
6 In attendance are representatives from 7 Teledyne, from Stone and Webster and PG&E.
Representad 8
also is the State of California.
9 Before we begin with our introduction of the 10 members here, I would you to be aware we are taking a 11 transcript of this meeting and for that purpose we should 12 limit ourselves to have only'one person talk at a time and 13 please speak clearly so we have a good transcript 14 available.
15 Why don't we start with the introduction.
16 Jack, why don't you go ahead.
17 MR. SPRAUL:
My name is Jack Spraul. I am with 18 the NRC Office of Inspection and Enforcement, Quality l
19 Assurance Branch.
I 20 MR. CHANDLER: I am Lawrence Chandler. I am with 21 the Office of Executive Legal Director and I am coun.sel to 22 the staff on the Diablo Canyon.
23 MR. BISHOP:
My name is Tom Bishop. I am Chief 24 of the Reactor Projects Branch in Region V of the NRC.
l 25 MR. HUBBARD:
My name is Richard Hubbard. I am l
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1 representing the State of California, 2
MR. FLAHERTY:
Jim Flaherty. Teledyne 3
Engineering Services.
4 MR. ERLANDSON: Ed Erlandson, Deputy Director of 5
Construction. Stone and Webster.
6 MR. RICHARDSON:
Carl Richardson, Engineering 7
Manager, Stone and Webster.
8 MR. BARANOW:
Stan Baranow, Assistant Deputy 9
Senior Manager, Stone and Webster.
10 MR. LUNDIN:
Craig Lundin, Chief Engineer, 11 Quality Assistance Division, Stone and Webster.
12 MR. SISTAK:
Franh Sistak, Project Manager, 13 Stone and Webster, IDVP.
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14 MR. IVES: Richard Ives, SDQA Engineering, Stone 15 and Webster.
16 MR. COOPER: Philip Cooper, TES Program Manager.
17 MR. NORIEGA:
Leandro Noriega, Senior Engineer, 18 TES.
I 19 MR. MASON:
I am Peter Mason, the Diablo Canyon i
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Froject. Bechtel.
20 21 MR. CRAGIN:
John Cragin. Teledyne Engineering 22 Services.
23 MR. TWIDDY: Dick Twiddy, PG&G Quality Assurance 24 Supervisor, Diablo Canyon.
25 MR. ETILER:
Rick Etzler, Project TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1004 Washington, D.C. 20006 (202) 293-3950
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Superintendent, Diablo Canyon.
2 MR. MANNING:
Jim Manning, Construction 3
Superintendent, Diablo Canyon Project.
4 MR. BEARHAM:
Fred Bearham, Quality Assurance 5
Engineer, Stone and Webster.
6 MR. FRIEND:
Howard Friend, Project Manager, 7
Diablo Canyon, the Diablo Canyon Project.
8 MR. NORTON:
Bruce Norton, Attorney for PG&E.
9 MR. SKIDMORE:
Steve Skidmore, Manager of 10 Quality Assurance, PG&E.
11 MR. DICK:
Charles Dick, Diablo Canyon Project 12 Managment.
13 MR. SCHIERLING:
Pete, do we have you in there?
14 MR. MASON:
Yesi sir.
15 MR. SCHIERLING:
Okay.
16 The purpose of the meeting, as I mentioned 17 earlier, is to discuss certain aspects of construction 18 quality assurance.
19 As you are aware, the Diablo Canyon project has 20 through Teledyne and Stone and Webster conducted an audit 21 or construction quality assurance efforts that were in 22 place prior during the construction of the Diablo Canyon 23 plan.
24 That effort has been completed.
It was l
25 primarily conducted by Stone and Webster.
The effort has l
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been completed.
Two interim technical reports have been 2
issued, ITR-36 and ITR-38, which exist in Revisien 0 and r
3 Revision 1. The staff has reviewed both of those reports.
4 We recently have requested the IDVP to provide some 5
additional information regarding the activities.
6 In eeneral we are interested in two aspects.
7 One is we would like to obtain some more information 8
regarding the close-out of specific EOIs identified in 9 'both reports and, secondly, we would like the IDVP to gg address the bases for the general statements in the report 11 regarding the adequacy of the quality assurance that was 12 applied and that existed and'was implemented for the two 13 companies that were audited.
14 We might have some additional specific 15 questions as we go along, but I understand that you hav'e 16 prepared a presentation and I think it might be best to 17 get everybody up to speed and on the common denominator to 18 go through that presentation hopefully without any 19 interruption.,
23 Bill, I turn it over to you.
21 MR. COOPER:
Thank you, Hans, and good morning, 22 gentlemen and the lady who is present, and welcome to 23 Boston.
24 (Laughter.)
25 MR. COOPER:
My role this morning is a brief TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1004 Washington, D.C. 20006 (202) 293-3950
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introduction of the status of the construction QA effort.
2 In a quick summary of the background, the first 3
introduction of this into the system was on September 1st 4 at a meeting between staff and the Diablo Canyon project 5 where Mr. Maneatis of PG&E announced that they were 6 volunteering to have such a program. This was confirmed oy 7
the PG&E letter of September 7th.
O During the next few weeks Mr. Maneatis and Mr.
9 Friend came and visited with me and talked about their
- g expectations from this program, their plans for it, the it interest in having the IDVP operate the program in the 12 same manner that we had the Pest of it from the viewpoint 13 of independence and our procedures.
14 The three of us and others met with the senior 15 Stone and Webster personnel in engineering, construction 16 and quality assurance and I may have missed one area, and 17 if I did, I am sorry, but to indicate the level of interest and the level of effort which the utility wanted 18 us to operate in in this manner.
Based upon those discussions, the IDVP defined an adjunct program for evaluation of CQA and we submitted this program, or Revision 1 of this program on October 5th of 1982.
Very briefly, that program established that two reanizations would be audited and established four tasks, 5
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reporting.
3 The reporting system used the normal ITR system 4
f the independent program and a modified EDI system, and 5
I think it is very important to understand that the EOI system used was differer.t here than elsewhere.
Our 7
8 We defined the Class A error as being a 9
finding, something which was accurate in potential for g
significant impact on adequacy.
g We defined in thesEOI system a Class C error as g
something that in the QA world would be termed an g
f observation, that the potential finding was accurate but g
it did not have a potential for significant impact on adequacy.
g The third category was that the potential g
"I 18 We reported these results in ITR-36 and 38.
36 9
applied to Wismer-Becker.
There was one finding, 19 g
observations and five were invalid, g
ITR-38 reported on Guy F.
Atkinson. There there 22 o
Were four observations.
Mr. Novak of staff in his letter 3
to me of May 2nd raised the issues which Hans has 24 summarized very well as to their concerns about the ITRs.
25 TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1004 Washington, D.C. 20006 (202) 293-3950
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9 First, that the information in the ITR they did not consider was sufficient to justify closing out the EOIs and, second, the review results did not appear to be 3
entirely consistent with specific EOI findings.
4 5
prepared revisions to both ITRs in what we thought was responsive to both of these issues.
7 A staff phone call of the 17th of this month 8
indicated very clearly that we had not fully understood 9
their concern in this second area, and it is as a result 0
of that phone call that we are having this meeting here this morning in an attempt to provide further discussion on these matters, 3
The Stone and Webster folks have prepared a g
very appropriate presentation which will introduce the 5
issues in a time of approximately a half an hour.
/
Following that we are prepared to go into whatever detail g
y uw s e u
s geest that since certain aspects 18 of the intent and the procedures of this program have not 9
l been fully understood, that it would be desirable to let 20 them go through that point.
g Let me ask first if there are any questions 22 l
and, if n t.
I will turn it over to Frank Sestak from 23 Stone and Webster.
24 Frank, why don't you go ahead.
l 25 I
l TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1004 l
Washington, D.C. 20006 (202) 293-3950
10 MR. SESTAK:
Thank you. I am Frank Sestak.
The construction QA review and audit was 2
intended to assess whether the construction of Diablo 3
Canyon Nuclear Power Plant, Unit 1,
was performed in 4
a rdance with the quality requirements appropriate for 5
the time of plant construction.
6 The program was accomplished by the development 7
of check lists of attributes for two contractors based on g
requirements from various documents such as PG&E 9
specifications, Contractor or subcontractor QA programs, PG&E drawings and contractor and subcontractor drawings.
g A Finding and Review Committee was established g
to reViaW each potential finding developed by field g
auditors and inspectors for determination and accuracy and g
assess its impact on the adequacy of the plant.
15 The FRC was made up of five senior experienced g
personnel as follows:
g Ed Erlandson, Deputy Director of Construction, 18 with greater than 35 years experience in construction and 9
l construction manager and superintendent at a number of
,0 nuclear plantsi g
Carl Richardson, Engineering Manager with 22 grea er an 0 years experience in power projects, 23 project manager and project engineer on nuclear plantsi 24 Craig Lundin, Stone and Webster, Chief 25 i
TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1004 I
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11 Engineer, Quality Assistance Division with greater than 15 years experience in QA and site QC manager at a number of 2
nuclear plantsi Jim Flaherty, Teledyne, Manager of Engineering, "8
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fieldi and Frank Sustake that is me, Chief Engineer of the 7
8 **
- 8 power projects, project engineer on various nuclear 9
projects, Project Manager of the Stone and Webster IDVP g
effort and Chairman of the FRC.
g Each potential finding report forwarded to the 2
FRC was reviewed and classified per IDVP program r e qu ir emen t s.
As Bill alluded to before, they were 4
ategorized as findings, observations and invalid.
5 Upon completion of all FRC reviews. 29 in total, the FRC conducted a site visit on November 16th and 7
"8 18 reviewed by one or more members of the FRC.
9 Upon receipt of the PG&E response to the PFRs, 20 29 EOIs were classified and categorized as follows: One g
was a finding, five were invalid and 23 were observations.
The observations were further broken down into 10 23 rogrammatic and 13 other.
24 During the course of our program today we hope 5
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to answer many of the questions raised in various and 2
recent documents such as the NRC letter to TES, 3
Novak/ Cooper of 5/2/83, and a recent joint intervenor 4
petition of 5/10 and 5/17.
5 At the conclusion of our program, we will be 6
open to questions and comments.
7 If there are no questions, we will proceed with 8
our presentation.
9 MR. CHANDLER:
Frank, let me j ust make one 10 comment on something you just said, and that is I guess 11 the staff's principal concern at this meeting is with 12 respect to the matters outliI1ed in Mr. Novak's letter of 13 May 2.
t 14 MR. SESTAK:
We hope to touch on those.
15 MR. CHANDLER:
Okay.
16 MR. SESTAK: Frank Lundin, the gentleman sitting 17 next to me, will begin with a review of the various check 18 lists developed for each contractor by the site QA team 19 and where approprite identify areas related to criteria in 20 10 CFR 50, Appendix 8.
21 He will also review in detail the documents 22 related to EOI 90-26, which was a finding, and two other 23 EOls which were classified as observations.
24' I hope we answer many of your questions 25 relating to the various documents.
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If there are no questions, we will proceed with 2 Crais.
3 MR. FRIEND:
Excuse me, I do have a question. I 4
think I would like to direct it to yourself and to Bill 5
Cooper, and I guess the question is the following.
6 Was it the intent to have the ITRs as a general 7
category be self-standing and answer all the possible 8
questions and al'1ow the reader to reach a total resolution 9
in accordance with the IDVP's resolution as part of the 10 ITR?
11 MR. COOPER:
No, sir, it was not, and our 12 procedures permit requests for clarification from all 13 parties and we had received none up to the May 2nd letter.
I 14 MR. FRIEND:
Thank you.
15 MR. SESTAK:
Craig.
16 MR. LUNDIN:
I am Craig Lundin. As Frank 17 mentioned, we were to review the two contractors to assure 18 that the elements of the quality assurance program were 19 present for construction at that period of time, as well 20 as to verify as much as could be done the implementation 21 of that quality assurance program.
22 In doing that we developed check lists to work 23 to.
Four check lists were developed and utilized by the 24 team at the site.
Two were verification check lists for
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to determine if the practices were in compliance with the 2
specifications and that they had a quality assurance 3
program in existence.
4 In development of these check lists, the 5
specifications we used, the quality assurance programs we 6
used and other documents that would be appropriate to make 7
this verification, the attributes developed can be 8
associated with the elements of a quality assurance 9
program as delineated in 10 CFR 50, Appendix B in that 10 they were appropriate for the scope of the contractor and 11 asked the appropriate questions to assure those functions 12 such as inspection, trainingI material control and other 13 appropriate criteria that should have been applied.
14 They were not cross-referenced specifically to 15 those.
However, they do relate in that we did assure that 16 the elements of that QA program were in existence for that 17 contractor scope of work.
18 In processing the findings, these check lists, 19 if I may digress, these check lists have been available 20 for audit and they have been completed by the team.
l 21 Subsequently they wrote potential finding reports and l
l 22 submitted them to the committee.
They were processed and 23 they are still available.
24 In processing the findings, the other aspect i
25 that I wanted to touch upon in File No. 9026 was to use it l
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1 as an example of how the committee processed the findings.
2 I brought'three as examples that I could talk 3
from, but 9026 being the finding, the only Class A, it
' 4 would probably be most appropriate.
5 The initial report which came from the field 6
reported that further specifications, an LP examination of 7
the lug removal areas on the loop piping, that there was 8
no record of it having been performed.
9 MR. SCHIERLING:
Craig, could you put in maybe 10 what time frame we are talking about, when was the work 11 done, the actual construction work?
12 MR. LUNDIN:
Approximately 1973 in this 13 particular scope of work.
Someone can correct me on that, 14 but in that time frame.
15 MR. SCHIERLING:
The records you looked at were 16 also appropriate for that time frame?
17 MR. LUNDIN:
That is correct. The records were 18 available and complete and we found no evidence of this 19 particular inspection having been performed as required.
20 We processed our open item report in that evaluated that 21 there was no documentation available and we issued it as
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22 that.
23 We did receive a response in which we were told 24 that PG&E had contracted with Pullman to perform this work 25 because their review had not turned up the records that it TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1984 Washington, D.C. 20006 (202) 293-3950 w
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had been performed. So that package for Pullman's work was 2
complete 1y done prior to it being presented to Stone and 3 Webster.for review.
4 That package was sent to us and it showed where 5
all the lug removal areas had been performed by Pullman.
6 It included information to show that Pullman had been 7
approved by PG&E and they were utilizing their QA program.
8 We reviewed the documentation and with one 9
exception Pullman had documented the acceptability of the 10 lug removal areas.
In that particular case, Pullman in 11 working to their procedures had rejected an indication.
to PG&E 'who had performed another 12 They turned it over 13 examination under their own-procedures and accepted that 14 liquid penetrant exam.
15 The Findings Review Ccamittee determined that 16 for our independence that we required that this liquid 17 penetrant test be performed by a third party which would 18 be Stone and Webster and witnessed by a member of the 19 Findings Review Committee to assure the compliance with 20 all the information that we had in the package.
21 That was done and that information in that 22 review and the required inspection was brought back to the 23 committee and the committee acted on the fact that, on 24 that one particular instance, that the liquid penetrant 25 exam that had been performed by PG&E was accurate and TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1004 Washington, D.C. 20006 (202) 293-3950 w
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acceptable.
In fact, the indication was within the 2
requirements that could be accepted per the Code as well 3
as the in-service inspection requirements of PG&E.
4 MR. SPRAUL:
Craig, pardon me, when was this 5
Pullman work done?
6 MR. SESTAK:
Late
'82.
7 MR. LUNDIN:
I think most of it was performed 8
actually in January of
'82.
9 MR. SPRAUL:
Fine, thank you.
10 MR. LUNDIN:
That particular review that 11 Pullman did, which I did not go into, included sketches of 12 all the loops and the surge line I believe as well and the 13 pump casings-and showed all areas of lugs per the drawings 14 and LP reports, thickness reports where required for all 15 those areas. This is in addition, of course, to our review 16 which had performed a visual inspection on all four loops 17 in the surge line piping.
18 The Findings Review Committee in closing this l
19 item, this file, or recommending closure, viewed the 20 information supplied by Pullman and the other information 21 we independently reviewed to assure that the specification 22 requirements were met in determining that the file was 23 adequate for closure. This particular example was 24 classified as an eight.
25 We utilized this type of process on all the i
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you will, to assure that that process was complete.
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Are'there any questions?
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MR. SCHIERLING:
Yes. Somehow I do not quite 4
understand.
We are talking about work that was performed 5
in the early '70sJand QA activities that are now being 6
conducted in the early '80s or as late as half a year ago.
7 Couid you somewhat clarify that for me?
I mean B what was the QA that was applied when the work was T
9 originally done?
10 MR. LUNDIN:
It was done to Wismer-Becker's
+y' 11 program,at that time and the inspections and tests that t
12 were required to be performed, we verified had been 4
13 performe'd.
W'e could not find evidence that this one f:
14 inspection that was required had been performed.
l 15 MR. SCHIERLING:
By Wismer-Becker.
16
'MR.
LUNDIN:
By Wismer-Becker. It was within 17 their responsibility to perform that and we could not find 19 the evidence that it had been performed.
19 We did look at all the inspection requirements.
20 We verified both by actual inspection on our own of what 21 'was available to be seen, a visual inspection of all four 22 loops, as well as verification by the documents required 23 by their program that they had performed all the required l
24 inspections.
25 The goal was to assure that the implementation l>
1 1
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1 of their program in that what they required to ba done to 2 assure that the piping was satisfactory was in fact done.
3 This was an exception that we found.
4 MR. SPRAUL: So there were radiographs available 5
of code welds?
6 MR. LUNDIN:
That is correct.
7 MR. SPRAUL:
And indications that visual 8
examinations had been completed acceptably and everything 9
was okay with this one exception of some lug removal areas 10 did not have a penetrant examination recordi is that 11 right?
12 MR. LUNDIN:
That'is correct.
13 MR. SESTAK:
Single, not plural. One indication 14 was found and there was an inspection performed on all 15 four loops.
16 MR. SPRAUL:
Now you are talking the '83 time 17 frame.
I am looking back at the '73 time frame records.
18 Everything was there except for this one non-destructive 1
19 examination of lug removal areas?
20 MR. FRIEND:
The record of a non-destructive 21 examination.
l l
22 MR. SPRAUL: Was not available from the '73 time i'
23 frame..
24 MR. FRIEND:
That is correct.
25 MR. SPRAUL:
The work was done in '83 with one l
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reject area by Pullman which was subsequently found to be 2 acceptabla to the code.
3 MR. NORTON:
Yes.
4 MR. FRIEND:
That is correct.
5 MR. LUNDIN:
In the total review of 6 Wismer-Becker there were in other file numbers cases where 7 we did not have documentation for specific inspections.
8 However, we found there was evidence the inspection had 9
been performed and documentation that it was successful by 10 other 11 documents. This particular case is the only case where we 12 found that we could not find'any evidence of that 13 inspection.
14 MR. CHANDLER:
Now your close-out on that then 15 is based on the corrective action that was done rather 16 than on some revelation concerning the initial finding 17 that was made 18 MR. LUNDIN:
That is correct.
19 MR. CHANDLER:
It is an otherwise valid finding 20 then that there was a deficiency of some size in 21 documentation with respect to that single item.
22 MR. LUNDIN:
That is correct.
23 MR. DICK:
Craig, I wonder if it wouldn't be 24 helpful to put your overall effort in some sort of 25 perspective.
Obviously it went beyond a simple audit, and TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1004 Washington, D.C. 20006 (202) 293-3950
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I wonder if it wouldn't help the frame of reference here 2
of the meeting if you or Frank would discuss the number of 3
hours you spent and the number of things you looked at and 4
that sort of thing.
5 MR. LUNDIN:
The overall effort, as you 6
mentioned, was not an audit.
It was an evaluation, and as 7
such was performed in a manner such as to look at as much 8
as was necessary by our people in the field to determine 9
that an area or a process or a piece of the program or 10 some hardware was acceptable.
11 To that end, for example, all the loop piping 12 was visually examined.
We performed visual inspection on 13 all the available that wasn't in concrete or couldr't be 14 seen of piping and structural work within the two 15 contractors that we could get to. We recreated as much of 16 the actual inspection as possibly could be done.
17 In looking at the program and the 18 documentation to assure that the appropriate inspections 19 and so forth were performed, we looked at a significant 20 volume of the records and when problems were seen or 21 things we didn't understand, those threads were followed 22 throughout the documentation to assure that it was not a 4
23 common problem.
24 We have some numbers, actual numbers of items 25 inspected and the physical installation of 2,298 items and I
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we probably have numbers of pieces of paper, but I think 2
it is more appropriate to say that we just virtually 3
looked at everything that we could.
4 We had several people there in the neighborhood 5
of eight weeks I believe on site full time doing a full 6
evaluation.
7 MR. SCHIERLING:
How many people did you say?
8 MR. LUNDIN:
How many people did we have on it?
9 MR. BARANOW:
We had 10 people I believe.
10 MR. LUNDIN: Ten people full time reviewing both 11 the documentation required by the program and by the codes 12 as well as the actual hardwa e within the scope of these 13 two contractors.
14 MR. NORTON:
How many things, and I use that 15 term " things," did you look at that could have resulted in 16 a finding or an observation, and I know you can't give us 17 a precise number, but are we talking about a couple of 18 dozen, are we talking about a hundred, or what are we 19 talking about?
20 MR. LUNDIN:
Tens of thousands I think as an 21 order of magnitude.
22 MR. NORTON:
So you looked at tens of thousands 23 and had 297 i
24 MR. SESTAK:
Nine physical findings for 25 Wismer-Becker in the piping area.
l TAYLOE ASSOCIATES t
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MR. COOPER:
Nine physical potential findings 2 which were resolved into one finding.
3 MR. NORTON:
But you looked at potentially tens 4
of thousands.
In other words, if nothing had been done 5
right you could have had tens of thousands of potential 6
findings?
7 MR. LUNDIN:
Correct. The degree of 8
magnification was as great as we could make it on the 9
physical verification at this point in time.
We did not 10 reperform anything and there are some things that just 11 can't be seen.
12 MR. SCHIERLING:
I3ill, let me ask you another 13 question in a broader sense. Do you intend at this meeting 14 to go through each one of the EOIs?
15 MR. COOPER:
We could, but we did not intend to 16 do it.
What we intended to do, by the way, in the 17 revisions if these ITRs was to present roughly a one-page 18 summary of each of the EOI files giving more detail as to 19 what the nature of the response was from PG&E, what the 20 evaluation result was based upon, that is was it simply 21 based upon the resolution sheets we got from PG&E or was 22 there additional field work done and so forth, and a 23 little more about what the nature of the resolution was.
24 The present ITR has a fault which we hadn't 25 recognized would be considered such.
We essentially say l
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that each of these observations was looked at, evaluated 2
by the Findings Review Committee and found not to be of 3
safety significance, not to significantly impact the 4
plant.
That is the reason for the term " observation."
5 What does not come out clearly in those present 6
drafts, and this is what we are trying to do in response 7
to your first concern was to give a little more detail as 8
to why that is so.
9 If you have got a favorite, I suspect the 10 fellows could go into that for you today, or they could 11 give you an illustration about one or two of the 12 observations that were more $ignificant to indicate that 13 the trail was not dissimilar to what was done on 90-26, 14 recognizing of course that they were of much less 15 significance. So not every one of these steps was 16 followed.
17 MR. SCHIERLING:
Let me check with staff for 18 Just a moment.
19 (Brief pause by NRC staff confer.)
20 MR. SCHIERLING:
Let me ask you, when do you 21 think you will come out with the revised ITRs?
22 MR. COOPER:
Ve were expecting to next week if 23 there is not some new development from this meating. I had 24 said earlier that perhaps we had not understood your 25 second point fully and our response to that was perhaps TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1904 Washington, D.C. 20006 (202) 293-3956 r
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26 1
too little as we had intended it and, depending upon how 2
the conversations go today, it may be decided that it is 3
advisable for us to expand on why we came to the 4
conclusion that there is no real problem here and why we 5
came to the conclusion that there is not a generic issue 6
to be faced based on the work that we have performed.
7 Now to the extent that we need to do that in 8
the ITR, it may slow us up a few days, but we need to have 9
more discussion in that area to see if it is necessary to 10 do that.
11 MR. SCHIERLING: Okay. Let me propose this then, 12 that maybe we take a few examples of the specific EOIs and 13 I think it will suffice if within a week or so we will get 14 a revised ITR and maybe even an advance copy of it in a 15 draft form or whatever it might be.
16 I think indeed we should concentrate more on 17 the second aspect which is the general conclusion that the 18 QA program that was used and implemented is acceptable.
19 I would like you to maybe address on what basis 20 you determined, and hopefully you can do that for all five
-21 EOIs together, the five EOIs that you determined to be 22 invalid.
23 MR. COOPER:
Well, let me respond to that one 24 directly and first because we can get those out of the way l
25 pretty fast.
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That was a procedural matter and there is 2
correspondence on this that has been made available to all 3
parties.
There was a misunderstanding at the site on the 4
part of the review team as to the extent to which these 5
concerns could be expressed to the PG&E people and 6
resolvsd on site. As a result of that misunderstanding, 7
there were five items that the site team resolved 8
themselves and had no intention of even issuing a 9
potential finding on.
10 I felt that we had to play this thing extra 11 carefully as far as the independence aspects were 12 concerned and I instructed FIank Sestak to issue those as
(.
13 potential findings to make sure that everybody knew what 14 the potential concern have been.
15 So those five were issued in that manner.
The 16 Findings Review Committee did then consider those and 17 agree with the site team that they were truly invalid.
18 I believe I am correct and, if I am not, one of you guys 19 correct me, but I believe that all five of those that were 20 determined to be invalid were determined on that basis.
21 So that all 24 of the potential findings 22 submitted by the field team to the Findings Review 23 Committee were considered to be valid and were evaluated 24 as to their potential impact on the adequacy of the plant.
25 MR. SCHIERLING:
Could you go through just one TAYL0E ASSOCIATES 1625 I Street, N.W. - Suite 1004 Washington, D.C. 20006 (202) 293-3950
28 1
of the five then and express what the concern was and get 4
2 down to the nitty-gritty of what the invalidity is.
3 (Brief pause - discussions off the record.)
4 MR. SCHIERLING:
Shall we take a quick 5
five-minute break and everybody can get a cup of coffee.
6 (Whereupon, a short recess was taken.)
7 MR. SCHIERLING:- Are we ready to start again?
8 Let's get back on the record a few general 9
statements before we return to the subject itself.
19 I really would appreciate it if you could move 11 along on a very rapid pace because I personally have a 12 flight at 10 after 1 and I had better make that flight 13 because otherwise you are going to have another Project 14 Manager.
15 (Laughter.)
16 MR. SCHIERLING:
You all are welcome for my 17 funeral, too.
18 (Laughter.)
19 MR. SCHIERLING:
I also would like to recognize 20 Mr. Hubbard being here and we will ask you, Dick, at the 21 end of the meeting or maybe during the meeting to provide 22 us with any comments or statements that you feel are 23 appropriate to the subject today.
24 Back to the detailed discussion.
With respect 25 to the forthcoming revision for both ITRs, can we expect TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1804 Washington, D.C. 20006 (202) 293-3950
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to have at least the amount of detail that you provided us 2 with, for example, on 9026 in that revision, and hopefully 3 maybe even more as you deem necessary, but this is about 4
the minimum information that we would like to see in the 5
revision.
6 MR. COOPER:
It is equivalent I believe.
7 MR. SCHIERLING:
That would be fine.
8 We want to make sure that we address the second 9
question in our letter to you and let me quite specific 18 there.
I am looking at, for example. ITR 38 where, and we 11 can take either one of those two, you frequently make 12 statements that something was faund wrong with respect to 13 a specific PG&E specification. Is it specification or what 14 is the proper word?
15 MR. COOPER:
That is as good as any.
16 MR. SCHIERLING:
We want to know what we are 17 talking about for the record.
18 MR. COOPER:
We will interpret it generically.
19 MR. SCHIERLING:
Many of the EOIs have that l
20 statement in there and yet there is the overall general 21 conclusion that well, wa look at all this, but the program 22 is acceptable.
23 As we discussed over the phone and as you know, 24 Bill, this is our concern, how can we come up with that l
25 general conclusion based on granted maybe only less than TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1994 Washington, D.C. 20006 (202) 293-3950 m
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30 EOIs issued on an enormous amount of information that 2
you looked at, and I hope you will address that later on.
3 MR. COOPER: I would suggest that the best thing 4
to do is to get the questions out of the way on this first 5
item and then turn to the second, because it is really on 6
the basis of having done everything we did with respect to 4
7 these, well, the field investigations resulting in 8 potential findings and resolutions of those, that we felt 9 we were in a position to make a judgment as to the overall 10 significance.
11 Just to get ahead though for just a moment, 12 when I reread and others reread that last paragraph that 13 you are referring to in our ITRs where it said it met the
(
14 specification, in a few regards it clearly did not to the 15 letter of the law meet the specification in the sense of 16 meeting a regulation perhaps, but it clearly ended up with 17 an equivalent end product for the service requirement.
18 It is that kind of rewording that we had 19 attempted to put in these revisions and which I am 20 concerned now hasn't gone far enough which we can benefit 21 from on the discussion.
l 22 To the letter of a detailed lawyer reading of 23 the specification and what was done, it may not have j
24 precisely met that detailed work, but it was clearly an i
l 25 eq1 valent kind of thing in those few instances where it l
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didn't meet the detailed work. I think to get into that 2 area at all we do have to resolve any concerns you have 3 about the way in which we resolved those specific EOIs.
4 The question that was on the floor just before 5
the break was give us an example of one of the five we 6
ruled invalid, which we are now prepared to do and then we 7 suggest we look at some of the observations.
8 MR. SCHIERLING:
Very good.
c MR. COOPER:
Craig.
10 MR. LUNDIN: Just after we reconvened,' I sat and 11 just flipped to see the first ones that we had.
As an 12 example, a potential finding' report was issued and 13 subsequently cancelled.
However, due to the procedural 14 problem we had that Dr. Cooper mentioned, we issued it, 15 but in this particular case there was a specification 16 requirement that PG&E review and approve the weld 17 procedures used by Wismer-Becker.
18 We found weld procedures that had not been 19 reviewed and approved.
There was no evidence of that 20 approval and subsequent checking found out that those were 21 -not weld procedures that had been used on that work.
So 22 they were part of Wismer-Becker's weld procedure book, but 23 were not used for Diablo Canyon, Unit 1 and there is no 24 reference to them in the records.
That was subsequently 25 cancelled.
l TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1004 Washington, D.C. 20036 t202) 293-3950
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We have two that were written specifically 2
MR. SCHIERLING:
In other words, that finding 3 was not applicable.
4 MR. LUNDIN:
That is right.
5 MR. COOPER:
It is invalid, is the program 6 working.
7 MR. LUNDIN:
We have two that were exactly that 8
way.
We had one which was a potential finding on the 9
radiographic report did not denote the status of its le review.
In this particular case in fact it was not that 11 the radiograph did not exist and it was not that it was 12 not well documented.
The reIiew had been performed.
13 It was a case of, and I don't remember the 14 exact way the form was designed, but it was that he did 15 not check the accept block and subsequently the team 16 assured that in fact the radiograph was in fact 17 acceptable.
It was obvious that it had been reviewed, but 18 the block for accept had not been checked.
19 When it was verified that in fact the 20 ' radiograph was acceptable, and there was other 21 documentation to show that that individual had accepted 22 that radiograph, the potential finding report was 23 developed.
24 Once again, it was issued as an open item 25 report because it had been sent to the Findings Review TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1004 Washington, D.C. 20006 (202) 293-3950
33 1
Committee.
2 Let me find another quick one here.That in 3
general is the type.
4 We had a potential finding on a piece of paper 5
that was not in the file on the certification of some 6
penetrant material.
Subsequently the document was 7
available and that would not have,been a finding if that 8 had been available at that time.
9 That characterizes I think the type of invalid 10 findings that we had.
11 MR. BISHOP:
Could we return then to the one 12 example you talked abciut earlier on how the IDVP used that 13 example.
It followed up on the particular issue of the 14 pipe lug removal.
15 We are interested, and this is central to our 16 concerns in both our c;u e s t i o n 1 and 2 in the letter to 17 you, we are interested in knowing the process you used in 18 determining whether this was symptomatic of larger 19 problems.
20 You determined I guess that records were not 21 available and that non-destructive examinations were made 22 of areas where the lugs were removed.
23 Our question would be did you conclude that the 24 conctractor in fact did not have a program to check that 25 type of effort? And 11 he didn't have a program, should he TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1004 Washington, D.C. 20006 (202) 293-3950
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34 1
have had a program? Does that mean that there may be other 2 ASME pipe out there that wasn't within your limited 3
sample that has had lugs removed off of it that hasn't 4
been examined?
Those were the types of questions we were 5
interested in.
6 Tied to that we notice in your program plan, 7 which was submitted to the NRC, that you indicate that the 8 Findings Review Committee will define criteria for 9
determining the degree of impact of the potential findings 10 on plant adequacy.
11 Could you indicate how that criteria was 12 applied in this case to tell'us something about the 13 overall adequacy of the programs?
14 MR. LUNDIN:
I would like to go back to the 15 first part of your question.
16 As far as determining the symptomatic, No. 9026 17 is a good example.
We did not have a limited scope of our
(
18 check.
We looked at all the required inspections that l
l 19 should have been done on that pipe and verified that they j
20 had been done.
21 Wismer-Becker did have a process or a program,
~
22 if you will, to assure that those things were done.
If in 23 fact this LP had never been performed, then they may have 24 not followed their program or someone had made an error in 25 implementing the program.
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We did assure that not only did they have a 2 program utilizing their operation process sheet, and they 3
had a manual which would be of course in accordance with 4 ASME 3, but that the process sheet did not pick up this 5
required inspection.
That is where it would normally be 6
and that is where it was for other inspections.
7 So as far as the ASME piping is concerned that 8 Wismer-Becker installed, we did ensure that all tha 9
inspections had been done and this was in fact an 10 exception that we could not find the documentation that 11 their program had in the process.
12 The program existed to make sure that all the 13 requirements of the specifications got through the 14 process, documented and processed through the loop.
15 The Findings Review Committee, as you 16 mentioned, developed the criteria.
We made the check list 17 for ourselves, a question and answer type of check list to 18 process the type of findings.
In doing so we wanted to 19 evaluate whether we had a problem that was symptomatic, 20 whether we felt we should be asking the site team to look 21 at something else to show us something.
~
22 We looked at whethe,r we were talking about 23 someone making an error or an actual program problem that 24 we could expect to see repetitive, like something never 25 being done because the program had a fault in it.
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Those are the types of questions we used.
We 2
also considered whether the feature or the specification 3
requirement was an implementation of an essential design 4
feature of the plant or was for the overall requirement 5
added to the specification to complete the overall 6
installation, such as we had open items on some of the 7
surface finish requirements in concrete which is in the 8
specif.ication.
9 It was a specification requirement and the is minor deviations we did see our inspector wrote up in that 11 he took the letter of the law for what the requirements of 12 the spec were for the surface finish of the concrete.
But 13 in fact, in an overall review it was strictly within the 14 confines of a cosmetic surface finish of the concrete.
15 So we did make those determinations, the 16 Findings Review Committee, and considered all those 17 aspects in our review utilizing a check list for 18 ourselves.
19 MR. BISHOP:
Could you clarify for me on the 20 example we were talking about, the piping issue and the 21 lug removal, did you in fact determine that that 22 contractor did have a program or had a program that should 23 have checked areas where lugs were remo'ved?
24 MR. LUNDIN:
His program should have picked it 25 up.
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MR. BISHOP:
So you would say in this case the 2
fact that you found an error was what might be called an 3
isolated case as opposed to a deficiency in the program?
4 MR. LUNDIN:
It was an isolated case. In fact, 5
all other features that that program was supposed to pick 6
up it picked up and we verified that.
7 MR. CHANDLER:.So if you looked at the next lug 8
down, you had documentation of LP testing?
9 MR. LUNDIN:
No, we are not talking a lug. We le are talking a feature.
That is some of the lug removal 11 areas we couldn't find.
12 MR. BISHOP:
That'is what I am getting back to.
13 MR. LUNDIN: These pieces of pipe, and I believe 14 they are cast pipe, are delivered with lifting lugs.
15 MR. RICHARDSON: Erection.
l l
16 MR. LUNDIN:
Erection lugs which may or may not
[
17 be removed.
They do not have to be removed. However, in l
18 the normal construction process with restraints, supports, 19 hangers, if you will i and insulation, it becomes more 20 expedient to the construction forces to remove them.
Now 21 that is allowed.
22 If the lug is completely removed, the code 23 requires it to be LP inspected.
If it is left on in some 24 part, that is not required because the original weld was 25 controlled at the manufacturer as required, which we did TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1004 Washington, D.C. 20006 (202) 293-3950 l
38 1
verify.
2 MR. BISHOP: I still have the question, as Larry 3 would say.
You concluded then that the contractor did not 4
have a program to check the surface of where lugs were 5
removed?
6 MR. LUNDIN:
If I may clarify. I think we are 7
hung up on what the term " program" is. There was a program 8
to assure that the specification requirements were 9
implemented on process sheets and subsequently through the 10 whole chain.
11 MR. BISHOP:
That is very general. I am getting 12 down to the narrow specificsI 13 MR. LUNDIN:
Okay. We could not find evidence l
14 that the program did implement this specification l
15 requirement. It wasn't on that process sheet and therefore 16 we can't find evidence that it was performed.
17 MR. BISHOP:
Okay. Then what does that tell us 18 about other piping that may have had lugs attached to it?
19 MR. FRIEND:
I think, Tom, I would like to 20 clarify at this point.
It is my understanding that the l
l l
21 only piping on the project that had lugs was the primary 22 coolant loop.
That is a matter of interest.
l l
23 MR. BISHOP:
Okay. Then could it be stated that l
24 in fact the entire population subject to that problem has t
l 25 been addressed?
l TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1904 Washington, D.C. 20006 (202) 293-3950 l
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39 1
MR. LUNDIN:
Yes. I thought I had said that.
2 MR. BISHOP:
I didn't gather that.
3 MR. CHANDLER:
It is not an isolated incidence 4
in the sense of one specific lug removal which had not 5
been LP tested.
It is just that LP testing had not been
=
6 done across the board in lug removal areas.
7 MR. LUNDIN:
We could not find evidence that 8
that had been done.
9 MR. BISHOP:
That is the type of information we 10 were looking for to get an understanding of whether you 11 looked at the root causes.
12 MR. COOPER:
I would think it is important to 13 note, although there was no documented evidence that this 14 examination had been performed, that when the examination 15 was subsequently performed that everything successfully 16 met the requirements.
17 Now obviously that can be one of two things. It 18 can be dumb luck or it can be the fact that it had been 19 done correctly in the first place and that the documents 20 are missing.
21 MR. FRIEND: I think it is also of interest that
~
22 the senior members of the construction group on the site 23 believed to the best of their recollection that the tests 24 were performed.
We cannot find the documentation, but it 25 is their memory that these tests were correctly performed.
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Is that correct?
2 MR. NORTON:
Yes.
3 MR. LUNDIN:
By the way, we did find in one of 4
the other findings that there was occasion where a test 5
was left off a process sheet but in fact did get 6
performed and we had the record. I think that is in one of 7
the findings as well.
That is why it was written up that 8 we just didn't have the record that it was performed.
9 MR. BISHOP:
I cut you off when you were about 10 to describe the criteria the Findings Review Committee was 11 using.
12 MR. LUNDIN:
WellI I think I mentioned most of 13 them earlier, but the things we wanted to evaluate was, 14 first, is the problem sufficiently defined to evaluate it, 15 and that would be an internal process where do we have 16 enough information to make some sort of evaluation to pass 17 on to the Program Manager.
That would be where we would 18 ask the site team to do something else or get something 19 else for us or submit more information.-
20 We look at the impact on the adequacy of the l
l 21 plant in that can we determine whether it is a hardware or l
22 a plant adequacy problem or do we have an error in the 23 implementation of a program.
Someone doesn't sign a 24 document, for instance, or there is a piece of paper 25 missing from a file that we have every evidence was there TAYLOE ASSOCIATES l
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before.
It is not necessarily hardware related. Does it 2
appear to be an isolated case? That is the first thing. Do 3 we need more information to judge that?
4 Do we have a potential judgment error or an 5
individual failure to follow procedures?
For instance, an 6
individual judgment error would be a case where the 7
original inspector accepted something and our inspector 8
felt it was rejectable.
It is very possible that that 9
person made a judgmental error.
10 Does it appear to be the symptom of a problem?
11 Is there evidence of a system breakdown?
Did this come 12 because the system broke down and this fell out the 13 bottom?
Were the procedures inadequate? Does it 1A demonstrate a lack of personnel awareness? Does it deviate 15 from a code or a standard? Those are the type of questions 16 we asked and discussed.
What may reasonably be considered 17 the effect on the plant if left undetected was one of the 18 things we discussed about each one.
Is there a potential l
19 for and product deviations or deficiencies?
Is there a l
l 20 potential to affect operability or maintainability?
Was 21 there a subsequent check test or inspection to confirm the 22 adequacy of the item?
23-When we consider that some things are subjected 24 to multiple tests, one of the considerations we looked at i
25 was well, was it checked later on for some other reason l
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42 1
and therefore we don't need to look at the adequacy of 2
that.
3 Then are the possible adverse effects of the 4
potential finding likely to affect the operability or 5
safety of the plant?
6 So these are the words we used to jog our 7
thought process as we discussed each and every item.
We 8 used this as a check list to assure we had discussed each 9
question and that is the type of criteria we used.
10 MR. BISHOP:
Okay. Thank you.
11 MR. CHANDLER:
While we are still on the 12 criteria for a moment, you mentioned earlier that you did 13 not specifically use Appendix B as a check list.
A lot of i
14 the words you say smack of Appendix B and you indicated 15 that there is a relationship between what you did look at 16 and Appendix B.
17 Was a conscious decision made not to use 18 Appendix B or why was Appendix B not used as applicable at i
19 any given point in time?
20 MR. LUNDIN:
I think you are probably get a l
21 'different opinion from each of us on that in that I think 22 each person had their own ideas.
l 23 Appendix B was considered and really utilized 24 in that our people in writing the check list used the 25 attributes that we would use to assure Appendix B.
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Because it was after the fact, significantly 2
after the fact in that the amount of people and the 3
processes were not in place and operating for us to look 4
at, we felt we had to assure that the elements of any 5
quality assurance program, which happened to be delineated 6
in Appendix B, were in effect to assure that the plant was
+
7 built right and in fact it was implemented.
8 We felt if took an approach like that we would 9
assure that in our evaluation we would be able to make a 10 determination as to whether there were controls in place 11 and they were effective.
That was our main goal.
12 By assuring the element s of a QA program were 13 there that would preclude any question of whether 10 CFR 14 50 applied.
I know I have seen some documentation which I 15 believe because of the early license of this plant that 16 there was some consideration as to whether 10 CFR 50 17 applied to Unit li and I know that PG&E committed to apply 18 their program as much as possible to that.
l l
19 So it was considered that a quality assurance 20 Program, and this i s i n my participation, the elements of 21 that program as they applied to these two vendors, would 22 be considered.
23 Obviously i f we had applied Appendix B from the 24 start, some criteria just would be not applicable to these 25 things.
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MR. CHANDLER:
You are talking about Appendix B 2 as it existed in various points in time.
There is no real 3
change.
I understand.
4 MR. LUNDIN:
I do not believe that that was 5
considered.
6 MR. CHANDLER:
Are there different opinions of 7
it?
8 MR. LUNDIN:
I don't know. Are there?
9 MR. SESTAK:
No, I don't have any vast 10 difference of opinion from Craig.
We tried to and we 11 recognized that the so-called PG&E agreed to utilize these 12 accepted components of 10 CFM 50 on Unit 2 which goes back 13 into this as much as possible on Unit 1 that is in the i
14 FSAR.
15 MR. BISHOP:
Along that same line of thought 16 looking at the program again that you submitted to the 17 NRC, one of the overall objectives is stated that you will j
18 deterine whether the construction of Diablo Canyon was 19 performed in accordance with the quality requirements 20 appropriate at the time and meets applicable regulatory 21 standards.
22 In another area, paragraph 3.2.1, it indicates l
23 that you will evaluate the quality programs to determine l
24 if controls were consistent with applicable NRC 25 requirements.
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I presume you did this in the development of 2
your check list, is that correct?
3 MR. LUNDIN:
Correct, the implementation being 4
the implementation of the specifications and the program 5
requirements and all the documents that'we used in 6
developing our check list.
7 MR. BISHOP:
In the check list subtask it D
9 indicates that you will evaluate each contractor's quality 9
program and procedures.
Could you discuss the extent to is which you looked at procedures?
11 MR. LUNDIN:
Well, I didn't do the evaluation.
12 Maybe somebody on the site team, maybe Fred or Stan could 13 address how far we actually looked at the actual 14 procedures.
15 MR. BEARHAM:
I am Fred Bearham. I was on the 16 site team.
We looked in great depth at the procedures and 17 we deterined the adequacy as we went along.
Most all of 18 the people on the team were experienced people.
So they 19 were used to looking for the adequacy of programs.
20 MR. SPRAUL:
Vas there a manual back at that 21 time that met code requirements that they developed the 22 procedures from?
23 MR. BEARHAM: Yes, there were manuals there both 24 for Vismer and Atkinson and there were programs developed 25 from manuals like weld procedures and such like.
There TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1904 Washington, D.C. 20006 (202) 293-3950
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wera progr3ms'for the qualification of personnel, et s
2 ;detera.
3 MR. COOPER:
The Wismer-Becker report, for 5 (
4 example, states that a total of 3,528 documents was 5
reviewed.,
s i
s.
6
.MR.
DICK:
I think, and Craig, you may wish to 7
comment on.this, but I think it was clear that there was s.
8 an approvad. quality progran that Wismer-Becker was m
9 following.
10 M R_. LUNDIN: -That is correct.
- t__,
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MR. BISHOP:.What we Axpected the IDVP to do, 12 and I refer to your plan, was to'tell us whether that 13 quality program was effective in meeting. regulatory s,
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14 requirements at the time.
15 MR. COOPER: I think that the key to our process 16 in conducting this work was to assemble a team of i
17 experiencea people both in the field team and in the Fydings[ReviewCommittee that gere familiar with la
(
19,: c.onstr'uction and the application of construction QA at 20 that t'ime and go(c'ut and see if the job was done right.
21 Clearly that experience reflects the growth of 3
_ s 22 t h e rio r e formal QA procedures-dur,ing that time period, but i
23 we did not wa'nt to get into a situation where we are s
s i
s 24 arguing, {or' example the pros and' cons of the FSAR l
25 statement that says for Unit 1 the PG&E program would be 1
- i TAYLOE ASSOCIATES d625 I Street, N.W. - Suite 1904 Washirigton, D.C. < 20006 (202) 293-3950 i
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1,used to the extent possible.
2 We didn't want to get into this what is the 3
extent,possible.
We wanted to get into the question of 4 whether there was a valid QA program which was implemented 5
and led to a construction which was acceptable.
6 I think that our emphasis has been on do we 7
have the right end product more than on is every "i" 8
dotted and "t"
crossed that might appear in some 9
interpretation of the various documents.
10 It is true that we don't have a formal s
t 11 comparison in our reports with each of the applicable 18 12 elements because we thought It was more important to find 13 out if things were done in a manner which was good 14 practice,at that time in these areas.
15 The emphasis was not on a paper comparison of 16 programs with othier documents.
We knew that they were 17 working through approved procedures and so forth and we 18 wanted to see how did it work and how well was it d o ri e.
19 MR. NORTON:
I don't mean to take the NRC to 20 task, but I am a little bit puzzled by Mr. Bishop's 21 questions, particularly his last one.
The letter of 22 October 5th, '82 from Teledyne addresed to Maneatis.
23 Denton and Engleker, page 4,
3.2.2 subtask, spells out 24 basically what Mr. Cooper just said is what they were l
25 9oing to do, and that letter is dated October 5th of '92 l
i, TAYLOE ASSCCIATES l
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as to what they were going to do in that respect.
2 A r.
I read page 6-1 of ITR 38 Revision 1, they 3
tell you what they did. If you look at the wording of what 4
they said they were going to do in October and what he 5
just said, all three seem very consistent.
6 So I am a little puzzled when you say you 7
expected something else.
8 MR. BISHOP:
Well, I expected to know how they 9
got there which I didn't see in the ITR.
10 MR. NORTON:
Okay. That is a different question 11 than what you just verbalized.
All right.
12 MR. BISHOP:
I would like to proceed with 13 exploring that particular aspect, and it ties in with our 14 second question in our letter to you.
15 Considering that you explained rather well to 16 me and I have a much better understanding and a better l
17 feeling of how you anal; zed the individual ITRs, and if 18 your depth of investigation was as thorough for the other 19 ones as it was for this finding in checking the broader 20 implications of that, I think our concerns would evaporate 21 in that area.
22 We have a similar concern in how you took into 23 account all these many relatively small items and drew l
24 your conclusions about the overall program adequacy.
25 Specifically let's take an example on material l
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control, for example.
I believe you had a number of 2
individual items talking about mill certs and things such 3
as that.
How did the Findings Review Committee handle 4
these many small items, recognizing that each one 5
individually didn't create a problem, but was it 6
symptomatic of perhaps a broader problem within that 7
contract?
8 MR. COOPER:
I would suggest that we go through 9
a couple of the observations in more specific detail.
10 MR. LUNDIN:
Well, I am not so sure one would 11 help, but we shall.
For example, we did have some that 12 were on material control.
With one exception, they were 13 determined to be programmatic as far as information that 14 wasn't available to us at the time.
When those threads 15 were followed, we found out that in fact somewhere the 16 information existed and the material was proper even 17 though the piece of paper was missing.
18 We checked the material from the reactor 19 coolant system from the hardware back to the paper. In oqe 20 case we found that at the receipt inspection the l
21 identification of two items on the same shipment were
~
22 reversed in the records tracing. So that one number traced l
23 back to the other piece of tubing. 'There were two 24 different thicknesses. The material was properly 25 installed. The right material went in the right place. The t
i TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1004 Washington, D.C. 20006 (202) 293-3950 aw w
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right size material went where it belonged.
2 Since this was the only case of all the 3 material that Wismer-Becker installed that did not trace 4
back to the appropriate number, we had no reason to 5
believe that this was a common occurrence except isolated, 6 and we did not tie that item because it was under material 7
control under everything that had something to do with 8 material because they were separate and distinct and the 9
others all happened to go away in that we found that in le documentation from Westinghouse and so forth where we went 11 beyond the scope of our review to assure that the material 12 was correct.
13 In the case of going to Southwest Fab and to k
14 Westinghouse for documents we assured in fact the material 15 was the correct material, although the Wismer-Becker 16 documentation was unclear to assure that.
17 So any particular one that you want to discuss, 18 we can pull out, but I wanted to talk about material 19 because they may all fit under the same criteria, but they 20 don't necessarily relate to each other and, as I said, 21 most of them went away as with the types of observations 22 were done.
23 MR. BISHOP: That is useful information. Perhaps 24 if you could just inform us in general terms how you drew 25 your overall conclusions considering the findings, the TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1004 Washington, D.C. 20006 (202) 293-3950
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individual findings you had.
2 MR. COOPER:
First, we had only one finding. I 3 have got to keep saying that because 4
MR. BISHOP:
Oh, let me correct my phraseology 5
there.
I didn't mean to indicate that you had more than 6 one finding.
I meant considering the results of your 7
investigation.
8 MR. COOPER:
The reason I want to go on on that 9
and starting cut in the manner in which I did was not to 10 chastise you for your counting ability, but rather to 11 point out that the 23 so-called observations, that they 12 were termed an observation because the potential finding 13 was considered to be valid.
14 There wasn't a piece of paper in the file that 15 it really should have been in perhaps, but then the 16 additional work that was done confirmed that although that 17 p-iece of paper rii g h t be missing, things are as they were 18 intended to be.
19 So when you ask the question about how did we 20 reach a broader conclusion about the work, you have got to 21 recognize that the number 29 was really much smaller in 22 entering into that question of judgment on that point, and 23 I don't know the exact number right offhand, but clearly 24 the 29 went down to 24 and clearly the right number is 25 some place between 1 and 24 of these were things that TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1004 Washington, D.C. 20006 (202) 293-3950 g
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really were of the nature that you might be concerned that 2
they could 1 tad to this kind of a generic situation.
3 It is a judgment call at that point to me on a 4
recommendation from the Findings Review Comm'ittee and we 5
are going to have to turn to them for the basis on which 6
they felt this was the proper judgment in some detail.
7 Having said all this though, I do want to make 8
it very clear that we are talking about conclusions based 9
upon the program we conducted.
We believe we properly is conducted the program that we were asked to conduct.
11 The questioni for example, were two 12 subcontractors the right number, that is outside of our 13 scope.
We did the program we were asked to conduct and we 14 believe that our conclusions based on the work we did are 15 proper, but we can't argue outside of that scope and we 16 don't intend to in any of this presentation.
17 If we can keep it within then what we could 18 possibly learn from the scope of the werk we undertook to 19 d o_,
then I think it would be appropriate to turn to the 20 Findings Review Committee and say, hey, you know, of this l
21 number that is like someplace between 1 and 24, how many 22 did you really think were potential indicators of generic 23 concerns and how did you feel about it?
24 I think this is the only way to answer your l
i 25 question, Tom.
l TAYLOE ASSOCIATEE l
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MR. BISHOP:
That is right, and what did they 2
consider in exercising their technical judgment to draw 3
this overall conclusion?
4 MR. LUNDIN:
We did determine and the 5
information that was presented to us gave evidence to the 6
fact that, No.
1, there were in the case of these two 7
contractors quality assurance programs in effect, No.
2, 8
they were being implemented because the evidence showed in 9
the great majority of everything we looked at that in fact la these programs were complied with and, thirdly, the result 11 of the application of these programs resulted in our 12 review of not finding anything in the plant that was not 13 in accordance with the intent of the specifications.
14 Those, I think, are the three key points which 15 could probably be expanded upon, but the program was in t
16 place and it was implemented, that is evidenced, and we 17 feel in the magnification that we used in looking at the 18 plant itself that in fact it essentially worked.
19 MR. CHANDLER:
Let me ask something if you will 20 indulge the simple mind of a lawyer on this for a moment.
21 (Laughter.)
22 MR. CHANDLER: Bill offered earlier to pick your 23 1avorite EOI and we could talk about it.
If you look at 24 EOI 9001, the fact that you found something, and then it 25 continues "This file was reviewed and analyzed with the TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1904 Washington, D.C. 20006 (202) 293-3950
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additional information provided by PG&E.
The Findings 2
Review Committee recommended and the IDVP concluded and it 3
was finally resolved as an Error Class C observation in 4
accordance with the program plan."
5 The fact that you found something, what does 6
that say?
Let me ask you, what does that say about the 7
program that was in place with respect to this item?
The O
8 fact that you found perhaps a piece of paper elsewhere 9
that supported the adequacy of the end product or that you 10 found documentation elsewhere that perhaps justified that 11 appropriate tests were done, does that say anything about 12 the lack of documentation or' evidence regarding the 13 particular thing you were focusing on?
14 MR. LUNDIN:
The program which was implemented 15 was not, as can be seen from the findings, at all times 16 fully implemented.
There were cases where we found that 17 the program was not fully complied with.
18 We don't consider, since we looked at all the 19 features of the program that were supposed to be applied, i
i 20 that with the level of magnification that we applied to f
l 21 the program that findings of that nature would not be in
?
l 22 existence under any scrutiny.
For instance, i r.
the normal l
l 23 NRC visit to a power plant, there are things found where 24 the program was not fully complied with, but one has to 25 make the evaluation as to whether it is a generic problem TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1304 Washington, D.C. 20006 (202) 293-3950 m.
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-1 or whether that means the program is ineffective or 2 whether there is a lapse in the application, 3
Our view with the magnification, the full 4 magnification of the implementation of the program is that 5
what we found was not significant to show the program was 6
not in effect at all.
It was normally in effect.
7 In a very small percentage of cases we did find 8
there were lapses in the implementation of the program, 9
but not as would be expected in the auditing program.
10 Particularly at the time this plant was built, you have 11 got a level of scrutiny that was not as great as we apply l
12 right now.
l 13 MR. COOPER:
Is it clear that that decision or 14 that conclusion as based not on the Findings Review L
i 15 Committee looking at paper, but the Findings Review 16 Committee members actually going out to the site and I
I 17 looking at it to see what was there?
18 I think that is a very important thing here 19 that we really hadn't expected to do when we planned the l
20' program.
That wasn't a necessary step in the program, but 21 it is something they felt they had to do in order to
~
22 exercise this judgment.
23 MR. SESTAK: I just want to mention that many of l
24 the findingins, EOIs, just to highlight some of the i
25 magnification that Craig mentioned, were in areas of the TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1904 Washington, D.C. 20006 (202) 293-3950
56 1
bottom mounted instrumentation support system which if 2
anyone has ever been down there, it is a latticed type of 3
support where many tubing arrangements are being 4
supported where the system has to be constructed almost in 5
place because of accessibility.
6 What we are talking about is strapping 7
material, carbon steel one inch wide by three-eighths of 8
an inch thick, strapped across in a lattice.
Some of the 9 welding that was performed on there, that is why you have 10 to see this thing to obtain the value of some of these 11 EOIs.
12 Also, the Wismer-Secker specification of the 13 program, the procedures related to reactor coolant piping, k
14 and sometimes the scope of the specifications or the 15 contractord standard to support systems, and they were 16 trying to implement pressure retaining requirements onto 17 structural requirements and that is what we had to 18 differentiate when we saw these things.
19 MR. CHANDLER:
Is that of any significance?
20 MR. SESTAK:
No, because this is a normal 21 occurrence.
You have a specification or a contract and it 22 expands for one reason or another and sometimes you don't 23 follow up on it immediately.
24 I would like to point out that;all of these 23 findings that we have -- well, not findings, because there l
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1 was only one finding 2
(Laughter.)
3 MR. SESTAK:
These observations that we have 4
uncovered I think could have been resolved in the same 5
manner then as they have been now.
I think that is quite 6
important.
7 MR. CHANDLER:
Before Tom goes on, let me stick 8 with.that EOI I asked about a moment ago, 9001.
When I j
9 read that, and perhaps even 9002 and so on, and then I is read Conclusions, Section 7, page 7-1, "Further, to the 11 extent reviewed the as constructed physical installation 12 conforms to the requirements'of design drawings and 13 specifications and the required inspections are performed i
14 and appropriately documented," do I perhaps detect in say 15 9001 that we had not a welding problem but a design i
16 problem?
17 MR. LUNDIN: No, that was not. The BMI tubing in 18 this lattice work of support structure, the design 19 requirements were put onto drawings.
What our potential 20 findings were was that in fact all the drawing 21 requirements have not been met to the letter.
22 What we did in our investigation was to find 23 that the design requirements had been met and that in the 24 scope of this work, which was a significant amount of 25 welding and bolting, there were deviations from the s
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drawing that were reasonablei but we identified them as 2
not being in accordance specifically with the drawing.
3 For instance, there was some angle iron which 4 was required to be bolted and in fact it was welded.
We 5
did go through the process of assuring that it was 6
adequate.
To an experienced person it was intuitively 7
acceptable, but the drawing didn't show and welded spices 8
but only bolting.
We identified it.
9 To the level of magnification that we saw the 10 welds which was requiured to be a certain length and it 11 was only 80 percent of that length, even though we knew it 12 essentially was a tack weld,'there was a drawing 13 requirement and it was in fact not met.
14 Our investigation found that only a fraction of 15 that welding was even required to hold it together.
15 Although we may have intuitively thought so looking at the 17 structure, we did verify it in fact.
i 18 We went through the process of, for instance, 19 on that particular EOI on the BMI tubing, we did receive 20 the design criteria and some of the design considerations 21 that were used by PG&E. They referenced their calculations 22 which were available to us and we had all this information 23 and had our engineering division review to concur in the 24 concept in those considerations that we used before we 25 made our determination that those in fact were reasonable TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1904 Washington, D.C. 20006 (202) 293-3950 e-m-,
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assumptions in the design itself.
2 MR. CHANDLER: It wasn't clear to me when I read 3
this, for example, in 9001 where it talks about short weld 4
length, and then the conclusion that I read earlier that 5
the justification for resolution of this item wasn't that 6
the welding was proper but it was the design that was off.
7 MR. LUNDIN:
The design was satisfied.
8 MR. DICK:
I wonder if I couldn't help this 9
discussion a little bit because I think I sense what is is troubling some of your gentlemen.
We had a little 11 discussion on closing that gap between not strictly l
12 meeting the drawing and accepting the product at the time 13 the work was accepted.
ti 14 In the documentation from getting from one l
15 point to the other, for example, I think we did provide 16 you some additional documentation along the line that 17 helps with that.
is MR. LUNDIN:
Well, there are two important 19 points really come out of that.
20 First of all, as far as the volume of 21 information we looked at, we got down to looking at 22 people's Pocket notes when it comes right down to it.
We 23 looked at everything that was available.
We had some guy l
l 24 track down who had retired a couple of years ago I think l
25 and get some stuff off of him to just try to put in TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1904 Washington, D.C. 20006 (202) 293-3950
60 1
perspective what actually happened back then if there 2 wasn't a record.
That in fact was done.
3 Secondly, the consideration by the team and the 4 Review Committee goes back to the purpose of the makeup of 5
those organizations in that some experience with what was 6
being done at that period of time ahd to be exercised when 7 we made those determinations.
8 For instance, in 1973 and '74 the sensitivity 9
to as-built drawings of situations like the BMI tubing 10 supports was not as great as it is today.
So the 11 possibility that these drawing deviations, although they 12 were not design deviations, may very well, since the 13 decisions made by the people doing the work apparently 5
14 were good decisions, might very well have been judgments 15 made by the field engineering people at that time and not 16 all of these were translated.
That is a possibility and 17 that is something we had to consider.
18 That process which was the state of the art and 19 was acceptable is what had to be considered in making some 20 of those evalautions.
21 MR. BISHOP:
EOI 9013 talks about that specific 22 issue about discrepancies between the installation and the 23 drawing requirements.
Is this the type of thing you are 24 saying where the sensitivity was different?
25 MR. LUNDIN:
Right, in that there were TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1904 Washington, D.C. 29906 (292) 293-3950
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differences between the installation and the specific 2
drawings requirements, but did not violate the design 3
requirements.
They were apparently, and I emphasize 4
apparently, judgments made by the engineering people in 5
constructing because of interferences, and they made minor 6
deviations that did not get documented on the drawing at a 7
later date as as-built, which some of those have been done 8
at this point in tima.
9 MR. BISHOD:
The question that occurred to us 10 when we saw this was was this an indication of lack of 11 procedure compliance on behalf of the crafts and the 12 quality control people?
13' MR. LUNDIN:
Yes.
i 14 MR. BISHOP:
You are saying that was the case?
15 MR. LUND:N:
To us it was apparent that all the 16 requirements of the procedures may not have been followed 17 in that case.
I cannot identify the specific violations, 18 but that is a possibility that there were procedural 19 failures, as I mentioned earlier, that the program did not 20 work one hundred percent of the time, but in fact it 21 worked acceptably as one would expect a program to 22 work.This was isolated to this one area.
23 MR. BISHOP:
How did you get from one point to 24 the other there?
If you saying it didn't work, yet it 25 worked acceptably, I would like to explore, like we did on TAYLOE ASSOCIATES 1625 I Street N.W. - Suite 1004 Washington, D.C. 20006 (202) 293-3950 n-w--
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the one finding, the process you went through to conclude 2
there were no generic implications on this one where you 3
have procedure compliance concerns.
How do you again 4
conclude that there is no broader issue here that deserves 5
investigation?
6 MR. LUNCIN: That is two questions. First, I got 7
from one point to the other in that, as I mentioned 8
earlier, any program that is implemented when audited can 9
be found to not be, if somebody failed to follow i t at 10 one point in time and that is identified, and they look to 11 see if it is a generic problem and resolve it.
12 Since we looked af all of their procedure 13 compliance as far as it related to whether the paper was 14 there and the job got done, but since we looked at all of i
15 it and felt that this was a failure in an area which would 16 not necessarily mean that the Wismer-Becker people didn't 17 follow procedures. It was, on the contrary, apparent that 18 they normally did.
19 MR. BISHOP:
Could you perhaps quantify some 20 things for me. I have looked at the tubing supports myself 21 and agree with you that it looked like a guy would nave to 22 hang by his heels or have a very difficult time assembling 23 that.
Could you give us a rough approximation in numbers 24 of the other types of supports, the numbers of other 25 supports you looked at and whether they obviously came out l
l TAYLOE ASSOCIATES 1625 I Streets N.W. - Suite 1004 Washington, D.C. 20006 (202) 293-3950 y
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satisfactory and there were no potential findings on them?
2 MR. LUNDIN:
How many supports in the cooling 3
system, would you say?
4 MR. BEARHAM:
There were about four or five 5
major supports on each coolant loop and we looked at those 6
thoroughly. I don't think we reported any discrepancies in 7
those.
8 In the BMI tubing very quickly I will say there 9
are probably 100 or so supports in there. We went over the i
10 whole thing with a fine toothed comb and got three guys 11 down there most of the time just going through the whole l
12 thing. We reported what we found and the numbers that came 13 up are in the report, and I would imagine that ---
14 MR. COOPER:
2,298.
l 15 (Laughter.)
l 16 MR. BEARHAM:
No, there weren't that many major 17 supports.
18 MR. COOPER:
Not that many major support units, l
19 I know.
l 20 MR. BEARHAM:
They were large. There were about 21 three or four major ones in each loop.
In the BMI tubing 22 there were sort of in the hundreds I would say and we 23 looked at each component and each weld on each support, 24 too.
25 MR. FRIEND:
So that is an important point.
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Although you looked at say four primary coolant loop 2
supports, you looked at all the welds on those supports.
3 MR. BEARHAM:
Yes.
4 MR. FRIEND:
So you looked at tens or hundreds 5
of feet of welds in that inspection.
6 MR. BEARHAM:
Yes, certainly and hundreds of 7
bolts.
I think what you see is significant inasmuch as we 8
looked at hundreds, and enough to sort of make you ask 9
questions I guess, but we certainly went through the whole 10 thing and by far the majority was good.
11 MR. BISHOP:
I think it would be useful to 12 indicate the comparative level of what you looked at to 13 what you found.
~
14 MR. COOPER:
Well, let me read it. "The BMI 15 tubing records consisted of two packages which contained 16 the documentation of all 350 welds.
These records were 17 examined for evidence of correct documentation, of correct 18 weld identification, assignment of qualified welder, 19 correct degree, correct electrical characteristics, visual 20 inspections and the repair data."
21 MR. BISHOP: I was speaking specifically that he 22 indicated there were hundreds of supports and here it 23 indicates three supports had tFese major weld problems.
24 That is quite a difference.
25 MR. BEARHAM: Well, I think it will show you how TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1004 Washington, D.C. 20006 (202) 293-3950 1
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many supports we looked at and, if not, a scrutiny of the i
2 drawings would show you very quickly.
3 MR. LUNDIN:
Might I clarify. We are talking 4
about numbers of supports in BMI.
It depends on whether 5
you could welds or count the little straps or just count 6
the angle irons going across which all these straps go to.
7 How many supports are there underneath, I would have to 8
ask the guy who designed it what he considered to be a 9
support.
There could be hundreds or there could be ten.
10 MR. BISHOP:
I am trying to compare the number 11 of supports 9, 10 and 11 to what is the total population 12 there we are talking about, 5.cause we say the majority of 13 welds on supports 9, 10 and 11 exhibited problems.
('
14 MR. ETILER:
By that counting there were 11 15 total.
There were 11 major locations of straps.
16 MR. BISHOP:
Okay, that is different than 17 hundreds.
18 MR. BISHOP:
I don't want to belabor the point 19 about numbers, but getting back to the issue on programs 20 and procedures, could you quantify for us the numbers of 21 procedures you may have looked at.
You indicated that you 22 looked at great depth of procedures.
Would it be 23 appropriate to say that for all the hardware you inspected 24 you looked at the corresponding procedure that related to 25 the fabrication of that hardware?
F TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1004 Washington, D.J. 20006 (202) 293-3950 m,?*em
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1 MR. BARANOW:
Yes.
2 MR. LUNDIN:
I believe that is true.
3 MR. BISHOP:
You are getting into the realm of 4
close to 100 percent review in that sense.
5 MR. LUNDIN:
Right around there.
6 MR. BEARHAM:
It was close to a hundred percent 7
review of what was actually in the scope.
~
8 MR. SPRAUL:
More installation than fabrication 9
though, was it not?
10 MR. BEARHAM:
Welle it depends on what you call 11 fabrication.
Of course, we didn't get into off-site 12 fabrication.
13 MR. SPRAUL:
Field fabrication.
14 MR. BEARHAM:
Some fabrication would have been 15 done in the field, yes. Most of it would have been done in 16 the field.
17 MR. LUNDIN:
If it was done by Wismer-Becker or 18 Guy F. Atkinson, whether i t was fabrication or insulation.
19 we icoked at it.
If it was fab by someone else, we only 20 assured that Wismer-Becker's program of receiving it and 21 utilizing it was followed.
~
22 MR. BISHOP:
We had the indication I think from 23 our inspection program that in the performance of your 24 review of the two contractors you did find it necessary to 25 some limited deg.ee to get into the work or the products TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1004 Washington, D.C. 20006 (202) 293-3950 e
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of subcontractors or vendors, and I think you just touched 2
on that subject. Could you tell us the extent of 3
involvement?
4 MR. LUNDIN:
An example would be Westinghouse 5
documentation and we did go to Southwest Fab to assure on 6
the lugs.
We needed some information as to whether an 7
initial potential finding was written concerning whether 8
the material actually met the specification requirement 9
and we had to go back to Westinghouse to find out that 10 that requirement had been revised during the process of 11 them buying it.
12 That was outside the scope because it was 13 supplied to Wismer-Becker by Westinghouse, but we did go 14 back to assure that that material was acceptable as 15 purchased by Westinghouse and the documentation is in the 16 file from Westinghouse that that process was appropriate, 17 We did in fact go back to Southwest Fab's 18 records to make sure that they had in fact properly 19 documented the welds where these lugs were removed, that 20 that was appropriately done.
21 We did have someone go back to get documents, 22 for instance, the Magnaflux supply, the copy of the 23 original document that was sent to Diablo Canyon in 1973 24 for that can of penetrant, the one piece of paper that 25 wasn't in the file.
Over the years an auditor kept it in TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1904 Washington, D.C. 20006 (292) 293-3950 aein w
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his book or something.
2 (Laughter.)
3 MR. LUNDIN:
It did exist and Magnaflux still 4
had it and we did go back to make sure it did exist.
5 MR. CHANDLER: What did you do? For example, you 6
mentioned a number of major subs to GFA in ITR 36, Pacific 7
State Steel, et cetera, et cetera.
How about those?
8 MR. IVES:
Dick Ives, Stone and Webster. If you 9
look at our check list, when we came up with an inspection 10 attribute or evaluation attribute, we then listed where we 11 obtained that attribute, whether it was from a 12 specification or Atkinson's QA program or someone that was 13 working for Atkinson, and that is identified on the check 2
14 list.
15 MR. BISHOP: One last question on the breadth of 16 your sample.
In your Wismer and Becker ITR you list four 17 systems, reactor coolant system piping, pressurizer surge 18 line piping, BMI tubing and reactor vessel leak detection 19 line. Of these four systems" what percentage of each of 20 those systems did you examine?
21 MR. BEARHAM:
A hundred pecent.
22 MR. LUNDIN:
A hundred percent of all of them, l
23 MR. BISHOP:
My question is for PG&E on a 24 slightly different subject, but there was a recent problem 25 that was reported to us and it was reported that that l
l TAYLOE ASSOCIATES 1625 I Streeti N.W. - Suite 1004 Washington, D.C. 20006 (202) 293-3950 w
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Particular problem on the reactor coolant system piping 2 was not one of the samples looked at by the IOVP.
3 MR. FRIEND:
Was that reactor coolant piping or 4
component cooling water?
5 MR. TWIDDY:
You are talking about the thin 6 wall?
7 MR. BISHOP:
Right.
8 MR. TWIDDY:
That would not have been something 9
these gentlemen would have looked at.
10 MR. FRIEND:
That is correct, Tom. They are 11 talking about the wall thickness measurement which is 12 something that the Stone and Webster team did not look at.
13 MR. BISHOP:
I understood that.
f
('
14 MR. TVIDDY:
You see, that was a non-required 15 thing that PG&E was doing in order to develop a data base 16 for the future.
17 MR. GISHOP: I am familiar with that. I was just 18 wondering about the statement that was made to us that it
. 19 wasn't something the IDVP looked at.
20 MR. TWIODY:
Right.
21 MR. BISHOP:
What you meant was that IDVP had 22 not considered that element, but in fact had looked at 23 that pipe for other things.
24 MR. TWIDDY:
Yes, for other things.
25 MR. LUNDIN:
The only thickness measurement we TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1904 Washington, D.C. 20006 (292) 293-3950
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looked at was as relating to the lug removal.
2 MR. BISHOP:
All risht.
3 MR. CHANDLER:
Wald driving also.
4 MR. FRIEND:
That particular weld was a shock 5 weld.
6 If I may, I would like to expand a little bit 7
on some of the remarks that Mr. Lundin just made.
When 8 PG&E and the project were considering this program, we 9 wanted to obtain exactly the kinds of things that Mr.
10 Lundin outlined.
11 We wanted a firm that understood what a 12 nuclear power plant was about and the important features 13 that went i nto the construction, and that was one of the i
14 considerations of why we selected Stone and Webster, 15 because we felt they had the experience and the judgment l
16 and the knowledge to go beyond the written record if there 17 was a quest on, to go to the supplier, to go to the shop, 18 to go to the mill cart and so forth, because we wanted an 19 independent assurance that what our beliefs were that the I
I 20 plant was constructed well, we wanted that independent 21 view from an experienced person, and the kinds of things 22 that Mr. Lundin has outlined gave us that assurance.
23 MR. BISHOP: My only concluding comment was that a
24 I would encourage you to:put in the ITR some of the topics 25 you discussed today and the judgmental processes you used TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1004 Washington, D.C. 20006 (202) 293-3950 w
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to draw your overall conclusions and your individual 2 conclusions.
3 MR. COOPER:
We clearly can be responsive to 4 giving more detail in each of the EOI files, what did PG&E 5
tell us, what did we think about it and what was the basis 6
for our classification.
That is easy.
7 The overall conclusion to document a judgment 8
is a rather difficult step and we felt that the basis of 9
that judgment was perhaps spelled out by the program plan.
10 Perhaps what we need to do is to place in one 11 or both of these ITRs, and I suspect both just because the l
l 12 reader might pick up one and not the other, but still an i
13 additional appendix which tries to summarize, for example, I
14 the page in the procedures that were read saying what the, i
15 and I forget just the way it was described, sort of the 16 thought process stimulator list that was read here today, 17 to put.that in and build some words around that and some 18 detail about the experience and capabilities of the 19 Findings Review Committee people so as to give the reader 20 some feel that that was a group who could properly 21 implement such a list.This sort of thing we can do.
22 My question to you folks at the end is if you 23 have got any other ideas of the sort of thing we could put 24 in there that would do this job better, please let us 25 know.
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MR. NORTON:
Is it i nappropriate for us to 2
request that something be in there?
I don't know whether 3
i t is in there or not and first I would like to ask.
Is 4
that appropriate?
/
5 MR. CHANDLER:
We will even ask Mr. Hubbard if 6 he feels there is something inappropriate?
7 (Laughter.)
8 MR. NORTON:
I am sure what he wants can't be 9
put in there.
10 (Laughter.)
11 MR. NORTON:
But my request is not so complex.
12 Bill, in the ITRs do you list the individuals 13 that conducted the audit and their backgrounds and i
14 experience and the Technical Review Committee by 15 individuals and their backgrounds and experience, because 16 a piece of paper that comes to a conclusion doesn't weigh 17 much.
We would hope it would weigh more when you look at 18 the people.
l l
19 (Laughter.)
l 20 MR. NORTON:
Do you understand? I just think l
21 that is important for a reader to ---
22 MR. COOPER: My suggestion is the identification 23 of the capabilities of the team that went out actually in 24 the field i n addition to the Findings Review Committee.
i l
25 MR. NORTON:
I would like to see a little i
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bibliography perhaps.
2 MR.' COOPER:
I think we can do this perhaps in 3
general terms.
I am not sure I want to identify them by 4
name and Frank and I will talk about that.
5 MR. NORTON:
Fine.
6 MR. SESTAK:
We didn't specify individuals. We 7
specified their qualifications.
8 MR. NORTON:
Well, this is a public record and 9
you have identified them all by name anyway.
Are all is members of the Technical Review Conmittee here today?
11 MR. SESTAK:
That is right.
12 MR. NORTON:
Well, I would like te ask a couple 13 of questions of that group.
(
14 MR. SESTAK:
The Findings Review Committee is 15 another 16 MR. NORTON:
Right, the Findings Review 17 Committee, I would like to ask a couple of questions of 18 that group collectively and, one, you can answer and then 19 if anybody has a different answer, then the other can.
20 In your review, understanding your scope, do 21 you feel that your review indicated a failure to 22 adequately control the activites of construction 23 contractors by PG&E?
24 MR. CHANDLER:
Would you repeat that.
25 MR. COOPER:
Yes, repeat that.
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4 MR. RICHARDSON:
No.
's 5
MR'." CHANDLER:
Let me make.a. request, if I can, a
6 The principal purpose l'would(say of the caeting today was s
s 7
to have an e) change between the staff and the'IOVP, 8
parti,cularly Stone and Webster, with respect to their 9
eva lua t ions 'as reflected in our letter to them of May 2nd.
Principally the participants were those 10 q
3 x.,
11 pareies and FG&( was not listed as a participant.
I 12 appraciate the points of clarification that have come out 13 during the rep e t i n g, but I really don't think at this point.
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1 x
1 14 it iss aFpropriate. 'If we are going to have a meeting that 15 is open, then.I.tuppose it is going to be a lot longer 16 meeting,$ d we'will have to extend,to Mr. Hubbard the same 17 opportuni,ty to pursue questions he may have, and certainly
's 18 we are g'oing to ask for his comme,nts.
th11 Mh,'NORTON:
you what the problem Let me 19 t
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independence here that l
20 is, Larry.
You have structured an s
t, 21 doe y.ri' t, a l l ow me to ever ask these questions, and if I
. 22 ' c a n ' t ask them at these meetings, I can never ask them, s
1 23 and they are car in germane questions.
24 You knob, you can have the right, it is 'your l
l 25 meeting, and yo'u can tell me to shut up and I will, but I l
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1 jast want to make it clear that the NRC has structured 2
thi/ independence.. thing and we are sticking with it to the U-3 best of; all of our abilities, but you know you put us in a e
4 very awkward spot when we can't ask a question.
5 f t1R. CHANDLER: I don't have a problem, Bruce, if 6
the Pro' ject wants to have the same kind of a meeting.
Let justjturn it around though and say if we are going to 7
me 8
expand it, that is fine, but I think we have recognize 9
that the meeting we had requested was a meeting with the
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la IDVP', Stone and Webster, to discuss our May 2nd letter.
MR. NORTON:
Don't you think that question very 11 12 directly relates to your letter?
13 MR. CHANDLER:
Oh, I have no doubt that there
!'(
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14-are a lot of questions that you may have that may relate 15 to that, and if you want to continue the meeting, if you 16 will, as a PG&E IOVP meeting, I am sure we can continue.
17 I have just one other question of these 18 gentlemen that I would like to ask them and we can 19 continue on.
20 MR. NORTON:
Fine.
21 MR. CHANDLER:
The only thing I had a question 22 about was in both ITR 36 and 38 in Section 2.0 the 23 statement is made that an appropriate sample for 24 evaluation was selected, et cetera.
25 I know one of the questions that we had had to l
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do with when you say appropriate. What does that term mean 2
and how did you come about that determination?
3 MR. COOPER:
The term I believe, without taking 4
the time to look at the words, the words "an appropriate 5
sample for evaluation shall be selected" is from the 6
program plan, and I believe when this was written it was 7
simply stated in that language to be consistent with the 8
program plan.
9 I believe the answer you received this morning 10 is that they basically for these two contractors did 11 everything that was physically accessible and available to 12 do.
13 MR. CHANDLER:
Okay.
14 I guess, Bruce, before sort of turning the 15 meeting around a little bit, I think it would be 16 appropriate to ask Mr. Hubbard if he had any comments.
17 MR. HUBBARD:
I think most of my comments have 18 been in the various declarations and affidavits.
19 There really are a couple of things that I 20 would have some interest in.
21 One is that my comment would be that the final 22 report ought to include the check lists that were used as 23 well as as many of the filled out check lists as possible.
O 24 I think the report ought to have something that 25 addresses the root causes relative to the QA/QC program.
4 TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1004 Washington, D.C. 20006 (202) 293-3950 p
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By tnat I mean where you say things were not fully 2
implemented."
3 I think in addition to talking about safety 4
significance, one should talk about what that means 5
relative to the QA/QC program.
6 I think time should be stressed a little more.
7 There seems to be a great emphasis on this, that the 8
quality being achieved was consistent with the time, and 9
we heard mention of the years all the way from
'73, 74 up is to some work that was done in 1982.
11 So if there is going to be some gradiation of 12 quality based on time, then I think more emphasis should 13 be given to time in the reporting.
t 14 MR. LUNDIN:
Excuse me. There was no 15 consideration of differences i n quality and time, but only 16 to procedural systems and maybe the level of compliance to 17 those specific things that were done. The level of quality 18 was never considered to be different than it would be 19 today.
20 MR. HUBBARD:
Well, there seemed to be slidiing 21 scale on criteria for acceptability based on time and it 22 would help me to understand what was the standard for good 23 practice in the various time spans that you were looking 24 at.
25 In terms of counting, if we do get into TAYLOE ASSOCIATES 1623 I Street, N.W. - Suite 1984 Washington, D.C. 20006 (202) 293-3950
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counting, a number of the observations talked about things 2
in plural.
So if we are going to get into counting, I 3
would request that we also count the observations in their 4
plurality so we know exactly what they mean where you say 5
many.
6 And, Larry, we will be requesting the check 7
list, both the ones that were used by the auditees plus 8
the Findings Committee.
We would like those check lists 9
and we would like as many of the filled out check lists as 10 possible.
11 We would also like to understand how the 12 documentation is arranged so that one could go to audit 13 it, and I guess I understand from the various meetings 14 that people are ready for us to come and audit that 15 documentation.
16 MR. CHANDLER:
Dick, in that connection, of 17 course, as Bruce advised all the parties, the IDVP has 18 retained counsel.
That is the law firm of Lowenstein, 19 Newman, Reis and Alexrad, and their counsel is Mr.
20 Alexrad or Kathleen Shea of that firm I guess, and 21 requests of that nature I think appropriately would be 22 directed to them.
23 MR. HUBBARD:
Well, that is very important, 24 Larry, for the record because I think there are a couple 25 of places where the statements were made that the records TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1004 Washington, D.C., 20006 (202) 293-3950 W
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are available and are available for audit or looking at.
2 There was an implication at least that I am sensitive to 3
that nobody has asked to look at some of these and we will 4
ask.
5 MR. NORTON:
I will address this to you, Larry.
6 We are in a hearing mode now.
We are now under a formal 7
discovery hearing mode.
We are no longer in the mode we 8
were in prior to April 21st.
We are in a different mode 9
now and any document exchanges and stuff like that is done 10 under formal or informal discovery requests, but at least 11 it has got to be handled through the attorneys, 12 MR. HUBBARD:
Well, I would like some more 13 explanation.
I didn't think we were into the hearing mode
(
14 on construction QA, which this is addressing. It seemed to 15 me we are still into the IDVP event.
So that is why I 16 thought it was appropriate to ask for those documents as 17 we normally would.
18 MR. FRIEND:
Well, this a little more complex 19 than that even I believe in that this program is an 20 adjunct program to the IDVP that was commissioned by PG&E l
l 21 to reach further assurance on the quality of construction.
22 I don't know that this part of the program 23 needs to be necessarily treated in the same manner as the 24 IDVP which was mandated by the commission.
25 MR. CHANDLER: I think though that in any event, TAYLOE ASSOCIATES l
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Dick, in a very real sense, it is a matter that i s before 2
the Board and is something before the Board for 3
consideration. To that extent I would have to consider it 4
a matter in litigation and the formal procedures would 5
apply.
6 Though certainly if the counsel for the 7
Governor would formally or informally contact counsel for 8
the IDVP to discuss it, I think whatever is appropriate 9
can be worked out.
le MR. BISHOP:
I would like to offer to you, and 11 it is already available to you, the reports of our audits 12 of that activity.
We have had inspections on the 13 construction QA plan and those reports are certainly c
14 available to you.
15 MR. CHANDLER:
Through me.
16 MR. SCHIERLING:
Did you have anything else, 17 Dick?
18 MR. HUBBARD:
No, not at this time.
19 MR. SCHIERLING:
Okay.
20 MR. NORTON:
I have two questions is all.
21 (Laughter.)
i it is my understanding 22 MR. SCHIERLING:
Well 23 that time is pressing on, No. 1 and, No.
2, I think it 1
l 24 might be appropriate to have a very brief recess and maybe 25 we can meet again in ten minutes.
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I think at that time parties can make 2
statements they wish to make, including PG&E I propose.
3 Isn't that appropriate?
4 MR. CHANDLER: Yes, Bruce can ask his questions.
5 MR. NORTON:
I am just going to ask two 6
questions.
I am not going to make a statement.
7 MR. SCHIERLING:
Do you want to ask them now or 8
after the caucus?
9 MR. NORTON:
I would rather ask them now.
10 MR. SCHIERLING:
Fine, go ahead.
11 MR. NORTON:
I think I had asked the first one, 12 but while this was going on I wrote it out so I will ask 13 it again, and I also heard somebody answer it, but this is I
14 to the TRC.
15 Did your review indicate to you that PG&E 16 failed to adequately control activities of construction 17 contractors?
18 MR. RICHARDSON:
I answered no.
19 MR. NORTON:
All right. Does anybody have a 20 different answer?
21 (No response.)
22 MR. NORTON:
All right. The Findings Review 23 Committee, and I said Technical Review Committee.
That is a
24 the Findings Review Committee.
25 The second question, did your review indicate r
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32 1
to you a lack of aggressive, corrective and preventative 2
actions by anybody?
3 MR. RICHARDSON:
No.
4 MR. SCHIERLING:
Well, let me make a few 5
statements.
6 No.
1, I think the information that was 7
provided today by you goes far beyond what you reported in 8
both ITRs, and I think if appropriately incorporated it 9
will give far better credit to the work that you did and 10 will address many of our questions.
11 I had written down specific questions and many 12 of those were already addressed.
13 I think it is appropriate, and I want to 14 emphasize that again, to include a statement similar to 15 the one that Crais read before, the philosophy on the 16 questions that you asked yourself, what does all this 17 mean?
I think that is very appropriate.
18 I do not know how voluminous the check lists 19 are, and I do not know right offhand if there is a 20 difference between check lists and attributes that you 21 developed, that you were considering in your evaluation.
22 I think they should be summarized in the 23 revision to the ITRs to give a better indication of the 24 depth that you looked into the various matters.
25 Although some of the documentation that was TAYLOE ASSOCIATES i
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generated, information that was generated during your 2
evaluation might not be open for audit in general at this 3
time because of the various elements in the hearing 4
process, I think staff still would like to, and I think we 5
can, look at the records any time, can't we?
6 MR. CHANDLER:
If worse comes to worse, we can 7
always ask for discovery.
8 (Laughter.)
9 MR. NORTON:
The staff clearly has the right.
10 MR. SCHIERLING:
I think staff would like to 11 look probably at some of the details that were generated, 12 the check lists anc the list of attributes.
I think we 13 want to do that.
14 MR. SES1AK: Hans, I just want to point out that 15 when I think Region V conducted an audit on us they did 16 review the 17 MR. SCHIERLING:
Tom Bishop just informed me 18 that we did that already.
Where is most of that 19 informaticn located?
20 MR. SESTAK:
In Boston.
21
.MR. SCHIERLING:
It is in Boston.
22 MR. SESTAK:
It is in our office.
23 MR. SCHIERLING:
Thank heaven.
s 24 (Laughter.)
25 MR. NORTON: Do you have in the ITRs the program TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite t004 Washington, D.C. 20006 (202) 293-3950
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itself, the initial program that I referred to earlier, 2
the October 3
MR. COOPER:
It is not included in there, no.
4 MR. NORTON:
Do you think that might be a good 5
appendix to the ITRs also which sets forth what the 6
program was?
7 MR. COOPER:
That would be one of the easier 8
ones to prepare.
9 MR. NORTON:
It certainly would.
10 (Laughter.)
11 MR. NORTON:
I think
- t would be useful.
12 MR. FRIEND:
Somebody might want to edit it.
13 MR. CHANDLER:
I think it would be useful as an 14 appendix because I think it would help put some 15 pr'spective on the findings when you can relate them 16 better to the things you were looking at and the way you 17 were looking at them.
18 MR. SCHIERLING:
I have to come back to one of 19 the two questions that Bruce just had.
In your effort did 20 you look or did you also evaluate the PG&E review and 21 approval of the QA programs by the two companies in other 22 words, the audit that was exercised by PG&E on the two 23 companies?
24 MR. LUNDIN:
We had an attribute that they were 25 approved.
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MR. BEARHAM: We saw evidence of their approval.
2 That is what we looked for, a lead sheet somewhere that 3
showed evidence of PG&E's approval of the two 4
subcontractors.
5 MR. LUNDIN: Also in the non-conformance process 6
the approval of the disposition of non-conformances which s
7 was another process.
We verify that there is an attribute B
on the check list to assure that that was done and that 9
was verified.
10 MR. SCHIERLING:
And, on the other hand, you 11 also looked at the QA programs and their approval by 12 subcontractors to Wismer-Becker and GFA?
13 MR. LUNDIN:
There were non to Wismer-Becker.
k 14 MR. BEARHAM:
None to Wismer, no.
15 MR. IVES:
To Atkinson, yes.
16 MR. SCHIERLING:
Okay, those are all the 17 questions I had.
18 Unless there are other specific questions at 19 this time, we can go and take a 10-minute break, readjourn 20 and if there are any closing statements, let's go and do 21 that and we will make our plane, l
22 We will meet at five minutes after twelve.
23 (Whereupon, a short recess was taken.)
24 MR. SCHIERLING:
Are we ready to go back on: the i
25 record.
l l
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Let's do this.
Howard, do you have any 2
statements?
3 MR. FRIEND:
Yes. I would like Mr. Dick to 4
address a couple of items that follow up on this morning's 5
presentation as a matter of clarification, if it is okay 6 with you.
7 MR. SCHIERLING:
That is fine.
8 MR. DICK:
Yes, I would like to clarify just a 9
couple of items which were covered partly but maybe not le completely by Mr. Lundin.
11 I believe this complements what he already 12 said, but it takes into account several elements which may 13 not have been apparent to these gentlemen.
i
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14 The first subject is that of the program 15 evolution.
The evolution of the contractor's program is 16 not as obscure as may appear.
It is a relatively 17 straightforward thing according to our observation.
18 PGLE wrote a very detailed specification in 19 making the original selection of contractors in which the 20 quality assurance requirements were set forth in some 21 detail.
22 The contractors in turn responded as part of 23 their proposals with a quality assurance program.
Now
\\
1 24 those programs were approved by PG&E and I believe the 25 contractors' programs also included provision for l
TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1904 Washington, D.C. 20006 (202) 293-3950
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subcontractors to in turn have programs.
2 Those programs were during the subsequent work 3
monitored by PG&E in accordance with the PG&G program and 4
I believe also by the NRC inspectors in the course of 5
their inspections. The programs were entirely consistent I 6
believe with the applicable provisions of Appendix 8.
7 So I think there is a rather clear and coherent 8
trail here on the evolution of the contractor programs and 9
it can be demonstrated.
10 The other point I would like to make deals with 11 the concept of use as is where the constructed product may 12 not be identical with the drawings with which it is being 13 compared.
i r
14 In addition to the reasons set forth by the 15 IDVP, there are other reasons that we' understand also 16 existed.
A very important reason was during the erection
/
17 of the portions of the steam supply system Westinghouse 18 Electric Corporation had its on-site inspectors present 19 and conducted a fairly comprehensive review of the work 20 that was ongoing.
21 We believe that some of their records tended to 22 support the conclusions of the IDVP, that in those cases 23 where tnere were some departures from the initial design 24 drawings, that those were duely considered and accepted at 25 the time the work was performed.
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So this was a real time sort of a review, and 2
it was'not an after the fact type of acceptance made in 3
1982.
4 We have also attempted to provide the IDVP with 5
other information that indicated that there was a 6
considered acceptance of the product as constructed.
7 Those are the two essential points that I 8
would like to make.
9 I might modify my earlier statement in one le small respect, and that is with regard to the timing of 11 the acceptance of the contractor program.
I believe in 12 most cases it was accepted at the time the contract was 13 awarded, but there was an evolutionary process here.
But 14 in any event the contractor did perform his work under an 15 accepted program.
16 MR. SCHIERLING:
Thank you.
17 Bill or Frank, would you like to add anything 18 at this time?
19 MR. COOPER:
Two quick things. One is I was 20 going to talk a little bit about use as is, as Charlie 21 did, because I think it is very important that many times 5
22 we are better off to use as is rather than try to make a 23' repair, and clearly in that period the documentation of 24 the acceptance of those sort of things were not of the 25 nature as they are today.
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Charlie said it all and I am not going to say 2
any more about that.
3 The other thing is we will commit to do the 4
best job we can in revising these ITRs, including some o f-5 the things that we have talked about here today.
Our 6
priority will be placed on getting those ITRs issued by 7
the end of next week with as much as we can in as we 8
possibly can.
9 We recognize the need that several parties in is this room have to be responsive to certain things where 11 time is of the essence, and we will do the best job we can 12 to include everything.
We may fall short in a couple of 13 areas, but we will give our priority to setting these
\\
14 things out on the street by the end of next week.
15 We may shortchange some or all of you on the 16 number of copies you receive, but clearly the normal 17 distribution pattern will be followed as far as the people 18 to whom it is distributed.
19 MR. SCHIERLING:
Is there anything else?
l 20 (No response.)
l l
21 MR. SCHIERLING:
Dick, did you want to add i
l 22 something?
23 MR. HUBBARD:
No.
l 3
1 24 MR. SCHIERLING:
Then any further questions or 25 comments the staff has?
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1 MR, BISHOP:
No.
2 MR. CHANDLER:
No.
3 MR. SPRAUL:
No.
l 4
MR. SCHIERLING:
For the staff I want to thank 5
all of you for coming out on a Saturday.
We are looking 6
forward to setting the information in the forthcoming 7
revisions.
8 I think the information as discussed today does 9
indeed provide the answers to the letter that we sent to 10 you. Bill, and again as much as you can put in there, we 11 are anxiously waiting for it.
12 If there are any complications that you cannot 7--
13 make the schedule, please let us know.
t' 14 MR. COOPER:
We will make the schedule.
15 Completeness is the question.
16 MR. SCHIERLING:
Okay.
17 Well, again, thank you very much for coming out 18 on a Saturday, and we will see you again very soon on 19 another weekend.
20 (Whereupon, at 12:15 p.m.,
the meeting 21 adjourned.)
s 22 23 3
24 25 TAYLOE ASSOCIATES 1625 I Street, H.W. - Suite 1004 Washington, D.C. 20006 (202) 293-3950 J
CERTIFICATE OF PROCEEDI:GS 3
I 2
This is to certify that the attached proceedings before the 3
1 NBC COMMISSION 4
In the matter of:
Diablo Canyon s
Date of Proceeding: May 21, 1983 Place of Proceeding: Boston, Passachusetts s
7 were held as herein appears, and that this is the original o
transcript for the file of the Commission.
10 Mary C. Simons Official Reporter - Typed 12
.f 13 he Officia6 Reporter - Signature 15 16 17 18 19 20 21 3
22 23 24 2S TAYLOE ASSOCIATES REGISTERED PROFESSIONAL REPORTERS NORFOLK, VIRGINIA e
/