ML20054F149
| ML20054F149 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/07/1982 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| NUDOCS 8206150260 | |
| Download: ML20054F149 (300) | |
Text
_ _ _ - _ _ _ _ _ _ _ _ _ _ _ _
NCCI.ZAR REGU.* ATORY CCMMISSIC'i (D Q ^ f)f 1 r>- -
_ .: L BEFORE THE ATOMIC SAFETY AND LICENSING BOARD m e -- e: ,
TEXAS UTILITIES GENERATING COMPANY, et al. : DOCKET NOS. 50-445
- 50-446 (Comanche Peak Steam Electric Station, :
Units 1 and 2) :
O DA*I: June 7, 1982 PAGES: 682 - 969
~
AT: Fort Worth, Texas 1
l
.unensox /' atm msa o F- Q 400 vi_ginia Ave., S.W. W==hdng.==, D. C. 20024 O :.i gn==. : <202) 554-2245 8206130260 820607 PDR ADOCK 05000445 T ,99
/ F" gg "t 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
- 2 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 3
O 4 In the Matter of: )
)
5 TEXAS UTILITIES GENERATING Docket Nos. 50-445 g )
9 COMPANY, --et al. ) 50-446 3 6 o )
6 (Comanche Peak Steam Electric )
6 7 Station, Uni.ts 1 and 2) )
A 8 8 0
ci 9 Times Square West, y Fort Worth Hilton, g 10 1701 Commerce St.,
$ Fort Worth, Texas j 11
- Monday, y 12 June 7, 1982 O! '3 rue ebove-eaete1ea eter oe e oa cor rurener
! 14 hearing, pursuant'to adjournment, at 9:00 c.m.
{m 15 BEFORE:
j 16 MARSHALL E. MILLER, Chairman d Administrative Judge I7 Atomic Safety and Licensing Board h
- U.S. Nuclear Regulatory Commission
{ 18 Washington, D. C. 20555 ,
g I9 DR. KENNETH A. McCOLLOM, Member Administrative Judge 20 Dean, Division of Engineering, Architecture and Technology 2I Oklahoma State University Stillwater, Oklahoma 75074 V DR. RICHARD F. COLE, Member 23 Admi-istrative Judge Atomic .;afety and Licensing Board 24 U.S. Nuclear Regulatory Commission Weshington, D.C. 20555 2, ;
ALDERSON REPORTING COMPANY,INC.
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68Q 1 APPEARANCES:
O 2 On Behalf of the Applicants, Texas Utilities Generating Company, et al:
3 O 4 '
NICHOLAS S. REYNOLDS, Attorney
-and- -
5 WILLIAM A. HORIN, Attorney g
! 9 Debevoise & Liberman
', 3 6 1200 Seventeenth Street,N.W.
{ Washington, D.C. 50036 2 I E SPENCER C. RELYEA, Attorney k 8 Worsham, Forsythe and Sampels 4 2500-2001 Bryan Tower 9 Dallas, Texas 75201 E.
g 10 On Behalf of the NRC Staff:
E k MARJORIE ROTHSCHILD, Attorney
. -and-
- $ GEARY MIZUNO, Attorney 3 g Office of the Executive Legal Director g U. S . Nuclear Regulatory Commission g g Washington, D.C. 20555 U
E SPOTTSWOOD BURWELL 15 G Licensing Project Manager g Comanche Peak Steam Electric Station j U.S. Nuclear Regulatory Commission g 37 Office of Nuclear Reactor Regulations a Washington, D.C. 20555 x
5 18
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2 19 M
20 21 Q 22 23 ,
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I l ALDERSON REPORTING COMPANY,INC.
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3 -hop 1 APPEARANCES: (Continued)
O 2 On Behalf of Intervenor, Citizens Association For Sound Energy:
3 Q 4 JUANITA ELLIS, President CASE 1426 South Polk Street e 5 Dallas, Texas 75224 '
h
@ 6 LANNY ALLEN SINKIN, Law Student R 838 Magnolia Avenue b 7 San Antonio, Texas 78212 3
8 8 WILLIAM S. JORDAN, III d -
Harmon and Weiss ci 9 1725 I Street, N.W.
$, Suite 506 10 h Washington, D.C. 20006
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1' _C _O _N _T _E _N _T _S l ,g ,
2 WITNESS DIRECT CROSS REDIRECT RECROSS EXAM.
3 MELITA P. OSBORNE By Mr. Reynolds 734 759 4 By Judge McCollom 753 767 e 5 6
$ 6 E i FRED W. MADDEN b 7 By Mr. Jordan 744 762 s
j 8 By Judge Cole 747 d 757 o 9 Y
$ 10 z
E SAMY DIAB By Mr. Mizuno 772 j 12 By Mr. Jordan 782 By Judge McCollom 777 Og g m
13 h 14 RA1MOND C. MASON b By Reynolds 790 2 15 837 y 16 RONALD G. TOLSON W By Ms. Rothschild 915 6 17
- M 18 19 R
20 21 0 22 23 24 25 ALDERSON REPORTING COMPANY,INC.
i f" 68Q I EXHIBITS 2 NUMBER MARKED RECEIVED Bd. 1 703 731 703 731
(]) 4 Bd. 3 App. 14 737 737 e 5 g App. 15 739 739 j
- 6 App. 16 App. 17 792 794 792 794 y App. 18 796 796 7
- App. 19 798 798 app. 20 800 800 E 8 a App. 21 858 899 App. 22 858 899
$ 9 g App. 23 878 899 C
$ 10 s
~
g 11 925 925 g CASE 4 6 CASE 5 938 938 12 3 CASE 6 943 943
()3$m 13 E 14 App 24 940 W
$ 965 15 CASE 8 965 2
y CASE 9 966 l .- 16 CASE 10 966
$ CASE 11 967 17 CASE 12 968 6
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20 21 22 C:)
23 ;
24 (3) 25 ;
ALDERSON REPORTING COMPANY. INC.
L _ - - - _ _ __
I ~ [26p 1-1 j j PROCEEDINGS
. e 2 JUDGE MILLER: 'Ihe pre-hearing conference in the 3 matter of Texas Generating Company, et al., which was the subject IO V 4 of a notice dated April 19, 1982, duly published in the Federal n 5 Register, will come to order, please.
N
$ 6 My name is Marshall E. Miller. I'm an attorney and R
S 7 practiced a number of years in Washington, D. C., and I've been s
j 8 with the NRC since 1974.
O C 9 To my left is Judge Kenneth McCollom, Dean of
- (
C g 10 Engineering at Oklahoma State University, and to my right is 25 h 11 Judge Richard Cole, who is eminently qualified in the field of k
j 12 environmental science, both academically and professionally, and Ol ia is e fu11-eime member of the neomic Sefeer end ticeneine soerd h 14 panel.
2 15 We will ask counsel and parties to identify themselves j 16 for the record, please, starting at my left, the Staff.
wi d 17 MS. ROTHSCHILD: Mr. Chairman, my name is Marjorie l 5 18 Rothschild. I am counsel for the NRC Staff. I'm with the U. S.
E 19 Nuclear Regulato g Commission, Office of the Executive Legal g
n 20 Director, Washington, D. C. 20555.
21 To my immediate right is Mr. Geary Mizuno. The first O 22 name is c_e_a_r_y, 1ast name is M_1.z_u_n_o. se is co_counse1 23 with me for the NRC Staff. His address is the same as mine.
24 To Mr. Mizuno's immediate right is Mr. Spottswood 25 Burwell, B-u-r-w-e-1-1. He is the Project Manager, the NRC Staff i
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ll ALDERSON REPORTING COMPANY, INC.
9 I~ bbd.
1 1' 1I Project Manager for the Comanche Peak Steam Electric Station.
.he 2 His address is U. S. Nuclear Regulatory Cormission, Office of l
3 Nuclear Reactor Regulation, Washington, D. C. 20555.
r~b l kJ 4 JUDGE MILLER: Very well.
g 5 MR. REYNOLDS: Good morning, Judge Miller.
b
@ 6 JUDGE MILLER: Good morning.
R
$ 7 MR. REYNOLDS: Appearing this morning for Applicants M
j 8 are, myself, Nicholas S. Reynolds, of the Washington, D. C. law d
d 9 firm of Debevoise and Liberman.
i o
g 10 To my near left is my associate, William A. Horin, E
11 and to my far left is Spencer C. Relyea of the Dallas law firm a
j 12 of Worsham, Forsythe and Sampels.
() =
13 We have provided the appropriate spellings and m
5 14 addresses for the court reporter.
{= 15 JUDGE MILLER: Thank you.
j 16 Intervenors?
M j d 17 MS. ELLIS:. Good morning.
5
$ 18 JUDGE MILLER: Good morning.
=
g 19 '
MS. ELLIS: I'm Juanita Ellis, President of CASE, 5
20 Citizens Association for Sound Energy.
21 To mv immediate right is Lanny Allen Sinkin, a CASE 22 member from San Antonio, and he is working as co-counsel. He is
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23 entering third year law school at the University of Texas at 24 Austin, and he will act as co-counsel with us.
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L-25 ; And to my far right is William S. Jordan, III, a i
i
! ALDERSON REPORTING COMPANY,INC.
I~ 683 1-3 1i Washington attorney with Harman and Weiss, and he will also be
"*() 2 acting as co-counsel with us.
3 JUDGE MILLER: Let me inquire, we have the notice 4 of appearance of Mr. Jordan, and it will be entered in the record, 5 but let me inquire who's going to be lead counsel, or is that j
9 I h 0 going to vary from matter to matter?
~
In other words, you can't G
E 7 all act as counsel simultaneously, as I'm sure you're aware, so s
- 8 M just indicate how you intend to designate lead or speaking counsel .
d
. MR. JORDAN: We expect that I will be lead counsel e
10 h most of the time, but I'll have to tell you I've been here for d
II
$ three days, so we will trade off in a way that we trust will make 3
d 12 z this hearing official and proper.
13 JUDGE MILLER: All right. I think you understand E 14 w the one who starts to handle a proposition, whether it be 9 15 g argument, witness, or what not, will continue throughout for
=
j 16 that purpose, and just keep the Board advised so we don't have w
any uncertainty, or be duplicitous in the sense simply of x
M 18
_ duplication at the same time.
s 19 3 MR. JORDAN: Your Honor, with respect to argument, n
20 certainly -- with respect to witnesses, we have some difficulty; 21 it really doesn't bring it out so much by witnesses as it does
() by subject areas. I think we'll broadly try to break it down 23 : by subject areas. In any event, we will avoid duplication.
() JUDGE MILLER: All right. And adivise the Board and 25 l parties so we know what you're doing, and if we do that, I'm sure f
i ALDERSON REPORTING COMPANY, INC.
- .. .~ _ _ . . - - - - . _ - __ _ _ .,_- .- .,
F 690 1-4 1 we'll have no problem.
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b 2 Anyone else, now, whose appearance should be noted 3 for the record or who should be identified for the record as
'h (V 4 parties or counsel?
e 5 (No response.)
3 6 JUDGE MILLER: All right.
R
$ 7 The first matter at this pre-hearing conference, s
j 8 and I will say that immediately following the pre-hearing d
d 9 conference we'll have a five-minute recess before we start the
- i C
$ 10 formal evidentary hearing, so for the benefit of people who are 11 not parties to this proceeding there's a little bit more, slightly is j 12 more informality to a pre-hearing conference than an evidentiary 5
Oi is heerine, it does heve e11 ehe forme 11er oc e eria1 end we wi11
@ 14 be following, where applicable, our own rules of practice, as
!E 15 well as where analogous the Federal Rules of Civil Procedure and j 16 the Federal Rules of Evidence.
as 17 In case that you wonder sometimes at the rulings of a:
{ 18 the Board, I'm sure you will realize that we are following n 19 g specified rules of practice which are applicable to this and all n
20 NRC proceedings.
21 I will open now the pre-hearing conference by noting O 22 ehat what the ,oard is aware of 1s, f i r s t o , a 1 1 , w h a t e v e r m o e 1 o n ,,
23 Mrs. Ellis, or whoever.is representing CASE at this point, wishes 24 to bring up, in our telegraphic notice or order in which we 25 rejected certain applications of continuances or delays, one kind ALDERSON REPORTING COMPANY, INC.
f~ 691 1-5 1; or another, related to discovery or commencement of this trial, he
- 2. . or both, that there would be an opportunity at this hearing 3 today, June 7, in Fort Worth, Texas, for any significant, or I 4 think I used the term " material," which may not be too precise e 5 but we'll go into that later, matters which are intended to be
$ 6 brought up. In other words, those matters which are relevant R
6, 7 in the sense in which the term is used and defined in the Federal X
j 8 Rules of Evidence. That, I understand, you'11 have the oppor-d c; 9 tunity.
g 10 There will also be what has been described and dated E
j 11 June 6th, 1982, as the Applicants' brief regarding scope of a
[ 12 hearing on Contention 5, and I assume that there will be some-Ojis thing brouehe to the 80 erd'e eetention with reserd to the scoge l$ 14 of Contention 5.
15 Those are those two matters. Now, is there anything j 16 else that we should be aware of before we open up the discussion A
I li 17 of procedural or relevant substantive matters at the pre-hearing l 5 M 18 conference?
e 19 g MR. REYNOLDS: The distinction you just drew, M
20 Mr. Chairman, is one which relates to the summary disposition 21 motion which is pending, which would be handled at the hearing i
22 O ghase as opgosed to __
23 ! JUDGE MILLER: No, it didn't, but that should be 24 number three, and should really be number one.
25 ! MR. REYNOLDS: In the pre-hearing conference?
ALDERSON REPORTING COMPANY,INC.
6 '~
692 1-6 1 JUDGE MILLER: Right. That, I think -- we're trying he 2 to get scrne ',gic to it in order to give everyone a fair 3 opportunity to be heard and yet have a little rationality to it.
G V 4 The Board probably, therefore, will take up first the pending 5 motion for summary disposition, duly filed in a timely fashion by g
a
@ 6 the Applicants, responsive to and in support thereof filed by R
& 7 the Staff in opposition, and various summaries and documents as j 8 well, I believe filed by CASE in a timely fashion.
d c; 9 Now, those matters are now pending before us. Unless z
o g 10 someone has something special to present, and we don't mean to E
II bar you, but we have read carefully the various and numerous 5
is j 12 documents 1i. led, the Board would be prepared to rule upon the 5
13 motion for a summary disposition.
I4 Is there anything of a compelling nature, above and ju 15 beyond your filings, that anyone wishes to present?
3[
I0 (No response.)
I wi f
x 37 JUDGE MILLER: The Board has concluded, after l { 18 examining the relevant affidavits and the documents filed, that i:
19 the motion for a summary disposition of Contention 5 will be g
20 denied.
2I There are enough matters which appear, even from the 22
'O ,,cmme,ts ,11ed sy App 11 cants ,ne sta,,, to raise certain
! questions of fact. We intimate no conclusion as to what the O decision of the Board will be upon those issues of fact, or 25 upon certain conclusions which allegedly flow or de not flow from ALDERSON REPORTING COMPANY, INC.
i~ 693 1-7 1 them. Nevertheless, they are of sufficient importance and A
2 gravity in this operating license proceedirg that the Board 3 believes that an evidentiary hearing should be held on the 4 matters.
e 5 Now, there has been filed the pre-filed written h
@ 6 testimony of both the Applicants and of the Staff in support of G
$ 7 their various positions on the factual and other issues. CASE M
{ 8 has not filed, as such, though they have filed documents which d
d 9 according to certain motions I think filed by CASE, may equal
$ 10 800 pages. I don't know. I didn't count them. It did not, E
II however, file as such a written or pre-filed direct testimony.
s I2 f So at this point the record now will show that the 13 motion for a summary disposition of Contention 5 is denied, and
- c
@ 14 those matters will be going forward at the evidentiary hearing, 15 to commence immediately after the pre-hearing conference, and j 16 as to which there has been testimony filed.
us I7 Any questions?
h a:
{ 18 (No response. )
E E
I9 JUDGE MILLER: Okay. Now, Point 2, when we start M
20 the evidentiary hearire the Board intends to make a record as to 21 Board Questions 1 and 3. The Board has determined -- I'm simply O 22 ,,,,1mg 1m , ,emm,,y ,y __ ,s,, es, 1mform,,1,, supp11 d sy 23 ; Staff and Applicants is sufficient for the purposes for which 24 the Board raised those questions.
25 l Dr. McCollom and Dr. Cole will each be addressing ALDERSON REPORTING COMPANY, INC.
!~ 694 1.- 8 1 one of those matters when we go into the evidentiary hearing, in 2 order not to take the time now unnecessarily.
3 As to the third matter, now, you were advised that on 4 BIT, so-called, we did wish to have evidence presented, or 5 witnesses, or whatever the parties deemed appropriate.
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lR 6 That's the boron injection tank, which has been 8 7 reduced to letters as I guess for want to do, BIT, B-I-T. That 2 s j 8 matter will be part of the evidentiary hearing.
(J ci 9 MR. REYNOLDS: Judge Miller, with regard to the BIT
$ 10 matter, the Staff and Applicants request -- well, not speaking 3
=
q 11 for the Staff -- but the Applicants request that the Board is g 12 entertain that matter first so that those witnesses may present
! Ol is the Boerd with whatever teetimony is aggropriate and then he l$ 14 discharged.
l a:
15 JUDGE MILLER: We can probably accommodate that 16 request.
3l as 17 There is one matter which I might as well mention to
{
18 you at this time. In certain motions filed with the Appeal Board U
39 there was attached a newspaper clipping, this one dated Thursday, g
n 20 June 3, 1982, which, without attempting to go into the merits in 21 any way, does refer to two matters, two alleged cracks.
22 Q We are therefore requesting Applicants, Staff and 23l CASE to take up, out of order, those questions. In other words, 24 we want to get to those immediately.
l
\ 25f Now, whether or not we can accommodate your BIT l
s ALDERSON REPORTING COMPANY,INC.
l' 695 1-9 1 witnesses within that context, I'll have to leave to counsel 2 and you can advise us, but we want to proceed immediately and 3 directly into those matters.
4 MR. REYNOLDS: We agree with that schedule. Thank e 5 you.
0 3 6 One other point, is the Board suggesting that those R
$ 7 issues are being undertaken within the scope of Contention 5 or a
j 8 are they being undertaken as Board issues, Board questions?
d ci 9 JUDGE MILLER: No, within the scope of Contention 5, Pi C
y 10 but I may as well say we don't regard Contention 5 as being as
@ 11 restricted as apparently the Applicants do. We regard in 12
{ Contention 5 as being rather broad in nature, going into Quality O!i3 m
iseurence/oue11ey Control.
l$ 14 I'm sorry. I'm wrong on the BIT. BIT is not part g 15 of 5. That is a separate matter where the Board asked for l
=
y 16 information. So it's neither Contention 5 nor is it a Board '
us N 17 question as such. It is a matter, however, upon which the Board l E
$ 18 has asked for information, and then after we receive it, the i:
{
M 19 Board will then decide whether that is sufficient, whether it 20 might become a Board question, or whatever, but we'll advise you 21 of the result on that. I'm sorry, I didn't understand the O 22 significance of your guestion.
23 MR. REYNOLDS: I understood your response to not 24 O inc1ude B1T as pare of conteneion 5. l j 25 i JUDGE MILLER: Correct.
ALDERSON REPORTING COMPANY,INC.
1
! s9ts !
1.-10 1 Any other questions?
2 Yes. You off the air?
3l Any other, or additional motions or matters to come 4 before this pre-hearing conference? I had heard none, but we g 5 had a short recess in order to get the record squared away with 9
@ 6 all the appearances.
R
{ 7 Is there anything further required of this pre-hearing A
j 8 conference at this time?
d d 9 MR. JORDAN: Mr. Chairman, we have a couple here
$ 10 what I would call motions, but let me first.get to the handling 11 of the matter of the crack. I'm sure you're aware that we a
j 12 consider the crack to be of extraordinary importance. We were i3 Ol edvised on1r in the 1eee two weeke, end if te hedn e seen for
! 14 CASE's effort, no one would know about it. We do --
15 JUDGE MILLER: Pardon me just a moment; just a j 16 minute. h...it 's this? Somebody just put a mike --
as d 17 Go ahead. Go ahead.
$ 18 MR. JORDAN: We certainly would be pleased to have
=
k 19 it come up first if you think it is important to get all this 20 information in the record, however, but we frankly are not 21 prepared to cross-examine on it yet. At least we need to put it O 22 to the end of our cross-exeminetion of whoever ehese geog 1e ere.
23 JUDGE MILLER: I'm sorry. I don't think we can take 24 it out of order. Now, this has been the subject of a news 25 i report which was attached to your client's petition or motion ALDERSON REPORTING COMPANY, INC.
l I] 697 1-11 I before the Appeal Board.
v 2 Now, we're raising the question which is raised there.
3 We haven't read it as such. We're not trying cases in the 4 newspaper, but we certainly are not going to dodge issues that g 5 have come up in this community. We think they are important, A
$ 6 both for that reason and our own responsibilities in the public R
$ 7 interest. We intend to proceed right away. We'll expect you to 7.
j 8 do the best you can*, if you think you're unprepared.
d d 9 MR. JORDAN: Your Honor, I'd like to -- as I say, we i
o
(; 10 absolutely agree with you, but I want to make it clear what the
$ 11 date of that news article is, if I may; is it not June the 4th?
is j 12 JUDGE MILLER: 3rd. Thursday, June 3. Attached to 25 s O gm is the geger -- the on1r ree on I mentioned the newsgever regore,
! 14 by the way, is because it was attached to your client's motion 15
{a: or pleadings before the Appeal Board.
j 16 MR. JORDAN: Yes, sir.
us 6 17 JUDGE MILLER: That's how it came to our attention.
5
{ 18 Now, other than that, we don't try case in the newspapers, of E
19 course, and no lawyer does, g
n 20 MR. JORDAN: No. If you hadn't brought it up, then 21 we would have.
O 22 ,UDcE MILLER, I.m sure you wom1d.
23 l MR. JORDAN: But I believe CASE first rendered that i
24 approximately two weeks ago, on the 8th.
25 JULGE MILLER: I don't know, but you'll have a chance ALDERSON REPORTING COMPANY, INC.
l I~ 698 1-12 to make your record at the evidentiary hearing. I think there 's-1 n
b 2 some indication that there's records that go back some years, but 3 I don't want to get into the merits of it. But we do intend to 4 go into it. We intend to do it seasonably, which is about the s 5 first order of business, and we expect everyone to do the best A
$ 6 they can, if indeed you are not prepared, and if you're not R
i S 7 prepared, why, I presume everybody will have a chance to state 3
l 8 the facts on that, if it be a significant matter, d
% 9 Anything further?
z o
g 10 MR. JORDAN: Yes, sir.
E j 11 JUDGE MILLER: Oh, I'm sorry, you did say you had in j 12 several things.
we neve O! is an aoaoin: ome oener metter -
h 14 JUDGE MILLER: Oh, okay.
2 15 MR. JORDAN: With respect to the crack, again, we s
j 16 believe the Board will want to hear from him, and we certainly us d 17 want to hear from Mr. Seifert from Region IV. Apparently he
$ 18 overlooked this matter, and we have a couple of other things as
=
C 19 well.
g i
20 We do intend to develop a list of witnesses to be 21 subpoenaeci . We simply are not ready as of now. We can give 22 that to you, we expect, after lunch, a list of people and the
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23 ; reasons we believe support the subpoenas.
24 Secondly, we are concerned, we have learned over the 25 i weekend that we do not have a complete reponse to at least one of 5
ALDERSON REPORTING COMPANY,INC.
i
! 689 l-13 I our interrogatories.
O 2 JUDGE MILLER: Which one is that? Whose interrogatory?
3 MR. JORDAN: The interrogatory related to matters 4 concerning the so-called, the ASME certification question as e 5 exploration.
U h 6 JUDGE MILLER: Well, for the record, identify the R
E 7 interrogatory, by whom, to whom, what date, what responses, if 3
] 8 any, if inadequate, give the -- identify the response, if you d
c 9 haven't received any, indicate that. Let's make a complete
$ 10 record.
E j 11 MS. ELLIS: I don't have that information readily j 12 available. I can have it in a few moments.
() 13 One thing in our interrogatories, I believe it was l$ 14 our sixth set, I'm not positive of that, I believe it was our g 15 sixth set, the first question, when we asked several questions x
g' 16 about the ASME matters and --
M N I7 JUDGE MILLER: Well, it isn't adequate to identify 5
{
18 the issue, Ms. Ellis. We have had in this case a large number
- 19 of documents of various kinds, interrogatories, rest ases, 20 motions, and it's about so high.
21 Now, therefore, in order to have a record, just slow
() 22 down and identify with precision what you're referring to, and 23 then we'll ask whatever party it's directed to to respond. We
() 24 want things in an orderly way. Remember we are conducting a 25 trial.
i ALDERSON REPORTING COMPANY, INC.
_ . o
.: ano 1-14 1 MR. JORDAN: Your Honor, my notes reflect that it O 2 was CASE's eighth set of interrogatories, No. 1 (c) and (d) and 1
3 the notice relating to that question.
O 4 JUDGE MILLER: To whom?
l
$ 5 MR. JORDAN: It was interrogatories to the Applicant. '
3 6 JUDGE MILLER: Okay. Do you have any further R
$ 7 information now, because I'm going to turn to the Applicant in s
j 8 a moment and find out what the record shows, d
c} 9 MR. JORDAN: It's right towards the end of it. I z
o G 10 don't have the language of the question in front of me. It l
$ l 3 Il related to essentially everything that the Applicant knew about j
- 1 12 the ASME certification question that came up late last year or
()dm 13 early this year.
h 14 We understand that there is a tape by a J. P. Clark i %
g 15 or S. J. Hawkins that was made of conversations with the ASME x
j 16 team, I believe, as they were going to begin to do their --
M l N I7 JUDGE MILLER: I think that's probably sufficient 5 18 to identify. We won't go into the merits at the moment.
E 19 MR. JORDAN: I think that's probably sufficient to g
n 20 identify it.
2I JUDGE MILLER: Yes. Let's find out, now, we'll ask
() 22 Applicants' counsel to state for the record what the situation is 23! with reference to the interrogatory answers that have been 24 alluded to.
25 MR. REYNOLDS: Well, Mr. Chairman, as you might I
i ALDERSON REPORTING COMPANY, INC.
. 701 1-15 I suspect, this catches us totally by surprise. We haven't had G l U 2 time to track down exactly what our responses were to these 3 interrogatories.
4 I would note for the record that the interrogatories e 5 request documents. There's no mention in here of tapes in the 2
9
@ 6 interrogatories. In fact, I don't know whether such tapes exist, R
$ 7 and if they do --
M j 8 JUDGE MILLER: Well, let's not get into the merits d
ci 9 of it.
$ 10 MR. REYNOLDS: -- and if they do, I don't think E
$ 11 they're within the scope of this interrogatory.
is f 12 JUDGE MILLER: Well, if you don't have the documents Oji3 hefore you, we don't wene 1e off the tog of your heed, so we
! 14 think you should take the time to find the interrogatories g 15 addressed to your client, and whatever responses were given.
y 16 Now, if you're going to need five minutes to do that, as 6 17 we'll take a short recess, which will also give an opportunity to
{ 18 the Applicants perhaps to get their documents together.
E g 19 MR. JORDAN: Your Honor, farnkly, I know you want to n
20 go ahead. I don't think we need to take a recess now. I think i
21 we can probably resolve it with the Applicant.
O 22 We didn.t know about this thing either une11 1 ate 23 l Friday afternoon.
I l
] 24 JUDGE MILLER: What is "this thing" that you're 25 l talking about?
l ALDERSON REPORTING COMPANY,INC.
l i[ 7nz 1-16 1 MR. JORDAN: I'm sorry; this tape, pardon me.
k k 2 JUDGE MILLER: Oh, a tape. All right.
3 Well, that might be something that you can talk about.
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(J 4 I do want to proceed, but on the other hand I don't want to leave e 5 anything dangling around or any inferences of one kind or another.
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$ 6 This is a trial. We intend to proceed right down the middle and l
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d 7 take it on an evidentiary basis. I will hear from counsel in s
j 8 this respect. Now, if you need time, and I'm talking about a a
d 9 short time, we'll give it to you. If you're able to proceed i
o
$ 10 without it, fine.
E 3
11 MR. REYNOLDS: Perhaps we could check into this at y 12 the break and take it up after the break.
( )) 13 l JUDGE MILLER: All right, but the break is going to 1 m
$ 14 be the break between the pre-hearing conference and the g 15 evidentiary trial.
=
y 16 MR. REYNOLDS: Then would you give us a five-minute i d N 17 break now?
l l N
$ 18 JUDGE MILLER: You've got it.
E g 19 (A short recess was taken.)
n 20 ///
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l ALDERSON REPORTING COMPANY. INC.
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1 JUDGE MILLER: As we hav. indicated to you, the O 2 Board will make a record on the information supplied by the 3 parties or by some of the parties, at least, on Board's questions O 4 1 and 3. We will do that in the evidentiary hearing.
5 It's probable, by the way, the responses will be g
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@ 6 numbered as to Board question 1. The information supplied will R
b 7 be identified for the record by the technical members of the Board Z
j 8 and will become Board Exhibit 1.
O ci 9 (The document referred to was 10 marked Board Exhibit No. 1 for h
=
II
$ identification.)
is JUDGE MILLER: The same with Question 3, Board O g i3 Exhibit 3.
E 14 w (The document referred to was i $
2 15 w marked Board Exhibit No. 3 for e
.* 16 g identification .)
b' 17 w JUDGE MILLER: Now, with BIT, since we've asked the e
M 18
= parties to proceed on that, we will await their pleasure on j 19 whatever number you want to make that. That will be dealt with 20 a little bit differently.
21 As far as the request of CASE's counsel for some time O 22 on cross _ examination, we re inc11ned to give you some time but 23 ' we hope that it won't have to be a great deal because this matter O 24 w,, ,pp,remt1y withi, the xmew1,dse of yo ,o11ent ,somt two 25 l weeks ago, so we'll ask that you move expeditiously and it may be ALDERSON REPORTING COMPANY,INC.
- 4 2-2 704 y hop ,
(~h I that you won't need as much time as you expected. Any way, we'll .l'
2 be going ahead in the evidentiary hearing with these other 3 matters which, itself, will give you some time.
O 4 And then anything further, you may advise the Board
- 5 and give your reasons.
3 6 MR. JORDAN: Let me just say, Your Honor, I fully R
b 7 intend to take that approach, not only on that issue but on all N
j 8 of them.
d c 9 JUDGE: MILLER: Fine. We appreciate that.
10 MR. REYNOLDS: Mr. Chairman, for the record, I think h
=
$ II we should state that the Intervenor had access to documents which f I2 discussed the shrinkage crack on April 22nd of this year, so 13 they've had better than six weeks, not two weeks.
E 14 i w JUDGE MILLER: All right.
9 15 E Well, we don' t want to get into . matters, now, z
~
16 3- because these matters do come up at other times when everyone is b' 17 w under pressure preparing for trial. We understand that.
x M 18
= We just want everybody to be reasonable and assist s
! 19 j the Board objectively to proceed in fairness to all and yet to 20 proceed expeditiously.
21 And you all have been cooperative in that regard,
() 22 which we appreciate.
23 , There being nothing further then --
1
() 24 MR. REYNOLDS: Mr. Chairman, may I respond to the 25 ' question about the tape?
l ALDERSON REPORTING COMPANY. INC.
2-3 p nop 1 JUDGE MILLER: Oh. yes.
O 2 MR. REYNOLDS: My --
3 JUDGE MILLER: Have you conferred with Counsel for O 4 CASE about that?
5 MR. REYNOLDS: Yes.
g ei j6 JUDGE MILLER: Fine.
R
$ 7 MR. REYNOLDS: My review of the record indicates that, N
j 8 again, this is an attempt by CASE to mislead the Board and the d
d 9 press --
l= 10 JUDGE MILLER: Please, please, please.
II Every trial has to proceed in a calm objective
's f II fashion. That is the duty of the Board.
O8g I3 We recognize the parties and Counsel have their own l$ 14 point of view, which we respect but nonetheless, we don't accept 15 it as being binding upon the Board.
16 ifus We would like for you and I'm saying it now because I7 you haven't been guilty of gross misconduct, but nonetheless, h
z I0 the first time that anything in the way of argumentative ad-E II hominem -- what so and so should have done, we would like to g
20 delete that so far as possible and if it isn't possible, then it's 21 going to have to be the subject of something very specific that <
O 22 the Boara rules on in aavance and I say this not because I want to 23 bear down on you, sir, but I want it to be true of all counsel C 24 and all parties.
25 MR. REYNOLDS: We understand.
ALDERSON REPORTING COMPANY,INC.
2-4 l~ 70g ihop 1 JUDGE MILLER: Proceed.
O 2 MR. REYNOLD3: The record reflects that in CASE's eighths @
3 of interrogatories, they defined the term " documents" as, I O 4 quote:
e 5 "Any writings, drawings, graphs, 6
$ 6 charts, photographs, repcrts, G
$ 7 studies and other data compilations s
j 8 from which data can be obtained."
d c; 9 CASE Interrogatories 1 (c)and (d) in EASE's eighth set z
h 10 request that Applicant supply for inspection and copying all s
j 11 documents in the possession of the Applicant and Brown and Root is g 12 relatincy' to- the ASME survsy.
13 No mention of tapes, cither in the definition or
, ! I4 .8 in the interrogatory.
15 The record reflects that in Applicant's response to 16 ife OASE's eighth set of interrogatories, dated March 16th, 1982, I7 Applicant's indicated that they would respond to the request for l h x
{ 18 production of documents prior to the March 29th, 1932 cutoff for e I9 g production.
n 20 The documents were produced in timely fashion --
2I JUDGE MILLER: When?
22 MR. REYNOLDS: On March 29th.
23 JUDGE MILLER: Thank you.
24 MR. REYNOLDS: The documents produced included written 25 l notes of the ASME exit meeting.
i ALDERSON REPORTING COMPANY, INC.;
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2-5 f ~ 707/ .
i hop 1 JUDGE MILLER: Very well.
O 2 Anything further to supplement the record at this l 3 time?
O 4 MR. JORDAN: Yes, Your Honor. if I may respond 1
5 on that point I must say I think it has been amply
$ 6 demonstrated that we are entitled to the tape, either under the R
b 7 exhibit or data compilation --
M j 8 You can forget about that definition and go the d
' bottom of the notes to the' interrogatory that says, "-- in o
10 short, we want all the information and documents you have or know
-h 2 II l of regarding this particular matter."
o 12 z Whatever your definition of documents is --
Ol a is MR. REY,OtDs, May I respond?
l$ 14 JUDGE MILLER: Yes, please.
15 MR. REYNOLDS: Such a broad request as "all information 16 and documents that you know about", is certainly too vague to a[
us II meet the standards of specificity required by Commission h
at M 18 Regulations for discovery requests, h
- 19 JUDGE MILLER: First of all, does such a tape exist? '
N 20 MR. REYNOLDS: My understanding is that a tape was 21 made of -- not of the exit interview but of the discussions O 22 detween ene arown and noot geoste, the rucco geoe1e nd the asas 23 ; people.
O 24 Jun s arttma: when s te m de na wa t w the 25 subject? I'll not ask you to get into matters at the moment I ALDERSON REPORTING COMPANY, INC.
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'hcp 1 until we rule but identify it enough so +.nat the Board has some O 2 indication.
3 MR. REYNOLDS: Mr. Chairman, the tape apparently was 4 made on October 14 and 15, 1981. We are checking as to whether I e 5 the tape still exists.
l h 6 JUDGE MILLER:Well, let me state this. That the Board l
57
$ 7 will, upon the basis of the showing made so far, grant the s
j 8 motion for the production of the tape or the tapes, so we don't i d ci 9 get into the question of authenticity of transcription.
$ 10 Now, if there be matters of whatever there may be, l
3 l h 11 it should be raised and considered by the Board, we will -- we 3
f 12 hope you will proceed with the utmost expedition, just as we've Oj i3 eexed cxSE to groceed in the same feshion.
! 14 We would like to get the tape matter resolved as E
9
. 15 soon as we can.
t ::
I j 16 Our inclination, I will say, is to order its us ti 17 production.
$ 18 MR. REYNOLDS: Mr. Chairman, we don't object to that 5
19 ruling at all. Had tney asked for the tapes in the beginning, we h
n 20 would have provided them.
2I We just want the record to reflect that there was O 22 no b,,,ch of the duty sy the Rpp11 cants here.
23 JUDGE MILLER: All right. I don't know --
24 Well, there's nothing for us to rule on in that i
25 ' regard. I think that the Intervenor's want the tape and that is l
I l ALDERSON REPORTING COMPANY, INC.
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2-7 1 the issue, as I understand them.
O 2 MR. JORDAN: That's right.
' hop 3 JUDGE MILLER: Very well.
4 There is no inference either way. If you will 5 produce the tapes as soon cs you can and please confer with g
a j 6 Counsel for CASE and Staff, so you can proceed harmoniously and n'
$. 7 expeditiously.
s j 8 MR. REYNOLDS: I'm now told that the tape was made d
d 9 of conversations on the 12th and 13th of October, 1981.
2 e
$ 10 JUDGE MILLER: All right.
E j 11 I think that's all we need to make the record now, 3
g 12 in this pre-hearing conference on that subject.
13 Is there anything further that any of the Counsal
! 14 or parties have?
15 MR. JORDAN: I have a couple more.
j 16- I'd like to direct your attention first -- this is as 17 simply a notice that this will happen at a later time -- we intend h
c::
{ 18 or we hope to have -- to make a motion to compel on raatters E I9 g arising under the CASE Interrogatories Set 11 to the Applicants.
n 20 There is no need to discuss it now. We hope to do that later and 2I you can rule at that time.
O 22 ,coc,szsssa, ,s,,,, 11, 1,,,,,,g,,,,y ,,. 11, 23 l Do you have the date?
O 24 ,,. ,c,,,,, 1,,,,,,,,,,,,se, ,,. 11.
25 l JUDGE MILLER: Do you have the date? If you do, ALDERSON REPORTING COMPANY, INC.
2-8 V ~ ' Q {}
bop 1 supply it to Counsel O 2 MR. JORDAN:
3 JUDGE MILLER: Was that also to the Applicant?
O 4 MR. JORDAN: And also to the Applicant.
e 5 JUDGE MILLER: All right.
b 3 6 Now, you know, we have asked and set up rules, as a R
$, 7 matter of fact, in this case, asking Counsel and parties to confer 3
8 8 before the matter is brought to the Board's attention. I think d
c; 9 those rules should still apply because you may well be able, by 10 g negotiation, to work these things out.
=
l1 MR. JORDAN: I believe there was an extensive is 12 conference of some hours on theTsubject.
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- i3 JUDGE MIttER: A11 righe.
l$ 14 MR. JORDAN: The inter'rogatories are dated May 7th.
15 JUDGE MILLER: The baces for your motion to compel j
. 16 are known to the Applicant? Are they?
w d 17 MR. JORDAN: I believe so.
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18 JUDGE MILLER: Well, if not, confer -- I see Counsel e 19 nodding in the negative, so confer at the earliest opportunity so M
l 20 you can get together and give them the information so it can 21 be at least negotiated.
O 22 MR. JORDAN: Now, I mentioned when we put together 23 the requests in the subpoenas -- we've also notified the l
(] 24 Applicants this morning and notified now the' Staff - - L 25 &nd the Board that up to now we've not had any witnesses.
! ALDERSON REPORTING COMPANY. INC.
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2-9 I I We do expect now to have a witness -- his name is
.ho 2 Charles Atchison.
3 JUDGE MILLER: Charles Atchison?
4 MR. JORDAN: Yes.
g 5 JUDGE MILLER: How do you spell that, please?
O 3 6 MR. JORDAN: A-t-c-h-i-s-o-n.
G E 7 JUDGE MILLER: And who is he?
A j 8 MR. JORDAN: He.is a former quality' assurance d
9
- f. engineering specialist at the project.
0 10 h We learned on Friday that -- and we didn't get an
" opportunity to talk to -anyone fiintil"today.
JUDGE MILLER: Is that Mr. Charles, C-h-a-r-1-e-s, O:g i3 Atchison, 744. Timber Oaks, Azle, Texas?
E 14 g MR. JORDAN: Right.
m 2 15 w JUDGE MILLER: He wrote to the Board, you know, on x
? 16 g May 28th.
d 17 MR. JORDAN: Yes, we were aware of that.
5
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18 JUDGE MILLER: That was May 28th. You got a copy of 19 it, didn't you?
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20 It was served?
21 MR. JORDAN: No.
O 22 JUDGE MILLER; Yes. It was served on the parties.
- 23 MR. JORDAN
- I don't have a copy, Your Honor. All O 24 I can sey is, I esk your indu1gence. we have ten thousend 25 i documents.
I f
! ALDERSON REPORTING COMPANY,INC.
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2-10 [^ 7Jj hop 1 JUDGE MILLER: So does the Board.
O 2 Go ahead.
3 What's new? We all do the best we can.
4 (Laughter) 5 MR. JORDAN: I have two other questions.
g ei 3 0 JUDGE MILLER: Go right ahead.
57 b 7 MR. JORDAN: First, we are going to have the boron s
j 8 That, I think, is clear. It ought to be easy to handle question. .
c.5 C 9 JUDGE MILLER: Yes.
b
_ l3 10 MR. JORDAN: Secondly, with respect tc, this crack n
11 matter, we want to get to the 2first: witness --
it f 12 JUDGE MILLER: Well, we'd like to -- after those Ol13 matters, then we'd like to have you working on it so that you h I4 would be able to, without being prejudiced in any way, g 15 participate.
m g 16 MR. JORDAN: We want to get to that and have it A
![ 17 wrapped up which would mean having Applicants' witnesses deal 5
5 18 with that subject and establish dealing with that subject.
E 19 JUDGE MILLER: That's what I thought, if feasible.
g n
20 We're hopeful it cen be handled in that clear-cut. fashion with 21 you -- with the opportunity both to cross-examine, to produce O 22 witnesse, if you wish -- 1 meen, we ere meesonas1y 1ibere1 in 23 permitting all sides to be heard in an evidentiary hearing.
Q 24 MR. JORDAN: Well, we think that's how we would 25 like to proceed.
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1 JUDGE MILLER: That's what we've planned, if we can.
ho 2 MR. JORDAN: On the question of whether we'll be 3 having opening statements --
O 4 JUDGE MILLER: That's optional. We don't really care e 5 one way or the other. It's up to the parties and Counsel.
h
@ 6 Whatever they deem to be most helpful -- we believe R
b 7 that they are capable and we know you are all experienced Counsel A
0 k trying your own case, so, to that extent, we try not to peer over d
d 9 your shoulder.
$ 10 You'll advise us, of course, in a timely fashion,
' 25 II what your choice is.
is g 12 MR. JORDAN: We expect to have opening statements.
Ol i3 JUDGE M1 ster 1f you do, 1 expece everyone e1se wi11 l$ 14 want to.
15 Ncw, is there anything further at the final pre-
==
16 resumed evidentiary J
hearing conference on this phase of the as 17 hearing, which we are about to move into?
h 18 MR. REYNOLDS: The reamining item that I see, Mr .
E 19 Chairman, is the scope of Contention 5, which was raised by us g
n 20 in our brief, which we filed recently.
2I We just understood what CASE's theory is as to the 22 scope of Contention 5, when it finally filed something last 23 Thursday, when we were able to glean from the myriad of ducments Q 24 that were filed, what it was they intenced to raise in this 25 [ hearing, it became clear to us, that as a preliminary matter, we should seek Board guidance and a ruling on the proper scope of
! ALDERSON REPORTING COMPANY. INC.
- 2-12 Contention 5.
I ~ 714 1 JUDGE MILLER: All right.
O
! hop 2 We have read yopr statement.
l 3 Let me just say, tersely perhaps, we are inclined, l O 4 you want to regard you as having posed the question of the broad
{
5 scope versus the narrow or specific scope,the Board would rule g
e' l 3 6 in favor of the broad scope.
l R b 7
( Now, we could spell it out and we could hear 1 3 g 8 arguraents but I think that the Board ruling is going to be that d
9 these matters are of significance. That whatever there may have 10 been in the way of phraseology or terminology in 1979 and '80,
=
II and we understand your position -- I'n not being critical of you 3
I2 f for raising it -- you are entitled to, but we think however, that 13 in pursuit of our responsibilities as Administrative Judges,
, as l$ 14 looking to the public interest, we think that we should permit 15 a reasonably broad, in that sense, scope.
h n:
y 16 Now, we can spell it out if you want to take the time as 6 17 but I believe Counsel and parties understand what we saying.
18 MR. REYNOLDS: I understand, Mr. Chairman. I don't
{
e 19 g think there's any need to spell it out.
n 20 I assume that that does not preclude objections to 21 lines of testimony on the basis of relevancy or other grounds?
O 22 ,oDcs MILLsR, , hat is correct.
23 l You may all make your re cord. We expect you to. As 24 you know, our decision, whatever it may ultimately be, is subject 25 ' to review by the Appeal Board and then it's optioned by the ALDERSON REPORTING COMPANY, INC.
2-13 ~
715~
hop 1 High Commissionero, themselves, so we have no objections.
O 2 We are not sensitive or thin-skinned about you making 3 your record, making objections. Feel free to do so.
O 4 Let me say also that in hearings of this kind, that s 5 while -- if you regard it as a trial, you're ninety-five percent 8
3 6 right.
- e. 7 Now, there are certain technicalities that don't apply 8 to Administrative Proceedings. We have somewhat more discretion d
d 9 or certain technical rules I won't go into, but the Board wishes Y
g 10 to have these matters fairly and fully presented so there is an 25 j
is 11 adequate record with all points of view, insofar as it's within y 12 the range and scope of the issues and we want to have a complete Oli3 record in feirnese to e11 gereies.
l$ 14 That will be the basis.
2 15 Now, one more thing. It's not like a town meeting, 5
g 16 as you know. People don't make speeches. This is proceeding us d 17 according to rules of evidence and when we ask to hear from E
{ 18 Counsel we like to have it brief because usually we've read the i: 19 Don't wear your heart g documents and the issue is fairly narrow. i n l 20 on your sleeve in this sense. )
21 If we interrupt you, it's not discourtesy. It's O 22 simp 1y en effore to get to the fina1 nub of ehe matter that.s 23 going to be decisive in what the Board rules and we would rather i
Q 24 get to it sooner rather than later.
25 So, we all have a tendency, lawyers, Judges, everybody ,
ALDERSON REPORTING COMPANY, INC.
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l2-1f 1 to wind rp. Pretend the bases are loaded. You can't afford a "ho 2 windup. Just shoot right out and we'll get a rulinc) and indicate 3 the basis for it and, as I say, don't feel we're imposing on you 4 because we reserve the right to do it to everybody and we'll try
- 5 to do it fairly and objectively.
9
@ 6 MR. REYNOLOS: Just so it's' spread around, Mr.
R
& 7 Chairman.
A j 8 JUDGE MILLER: We'll spread it around.
d c; 9 (Laughter.)
g 10 JUDGE MILLER: Anything further?
E
$ II MR. REYNOLDS: Mr. Chairman, your order earlier is f 12 indicated that limited appearances would take place on Tuesday.
13 Is that still --
=
I4 JUDGE MILLER: You tugged my sleeve on that.
~
Yes. We did. We notified the parties that we will 16 hear limited appearances as we can reasonably, without interfering h'
=
with the evidentiary hearing or trial.
$ 18 We also indicated that at 9:00 o' clock tomorrow, 19 j Tuesday, chat we would hear some limited appearances and we asked 20 to be notified of those who wished to and that's how we came in 2I contact with your prospective witness, Counsel, Mr. Charles O 22 stoh1som, heo,mse he did write to us and reguest an opportunity 23 ; to make a limited appearance statement.
24 Now, we haven't received anyone el e.
i 25 We have fulfilled the request previously brought to ALDERSON REPORTING COMPANY, INC.
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71 7 1 our attention and some that came up at the hearing itself, at 2O' 2 the prior evidentiary hearing which we held in -- I think it was hop 3 December, 1981 on earlier matters.
O 4 At any rate, we did hear a number of limited 5 appearance statements then.
y n
@ 6 Now, in response to your question, yes, at 9:00 R
b 7 tomorrow we will hear some. We have to ask they be kept to five j 8 minutes, although we will receive practically any length.
d d 9 We will receive written limited appearance statements N
g 10 at any time and they will be read and they will be made part of E
j 11 our evidentiary record but those persons who do wish to make is g 12 statements may request the opportunity. We would hope that you Ol i3 wou1d confer with Ms. Minton, our 1ege1 eseistene seatea here,
!' 14 so that she will have a list of those who have requested it.
t 15 The name and address is all that we need.
j 16 And after a reasonable time tomorrow morning at 9:00, as ti 17 say a half-hour or so, then future scheduling will be done as s
5 18 the result of a request to Ms. Minton.
=
U g 19 Does that answer your question, Counsel?
n 20 MR. REYNOLDS: Yes, it does.
21 Thank you.
O 22 ,UDGs M1LLER, Any other questions, 23 (No response.)
Q 24 JUDGE MILLER: Going, going --
25 j All right. We will now conclude the final pre-hearing u ALDERSON REPORTING COMPANY, INC.
71 8 2-16 hop I conference.
O 2 We wi mow move into the evidentiary hearing.
3 (Slight pause.)
O 4 JUDGE MILLER: All right.
g 5 The evidentiary hearing in this cause, in the matter 9
3 6 of the Application of Texas Utilities Generating Company, et al, R
$ 7 Comanche Peak Steam Electric Station, Units 1 and 2, being an A
j 8 application for operating license in Docket Nos. 50-445 OL, and d
d 9 50-446 OL, will come to order.
z, c
10 First we will ask Counsel and parties in the h
=
$ Il evidentiary hearing to; identify-themselves. Name, address and 3
g 12 status of associate, please.
13 Starting with Staff.
E 14 w MS..ROTHSCHILD: Mr. Chairman, my name is Marjorie 9 15 I am with U.S.
Q Rothschild. I am Counsel for the NRC Staff.
m Nuclear Regulatory Commission, Office of Executive Legal Director, d 17 x Washington, D.C. 20555.
z M 18
= To my immediate right is Mr. Geary Mizuno, Co-Counsel 19 l with me. His address is the same as mine.
20 To Mr. Mizuno's immediate right is Mr. Spottswood 21 Burwell, who is the NRC Staff Project Manager for the Comanche O 22 Peak and he's with the U.S. Nuclear Regulatory Commission, 23 Office of Nuclear Reactor Regulations, in Washington, D.C. 20555.
() 24 JUDGE MILLER: Thank you.
, 25 l MR. REYNOLDS: Mr. Chairman, my name is Nicholas S.
! ALDERSON REPORTING COMPANY, INC.
~ 71 3
- 2-17 1 , S. Reynolds. I am appearing this morning on behalf of Applicants.
hL 2 I'm with the Washington, D.C. law firm of Debevoise & Liberman, 3 1200 Seventeenth Street, N.W., Washington, D.C. 20036.
4 To my immediate left is my associate William A.
5 Horin and to my far left is Spencer C. Relyea. He is an Attorney g
n
@ 6 with the Dallas law firm of Worsham, Forsythe and Sampels ,
R S., 7 2001 Bryan Tower, Dallas, Texas 75201.
A 8 MR. JORDAN: Mr. Chairman, my'name is William S.
~
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d 9 Jordan, appearing on behalf of Citizens Association For Sound z.
O 10 Energy, CASE, from the Washington, D.C. law firm of Harmon and h
=
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$ Weiss. The address is 1725 I Street, N.W., Washington, D.C.
is j 12 20006.
13 To my immediate left is Lanny Allen Sinkin, Third a
l t
l$ 14 Year Law Student, experienced in these-NRC proceedingsw His address 15 if 838 East Magnolia Avenue, San Antonio, Tex ~as.
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=
g 16 To my fair left, Ms. Juanita Ellis, who is the l . uS I7 President of CASE and her address is 1426 South Polk Street, x
E g 19 JUDGE MILLER: Thank you.
! E 20 Mr. Sinkin, do I understand you are a law student and 21 experienced in NRC proceedings?
O 22 MR. SINxIN: Mr. cheirmen, I em entering the third 23 year of law school in September and I have been representing Q 24 Intervenors in the South Texas proceedings for four years.
25 I JUDGE MILLER: Fine.
ALDERSON REPORTING COMPANY. INC.
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~ hop 1 This is purely a. footnote.
O 2 Have you assisted Mrs. Ellis in the preparation of 3 some of these motions and papers that have been filed?
4 MR. SINKIN: Yes, I have.
5 JUDGE MILLER: Thank you.
g 9
@ 6' We will now proceed.
R E 7 I think there was a request for opening statements.
A y 8 If that be true, we will accord the rights of an d
9 opening statement in the order in which we will be hearing o
10 h generally. We may vary this with witnesses but the Applicants
=
I normally -- this is plural -- Applicants -- now, isn't it?
f I2 MR. REYNOLDS: It is.
13 JUDGE MILLER: All right.
m I4 The Applicants, having the overall burden of proof, g 15 have the right to go first'.
x i:[
I6 MR. REYNOLDS: Mr. Chairman, the Applicantes will as I7 demonstrate in this proceeding that they have designed and h
e IO constructed Comanche Peak in accordance with applicable NRC b
i:
19 ll Regulations.
g" 20 They will demonstrate that they have structured and 21 implemented a quality assurance program that fully complies with O 22 a11 aspects of 10 cER, aggendix e.
23 They will demonstrate that the quality assurance /
24 quality control implementation at Comanche Peak has been responsive 25 to the needs of the project, has been in compliance with ALDERSON REPORTING COMPANY,INC.
~
721 2-19 1 pertinent regalations and has rendered the plant in such a state A l hor 1 that a high level of assurance is given that it is constructed in 2
3 a satisfactory manner and in compliance with all regulations.
G U 4 We will~also demonstrate that Brown and Root is fully n 5 qualified in its quality assurance program to handle N
j 6 construction activities performed under the ASME code.
$ 7 We will demonstrate that TUGCO quality assurance A
j 8 organization has adequately and satisfactorily audited and d
@ 9 surveilled the quality assurance performance at Comanche Peak,as E -
g 10 well as the quality assurance performance of vendors and 5
11 contractors.
3 y 12 We submit that when this hearing is completed, the 0- 3j 13 record will clearly show that the quality assurance / quality l$ 14 control implemented at Comanche Peak has been an excellent 2 15 quality assurance program and that the plant has been constructed j 16 in accordance with appropriate regulations.
A 6 17 We feel that at the end of this hearing, the Board E
$ 18 will have substantial evidence upon which it can base a finding E
b g 19 that the plant was designed and constructed in accordance with n
20 the application and the Commission's rules of practice, the 21 design and the Atomic Energy Act, all in accordance with 10 CFR l
)
O 22 so.s2 A.
23! In addition, we will present evidence which will Q 24 demonstrate that the allegations made with regard to 25 l construction practices are unfounded. Specifically with regard i
l
! ALDERSON REPORTING COMPANY. INC. l
1 2329x
~
gg l
2-20 1 to the matters of the shrinkage crack at Comanche Peak and the hE].. 2 breakage of rock in the excavations for Comanche Peak.
3 We will demonstrate through the testimony of expert O 4 witnesses that these matters raise no safety issue whatsoever with 5 regard to the construction and operation of Comanche Peak and we
@ 6 believe that the Board will have in the record substantial R
b 7 evidence to so find at the conclusion of the hearing.
A j 8 That concludes our opening statement.
d c; 9 ///
$ 10 6
5 11 g 12 O! m i3 l
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16
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M 18 iE 19 X
20 21 -
Q 22 23 i O 24 25 I ALDERSON REPORTING COMPANY,INC.
723 3-1 1 MS. ROTHSCHILD: The Staff, through the presentation 2 of certain Staff witnesses, will demonstrate that its inspection 3 and investigation findings at Comanche Peak to date do not
( 4 substantiate the allegation in Contention 5 that there are
<. 5 substantial questions as to the adequacy of construction of the 3
n j 6 facility.
7 Specifically, we will demonstrate that our inspections s
8 8 and investigations, as well as assessments of the Applicants' n
d d 9 performance on an annual basis, have determined that the z
h 10 Applicants have adequately developed and implemented a Quality 3
l 3
11 Issurance/ Quality Control program meeting NRC requirements.
y 12 We will also demonstrate that the inspection and
() 13 investigation findings that were indicative of actual defects in l$ 14 construction were resolved by correction of the defective 2 15 construction as necessary, along with correction of any under-j 16 lying QA/QC program deficiency.
w d 17 We will further show that all but two of the matters
$ 18 raised in the inspection reports cited in support of Contention 5
=
- 19 as negative findings have been resolved, and that resolution g
n 20 verified by the NRC Staff.
21 The two unresolved matters we will demonstrate are 22 being appropriately handled and will be appropriately resolved.
(])
23 We will further show that any negative findings in 1
24 the Staff's inspection reports that were essentially programmatic
()))
25l in nature, in other words, those that did not indicate any actual i
l
! ALDERSON REPORTING COMPANY, INC.
l 72[
I 3-2 1! construction deficiency, occurred in early in each given phase 2 of construction and were corrected in a timely manner, such 3 that there's little likelihood that any significantly defective 4 construction has not been detected.
m 5 The Staff will also demonstrate that although b -
j 6 construction of Unit 1 of Comanche Peak is essentially complete, R
& 7 additional final construction testing remains to be done, along 7.
j 8 with system tests are prerequisites to the issuance of operating d
c 9 licenses.
g 10 The Staff will show that these tests are designed to E
$ 13 reveal any deficiencies in either the design or construction of is j 12 the facility that could adversely affect the safe operation of Ol13 the feci11tv et e future time.
! 14 We will emphasize that additional inspections of 15 Units 1 and 2, including monitoring of testing by the Applicants,
{e j 16 will be conducted by the Staff to insure that safety related w
d 17 construction matters identified will be adequately resolved s
y 18 prior to recommending authorization for the loading of fuel and i:
19
{n the operation of Comanche Peak.
20 JUDGE MILLER: Does that conclude the Staff's 2I statement?
22 MS. ROTHSCHILD: Yes.
I 23 ! JUDGE MILLER: Thank you. ,
! l O 24 Intervenor, cxSE.
25 l MR. JORDAN: Thank you, Mr. Chairman.
I I ALDERSON REPORTING COMPANY, INC.
I
f I' ~
72Qj 3-3 1 I'll touch on a few matters. First, we are compelled
() 2 to add'ress the status of our procedure to date. CASE has, going 3 into this hearing, been attempting to develop the evidence and
() 4 prepare adequately for this proceeding.
e 5 We're fully aware that for several years there were b
@ 6 more than one intervenor in this case. CASE was not the lead
. R R 7 intervenor on this particular contention for most of that time s
j 8 until early this year, and the others dropped along the way, d
c 9 exhausted, one might say, by their administrative remedies.
$ 10 JUDGE MILLER: Now, remember the admonition.
E g 11 MR. JORDAN: Well, sir, I --
B j 12 JUDGE MILLER: Ad hominem arguments really don't help 3
13
(]) anybody, and we'd rather none of you did it, becuase once you l$ 14 start it, it's unending. So we understand your position.
2 15 MR. JORDAN: I'll leave out the rhetoric.
g 16 JUDGE MILLER: Okay.
M d 17 MR. JORDAN: In the course of that time, CASE believes Y
{ 18 that it fulfilled its responsibilities in earnest. It filed E
g 19 eleven sets of interrogatories. Ultimately, in the last few n
20 months CASE finally received some 30,000 pages of documents on 21 ' discovery. Many, or most of these, some apparently extremely 22 important, only a week ago last Friday.
23 At the same time we received a massive summary 24 disposition, motion by the Applicant, which we considered to be 25 filed out of time. However, we responded to that motion and ALDERSON REPORTING COMPANY,INC.
3-4 1 that effectively elminated the last week of preparation for this O 2 hearing. In our view, it has been essentially impossible to 3 prepare. We have not even yet been able to copy the proposed 4 exhibits, although they are doing that constantly and have been e 5 since we filed a response to the summary disposition motion.
A n
3 6 We do consider it an unfair burden at this point.
R
$ 7 We believe that this is clearly shown by the facts, and we do s
j 8 expect to appeal on that basis unless the problem is sufficiently d
c; 9 mitigated during the hearing, and we do expect to go ahead and z
o
@ 10 make every effort to proceed efficiently and effectively and to E
j 11 eliminate what we feel is past wrongs, and we hope we can do that, S
j 12 With respect to what we~ intend tc show, we believe ,
gs 5
(_) y 13 we'll be fair.
m
! 14 ,
Let me go back to what CASE's feelings originally were g 15 about this plant. Originally, CASE never though it was needed, x
j 16 and that's not what we're talking about now.
W N 17 Given that if someone else desired it, even.if CASE 5
$ 18 did not, perhai3 that could be acceptable, as long as someone P
{
n 19 made sure that it was built correctly. CASE felt it could take 20 a position of that sort.
21 As of this time, having seen the development, CASE
() 22 believes it is impossible to render this plant safe. Certainly, 23 l at the bare minimum, there must be a thorough re-QA,_re-24
(]} examination of all aspects of that plant by an independent outfit, 25 not the NRC Staff, which has failed all along to find these l
ALDERSON REPORTING COMPANY, INC.
M 3-5 1 things, and not the company itself, we would perhaps like to see 2 that so that the plant will be safe. I believe -- think it is 3 absolutely essential that that kind of effort be undertaken.
4 We expect to show, in the course of this hearing, and e 5 almost entirely through the Applicants' own documents, a h
@ 6 consistent and unending failure of Quality Control / Quality R
8 7 Assurance at that plant for a nonexistent Quality Assurance s
j 8 procedure, for a nonexistent documentation and records, recurring d
q 9 failures of the same type throughout the life of that plant, an y 10 inability to prevent major deficiencies, pressures on Quality E
$ 11 Control to get the job done guickly, major repairs and major 3
12 work with no Quality Assurance control and no verification of
-f gue11ey, fe11ere to te11 the nac of me3er deficiencies, inc1uding Ol i3 l$ 14 the rock overbreak in the course of blasting related to the Fuel 15 Handling Building; an enormous crack in the reactor base hatch g" 16 that as far as we can tell indeed goes directly underneath the e
d 17 reactor.
18 Those, of course, are merely examples.
3 E
l9 Finally, as we go into this hearing we have at long g
n 20 last someone who has come forward and wants to tell the truth 21 about this plant. He had apparently written to the Board. He O 22 has come to us. char 1es Aechison, a former Qua11ty Assurance 23 , engineering specialist at Comanche Peak.
Q 24 In essence,. it is our understanding that he was fired 25 from Comanche Peak because he did his job too well.
! ALDERSON REPORTING COMPANY, INC.
728
.3-6 1 For example, because he reported obvious defects O 2 that were next to, but just outside of, his inspection area, and 3 he was fired for misconduct as a result.
O 4 Now, we are informing the parties and the Board now, e 5 since this is our first opportunity to do so, we are not even h
j 6 certain at this date precisely what we will discuss. We, in R
{ 7 effect, need to debrief him and then allow those things that are s
j 8 essentially relevant to this case, but we certainly expect him d
C 9 as a witness. He will also be consulting with us during the
$ 10 course of the hearing.
E 3 II And the last point --
B y 12 JUDGE MILLER: Well, pardon me on that, you don't Ol13 mean -- you don't expect him to sit at counsel table or matters l$ 14 of that kind, do you?
l 15 MR. JORDAN: Well, we don't have room at the counsel-h=
16' table.
3[
( us I7 JUDGE MILLER: Well, regardless of room; you know the h
x IO rules, now, as to attorney. We recognize you've got consultants E
19 who are not attorneys, but we don't expect witnesses to put on g
n .
20 another hat; the usual I, 3.
21 MR. JORDAN: Well, he will be consulting with us O 22 3ust as a consu1tane can consu1t with the Apg11 cane, or the seaf, j for that matter, throughout my experience in the hearing. He 23 l l .
Q 24 would not -- unless there were a situation for an expert to 25 cross-examine a --
l ALDERSON REPORTING COMPANY. INC.
1
729 3-7 1 JUDGE MILLER: Well, I point out, too, we expect the O 2 same rules to apply to all equally. In other words, if you want 3 him as somebody sitting there and assisting you directly, then O 4 we wouldn't expect him to be a witness. We'd expect him to e 5 withdraw from one or the other status, but we'll leave it to your h
@ 6 judgment. You're a lawyer and you know what we're talking about.
R S 7 MR. JORDAN: Yes, sir, s
j 8 JUDGE MILLER: Okay, d
C 9 MR. JORDAN: Lastly, I urge, I strongly urge that i
C g 10 anyone else that knows the truth about that plant, the cracks **
i5 l
is 11 and the deficiencies in it, step forward-now;. now is..the. time to j 12 inform the public and this Board of what you know. If there is 3 13 any hope of assuring the safety of this plant, we, CASE will do l$ 14 everything we could to protect you, and I'm sure the Board and 15
{x the NRC will do everythf.ng they could to protect you, but it's j 16 extremely important that that happen now.
as 6 17 That concludes our opening statement.
s
{ 18 JUDGE MILLER: Very well.
E
, 19 We will now proceed with the making of our record on M
20 Board Question 1.
21 Dr. Cole will identify for you the Board question, O 22 the nature of ie, the documente which heve been f11ed gursuane 23 thereto and which will be identified as Board Exhibit 1 with i
O 24 various subgares es he w111 ee11 yeo.
25 Dr. Cole.
l ALDERSON REPORTING COMPANY, INC.
l i
730
- 3-8 1 JUDGE COLE: Board Question 1 was raised in the O 2 June 16th, 1980 Board Order, the Order subsequent to the pre-3 hearing conference of April 30th, 1980.
O 4 The question reads as follows:
- 5 " Describe in detail the planned methods O
@ 6 for handling any hydrogen gas in the CPSES R
$ 7 containment structure."
l 8 We did receive responses to that question. The d
[ 9 Applicants response is dated April 19th, 1982. It is a three-5 g 10 page summary by Mr. Reynolds, summarizing an affidavit dated 5
11 4-19-1982, which is a nine-page document with Attachments A is j 12 through F. The title of the affidavit is " Affidavit of Fred 5
pb 13 W. Madden, Jr. Regarding Board Question 1 Related to Hydrogen l$ 14 Generation."
15 The Nuclear Regulatory Commission also responded to gj 16 that Question No. 1 on May 7th, 1982. Their response is us 17 identified as NRC Staff Response to Applicant's Answer to h
e 5 18 Question No. 1, and summarized the Applicant's answer and gave I E 19 the Staff's comments on that. That is an eleven-page response, l g l
n 20 signed by Geary S. Mizuno, co-counsel for the NRC Staff, and 21 . attached to that are two affidavits, one the affidavit of David O 22 Shum, S h_u_m, eatea __ uneatee, and the effidevie of Roserr t.
23 i Palla, P-a-1-1-a.
Q 24 Each of those documents is pertinent to Question No. 1 ,
25 f Board Question No. 1. The Board has reviewed each of these I
i ALDERSON REPORTING COMPANY,INC.
?st
~ ~ ~
3-9 1 documents, the responses of the Staff and the Applicant, and in
() 2 our view there's sufficient information there to adequately 3 answer our questions on that.
O 4 JUDGE MILLER: Very well.
e 5 The documents thus described by Judge Cole will be N
3 6 marked, then, as Board Exhibits 1, with the appropriate A, B, C R
R 7 for the individual affidavits and other matters that he has s
j 8 described, and will become part of the evidentiary record.
d d 9 (Board's Exhibit No.1 was N
$ 10 received in evidence.)
E j 11 JUDGE MILLER: Board Question 2, as you will recall, k
j 12 was a subject of testimony at a prior hearing and has now been
( 13 removed from the case as a result of changes in the regulations m
h 14 by the Commission.
2 15 Board Question 3 will be identified -- oh, am I E
j 16 wrong on that? What is 2? I'm sorry; 2 was the subject of an w
d 17 evidentiary hearing and has not yet been passed upon by the Board 5
5 18 and refers to Quality Assurance / Quality Control operation, E
g 19 operating. Well, we've taken evidence, we haven't ruled; that is, n
20 we haven't rendered a decision yet. It is pending, along with
- 21 the product of this evidentiary hearing.
l l
() 22 Board Question -- while I'm at it, I might as well 23 straighten out the record, which I confused for you. The questior;
(]) 24 of financial qualification is a matter which was the subject of l 25 i some evidence but which in the meantime has been taken care of, i
ALDERSON REPORTING COMPANY, INC.
i 7.N
- 3-10 1 removed from this and other proceedings by the Commission's 2 actions, which are quite often the case.
3 Now, Board Question 3 will be identified for you, and (3
'# 4 the documents described by Dr. McCollom will be Board Exhibit 3.
m 5 Judge McCollom.
3 9
@ 6 JUDGE McCOLLOM: Board Question No. 3 is:
R
$ 7 " Describe the status of resolution of A
j 8 Safety Issue TAPA-9(ATWS) as it relates to CPSES 1 d
d 9 and 2."
i o
g 10 ATWS stands for anticipated transient without scram,
$ 11 and it is a concern that was brought up some 12 or 13 years ago k
j 12 for the first time that there might be situations existing, very
() 13 abnormal situations in certain lightwater reactors that could h 14 have a situation that would not call for scram when it should be 15
{= handled.
j 16 It has had considerable discussion since that time e
d 17 and there is a Nuclear Regulatory Commission document called Y
$ 18 NUREG 0460, which is entitled, " Anticipated Transients Without E
19 Scram for Lightwater Reactors," which addresses some of the g
n 20 concerns and proposes some methods of enhancing the safety of 21 reactors.
() 22 In response to our Board Question No. 3 the NRC 23 l Staff, in a response dated May 7th, 1982, entitled, "NRC Staff's 24
({} Answer to Board Question 3 Regarding the Status of Safety 25 Issue TAPA-9," was submitted with attachments, with affidavits ALDERSON REPORTING COMPANY, INC.
7.'43 3-11 1 ,
from David W. Pyatt, spelled P-y-a-t-t, James W. Clifford ant' O 2 Marvin W. Hodges.
3 There is one other aside that I might make with O 4 respect to this. In the Federal Register dated November the e 5 24th, 1981 there is a proposed rule which further addresses the
, A n
@ 6 risks and the reduction of risks from anticipated transients R
$ 7 without scram, s
l 8 It is true that the statement of the NRC Staff says d
C 9 that we've had approximately a thousand reactor years of E,
$ 10 operation without an anticipated transient without scram, giving E
j 11 you some idea of the risk involved. There has been no anticipated 3
j 12 transients without scram in the history of the nuclear power
() =
13 industry at this point.
l$ 14 JUDGE MILLER: Thank you.
15
{e The documents, then, will be admitted into and made a j 16 part of the evidentiary record, designated as Board Exhibit 3.
w N 17 (Board bhhibit No. 3 was
$ 18 " received in evidence.)
E 19 JUDGE MILLER: We'll ask the parties, Applicants, g
n 20 or Applicants and Staff, to provide a sufficient number of copies 21 of these to the reporter, in accordance with the usual rules,
() 22 please.
23 , MR. REYNOLDS: We'll do so.
() 24 JUDGE MILLER: All right. That will then conclude 25 l the designation of the Board's exhibits with reference to Board's ALDERSON REPORTING COMPANY,INC.
I 7.'44 3-12 1 Questions 1 and 3.
O 2 We will now proceed to the boron injection tank 3 question, BIT for short. In that matter, tn! ,oarties by counsel O 4 will proceed to present whatever evidence they wish on that
- 5 subject, please.
R
$ 6 MR. REYNOLDS: Mr. Chairman, Applicants call R
$ 7 Ms. Melita P. Osborne and Mr. Fred W. Madden.
A j 8 JUDGE MILLER: Will the witnesses come forward, d
@ 9 please.
$ 10 Whereupon, E
h 1I MELITA P. OSBORNE is 12 called as a witness by counsel for the Applicants, having first
- f Ojis been duly sworn by the Chairman, was examined and testified as l$ 14 follows:
[:::
15 Whereupon, g 16 FRED W. MADDEN A
b^ 17 called as a witness by counsel for the Applicants, having first.
5 5 18 been duly sworn by the Chairman, was examined and testified as E
g 19 follows:
K 20 DIRECT EXAMINATION 21 BY MR. REYNOLDS:
O 22 . Mrs. Osbomme, g1 ease stete your neme, tie 1o end 23 business address.
Q 24 BY WITNESS OSBORNE:
25 l A. My name is Melita Osborne. I am an engineer in the l
ALDERSON REPORTING COMPANY. INC.
i
l 735 l3-13 1 Nuclear Section of the Westinghouse Electric Corporation. My O 2 address is Westinghouse Electric Corporation, P. O. Box 355, 3 Pittsburgh, Pennsylvania 15230.
(Z) 4 G Have you prepared a statement of your educational c 5 and professional qualifications for use in this proceeding?
@ 6 BY WITNESS OSBORNE:
R i
& 7 A Yes, I have, s
j 8 G And do you have a copy of that document with you?
I d d 9 BY WITNESS OSBORNE:
l i i o
$ 10 A No.
E j 11 JUDGE MILLER: Well, we have. We'll show you who w
j 12 you are.
() m 13 (Laughter.)
h 14 BY MR. ?.EYNOLDS :
2 15 G Now do you have a copy of that statement?
E y 16 BY WITNESS OSBORNE:
M l d 17 A Yes, I do .
{ 18 G Are there any additions or corrections to that E
l g 19 statement you would care to make at this time?
n 20 BY WITNESS OSBORNE:
l 21 A No.
() 22 G Would you kindly summarize your educational back-23 ; ground for us?
() 24 BY WITNESS OSBORNE:
1 25 ' A I have a Bachelor of Science degree in chemistry r
! ; ALDERSON REPORTING COMPANY,INC.
1
o.'16 3-14 I from the College of William and Mary in Virginia, and a Master O 2 of Engineering and Nuclear Engineering from the University of 3 Virginia.
4 g It the document true and correct?
e 5 BY WITNESS OSBORNE:
E n ~
@ 6 A Yes.
R
$ 7 0 And do you adopt it as_part of your testimony in Z '
j 8 this proceeding?
d d 9 BY WITNESS OSBORNE:
i '
O
$ 10 A Ye s . '
3 h 11 MR. REYNOLDS: Mr. Chairman, we request that 3
p 12 Ms. Osborne's statement'of educational and professional
( 13 qualifications be received into evidence and incorporated into m
l$ 14 the transcript as if read.
g 15 JUDGE MILLER:What number do you wish to give it?
=
g 16 MR. REYNOLDS: We weren't going to designate it as an W
d 17 exhibit. We were going'to have it just incorporated into the E
{ 18 paginated transcript. We can designate it as an exhibit if you A
g 19 wish.
M 20 JUDGE MILLER: I wish you would. We can do it either 21 way, and I think just so there's no question as we go along it
() 22 might be -- it will be ' incorporated into the record and adopted 23 ! into the record. We will also give exhibit numbers, if you
() 24 please, as we go.
25 l MR. REYNOLDS: Can the reporter give us the next t
l ALDERSON REPORTING COMPANY. INC.
D.'Ij
- 3-15 1 number for Applicants' exhibits?
2 JUDGE MILLER: 13, I believe, was your last --
3 MR. REYNOLDS : This would be designated for O 4 identification as Applicants' Exhibit 13. -
g 5 JUDGE MILLER: Wait a minute. Wasn't 13 the last 9 ~
@ 6 one? I think it's 14. We'll verify it at recess or noon and
( "
$ 7 we'll correct the record, but my i'nformation was that the A -
[ 8 Applicants had 13 exhibits so far identified in the recofd.
d '
q 9 ( Applicants Exhibit tro'. 14 was
$ 10 marked for'ider. ification.)
$ II JUDGE MILLER: Then I take it that you are offering 3
N 12 the Applicants' Exhibit 14, which has' be'en ' identified and E
Oa5m 13 incorporated in the record?-
l$ 14 MR. REYNOLDS: Yes, we are.
g 15 JUDGE MILLER: Let me inquire, any voir dire
= ,,
y 16 examination requested? ' __
A I7 MR. JORDAN: No, Your Honor.
hx 5 18 JUDGE MILLER: Staff? i e l9 g MS. ROTHSCHILD': No, Vour' Honor.
n ~.
20 JUDGE MILLER: Ver'y welli ~ ,
2I It will be admitted into evidence and'will be _
() 22 incorporated into the record. ' '
23 (Applicant's' Exhibit No'. ,14' was 24
(]) , received in evidence.)
25 JUDGE MILLER: Proceed.
i .
ALDERSON REPORTING COMPANY. INC.
sh8
~
3-16 1 BY MR. REYNOLDS:
(7
\- g 2 Mr. Madden, would you please state your name, title 3 and business address?
4 BY WITNESS MADDEN:
e 5 A My name is Fred W. Madden, Jr. I'm Lead Nuclear N
8 m
6 Engineer for Texas Utilities Services, Inc., Comanche Peak Steam R
g 7 Electric Station, Post Office Box 1002, Glen Rose, Texas 76043.
l 3 j 8 G Have you prepared a statement of your educational 0
d 9 and professional qualifications for use in this proceeding?
i o
g 10 BY WITNESS MADDEN:
5
{ 11- A Yes, I have, k
12 g And do you have a copy of that document before you?
13 BY WITNESS MADDEN:
m v
j! 14 A Yes, I do.
~ c.
N ' 15 g Do you have any additions or corrections to the l
Y' -
- y 16 document?
e d 17 BY WITNESS MADDEN:
E 5 18 A No, sir.
=
b 19 Would you please summarize your educational back-
{
n G
20 ground?
I l
21' BY WITNESS MADDEN:
I l (]) 22 A I have a Bachelor of Science degree in Engineering 23[PhysicsfromTexasTechUniversity,aMasterofSciencein
(]) 24 Nublear Engineering from Purdue University.
25;[ g Is it true and correct?
i k
ALDERSON REPORTING COMPANY, INC. I
E 7.%
3-17 1 ! BY WITNESS MADDEN:
} Yes, it is.
2 A
! 3 0 And do you adopt it as part of your testimony in l
() 4 this proceeding?
e 5 BY WITNESS MADDEN:
l 3 l
@ 6 A Yes.
l l R l $ 7 MR. REYNOLDS: Mr. Chairman, we request that i
s j 8 Mr. Madden's statement of educational and professional d
& 9 qualifications be marked for identification as Applicants' I
$ 10 Exhibit 15.
E j 11 JUDGE MILLER: It will be so marked.
B j 12 (Applicants' Exhibit No. 15 was
()d
, a 13 marked for identification.)
i h 14 JUDGE MILLER: Is there any objection to the l C 2 15 admission in evidence of Applicants' Exhibit 157 g 16 MR. JORDAN: No, Your Honor.
W 6 17 JUDGE MILLER: Okay. That will be admitted into
$ 18 evidence and will be incorporated into the record.
e 19 g (Applicants' Exhibit No. 15 was n
20 received in evidence.)
21 BY MR. REYNOLDS:
() 22 4 Mr. Madden, are you familiar with the term " boron 23 , injection tank"?
1
() 24 BY WITNESS MADDEN:
25 A Yes, sir, I am.
t i ALDERSON REPORTING COMPANY. INC.
L
740 3-18 1 B In your own words, would you please describe what O 2 that means to you?
3 BY WITNESS MADDEN:
4 A The boron injection tank, or BIT, is a cocponent sub-e 5 system of the emergency core cooling system, or ECCS, at Comanche A
9
@ 6 Peak. Its purpose was to provide a reservoir of high concentratio n, R
R 7 1208 percent boric acid delivered in the event that the "I" head M
l 8 or centrifugal charging pumps deliver safety injection flow to d
c; 9 the reactor systems.
z o '
$ 10 G and did the present -- did the original design for 5
j 11 Comanche Peak contemplate the installation of a boron injection s
~
j 12 tank?
Oj i3 BY WITNESS nADDEN:
l$ 14 A Yes, it did.
2 15 0 And does the present design contemplate a boron 5
g 16 injection tank?
W 6 17 BY WITNESS MADDEN:
$ 18 A No.
=
- 19 g % Why was the decision made to change from -- to delete M
20 the boron injection tank from the design?
21 BY WITNESS MADDEN:
() 22 A In summary, the deletion of the BIT, and its 23 , associated support systems, boron injection recirculation pumps 24
(]) and boron injection service tanks, heat tracing, emergency 25 heaters, instrumentation and control, provide us a number of l
ALDERSON REPORTING COMPANY,INC.
741 3-19 1 operational advantanges in that it simplifies the design and w
] reduces the number of components to maintain to Tex-Spec 2
3 surveillance requirements.
4 The operating history with these types of systems in e 5 different power plants has shown a number of problems with 2
6 maintaining that high concentration of boric acid in the solution, 9
R 7 and in general it provides a great deal of operational X
j 8 simplification. It eases clean-ups in the event of an inadvertent d
d 9 actuation of the safety injection system. In summary, it i
e g 10 simplifies the design of the plant and makes the maintenance E
5 11 easier.
j 12 To justify the deletion of it, we
() 13 number of analyses, re-analyzedthe safety analysis in Chapter 15 l$ 14 in the Comanche Peak Final Safety Analysis Report.
2 15 It demonstrated that all licensing and safety criteria J 16 were achieved without the BIT.
G 6 17 g Is there some substitution for the BIT that you are
$ 18 proposing?
=
U g 19 BY WITNESS MADDEN:
M 20 A Not directly, no.
21 g Ms. Osborne, did you analyze the deletion of the BIT
() 22 from Comanche Peak?
23 , BY WITNESS OSBORNE:
() 24 A Westinghouse did analyze the deletion of the BIT.
25 g Are you familiar with the BIT system?
ALDERSON REPORTING COMPANY,INC. l
- 7d2.
3-20 1 BY WITNESS OSBORNE:
2 A Yes, I am.
3 G Please describe your involvement in that system, gs 4 BY WITNESS OSBORNE:
e 5 A I am the cognizant engineer in the Nuclear Safety
@ 6 Department on steam line break and boron concentration for BIT G
$ 7 reduction, or BIT removal, on a generic basis for Westinghouse.
s j 8 G Is the deletion of the BIT from Comanche Peak d
c; 9 unique to Comanche Peak?
z C
U 10 ///
g 11 a
j 12
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f 24 (2) 1 25 '
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- ALDERSON REPORTING COMPANY,INC. I
743 4-1 1 BY WITNESS OSBORNE:
ho
- 2 A. I know it is not Westinghouse' practice to perform 3 similar analyses for other utilities.
i 4
O 4 Q. Are there Westinghouse reactors of the vintage of 5 Comanche Peak which don't have BITS?
g e'
$ 6 BY WITNESS OSBORNE:
R S 7 A There are several Westinghouse reactors. One reactor A
j 8 to the.. poi'nt,' Units 3 and '4,- for which the -analyses have been d
9 done and they are now approved by the NRC and are in the process o
10 h of being implemented for the utility.
=
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Oeg i3 MR. REYNOtDS: No further questions, Mr. Cheirmen, l 14 and we offer them for Board examination.
, g 15 JUDGE MILLER: Any questions from Staff?
z y 16 MS. ROTHSCHILD: Excuse me, Mr. Chairman, my co-as 17 Counsel, Mr. Mizuno, is handling this issue for the Staff.
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18 JUDGE MILLER: Very well. You may proceed.
5 19 . -
$ MR. MIZUNO: The Staff'has no direct examination 20 at this time.
2I JUDGE MILLER: Thank you.
O 22 z,,,,veoor CASE. .
23 MR. JORDAN: Thank you, Your Honor.
1 O 24 25 j ALDERSON REPORTING COMPANY,INC.
I 7 11 @
4-2 l CROSS-EXAMINATION O 2 BY MR. JORDAN:
' hop 3 g Mr. Madden,the boron injection tank is forward, which 4 you said was part of the ECCS, subweguent ECCS system.
e 5 I gather the purpose of this is to inject boric acid h
3 0 into the ECCS system to go into the reactor at the time of -- if l
l R b 7 ECCS is needed.
- 8 5 Is that correct?
d I
k BY MR. MADDEN:
s
@ 10 A. Let me see if I can clarify it.
E y 11 g Please do.
B g 12 BY MR. MADDEN:
Oji3 a. The ECCS de1ivers horic ecid eo1ueion from your h 14 cooling water storage tanks. The fifth is in the flow path --
l 5 15 ECCS and in essence where the ECCS is actuated and sweeps the j 16 high concentration of boric acid from the disc into the reactor us f
17 vessel.
18 G And you deleted the high concentration of boric acid.
! A
{M 19 BIT arrangement, from the ECCS --
20 BY MR. MADDEN:
21 A That's correct.
O 22 g And the purgese of soric acid __ 1et.s go sacx to 23 what you suggest for ECCS 4.
24 ECCS doesn't actuate, does it, until an accident or 25 ! a need or an emergency shutdcwn of the reactor. Is that c o rrect?
ALDERSON REPORTING COMPANY,INC.
4-3 gg -
hop 1 BY MR. MADDEN:
O 2 A The purpose is several-fold. They are occasionally 3 actuated in an emergency.
O 4 G The actual purpose, is it not -- the purpose of the e 5 ECCS emergency core cooling system is to protect the reactor and
@ 6 the public in the event of a core cooling accident; correct?
R b 7 BY MR. MADDEN:
A j 8 A That is essentially a correct question.
O q 9 G To cool down the reactor so that it is safe?
z o
a 10 BY MR. MADDEN:
2
=
II A Correct.
E f I2 g And the purpose of the boric acid, as I understand it,
( 13 in a situation like that, it se-ves to dampen the nuclear m
E 14 w reactions to absorb -- as a part of the chain reaction; isn't b
that correct? -
x y 16 BY MR. MADDEN:
M 6 17 A Correct.
M 18 And what you've done is delete the use of boric acid
, g A
19 that would otherwise.: absorb the particle? ,
20 BY MR. MADDEN:
2I A No,[that'.s not correct.
() 22 I said the ECCS system is taking water from the 23 i cooling water storage tank which also contains boric acid solution .
() 24 g The amounts that are in the boron injection tanks are 25 not going to be going into the ECCS?
i ALDERSON REPORTING COMPANY, INC.
?^6 4-4 I BY MR. MADDEN:
2 A That's correct.
3 g To your knowledge, has the existence of the boron i ( 4 injection tank ever caused a safety problem in a nuclear reactor?
5 BY MR. MADDEN:
, g 4
@ 6 A It's hard to say what you mean by safety problem that G
S 7 was caused. The maintenance of that sub-system containing a s
j 8 high concentration of boric acid has caused numerous maintenance d
d 9 problems such as crystallization and solidification, overcoating 7.
c 10 h and possible gumming up valves has caused operational problems
=
f as opposed to safety problems.
N I2 g But you're not aware of any event in which ECCS was 13 needed on a baron injection tank in which a problem arose a
b I4 resulting in a safety hazard?
g 15 BY MR. MADDEN:
x E I0 A No, I'm not.
W d 17 g Ms. Osborne, I'm afraid I'm not quite clear on what 5
{ 18 you had to say -- you were asked whether you had analyzed the boran 5
g 19 injection tank deletion and you said that Westinghouse analyzed n
20 it.
21 I take it, then, you did not analyze it personally 22 but someone at Westinghouse did?
(])
i 23 24
(])
25 '
i ALDERSON REPORTING COMPANY, INC.
747 4-s I. BY WITNESS OSBORNE:
. ho] 2 A. That is true.. I did not personally do an analysis.
3 BY MR. JORDAN: That's all I have.
i O 4 JUDGE MILLER: Thank you.
5 y Judge Cole has some questions, I think, that he would e'
- @ 6 like to address to the witnesses, please.
R*
" 7 You might get your microphones located in front of n
9 8 5 you so that their volume will carry to the rear of the room.
O 9
k Thank you.
$ IO BOARD' EXAMINATION E
II k BY JUDGE COLE: '
is f 12 G Just one or two questions.
Ol i3 Mr. Medden, you were gresene-ae the meeting on h 14 Comanche Peak design change in response to RSD, which I assume g 15 that's Mr. Spottswood Burwell's question.
a:
g 16 That meeting was held of March 10, 1981.
cA N I7 BY MR. MADDEN:
{ 18 A. I believe that's correct.
E s I9 g Do you have that document in front of you, sir? The l
l 20 summary of that meeting?
2I BY MR. MADDEN:
22 A. Yes, I have.
23 g could you briefly describe to me the scenario in O 24 which the ho,on in3ection tank wom1d he activated?
25 ALDERSON REPORTING COMPANY,INC.
4-6 hop I BY MR. MADDEN:
O 2 l
A Any situation where the emergency core cooling system 3 was actuated and the -- I had the centrifugal charging pumps that 4 were delivering the flow. Would in effect actuate the BIT.
e 5 BY JUD'_s COLE:
5 l 6 g Have you done or made any calculations and/or do you R
b 7 know what the ratio of DNBR, the departure from the nuclear boron 3
8 8 ratio would be without the boron injection tank system and with d
9 the boron injection tank system in place, after it's activated?
BY MR. MADDEN:
=
II k A For what transient or accident?
Es BY JUDGE COLE:
O: g i3 g For the most likely transient':.that would occur when E 14 W it would be activated, let's say a steam break, a small OR steam 2 15 break.
g j
. 16 BY MR. MADDEN:
vi
,N I7 A As I recall, the Condition 4 steam line break analyses x
{ 18 as performed buestinghouse, calculated without the BIT. The DNBR
& was only 102.5; is that correct? -
19 g
! n 20 BY JUDGE COLE: .
21 g Yes.
Have you made any calculations and/or do you know C 22 23 what the ratio would be if the BIT was in place and operating?
] 24 BY MS. OSBORNE:
25 l A I do not know what the exact combination would be if i
I l the BIT was installed. However, it would be slightly higher i ALDERSON REPORTING COMPANY, INC.
4-7 7et$.
hop I than the 2.5 that was calculated without the BIT.
I
(:) 2 BY MR. MADDEN:
3 A Those calculations were performed and were a part of (3
\' 4 the FSAR until Amendment 16 was revised, that particular transient o 5 analysis to show the test without the BIT. Those figures are M
9
@ 6 available. I just don't recall them.
R d 7 BY JUDGE COLE:
A
- j. 8 0 In your direct testimony, Mr. Madden, I got the d
c; 9 impression that the main reason why the BIT system was being 2
0
$ 10 removed was more from an operational viewpoint. It was sort of a E
g 11 nuisance to operate. You had operational problems associated with 3
12 it and in a review of the safety implications, it was not a
() 13 significant factor in the safety of this plant.
h 14 Does that adequately summarize your position on the 15 issue, sir?
{=
y 16 BY MR. MADDEN:
W 6 17 A That is accurate.
E
{ 18 BY JUDGE COLE:
P 19 g would you like to add anything to that?
g n
20 BY MR. MADDEN:
2I A No..
() 22 BY JUDGE COLE:
4 In looking at certain of the charts that were 23 l 24
(]) associated with the summary of the meeting on March 10th, I recall 25 seeing a lot of those charts that it was at zero power at the ALDERSON REPORTING COMPANY, INC.
4-8 9%()
hop 1 beginning of the chart.
O 2 The most likely scenario for this being involved would be 3 at fullpower; would it not, sir?
O 4 BY MR. MADDEN:
g 5 A. We hope we would be at full power more than at zero
?.
$ 6 power, yes.
R
@, 7 BY JUDGE COLE:
M j 8 Let me see if I can find some of those charts here.
G O
ci 9 You have a copy of that document in front of you, z
o l
10 don't you sir?
II
$ BY MR. MADDEN:
it f II A. Yes.
Og i3 BYJUDGE COLE:
E 14 w G Could you look at Pages 2-7 through 2-9 of that 15 document? It talks about 1.4 square foot DER zer power to the 5th .
j 16 My first question; what is DER and then, why are these as I7 figures shown at zero power?
{
18 BY MR. MADDEN:
g I9 A. . DER is an abbreviation for Double Ended' Rupture ~. -
1 n
20 BY JUDGE COLE:
2I G All right, sir. I O 22 ,y yo. xxooss, 23 A. They basically analyze the limiting cases at zero O 24 p,,,, ,,,,,,,yo, ,,,,1,,, ,,,,1, ,,, ,,,,,,, ,,,1,,, ,ys,, .
25 ALDERSON REPORTING COMPANY,INC.
4-9 8 79 ihop 1 BY JUDGE COLE:
O 2 g So that whatever problem can be associated with that 3 will be exacerbated by being at zero power. I know that you're O 4 looking more toward the problem of an overcooling transient as 5 being limiting rather than the opposite?
g e
3 6 BY JUDGE COLE:
R b, 7 0 Is it really that simple, Ms. Osborne?
s j 8 BY MS. OSBORNE:
0 9 A. Yes. W-stinghouse has done studies where we have o
l= 10 analyzed a steam line break accident at various power levels.
j 11 These are documented in Westinghouse Topical Report at 92.26, in . .
is j 12 which we demonstrate that at zero power steam line break is indeed O! m 13 the limited case, and that is why only zero power steam line l$ 14 breaks are presented in the FSAR.
g 15 BY JUDGE COLE:
=
ij 16
% You alluded to examples of operational problems with us II the BIT system.
=
{ 18 Was thist the prime mover for analyzing the system and E
g making a determination that the reactor system does not need BIT?
20 BY MR. MADDEN:
21 Yes. That is correct.
A.
BY JUDGE COLE:
23 g I guess my concern is the many trade-offs of safety O 24 with respect to convenience of opereeion end you responded to some 25 of that.
I don't know whether I really have a feel for the
. ALDERSON REPORTING COMPANY, INC.
4-10 i
l X2 1 balance there.
ho 2 That's why I asked the question about the ratio of 3 nuclear volting with or without the BIT and that would tend to O)
\
'- 4 give me a handle on some of the trade-off.
- 5 Would you like to add anything to that question 0
@ 6, concerning any safety trade-off before removal of the BIT system R
8 7 as cor. pared to operational convenience of not having and/or 3
j 8 the possibility of having safety problems by its inclusion iri the d
9 system by diversion of the operators.
i o
$ 10 BY MR. MADDEN:
3 j 11 A I perhaps have one remark in that vein.
3 12 I have a personal philosophy but I think the power l
()5y m 13 plants are large_and' complex and any time we can'have them m
l$ 14 simplified, it makes it easier for the operators to understand j= 15 how to operate and maintain it. I think it will lead to a safer j 16 plant.
t A 17 Also, we took a pretty complete reevaluation of all h
=
$ 18 the accident transients that were mitigated by the BIT and found P
19 there was very little difference in the transient b ehavior, with
, g l
20 or without the BIT.
l 21 l We felt perhaps it might be a little safer plant 1
() 22 without the BIT, just from the simplification of operation and 23
, in terms of maintenance.
I 24 BY JUDGE COLE:
( )1 25 g Ms. Osborne, do you agree with that?
l l
ALDERSON REPORTING COMPANY, INC.
W3 4-11 1 BY MS. OSBORNE:
'hoh' C
2 A. Yes, I do agree with that.
3 The only point that I would like to add is, you O 4 mentioned your concern is related to the change in how the DER e 5 is calculated.
b
$ 6 I would like to point out that the Double Ended R
b 7 Rupture is a condition in which fuel failure is permitted to occur ,
l 8 Whereas, Westinghouse is able to demonstrate that d
d 9 even in a Condition IV event, you show no fuel failure at all.
E, 10 That demonstrates that there is a large degree of h
II safety in the plant even without BIT.
f I2 BY JUDGE COLE:
Ol13 a what is the Condition Iv evene?
h I4 BY MS. OSBORNE:
15 A. There are about four classes of events.
y 16 Condition I events are normal operation transients.
as I7
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h Condition IV are transients which are not expected x
{ 18 to occur.
E g 19 The most common one that we could think of was the M
20 loss of coolant accident.
2I JUDGE COLE: No further questions.
O 22 ,coOE M1LLER, audge Mcco11om, I he11 eve, has some 23 questions.
Q 24 BY JUDGE MC COLLOM:
25 You indicated, Ms. Osborne, that the Class 4 j G I ALDERSON REPORTING COMPANY. INC.
e
' My4 4-lk hop j accident was analyzed and I wonder about the smaller break. The 2
so-called small loss of coolant break?
3 Did you do analyses on the impact of removing the 4'
l BIT on that?
BY MS. OSBORNE:
@ 6! A. We did do the analyses for Condition 2 steam line G7 b 7 break as well as for a Condition 4.
k 0 BY JUDGE MC COLLOM:
G I c' 9l G What did you find before and after with the removal 0 10 g of BIT? What was the comparison?
=
II BY MS. OSBORNE:
ic N I2 A. If the event is in place.for a Condition 2 steam line E
Om 13 break, there is no return to criticality for the commission of l$ 14 analysis.
g 15 If the BIT is removed,then there is a return to
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g 16 criticality. However, Westinghouse demonstrates that .
as f
=
I7 departure from the DNBR.
IO BY JUDGE MC COLLOM:
i:
" )
19 8 Pardor me.
8 G n
20 Departure from what?
BY MS. OSBORNE:
A. DNBR.
23 l BY JUDGE MC COLLOM:
G Did, in your analysis, you consider the variation in 25 i! what might be called thermal shock between having the BIT and ALDERSON REPORTING COMPANY, INC.
-755,'$
4-13 I not having the BIT?
.no 2 The change in temperature, is it greater per unit 3 time on any events that would occur, as compared to when the BIT O 4 is in it?
g 5 There are some plots on the back of the same document 9
@ 6 that has been referred to, which I'm sure will come into R
$ 7 evidence later, that shows different thermal transients and I a
j 8 just wondered if there had been analyses of the thermal 6
d 9 transients that occur and related to thermal shock of the fuel
$ 10 elements and the like?
E B
{ 11 BY MS OSBORNE:
12 A Referring to the fossil versus nuclear power or I
5
()y 13 fossil versus time?
m l$ 14 BY JUDGE MC COLLOM:
g 15 g Yes . It would have to be versus time and I'm e
~
g 16 concerned about the fuel element temperature and what happens for M
I7 the worst transient,I suppose, with the BIT and without the BIT h
m
$ 18 with respect to rate of change of temperature.
E g I9 B Y MS . OSBORNE:
n 20 A When we do the calculations of the DNBR at various 2I points in time for transient and for all points analyzed, we 22 are able to show that the limit is met, at various points in l
time for the transients for all the plants analyzed.
l
() 4 BY JUDGE MC COLLOM:
25 ~
j G I'm more concerned, not with having met a given limit I
l I ALDERSON REPORTING COMPANY, INC.
- 756 .
l 1 on it but the rate of change of temperature as you get to that.
n 2 I don't have any prejudices that there is or isn't a hop 3 rate of change of temperature that is increased or decreased but 4 the thought did occur to me that if you do not have as much 5 shutdown of reactivity, that there is a difference and the rate j
e'
@ 6 of change of temperature for the fuel element surface.
R
$ 7 Yes, Mr. Madden.
A j 8 BY MR. MADDEN:
d c; 9 A. Perhaps I can point out some relevant information
$ 10 here about this.
E
$ II Figures 3-4 and 3-5 of that same attachment are the is I2 plots of the large steam line break, Condition IV, without the BIT Os .a 5
a:
13 and with the BIT, respectively.
14 J Tlie middle curve shows the core average tamperature 15 as kept -- as captivated by analyses. In fact, you can see that d I0 without the BIT the core average temperature stays up. There is
'^
l I7 less of a rate of change without --
E Is it g 19 4 How do you measure core average temperature?
n 20 the water or the fuel element?
21 BY MR. MADDEN:
O 22 3. This is gege 3-4, 3-5 of the summery, 23 BY JUDGE MC COLLOM:
l C 24 g That labeled Transiet Response, Large Break 25 (Condition IV) With BIT, at the bottom of Page 3-4 and then the ALDERSON REPORTING COMPANY. INC.
757'
= ft 4-15 1 following page.
hop O 2 But as far as you know, you do not have information 3 on the actual temperature of the fuel element itself at that O 4 point? Per unit time?
5 BY MS. OSBORNE:
6 A. No. It would have been internally calculated R
" 7 according to the overall calculation but is not a parameter that n
- 8 M was studied.
d d 9 BY JUDGE MC COLLOM:
i C
$ 10 g Okay.
11 JUDGE MC COLLOM: I think that's all I have.
it f 12 JUDGE COLE: I have one question.
Ol m i3 BY JUDGE COTE, h 14 g I read some place here concerning - .and I couldn't g 15 find it -- where it concerned with respect to over cooling and 1 =
g' 16 the BIT -- the presence of the BIT system exacerbated the us I7 overcooling transient and by that, reduced the temperature in h
x
$ 18 the reactor, the reactivity increased and that was offset by the P
{n 19 increased b oron concentration and I guess my concern has ta do 20 with the small volume of this tank, it being what -- 800 to 900 21 gallons and how that particular tank with this volume would be l O 22 resgonsib1e for temperature change thae wom1d change the 23 reactivity that was balanced by the boron concentration inside.
Q 24 I guess I have a problem with that small volume 25 creating a temperature reduction and increased reactivity and how 1
i ALDERSON REPORTING COMPANY,INC. l
758 4-16 1 removing that would balance that out.
'hoVO 2 Am I reading soinething that wasn't there, sir?
3 BY MR. MADDEN:
O 4 A. I'm afraid I don't quite understand.
e 5 BY JUDGE COLE:
h l @ 6 g Maybe that's two of us.
l E
- 5 7 Let me start over.
A j 8 There is a concern with an overcooling transient d
ci 9 throwing the introduction of emergency core cooling water; is
?
10 that co-rect, sir?
h
=
$ II BY MR. MADDEN:
is f I2 A. We're talking about an inadvertent actuation of the 13 inj-ction system, now, as opposed to the steam line break or x
l$ 14 cooling transient?
2 15 BY JUDGE COLE:
x y 16 g Let's call it a steam line break situation.
as II h BY MS. OSBORNE:
a:
$ 18 A The cool down is not caused by the injection of cold P
t-I9 water from the safety injection system. It is caused by the 8
n 20 blow down of the working steam generator.
21 The increased steam flow on the secondary side will j
l O 22 grovide a very 1arge intake of water ane that causes the coo 1 23 l down. It's not the boron.
l 24 O sy ,cocE COLE, l 25 0 Okay. That's where I was confused because I got I
I i ALDERSON REPORTING COMPANY, INC.
759 4-17 i imprassion that the cooling was caused by the injection of this hop 2 small -- rather small volume tank and I just couldn,t visualize 3 that being the problem.
() 4 B Y MS . OSBORNE:
5 A No. No. It's the blow down from the faulty coolant.
A 6 3 JUDGE COLE: Okay. I have no problem in that regard.
E E Thank you.
A S 8 n JUDGE MILLER: Amything further?
d c 9 7-(No response.)
o H 10
@ JUDGE MILLER: All right.
=
I guess that's the conclusion of the interrogation d 12 E of these witnesses.
13 I
()@ MR. REYNOLDS: I have a few questions on redirect, E 14
- if I ray.
m 15 JUDGE MILLER; All right.
]r
=
E I0 -
REDIRECT EXAMINATION 4 W J .
I7 BY MR. REYNOLDS:
h x
{ 18 g Ms. Osborne, did you review the Westinghouse analysis P
19 8 relating to the deletion of the boron injection tank?
l BY MS. OSBORNE:
2I A I reviewed it in connection with this case. I did not 22
, O- review it at the time it was done.
23 l 0 I understand.
( Are you familiar with it?
25 ;
i ALDERSON REPORTING COMPANY, INC.
(4-18 76'O
@P 1 BY MS OSBORNE:
O 2 A Yes, I am.
3 g Is it correct, technically, in your opinion?
O 4 BY MS. OSBORNE:
5 A Yes, it is.
^
6 g You testified that the DNBR without the boron e.
b 7 injection tank was in the range of what number?
E j 8 BY MS. OSBORNE:
d N 9 A 2.5.
E g 10 g 2.5.
E
' And you testified that the DNBR would be slightly higher with the BIT; is that correct?
i OSg i3 BY MS. OSBORNE:
E 14 A Yes, it would be slightly lower.
g 9 15 g g What order of magnitude lower would it be?
16 g' We recognize you might not know the exact number.
$ 17 w Are we talking about 2.4, 2.3?
m M 18
- JUDGE MILLER: Remember now, this is your witness.
4 19 l MR. REYNOLDS: Perhaps that's a number we could supply 20 later for the record.
21 JUDGE MILLER: All right.
O 22 Yhat.s agreea31e. Yhse mighe se mere satisfactory.
23 - BY MR. REYNOLDS:
O 24 g Ms. Os,orno, what is the safety criterion for oNeR?
25 or Mr. M adden.
ALDERSON REPORTING COMPANY, INC.
761 ~
1 BY MS. OSBORNE:
- 4-2 A To meet the limit DNBR, you are demonstrating that
. hop
) 3 no fuel problem has occurred.
\
4 0 Yes. What is the numerical value for the criterion?
$ 5 BY MS. OSBORNE:
N
$ 6 A Oh, 1.3.
l I R 8 7 0 1.3.
j 8 Mr. Madden, what are the. transients for which credit d
q 9 was taken in the design with the BIT included?
8 10 BY MR. MADDEN:
h
=
II S A The only transient for which credit was taken were the 3
N II effects of BIT on a steam line break of transient Condition IV (2)5j 13 and Condition II.
I4 Condition II, small break LOCA. Is that what you're 9
g i5 referring to?
x E I0 BY MR. MADDEN:
w I7 A It's an inadvertent opening of the largest safety h
z 18 f valve or primary safety valve or the steam valve.
19 8 g And they are the only transients for which credit was n
20 taken for the BIT?
21 BY MR. MADDEN:
() 22 A That's correct.
~
23 MR. REYNOLDS: No further questions.
() 24 JUDGE MILLER: Anything further?
25 ' MR. MIZUNO: The Staff has no'further questions.
ALDERSON REPORTING COMPANY,INC.
762s 1 MR. JORDAN: Mr. Chairman, I have some questions.
.g _ "'
2 RECROSS-EXAMINATION P 3 BY MR. JORDAN:
O 4 g Ms. Osborne, who performed the Westinghouse analysis?
5 BY-MS. OSBORNE:
$ 0 A There have been several groups within Westinghouse R
7 that have participated in the re-analysis of the steam line break.
6 8
M There would be nuclear safety, of which I am a member.
0 6 9 7.
Nuclear tools division and thermal hydraulic design o
G 10 z group, all were involved.
=
E 11 g They are the groups that determine what the reactivity 6 12
% co-efficients are and they are the group that actually calculate Oo a 5
m 13 the departure from the nuclear blowing rate ratio.
@ 14 Now, you mentioned two groups.
0 g 15 BY MS. OSBORNE:
x j 16 A Nuclear engineering and thermo-hydraulic design.
w
! I7 They are both part of the nuclear tools division.
h x
M 18
_ G Now, what are we talking about here regarding the C
19 8 number of people in each of these groups involved in these 20 analyses?
21 BY MS. OSBORNE:
() 22 A I would say there would be usually one engineer who 23 is actually doing the numbers.
() 24 25 !
l I
I ALDERSON REPORTING COMPANY,INC.
AS ..,
763' 4-21
- 1 I
Another engineer who is reviewing, checking the work hopm 2 as it's done. There are two engineers for every group that's 3 involved.
' O 4 G You mentioned two groups. That means four people?
e 5 For what period of time did this last?
b i
h 6 BY MS. 03 BORNE:
R
& 7 A. I cannot say for sure on this particular analysis but a
j 8 that entire analysis normally takes three to six calendar months, d
' d 9 depending on the work load.
! 2, e
g 10 0 And you were not involved in that?
$ II BY MS. OSBORNE:
f I2 A. No, I was not.
O!i3
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j 16 us 6 17 18
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i 20 21 i
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23 ;i O 24 25 i ALDERSON REPORTING COMPANY, INC.
764i I
5-1 1 G Mr. Madden, following a question by Judge Cole about O 2 the reasons for -- well, I'm confused on the issue. Part of the 3 purpose of this hearing is r.omewhat of public education and this rmI t
'# 4 seemed backwards to me. You say that overcooling is worst at g 5 zero power, and just as a lay person I don't understand, because 8
@ 6 you have the most heat when you have the most power; why in the R
$ 7 world is overcooling the worst at zero power?
3 j 8 BY WITNESS MADDEN:
d q 9 A Would you like to try that for me? I think you're a z
o
$ 10 little more famili.ar with the job than I am.
E 11 BY WITNESS OSBORNE:
E .
g 12 A If, for instance, you take the opposite case for a
() 13 steam line break occurring, for full power there's quite a bit h 14 of decayed heat that would remain following the reactor trip 15 and the cooling would be somewhat less into that.
j 16 However, I would like to point out that it is not --
W 17 the primary cooling comes from the blowing down of the broken h
x
{ 18 steam generator. It is not something that is generated from the P
o l9 safety injection system.
g n
20 The broken steam generator provides a very large 2I heat synch and you would get a large degree of cooling, no matter l () 22 what power level you were at. It's just that Westinghouse has 23 i done studies at various power levels and has determined that the
() 24 limited case occurs at zero power.
25 j jff i ALDERSON REPORTING COMPANY,INC.
~
765' i 5-2 1 BY WITNESS MADDEN: -- -- 1 2 A. Let me see if I can amplify on that. When we say 3 zero power we're talking about hot zero power, irredescence of G
D 4 full reactor coolant system temperaEure but no load or no power e 5 and therefore you don't have the degree 'of steam energy as far as I l
h
@ 6 decay heat, hot metal and so forth, so without that extra stored g m.
E 7 energy that's available to power, that results in a'more severe A -
j 8 rate of. overcoming the' transient'. -
d o; 9 JUDGE McCOLLOM: May I ask a question here.
E i g 10 Does this reactor, in these 'two situations you-just E
$ 11 addressed, have a positive 'or a negat'ive temperature coefficient is P
I 12 of reactivity? ;
Oii3 m
W1TNESS oSeORNE: It hes e nesetive temgereture l$ 14 coefficient.
g 15 JUDGE McCOLLOM: Okay. And would you describe what x
16 d that means? ,
vi I7 WITNESS OSBORNE: A negative moderated temperature h
x -
} 18 coefficient means that a decrease in reactor core temperature g
g l9 will provide a positive reactivity' insertion. _
n ~
20 JUDGE McCbLLOM: And that means close to criti ality, 2I right? Or further from criticality?
22 WITNESS OSBORNE: Oh, it would make you closer to 23 criticality, positive reactivitp insertin.
=
O 24 ,ooOE MccOLLOM, Is that one of the reasons; sy over_
25 cooling is a probleba?
t T ALDERSON REPORTING COMPANY. INC. -
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o ' %
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766' 3 1 , WITNESS OSBORNE: Yes. The large degree of cooling O s 2 combined with the very large negative moderated temperature 3 coefficient provides a large reactivity insertion.
4 JUDGE McCOLLOM: Thank you.
e 5f JUDGE MILLER: You may resume.
N
$ '6 ,
MR. JORDAN: Thank you.
~
'R ~
{ 7 BY MR. JORDAN:
3 8 8 G Finally, Mr. Madden, in the area of why it was d
d 9 chosen, the removal of the boron injection tank, you testified g 10 that it was essentially --
E 5 11 Getting to the reason for moving this thing, do you g 12 know how much it costs for that removal, the boron injection tank?
Oli3 BY W1TNESS MADDEN:
l$ 14 A What, the initial cost of the boron injection tank?
2 15 % hat would be the cost of the boron injection tank E
j 16 facility?
w d 17 BY WITNESS MADDEN:
5 M 18 , A I have no idea.
=
g 19 a You have no idea. Do you know whether cost was n
20 considered as a factor in this or not?
21 BY WITNESS MADDEN:
() 22 A Not directly. .
23 , G You don't know directly or it wasn't considered?
24 BY WITNESS MADDEN:
(])
25 l A It was not directly considered, no.
1 ALDERSON REPORTING COMPANY. INC.
.767 5-4 1 % Do you know whether it was indirectly considered?
O 2 BY WITNESS MADDEN:
3 A Well, you would have to say, when you talk about O 4 the the so-called maintenance advantage and the simplification e 5 of the design, there is some indirect costs there, but we never b
3 6 attempted to try to make a direct determination of what the cost R
{ 7 of that would be, no.
s j 8 G Would it in fact cost anything at all?
d d 9 BY WITNESS MADDEN:
$ 10 A Yes.
E
$ 11 MR. JORDAN: That's all.
12 JUDGE MILLER: Thank you.
I
/~l
(/ g b 13 Is there anything further?
m l$ 14 BOARD EXAMINATION 15 BY JUDGE McCOLLOM:
y 16 g Miss Osborne, in response to a question from your s
N 17 counsel you indicated that you have a departure from nuclear 5
M 18 boiling ratio of 2.5. I assume you're referring to a typical E
19 situation such as a large steam line break accident.
g n
20 BY WITNESS OSBORNE:
21 A Well, that --
() 22 O And you indicated that that would be without the 23 boron injection tank system, and in response to a question as to i
24
(]) what ratio would be with the boron injection tank system in place 25 i and operating in that same area that the departure from nuclear ALDERSON REPORTING COMPANY,INC.
l 768 5-5 1 boiling would be less than 2.5.
() 2 BY WITNESS OSBORNE:
3 A I take it all back.
4 (Laughter.)
e 5 g Nhat did you mean?
h 3 6 PY WITNESS OSBORNE:
E l 8 7 A Please permit me to state it, and then you can give N
j 8 it back to me. I think I'm confused.
d d 9 A high value of departure of nuclear boiling ratio i
o
$ 10 is conservative. The higher your value of departure from nuclear 3
l 11 boiling ratio is, the farther away you are from actual DNBR S
g 12 more subcooling.
() x 13 For example, if the BIT were in place, I would expect l$ 14 a departure from nuclear boiling ratio to be higher than -- and 2 15 I know I'm right this time -- I would expect the departure from g 16 nuclear boiling ratio to be higher than that number that you would M
l b~ 17 attain if you did the analysis without a BIT, and the reason for M 18 that is if the analysis is done with a BIT the increase in l _
P 19 nuclear power is somewhat less than if the analysis was done n
20 without a BIT.
l 2I g Okay. So when you answered that it would be lower l
() 22 than 2.5, you didn't mean that?
23 BY WITNESS dSBORNE:
l ,
I i 24 A Yes, that is true.
(}
25 ' g so you would have a greater safety factor with the BIT ALDERSON REPORTING COMPANY, INC.
769~
3-6 1 system in place, under similar circumstances?
O 2 BY WITNESS OSBORNE:
3 A. Yes.
O 4 G Okay. How much higher would it be, do you know?
e 5 BY WITNESS OSBORNE:
h
@ 6 A. I would not expect it to be more than a couple of G
$ 7 percent higher.
j 8 g Would you, for the educational aspects, tell us why a \
ci 9 it's good to have a high DNBR?
E
$ 10 BY WITNESS OSBORNE: ,
E
$ 11 A. A Westinghouse Pressurized water reactor is designed is f 12 such that there is no boiling in the primary site. In other Ol13 words, the collant that flows through the fuel does not boil.
l 14 This is measured, in our analysis, by measuring this departure 15 from nuclear boiling ratio. Nuclear boiling is a phenomenon in 16 which bubbles start to form, but it is not full-fledged boiling a[
as 17 that you get when you're making tea.
h 18 Westinghouse, based on the_ correlations which they li 19 used to calculate the amount of water which occurs, has determined 20 that if your ratio is greater than one to three, and we can show 21 a 95 percent confidence level, that there is no departure from O 22 nuc1 ear bo111ng, and hence no fue1 fa11ure.
23 If, for instance, boiling were to occur in the Q 24 reactor vessel, then the heat transfer from'the fuel through the 25 ' fuel through the clouding into the water would be greatly ALDERSON REPORTING COMPANY, INC.
-770
~ 3-6 1 reduced, because heat transfer through vapor is much less O 2 efficient than heat transfer through a liquid coolant.
3 JUDGE McCOLLOM: Very good.
O 4 JUDGE MILLER: Anything further?
e 5 Thank you. You may step down, b
h 6 (Whereupon, the witnesses were excused.)
R
$ 7 JUDGE MILLER: ciext witness, witnesses.
- A j 8 MR. MIZUNO: Eefore the Staff continues with the d
d 9 boron injection tank issue, the Staff would like to note that
$ 10 the affidavit of David Shum was in fact dated May 7th, 1982, 25 h 11 and David Shum's affidavit addressed the hydrogen control problem.
is j 12 I believe there was some question as to whether -
O! m i3 Mr. Shum s effidevie hed e dete or noe.
i l$ 14 JUDGE MILLER: Let Ice get this straight.
[= 15 JUDGE McCOLLOM: Well, I couldn't find a date on it.
g 16 I didn't say it didn't have one.
I us d 17 JUDGE MILLER: Where is the date?
$5 18 MR. MIZUNO: It's on Page 5, the last page of 5
19 Mr. Shum's affidavit, below his signature.
{
n 20 JUDGE McCOLLOM: That's correct. Thank you.
21 JUDGE MILLER: The record will stand corrected, as O 22 neeed. Thanx you. you may groceed.
23 l MR. MIZUNO: Thank you.
{} 24 Mr. Chairman, before we present Mr. Diab on the boron i
25 { injection tank deletion, the Staff would like to note that at t
I i i
! ALDERSON REPORTING COMPANY,INC.
,771.
~5-7 1 prcsent there is no contention or Board question, a specific O 2 Board question concerning the boron injection tank deletion, and 3 therefore if the Board is going to make some findings on this 1
O 4 issue that it first must raise the issue sua sponte and fulfill e 5 the standards set forth in the Commission's regulations.
5
$ 6 JUDGE MILLER: Let me address that right now. It's a g
- $ 7 question of law. You've directed it to the Board. The Board, 4
j 8 I think, made clear that we were asking for information when this d
o 9 situation came about.
E
[3 10 We also said that depending upon the results of the E
1I responses the Board would decide whether or not to make it an f is y 12 issue sua sponte, or otherwise.
i3 Yes, mr. Chairman, therefore the Seaff Ol ma. MIzuso:
! I4 would just like to note that it's providing Mr. Diab at this l $
g 15 time so that it would help the Board in making the 2.760-A z
-g 16 finding of whether there is in fact a serious safety issue at s
17 stake here.
h m
$ 18 JUDGE MILLER: Well, would there be any other E
e I9 purpose? We accept it, but we're a little puzzled why you make M
20 such a point of it.
2I All right. Proceed. I think we understand.
O 22 xa. xIzuno: oxer. rinetiv, hefore ca111ne Mr. Diah, 23 we would like to note that Mr. Diab was in fact the Staff person Q 24 who provided the supporting affidavit to the NRC Staff's response 25 to the Atomic Safety and Licensing Board's request for information
! ALDERSON REPORTING COMPANY. INC.
I
I 772'.
5-8 1 concerning the deletion of the boron injection tank. That G
\/ 2 pleading was filed, and is dated May 7th, 1982.
3 At this time I would like to call Mr. Sammy Diab to 4 the witness stand, s 5 JUDGE MILLE's Very well.
A j 6 Mr. Diab, come forward, please.
G
$ 7 Whereupon, s
j 8 SAMMY S. DIAB d
c; 9 called as a witness by counsel for the Regulatory Staff, having
$ 10 been first duly sworn by the Chairman, was esamined and testified E
j 11 as follows:
2 12 DIRECT EXAMINATION
() m 13 BY MR. MIZUNO:
h714 g Mr. Diab, can you please state your name and who you g 15 are employed by?
m j 16 A My name is Sammy S. Diab. I'm employed by the i
d l N 17 Nuclear Regulatory Commission.
l 5
5 18 g And what is your position at the USNRC?
E g 19 A I am the lead reviewer for the Reactor Systems Branch
! n 20 for CPSES.
21 G And what sections of the CPSES final safety analysis
() 22 report were you responsible for?
23 A I'm responsible for several sections. The one that ---
l
() 24 or actually the two that directly relate to this hearing, is 25 l Chapter 15 and the Standard Review Plant.
ALDERSON REPORTING COMPANY, INC.
7737 i-9 1 G And you are familiar with --
O 2 JUDGE MILLER: Pardon me just a minute. Would you 3 tap your mike so we can get a sound? We're trying to get the O" 4 sound level improved.
e 5 BY MR. MIZUNO:
h j 6 G Mr. Diab, could you spell your name for the record, R
$ 7 please?
s j 8 A. Sammy, S-a-m-m-y, S., middle initial, and the last d
d 9 name is Diab, D-i-a-b.
g 10 G Thank you, and can you repeat your answer to my G
j 11 question regarding the sections of the Final Safety Analysis D
j 12 Report for Comanche Peak for which you are responsible for?
13 A. I reviewed several sections in the Safety Analysis
@ 14 Report for Comanche Peak. The two that are directly related to
[x 15 the BIT removal are Chapter 15, specifically steam line break j 16 analysis, and Section 6.3, which is ECCS.
A 6 17 MR. MIZUNO: The Staff has no further questions at
$ 18 this time and makes available Mr. Diab for any Board questions.
E g 19 JUDGE MILLER: Do you wish to mark and offer into M
20 evidence the affidavit or any -- what's his testimony? So far 21 we don't have too much to go on.
O 22 MS. RoTsScsItE, Me11, Mr. chairman, as we saie, we 23 ; provided the affidavit of Mr. Diab --
0 24 JUDGE MIttER: Ie's not in the record.
i 25 MS. ROTHSCHILD: That's correct. -- to respond to i ALDERSON REPORTING COMPANY,INC.
774 '
5-10 1 the information requested by the Board. We are now making him 2 available for questioning.
3 We had not planned to offer into evidence his 4 affidavit. It was just provided to provide information for the e 5 Board.
A 9
3 6 Does the Board wish to have it into the record?
R S 7 JUDGE MILLER: Yes -- well, the Board wishes to have s
j 8 the information that was requested so the Board could decide d
d 9 where it would go from there on this matter.
$ 10 You've proffered the affidavit in response to the E
j 3
11 Board. The Board indicated to you, I believe indirectly, you had g 12 a message from my secretary, did you not, that we would like to
[
() 5 13 have testimony or eviderce presented on the BIT matter, but was l
l$ 14 not necessary on Board Questions 1 and 2.
2 15 Did you get that request?
g 16 MS. ROTHSCHILD: Yes, we did.
M 17 JUDGE MILLER: All right.
l i
{x 5 18 MS. ROTHSCHILD: And that is why we have Mr. Diab
=
l U
l
, 19 here. We --
M 20 JUDGE MILLER: Well, he's here but he's not saying
- 21 anything. If you want to use his affidavit as direct testimony, I
() 22 offer it.
23 , MS. ROTHSCHILD: That's what we would propose to do.
l
() 24 I
JUDGE MILLER: All right. Do it.
25 j MS. ROTHSCHILD: Okay.
I ALDERSON REPORTING COMPANY, INC.
8 775 5-11 1 BY MR. MIZUNO: l O 2 G Mr. Diab, do you have in front of you a copy of the 3 document entitled " Affidavit of Sammy Diab," dated --
4 JUDGE MILLER: It says the blank date of May 1982.
e 5 That's what my copy has.
3
] 6 MR. MIZUNO: Right. I believe Mr. Diab's affidavit G
E 7 was provided in a signed form later. I don't have that at this a
j 8 moment.
d c 9 JUDGE MILLER: Yes. That's correct. It was.
$ 10 Do you happen to have the date in mind? We'll 3
l3 11 accept your statement. I believe it's the 18th day of May. Is
, j 12 that your understanding?
(m 5
(,I ym 13 MR. MIZUNO: Just a moment.
I l$ 14 JUDGE MILLER: We would accept whatever date you tell 2 15 us. It's not a matter in controversy.
l $
l j 16 MR. MIZUNO: Yes, it is the 18th of May.
W d 17 JUDGE MILLER: Very well. The record will so reveal.
N
$ 18 You may proceed, please.
=
t g 19 BY MR. MIZUNO:
n 20 G Mr. Diab, do you have a copy of your affidavit, 21 dated the 18th of May, concerning the BIT?
() 22 A Yes, I do.
23 G And have you reviewed that document and do you have
(]) 24 any changes or corrections to make to that affidavit at this 25l time?
i ALDERSON REPORTING COMPANY,INC.
7'76'
.5-12 1 A I have reviewed it and I do not have any additions rs U 2 to make.
3 MR. MIZUNO: At this time I would like the record to
/'
4 reflect that I am going to be giving the court reporter ten copies e 5 of the affidavit of Sammy Diab.
A d 6 JUDGE MILLER: Thank you. Marked for identification 1
k 7 as Staff Exhibit 7? Is that correct, Counsel?
E j 8 Would you prefer to have this marked as a Board d
d 9 exhibit? We don't mind.
i h 10 MS. ROTHSCHILD: Yes, I think so.
3
{k 11 JUDGE MILLER: All right. Let the record show that p 12 the testimony of Sammy Diab, which has been sworn to and
() 13 subscribed, and the like, on May 18, 1982, ten copies of which l$ 14 have been supplied to the reporter, maybe marked Board Exhibit 2, 2 15 and you may proceed.
j 16 (Board Exhibit No. 2 was w
g 17 marked for identification.)
$ 18 BY MR. MIZUNO:
E 9 19 G Mr. Diab, do you adopt the affidavit of Sammy Diab n
20 as your written testimony regarding the BIT?
21 A Yes, I do .
22
(]) MR. MIZUNO: At this time the Staff would like to 23 move that the affidavit of Sammy Diab be introduced into the 24 record and taken as his written testimony.
(])
i 25 JUDGE MILLER: We'll rule on that after examination, ALDERSON REPORTING COMPANY. INC.
777 -
5-13 1 but we understand you and it will undoubtedly be granted, but we O 2 want to keep our record straight.
3 All right. Now, are there any questions, first of O 4 all, by the parties, and then the Board will have some questions e 5 concerning this matter; Applicants?
A
, n
$ 6 MR. REYNOLDS: Applicants have no questions.
R
& 7 JUDGE MILLER: Intervenor CASE?
A j 8 MR. JORDAN: No questions.
d c; 9 JUDGE MILLER: Very well.
2 c
g 10 BOARD EXAMINATION 5
11 BY JUDGE McCOLLOM:
k g 12 G Just one question, Mr. Diab, a question similiar to Og S m
13 one the witnesses for the Applicant. My concern is the balance l$ 14 between safety and convenience, and could you decribe to me g 15 briefly what you consider to be what if any safety aspects of x
j 16 this are modified or changed and what conveniences, if any, w
17 balance that off, sir? -
x
$ 18 A In the review process we don't necessarily concentrate E
19 too much on convenience of operation. As you might know, our g
n l 20 function is to insure that the plant can be operated safely, and 21 therefore we have a standard review plan in which we have
() 22 acceptance criteria by which we review, and if the plant meets 23 , that acceptance criteria then we consider it safe. And we have 24
(]) reviewed the plant after the change, after the removal of the BIT, i
25 l and it does meet our acceptance criteria, so therefore we
! ALDERSON REPORTING COMPANY, INC.
778
>-14 1, consider the plant is safe without the BIT.
O 2 G So you looked at it only from the safety viewpoint, 3 is that correct?
4 A. Yes, sir.
e 5 0 Was there much of a difference in the margin of 9
@ 6 safety without the BIT? Do you have any knowledge of that, sir?
R
& 7 Is this a case where the safety margin was at one 3
g 8 level and was -- and how was it changed with the removal of d
d 9 the BIT?
$ 10 A Okay. According to the analysis provided to us, the j 11 steam line break with the BIT in place and without the BIT, the is 12
{ margin isn't that great between the two cases.
O!i3 m aowever, I d 11ke to meke 3use one commene on the
! 14 question of convenience. There has been some operational problems g 15 that we knew of from the high concentration of boron, the e
j 16 crystalization of the boron has its own properties us 6 17 and since there are four valves, two downstream of the BIT and 5
{ 18 two upstream of the BIT, and those valves are normally closed.
i:
19 If you should develop a crystallization in any valve
{n 20 during the operation of the plant, which is a normal condition, 21l and if those valves are called upon to be open, actuated, and if O 22 they cannoe secause of crysee111zation, I think this wom1d se an 23 ; unsafe condition. The removal of the BIT would probably avoid
] 24 that kind of a problem.
25 l G Do you have any knowledge or information that this is i
i ALDERSON REPORTING COMPANY INC.
} 779;;
'15 1 in fact a problem at this plant?
O 2 A I don't have any knowledge, except like I mentioned, 3 that those reports of the crystallization of high concentration of O 4 boron have surfaced in the past.
e 5 G All right, sir. You testified that the safety margin M
N
@ 6 was not significantly different between the situation where you
$ 7 have the BIT and do not have the BIT. Did you say that, sir?
N 8 8 A It's not significantly different; however, the steam d
c 9 line break with the BIT removed still meets our safety criteria i
e g 10 with a comfortable margin, and we feel, based on our review of E
j 11 the analysis and of the codes used in the analysis, that the plant 3
y 12 can be operated safely, within the safety criteria with the BIT
() m 13 removed.
! 14 G What safety criteria did you use, sir? Is it some-E jz 15 thing like the nuclear boiling ratio, is that the figuro you used j 16 as the safety factor? If it's not, what?
w
$ 17 A Yes, sir. The safety criteria basis for the steam 5
$ 18 line break are limited to a failure in a small particle density
=
C program, and Comanche Peak meets those safety regulations.
19 g
n 20 According to the analysis, there is no fuel failure.
21 G And the margin above which you meet the safety
() 22 criteria, how much is that changed with and without the BIT?
23 ! A It does not change any, and the reason is the
(]) 24 analysis did not produce any departure from nuclear boiling, 25l meaning it does not go below 1.3, and therefore there is no fuel l ALDERSON REPORTING COMPANY. INC.
l
780' 5-16 1 failure with or without the BIT. And of course, consequently, 2 there's no offsite releases to the steam line break.
3 JUDGE McCOLLOM: Okay. Thank you.
(.-
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781' 6-1 1 g Are those in series with the emergency core c.aoling hot 2 system or are those just part of the BIT?
3 A Those are the two downstream and the two upstream of 4 the BIT.
e 5 G If they were blocked, would it stop the ECCS?
9 3 6 A. If they were blocked, it would stop the ECCS.
R
$ 7 MR. REYNOLDS: Okay. Thank you.
A j 8 JUDGE MILLER: We will have a short recess.
d d 9 (Short recess.)
- i o
$ 10 JUDGE MILLER: -With regard to Mr. Diab, the motion E
$ II to admit his testimony as Board Exhibit 2 will be granted, and is j f I2 the testimony will be incorporated verbatim into the transcript 13 of the record of the proceedings..
l$ 14 (The document previously identified j I5 as Board Exhibit No. 2, was received 16 3l in evidence.)
as I7 Whereupon, the Statement of Ssmmy Diab was incorporated h
IO into the record as if read, as follows:
E 19 g
n 20 STATEMENT 2I OF O 22 SxxMY DI3e 23 ,
O 24 25 !
ALDERSON REPORTING COMPANY, INC.
l e
- i UNITED STATES OF AMERICA flUCLEAR REGULATORY COMMISSION O 8Er0aE TsE ATOMIC SArETv AnD tICENSInG BOAaD In the Matter of TEXAS UTILITIES GENERATING COMPANY, ) Docket Nos. 50-445 ET AL. ) 50-446 (C a he Peak Steam Electric (Application for Operating License)
Station, Units 1 and 2) )
AFFIDAVIT OF SAMfiY DIAB I, Sammy Diab, being duty sworn, do depose and state:
Q.1. By whom are you employed, and what is the nature of the work you perform?
A.1. I am employed by the U.S. Nuclear Regulatory Comission, Division of Systems Integration, Reactor Systems Branch
("RSB"). A copy of my statement of qualifications is attached to this affidavit.
Q.2. What is the nature of the responsibilities you have regarding the Comanche Peak Steam Electric Station ("CPSES")?
A.2. I was the Reactor Systems Branch lead reviewer for CPSES. In this capacity, I was responsible for the safety review of the CPSES Final Safety Analysis Report ("FSAR") Sections 4.6, 5.2.2, 5.4.7, 6.3 and 15.0, in accordance with the corresponding C> sections in the Stenderd Review eient, NuaEs-75<087. Section 6.3 above addresses the design of the Emergency Core Cooling System ("ECCS").
4 I
' s
~
Q.3. What is the subject matter of your affidavit?
A.3. I will address the Atomic Safety and Licensing Board (" Licensing -
O Board > questions reserdins the deietion of the Boron Injection Tank (" BIT"). The Licensing Board requested that the Staff pro-vide the following information:
- 1. A copy of the " Summary of Meeting on Comanche Peak Design Change and Responses to RSB Questions," by S. B. Burw-U dated May 26, 1981.
4
- 2. A description of the system or equipment to be deleted by removal of the BIT.
- 3. The status of the deletion of the BIT.
- 4. The basis for the deletion of the BIT.
- 5. The intended purpose of the system that was being taken out.
O Q.4. Are you familiar with the report entitled, " Summary of Meeting on Comanche Peak Design Change and Responses to RSB Questions,"
by S. B. Burwell dated May 26, 1981?
A.4. Yes. A copy of that report is attached to this affidavit as
[ Attachment 1.
Q.5. Please describe the BIT?
! A.S. The BIT is a 900 gallon stainless steel tank filled with 12%
l l concentration Boric Acid, which is located between the discharge of the centrifugal charging pumps and the injection point into the reactor vessel cold legs. The BIT system is provided with a recirculation loop consisting of a 75 gallon Boron Injection Surge Tank ("BIST"), and two 20-gpm Boron Injection Recirculation
.' 6 Pumps ("BIRPs"). This loop maintains the 12 percent boric acid solution in the BIT at a temperature in excess of the :
O soiu8 titty it it. #8 circuietes the saiutioa to Preve t'coid spots and stratification. In addition the BIT, the BIST and the BIRPs are monitored by instrumentation indicating the system temperature, pressure and flow, and the level in the BIST. Alarms are provided in the control room to alert the operator to any deviations in the system operation. The BIT system which contains the 12% boric acid solution is isolated on each of the two sides (i.e., the charging pump side and the reactor vessel side) by parallel motor operated valves that are normally closed, and which open on a safety injection signal. All the piping, tank's and pump surfaces adjacent to the high concentration boric acid solution are either heat traced or maintained in heated enclocures.
Q.6. What system was the BIT part of?
A.6. The BIT was a component in the high head charging pump system for the Emergency Core Cooling System ("ECCS"). This charging pump system is designed to provide make-up water for core cooling when the reactor vessel (or primary coolant system) pressures remain high.
The system is made up of two centrifugal charging pumps in O parallel taking suction through two parallal motor-operated valves from the Refueling Water Storage Tank ("RWST"). The
.*s RWST contains 450,000 gallons of 2000 parts /million (ppm) boron concentrated water. The two centrifugal charging :
O oum9s are desis#ee to provide iso 99m-e ca or emerseacy 'c ore cooling water at 2500 psig. That is, the high-head pumping system is designed to provide core cooling at high pressures, when lower pressure systems are ineffective. The two centrifugal charging pumps discharge into four 11" lines that inject directly into the four reactor vessel cold legs.
~
Attachment 2 is a schematic of the high-head charging system with the BIT. Attachment 3 is a schematic of the system without the BIT. Attachment 4 is a piping and instrumentation diagram
("PID") of the high-head charging system with the BIT. Attach-ment 5 is a PID of the high-head charging system without the BIT.
f Q.7. How would the BIT be utilized? What was it's intended purpose?
A.7. The intended purpose of the BIT was to limit the power increase following a steam line break event.
The BIT would be utilized any time the ECCS is activated by a Safety Injection Signal (" SIS"). The SIS starts the charging o .
, 6 ,
pumps and causes the four BIT isolation valves to open, thus allowing the emergency core cooling water discharged by the :
O centrifugal charging pumps to sweep the BIT inventory in'to the reactor vessel cold legs, and then into the reactor vessel.
The following is a scenario that delineates the operation of the BIT. For a steam line break, the excessive RCS cooling leads to the primary coolant shrinkage. As a result the pressure in the RCS drops to the point that SIS is initiated and the BIT boron-concentrated inventory is introduced into, the RCS. The RCS cooling that caused the RCS pressure drop, also adds positive reactivity to the core effecting a power increase. Since the boron-concentration inventory of the BIT adds negative reactivity to the RCS, the net effect of the BIT is to limit the power increase following an excessive cooling accident.
Q.8. What is the basis for the BIT deletion?
A.8. The Applicants have submitted for Staff review an ECCS design change deleting the BIT. The supporting evaluation submitted by the Applicants for the BIT removal while the BIT provided additional shutdown margins in the form of negative reactivity through the 12% boric acid solution, this additional shutdown O -
' s
. s
~
margin was taken credit for only in the steam line break analysis. With conservative system assumptions in the steam .
O line break analysis the removal of the BIT does not change the analysis results significantly, nor does it violate any safety criteria. The Applicants calculated, for a large steam line break accident without the BIT, a Departure from Nuclear Boiling Ratio "(DNBR)" of about 2.5, which is well above the safety limit of 1.3. Consequently, no fuel failure will result from a steam line break with no BIT, according to the Applicants' calculations. However, the Applicants' FSAR conservatively -
assumed 1% failed fuel initially and an additional 5% fuel failing after the steam line break accident for the purpose of maximizing offsite dose calculations. Those doses were calculated to be a small fraction of the 10 CFR 100 limits.
Since the BIT deletion did not cause a violation of any safety limits,theStaffhasfoundthatdeletiontobeaccegable. y Q.9. What components or equipment are deleted when the BIT is deleted from the CPSES ECCS?
A.9. Components between the two upstream isolation valves and the two downstream isolation valves, except for the 4" pipe O -
connecting the two sets of valves, are to be removed. The upstream isolation valves are either locked-open or removed. -
O The heet trecins is eise removed. See Attachmeats 3 and S for .
schematics of the high-head changing system without the BIT.
Q.10. What is the status of the Staff's review and evaluation of the BIT removal?
A.10. The Staff has completed its review of the BIT removal and has found it acceptable for CPSES, as stated on page 4-21 of the Safety Evaluation Report ("SER") for CPSES: ,
The applicant has proposed deleting the concentrated boron injection tank (BIT). Although this is a change from previously approved Westinghouse designs, the applicant has shown that removal of the BIT will not result in any unacceptable transient or accident analysis results.
Q The staff concludes that the designs of the reactivity control systems conform to all applicable regulations and are acceptable.
The Staff concluded the CPSES has an acceptable ECCS design as shown in the Safety Evaluation Report ("SER") and Supplement 1 for CPSES. The Staff had previously concluded that removal of the BIT was also acceptable for the Turkey Point plant, units 3 and 4.
Q.11. Will the BIT deletion affect the ability of the CPSES to operate safely?
O A.11. No. As explained in my Answer to Question 8, removal of the BIT will not affect the ability of CPSES to operate Safety.
The Staff's safety evaluation of the CPSES ECCS is shown in the SER and Supplement 1 for CPSES.
Q.12. What is the construction status of deletion of the BIT?
A.12. The Applicants advise that it is bypassing the BIT in Unit 1, .
leaving the BIT unconnected and in place. The PIT will not be
(}) .
installed in Unit 2.
i The above statements and opinions are true and correct to the best of my personal knowledge and belief.
SAftMY DIAB Subscribed and sworn to me this day of May, 1982.
O Notary Public My Commission expires:
O -
. ~- . :. -
' STATEMENT OF PROFESSIONAL QUALIFICATIONS SAMMY S. DIAB 9 I am a Nuclear Engineer in the Reactor Systems Branch of the U.S.
Nuclear Regu'latory Commission (NRC).
In this position, I am responsible .
for the technical analysis and evaluation of reactor systems, accidents and transients, and applications for nuclear reactor operating licenses.
I have been in my current position since 1980.
From 1978 to 1980, I was a reactor systems reviewer in the Reactor .
In that position Safety Branch, Division of Operating Reactors of the NRC.
my responsibilities included: systems analyses, accident and transient ,
analyses, and reload applicatien reviews.
From 1977 to 1978, I was a Nuclear Engineer in the Engineering In that Methodology Standards Branch, Office of Standards of the NRC.
position I was responsible for updating and revising the standard review plan. I developed Regulatory Guide 1.139, " Residual Heat Removal Guidance",
and Regulatory Guide 1.141, " Containment Isolation Provisions for Fluid Systems".
From 1973 to 1977, I"was a Nuclear. Engineer with Bechtel Power I was responsible Corporation, Gaithersburg Power Division, Maryland.
for reactor containment pressure and temperature analyses following a spectrum of high energy line breaks, jet impingement calculations, and I developed and used computer codes.
subccmpartmen't' transient behavior.
I also modified existing computer codes.
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.- From 1971 to 1973, I was a research assistant with the Nuclear Engineering Department of the Pennsylvania State University. In 1974 ,
i I was awarded a M.S. degree in Nuclear Engineering from Pennsylvania I .
L State University.
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From 1967 to 1971, I was a researcher with the Egyptian Atomic -
Energy Establishment. I received my B.S. degree in Nuclear Engineering -
e
- from the University of Alexandria, Egypt.
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- pa ascg 0, UNITED STATES
[ Y, s , , }, NUCLEAR REGULATORY COMMISSION '
s E WASHINGTON,0. C. 20555
,s %nys
.. [. .* MAY 2 6 1931 O ~
Docket Nos. 50-445 -
and 50-466 -
APPLICANT: Texas Utilities Generating Company FACILITY: Comanche Peak Steam Electric Station Units 1 and'2
SUBJECT:
SUMMARY
OF MEETING ON COMANCBf PEAK DESIGN CHANGE AND RESPONSES TO RSB QUESTIONS Summary A meeting was held at NRC Headquarters, 7920 Norfolk Avenue,-Bethesda, Maryland on Tuesday, March 10, 1981.' The purpose of the meeting was to permit Westinghouse to brief the NRC staff on a proposed design change to eliminate the boron injection tank from the emergency core cooling system, and to discuss information submitted in FSAR Amendments 14 and 15 on baron dilution transients -
and responses to Reactor Systems Branch questions. Attendance at the meeting is listed in Enclosure 1.
Meeting Details
~
The applicant opened the meeting by advising that FSAR Amendment 16 to be submitted March 31, 1981 will show the proposed deletion of the boron injection tank from the emergency core cooling system. Comanche Peak will ba the first Westinghouse reactor to be licensed withcut the boron injection tank. However the concept has been reviewed on RESAR 414, Byron-Braidwood and South Texas.
G. Narasimhan, Westinghouse, ga/e the first part of the presentation on the deletion of the boron injection tank using the slides identified as Boron Injection Tank Removal, Enclosure 2. This presentatier . reviewed the impact i of deleting the boron injection tank on Westinghouse pcwer reactors in general.
l The steam line break is the only design basis accident (Chapter 15) for which credit is taken for the boron injection tank. The presentation concentrated on the response of the' nuclear system to a steam line breik with.and without the boron injection tank.
F. Thomson, Westinghouse, gave the second part of,the presentation using the slides identified s Comanche Peak Baron Injection Tank, Enclosure 3. This presentation revit:.ed the impact of deleting the boron injection tank on Comanche Peak. Again, the presentation concentrated on the steam line break Q accident with and without the boron injection tank. ' Comparison of the transient response shows that core power becomes essentially the same with and without the boron injection tank in about 300 seconds.
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The applicant described the removal of the boron injection tank'as an operational
- Q advantage, using FSAR Figure 6.3-1 Sheet 1 to illustrate the auxiliary equipment needed to support the boron injection tank. .
The second part of the meeting started with a presentation by V. Koch, Westing-house, on the design modification responding to the boron dilution transients using the' slides identified as Inadvertent Boron Dilution, Enclosure 4. The presentation' tracked the earlier Westinghouse presentation given at the meeting of October 15, 1980. The staff raised questions about the administrative controls on valves within the chemical and volume control system which were resolved in the discussion. The staff raised questions on how the electrical controls of these valves tie into the instrumentation and control drawings and the impact of control failures on system performance. The applicant will p'rovide additional information on these matters.
The last part of the meeting consisted of a discussion of the applicants responses to Reactor Systems Branch questions. Of the 51 questions issued in our letter of November 20, 1980, the applicant has responded to 40 questions in FSAR Amendments 14 and 15. The applicant expects to respond to 9 more in FSAR Amendment 16 at the end of March, and the remaining 2 in April. We i discussed the applicants responses to several of the questions. In most cases the discussion resolved the matter. The applicant agreed to revise the response to' Question 212.96(f) to clarify the consideration on decay and plate-out.
l ] The applicant also advised it is revising the low pressure overpressure protection 3, stem. ,
5/ / c -+.
S. B. Burwell Licensing Project Manager Licensing Branch No. 2 Division of Licensing
Enclosure:
As stated cc w/ enclosures:
See next page l
1
fir. R. *. *u.;
Execu+4"a "' a Deesident and Generai F*e na wer Texas '.9-' : 0:n r: ting C :pany 2001 Bryan T .e. :
Dallas, 7c.;; 75201
({])
- 'H:h:!:: S. o.eyn !ds, Esq. Mr. Richard i enuta -
Debavnica A Liberman Citizens for Fair Utility Regulation 1200 Seventeenth Street 1668-B Carter Drive Washinoton, D. C. 20036 Arlington, Texas 76010 Spencer C. Relyea, Eso. Resident Inspector /Lemanene Peak Worsham, Forsythe & Sampels Nuclear Power 5:ation 2001 Bryan Tower c/o U. S. hucieni Regulatory Commission Dallas, Texas 75201 P. O. Box 38
, Glen Rose, Texas 76043 Mr. Homer C. Schmidt Manager - Huc1 car Services Texas Utilities Services, Inc.
2001 Bryan Tower Dalias, Texas 7523; Mr. H. R. Rock Gibbs and Hill, Inc. '
393 Seventh Avenue "ew York, New York 10001 O Mr. A. T. Parker Westinghouse Electric Corporation P. O. Box 355 Pittsburgh, Pennsylvania 15230 David J. Preister Assistant Attorney Genaral Environmental Protection Division P. O. Box 12548, Capitol Station Austin, Texas 78711 Mrs. Juanita Ellis, President Citi: ens Association for Sound l
Energy 1425 South Polk Dallas, Texas 75224 Geoffrey M. Gay, Esq.
West Texas Legal Services 100 Main Street (Lawyers Bldg.)
Fort Worth, Texas 76102 O .
0
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___l______
ENCLOSURE 1 :
ATTENDANCE LIST FOR MARCH 10, 1981 MEETING COMANCHE PEAK STEAM ELECTRIC STATION, UNITS 1 AND 2 Texas Utilities Services, Inc. NRC Staff F. Madden S. Burwell J. Shrewsberry Hulbert Li T. Dunning Westinghouse C. Rossi J. Guttman D. Popp S. Diab G. Narasimhan D. Shum R. Steifler Chang Li F. Thomson V. Koch EG&G M. Torcaso S. Bruske Gibbs & Hill S. Kumar
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BORON INJECTION TANK REMOVAL O .
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- LOCATED IN THE ECCS l
- CONTAINS 12% BORIC ACID SOLUTION l
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- flTLE PAGE !
08 P ROJE CT AuTMCA CATE CME"O. S v QATE CM E 0. S v QATE S 0. CA LC. NO. FILE NO. Gmoup O -
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WHY IS THERE A BIT ?
- CONSERVATIVE DESIGN FEATURE FROM PAST YEARS
- SIZING OF THE SHUTDOWN MARGIN
- BIT AT 12". TO BE COMPATIBLE WITH THEN CURRENT CVCS SYSTEM i
LOCATION IN ECCS SYSTEM NATURAL AND APPROPRIATE PROVIDES BORIC ACID SOLUTION FOR A STEAMLINE BREAK EVENT O .
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NEGATIVE MODERATOR TEMPERATURE COEFFICIENT CAUSES POSITIVE REACTIVITY INSERTION REDUCTION IN CORE SHUTDOWN MARGIN j
l POTENTIAL FOR CORE TO BECOME CRITICAL AND RETURN TO POWER I
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- CORE POWER WILL SEEK A LEVEL B0UNDED BY STEAM LOAD DEMAND O -
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STEAMLINE BREAX CONCERNS
- FUEL AND CORE INTEGRITY i
CONTAINMENT INTEGRITY
- 10CFR20 #1D 10CFR100 DOSE LIMITS G -
2-15
, 5 ACCEPTANCE CRITERIA FOR STEAMLINE BREAK O .
LICENSING CRITERIA
- MEET DOSE LIMITS FOR SPECTRUM OF BREAKS
- CONTAINMENT PRESSURE LIMIT WESTINGHOUSE INTERNAL CRITERIA
- SHOW ONBR > 1.3 FOR SPECTRUM OF BREAKS
( ,
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- WITHOUT A BIT THE CONDITION II BREAK MAY RETURN TO A LOW POWER LEVEL i
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CONCLUSIONS
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4 BOUNDING ASSlWTICNS O .
EOL SHlIIDOWN MARGIN MOST EETIVE RCC STUCK - RJLLY WITHDPAWN
[9XIFUi FEEDEACK PHYSICS PAP #ETES (E00 MINIM SAFEGJARDS MAXIFUi AUXILIARY FEEDWATS FLOW TO FAULTED LOOP MINI M AUX FEED TEMPEPATURE MAXIFifi STE#i GENEPATOR HEAT TPANSFER NW-BOPATED WATER IN RJEE LINES EWIR0ffENTAL ERRORS O -
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0 300 - 200 200 =0 s00 .00 TIME (SECON05)
TMNSIUS ESPONSE SFALL BEAK (CmDITION 11}
3-9 WINN BIT l
Y 2500 l [ ] l ,
RCS PRESSURE 1
(PSIA) 1500 - - -
500 - ; ! l
.10 l l STEAM FLOW (FRAC. OF NOMINAL) .05 - - --
O _
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P CORE BORON '
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TIME (SECONDS) ,
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0 200 400 600 TIME (SECONDS)
O l#EE BEAK ,
'WITH BIT 3-12
L e a._ _ _ _ -. A 4
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4 200- - --
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NRC GITERIA l
CmDITION II/IV + 100%0/10CFR100 CORE INTEGRITY FOR ALL CASES, WITH OR WITH0lK BIT DNBR "1.3
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t O NO RJEL FAILURES CONTAlfMNT INTEGRITY W/ BIT W/0 BIT AK TEMP (*F) 333 334 EAK PS (PSIA) 37.5 37.5 0 -
ALL SAFETY CRITERIA MET 3-16
EllCLOSURE 4 INAINERETMON DIWTION :
O
~
C0PANDE PEAK FSAR SECTION 15A.6:
IEWS AND CVCS OPEFATION AND FAILURE N DES
- SYSTEMHARDWAREMODIFICATIONSTOADDRESSREG, GUIDE 1,70 REV. 2 REWIREENTS ANALYSIS ASSLIPTIONS AND RESULTS O .
e e e O -
4-1
9
- I ESCRIPTION OF ACCIDENT INITIATION -
- O .
- l RM/CVCS FAILUE EDES:
D VALVE El.ECTRICAL OR MEOMNICAL FAILUES
- 2) MAEUP CONTROLLER FAILURES
- 3) OPEFATOR INITIATED FAILUES ESULT IS INCEASED 19EllP FLOW AND/0R DECEASED BORIC ACID FLOW O .
OPEPATOR HAS SEVEPAL INDICATIONS AVAIL #E TO HIM TO VERIFY CHANGE IN STATUS OF RCS MAEUP O -
4-2
t
. i ANALYSISASSLNPTIWS .
O -
l ANALYSIS COVERS ALL IT0ES OF OEPATION AS DEFItED BY SIS
- CONSERVATIVE ASSLIPTIONS PADE FOR BORON CONCENIFATIONS, BORON WORTHS, SRfiDOWN MARGINS, #0 RCS VOLLES .
DIUJTION PATE LIMITED BY ADMINISTPATIVE CONIPDLS WHILE RCS IS DEPRESSURIZED.
l O
DILUTION PAE LIMITED BY CHARGING PLW CAPACITf WITH RCS AT PRESSURE l .
I o .
4-3
~ ' ~ ~ ~
_ _ _ _ _ - . _ _ _ _ _ _ _ _ - . ___..-. _ I l~l - " I - ~ ~ ~ ~~ ._ - -- __ _ LI .~ ~ l~_ _ _
i ERJEl.ItG O DIlllTICN PEC110ED BY AmINISTPATIVE C0fmd.S WHICH ISOLATE RCS FM (JNB0 RATED PAELP WATER COLDSED0hN MINI M S M DOWN PARGIN OF 1% W K MOST LIMITItE WHEN RCS WATER LEVEL DPAIED TO MID-f02ZLE WHILE ONRHR PAELP FLOW RESTRICIED TO 150 CE FOR THIS CASE O .
HOTSMDOWNANDHDTSTN0BY MINI M S M DOWN MARGIN OF 1.6% W K POST LIMITING kHILE ON CtE TPAIN 7 RHR WITH RCS FILLED AND WNTED MAXIM EMISSIBLE MAEl)P FLOW PATE IS IGS GPM (ND ESTRICTIONS ECESSARY FOR CTAf0E PEN 0 -
O -
4-4 9
t STARRP O, -
MINIM SMEN MARGIN F 1.6% 4'/K AU. 4 RCP'S QUATIE DIUJTION FLOW LIMITED BY CAPACITY OF TWO 0%RGIE RNS ,
RJLL RCS VOUfE MINJS PRESSURIZER ASSHD AVAILABLE FOR DIUJTION POW 2 OPEPATION DIUJTION Fl.0W LIMITED TO MAXIM LEIDChN FLOW WEN IN i O, NATIC PESSURIZER I.EVEL ONROL l
1 DIURION FLOW LIMITED BY MAXIM 0F 2 OMRGIE RMS IN OPEPATION WEN IN MANJAL PRESSURIZER LEVEL CONTROL @ST LIMITIE) l 0 -
4-5
l, .
- s RESULTS T # % LYSIS .
O .
CDU) SHJTDOWit HDT SRHDontt HOT ST#0BY
- SOURCE RNEE NIS, BY WAY T A MICF0 PROCESSOR., It01 CATES DOUBLIfE T fEUTRCN FUJX DUE 10 DIUJTION ALAFM ALERTS TE CEFATOR TO A FUJX DOUBLIfE CVCS #NATICALLY REALIGNED TO SWITCH SJCTION FRCN VOUM C0tifROL TANK TO RWST (CLOSE VALVES 1-LCV-112B NO C, OPEN O VALVES 1-LCV-112D NO E IN THE CVCS)
THIS MMATIC ACTION MINIMIZES THE AFFROACH TO CRITICALITY
- 0 REGAINS LOST SHEDChN PARGIN Q .
4-6
..~
SIE :
~
OPEPATOR INTENTIONALLY DIllflES IN THIS K!DE TO GO TO POWER IN TE EVENT T M INADVERIEhT DIllITION WHILE ESCALATING IN POWER, THE PLANT TRIPS ON TE LW SETPOINT OF FGER RANGE l HIGH fETIR m FLUX OPEFATOR HAS > 15 MIfCTES FRm TRIP TO PATUALLY TEPINATE DILUTION AND INITIATE B0 RATION BEFORE Cm PLETE LOSS m SHI1DC%NYARGIN O
e l
l 4-7
POWER MAtijAL E CONTROL:
O _
TIE EACTIVITY EXOJRSION ESJLTS IN EACTOR TRIP ON OWRTEMPEFATUE N-16 OPEFATOR HAS > 15 MIfUIES F M TRIP TO TEFMINATE DILUTION ANDINITIATEB0PATION THIS TRANSIENT BOUNDED BY UtM:fPOLLED RCD WITHDPAWAL AT POWER TRANSIENT AUTCf% TIC E C0tifROL:
CPEFATOR ALERTED TO DIUJTION BY f0D INSERTION UMIT ALARMS
~> 15 MIMITES IS AVAILABLE FiDi ALAINS FOR OPEPATOR TO TEININATE DIUJTICN AND INITIATE B0FATION 1
0 -
4-8
=
CONCl.llSI0f6 .
O .
IN ALL MODES T OPEFATION, AN IfMIMENT DIURION IS PE0JJDED, llTO- -
MATICALLY lERMIfMTED, OR TERiltMTED BY OPEFATOR ACTION TE REACTOR IS BROUGHT TO A STABLE C0f0lTICN WITH TE LOST SHJTDOWN MARGIN REGAltED, O
O -
l 4-9
COM A. JHE PEAK' REACTOR MAX JP' SYSTEM ,
( 'A < R.C. FILTER o f % -
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k DECEMBER 21* 1981 EM f". D ef G B
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. l 782 l 6-2 1 JUDGE MILLER: Now, before we permit him to step down, v 2 I am assuming that no Counsel has any further questions of him?
3 MR. JORDAN: I did have one or two.
4 JUDGE MILLER: Go ahead. Now that you're being heard.
'2 5 RECROSS-EXAMINATION h
3 0 BY MR. JORDAN:
$ 7 g Mr. Dieb -, you said that you based your conclusions s
y 8 on the -- that according to the analysis presented to us or rJ ci 9 provided to us, I take it that the NRC did not do an independent 10 analysis?
h
=
I is II A No, it did not.
g 12 g Do you know of any analysis as to the valve malfunctica 13 by crystallization?
l5 14 A Yes. I know of some reported crystallization. I g 15 don't know specifically which plants. Or which valves.
x 16 ii 0 You do know of some crystallization?
us I7 A Yes.
x I0 f
i g Do you know whether crystallization c&use. the valve 19 j not to function or whether it's just crystallization that 20 happened to be there?
21 A No, that crystallization just happened to be not' .
22 O heeted in emough area.
23 The crystallization was not heated enough beyond the 24 point that the solubility of the boron so12 tion,i .,
g AnEl there was crst'allization y but to your knowledge i ALDERSON REPORTING COMPANY, INC.
i 6-3 783' 30P 1 there were no valves that were actually prevented 2 from operating properly?
3 A That's correct.
4 MR. JORDAN: That's all.
5 JUDGE MILLER: Thank you.
$ 6 You may step down.
R b 7 (Witness excused.)
s y, 8 JUDGE MILLER: Anything further now on BIT?
d c; 9 (No r(sponse.)
$ 10 JUDGE MILLER: Do you want the witness excused?
3
=
II 4 MR. REYNOLDS: Yes. The Staff would like to request iit g 12 he be permanently excused.
c
- j. 13 JUDGE MILLER: If anybody objects to his being b I4 excused now -- you are not sure of seeing him again.
ba:
(No response.)
6 il[ JUDGE MILLER: Very well. You may be excused.
a5 h Thank you, Mr. Diab.
b 18 MR. REYNOLDS: Mr. Chairman, does that likewise apply E
g I9 to Applicants' witnesses on this issue?
n 20 JUDGE MILLER: Pardon me?
2I MR. REYNOLDS: Does that likewise apply to 22 Applicant's witnesses?
23 l JUDGE MILLER: Not unless you request it. I just 24 permit them to step down.
MR. REYNOLDS: We request that our witnesses on BIT ALDERSON REPORTING COMPANY, INC. l l
784.. ,- ,
1 6-4 1 be discharged from the proceeding.
2 JUDGE MILLER: Is there any objection?
3 MR. MIZUNO: The Staff does not object.
O 4 MR. JORD^u= No chsection.
o 5 JUDGE MILLER: Very well. The witnesses produced by b
$ 6 the Applicants will likewise, then, be excused.
R
$ 7 MR. REYNOLDS: Mr. Chairman, does the Board wish us s
j 8 to supplement the record with that DNBR ratio number?
d d 9 JUDGE COLE: Yes. I'd like to have it.
10 JUDGE MILLER:
g If you can, yes.
11 Anything else?
in 12 (No response.)
N Ta Oi1 JUDGE MILLER: All right, then. That concludes the b I4 furnishing of the information that was requested by the Board 15 with reference to the boron injection tank matter, i[ I6 ul We come now to the presentation of testimony and I7 evidence by Applicants and Staff.
h
$ 18
_ Have Counsel had an opportunity to give any further E
I9 8
e thought to the Board's request to proceed first and, perhaps, out 20 of order, if that be the result, with the questions revolving 21 around the cracks.
Q MR. REYNOLDS: We believe it is the best course to 23 '
proceed immediately with those two issues; the one involving Q the excavation at Comanche Peak and the second involving the 25 shrinkage crack in the cavity wall.
ALDERSON REPORTING COMPANY. INC.
l 785 1 JUDGE MILLER: Are the Applicants prepared to go 2 forward with evidence or testimony on that sub pct at this time?
hop 3 MR. REYNOLDS: Yes, sir.
4 JUDGE MILLER: Very well.
e 5 Staff?
h
@ 6 MS. ROTHSCHILD: Yes, we are.
R
$ 7 JUDGE MILLER: Very well.
A j 8 And Intervenor?
O ci 9 MR. JORDAN: I'm afraid that I understood that the
$ 10 testimony would involve the cracks.
3
$ Il JUDGE MILLER: The Board doesn't know, of course.
is f 12 We're going now on the evidentiary record that is being made.
OlI3 We do not xnow whether the overdreak gettern has or has noe -
l$ 14 logical relationship to the question involving the two different 15 cracks.
x ij 16 Therefore, we're prepared to proceed with the crack,
- ri I7 if it's involved and may be addressed in that fashion.
h x
M 18 It it's not, of course, leave it for development when 19 j we resume the normal presentation of evidence.
l 20 Do we have any problem in that connection?
21 (No response.)
22
- j. JUDGE MILLER: I guess not.
23 j MR. REYNOLDS: Let me understand.
O Is that to say that you don't wish to receive evidence 25 at this time on the overbreak question?
ALDERSON REPORTING COMPANY, INC.
l ,. .
6-6 786 hop I JUDGE MILLER: We don't know. '
2 MR. REYNOLDS: We would propose to go forward with 3 that panel first.
O 4 MR. JORDAN: I understood the soerd wented the creck e 5 in the newspaper recently to be first.
5 h 6 JUDGE MILLER: Well, we're not doing it because it's R
b 7 in the newspaper recently, close quotes. That matter was presented 3
j 8 to the Appeal Board by one of the parties and so we discussed d
9 the matter in terms of two clleged cracks, whatever they may be o
10 ~
h and in connection with whatever. We're not trying to judge it at
=
II
$ all.
E fI c
Our purpose was to break out the testimony on those O l I3 two matters, so far as we could, out of order, if you regard E 14 w it that way or, perhaps, in order. I don't know but we wanted to 2 15 g address them directly and permanently and promptly.
16 2[ Now, I understand that the Applicants are prepared w
hI x
to do that. The Staff is and I take it you are prepared to cross-M 18
= examine, at any rate and you'll make a decision later about what
- 19 g your evidence may or may not be.
n 20 Is that correct?
2I MR. JORDAN: Yes,that's correct. We're calling our 22 own witnes. I used the newspaper refernce only for identification 23 purposes and there are, I-think, two distinct issues. The crack 24 and the overbreak and if the Board doesn't know exactly, we 25 l certainly don't know, and if it is possible to proceed with that - -
I l
ALDERSON REPORTING COMPANY,INC. '
787 6-7 -
JUDGE MILLER: We don't know.
O hop MR. JORDAN: We would like to go ahead with the crack.
3 We are not prepared to go ahead with the overbreak right.at the.
O 4 moment.
ic 5 We're taking this out'of order.
$ 6 JUDGE MILLER: The overbreak alone, but you are R
h7 prepared to go with the overbreak insofar as it has any reasonable j 8 relationship to the crack or cracks; is that right?
U s.
ci 9 MR. JORDAN: Yes; '
b g 10 JUDGE MILLER: All right.
E j 11 I think that's the context in which we discussed it..
! is y 12 Do we have any problem there?
Q m 13 MR. REYNOLDS: Well, my thought was that you l$ 14 discussed the base matterifirst, the escavation first, so that i
2 15 that facts are clear and the distinction-is made between the base N
g 16 mat- for the containment and the wall which we're discussing us
~d 17 which has this shrinkage crack in it.
Di 18 I thought from a factual and chronological standpoint k 19 it would be better to talk about the excavation, then the R
20 subsequent construction.
I 21 JUDGE COLE: Mr. ic d.sr is it your concern that you 22 don' t have your witness ready to testify on that or are you 23 prepared to work with the Applicants' witnesses on this topic?
24 Because it appears to,me that, notwithstanding whether 25 ! it's quality assurance or what, that if there is a crack there, ALDERSON REPORTING COMPANY, INC.
1 iB8' 6-8 1 then we need to know why it was caused and there's a real hh 2 possibility that it could be coupled to the evidence that will be 3 presented on the overbreak.
i Q 4 MR. JORDAN: I think what the logic of -- if there is y 5 ind'ed e a connection, the logic would be to follow the story 9
@ 6 chronologically. In effect saying, is this the case? We did do, R
e S 7 an excavation and that these cracks somehow resulted from that M
k 0 or are related to that. That makes sense.
O ci 9 Our problem is with the handling of the overbreak
$ 10 and quality assurance matters related to that, that particular aspect of it that we want to wait on.
N I2 Now, I do want to make clear, it's not that we have a 25 Q 13 slew r,' witnesses on it or people who will be working with the
@ 14 docaments, especially from the Applicants and the Applicants and 15 Staff witnesses --
E I0 JUDGE MILLER: I don't see where there's a problem, as I7 frankly.
!B 18 .
v ..? . .. -.v.
- MR. JORDAN: Why don't we just put on our panel on 19 r ck overbreak and proceed?
rock 8n 20 JUDGE MILLER- ' You' re ' going' tci pub y~our panel' on with 2I reference to ' the~se' matters of the two di'ffererit' cracks that have I
2
Q beer. alluded to.
23l MR. JORDAN: Have we got to produce a relationship i
24 between the two --
25 JUDGE MILLER: I don't know. I don't know.
I
, ALDERSON REPORTING COMPANY, INC.
789?
1 The Board has asked to put on the evidence as it is evolvin;.
,6-9 2 None of the preceding matter, discovery-wise, is part of the hop 3 Board's records, so we can't say one way or the other. We must 4 leave it to Counsel and witnesses.
g 5 MR. REYNOLDS: Applicants call Mr. Raymond C. Mason, 3 6 Mr. John T. Merritt, Jr., Mr. Kenneth L. Schepple, Mr. Ralph E.
R
& 7 McGrane and Mr. Ronald G. Tolson.
A j 8 JUDGE MILLER: Will the panel please rise?
d d 9 Whereupon,
$ 10 RAYMOND C. MASON E
II called as a witness by Counsel for the Applicants, having first g 12 been duly sworn by the Chairman, was examined and testified as 13
- a follows:
E 14 w Whereupon, 15 ;.J,OHN T. MERRITT, Jr.
j 16 called as a witness by Counsel for the Applicants, having first us
'd 17 been duly sworn by the Chairman, was examined and testified ws 5
$ 18 follows:
E g I9 Whereupon, e
20 KENNETH L. SCHEPPLE 21 called as a witness by Counsel for the Applicants, having first 22 been duly sworn by the Chairman, was examined and testified as Q
23 follows:
24 s J 25 !
ALDERSON REPORTING COMPANY. INC.
6-10 790 hop 1 Whereupon,
( 2 RALPH E. McGRANE 3 called as a witness by Counsel for the Applicants, having first
() 4 been duly sworn by the Chairman, was examined and testified as i
e 5 follows:
b 3 6 Whereupon, 7
RONALD G. TOLSON A
j 8 called as a witness by Counsel for the Applicants, having first d
d 9 been duly sworn by the Chairman, was examined and testified as o
10 gg11gyg, h
=
II
$ JUDGE MILLER: Be seated.
W hI Let's see if those mikes are working now. We've S
() j 13 had a lot of trouble over there.
E 14 W Be sure that you're looking directly towards the 2 15 w
x maike and, hopefully, toward the Board, after you've heard the
! 16 g question and speak directly into the mike because we've been d 17 w having a little bit of a problem but I think you'll come through m
M 18
= all right.
- 19 g Pass the mikes between and among you as seems M
20 appropriate.
21 Counsel, you may proceed.
22 DIRECT EXAMINATION 23 BY MR. REYNOLDS:
24 4 Mr. Mason, please state your full name, title and
/]}
25l business address.
ALDERSON REPORTING COMPANY. INC.
!' jgt.]
r.
I BY WIT';ESS MASON:
2 A. My name is Raymond C. Mason. I am Chairman of the 3 Board and Prinicpal Engineer of the firm of Mason,..Johnston.and O 4 Associates, Incorporated. Our aadress is 23s Market Avenue, g 5 Dallas.75203. .
Il
$ 6 G Sir, did you prepare a statement of your educational R
b 7 and prcsfessional qualifications for use in this proceeding?
A j 8 BY WITNESS MASON:
d d 9
, A. Yes, I did.
?-
10 g h Do you have a copy of that document before you?
=
II
$ BY WITNESS MASON:
is II N A. I do.
o G Are there any additions or corrections you vish to I4 make te it at this time?
BY WITNESS MASON:
~
'- 16 j A. No. It is correct.
'd 17 w G Do you adopt it as part of your testimony in this x
$ 18
= proceeding?
19 l BY WITNESS MASON:
20
- a. I do.
21 MR. REYNOLDS: Mr. Chairman, we request that Mr.
22 O. Mason's statement of educational and professional qualifications 23 be marked for identification as Applicants' Exhibit 16 and be Q received into evidence at this time.
JUDGE MILLER: It will be so marked.
ALDERSON REPORTING COMPANY,INC.
792~
i Is there any objection to receiving the statement of g
2 qualifications into evidence?
hop E MR . . JORDAN: I don't exactly have an objection but j
4 I haven't receised a copy of it.
5 JUDGE MILLER: Well, we'll wait until they give you l 6 a copy.
R
& 7 Cindy, do you have a copy?
s j 8 MR. JORDAN: I have one.
O C 9 JUDGE MILLER: All right.
$ 10 Is there any objection to Applicants' Exhibit 16?
E II Does Counsel wish to request voir dire at this time?
is f 12 MR. JORDAN: No, sir.
O! 13 aooos aIttra: Then* rou.
l$ 14 Any other objections or request for voir dire?
{x 15 (No response.)
j 16 Judge miller; Hearing none, the Applicants' Exhibit 16 ,
d i I7 the statement of qualifications and experience of Mr. Raymond C.
h x
M 18
_ Mason will be received into evidence and may be incorporated along 19 y with his testimony in the transcript.
0 (The document referred to was marked 21 Applicants Exhibit No. 16 for O taeatiricetioa ena wee receivea ia 23 , evidence.)
' ~
O '
25 : ,- . ,-- . , ', '
ALDERSON REPORTING COMPANY, INC.
6
'7,79,3 lb 5~1# 1 BY MR. REYNOLDS:
ho() 2 % Mr. Merritt, please state your name, title and 3 business address. 1
() 4 B Y WITNESS MERRITT:
l e 5 A My name is John Merritt. I am Manager of Engineering j 6 and Construction, Comanche Peak Steam Electric Station.
R E 7 G Sir, did you prepare a statement of your educational A
9 8 M and professional qualifications for use in th is proceeding?
d k 9 BY WITNESS MERRITT:
10 h A Yes, I did.
=
11 Do you have a copy of that before you?
3 12 BY WITNESS MERRITT:
N o
Q ym 13 A Yes.
l$ 14 g Do you have any additichs"or corrections you'd care 15 to make to it at this time?
E I6 BY WITNESS MERRITT:
M I7 A None.
t IO G Is it true and correct?
E 8 BY WITNESS MERRITT:
n A It is correct.
21 G And do you adopt it as part of your testimony in this O eroceeat=92 23 ' BY WITNESS MERRITT:
() A Yes.
25 ! '
ALDERSON REPORTING COMPANY, INC.
6-k5 :7S 4 hop I MR. REYNOLDS: Mr. Chairman, we request that Mr.
O 2 Merritt's statement of educational and professional qualifications 3 be marked for identifidation as Applicants Exhibit 17 and 4 received into evidence at this time.
5 g JUDGE MILLER: It will be so marked.
] 6 Is there any objection or questions?
R (No response.)
n -
9 8 N JUDGE MILLER: Hearing none, the Applicants Exhibit d
6 9
.j 17, the qualifications of Mr. John T. Merritt, Jr. will be 0 10 y admitted into evidence and associated with his testimony by 15 11 g incorporation directly into the transcript.
d 12 i5 (The document referred to was marked 3
13 O
v @- Applicants Exhibit No. 17 for E 14 g identificaticn and was received in 2 15 g evidence.)
y 16 JUDGE MILLER: You may proceed.
c,5 I7 BY MR. REYNOLDS:
h a:
IO b G Mr. McGrane, please state your name, title and E
39 g business address.
O BY WITNESS MC GRANE:
I A. My name is Ralph E.McGrane. I am Assistant Chief of 22 O ,,,,,,,,,1 z,,1,,,,1,, ,,,c1,,, ,,,a111,.1,,,,,,,,,,,. 3,3 23 Seventh Avenue, New York, New York 10001.
O a oid you grevere e seeeemeae or your eaucetioae1 25 !
! and professional qualifications for use in this proceeding?
I ALDERSON REPORTING COMPANY, INC.
' 7 9 5' ,
6-15 1 BY WITNESS MC GR7.NE:
hch 2 A I have.
3 g Do you have a copy of that document before you?
4 BY WITNESS MC GRANE:
e 5 A I do.
b 3 6 O Are there any additions or corrections you'd like to R
b 7 make to it at this time?
A j 8 BY WITNESS MC GRANE:
O d 9 A No, sir.
2.
10 g Is it true and correct?
II
$ BY WITNESS MC GRANE:
a g 12 A It is.
OlI3 E 14 g
And do you edoge it es gere of your testimony in this w proceeding?
E 15 BY WITNESS MC GRANE:
16 A I do, 37 MR. REYNOLDS: Mr. Chairman, we ask that Mr. McGrane's h
x
{ 18 statement of quqlifications be marked for identification as E
s I9 Applicants Exhibit 18 and be received into evidence.
M 20 JUDGE MILLER: It will be so marked.
21 Are there any questions or objections?
2 O ss. ,0,,sc,1so, y,. cs,1,m,,. sx,,,, ,,. z ,,,,,
23 ! believe we have a copy of that.
O 3uoom a cosa: we seem to be oae oogy enore-25l t MR. REYNOLDS: We will provide the Staff with a copy.
ALDERSON REPORTING COMPANY. INC.
6-16 . 7964' hop Il MS. ROTCHSCHILD: Thank you.
2 BY MR. REYNOLDS:
3 G ,Mr. McGrane, would you spell your name, please?
() 4 BY WITNESS MC GRANE:
e 5 A First,last or all of it?
8 3 6 All of the above.
G R
b 7 BY WITNESS MC GRANE:
M j 8 A First nr.ne is Ralph, R-a-1-p-h. Middle initial E.
d y 9 M-c-G-r-a-n-e.
E g 10 JUDGE MILLER: What is that P.E? " - '
E
=
k .I . ,
S 12 WITNESS MC GRANE: Professional Engineer.
I 5
(]) 13 JUDGE MILLER: Thank you.
h 14 Is there any objection to the statement of l Y g 15 qualifications, Applicants Exhibit 18?
x
.'j 16 (No response.)
W l 6 17 JUDGE MILLER: There being none, it will be received l E
{ 18 into evidence as that exhibit number and will be associated with E
19 the testimony in the transcript.
g n
20 (The document referred to was marked 21 Applicants Exhibit No. 18 for
(} 22 identification and was received in 23 ! ,
evidence.)
24 JUDGE MILLER: Next.
)
25 ;
P ALDERSON REPORTING COMPANY. INC.
l 797 1 .
BY MR. REYNOLDS:
6-17 l
2 g Mr. Scheppele, please state your name, title and hop 3 business address, if you would.
4 BY WITNESS SCHEPPELE:
<> 5 A My name is Kenneth L. Scheppele, Senior Vice h
3 6 President, Gibbs and Hill, based at 393 Seventh Avenue, New York, R
b 7 New York, zip code 10001, a
j 8 g Please spell your last name for the record.
d C 9 BY WITNESS SCHEPPELE:
b g 10 A S-c-h-e p-p-e-1-e.
$ 11 g Sir, did you prepare a statement of your educational 3
g 12 and professional qualifications for use in this proceeding?
5 Q 13 BY WITNESS SCHEPPELE:
@ 14 A I did.
m 15 g Do you have a copy of that document before you? '
i[ I6 BY WITNESS SCHEPPELE:
as I7 A I do.
h a:
{ 18 g Are there any additions or corrections you'd care to e 19 g make to it at this time?
n 20 BY WITNESS SCHEPPELE:
21 A No, sir.
22 g Is it true and correct?
23 ; BY WITNESS SCHEPPELE:
p 24 A Yes.
G 25 g And do you adopt it as part of your testimeny in i ALDERSON REPORTING COMPANY. INC.
I 6-18 798 i hop I this proceeding?
2 BY WITNESS SCHEPPELE:
3 A I do.
O' 4 MR. REYNOLDS: Mr. Chairman, we ask that Mr.
5 Scheppele,s statement of qualifications be marked for g
e
@ 6 identification as Applicant's Exhibit 19 and be received into R
b 7 evidence at this time.
Z l 8 JUDGE MILLER: Any objections?
d q 9 (No response.)
s 10 h JUDGE MILLER: There being none, it will be rec eived
=
II
$ into evidence and associated with his testimony.
E fI a
(The document referred to was marked
( 13 Applicants Exhibit No. 19 for M 14 E identification and was received in 2 15 w
x evidence.)
j 16 BY MR. REYNOLDS:
e d 17 0 Mr. Tolson, please state your full name, title and 5
{ 18 address.
E g 19 BY WITNESS TOLSON:
n 20 A My name is Ronald G. Tolson, T-o-1-s-o-n, 2I Construction Quality Assurance Supervisor, Texas Utilities t
() 22 Generating Company, P.O. Box 1002, Glen Rose 76043.
23 l g Sir, did you prepare a statement of educational and i
24 professional qualifications for use in this proceeding?
(])
25 i ALDERSON REPORTING COMPANY, INC.
799'.
>19 1 BY WITNESS TOLSON:
2 A Yes, sir.
3 g Do you have a copy of that' document before you?
(~\
'v 4 BY WITNESS TOLSON:
5 A Yes.
g e.'
@ 6 g Do you have any additions or corrections to that R
E 7 document you would care to make at this time?
E k 0 BY WITNESS TOLSON:
0 k 9 A No, sir.
z o
@ 10 0 Is it true and correct?
E 11 BY WITNESS TOLSON:
s 12 A Yes, sir.
N E
r% a q ,) 13 g 5 And do you adopt it as part of your testimony in this a
h 14 proceeding?
b IS BYW-ITNESS.TOLSON-
=
10 A E I do.
A 17 MR. REYNOLDS: Mr. Chairman, we request that~Mr.
=
f IO Tolson's statement of qualifications be marked for identification I9 as Applicants Exhibit 20 and be received into evidence.
8 n
20 JUDGE MILLER: Any objections?
21 (No response.)
22
([ ) JUDGE MILLER: Applicants Exhibit 20 may be received 23 l- into evidence and associated with the testimony.
(3 24 LJ ,
25 O 1
1 i ALDERSON REPORTING COMPANY, INC. i l
'300k 6-20 1 (The document referred to was marked hd) 2 Applicants Exhibit No. 20 for 3 identification and was received in
() 4 evidence.)
5 BY MR. REYNOLDS:
g 9
@ 6I 4 Mr. Mason, during the early stages of Comanche Peak- ,
R b 7 construction, January +,1975' time frame, what was your involvement M
y 8 at the project?
d q 9 BY WITNESS MASON:
z o
10 A h My involvement duing that period ofc time' i:d
=
II 5 .-. as well as earlier periods of time. There were three R
12 h rendily visible areas. - .
a .
() I One was in the design investigation and construction E 14 W control of the Swamp Reed Dam.
9 15 E
x .
The second was in a similar situation. Design
.' 16 E . investigation and construction control of the SSI embankment, d 17 a which meant the safe shutdown of power.
m
$ 18
= And the third was to comply with our client's 19 j requirements, meaning to.. provide:.; engineering challenges to mat 20 and a detailed study of the excavation of structures for the 21 plant itself.
22 Those were the three categories of service to our
[])
23 client.
24 g Were you actually involved in the excavation activity
{])
25 ! at that time?
)
ALDERSON REPORTING COMPANY, INC.
801 .
l 5-21 I! BY WITNESS MASON:
aop 9 2 A. As a monitor and providing the services of 3 engineering jobs.. As a.. contractor,..we did not move any material.
h 4 Q You were employed by Gibbs and Hill at the time?
5 BY WITNESS MASON:
g
@ 6 A. By Texas Utilities Services.
R "7 Q You were a consultant'to Texas Utilities Services; E
S 8 M is that what you're saying?
rJ 9
BY WITNESS MASON::
H 10 j A. That is correct.
=
hII d 12 G And you were employed by whom?
i5 BY WITNESS MASON:
o g y= 13 A. By TUSI.
b I4 G You were a contractor to TUSI?
15 BY WITNESS MASON:
Ef I0 A. In the sense that there was a contract between two us I7 firms.
=
k 18 0 Yes.
=
k 19 g BY WITNESS MASON:
n 20 A. To provide professional services.
2I % I'm not speaking about Gibbs and Hill here. I'm g 22 speaking about you personally.
23 You were employed by whom?
g 24 BY WITNESS MASON:
25 A. Texas Utilities Services.
ALDERSON REPORTING COMPANY,INC.
802 .-
5-22 1 G You weren't employed by Gibbs and Hill?
UO U 2 BY WITNESS MASON :
3 A We were not.
4 JUDGE MILLER: You can impeach him.
5 (Laughter .)
g 9
3 6 MR. REYNOLDS: I'm sorry. -
R
@, 7 It's not as complex as it seems.
E j 8 BY MR. REYNOLDS:
d C 9 % What involvement did Mason and Johnston have in the e 10 plans for excavation for Comanche Peak? Category One structures.
35
$ II BY WITNESS MASON:
is f 12 A. All right, sir.
13 At the very beginning was- the sub-surface exploration at the m
l$ 14 site, prior to any work whatsoever having been done.
15 Evaluating the materials that were present at the site ,
j 16 from an engineering and geological standpoint.
v5 I7 JUDGE MILLER: Pardon me. Coul'd you sort of look
.h u
M 18
_ this way once in a while? It would help.
H 19 j ,
MR. REYNOLDS: Address your answer to the Board, 20 please.
21 WITNESS MA_ SON: The services consisted of that of 22 geo-technical engineering. Evaluation of the materials present 23 ; at the site both from a geological standpoint, from the 24 strength of tne physical materials standp. int, from the 25 I engineering standpoint and from that formulating 'recommendat' ions ALDERSON REPORTING COMPANY. INC.
6-23 803 '
hop I
which were transferred first to our client TUSI and then direct O 2 to the structural group of its affiliate.
3 G Were you directly involved in that effort?
() 4 BY WITNESS MASON:
5 A Yes. I was directly involved. I being the person g
n
@ 6 responsible, in charge.
R b 7 G For how long did Mason and Johnston study the 3
j 8 geologic structures at Comanche Peak?
d C 9 BY WITNESS MASON:
z O
10 A My memory is now trying to zero in on the first date.
h
=
II
$ I am going to be wrong on whatever I say but it is 3
g 12 my recollection in the very early '70,s. '70 or '71. Somewhere
)c 13 in that time frame. Ten years ago.
E 14 g G Pre-construction activity surveys?
e 15 BY WITNESS MASON:
16 A Yes, very definitely.
d 17 w G These were site suitability type surveys?
m M 18
= BY WITNESS MASON:
j 19 A That is. correct.
20 On what type of geologic structure is the Comanche 0
21 Peak foundation set?
() 22 BY WITNESS MASON:
23 ' A That is known geologically as Glen:tRose limestome.
() 24 A marine formation of crustaceous age.
25 g Is limestone rock?
ALDERSON REPORTING COMPANY. INC.
-804.,.
6-24 hop 1 BY WITNESS MASON:
O 2 A Yes.
3 g Please describe the specific excavation activity for
() 4 Category One structures at Comanche Peak.
$ 5 JUDGE MILLER: Have we defined Category One structures 0
3 6 for the public in the record?
R b 7 BY MR. REYNOLDS:
s j 8 g Mr. Mason, to your knowledge, what does Category one d
9
. structure mean in the parlance of a nuclear power reactor?
10 BY WITNESS MASON:
=
II
$ A To me'it's very simple. Those that are safety 2
y 12 related.
() 5y 13 g And does Category One relate to seismic activity?
h 14 BY WITNESS MASON:
g 15 A Among other things, yes.
m g 16 g What else?
A 6 17 BY WITNESS MASON:
{ 18 A Oh, anything that would impair the safety of the E
19 completed project. Floods.
g Hurricanes. Tornados. All those n
20 natural phenomeno.
21 g Thank you.
1
() 22 Now, would you please describe the excavation 23
, activities in detail for Category One structures at Comanche Peak?
I -
24
(]) First, let's identify the Category One structures 25 ' we're.. discussing.
i ALDERSON REPORTING COMPANY, INC.
,6-25 hop I BY WITNESS MASON:
2 A. If you will permit, I would like to begin with the 3 actual excavation which was uniform for all structures and, in 4 fact, we'll identify with a specific question something that might 5
apply to a Category One.
' 0 0 Please do.
R
< b I BY WITNESS MASON:
3 5 8 M A. From the excavation standpoint, the amount of d
4 excavation job was of no concern whatsoever to Category One or O 10 j other non-safety related structures.
=
$ II g Are you saying that the excavation procedures were is f 12 the same regardless of whether the structure was Category one O !m is or non-Cetegory One2 l$ 14 BY WITNESS MASON:
15 h A. Precisely.
x f 16 g Please proceed.
A 6 17 BY WITNESS MASDON:
5 18 A. The site, prior to any construction, had a reasonably 1 p
{M 19 well-developed topography. The actual plant location prior to 20 construction was a peak of maybe --
2I JUDGE MILLER: Was a what?
22 WITNESS MASON: A peak.
23 MR. REYNOLDS_ Please address your responses to the 24 Board.
, 25f WITNESS MASON: All right, sir.
ALDERSON REPORTING COMPANY, INC.
806::
The plant conditions as envisioned by the 6-26 1 prime consultanty Gibbs and~ Hill,Lan< envisioned by others'was I
hOO 2 the removal of the hill, peak or mountain top, down to a certain 3 plateau. At the location of the reactors, for example.
O 4 This resu1eed in e cut of aggroximete1y e0 feet. The 5 material existing that was removed by this excavation cut would j
a
@ 6 have consisted of perhaps two, maybe three, a maximum of four N
b 7 feet of soil.
M j 8 The remaining distance was composed of the limestone d
9 of the Glen Rose formation.
h BY MR. REYNOLDS:
'I
. 0 And how was that limestone removed?
N BY WITNESS MASON:
S 13 O% j A. The limestone was removed in any of two basic methods.
E
' 14 g Frequently a combination of the two.
9 15 g The upper portion, which was weathered, severely j 16 weathered, was removed by the normal earth handling equipment.
us 17 Scrapers, front end loaders et cetera.
h 18 JUDGE MILLER: Scrapers and what?
E l9 2 WITNESS MASON: Front end loaders.
5 20 JUDGE MILLER: Thankyou.
21 WITNESS MASON: They checked with depth the hardness 22
] of the material increased, meaning the weathering had not 23
, proceeded with depth.
l i 24 Q At these times blasting and ripping, all again on a 25 Ii i large scale operation, took place and, really, my personal ALDERSON REPORTING COMPANY. INC.
8.07 ,
~
6-27 hop 1 memory, I think the ripping operatica was far greater than that 2 of any blasting.
3 Excavation continued until the plateau desired, O 4 which on the 3eh is ca11ed g1ene greee, wes reeched.
s 5 BY MR. REYNOLD3:
h 3 6 Now, were you now to the bottom of the excavation
- G l fr e
E y as it ultimately was excavated?
E j 8 BY WITNESS MASON:
d ci 9 A. No. As a matter of fact, we are now to the top of o
10 h the proposed excavation. We have removed the h illtop to a plahe.
=
II
.I'm waving my hands. Sorry about that.
h g 12 From this newly established plane all excavation for g foundation for plants and anything on the ground then commences.
l$ 14 4 What was the term you used for this level? Plant 15
{m grade?
d I6 BY WITNESS MASON:
at I7 Plant grade.
h m
A.
{ 18 0, And all excavation for Category One structures below E
I9 plant grade was conducted in the same manner?
8 n
0 BY WITNESS MASON:
21 A. In the same manner as all other structures, yes.
22 Q That is true.
23 g Yes, and as to distinct Category One structures in the j
24 same manner, as well?
25 l
, ALDERSON REPORTING COMPANY, INC.
,808 6-28 hop I BY WITNESS MASON:
() 2 A That is correct.
3 G To what elevation was the ultimate excavation taken?
4 BY WITNESS MASON:
5 y A I'll have to have . help in memory .
9 h 0 JUDGE MILLER: Please feel free to refer -- I assume R
R 7
- these are not sharply controverted matters -- but anything that n
S 8 n will assist your memory, we don't mind a little leading at that G
c 9 j point, if Counsel has the information.
c g 10 MR. REYNOLDS: Perhaps I could ask it more simply.
II
$ JUDGE MILLER: All right.
g 12 BY MR. REYNOLDS:
c
( ) ym 13 g Below plant grade, how deeply did you have to
@ 14 excavate to get to the bottom of the excavation?
15
{ BY WITNESS MASON:
j 16 A Yes. I understood your question.
W I7 Subject to correction by someone who has a better h
m 18 memory, I think the reactors were some 40 feet below the plant E
I9 grade. I no longer remember the depth on the fuel building or g
20 any other of the lesser depths.
21 4 What type of general excavation procedure was employed 22
(]) to excavate from plant grade downward?
23 ' BY WITNESS MASON: ,
' 24 A I'd like to start'my answer by calling to the
(])
25 attention of everyone -- particularly the panel -- that in our
- earlier geotechnical recommendations to the owners, who in turn I ALDERSON REPORTING COMPANY, INC.
809-
.J., '
I provided them to Gibbs and Hill. It was our recommendation, r*
6-Q 2 first of all, that all structures, Category One and others be hop 3 f unded on in situ, meaning intact, in place materials. That no O 4 fills be c nstructed to support any portion of the plant.
e 5 Thirdly, that in the case of safety-related or b
d 6 sensitive structure, that the concrete be placed -- the concrete e
7 that would comprise these structures, be placed against intact s
8 8 rock.
N d
d 9 For that reason, in the case of the nuclear reactor
$ 10 containment vessels themselves, which are circular it form, the E
E 11 contractor proposed an excavation scheme that would comply with g 12 this design requirement.
Q 13 This excavation scheme consisted, as purveyed by l$ 14 the specifications, of a process called line drilling. Line 15 drilling consists of a series of very closely spaced holes
.j 16 outlining the perimeter of the shape of the structure us ti 17 to be excavated. In this case, a circle.
5
$i 18 So the circumference of the circle was line drilled
=
U 19 by holes of two to four inches in diameter and placed g
n 20 probably two feet apart.
21 In addition to that, a series of holes in the center 22
] from the excavation -- in this chse midpoint of the. circle was 23 also drilled. Charges of dynamite were placed by the contractor 24 in the holes from the line drilling operation and in the holes 25 in the center of the planned excavation area,
- l. ALDERSON REPORTING COMPANY. INC.
i 810
~'4) 6-30 g 1 Mr. Ma, son, who determined the size of those charges?
h"#
w /'\ 2 BY WITNESS MASON:
3 A The planning of the line drilling and the determination
() 4 of the dynamite charges were adopted as a result of a conference g 5 between the contractors management people, by, on one occasion, 0
@ 6 representatives of the DuPontPowder Company and on another and R
$ 7 distinctly different occasion, representatives of the Hercules s
j I 8I Powder Company. '
d d 9 g These were all meetings relating to the size of the b
$ 10 charge in the excavation for each unit?
E j 11 BY WITNESS MASON:
3 y 12 A That is corre. c.
5
(]) $
3 13 4 Please proceed.
lm 14 _
2 15 .
E j 16 w
b' 17 M 18
=
e 19 M
20 i
21 22 (2) 23 ,
i
() !
25 I
h ALDERSON REPORTING COMPANY, INC.
I 8_14 3
' 7-1 1 BY WITNESS MASON:
.3e 2 A Those loaded blast-offs were detonated with loaded 3 with time delay caps or fuses, such that a limited number of the
() 4 charges would be exploded and in the case of the plain drilling e 5 holes, those around the perimeter, would start, for example, at h
@ 6 zero degrees and progress clockwise until they reached 360 degrees, R
$ 7 with milli-delayed blasting caps, to my remembrance, at four 3
j 8 delay intervals, such that the total delay time was in the range U
o 9 of 16 milliseconds, i
o
@ 10 g What was the technical reason for the delay sequence?
z II BY WITNESS MASON:
E y 12 A This was an attempt to create a fractured, or a
(])5 13 controlled crack totally around the perimeter of the material
~
! I4 to the excavating, so as to prevent any cracks going beyond the g 15 intended limit and damaging rock.
m '
j 16 Had it been a simultaneous shot would you have run O
A l I7 that risk?
z
$ 18
- BY WITNESS MASON:
h 19 g A You run more risk with the volume of dynamite that n
20 goes off at any one time, so the answer was yes.
l 21 g And the response spectra cf that rock is such that it
() 22 '
could distinguish between simultaneous shots and shots with milli-23 seconds separating them?
! 24 l BY WITNESS MASON:
25 ' g 7,d rather answer you in my words, and that is that ALDERSON REPORTING COMPANY, INC.
812 -
'7-2 1 the strength of the rock was such that a crack could be 2 propogated by a series of closely spaced impacts rather than by 3 one big jolt which would break up the whole smear.
4 0 Please proceed.
- 5 BY WITNESS MASON
0
@ 6 A. Following the detonation of the perimeter blasting, R
$ 7 or the line drilling blast-offs, the central portion of the j 8 excavation containing several holes, I no longer remember, was d
d 9 detonated.
b g 10 This, of course, was to create the first breaking of E
j 11 large volumes of rock to permit a load-out operation coming from is g 12 the center of the circle, the center of the planned excavation.
5 Oi13 g so the discharges -- the charges on the perimeter h 14 would not have broken up the rock in the middle?
2 15 BY WITNESS MASON:
g 16 A. Their intended function was only to crack the rock .
- ,5 6 17 into a cylindrical pattern beginning at the surface and to the M 18 bottom of.the planned excavation, to create by this blasting E
g 19 a separation of the rock to be removed from the rock to be n
20 retained.
21 g Was the shot in the middle of the area simultaneous 22
] with the perimeter shots or subsequent to them?
23 BY WITNESS MASON:
24 A. No, subsequent to, and again by milliseconds.
25 l 0 Thank you. Please proceed.
ALDERSON REPORTING COMPANY. INC.
- 813, I
7-3 BY WITNESS MASON:
O 2 A. That portion of the rock that had been torn loose 3 or removed from its in-place position in the central portion of 4 the excavation was then removed by proper tools, probably a e 5 front-end loader. There was very little rock that could be h
3 6 removed by that technique, and additional blasting was required.
R b 7 This was done by drilling holes on the radii from E
j 8 the center of the circle approaching the previously split d
c; 9 perimeter, and additional charges placed and additional blasting 10 performed.
h Now the rock throw is from the newly created
=
II
@ perimeter wall around the center of the excavation into the 3
f I2 center portion of the excavation where it can be loaded out.
13 m This process continued until the excavation was
' I4 deemed complete, meaning that it had its proper diameter and g 15 depth.
x E I0 The excavation depth was, you testified, 40 feet?
vs G
,h I7 BY WITNESS MASON:
x f# 18 A. In the range of 40 feet.
8 G Range of 40 feet.
n 20 BY WITNESS MASON:
I A. Right around there.
22 O , ,,,, ,,, ,,1,, ,,111,e ,,, ,,,p1,c1,, ,, ,,,cm,,ge, 40 feet deep?
O av w1razss n^ son:
A. I believe they were, yes.
l
! ALDERSON REPORTING COMPANY. INC. ,
I
~
814 7-4 1 g Approximately 40 feet deep?
O 2 BY WITNESS MASON:
l 3 A Approxiniately 40 feet. I think they were slighbly
() 4 deeper. '
g 5 g So now the process involves removing the fractured 9
3 6 rock?
R S 7 BY WITNESS MASON:
c' j 8 A That is correct.
0 0; 9 G And that procedure was conducted by front-end loaders,
$ 10 you testified?
z
= 1
$ Il BY WITNESS MASON: '
3 y 12 A That is right.
5
(]) 13 G All right. Theyremovedtherokandwhatdidthey l$ 14 find? C
{m 15 BY WITNESS MASON:
j 16 A As the rock was removed, our engineering geologist w
17 , came in for the first time to inspect the rock wall, the wall h
e M 18 that was intended to have been left intact and undamaged.
E 19 g g Was the rock wall basically on the plane that you n
20 were seeking? Did you basically accomplish what you were after 2I with regard to the circle you were trying to excavate?
() 22 BY WITNESS MASON:
23 l A A casual observer would agree that the excavating was i
24 in general in search of facts, and it was to the' proper depth.
(])
25 I It was not, however, in such a way as to create the quality -- or i
ALDERSON REPORTING COMPANY. INC.
815 7-5 1 leave in place is a better answer, or leave in place the quality 2 of rock that we as engineers wanted to transfer the load to, so 3 we were disappointed.
O 4 0 wel1, what did-rou find specifica11y-in the' walls of e 5 the excavation?
h 3 6 BY WITNESS MASON: -
R
& 7 I The upper portion of the 40 feet, for a distance s
j 8 somewhat less than ten feet, le'<.od as if all of the blasting l d
d 9 charges had elevated the rock, had tilted it so that it was z'
o
$ 10 upward toward the center of the excavation.
E j 11 Distances of displacement were in inches. Void spaces is j 12 were present. One could run his hand flatly into the previously Ol 13 intece rock enet 1 now e1evetea ue-h 14 There were vertical factors present that had not been 15 present in situ, created by additional gases excaping toward
.j' 16 the sidewalls.
vi ti 17 These conditions decreased with depth, and I believe 5 18 were totally confined to the thin upper ten feet of the 12 19 excavation.
20 g So let me understand, the excavation is 40 feet deep, 21 the lower 30 feet were acceptable from your standpoint?
22 I
] BY WITNESS MASON:
23 A. Yes.
, 24 g The upper ten feet had experienced these cracks?
25 yff ALDERSON REPORTING COMPANY, INC.
~'
11'66 7-6 1 BY WITNESS MASON:
O 2 A Thee is correce.
3 G Now, were the cracks more in a horizontal direction O 4 or vertice1 direction 2 g 5 BY WITNESS MASON:
h 3 6 A Cracks were present of both types, but by sheer R
.& 7 majority I would have to say that they were present more in a y 8 horizontal direction as a result of rock masses being pushed up.
c3 d 9 G Is there any significance as to a vertical crack
$ 10 versus a horizontal crack?
E j 11 BY WITNESS MASON:
is y 12 A It's a question of the strength of the material.
O!13 The materi 1 is broke, nd when it's shear strength is exceeded l$ 14 it cracks.
15 4 Based upon your -- let me back up.
j 16 Did you observe these cracks first-hand?
us 6 17 BY WITNESS MASON:
$ 18 A Yes.
E 19 q Did you map them?
20 BY WITNESS MASON:
21 A They were mapped by our staff geologist, yes, n 22 photographed and documented.
U 23 G Photographed and documented.
24 Did you recommend to your client that they were 25 i satisfactory to proceed with pouring of concrete?
ALDERSON REPORTING COMPANY, INC.
811' 7-7 I BY WITNESS MASON:
2 A. No on the concrete.
3 G What did you recommend?
4 BY WITNESS MASON:
c 5 A. We recommended to the client, and in this case I'm 9
@ 6 going to expand on the return also directly to Gibbs and Hill.
R R 7 In fact, it was after a concurrence with a member of the firm of M
j 8 Gibbs and Hill here that the solution was finally adopted. There d
c; 9 were several methods that could have been used to correct the
$ 10 problem.
II
$ The one we recommended, and was eventually adopted, is I2 consisted of the total removal of all displaced rock, the removal
-f Ol is redie11v unei1 e11 crecke ehee were greeene from -- ehee were b I4 apparent from the then ground surface were removed, physically 15
{e removed. The rock was excavated very carefully with a totally d I6 different method and hauled off.
vs I7 The rock was broom cleaned, air hosed, watered h
m
{ 18 until we were all convinced that all evidence of cracks and/or E
g displacements created by the blasting had been removed, and then 20 the desired geometry required to contain concrete for the 21 containment vessel was restored by means of dental concrete.
22 O , oh,,were the ,1,emm,,1ve me,,umee yon cou1,h,ve 23 : taken that you chose not to take?
24 BY WITNESS MASON:
I 25 A. Several. Number one was a total redesign of the I
ALDERSON REPORTING COMPANY, INC.
I 818 7-8 1 containment vessels of which a soil could have been used as the 2 supporting material.
3 G Taking no credit for rock foundation?
4 BY WITNESS MASON:
e 5 A That is correct.
h j 6I Another would have been what we somewhat facetiously R
$ 7 called the gluing process, wherein a series a rock bolts that j 8 had been drilled and cemented in place and highly grouted so as d
c 9 to attempt to restore by means of glue the previously displaced
$ 10 rock, and hope that it now performed as its neighbor intact and E
j 11 adjoining rock would perform, is y 12 0 '.n your professional opinion, which was the best 5
Q 13 option to pursue from a structural standpoint?
l E
14 BY WITNESS MASON:
15 A. The one that we recommended.
16 Who made the decision to pursue that course?
.] 0 us
(( 17 BY WITNESS MASON:
$ 18 A. As I recall, Mr. Ralph McGrane, sitting one chair s 19 here from me, concurred, and I do not recall a moment's R
20 hesitation on the part of our client owner of saying let's go.
21 G Now, let's try to be graphic for the Board and l
i
(] 22 describe what we have at this point.
23 , We have a 30-foot wall, an offset and then a 10-foot i
24 wall, is that a fair way to describe it, a cross-section of the 25 ' excav'ation on one side?
ALDERSON REPORTING COMPANY, INC.
819.
7-9 I BY WITNESS MASON:
() 2 A The upper ten feet -- number one, the wall was 40 3 feet high, or whatever the full depth was. The upper ten feet
() 4 looked as if one had a deck of cards tilted upward with each card a 5 representing a layer of rock. The upper ten feet of the formation
@ 6 had been broken free from the lower 30 feet and each layer of R
$ 7 rock pushed upward as it approached the perimeter'of the s
j 8 excavation.
O q 9 This continued radially, horizontally, beyong the z
C
$ 10 intended cut line for distances in the range of ten to twenty 11 feet.
E f 12 G How did you determine those distances?
13 BY WITNESS MASON:
i
() m l$ 14 A Again by very careful technique. First of all, all g 15 debris on the ground surface was removed by brooms, then by air
=
g' 16 and then by water, so that we could see precisely what was on w
d 17 the ground surface. We saw cracks.
M 18 A trench was then excavated in a circular form h
P
{n 19 around the perimeter wall and back a distance selected by the 20 field geologist in the range of five feet.
21 This trench was big enough that he could get in and 22 look and see if there was a crack on the cut side and on the
(])
23 side away from the cut. In other words, if it continued across 24 the trench that was declared bad, and a second trench was
(])
25 excavated, and so on, until the last trench was in total sound ALDERSON REPORTING COMPANY, INC.
820'- ;
7-10 I rock.
O 2 2 And how far out from the excaveeien wa11 was thet 3 last trench?
4 BY WITNESS MASON:
e 5 A In the vicinity of 30 feet.
5
$ 6 0 30 feet. What did that tell you, then?
E
- d. 7 BY WITNESS MASON:
E
[ 8 A That no fractures had been propogated beyond that d
d 9 distance.
o 10 h 0 How deep was the t:rench?
=
II
$ BY WITNESS MASON:
is I2 A I.
. As shallow as we could make it, and probably no more 3
13 than three feet.
h I4 G Why as shallow as you coulci make it?
{x 15 BY WITNESS MASON:
5[ I6 eis A That is a most sensitive area, the area that had no (x 17 restraint on it. If that area was not cracked, nothing below it
$ 18 could be cracked.
E g 39 n
0 Couldn't you have not found cracks in a three-foot 20 trench yet found cracks had you trenched deeper?
2I BY WITNESS MASON:
22 A No, not in that formation.
O 23 0 Why not?
I !
24 BY WITNESS MASON:
25 ! A Because of the techniques of the crack propogations ALDERSON REPORTING COMPANY. INC.
l
821:
11 1 in a limestone containing clay stone layers.
() 2 0 So then through this process you determine the extent
- 3 of the cracking?
O 4 BY W1TNESS MASON:
g 5 A Yes.
A
$ 6 G Then what did you proceed to do?
R R 7 BY WITNESS MASON:
A j 8 A The entire area containing cracks and displaced d
d 9 material was removed and replaced with dental concrete.
i o
g 10 G How was it removed?
E h 11 BY WITNESS MASON: ,
k 12 A Again, the front-end loaders and hand tools were
(]) 13 brought into play. The front-end loaders would operate only in lE 14 a certain width, any width plus than that had to be done by hand E 15 tools, picks and shovels.
s j 16 G Mr. Mason, take the microphone and put it right in w
d 17 front of you.
E M 18 Was any blasting employed to break that cracked rock
=
19 free?
. g l n l 20 BY WITNESS MASON:
21 A To my knowledge, and to my personal observation,
{) 22 there was only one other time that blasting was used for that 23 condition forward. There was a zone of crystalline rock, 24 crystalline meaning somewhat harder than its surrounding
)
25 I neighbors, that,as a result of the blasting fell into the Ai_DERSON REPORTING COMPANY, INC.
822 '
7-12 1 excavation in such a way that the front-end loader's bucket was G
2 too small, or the rock was too big to fit into the bucket. That 3 rock was capped, meaning that a small piece, or charge of O 4 dynemite with an e1ectrice1 cag wes denoeated on it se that that n 5 one rock was split in two, which it did do.
9 3 6 G This was not rock contiguous with the underlying R
b 7 rock formation?
3 j 8 BY WITNESS MASON:
d ci 9 A. No, no, this is rock that had previously been 10 blasted and fell into the hole as it should have, but in a piece 11
$ too big for the piece of construction equipment to remove it.
is f
- I2 O Had there been other blasting on the foundation O! m
'3 itse1f wou1d you have known eboue 1e2 l
14 BY WITNESS MASON:
g 15 A. Yes.
m i[us I6 G And there was none?
I7 BY WITNESS MASON:
18 A. That's right.
19 n
G Now, as I understand it, we have an open excav'ation.
20 Let's not assume that the dental concrete has been placed yet.
21 You've removed the cracked material. What does the open 22 C excavation look like now, cross-section-wise?
B7 WITNESS MASON:
O A. A plant view is perhaps easier. If you were on the 5l top looking down, you would see, with the upper ten feet, an I
. ALDERSON REPORTING COMPANY, INC.
823 -
7-13 1l excavation circular in form, but with a diamter approximately 2 twice what you'd intended to get. As you progress down to 3 perhaps a ten to twelve-foot level your diameter suddenly 4 decreases to what you wanted to get, so you have two cylinders e 5 with a common axis, one approximately twice as deep as you wanted b
@ 6 and one about like you wanted.
R
$ 7 G Did you inspect the walls of the larger ring? If we j 8 can call it that?
d ci 9 BY WITNESS MASON:
10 A. The vast majority of our deteiled work was in that 11 zone, yes.
is j 12 G And did you confirm that all cracks were excavated 5
Q y. 13 out of that area?
h 14 BY WITNESS MASON:
15 A. We thought that all had been. As work progressed j 16 we found there were others, as b' 17 G And what did you do in response to that finding?
{ 18 BY WITNESS MASON:
E '
19 A. Those were treated as cracks to be filled with grout.
g 20 This created a dilemma so far as time was concerned, because it 21 was mandatort, it was necessary to have concrete covering those 22' Q cracks so as to provide a resistance to the escape of grout when 23 , the cracks were grouted in place.
24 G Where were these cracks found?
25 l fff ALDERSON REPORTING COMPANY, INC.
l l
l 824 -
7-14 1 BY WITNESS MASON:
2 A Primarily in the walls, though there are, to my 3 remembrance there are two that penetrate both the wall and the i
[)
s- 4 base.
e 5 G The wall of the excavation for the containments?
b
@ 6 BY WITNESS MASON:
$ 7 A That's my remembrance.
A j 8 0 Were there any found in the fuel building?
d d 9 BY WITNESS MASON:
N
$ 10 A Oh, yes. The one in the containment is the exception.
$ 11 g Were these cracks in the sidewalls or in the base?
k 12 BY WITNESS MASON:
I
(]) =
13 A In the sidewalls as far as the containment is l
E 14 concerned; in the base as far as the fuel building, both the g 15 walls and the base.
=
g 16 G Had you found any cracks in the base of the excavation W
17 for the containments?
h x
5 18 BY WITNESS MASON:
E 19 A There is one.
g n
20 And what did you do about that?
G l
l 2I BY WITNESS MASON:
22 A It was grouted.
(])
23 i With grout pipes, as you just described?
G 24 BY WITNESS MASON:
(])
l 25 A Yes.
ALDERSON REPORTING COMPANY, INC.
~
'825'
- 7-15 1 G How did you --
() 2 JUDGE MILLER: Counsel, pardon me. The term base 3 has been used several times, I believe.
() 4 MR. REYNOLDS: Yes, by base I mean the bottom of the g 5 excavation for the containment structures.
N e
$ 6 JUDGE MILLER: The bottom, period, nothing below R
8 7 that?
A j 8 MR. REYNOLDS: That's correct.
d d 9 JUDGE MILI.ER: And is the witness using it in the b
g 10 same sense?
E I 11 BY MR. REYNOLDS:
g 12 G Mr. Mason, are you?
5 O sm '3 av w'T"ess "^so":
h 14 A Yes, sir, I'm using it in the same sense.
2 15 JUDGE MILLER: Okay. You may proceed.
E g 16 BY MR. REYNOLDS:
e d 17 G Please describe the specific procedure employed for 5
5 18 the placing of dental concrete in the --
k g 19 BY WITNESS MASON:
n 20 A Dental concrete --
21 G Dental concrete in the area which you had excavated
{) 22 out of the upper ten feet of the containment.
23 BY WITNESS MASON:
24 A The specifications as prepared by Gibbs and Hill 25l provided for the placement of dental concrete, as used in the ALDERSON REPORTING COMPANY, INC.
l i 826 7-16 1 , word specifications, to provide the strength of the concrete, O
b' l
2 mix designs, and so on. That concrete was mixed on site, placed 3 on previously clean rock in a conventional manner, using an 4 interior form to create the walls so that the fresh plastic e 5 concrete would not fall into the previously excavated hole.
3 6 G The exterior form was the rock itself?
G
$ 7 BY WITNESS MASON:
E j 8 A The exterior form and the base of the concrete pour d
o 9 was the rock itself. That's correct.
i h 10 0 What is dental concrete?
$ 11 A A construction term given to concrete that is used to is g 12 repair a defect in rock.
Oj is G are its characterieeice different from norme1 concrete l$ 14 used in construction of structures?
2 15 BY WITNESS MASON:
5 j 16 A They can be; in this case they were, as 6 17 0 Who were they different?
$ 18 BY WITNESS MASON:
E g 19 A The: strength of the concrete as used in structures n
20 is dependent on the intended use of the structure, and at 21 Comanche Peak it was quite high. The concrete, the dental O 22 concrete was used to repair a rock that had a strength require.
23 ; ment far less than the requirement of the concrete used in the 24 plant. As a matter of fact, the strength of the concrete for 25 dental uses, as I recall, was 2,500 pounds per square inch at an 1 ALDERSON REPORTING COMPANY, INC.
l 827."'
l 7-17 1 age of 28 days, shich produced a material with a strength and 2 physical properties far greater than that possessed by the 3 limestone itself.
O 4 a Is there any eneineerine sienificence to the fece e 5 that the dental concrete would be stronger than the concrete U
$ 6 below it?
R
$ 7 BY WITNESS MASON:
s j 8 A. That is not the case.
d c 9 JUDGE MILLER: Concrete below it?
g 10 MR. REYNOLDS: I'm sorry, I misspoke.
3 Q
II BY MR. REYNOLDS:
a y
~
12 g Than the rock below it.
c 13 BY WITNESS MASON:
l 14 A. The concrete could have had a strength lesser than 15 what it had because it was now stronger, or would be when it j 16 cured, it's stronger than the rock.
v5 17 h Our philosophy was there is nothing to be gained by IO reducing the cement content such that it is equal only to the e I9 g strength of the rock. Let's use a non-cement content, normal M
20 placing techniques, as called for in the previously adopted 2I specifications. Perhaps Mr. McGrane can speak to that later one.
22 From the soils and foundation standpoint, it was quite adequate.
23 g Was reinforcing steel placed in this area where 24 ' dental concrete was placed?
r3 C' !
25 j fff ALDERSON REPORTING COMPANY, INC.
828 7-18 1 i BY WITNESS MASON:
() 2 A No, it was not.
3 G Why not?
() 4 BY WITNESS MASON:
e 5 A The mission in using dental concrete is to try and 6
j 6 approximate what is in the ground. The Glen Rose limestone R
R 7 contains no reinforcing steel. We are attempting for uniformity, M
j 8 and I'm not being facetious, I'm trying to give you the reasons d
d 9 here. We are attempting to reproduce by mankind a formation
! 10 that is already present and is near the reproduction as we can E
j D
11 economically do so as to create a uniform system for the final j 12 structure.
5
(]) 13 0 What in your opinion was the engineering significance l$ 14 of the repaired excavation, relative to the excavation as it 2 15 would have been had there been no cracks?
s y 16 BY WITNESS MASON:
W 6 17 A In service people and construction costs, W
$ 18 appreciably more.
=
g 19 G In service equal?
n 20 BY WITNESS MASON:
21 A Yes.
r~s 22 G You've just described the procedure for excavation of O
23 the containment building. Was that for Unit 1 or for Unit 2?
24 BY WITNESS MASON:
25 A They were both the same way.
ALDERSON REPORTING COMPANY. INC.
829 7-19 1 G Were they done si.aultaneously?
2 BY WITNESS MASON:
3 A No, they were not. They were in sequence.
4 G Was the excavation procedure changed after your e 5 experience with Unit 17 h
3 6 BY WITNESS MASON: '
R
$ 7 A. Yes, it was, but --
E j 8 G And by the question I am taking for granted that d
c 9 Unit 1 was excavated first.
g 10 BY WITNESS MASON:
G II A. I think you're right. Unit 2 --
is 12
{ JUDGE MILLER: Pacdon me. When you come to a
'3 Ol conveniene e1ece to recess for 1unch, you miehe indicete it.
l$ 14 BY MR. REYNOLDS:
g 15 0 Please proceed.
x 16 Unit 2 did follow Unit 1 in excavation. Subject to d
A.
us
!;[ 17 correction for something I said in the FSAR, the distance.on the 18 lime drilling holes was reduced, meaning that they are now closer e 19 g together, taking less of an explosion to perpetuate a crack.
n 20 Powder companies were changed, powder consultants were changed.
21 The over-break, however, was present with very little reduction 22 Q in volume.
23 l 0 Tc what do you attribute the fact that even though 24 you changed your procedure, changed the method specifications, 25 you nevertheless experienced basically the same amount of crackinc ?
ALDERSON REPORTING COMPANY, INC.
830, 7-20 1 BY WITNESS MASON:
2 A. The mechanics and characteristics of the Glen Rose 3 formation are such that I do not believe it possible to get an O 4 ineace dese resu1 tine from lime dr1111ne end $1eetine, end e 4 5 different technique was called on, which was later employed on
$ 6 the site which worked fine.
I k7 a
g If I asked you to explain the process for repair of j 8 cracking in the Unit 2 excavation, would you repeat basically d
d 9 the testimony you've just given with regard to Unit 1?
d
$ 10 BY WITNESS MASON:
iG j 11 A. Absolutely.
is y 12 g Was anything different done in the repair of Unit 2 Qh g 13 relative to Unit 17 m
h 14 BY WITNESS MASON:
15 A. No. The prior techniquc worked fine.
j 16 0 Was the extent of dental concrete placement about as 6 17 the same?
5 y 18 BY WITNESS MASON:
E 19 A. To my memory, yes.
20 0 About ten feet deep?
21 BY WITNESS MASON:
22 A. About ten feet deep and from 15 to 20 feet beyond 23 the intended wall line.
1 24 g What is the building which joins the Unit 1 and 25 l Unit 2 containments?
I l
l ALDERSON REPORTING COMPANY, INC.
I
i 831.
'21 1 BY WITNESS MASON:
2 A That --
3 0 Is there a building that joins them?
O 4 BY W1TNESS MASON:
o 5 A Yes.
U
$ 6 -Q What is that called?
R 8 7 BY WITNESS MASON:
A
[. 8 A Well, my geography is going to be as bad as yours.
d d 9 G Perhaps Mr. Merritt can help you.
$ 10 BY WITNESS MERRITT:
E 11 A Fuel building.
h 3
j 12 G Fuel building.
(]) 13 What did you observe after the excavation of the l$ 14 fuel building?
2 15 BY WITNESS MASON:
j 16 A First of all, the proximity of the wall of the fuel m
6 17 building to that on the reactor is relatively close. Without the
$ 18 plan in front of me, I'd say it's in the range of 50 feet or less.
P 19 In the plan view there is a service water pipe tongue M
20 that parallels one wall of the fuel building. In the drilling and 21 blasting of that operation ,some substantial blocks of rock were 22 displaced horizontally.
({}
23 ; O By at.ostantial what do you mean in terms of volume?
24 BY WITNESS MASON:
25 l A In terms of height and length, perhaps it would lead ALDERSON REPORTING COMPANY,INC.
l l
l 832
'7-22 1 me to compute a volume for you. Let's say the block is 50 feet s 2 in width and approximately 100 feet in length, and a depth of 3 somewhere between five and ten feet, was phyiscally moved 4 horizontally a distance that you could put your fist through, c 5 It slid horizontally. As a matter of fact, there is, in Friday's 9
@ 6 paper -- we're talking about newspapers -- there is a reproduction R
$ 7 of our own photographs that shows that displacement.
j 8 MR. REYNOLDS: I'm sure the copy the Board got was not d
c 9 very well reproduced.
g 10 BY MR. REYNOLDS:
z l
=
$ 11 G Were there cracks in the bottom of the excavation 5
y 12 of the fuel building?
c Q y m 13 BY WITNESS MASON:
! 14 A Cracks, yes.
15 0 Significant cracks?
j 16 BY WITNESS MASON:
A 6 17 A No.
E
{ 18 0 What size cracks?
E 19 g BY WITNESS MASON:
M 20 A Less than a quarter inch in maximum width, and the 21 decay or beginning end of every crack was visible. We knew where 22 it started and where it endea and its maximum width.
({}
23 l g What criterion did you use to distinguish between 24 cracks which would be repaired by grouting and cracks which would
[]}
25 l have to be removed and replaced with dental concrete?
ALDERSON REPORTING CCMPANY. INC.
833 ,
7-23 1 BY WITt2SS MASON:
2 A Rock which had been displaced horizontally and was 3 intended to give resistance to a wall, to be pushing against it, O 4 we considered worth 1ese. It wes removed. We did noe wene eny e 5 stress on it.
h 5 6 The cracks that I'm alluding to, or describing in the N
$ 7 fuel building were in place, as other places, but those in other j 8 places were immediately removed in the excavation process when d
o 9 we removed the rock mass. Those remaining had experienced no
$ 10 displacement and were best treated by means of the grout
$ 11 injection.
is j 12 g So there was this large block of displaced rock Q 13 that you recommended be removed?
l$ 14 BY WITNESS MASON:
g 15 A That's correct.
x 3l 16 g Was it removed?
us 6 17 BY WITNESS MASON:
{ 18 A It was.
E
- 19 G And what was the repair procedure in that area?
R 20 BY WITNESS MASON:
21 A Again, I've gone through that previously, that I 22 had previously described around the containment building, dental 23 , concrete.
24 g You placed forms?
25 ///
ALDERSON REPORTING COMPANY, INC.
l 834 ,
i l
7-24 Il BY WITNESS MASON:
2 A. Yes.
3 0 Was it a continuous pour?
4 BY WITNESS MASON:
e 5 A I'm sure not, not with the volume that was there.
h j 6 0 Was it reinforced by reinforcing steel?
N
$ 7 BY WITNESS MASON:
7.
S q 8 A. No.
O c 9 G Same reason?
g 10 BY WITNESS MASON:
E j 11 A. Same reason.
is 12
{ G Was it somehow joined to the rock that was unbroken?
Q 13 BY WITNESS MASON:
l$ 14 A. Yes. I've been amiss for not describing that. Sorry.
15 When I used the words displaced and fractured rock j 16 was removed down to sound rock, this means that in order to us li 17 accomplish that, jackhammers or clay spades are used to make sure 5
{ 18 that all drummy rock, all loose rock is, number one, identified, k 19 g and number two, removed, and the result is a reasonably a
20 horizontally plane that acts really as a continuous key way, it 21 is rough, it shows undulations of two to six inches, all caused 22 by the jackhammer tools and/or the clay spades, and gouged it out.
23 ; So in that sense of the word there's intimate contact, 24 shear resistant contact between the dental concrete and the 25 l underlying firm, undisturbed rock.
ALDERSON REPORTING COMPANY. INC.
l 835 '
7-25 1 0 Upon repair of the area we're discussing, was the
() 2 foundation structurally as it would have been had there been no 3 cracking in the rock?
() 4 BY WITNESS MASON:
g 5 A Definitely.
9
@ 6 0 Was it stronger?
R
$ 7 BY WITNESS MASON:
A Q 8 A It was stronger.
d d 9 G Do you have, Mr. Mason, experience prior to the
$ 10 Comanche Peak excavation project, in the excavation or blasting 11 in limestone of the quality of the Glen Rose limestone k
g 12 foundation?
Q 13 BY WITNESS MASON:
l$ 14 A Yes.
~
g 15 G Did the Glen Rose limestone react consistent with
=
j 16 your past experience in similar limestone deposits?
2 6 17 BY WITNESS MASON:
$ 18 A In a very general sense, yes, in that it was e 19 blastable and we did fracture the rock. In a less than expected 20 sense, inasmuch as it was a softer material, so far as the 21 blast charge that was used, we were all surprised, including
~g 22 (J both representatives of the two major power companies.
23 t MR. REYNOLDS: Mr. Chairman, this is a convenient 24 (Jg time to break, if you wish'.
25 JUDGE MILLER: All right. We'll recess for lunch, ALDERSON REPORTING COMPANY. INC.
4
\!
836 '
7-26 1 then, until 2:00 o' clock, please.
'O 2 (Whereupon, at 1:00 p.m., a recess was taken 3 until 2:00 p.m., the same day.)
4 ---o00---
g 5 9
3 6 a
R 7 j 8 e
c 9
$ 10 5
it 5
a p 12 vg lm 14 2 15 s
j 16 us 6 17
!3 18
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"O b 19 R
20 21 22 0
23 24 25 ,
l l
I ALDERSON REPORTING COMPANY,INC.
8 837,
' 8-1 1 AFTERNOON SESSION 2 2:00 p.m.
3 JUDGE MILLER: Okay. Go right ahead, please.
4 DIRECT EXAMINATION (resumed) e 5 BY MR. REYNOLDS:
U G Mr. Mason please describe the foundation of the j 6 excavation whenfit was- comple~ted/ and the repairs were effective.
~
R
@, 7 BY MR. MASON:
A l 8 A. In response to the question as to what the. completed d
d
~
9 excavation after remedial work looked like, with respect to the
- i h 10 view on the top of the completed excavation, the first thing to b
j 11 note is the observer is standing on concrete; approximately eight is y 12 to ten feet beneath him is a vertical concrete wall. Then the E -
Q 13 wall, while continuing vertically, is composed of the limestone, h 14 the intact, unfractured rock.
15 Then, due to the structural requirements, the j 16 diameter of the excavation decreases. One would see the intact, e
6 17 unfractured parts on the surface of the limestone, and thence
$ 18 the lowermost portion of the reactor excavation, which is a E
g 19 central, somewhat deeper section. It is composed of intact, a
20 unfractured limestone.
21 0 So then your testimony is that there was no rock
(] 22 breakage in the deeper center excavation?
23l BY WITNESS MASON:
i 24 A. That is correct.
25 I 0 In your professional opinion, was anything done ALDERSON REPORTING COMPANY. INC.
^
838 'Js 8-2 1 during the excavation in repair work that would or cause cracks
() 2 in any structure to be placed upon the foundation?
3 BY WITNESS MASON:
() 4 A No. Absolutely not. The condition at the completion e 5 of the excavation and remedial measures were equal to c,r superior b
$ 6 to those that were intended in the design.
R 8 7 G Mr. Scheppele, have you heard Mr. Mason's testimor.y a
j 8 over the past one or two hours?
d d 9 BY WITNESS SCHEPPELE:
! 10 A I have.
E j 11 g Are there any aspects of that testimony with which k
j 12 you disagree?
5
() 13 BY WITNESS SCHEPPELE:
h
. 14 A There is not.
2 15 G Is there any clarification that you feel should be j 16 made to that testimony?
W d 17 BY WITNESS SCHEPPELE:
$ 18 A No, sir.
5 3 19 % Mr. McGrane, have you heard Mr. Mason's testimony?
n 20 BY WITNESS McGRANE:
21 A Yes, I have.
22 G In your professional opinion, is it accurate?
23 BY WITNESS McGRANE:
24 A It is.
25 ' g Do you think any corrections should be made to it?
ALDERSON REPORTING COMPANY. INC.
839 8-3 1 BY WITNESS McGRANE:
() 2 A No, sir.
3 G Mr. McGrane, were you present at the Comanche Peak
() 4 site during the work described by Mr. Mason?
g 5 BY WITNESS McGRANE:
9
$ 6 A I was present for some of it.
R
& 7 G Were you on site during the excavation, when the a
j 8 excavations had been cleared of rock prior to repair?
d d 9 BY WITNESS McGRANE:
$ 10 A Yes, sir.
E 11 G Did you observe the cracks which were experienced as k
j 12 a result of the blast?
5
(]) 13 BY WITNESS McGRANE:
! 14 A At the time that I believe they're referring to, we 15 had the excavation, or the fractured rock had been cleared.
g 16 G Had you observed the cracks before that had been w
d 17 cleared?
18 BY WITNESS McGRANE:
h E
19 A Yes, sir.
20 G Had you observed the techsnical approach to resolving 21 this?
22 BY WITNESS McGRANE:
, 23 , A I did.
s 24 G Did you concur in that technical procedure for
('d 25 repairs that were effected?
I ALDERSON REPORTING COMPANY, INC.
8dO4-8-4 1 BY WITNESS McGRANE:
2 A. Yes, I do.
3 G Did you discuss those with Mr. Mason?
O 4 BY WITNESS McGRANE:
5 A. Yes, sir.
g e*
3 6 g What is your discipline, sir?
R
$ 7 BY WITNESS McGRANE:
A
] 8 A. I am a civil structural engineer.
d o 9 g Did you observe the cracks in the fuel building?
$ 10 BY WITNESS McGRANE:
$ II A. Yes, sir.
is g 12 g First-hand?
Q m 13 BY WITNESS McGRANE:
l$ 14 A. Yes, sir 15 JUDGE COLE: Excuse me. Cracks in the fuel building?
j 16 Is that what you said? ,
as
,N I7 MR. REYNOLDS: Fuel building excavation is what I a:
18 meant to say. This whole testimony involves a hole in the ground.
h E
19 BY MR. REYNOLDS:
20 g Does it not?
2I BY WITNESS McGRANE:
22 Q A. Yes, it does.
23 g There are no structures that have been built?
24 BY WITNESS McGRANE:
I 25 A. That's correct.
ALDERSON REPORTING COMPANY. INC.
841
8-5 1 JUDGE McCOLLOM: Excuse me. Is your microphone on?
2 MR. REYNOLDS: No.
3 BY MR. REYNOLDS:
4 G Did you concur in the repair procedures devised for a 5 the repair work in the fuel building area?
h j 6 BY WITNESS McGRANE:
R 6 7 A Yes, I did.
N 8 8 g In your opinion as a structural engineer, was there d
c; 9 anything done during the excavation and repair work that could 8
G 10 or would cause cracks in any structure placed upon the found:ation?
$ 11 BY WITNESS McGRANE:
is 12
{ A No, sir.
ar Ol is a schevee1e, cea vou a er enee eme sue eioa2 l$ 14 BY WITNESS SCHEPPELE:
1 jx 15 A I would also answer no, sir.
y 16 0 Thank you.
us d 17 Mr. Tolson, was the excavation work for Category 1 5
bi 18 structures at Comanche Peak subject to Quality Assurance e 19 g procedures and controls?
n 20 BY WITNESS TOLSON:
21 A No, sir.
22 G And why was it not? ,
23 , BY WITNESS TOLSON:
i 24 A The specifications for the excavation work did not 25l impose the requirements of 10 CFR 50, Appendix B.
ALDERSON REPORTING COMPANY. INC.
8 842 -
/
8-6 1 0 When did the procedures for Quality Assurance come '
( 2 into play, at what stage of construction?
3 BY WITNESS TOLSON:
( 4 A At that stage of construction which is the end of the I
e 5 l excavation stage and prior to the placement of the Category 1 i
3 6: structure.
- R
$ 7 0 So there were no Quality Assurance or Odality Control Z '
j 8 procedures pursuant to which excavation was conducted?
d d 9 BY WITNESS TOLSON:
$ 10 A That's correct.
11 G And your Quality Assurance organization was not a
p 12 involved in inspecting, auditing and surveilling the excavation
(]) 3y 13 activities?
m l
E 14 B'l WITNESS TOLSON:
g 15 A That's correct.
x .
g 16 g Were you employed by Texas Utilities at the time of w
d 17 the excavation of Comanche Peak?
E
{ 18 BY WITNESS TOLSON:
A 19 A Yes, sir.
M 20 g In what capacity?
2I BY WITNESS TOLSON: .
/~T 22 A At the time of the excavation work I was a senior V
23 Quality Assurance engineer assigned to the corporate QA staff 24 in Dallas.
({}
25 G Were you familiar with the rock breakage that ALDERSON REPORTING COMPANY, INC.
~
8 4 3 '.. ,
4 8-7 1 occurred during the excavation?
2 BY WITNESS TOLSON:
3 A Yes, sir.
n v 4 G Did you observe it first-hand?
J I e 5 BY WITNESS TOLSON:
2 4
3 6 A Yes, sir.
R
& 7 g Why did you observe it first-hand if it was not A
j 8 subject to Quality Assurance procedures?
d e d 9 BY WITNESS TOLSON:
/
o
$ 10 A It was of interest to me as a professional.
E j 11 % You were observing it then as a professional and not k
g 12 as a Quality Assurance engineer?
() m 13 BY WITNESS TOLSON:
! 14 A ,Let me clarify that. My personal background is in U .l' <
15
{e the geophysical field, and therefore I have more than just a j 16 passing interest-in the excavation work. As I stated previously, w
g
~
17 QA/QC function was to be applied prior to concrete placement, i $
$ 18 which is just immediately subsequent to the period of time that A
19
{
we're currently talking about.
l 20 0 Were Quality Assurance procedures employed for the 21 repair work? '
I 22 BY WITNESS TOLSON:
(]) /,
23 A Yes, sir.
24 0 l ([) Wny?
! l l 25 j ///
l -
ALDERSON REPORTING COMPANY, INC.
84,4 8-C 1 I BY WITNESS TOLSON:
2 A. At that time the project specification was modified 3 to impose 10 CFR 50, Appendix B, on the repair work.
O 4 JUDGE M1ttER: Perdon me. tee interrupe here. We e 5 have the sound experts back, and we'd like to get this thing h
$ 6 straightened out if we could, please.
R M 7 Let me indicate for the record that our numbering a
j 8 system turned out not to be quite accurate. Therefore, we will d
ci 9 keep the numbers that have been assigned to exhibits, but there
$ 10 will be and is presently no Staff Exhibit 6, and there is not g 11 presently any Applicant Exhibit 13. By leaving those in the 3
y 12 numbering sequence is presently correct, but it leaves the one 5
Q 13 gap because we should have started with those numbers rather than h 14 assuming they were the last ones, as it turned out.
2 15 MR. P2YNOLDS: Well, perhaps we're fortunate that we j 16 don't have an Exhibit 13.
v5 ti 17 (Laughter.)
,{ 18 JUDGE MILLER: All right. Secondly, I think that i: .
'{n 19 some of the exhibits, or at any rate those pertaining to Board 20 Questions 1 and 3, which would be Exhibits 1 and 3, the reporter 21 does need the copies which Staff and Applicants agreed to furnish, 22 so if you could supply that, it would be helpful.
23 Any other housekeeping chores?
24 (No response.)
25 l JUDGE MILLER: All right. You may resume your l
l ALDERSON REPORTING COMPANY, INC.
845
- u 8-9 1 interrogation.
2 BY MR. REYNOLDS:
3 G Mr. Tolson, was the excavation matter, and the matter 4 of the over-break of rock reported to the NRC?
e 5 BY WITNESS TOLSON:
h 3 6 A. Yes, it was.
i:7 6 7 G How was it reported to the NRC?
N l 8 BY WITNESS TOLSON:
d c; 9 A. Basically verbally and followed up in writing by o l' an interim report in February '75, and a final report in 11 December of '75.
m j 12 G Would it have been reported verbally prior to the 5
Q 13 removal of broken rock, that is to say properly broken rock as e
g 14 opposed to cracks?
$i 15 BY WITNESS TOLSON:
y 16 A. I'm sorry; I don't understand.
as 6 17 G Was the excavation cleared of broken rock before the
{ 18 NRC was advised, or was the NRC advised immediately upon the E
19 shooting of dynamite?
g r3 20 BY WITNESS TOLSON:
2I A. Let me try to answer it this way. I think we need 22 to go back to part of Mr. Mason's testimony relative to the pre-23 splitting operation, the concentric blasting operation and the l 24 removal of the resulting rock, which occurred over a tremendous 25 ! period of time, and I don't have the exact date in my mind.
ALDERSON REPORTING COMPANY,INC.
846..
'8-10 1 Evidence of the rock over-breakage, if you will, did not really
() 2 become visually apparent until we had reached the final grade, 3 if you will, thinking in terms of the excavation.
() 4 G So it was at that point that the NRC Staff was e 5 advised verbally and what type of written notification did you
$ 6 provide to the Staff?
R
$ 7 BY WITNESS TOLSON:
M
[ 8 A Well, in accordance with the requirements of
, d c 9 10 CFR 50.55(e), we filed, as I mentioned earlier, both an i
o y 10 interim and final report.
E j
M 11 G Did the NRC Staff come to the site to observe the
. 12 excavation?
13 BY WITNESS TOLSON:
(]) m i l$ 14 A Yes, sir.
2 15 G Who from the Staff came, if you recall?
s y 16 BY WITNESS TOLSON:
A d 17 A The principal inspector at that time was Mr. Bob s
M 18 Stewart.
E 19 G And do you have first-hand knowledge that he in fact h
n 20 came to the site to observe the excavation?
21 BY WITNESS TOLSON:
r3 22 A That's correct.
V 23 , G Would he have observed the excavation for the
! l 24 containments for Unit 1 and Unit 27 L
25 li
/// , 1 l l ALDERSON REPORTING COMPANY. INC.
8 4 7 _ ..
- 8-11 1 BY WITNESS TOLSON:
() 2 A Yes, sir. ,
3 0 Would he have observed the excations for the fuel O
V 4 building?
e 5 BY WITNESS TOLSON:
d j 6 A Yes, sir.
R
& 7 G Is there any way he could not have seen the rock A
j 8 damage in the fuel building if he observed the excavations for d
o 9 the containment units?
$ 10 BY WITNESS TOLSON: '
E i j 11 A Not in my opinion.
k j 12 G Why do you say that?
5
(]) ym 13 BY WITNESS TOLSON:
l$ 14 A As Mr. Mason described, the rock fracturing in that 2 15 particular area was quite visible.
s y 16 G So that one standing at the opening of the hole for a w
d 17 containment would have a view of the entire excavated area?
E
{ 18 BY WITNESS TOLSON:
P l 19 A That's correct.
R 20 g Was the displacement of rock in the fuel building 21 subtle or very obvious?
22
{) BY WITNESS TOLSON:
l 23 A It was very obvious and very pronounced.'
24 G Mr. Mason, what length of displacement was there 25 for the rock in the fuel building?
ALDERSON REPORTING COMPANY, INC.
I ._ _
{
8480 ~ee 8-12 i BY WITNESS MASON:
2 A I recall an open crack, meaning that the rock was 3 displaced in an amount that -- and I'm not very big, but I could O 4 saueeze my body throush, 1ee's ear een inches.
- 5 G Substantial?
9 3 6 BY WITNESS MASON:
R
& 7 A substantial, n
$ 8 G Very visible?
d
- i 9 BY WITNESS MASON:
$ 10 A Oh, right; daylight where it should be rock.
$ 11 g So then, Mr. Tolson, in your opinion, you -- the is j 12 Applicants fulfilled the requirements of reporting to the NRC?
E Q 13 BY WITNESS TOLSON:
h 14 A That's correct.
15 g Fully and completely?
g' 16 BY WITNESS TOLSON:
us 17 A I beg your pardon?
h x
$ 18 G Fully and completely?
E g I9 BY WITNESS TOLSON:
1 20 A Yes, sir.
21 G Was anything withheld from the NRC?
22 Q BY WITNESS TOLSON:
23 t A No, sir.
24 G The inspector was on site and he observed all aspects 25 of the over-break?
i l
ALDERSON REPORTING COMPANY, INC.
1 l
849.;-
- 8-13 1 .
BY WITNESS TOLSON:
l
() 2 A Yes, sir.
3 G Mr. Scheppele, at this stage we now have a clean and
() 4 repaired excavation, and is it fair to call it the foundation e 5 for the Category 1 structures?
h j 6 BY WITNESS SCIIEPPELE:
R
$ 7 A This would be the rock surface on which the concrete s
8 8 foundation of the primary structure, in this case the containment d
d 9 structure, would rest.
i
- o 10 g G So it's fair to use the terminology foundation for
=
11 the rock surface and the repaired concrete?
2 g 12 BY WITNESS SCHEPPELE:
3
() 13 A That's correct.
h 14 % What structure was placed immediately on top of that g 15 foundation?
m j 16 BY WITNESS SCHEPPELE:
M 17 A This would be the containment structure for Unit No. 1 18 first. I think if you would bear in mind the description that P
19 g" has previously been given, what we basically have here is two 20 concentric circles -- not concentric, but two circles, a large 21 circle that would be in the neighborhood of, oh, perphapsl50 feet 22 in radius, in that range --
(]}
23 j G In radius?
24 BY WITNESS SCHEPPELE:
25 A In diameter, I mean; diameter. Then there would be a ALDERSON REPORTING COMPANY, INC.
8'5 0 ' '
8-14 I smaller circle within that larger circle, which would represent 2 the depressed portion of the land itself which would be non-3 concentric with the center of the reactor building or the O 4 coneeinment etructure, e11ehe1y offset but neverthe1ese e eme11er e 5 circular shape which would be roughly 20 to 24 feet below that.
h j 6 These would represent the concrete -- the rock R l
@, 7 surfaces which had been prepared for the placeme t then of the s
j 8 concrete foundation mat, which is the supporting element for d
ci 9 the containment structure itself.
- s o
@ 10 Now, that mat is 12 feet in thickness. The construc-11 tion sequence would be one in which the concrete would be placed is j 12 first at the lowest depth.- It would be placed entirely around 5
() 13 the smaller circle ac a depth which would be roughly 24 feet
@ 14 below the larger circle.
15 It's difficult to describe this without the use of j 16 hands.
- ss N I7 JUDGE MILLER: That's all right. We see them.
$ 18 BY WITNESS SCHEPPELE:
P 19
{
n A. Then the next point to be constructed after that 20 lower mat was constructed would be the walls, the little wall 21 going up which would in effect be a vertical surface to the 22 Q foundation mat. That would be roughly 12 feet in height. The 23 inside surface of that would be a steel arm added to the form.
24 BY MR. REYNOLDS:
25 l (L Would that also be 12 feet thick?
l l
l ALDERSON REPORTING COMPANY, INC.
l 851" 8-15 1 BY WITNESS SCHEPPELE:
2 A. It would be 12 feet in thickness as well. . (
l 3 Now, if I could use my hands again, we have a 12-foot 4 horizontal mat. We have a 12-foot cylindrical wall, on top of e 5 that then we would have a 12-foot thick concrete mat that would d
j 6 go out to the exterior of the larger circle.
R
$ 7 All of that concrete is heavily reinforced. That '
s j 8 concrete, as I mentioned, is the basic support element for the d
c; 9 containment structure. On top of that liner, on top of that E
$ 10 construction, that concrete construction there is eventually a 11 liner placed at the proper surface of the horizontal concrete is I2 pours.
N_.
O!'m so in errece whee <<e neve then is e stee1 11ner et g 14 the top of the foundation mat, again in a shape that would be 15 compressed in the center, vertical in the vicinity of the j 16 reactor, horizontal on the larger diameter circle, and that steel us 17 plate would extend to the cylindrical wall where the steel liner
=
{ 18 plate and the cylindrical wall would be joined and that in turn E
19 would go up over the hemisphere. So then in effect waa t we have
~
g n
20 is a complete steel envelope which is at the top of the foundation 21 mat, which is the point now in question.
22 What purpose does the reinforcing steel serve in a (L
23 structure such as that? Can we call it base mat?
24 BY WITNESS SCHEPPELE:
l 25 i ,. yes, we com1, c,11 it h,se m,t. , hie reinforceme,t ALDERSON REPORTING COMPANY. INC.
l 852 8-16 1 was placed in that base mat, is designed to accommodate all the
() 2 various loading combinations which that containment would realize 3 during the course of its life and also during all of the
() 4 environmental effects which that plant would have received.
- 5 This would involve loading combinations, which would 9
3 6 incorporato internal proccuro, it would incorporate seismic R
2 7 conditions. It would incorporate the regular operating conditions a
8 8 of the plant. All of these factors in accordance with the d
d 9 generally recognized practice from the viewpoint of design of Y
$ 10 the :ontainment structure.
E j 11 G And what function would the concrete serve in such a
p 12 a structure?
5
(]) 13 BY WITNESS SCHEPPELE:
@ 14 A In the design of reinforced concrete, primarily they g 15 use concrete as a compression element. Concrete really is never x
j 16 used as tension because concrete in itself -- as a tension w
6 17 element because concrete as tension is a very weak material.
{ 18 As a consequence, we marry the compressive strength E
19 of concrete and the tensile strength of steel, and basically g
n 20 that's a marriage which has worked out well for many, many 21 hundreds of years.
22 g Perhaps we could simplify your testimony a little bit.
(])
23 ; Would you explain what you mean by compression I
{} /24 element of concrete?
25 ///
ALDERSON REPORTING COMPANY,INC. ,
1
i 853 1 .
l 8-17 1 ! 3Y WITNESS SCHEPPELE:
2 A. A compression element is one which we primarily have 3 a situation where the forces are working towards one another, and O 4 thet groduces e comgressive stress es oggesed to e tens 11e seress, e
3 5 l which would tend to pull things apart.
i l
l
$ 6 If you can visualize something like concrete, which R
& 7 is a brittle material when it's subjected to a tension it would
% i j 8 tend to crack, and basically the design of reinforced concrete d
o 9 structures does indeed involve cracking, because in order for A
o a 10 the reinforcing steel to physically work it is necessary for the E
j 11 concrete in most instances to crack.
3 12 G Mr. Scheppele, are you cognizant of the existence of c]
Ol '3 i e surinxese crecx which nes beea ene subsece of various newsgeger l$ 14 articles and discussion here this morning at Comanche Pe k?
2 15 BY WITNESS SCHEPPELE:
j 16 A. Yes, I am.
us d 17 G In what structure is that crack?
E y 18 BY WITNESS SCHEPPELE:
E g 19 A. This would be in a structure which would be above n
20 the land plane. I think I previously explained how this was 21 constructed so that we have a base mat, a liner plate and then 22 Q above the liner plate is the internal concrete which makes up 23 what we call, what we would call the reactor building, which is J 24{n generally massive concrete structures within the containment
)20 where these structures are utilized to support the reactor, the ALDERSON REPORTING COMPANY, INC.
854 8-18 1 steam generators and the coolant pumps, and so forth, and where
( 2 that concrete generally is in many cases, determines the 3 thickness and size by shielding requirements as opposed to
() 4 structural requirements. So that we have generally massive e 5 uses of concrete as a radiation shield.
h
@ 6 Now, the point in question is a shrinktge crack that R
$ 7 took place in a concrete pour that surrounded the reactor vessel.
N j 8 G So then it is not in the base mat?
d d 9 BY WITNESS SCHEPPELE:
b
$ 10 A By definitions which we have established, that's g 11 correct. It is not in the base mat.
W j 12 G Would it be fair for reference to call it the -- in 5
(]) 13 the wall of the reactor building? How would you phrase it?
h 14 BY WITNESS SCHEPPELE:
2 15 A This would be a wall of the reactor cavity. If you 5
g 15 would picture a cylindrical, basically a cylindrical concrete w
d 17 structure, and this is simplified somewhat, but if you would 5
{ 18 picture a cylindrical concrete structure within which the e 19 g reactor would sit, this would be, I would say, a wall of that n
20 particular structure.
21 G How high is that wall? Approximately.
22 BY WITNESS SCHEPPELE:
(]}
23 A The wall is a varying height depending on the view 24 that you would take with a cross-section you would take through
)
25 I the containment. The wall itself, I would say, at its least ALDERSON REPORTING COMPANY,INC.
855 8-19 1 height, would be something in the neighborhood of 35 feet in
() 2 height.
c3 G And --
() . 4 BY WITNESS SCHEPPELE:
e 5 A And the thickness would be in the range of eight foot h
@ 6 six inches as a minimum. Now, that is a considerable concrete R
$ 7 thickness which has been set primarily because of radiation s
l 8 requirements. It is not a structural requirement, but of course d
o 9 we use it as a structural element.
i o
@ 10 g Is there reinforcing steel in that wall?
E j 11 BY WITNESS SCHEPPELE:
j 12 A Yes, there is reinforcing steel, as there always is
(]) m 13 in every reinforced or concrete structure in a nuclear plant.
l$ 14 G Taking the bottom of the reactor cavity wall as je 15 elevation zero, how high on that wall were these cracks found?
j 16 BY WITNESS SCHEPPELE:
M d 17 A Well, now, we have to start establishing a date base E
} 18 again.
P
{
n 19 g Please help us.
20 BY WITNESS SCHEPPELE:
21 A The top of the uppermost foundation mat is an 22 elevation which is 805, elevation 805 plus six inches. That
(]}
23 would be the top of the upper portion of the 12-foot mat.
24 As I mentioned before, this 12-foot horizontal mat k 25 is joined by the vertical mat, was the two levels, so if you ALDERSON REPORTING COMPANY, INC.
856,:
8-20 1 take the upper foundation mat, the bottom of the placemenc 2 which is in question, took place starting at elevation 8056, 3 and that concrete pour then went up to elevation 812, so it O 4 encompasses a height of about six foot six inches that extended e 5 for the most part well over halfway around the reactor itself,
$ 6 and that was on the north side, the cast and the west. On the R
6, 7 south side there was a small opening which goes into the 7.
[ 8 reactor cavity, and at that point that particular pour then d
c; 9 spanned that opening, and at that point that pour was about 13
$ 10 feet deep.
E 11 This is difficult, I'm sure, for you to visualize.
is 12 JUDGE McCOLLOML Well, now, it seems to me that it N
3 Q 13 would be very helpful if you could get a sketch which describes l$ 14 what you've just described so that we can all know that we're 15 talking about the same thing. I don't think it has to be of
-j 16 engineering detail, but in terms of the dimension that you just us I7 got through describing, it would be very helpful.
{ 18 MR. REYNOLDS: We have a sketch, an engineering E
19 drawing. Unfortunately, we don't have enough copies to put them g
n 20 all in the record. We can produce them today. In fact, provide 2I them to the Board at your pleasure, and of course, share with all 22 parties. We have two sets, I believe, and of course we could 23 reproduce more sets later.
O 24 JUDGE McCOLLOM: I think the engineering detail is V
25 ' not important, as much as being able to just put down what he has ALDERSON REPP 'lTING COMPANY, INC.
l . .
857 8-21 1 just described, which can be done in a sketch so that we know l
()
2 that we're all talking about the same thing, like when you 3 identified the base mat and the upper mat and those sort of I
() 4 things.
m 5 MR. REYNOLDS: Would you prefer that we take five 5
8 6 minutes and do that now?
i l
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JUDGE McCOLLOM: I think it would be helpful, j 8 MR. REYNOLDS: We can do that, d
c 9 (A short recess was taken.)
b 10 ///
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ALDERSON REPORTING COMPANY, INC.
9-1 85'8.
E 1 JUDGE MILLER: All right.
O 2 Let's proceed. ,
l 3 MR.REYNOLDS: Mr. Chairman, we request that the drawing '
4 entitled RV Sections & Detail SH .2 be marked for identification e 5 as Applicants Exhibit 21 and that the drawing marked RD Sections 9
@ 6 & Details, Section 1, be marked for identification as Applicants R
b 7 Exhibit 22.
E j 8 JUDGE MILLER: They will be so marked.
d MR. REYNOLDS: Thank you.
E t 10 y, (The documents referred to were
=
fII , marked Applicant Exhibit Nos.21 and d 12 3 22 for identification.)
Q m 13 BY MR. REYNOLDS:
h 14 G Mr. Scheppele, would you describe Applicants Exhibit 2 15 for identification 21?
y 16 BY WITNESS SCHEPPELE:
us 17 A. These drawings, and I have to apologize for the fact h
x
$ 18 that we colored a portion. We did not anticipate using them at 5
19 g this particular hearing -- but these drawings are actually n
20 working drawings that we utilized on the project and for 21 clarification purposes and so we could use this as a point of 22 reference in our discussions.
23 What we did was to color portions of the structure 24 up but these are not special drawings. These are the regular 25 working drawings on the project.
ALDERSON REPORTING COMPANY, INC.
'8590 1 0 When did you color the drawings?
0- 2 BY WITNESS SCHEPPELE:
hP 3 A. These were colored by our staff last Friday.
O 4 o. Thank you.
e 5 Would you describe what that drawing in Appli mnts h
3 6 Exhibit, for identification, 21, depicts?
R b 7 BY WITNESS SCHEPPELE:
N j 8 A. This is a cross-section through the containment d
Structure showing also, in addition to the containment structure, 10 h the internal concrete.
E II 4 These sections are taken at 90 degrees to one another.
is Basically, I think, from what we have already described, you can a
Q 13 see the first cylindrical -- first circular shaped foundation
!$ 14 mat, which would be poured as I previously described and this 15 would be of that diameter.
j 16 Then, this portion of the wall, from here to the as 6 17 underside (witness indicating) --
5 18 Fxcuse me. Can you see me all right?
E 19 From here to the underside --
20 JUDGE MILLER: From here? Pardon me.
21
.. WITNESS SCHEPPELE: From this point here at the top O of the foundation mat -- we're describing it to gain est blish 23 the foundation.
24' O JUDGE MILLER: No, I just wanted for the record, when 25 I
! you say "From here", tell what here is.
i ALDERSON REPORTING COMP ANY, INC.
860 .
~3 I WITNESS SCHEPPELE: From the top of the lower O
ho v 2 foundation mat of 12 foot thickness, then we pour next to the 3 underside of the top 12 foot slab.
O 4 This is egainse the stee1 1iner and then, 1ast1y, 5
the rest of the concrete slab of 12 foot thickness is poured and 6
all of that is heavily reinforced.
R b 7 BY MR. REYNOLDS:
s
] 8 G If that foundation mat is 12 feet thick on that d
9 drawing, what would be the scale?
o b BY WITNESS SCHEPPELE:
II
$ A. The scale is 1/8 of an inch equals a foot.
is j 12 Now, I think as we previously described, then the E
Q 13 steel liner is over the entire top elevation of the foundation
@ 14 mat.
15 That steel liner linked with the steel liner that goes j 16 up the cylindrical wall and over the hemispheric dome, in effect us 17 h creates i leak-tight membrane. So, in effect, you have wrapped x
$ 18 within that cocoon of steel, which is backed up by reinforced 19 8 concrete, you have within that then the reactor building and n
0 the basic auxiliary equipment. Steam generators and the pumps and 21 other radioactive equipment.
p 22 g Please point out the wall of the reactor cavity.
U 23 i BY WITNESS SCHEPPELE:
24 A. The wall of the reactor cavity, as we described, was 25 ' circular in shape and it is a wall which is roughly 8 foot, 6 i ALDERSON REPORTING COMPANY,INC.
Exx 861 9-4 1 inches in thickness and, as I mentioned,at a minimum height from hd) 2 an elevation at the top of the upper foundation mat; this 3 distance would be in the neighborhood of about 25 feet, 28 feet.
() 4 Somewhere in that range.
g 5 That would be from here to here (witness indicating).
6 3 6 And as I mentioned, in other sections, this wall would be
^
e.
y7 considerably higher and if we were to take a section perpendicular 8
to this, this wall would indeed extend all the way up to elevation d
d 9 2,
906 --
o
@ 10 JUDGE MILLER: This wall being what wall?
N 11 WITNESS SCHEPPELE:
$ That wall functions primarily as E
y 12 the refueling canal itall and also supports the upper floor c
(]) 13 elevations of the internal concrete structure.
l$ 14 BY MR. REYNOLDS:
!z 15 g Is the reactor cavity wall inside or outside the
_ 16 f pre sure boundary?
m I7 BY WITNESS SCHEPPELE:
h x
{ 18 A The reactor cavity and the internal concrete are all P
19 8 within the pressure boundary of the containment structure.
n 20 g What is the pressure boundary for that containment 21 structure.
22 BY WITNESS SCHEPPELE:
s 23 , A The pressure boundary would be the steel liner which 24 I previously described and, again, that steel liner would be the 25 l cylindrical wall, the hemispherical dome would come down the ALDERSON REPORTING COMPANY, INC.
9-5 7862{
hop I concrete foundation mat, at the top of the foundation nat, down 2 the wall and across the top of the lower foundation mat.
3 g Now, can you point out for the Board in what location
() 4 on the wall of the reactor cavity the shrinkage cracks were found?
g 5 BY WITNESS SCHEPPELE:
0 3 6 A This is one element that we did not color up so that R
E 7 We could have but we did not, but it would stand out completely.
3 j 8 I can explain to you -- I can explain where this pour took place.
C 9
JUDGE MILLER: Pardon me. We have a red pen here.
o 6 10 g We would like to have you mark it, if you could, and then put
=
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, your initials by it so that the document may be identified c 12 3 subsequently for the record.
o
(]) 13 (Witness complying.)
[ 14 JUDGE MILLER: Describing also in words what you're g 15 doing as you're marking it. Counsel and witnesses may get
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. 16 closer so they can view it' accurately.
e b~ 17 (Short pause while witness marks exhibit.)
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{ 18 JUDGE MILLER: Mr. Scheppele, would you now tell us P
19 in words what you have done with your red pen, so we can have g
n 20 the record matching up with the visual aspects.
2I WITNESS SCHEPPELE: As we pour concrete on major 22
(} structures of this sort, it is necessary to introduce 23 i construction joints into the concrete pours. Basically, to 24 accomodate the structural configurations and also to live within
(}
25 the limits of the concrete placing equipment which is used by I
i ALDERSON REPORTING COMPANY. INC.
l
. . . l 9-6 863 .
E I the contractor.
O 2 Now, in this particular case, the construction had 3 proceeded with a considerable amount of concrete fill. This is 4 mass concrete fill that took place within this depressed area, g5 which we previously described.
A 6 3 I might add that this is depressed because we have E
in-core instrumentation tubes coming out of the bottom of the n
8 a 8 reactor.
O ci 9 JUDGE MILLER: We have what kind of tubes?
- r:
o g 10 WITNESS SCHEPPELE: In-core instrumentation.
E II JUDGE MILLER:
$ Thank you.
is N I2 WITNESS SCHEPPELE: Which come out of the bottom of E
13 the PWR vessel and, therefore, rather than take the whole l$ 14 foundation mat to a much lever depth, we took it just locally at 15 that particular location.
Ej 16 So that prior to the time of the pour which is in as I7 question, there had been a considerable amount of concrete which
!3 18
- had been placed atop of the liner, inside the liner plate, which l~
g 19 makes up the primary containment boundary, pressure boundary, and n
20 the concrete fill had been placed across this walkway and concrete 21 fill had been placed up these walls.
22 O sow, we come to the point in suestion and that 1,this 23 : particular pour, which took place from an elevation which is 8056 24 to elevation 812.
25 I ALDERSON REPORTING COMPANY. INC.
1 l
l 86'4- ~
, .i (il 1 BY MR. REYNOLDS:
(
2 G Would you identify where --
p )
3 BY WITNESS SCHEPPELE:
4 A 8056 is this point and the top elevation is 812.
5 The significance of the 812 level is that this was g
n 6
j the elevation of the adjacent floors beneath the steam generator R
b 7 compartments, so that this concrete placement in those areas R
j 8 extended to the heighth of that floor placement.
d C 9 z,
0 Does the crosshatching which you've drawn in red, h 10 reflect the entire pour?
11
$ BY WITNESS SCHEPPELE:
a -
g 12 A To the best of my knowledge this is the approximate E
f~% a
(_) 5m 13 pour distance. I've initialed it and dated it but the cross-l 14 hatched area indicates the limits of that pour.
g 15 In a section perpendicular to this then, the pour x
y 16 was of smaller configuration and at one point was somewhat deeper A
G 17 because this concrete itself had not been poured previously.
E
{ 18 So at this point this concrete placement was about P
19 13 feet deep. This concrete placement was about 6 feet deep.
n h
20 (Witness indicating.)
21 JUDGE MILLER: What is the second this?
() 22 WITNESS SCHEPPELE: Pardon?
23 l JUDGE MILLER: "This and this". What is the second i
() 24 this? That you're referring to.
25 j W1TNESS SCHEPPLE:, On this side of the reaccor.
l I ALDERSON REPORTING COMPANY, INC.
865' ~$
9-8 I JUDGE MILLER: In words because it's going to be in l
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'v 2 a typed record.
3 WITNESS SCHEPPELE: I can appreciate that.
4 The section that we have here would be a section e 5 looking East. This section, I think, would be a section looking h
@ 6 East. You fellows might give me a --
R b 7 JUDGE MILLER: That exhibit -- when you said "this" Z
8 8 you were referring to Exhibit 22, were you not?
d k 9 Applicants --
E 10 h WITNESS SCHEPPELE: This exhibit would be looking East .
=
II
$ MR. REYNOLDS: Yes. Exhibit 22.
is y 12 JUDGE MILLER: "This" means Exhibit 22, 3 '
Os c.2 I3 Go aheed.
h I4 WITNESS SCHEPPELE: This exhibit would be looking g 15 North.
x 5[
I0 JUDGE MILLER: So that one is "that" and that's going us I7 to be 21.
.h x
{ 18 WITNESS SCHEPPELE: The exhibit whose drawing number E
19 is 0553, is a view looking North.
g n
20 BY MR. REYNOLDS:
21 0 What is the structural purpose for the reactor cavity 22 Q wall?
23 ; BY WITNESS SCHEPPELE:
24 A. The primary purpose; of the reactor cavity wall is to 25 l provide radiation shielding.
ALDERSON REPORTING COMPANY, INC.
866,. . . -
9-9 1 The thickness of that concrete wall is a minimum, hoth 2 as I mentioned previously, was 8 foot 6 inches. It also, of 3 course, serves a structural purpose in that it supports the 4 reactor and transfers the reactors loads down through the concrete 5 fill into the base mat of the containment structure.
g 9
@ 6 '
G Is it designed to provide tensile support?
R I
& 7 BY WITNESS SCHEPPELE:
s j 8 A. As I mentioned previously, concrete is not used as d
ci 9 a tensile resistant material, without the use of reinforcing s
y 10 steel, which, in effect, provides the tensile strength in 5
11 reinforced concrete.
is (E 12 g Is there reinforcing steel in this reactor cavity i
Os m is wa112 l 14 BY WITNESS SCHEPPELE:
15
{m A. Yes, there is.
j 16 g And what purpose does that steel provide?
us N I7 BY WITNESS SCHEPPELE:
$ 18 A. Now that steel provides structural purposes, any E
I9 loading combination that results in tension in the concrete, l g 20 requires reinforcing steel and, generally speaking, in all 21 reinforced concrete construction, we normally have all exposed 22 O ce,c,,,, ,,,,,ce, its ,,1,fe,c1,g ste,1 p1,ced 1,two directions 23 to minimize extensive cracking.
24 g How wide is the crack which was found?
25 I ALDERSON REPORTING COMPANY. INC.
I 867 9-10 1 BY WITNESS SCHEPPELE:
U 2 A The crack that was reported was a shrinkage crack 3 which basically was hairline in appearance. It's a crack which
() 4 would take place in the plane. The same plane as this particular 5 section, g
a
@ 6, G Applicants Exhibit 22?
R b 7 BY WITNESS SCHEPPELE:
s k 8 A This is 22?
d c 9 JUDGE MILLER: Yes.
@ 10 WITNESS SCHEPPELE: 22.
II
$ BY MR. REYNOLDS:
a fo I2 G Would you repeat that answer?
13
()f BY WITNESS SCHEPPELE:
14 A The shrinkage crack which was reported, took place 9 15 y at a point on the North side -- and this would be North side of x
6 Exhibit 22, at a point which was direct North on the reactor hI x
cavity and on the South side of the reactor cavity, which would M 18
- appear in this plane in reference or in -- this is document 22?
- 19 g G Yes.
20 BY WITNESS SCHEPPELE:
21 A It would be at this location (witness indicating) on 22 Os the South surface of the reactor cavity.
23 g Mr. Scheppele, what did you intend to depict when 24 O you cross hatched Applicants Exhibits 21 and 22?
25 '
I I ALDERSON REPORTING COMPANY,INC.
l 868 '
i 9-11 !
1 BY WITNESS SCHEPPELE:
ho ~
2 A Well, the intent was to indicate very clearly the 3 concrete that was in question and, also, put it into perspective 4 from the viewpoint of seeing its impact in looking at the whole s 5 structure.
h
@ 6 G Well, is there a crack depicted on Applicants Exhibit R
b 7 21?
E
[ 8 BY WITNESS SCHEPPELE:
O q 9 A No. The crack is not depicted on either of these i
10 exhibits, other than by description.
h
=
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$ O Then your cross hatching is intended to show the a
g 12 pour, the concrete pour that was in question?
c
() 13 BY WITNESS SCHEPPELE:
E 14 g A That's ccrrect.
m 2 15 w
m 0 I see.
It is not intended to diagram or depict the crack G 17 w itself?
z M 18
= BY WITNESS SCHEPPELE:
19 l A That's correct. This crosshatched section would be 20 one which would clearly indicate the extent of the concrete that 21 was placed in the pour that's in question.
() The total pour that's in question.
23 G And Applicants Exhibit 22 shows a cross-section of
' n 24
() the approximate locations of the crack in the areas which are 25 '
cross-hatched?
ALDERSON REPORTING COMPANY. INC.
l
' 8,6 9 1
BY WMNESS SCHEPPELE:
9-12 2 A That would be correct.
g 3 g What is the structural significance of that crack?
p) s 4 BY WITNESS SCHEPPELE:
l l
5 A This crack is one which is a shrinkage crack. It's a g
a 3 6 very small hairline crack which is not unusual from the viewpoint
^
n b 7' of mass concrete. We're talking about concrete which is quite M
{ 8 thick, as I mentioned, which is primarily there for shielding d
d 9 purposes.
o g 10 Now, from the viewpoint of the actual way in which
$ I1 this concrete works as a structural element, the concrete to the 3
12 North side functions simply as a conrete wall. It has no function I
]5 13 other than to transfer the vertical load from the point of the lt 14 reactor loadings down through the wall and into the base mat of 15 the containment structure, g 16 G Does the existence of that crack compromise the us 6 17 transfer of vertical loads?
a:
18 BY WITNESS SCHEPPELE:
- 19 g A It does not compromise that structure in any way.
n 20 g Is this hairline crack straight or jagged, sawtoothed?
2I BY WITNESS SCHEPPELE:
22 A That crack -- shrinkage cracks always exist in l 23 : concrete structures as a jagged line. It's never a straight 24 It's a jagged line which can transmit sheer forces.
l surface.
25 l g Why are --
ALDERSON REPORTING COMPANY. INC.
870 '
9-12 1 JUDGE MILLER: Pardon me. 5 '
ho s 1 2 Did you observe this crack yourself? s \
3 WITNESS SCHEPPELE: I did not observe .this crack
( 4 myself but I have observed many shrinkage cracks in concrete g 5 structures where --
a
$ 6 JUDGE MILLER: We're talking just about this particula :
R d 7 one, I believe now.
3 j 8 MR. REYNOLDS: That's correct.
d d 9 WITNESS SCHEPPELE: I have heard it described. It is
[
10 h not dissimilar from what I would anticipate seeing, had I been
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- 5 there.
s fo I2 BY MR.REYNOLBS:
()f13 % Mr. McGrane, did you observe the shrinkage crack in
@ 14 question?
15
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=
BY WITNESS MC GRANE:
d I0 A w
I did observe the crack.
I7 g h
=
And would you concur with what Mr. Scheppele said in
$ 18
= his description of it?
- 19 i 8 BY WITNESS MC GRANE:
l l 20 A I certainly would.
21 G Mr. Scheppele, why are shrinkage cracks normally 22 r-)s
(_ Jagged?
23 BY WITNESS SCHEPPELE:
24 r~)
(, A Shrinkage cracks usually result in mass concrete 25'! pours because there is heat generated by the chemical action in ALDERSON REPORTING COMPANY. INC.
s
871-3-13
!h op 1 the placement of the concrete and as that mass, concrete mass O 2 tends to cool and also tends to relieve itself from the moisture 3 which is within it, initially, there is a tendency for that O 4 concrete to shrink and when it does shrink and is restrained in o 5 some way, then its possible that the small hairline cracks would h
j 6, develop to relieve that stress.
R
$ 7 G Would the jagged characteristics of most hairline j 8 cracks also be attributable to the existence of aggregate in the d
d 9 concrete?
b g 10 BY WITNESS SCHEPPELE:
E 11 A. Yes. I think that when you get this tension force is j 12 which I mentioned previously, concrete is not good at 5 / r Q 13 withstanding. When you get this tensile force resulting from l$ 14 the shrinkage, then the conrete does have hairline cracks, which
[x 15 seek out the most -- the weakest, point in the concrete' matrix.
sj 16 Whether this is in the concrete paste or the aggregate ess I7 would depend on the mix, but you always get generally a very h
=
$ 18 ragged lines from the viewpoint of the shrinkage crack. /
e I9 g 0 Mr.McGrane,doyouhappedtoknowthesizeofthe 20 aggregate in thia concrete pour?
BY WITNESS MC GRANE:
^ 22 Q A. That concrete pour, the aggregate was specified to 23 be an inch and a half.
24 25 ALDERSON REPORTING COMPANY. INC.
1 I
872>
/14 1
1 JUDGE MILLER:. Please continue.
r-
' </ 2 WITNESS SCHEPPELE: We have one unfinished point here 3 that we shou?d mention.
[) 4 We discussed a crack onthe North side of the e 5 containment structure. We did not discuss the crack on the d
j 6 South side of the containment structure.
R h7 u
At this particular point, we have a rather large g 8 wall, although this wall is cast in various layers, that wall d
acts as a composite section, so that in effect, when the reactor o
10 h load is introduced, the total thickness of concrete, which is II 5 roughly 35 feet from this point to this point (witness is
,3 f I2 indicating), would basically span this small opening, supporting 13 J g the reactor on a wall-shaped structure.
I4 '
The portion of the pour which we have described previously as being the one in question and in which a small hairline shrinkage crack was found, was in this lower 13 foot I7 portion of the wcil.
h IO b
JUDGE MILLER: Wait a minute now.
P 19 e Has that crack been marked?
n 20 At least the pointer wasn't coincident with the marks.
2I MR. JORDAN: My understanding, Mr. Chairman, that the g 22 cross-hatching on Applicants Exhibit 22 represents both the 23 size of the pour and the size of the crack.
t g 24 Mr. Scheppele, is that correct?
25 i WITNESS SCHEPPELE: That's correct.
ALDERSON REPORTING COMPANY,INC.
873 9-15 1 This would be the plane of the crack, roughly A
hoh-) 2 speaking, from the viewpoint of the concrete shape. There would 3 be a shrinkage crack in this plane (witness indicating) ; a
() 4 shrinkage crack in this plane (witness. indicating).
o 5 BY MR. REYNOLDS:
5 h 6 g The cross-hatched part on Applicant. Exhibit 22, E
E 7 then, is the plane of the crack?
A j 8 Am I correct?
d c; 9 The lined in a single direction on Applicants Exhibit 10 21 describes the dimenaion of the pour?
h=
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$ BY WITNESS SCHEPPELE:
a g 12 A In that plane; that's correct.
() 13 This also represents, on Exhibit 22, the extent of the 3 14 g pour. It was only to this point and to this point (witness x
15
{m indicating).
j
. 16 You see, it was relatively small in this section and w
d 17 larger in this section (witness indicating).
E
{
18 g But you assumed, then, that the crack, the hairline
- 19 g crack went clear through the wall?
n 20 BY WITNESS SCHEPPELE:
21 A Yeah.
22 g
(]) why do you think it went clear through the wall?
23 ; JUDGE MILLER: Pardon me.
() I think we better get that marked then, Counsel.
MR. REYNOLDS: It is marked.
ALDERSON REPORTING COMPANY. INC.
1 3-16 I
'874 ~ l' .
)
l Top '
1 Oh, you mean the wall?
2 JUDGE MILLER: I'm having difficulty following --
3 BY MR. REYNOLDS 4 G Is that because the crack that you're talking about g 5 was associated with the interface between the old pour and a new 8
@ 6 pour?
R b 7 BY WITNESS SCHEPPELE:
A j 8 A. No, that was not.
d d 9 This was a continuous pour at this elevation.
z o
10 g Elevation 805.
h
=
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$ BY WITNESS SCHEPPLE:
is f I2 A. 8056 going on up to 812.
O!IE W 14 JUw E MI uER: Weit a minute -w.
Let's get clear -- I'm just sitting here and I'm not 9 15 y down there in the pit with you -- what are those red marks and x
6 initials? With reference to any cracks or if that be what it
(( 17 .
w is purporting to show.
m 5 18
= If not, what does it show?
19 8 WITNESS SCHEPPELE: The cross-hatch sections that I n
20 initially had shown here -- let's take Exhibit 21 --
JUDGE MILLER: 21.
O W rurss scazerzts: -- cro==-heech sectioa whica now 23 l the limits of the concrete pour within question from the O viewpoiae or ene eree ia which ene crecx enge rea- !
25 I l JUDGE MILLER: The limits of the pour?
ALDERSON REPORTING COMPANY, INC.
875.
9-17 a hop 1 WITNESS SCHEPPELE: The limits of the peur, from 2 right here to - '
3 JUDGE MILLER: Now, let's stay right there, with 4 the limits of the pour.
e 5 WITNESS SCHEPPELE: That's correct.
] 6 JUDGE MILLER: Now, what is the red marking here R
$ 7 with your initials on it, limits of the pour? What is that j 8 purporting to show?
d c; 9 WITNESS SCHEPPELE: That shows the limits of the 3
@ 10 pour on this cros's section.
II k JUDGE MILLER: All right.
3 i fc I2 Now, what does that have to do with any crack? l 1
I WITNESS SCHEPPELE: Well, I think its reasonable to E 14 y assume that in setting up the parameters of this concrete
=
9 15 2 placement, its necessary to know, obviously, between what x
16 P
j elevations that concrete pour took place, because that defines 6 17 w the problem.
18 JUDGE MILLER: We're not getting ourselves on the same A
19 wave length.
h n
20 I'm talking about a crack, an alleged crack. Correlatp 21 those if you would.
g 22 MR. REYNOLDS: May I try to help him?
23 , JUDGE MILLER: Yes.
l 24 BY MR. REYNOLDS:
25 ; (L Mr. Scheppele, if we were looking at this structure ALDERSON REPORTING COMPANY, INC.
876
@-18 I from above, in which directions would the crack be radiating?
A UE 2 BY WITNESS SCHEPPELE:
3 A Those would be perpendicular to the plane.
4 g Coming out toward us and going into the wall?
5 BY WITNESS SCHEPPELE:
$ 0 That's correct, A
e.
G On Applicants Exhibit 21?
E 8 M BY WITNESS SCHEPPELE:
d A That's correct.
E H 10 E G And on Applicants.Exhibita22, how are they depicted?
BY WITNESS SCHEPPELE:
d 12
. E A Applicants Exhibit 22 is a right-angled section here.
t 3
13
@ So, in effect, we're looking in this direction, we're looking E 14 y North and the crack that we would be discussing would be a crack
=
9 15 g that would be in this plane.
16
$ % So, in other words, the cross-hatching on Applicants i
d 17 g Exhibit 22 is both the size of the pour and the dimension of the
!5 18
= crack?
19 8 BY WITNESS SCHEPPELE:
!' 20 A That's correct. The plane of the crack.
21 JUDGE MILLER: Well, wait.
O The 91 ene or the dimension of the crecx2 That's where
! 23 '
1 I keep getting confused.
(~'N 24 MR. REYNOLDS: It's both.
O 25I' Is it both, Mr. Scheppele?
I l
l ALDERSON REPORTING COMPANY, INC.
i 877..
!9-19 I 1 WITNESS SCHEPPELE: That's correct.
- hoO 2 i
ey xa. aEyNoi.oS:
t 3 G Is Exhibit 22 facing North?
4 BY WITNESS SCHEPPELE:
e 5 A That's correct.
k h 0 G Then the crack r'uns East and West?
g .
b 7 i BY WITNESS SCHEPPELE:
3 8
k A. That's correct.
d d 9
, No. The crack runs North and South.
o 10 JUDGE MILLER: This is inconsistent.
h 11
$ We are going to take five minutes here. Let's get is g 12 , a consistent coherent testimony and the crack and the red marks O *! '3 i . ena e11.
1 h I4 i (Short recess.)
g 15 jjf
=
j 16 us d 17 M 18
- 19 A ;I 20 ;
21 22 23 l t 24 O i 25 l ALDERSON REPORTING COMPANY, INC.
.878 TLO-1 1 MR. REYNOLDS: Mr. Chairman, we have a drawing titled 2 RB Internal Structure El. 808 feet zero-inches outline to be 3 marked for identification as Applicants' Exhibit 23.
O 4 acDcE MILLER: It will be marked 23.
m 5 (Applicants' Exhibit No. 23 was h
3 6 marked for identification.)
R 6, 7 JUDGE McCOLLOM: What is that elevation again?
A
[ 8 MR. REYNOLDS: 809 and no inches.
O c; 9 BY MR. RE"NOLDS:
8
$ 10 0 Mr. Scheppele, would you describe Anplicants' E
II Exhibit 23 for identification?
is 12 BY WITNESS SCHEPPELE:
N Os5' m A- I think with Exhibit 23 this now will clarify the l$ 14 cross-sections and looking north and east, and so forth.
15 This is a plan view of the containment. North is j 16 to the left.
us 17 Exhibit 22 is a section looking east. The h
18 designation on Exhibit 23 is Section 11, which is a section cut i3 s 19 in this form, and Section 11 is shown on Exhibit 22.
n 20 So in effect, Mr. Scheppele, this is an overview of 0
2I Applicants' Exhibits 21 and 22?
' 22 BY WITNESS SCHEPPELE:
23 l A. That's correct.
24 Have you marked on Applicants' Exhibit 23 the
) %
25 l placement of the cracks?
ALDERSON REPORTING COMPANY, INC.
1 l
~
8'79 -
10-2 1 BY WITNESS SCHEPPELE:
2 A. Yes. The cracks that were reported to us are 3 oriented approximately in this direction, as we were trying to O 4 exgtein the creck on the north eide of the we11 wee e crack which e 5 was in this plane on Exhibit 22, and so --
h h 6 JUDGE MILLER: Well, have you marked A, B and C, then, R
$ 7 the red marks that are showing up on Exhibit 23?
A j 8 WITNESS SCHEPPELE: We show on Exhibit 23 the fact d
d 9 that this concrete crack here is in the range of, in a slab d
g 10 which is six foot six inches deep and that's six foot --
25 j 11 JUDGE MILLER: Hold it, now. This concrete slab here 3
y 12 which you pointed to --
Q 13 WITNESS SCHEPPELE: This concrete --
l s
14 JUDGE MILLER: -- put an "A" on it, or some way so 2 15 we can distinguish it from all other marks.
j 16 WITNESS SCHEPPELE: This concrete slab at the north us
![ 17 side of the reactor, the pour which was made, which was six foot
$ 18 six inches high, has been so labeled on Exhibit 23 and also is i
3 19 shown on Exhibit 22.
M 20 BY MR. REYNOLDS:
21 G Have you further marked Applicants' Exhibit 22 and 23 22 for clarification purposes?
23 BY WITNESS SCHEPPELE:
24 A. Yes, we've now shown the reported crack, which is i 25 l labeled as "A" here. It's shown as "A" on this cross-hatch l ALDERSON REPORTING COMPANY,INC.
880 C 10-3 1 . section, "B" shown on the south side has also been similarly 1
2 labeled "B" on Exhibit 22.
3 JUDGE MILLER: So we've got two cracks?
4 WITNESS SCHEPPELE: That's my understanding, sir.
g 5 JUDGE MILLER: Okay. Hate you described them? I
@ 6 don't want you to repeat, but I'm not sure I was folling you R
6, 7 with reference to the two cracks. I was laboring over one, I s
j 8 thought.
O d 9 WITNESS SCHEPPELE: I can appreciate that. These
$ 10 are basically shrinkage cracks. They're small hairline cracks,
$ 11 cracks which I previously explained was due primarily because of a
p 12 the heating and then eventually the cooling of the concrete 5
d l
Oa 13 caused by the chemical reaction.
l$ 14 BY MR. REYNOLDS:
~*
G Now, when we combine Applicants' Exhibit 22 and g 16 Applicants' Exhibit 23, do we have a three-dimensional perspective us b^ 17 of the cracks?
M
{ 18 BY WITNESS SCHEPPELE:
E y 19 A. Yes, we do.
. n 20 JUDGE MILLER: Cracks? Pardon me; plural, cracks?
l 21 MR. REYNOLDS: Yes.
22 JUDGE MILLER: Fine. Go ahead.
23 WITNESS SCHEPPELE: That's correct.
l 24 BY MR. REYNOTDS:
25 G What is the blue marking on Applicants' Exhibit 23?
! ALDERSON REPORTING COMPANY, INC.
881 ,,
10-4 1 BY WITNESS SCHEPPELE:
2 A. This blue marking -- and bear in mind that Exhibit 23 3 is to a different scale than Exhibits 21 and 22 -- the blue O 4 merking besice11y indicetee the 11mies of the internet concrete m 5 inside the pressure boundary which would be defined in Exhibit 22 b
@ 6 as these circular walls making up the vertical portion of the R
@, 7 foundation mat.
y 8 JUDGE COLE: So all of the shaded blue on each of d
ci 9 the three exhibits, 21, 22 and 23, is internal concrete?
$ 10 WITNESS SCHEPPELE: That's correct, and we did not E
g 11 color all of the sections blue. We only colored the areas is y 12 immediately around the area in question, because had we colored E
() 13 all sections blue it would have been necessary to actually l$ 14 color in all those cross-sections in each of the exhibits in 15 which there is presently shown a coloring. We just did this gj 16 to reinforce the coloring in a specific area.
us
!;[ 17 BY MR. REYNOLDS:
s
{ 18 G Let me be clear, then. The shading on Applicants' i:
j {
n 19 Exhibit 23 reflects concrete below the elevation of the pour in 20 question?
21 BY WITNESS SCHEPPELE:
22 A. The brilliant blue does that. The other shading on 23 this particular drawing represents the sections through the 24 concrete itself at that particular elevation on Exhibit 23,
! 25 l which is elevation 808.
ALDERSON REPORTING COMPANY. INC.
'882' I
10-5 1 0 Mr. Scheppele, why, in your professional opinion, O 2 did the crecke occur where they did2 3 BY WITNESS SCHEPPELE:
O 4 x The confieureeton of the concrete e1ecemene, which e 5 basically encompassed, as shown on section -- limits of 6
$ 6 Section 22, were ones where the concrete pour extended roughly R
{ 7 from the outside face of the steam generator wall on the east to a
j 8 the outside face of the steam generator wall on the west.
O d 9 This was a pour of roughly 88 feet, in that range.
- i h 10 The pour transversely, right at this particular junction at the l
is 11 reactor vessel was approximately eight foot six inches across in y 12 thickness as shown on Exhibit 22.
Q 13 This creates a plane here which indeed if that /
l$ 14 shrinkage crack were to occur, it would most likely occur at 2 15 that point of a reduced concrete section.
gg 16 This could also have been a construction joint and us ti 17 would have been reasonable. We would have accepted a
$ 18 construction joint at that particular location.
E g 19 % What is a construction joint?
20 BY WITNESS SCHEPPELE:
21 A A construction joint would be the placement of form 22 work, and instead of pouring the entire placement in one pour, 23 , it would be poured in two sections using the form work at that 24 particular location as a dam. Then after the concrete had
( 25 hardened, that form work would be removed and the adjacent ALDERSON REPORTING COMPANY, INC.
( , ..
883.'
10-6 1 concrete would be placed.
O 2 e Wou1d there heve seen eny seructure1 diseinceien 3 between a pour, continuous pour such as was done and a pour with O 4 conseruceton 30ines2 g 5 BY WITNESS SCHEPPELE:
8 3 6 A In my opinion, very little.
R
& 7 0 What --
N 8 8 BY WITNESS SCHEPPELE:
d d 9 A I would say we would look very closely at the key E
10 g arrangement from the viewpoint of shielding, had we created a
=
11 construction joint at that particular location.
-$ Actually, with s
g 12 a shrinkage crack nature does that for you because it creates a 25 Q 13 surface which is rough and a surface which does not diminish the l$ 14 purpose of the radiation shielding.
g 15 g Would the placement of keys been only for radiation a:
ig 16 shielding purposes?
us
!i 17 BY WITNESS SCHEPPELE:
{ 18 A It would be to transmit shear, too, just as the E
19 g
n very roughened surfaces that exist on a shrinkage crack would 20 transfer shear.
21 g In your professional opinion, is there any structural 22 problem that arises as a result of this shrinkage crack?
23 BY WITNESS SCHEPPELE:
24 A In my opinion, there is no structural integrity lost 25 I with this kind of a shrinkage crack at this particular location.
I ALDERSON REPORTING COMPANY, INC.
! 884 ,
LO-7 1 As I mentioned previously, the stresses in the
( 2 concrete immediately surrounding the reactor are generally very 3 low because the concrete thickness was not set by structural
() 4 considerations. So in looking at the overall composite e 5 structual member which does include more than the just one pour b
$ 6 alone, because the concrete wall, for example, that is immediately R
$ 7 around the reactor, as I previously mentioned, is something that j 8 extends at least 29 feet, is more than adequate to transfer that d
q 9 load back into the adjacent concrete structures and thence into
$ 10 the foundation mat of the containment structure.
E j 11 O In your opinion, is this a major deficiency in k
N I2 construction?
5
() 13 BY WITNESS SCHEPPELE:
l 14 A In ny opinion it is not.
15
{x 4 In your opinion, is it a minor deficiency in E I6 construction?
w N I7 BY WITNESS SCHEPPELE:
$ 18 A I would say it would be a minor deficiency.
E 19 G Would you say it is the type of deficiency that g
n 20 should be reported to the Nuclear Regulatory Commission?
2I BY WITNESS SCHEPPELE:
() 22 A I think from the viewpoint of shrinkage cracks and 23 ; locations of this sort there is not a compromise in structural i
24 adequacy and therefore I see no reason to make a federal case
[]}
25 out of this particular type of structural problem.
ALDERSON REPORTING COMPANY,INC.
O
l
'885-1 G What do you mean by federal case?
\
2 (Laughter.)
3 BY WITNESS SCHEPPELE:
4 A. I'm sure I used the wrong terminology there.
e 5 (Laughter.)
$ 6 This was something which I feel is adequately R
$ 7 handled by means of remedial procedures, if there is any required 7.
j 8 at this particular location. It's something that can readily d
ci 9 be handled between the Quality Assurance organization at the
$ 10 site and the engineer who is responsible for the design.
$ II G From a structural standpoint, was the reactor cavity is j 12 wall impaired?
5
) y 13 BY WITNESS SCHEPPELE:
- n h 14 A. This reactor cavity wall will indeed perform in the 15 way it was intended, and there's not a structural ceficiency j 16 because of this shrinkage crack.
us N I7 JUDGE MILLER: I think the question was would it be u
{ 18 impaired, but to a greater or lesser extent. Would it be E
19 imptired, first, and then you may describe the extent.
g n
20 WITNESS SCHEPPELE: My viewpoint is that the strength 21 is not impaired because we have made judicious use of reinforcing 22 steel to account for situations in which the concrete cannot take
)
23 4 tension.
24 BY MR. REYNOLDS:
)
25 l G Has the radiation shielding capability of the concrete i
i ALDERSON REPORTING COMPANY. INC.
i 886
i-9 ) been impaired?
O\
V 2 BY WITNESS SCHEPPELE:
3 A It has not.
r 4 G Please describe the repair procedures which were e 5 implemented to fix the crack. 1 l
5 8 6 BY WITNESS SCHEPPELE:
I k 7 A The repair procedures were --
a i
[ 8 G Cracks.
O d 9 BY WITNESS SCHEPPELE:
$ 10 A -- were minimal.
E j
D 11 JUDGE MILLER: Thank you.
g 12 BY WITNESS SCHEPPELE:
(]) 13 A The repair procedures were minimal. The repair l$ 14 procedures were primarily cosmetic from the viewpoint of sealing 2 15 the outer roughly inch or inch and a half of that hairline crack E
g 16 with grout, so that there could be a very smooth surface which w
d 17 could be painted in that vicinity and not be subject to any local u
{ 18 spalling, so that the surfaces on the vertical surface of the e 19 reactor concrete, as well as the underside of the concrete 20 surface, where these cracks were exposed, was fixed by means of 21 V'ing out a notched configuration and then placing grout in that 22 V-notch to fill it in.
(~}
s.-
23 JUDGE MILLER: Pardon me. I think you used the term 24 spalling. Would you define that for the record, please?
}
25 WITNESS SCHEPPELE: I would say if you have a ALDERSON REPORTING COMPANY. INC.
88.7-f 10-10 I hairline crack there may be a tendency over time to have small 2 pieces of concrete chip off the edges of that crack through the 3 plant operation, or whatever means. It's a very unlikely thing O 4 but te cou,.d conceiveb17 heggen, end if you have e geinted p 5 surface at that particular point it's best to avoid that.
A
$ 6 JUDGE MILLER: Yes. What does the term spalling R
& 7 generally mean, apart from this?
s j 8 WITNESS SCHEPPELE: Spalling probably has several d
d 9 definitions as far as a structural engineer is concerned.
$ 10 Spalling could conceivably mean concrete which would be sort of j 11 a scabbing on the surface, if you would have a structural member is
{ 12 very heavily loaded in which the reinforcing steel was very Oli3 neev11v sere ==ed- r wou1d enin* enere =isat de e eoe ibi11er l$ 14 to get spalling, at least by my definition.
15 JUDGE MILLER: Well, is spalling now scaling? I'm j 16 trying to get spalling, what causes it or --
us d 17 WITNESS SCHEPPELE: Let's perhaps use another term 5
18 rather than spalling.
h E
19 JUDGE MILLER: Well, I like spalling because I want g
n 20 to get it defined. Give me the deIinition and I'll stop 21 inquiring.
22 WITNESS SCHEPPELE: In this particular area, let's 23 say that definition of spalling is one in which there's a 24 hairline crack. If indeed during plant operation that surface 25 l is hit, for some reason or other, there might be some tendency ALDERSON REPORTING COMPANY,INC.
888 ~~
l10-11 1 for that concrete immediateJy adjacent to that crack to become
' disengaged from the main source of concrete.
2 This might mean a 3 very small quarter of an inch, cighth of an inch surface 1
() 4 imperfection which could be alleviated by means of the remedial e 5 measures which we've described.
h 6 JUDGE MILLER: Sometimes the walls of a building R
R 7 which is subjected to some seismic forces, and so forth, have j 8 been described as spalling, have they not? That's a use of the d
d 9 term?
$ 10 WITNESS SCHEPPELE: It could be.
E j 11 JUDGE MILLER: All right. What does it mean, then, j 3 l
{ 12 in that sense? You've got an earthquake, you've got walls,
(]) 13 you've got spalling. What do you have?
! 14 WITNESS SCHEPPELE: I would say in that particular g 15 case it's probably a situation where the concrete physically is e
g' 16 removed from the structural member.
A d 17 JUDGE MILLER: So it's cracked; cracked and partially 5
M 18 and --
5
{ l 19 WITNESS SCHEPPELE: On the principle in which M
20 concrete is removed from a structure, then it would be c racked .
21 JUDGE MILLER: Okay. Thank you.
22 ///
(])
23 I 24 (v~3 25 ALDERSON REPORTING COMPANY, INC.
889 10-12 1 BY MR. REYNOLDS:
2 O Mr. Scheppele, what repairs were effected to the top 3 of the cracks?
4 BY WITNESS SCHEPPELE:
1 e 5 A. Well, subsequent placement continued on with the 5
$ 6 following placement of concrete lifts in the vicinity of the R
& 7 reactor vessel.
l M j 8 G What is the normal course for a subsequent --
r) d 9 BY WITNESS SCHEPPELE:
, l
$ 10 A. Normally the practice here is to -- if we were to E
11 take the pour in question, when we continue on with a wall pour is j 12 it's necessary to expose the aggregates at the elevation of the Olis 14 tog of the grecemene. In chie cese it wou1d de et e1evetion 812.
@ We would do that by means of air jets or water jets. It would be 15 to expose the aggregate and improve the -- remove the imperfection s j 16 that had taken place in the lower concrete pour so that the next us 1
{x 17 concrete pour placed against it would be properly bonded. There
$ 18 would also be a rough joint created at that point that would E
19 maintain its integrity as far as a radiation snield.
20 0 That is the routine procedure. Was that procedure 2I employed here?
22 l
O sY WI, NESS ScsE,PELE, 23 ; A. I was not at the site personally. That would be a l
24 question for Quality ssurance.
25 I G Mr. McGrane, could you answer that question?
ALDERSON REPORTING COMPANY, INC.
l 890 0-13 1 BY WITNESS McGRANE:
l() 2 A I wasn't at the site either, but I can say that 3 since it was inspected by people in the field and specifications
() 4 required that it be done that way, I would assume that that's e 5 how it was done that way here as it would have been done in all h
3 6 other horizontal --
R
$ 7 0 Mr. Tolson, as site QA supervisor, can you answer s
j 8 the question?
O d 9 BY WITNESS TOLSON:
i o
g 10 A Mr. McGrane state that it's appropriate. It's 11 standard procedure on succeeding placements to level the surface s
j
- 12 of the previous placements just prior to placing the concrete.
5
(]) 13 JUDGE MILLER: Pardon me. I don't hink we're asking
$ 14 about standard procedure or general procedure. We're trying to g 15 find out if someone has direct knowledge of what, if anything, x
g 16 was done in this instance. If you don't, it's a fair answer to A
17 say you don't know, but we're trying to find out who did.
m
} 18 Does anyone know who would have.that direct P
g 19 knowledge?
n 20 BY WITNESS McGRANE:
21 A I think I can answer that by saying that there was 22 ' no special repair required at that point, and all that needed to
(])
23 be done was to place the concrete above the surface of that crack 24 in a normal manner.
25 i JUDGE MILLER: So that kind of repair was not done, I
! ALDERSON REPORTING COMPANY, INC.
1 891;
- 10-14 1 then, in this instance?
() 2 WITNESS McGRANE: It was not required.
3 JUDGE MILLER: All right. Well, it was not required
() 4 and it was not performed.
e 5 WITNESS McGRANE: It was not done, h
3 6 JUDGE MILLER: Thank you, sir.
R R 7 Okay. Go ahead.
A j 8 BY MR. REYNOLDS:
G c 9 0 Mr. Scheppele, you testified that the cracks on the
$ 10 sides on the vertical surfaces were v'd out. Do you mean to E
g 11 say V or do you mean notched?
E j 12 BY WITNESS SCHEPPELE:
() 13 A I would say it was a V-notch.
lm 14 0 What does that mean?
C 15 BY WITNESS SCHEPPELE:
j 16 A It's a notch with a V configuration.
e d 17 g How many points where the V is?
{ 18 A It's triangular, it's roughly triangular.
{ 19 0 And then what type of compound was inserted in the n
20 notch?
21 BY WITNESS SCHEPPELE:
(~) 22 A I think in this case they used a special bonding
\.s 23 compound. I am not sure of the trade name. I believe it's in 24 the files. It was something that was recommended by the 25 ' contractor and accepted by the engineer.
l ALDERSON REPORTING COMPANY, INC.
8'92 10-15 1 g Mr. McGrane, do you know the name of the substance O 2 e1ecea in the crecks2 3 BY WITNESS McGRANE:
O 4 A It was e -- ehe trade neme of it wes, I be1ieve, c 5 Burke-plog.
h j 6 g Say again and spell, please?
R
& 7 A I'm not sure of the spelling, but I believe it's s
j 8 B-u-r-k-e and plog, p-1-o-g.
O d 9 G Mr. Scheppele, were other repair procedures g 10 contemplated and studied before the repair procedure that was j
11 effected was adopted?
3 g 12 BY WITNESS SCHEPPELE:
In Q jm 13 A No.
l
$i 14 g So this was the first repair procedure that was 2 15 considered?
E y 16 BY WITNESS SCHEPPELE:
as p 17 A Yes. Actually, what we're considering here is a
{ 18 treatment of a surface, and that is a relatively minor repair h 19
, procedure.
M 20 ///
21 22 0
23 ,
24 25 !
ALDERSON REPORTING COMPANY, INC.
893-10-16 1i BY MR. REYNOLDS:
I O 2 e 00 rou rece11 the eperoximeee deee of the pour which 3 led to this situation?
4 BY WITNESS SCHEPPELE:
e 5 A I'd have to refer to the written record on that.
h
$ 6! G Can a member of the panel help, approximate month R
$ 7 and year?
s
[ 8 BY WITNESS McGRANE:
O d 9 A I believe it was April 1977.
$ 10 0 Mr. McGrane, do you happen to know when the repair j 11 was effected?
is g 12 BY WITNESS McGRANE:
Q 13 A. I know only by hearsay.
l$ 14 G Well, why don't you tell us what you think you know?
2 15 BY WITNESS McGRANE:
g 16 A. I was informed of the repairs, the surface repair us 6 17 which exposed a portion of the crack. It was conducted
{ 18 approximately two years later in 1979.
E 19 0 Can you give us a month?
g n
20 BY WITNESS McGRANE:
21 A. No, sir, I can't.
22 4 Mr. Merritt, can you give us a month?
- 23. , BY WITNESS MERITT:
24 A. No. The repair was carried out over a -- as 25 Mr. McGrane has indicated, over a two-year period, part of which ALDERSON REPORTING COMPANY. INC.
l 894 j '
i)-17 i was the inclusion of bringing up the next lift of concrete, and !
\ 2 then the repair itself, I believe on the exposed surface, was 3 done shortly after, but I'd have to go back to the records.
() 4 G Mr. Tolson, can you give us a month?
e 5 BY WITNESS TOLSON:
A N
6 A It was either February or March of 1979.
R
& 7 G Thank you, s
l 8 Mr. Merritt, why was there a delay of two years G
d 9 before the sides of the cracks were repaired?
b
$ 10 BY WITNESS MERRITT:
E 11 A Well, again going back'to a judgment on this, we 4
k 12 did not consider that to be a major, or even a mir.or type problem with shrinkage cracks as such.
(]) 13 It was more of a l$ 14 convenience, I believe, to the site at that point in time, and 2 15 accessibility, removal of form work so you could get at it, and 5
g 16 the like.
W d 17 G Mr. McGrane, is there any possibility that the
$ 18 reinforcing steel in that section of concrete where the cracks 0
19 occurred could rust or corrode to the extent that it would be R
20 of structural significance?
21 BY WITNESS McGRANE:
r^s 22 A I do not believe so.
V 23 , G On what facts do you base that statement?
g^ 24 BY WITNESS McGRANE:
N 25 f A First, the crack was very small. It was hairline, ALDERSON REPORTING COMPANY. INC.
895 10-18 1 and it would be very difficult for anything to -- well, there's 2 no source, let's say there's no real source of corrosion there.
3 G What would be typical sources of corrosion?
O 4 Br W1TNESS McGRANE: :
e 5 A I guess basically water, water and air, and a d
j 6 considerable amount of it.
R
$ 7 Let me just make a note in regards to shrinkage s
j 8 factors. These are relatively common phenomena in many poured d
c 9 concrete structures. They occur even in structures such as
'i o
g 10 water intake structures, structures that are immersed in water, E
j 11 and experiences says that it has not proven detrimental to those is
.j 12 structures. There has not been corrosion on those structures.
Olis 14 Thoee structures heve not feitea deceuse of the effects of water.
g Was there a source of water which would have fed 15 into th cracks during the period April 1977 through February-g 16 March 19797 v5
@ 17 BY WITNESS McGRANE:
5
{ 18 A. There may have been from time to time some small E
19 accidental spillage of water one way or another, but certainly g
n 20 not in any significanat amount, past the first stage, which is 21 the curing of concrete.
22 Q g There would have been curing water dripping down 23 ; from the subsequent placements?
24 BY WITNESS McGRANE:
25 A There would have been curing water from -- perhaps i ALDERSON REPORTING COMPANY, INC.
I j 896 ,
10-19 ; even from that placement in that the surface would have been O 2 kege moiee durine the curing geriod.
3 0 Is it likely that water seeped through the crack O 4 during the sueeeguene grecement of concrete esove ehee etee2
.a 5 BY WITNESS McGRANE:
3 j
. 6 A. It is possible that some very little water seeped R
8 7 through it immediately after the placement of that concrete.
K j 8 It would not have continued for long because the chemical 0
d 9 reaction between the water and the cement would have used up g 10 much of the water.
j 11 0 What is the timing of the chemical reaction between 3
g 12 water and cement, typically?
Ol'3 sv w Tusss " con ^"s=
l$ 14 A. Well, I really can't answer that because it starts 2 15 in the beginning and it's known to continue for many, many years.
j 16 It accelerates. It's very rapid. The rate of reaction is very as 6 17 , rapid in the beginning and then slows down.
N
{ 18 G As concrete cures -- I'm sorry. Did you finish?
E g I" BY WITNESS McGRANE:
n 20 A. I say it just gradually slows down. The rate of 21 chemical reaction and the rate of sixangth gain slows down with 22 Q age.
23 g Are you talking about discharge of water from cured r 24 concrete, or are you talking about an internal chemical 25 [ reaction?
l ll
. If i! ALDERSON REPORTING COMPANY. INC.
897 10-20 1 BY WITNESS McGRANE:
O 2 A. oischeree of exceee water initie11y after the 3 placement of concrete.
, O 4 e and over whee veriod of time wou1d ehet discheree e 5 occur?
1 h h 6 BY WITNESS McGRANE:
R 8 7 A. Probably it's measured in hours, but I can't give 3
j 8 you it exactly.
6 J 9 G Not months?
$ 10 BY WITNESS McGRANE:
9 j 11 A. No.
is j 12 G So then the source of water that might seep into Q 13 this crack, that might have seeped into this crack, wtuld have
!$ 14 been curing water from the subsequent pours, and that curing 15 water would have constituted perhaps hours, perhaps a few days?
g 16 BY WITNESS McGRANE:
us d 17 A. Curing water for a few days.
$ 18 G What is the size of reinforcing steel in this area O
g 19 of the cavity wall?
n 20 BY WITNESS McGRANE:
21 A Most of it is No. 11 bars. These are an inch and a 22 quarter in diameter.
23 G Inch and a quarter in diameter.
24 Is it possible, in your judgment, that there could 25 l have been rusting or corrosion of No. 11 rebar in this wall as a ALDERSON REPORTING COMPANY, INC.
89,8 ,,
10-21 1 result of the amount of water that the rebar may have seen 2 through seepage?
3 BY WITNESS McGRANE:
O < n. no.
e 5 Mr. Scheppele, would you agree with that?
Q.
b h 6 BY WITNESS SCHEPPELE:
R b 7 A. Yes, I certainly would. As Mr. McGrane has indicatt.d, s
j 8 we have evidence of many structures over the course of the 11fe a
c; 9 of the designing concrete structures for many years where they're z
h 10 exposed to water on a continuing basis, and as long as that II '
$ concrete coverage is over the reinforcing steel, even though is -
. t g 12 there might be small cracks in the concrete, that reinforcing 5 '
Os m l'
stee1 senera117 does noe deterioreee.
l$ 14 But as you've indicated, there is no real source g 15 here for corrosion. As a consequence, it should not be an area ,
c::
j 16 of concern as far as the reinforcing steel is concerned.
A I7 MR. REYNOLDS: Mr. Chairman, Applicants request that h
x IO b Applicants' Exhibits 21, 22 and 23 be received into evidence at 1 g
II g this time.
20 JUDGE MILLER: Is there any objection?
21 MR. JORDAN: No objection on the premise that we will 22 have a copy of them.
23 MR. REYNOLDS: Of course.
24 JUDGE MILLER: Yes. Copies will be providf{d. I 25 Any objection? g ALDERSON REPORTING COMPANY, INC. b
899' 10-22 1 (No response.)
() 2 JUDGE MILLER: Apparently none. Exahibits 21, 22 -
3 and 23 of the Applicant will be received into evidence and copies
() 4 will be supplied by the Applicant.
e 5 MR. REYNOLDS: We would request that we bespermitted M
N 8
o 6 to keep these so that we may duplicate them. They are custom N
g 7 jobs, if you will. Well, we do have an extra set, don't,we?
M k j 0 We will give this set to the court reporter and use d
d 9 our duplicate set as/the model for reproduction.
i h 10 * (Applicants' Exhibits Nos. 21, 22
? '
i
^
l
^
11 and 23 were received in evidence.)
k d 12 JUDGE MILLERd !Well, since the'y're exhibits, i t- i s n.' t n .,
9g 13 enough t,o just give one to the reporter. You might have to
(]) =
l$ 14 photograph them, or something, if you can't otherwise supply them.
2 15 MR. REYNOLDS: All right.
g 16 JUDGE MILLER: But you may do what's reasonable, and M
g 17 certainly make them available to the Court, Staff and to the 5 18 intervenor.
k
- 19 MR. REYNOLDS: Of course.
5 20 MR. JORDAN: Just for caution, we want them with all 21 the red marks and all the other marks, whatever document is used 22 to make the duplicates.
23 I MR. REYNOLDS: I assure you you will be satisfied 24 with what you receive.
25 JUDGE MILLER: Well, the original is marked by the ALDERSON REPORTING COMPANY,INC.
900 /'
)-23 1 witness. It will be one of the ones that's turned over to the O 2 regotter.
3 MR. REYNOLDS: Yes. That's correct.
() 4 JUDGE MILLER: Very well.
e 5 Does that conclude your --
6
$ 6 MR. REYNOLDS: No, it doesn't.
R
$ 7 JUDGE MILLER: Oh, I'm sorry. Go ahead.
s l 8 BY MR. REYNOLDS:
d d 9 g Mr. Tolson, was the existence of the shrinkage 5
$ 10 cracks reported to the NRC?
E f
3 11 BY WITNESS TOLSON:
12 A No, sir.
g
']) 13 How was the existence of the shrinkage cracks l$ 14 documented?
2 15 BY WITNESS TOLSON:
g 16 A It was documented initially on an informal memorandum W
d 17 to construction from QC and subsequently formally documented on l 5 l 5 18 a nonconformance report.
=
5 g 19 % Who found the shrinkage cracks?
n 20 BY WITNESS TOLSON:
i 21 A Quality control inspector.
'-)
, ,n/
22 g When? ,
23 i BY WITNESS TOLSON:
i !
>s 24 A In April of 1977, as I recall.
- -)
25 g At what point in the removal of the placement forms?
ALDERSON REPORTING COMPANY. INC.
9 901 i i
10-24 I JY WITNESS TOLSON:
2 A. This would have been immediately subsequent to the 3 removal of the placement forms.
O 4 0 would the oc inspector have been present when the g 5 forms were removed?
E 3 6 BY WITNESS TOLSON:
R
- b. 7 A. Yes, sir.
7.
j 8 % And he was the -- he or she was the individual that d
", 9 issued the informal report?
z o
$ 10 BY WITNESS TOLSON:
E II
$ A. That's correct.
is N I2 g Is that standard procedure?
5 Os m I3 BY w1TNESS TOtSON:
l$ 14 A. In this case I would say yes, Mr. Reynolds.
g 15 g Is this a -- are shrinkage cracks always reported as x
j 16 nonconforming situations?
- rl I7 BY WITNESS TOLSON:
h x
{-
18 A. No, sir.
I9 g g
n Why was this one reported as a nonconforming 20 situation?
2I BY WITNESS TOLSON:
22 A. I think, as referred to here this afternoon on 23l testimony, the magnitude of it, if you will, and the vertical 24 dimension particularly, were likely to cause the inspector to 25f be a little bit conservative in the manner in which he handled ALDERSON REPORTING COMPANY,INC.
1 1
92' l
10-25 I his reporting mechanisms.
() 2 JUDGE MILLER: Pardon me. Which inspector are we :
3 talking about? Is that the Applicants', Mr. Tolson?
() 4 WITNESS TOLSON: It would be the contractor's 5
y employee under my direct supervision.
9
$ 0 BY MR. REYNOLDS:
R b 7 G What contractor?
E k 0 BY WITNESS TOLSON:
d c[ 9 A Brown & Root.
2 o
10 h 0 It would be a Brown & Root QC inspector functioning
=
II
$ under your supervision?
k I
BY WITNESS TOLSON:
5
() 13 A That's correct.
l$ 14 JUDGE MILLER: Do we know who it is?
g 15 BY MR. REYNOLDS:
=
i E I6 Do you have the person's name?
G w
I7 BY WITNESS TOLSON:
h m
$ 18 .
_ A Yes, sir.
i E
' I' 8
n G What is the name?
0 BY WITNESS TOLSON:
A The inspector's name was James D. Pace, P-a-c-e.
() G Thank you.
23 i Was this matter brought to your attention?
l
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w-BY WITNESS TOLSON:
25 ' A Yes, sir.
l l ALDERSON REPORTING COMPANY, INC.
l
-26 1 G How was it brought to your attention?
2 BY WITNESS TOLSON:
3 A By a copy of the informal memorandum from the k 4l Brown & Root project QA manager at the time, e 5 G How long after the informal memorandum was written h
@ 6 did the formal NCR -- did you issue the formal NCR?
R 8 7 BY WITNESS TOLSON:
s j 8 A The formal NCR was initially issued in June of '77, d
c 9 as I recall.
i o
g 10 G Did your --
$ 11 JUDGE MILLER: Is that a document? Is that a 3
g 12 document you have there? If so, you might look at it and give us E
13 ll) the exact date, if it can be done readily. Do you have it at
$ 14 hand?
g 15 MR. REYNOLDS: Yes, I'm sure we do.
=
g 16 JUDGE MILLER: All right. Let's start identifying
+
6 17 the documents, the dates, and so on, with the precision that is 5
16 possible from the records.
h E
'9 e
n
///
20 21 2
ID 23 ID 25 ALDERSON REPORTING COMPANY, INC.
904.
10-27 1 JUDGE MILLER: What do you have in your hand, a 2 collection of documents?
3 MR. REYNOLDS: These are CASE exhibits, Mr. Chairman.
4 JUDGE MILLER: Oh, I see.
o 5 MR. REYNOLDS: We're looking now at CASE Exhibit 23 h
3 6 for identification.
R 8 7 JUDGE MILLER: CASE Exhibit 23.
E j 8 MR. REYNOLDS: Yes, for identification.
O c 9 BY MR. REYNOLDS:
s y 10 g Is that the correct document?
E 11 BY WITNESS TOLSON:
B j 12 A. That's the correct document.
3 Oi1 MR. REYNOLDS: f il to see the humor --
!$ 14 JUDGE MILLER: Now, let's not have any demonstrations, g 15 please.
x j 16 BY MR. REYNOLDS:
v5 6 17 g Amd what is the date of that document?
$ 18 BY WITNESS TOLSON:
E g 19 A. The date of -- it's actually two dates. One is the M
20 date of preparation, which would be June 1, 1977, and the second 21 date is the date of formal issue, which is June 6th, 1977.
22 g Was this situation reported to the NRC as a 23 significant deficiency under 10 CFR 50.55(e)?
24 BY WITNESS TOLSON:
25l A. No.
ALDERSON REPORTING COMPANY,INC.
I l
]905-10-28 1 G Why was it not?
2 BY WITNESS TOLSON:
3 A It was not classified as significant in our review
( ). 4 process and evaluation process of a nonconformance report.
s 5 G Were you involved in that evaluation?
@ 6 BY WITNESS TOLSON:
R
$ 7 A Yes, sir.
s j 8 G Did you inspect the crack?
d c 9 BY WITNESS TOLSON:
i o
g 10 A No, sir.
11 G Did your staff inspect the crack?
k 12 BY WITNESS TOLSON:
I 3
(]) 13 A I don't recall, Mr. Reynolds.
m g 14 G Would they normally have inspected the crack?
g 15 BY WITNESS TOLSON:
x y 16 A Not in this particular situation where a design w
d 17 engineer had previously inspected the crack himself.
E
{ 18 G Who made the determination that it wasn't a P
19 significant deficiency?
g n
20 BY WITNESS TOLSON:
2I A The initial determination was made by the Brown & Root 22 project QA manager and I concurred with that decision.
)
23 JUDGE MILLER: But none of you looked at the crack, 24 is that correct?
(])
25 l WITNESS TOLSON: I don't recall. I did not personally ALDERSON REPORTING COMPANY, INC.
l'
- 906 ;-
i
/O-29 1 look at it, Your Honor.
( 2 JUDGE MILLER: Thank you.
3 BY MR. REYNOLDS:
( 4 Q Mr. McGrane, you looked at the crack?
e 5 BY WITNESS McGRANE:
3 6 A Yes, I did.
R
$ 7 O Do you concur that it was not a significant U
$ 8 deficiency?
d C 9 BY WITNESS McGRANE:
i C
g 10 A I do. If you'll recall, Mr. Scheppele, a while ago 11 gave a description of it, and answered affirmatively, I think, k
12 to the same question, that it was not significant.
l 5
(]) y 13 G Mr. Tolson, had it been a situation that was un-i m
l$ 14 anticipated totally, would you have inspected the cracks?
{z 15 BY WITNESS TOLSON:
j 16 A I don't fully understand your question, Mr. Reynolds, w
d 17 G Are shrinkage cracks anticipated in construction
{ 18 jobs of this magnitude?
P 19 BY WITNESS TOLSON:
h n
20 A Yes, sir.
21 O Is this the first shrinkage crack that came to the 22 attention of your organization?
(]} .
23 , BY WITNESS TOLSON:
I l 24 A Yes, sir, and to my knowledge this is the only one.
(}
t l
25 ' G The only one that ever came to your attention?
l l
ALDERSON REPORTING COMPANY, INC.
I 907 '
10-30 i' BY WITNESS TOLSON:
2 A Yes, sir.
3 G Why do you think that's so?
() 4 BY WITNESS TOLSON:
e- 5 A I think it was early in the project, and again I A i e
@ 6 {I repeat that the inspectors are trained to identify items which R
$ 7 in their judgment is nut quite right. In this case I'd have to j 8 presume the inspector felt that it needed to be identified and U
c 9 he did so.
i o
a 10 4 Please describe the process which would follow the 11 issuance of an NCR, a nonconformance report.
12 JUDGE MILLER: Well, instead of "would," could you N
5 j 13
(]) m phrase it "did"? In other words, particularize now?
l$ 14 MR. REYNOLDS: Well, I wanted to first establish the
[= 15 general procedure and then follow on with the specific question j 16 of was the procedure followed in this case.
w 17 JUDGE MILLER: Well, why not do it the other way
=
{ 18 around? We are more concerned with what was,done here with these E
19 particular situations. If you wish to go beyond that, we'll let g
n 20 you, but we're getting too much on a general principal, must 21 have, and then it turns out that whoever is the "must have," he 22 doesn't seem to do those things, so I think we better get
({}
23 - particular now.
24 BY MR. REYNOLDS:
[])
25 4 What was the procedure followed in this case with ALDERSON REPORTING COMPANY, INC.
_ ,908 10-31 1 regard to disposition of the NCR?
O V 2 BY WITNESS TOLSON:
3 A The NCR was assigned to the construction manager 4 for preparation of disposition.
e 5 G Then what occurred?
5 h 6 BY WITNESS TOLSON:
R
$ 7 A A disposition was presented to Quality Assurance for s
j 8 review.
d ci 9 0 What was that disposition?
5 g 10 BY WITNESS TOLSON:
E j 11 A It was to repair in accordance with a documented is 12 civil engineering instruction, which is part of CASE Exhibit 23, l
5 i3 entieted CvI 17.
O s.
l$ 14 G Then what did Quality Assurance do?
15 BY WITNESS TOLSON:
g 16 A The QA person reviewed the disposition for appropriate us li 17 inclusion in the Quality Assurance requirements, which in this 5
{ 18 case would have been the procedure, and authorized the work E -
g I9 activity to continue, by signature on the NCR form.
n j 20 0 And at that point did work proceed to repair?
2I BY WITNESS TOLSON:
22 A Apparently not.
23 0 Is that a matter with which Quality Assurance was 24 concerned?
25! fff I ALDERSON REPORTING COMPANY,INC.
909 10-32 1 BY WITNESS TOLSON:
2 . A. Not at all.
3 g When the repair procedure was effected, did Quality 4 Assurance then verify that the work was done in accordance with o 5 the procedure?
h j 6 BY WITNSSS TOLSON:
R
& 7 A. That's correct.
M j 8 g And is that documented?
d d 9 BY WITNESS TOLSON:
$ 10 A. That is also documented.
E 11 G Where would that be documented?
is f 12 BY WITNESS TOLSON:
O l 13 A- on Revisions 2 and 3 of the subject NCR's, which are l$ 14 CASE Exhibits 26 and 27.
15 g What are the dates of those documents?
3[ I6 BY WITNESS TOLSON:
us 17 A. That Revision.2 of the NCR's was issued on x
{
18 December 14th, 1978. Revision 3 was issued on February 1st, 1979.
- 19 i g 0 Why were two revisions issued?
f 20 BY WITNESS TOLSON:
l 21 A. Part of the Rev. 2 disposition to the nonconformance 22 O report dea 1t with a coatin,o, paint app 11oation on top of the 23 i grout, which was subsequently deleted as far as the requirements l
24 which necessitated a revision of the NCR in order to protect the 25 ' records.
l ALDERSON REPORTING COMPANY, INC.
910, 10-33 1 g Was Mr. McGrane's evaluation of the disposition 2 included in the NCR Rev. 2 or Rev. 17 3 BY WITNESS TOLSON:
O A. A member of Gibbs and Hill's organization stationed at the site did participate in the disposition.
l G Mr. McGrane, who was that individual?
i R S 7 ///
E g 8 a
ci 9
$ 10 E
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g 16 us i 17
$ 18 19 R
20 21 O
! 23 24 0 25 ALDERSON REPORTING COMPANY, INC.
911 11-1 ' ' .l .
!i hop 1 G Mr. Tolson, is that individual's name reflected in l l '
2 the document?
3 BY WITNESS TOLSON:
O 4 A Yes.
5 G Would you please provide it to the Board?
g 9
@ 6 BY WITNESS TOLSON:
R S 7 A Provision 2 of the Deposition of the NCR was reviewed i
A 8 8 and approved by -- under the supervision of Mr. Bob Haim ,. whose d
d 9
, resume o &
10 h And the individual who signed the memo was Mr. Louis McAllister.
=
II
$ G Would you spell those names for the Reporter, please?
NI E
BY WITNESS TOLSON:
() o 13 A R. E. Haim, H-a-i-m.
I4 McAllister, M-c-A-1-1-i-s-t-e-r.
x 2 15 Was w G this matter handled any differently from any x
~
16 g other issuance and disposition of an NCR?
I7 BY WITNESS TOLSON:
h x
$ 18*
- A I'm sorry, Mr. Reynolds. Could you speak up a bit?
II
, 8 G Was the issuance of the NCR in this situation and the
- n 20 dispostion of that NCR handled any differently from the typical 2I disposition of NCR's by your organization?
() 22 BY WITNESS TOLSON:
23 .
A No, sir.
() G Is it unusual, then, that the NRC was not notified 25 as to the issuance of this NCR?
ALDERSON REPORTING COMPANY, INC.
912 11-2 l BY WITNESS TOLSON:
hop 2 A No, sir.
3 G Does the NRC have access to your files which contain 4 NCR's?
g/5 BY WITNESS TOLSON:
h '
@ 6 A. Yes.
R
$ 7 G Do you prepare logs wh ich reflect the contents of M
j 8 NCR's?
d ci 9 BY WITNESS TOLSON:
5 a 10 A. Yes.
II
$ G Does the NRC have access to those logs?
it II N BY WITNESS TOLSON:
3
- ) 13 A. Yes, sir.
E 14 w MR. REYNOLDS: Mr- Chairman, may I have about 30 9 15 y seconds, please?
m 5 JUDGE MILLER: Yes, as (Short pause.)
x M 18
- JUDGE MILLER: We're off the record.
P g 19 MR. JORDAN: Mr. Chairman, if I may.
n 20 JUDGE MILLER: I'm sorry.
21 Did you conclude?
(] 22 MR. REYNOLDS: No, sir. I have two more questions.
23 ' JUDGE MILLER: Were you interrupting him; is that it?
24 MR. JORDAN:Ybs, sir.
25 j JUDGE MILLER: All right.
ALDERSON REPORTING COMPANY, INC.
l
~
91'3i . 't
!L1-3 1 What's your point?
'~
Top' 2 MR. JORDAN: We have not objected. I've been sitting 3 here thinking I could object but I didn't, largely because I. don' t O 4 ehink things oue enough to measure credib111ty issues. rhere ere 5 an awful lot of foundation problems, so far, and I just wanted l
lR 6 it for the record that this seems to be a conference between b 7 witness and Counsel in the midst of testimony, which again I am M
] 8 not going to object to. Which I think it's probably aimed 0
I
. toward clarification matters.
10 I am concerned about that and I guess I expect to E
II
- % rev up, if you will, as time goes on.
2 in MR. REYNOLDS: Is that to be taken as a threat, c
I3 Oi Mr. chei men 2 l E 14 g JUDGE MILLER: No, it's not to be taken as anything.
x 2 15 w Now, to call Counsel, if you want to object, object.
x
? 16 g If you don't object, then don't come to us afterwards and tell g 17 l w us what might have been and what you're going to do in the future.
t x Bi 18
= That applies to all of you.
19 l I am aware of what you're saying. I looked over 20 several times to see if there was an objection and there was none.
21 22 Q / -
23 O
25 '
ALDERSON REPORTING COMPANY,INC.
( 914 .
11-4 I Now, being none - you' re all experienced Counsel --
ho 2 we then proceed.
3 Go ahead.
( )) 4 BY MR. REYNOLDS:
5
$ G Mr. Scheppele, would you please clarify your testimony a
@ 6 with regard to the repair procedure for the cracks and Gibbs and R
" 7 Hill's involvement in the development of those procedures?
N S 8 M BY WITNESS SCHEPPELE:
0 o 9 j A I believe I previously testified -- I think I used o'
H 10 y the phrase " detox". I think that was one of the points that
=
E 11 g might have been considered with regard to the shape of that d 12 E particular group, which I imagine, as I recall after five years, c
() 13 it could very well have been U-shaped.
l$ 14 To me the shape is somewhat academic but it was 15
$ worked out in close detail with the contractor.
=
g 16 G Was the procedure which you just described, the e
I7 only procedure with which Gibbs and Hill was involved?
h
= i IO b BY WITNESS SCHEPPELE:
E g I9 A It was the only procedure that I was aware of and n
20 I believe, you might ask Mr. McGrane that.
2I Mr. McGrane? Same question.
G 22 p) m BY WITNESS MC GRANE:
23 A I was not aware of any other procedure.
24 G And Mr. McGrane, is it your opinion that the 25 l procedure was adequate to repair the cracks?
ALDERSON REPORTING COMPANY, INC.
J
-915' g i BY WITNESS MC GRANE:
2 A. Yes, it was'.
hoh 3 g Mr. Scheppele? Same question.
4 BY WITNESS SCHEPPELE:
g 5 A. Yes.
U
$ 0 MR. REYNOLDS: No further questions.
R b 7 JUDGE MILLNR: Very well.
A j 8 Any questions by the Staff?
d 9
MR. ROTCHSCHILD: Yes. I had a question for Mr.
10 Tolson.
=
j 11 CROSS-EXAMINATION a
j 12 BY MS. ROTHSCHILD:
Ol is a This sets becx to the' rocx overbreex.
l$ 14 Mr. Tolson, I believe you stated that after the 15 rock overbreaks that QA/QC procedures were developed for the j 16 repair.
us 17 Were any QA/QC procedures developed subsequently to M 18 the rock overbreak for later blasting that occurred?
E g I9 BY MR. TOLSON:
n 20 A. There was not a procedure, from what I would interpret 21 your question to be. It would not be what we refer to as QA/QC 22 O p,,ceemme.
23 l What would occur would have been a construction 24 procedure issued for the blasting activities that is therefore 25 subject:to monitoring and surveillance.
ALDERSON REPORTING COMP /.NY, INC.
916 11-6 1 g I see. and that applied to this subsequent blasting?
O hoiJ 2 BY WITNESS TOLSON:
3 A - '
Yes, ma'am.
4 MS. ROTHSCHILD: Okay. Thank you.
5 JUDGE MILLER: Thank you.
$ 6 Mr. Jordan?
G7 6 7 BY MR. JORDAN:
E me
[ 8 g Mr. Tolson, I guess it occurred to, you said earlier d
9 that before blasting, there was no QA/QC procedure?
L 10 BY WITNESS TOLSON:
II
$ A. That is correct.
is j 12 g Was there such a procedure for the first' blasting 5
O5
.a 13 of the containment?
m l$ 14 BY WITNESS TOLSON:
2 15 A I don't know.
g 16 0 Was there such a procedure for the construction as I7 procedure of the AQ procedure?
h 18 MR. REYNOLDS: Objection, Mr. Chairman.
A 19 JUDGE MILLER: I don't think he finished the question; g
n 20 had he?
2I MR. JORDAN: I can see where he would have a problem.
22 7 11 __
23 JUDGE MILLER: All right. Rephrase it, then.
4 B,Y MR. JORDAN:
25 ' g And the panel, does anyone on the panel know, you know ALDERSON REPORTING COMPANY,INC.
91,7, ,
11-7 1 of no construction procedure or QA procedure ho 2 for the excavation for Unit I?
3 Or for the construction of Unit 2; is that correct?
4 g 5 BY } FITNESS :TOLSON:
N 0 A. Except for the basic contract, that's the answer R
b 7 I gave.
M j 8 g And in addition, there was no QA procedure for the d
ci 9 excavation of Unit 27 8
g 10 BY WITNESS ~'f0LSON:
E II k A. That's correct.
3 f I2 g For the fuel handling building, Mr. Tolson, I'll Ol i3 esx vou, wes there eny construction grocedure for the excaveeien
- I4 of the fuel handling building?
15 BY WITNESSSTOLSON:
~ 16 A. I don't recall.
4 Does anyone on the panel recall?
z
$ 18
- BY WITNESS' MASON:
I"'
19 A. I.do not, recall.
H 20 g And the QA procedure for the excavation of the fuel 21 handling building was there one of those?
22
] BY WITNESS TOLSON:
23 A. Mr. Jordan, I'm confused. I have a feeling that's 24 the same question that I just answered.
25 l 4 The question I just asked you was, was there a construction procedure --
ALDERSON REPORTING COMPANY, INC.
,918',
j11-8 1 BY WITNESS TOLSON:
l:1o V 2 A. The answer is no.
3 G And that's not only for --
4 BY WITNESS TOLSON:
5 y A. The answer is no.
9 6 No, there was no QA
@ G And that's the second answer?
R E 7 procedure for the excavation of the fuel handling building?
s j 8 BY WITNESS TOLSON:
d A. That's correct.
$ 10 0 Just so that's clear.
E 11 Now, the question that the NRC Staff Counsel just it g 12 asked you was whether there was any construction -- she asked if
/~'i O 13 V 5a there was a QA procedure for later blasting and I believe you l$ 14 answered no but there was a construction procedure and that would 15 have been inonitoring andisurveilling.
16 What was the later blasting you were referring to?
3[
w 17 To which there was such a construction procedure?
h 18 BY WITNESS TOLSON:
E g I9 A. I can't recall specific details. The job or anything n
20 that occurred subsequent].y - to approximately November or December 21 1975.
22 O mm. ,omo,s,, . . ,,. ch,1,m,m, 1 w,,,,,1,we cou1, 23 take a break for a few minutes?
24 We've been going for about two hours.
25 , ,coes mzsssa, se,,,see, ,,1,,w1,s sem,1mee,,,p,1,,,
l .
ALDERSON REPORTING COMPANY. INC.
l
)
917' l 19x l 11-9 1 We will have a ten-minute recess. Now, let's resume ho" ') 2 promptly in ten minutes. We've been sort of overrunning a 3 little.
O j4 < Shore recess.3 5 JUDGE MILLER: On the record.
g 3 6 Proceed.
R C
" 7 BY MR. JORDAN:
A 8 8 a G Ih11 direct a' question to you, Mr. Mason.
d c 9 j I'd like to get clear as to what the sequence of o
F 10 y events was with respect to this matter.
=
,$ I take it the first -- the procedure was originally 6 12 developed -
E based on Your studies and the excavation was implemented for the 3
O -@ 13 Unit 1 area; is that right?
E 14 y BY WITNESS MASON:
m 2 15 g A No, sir, that'is not; correct.
I0 Our firm, R.A. Mason, or any of Sis ~' 'i IA ~
d 17 a employees, did not develop a procedure for blasting.
x M 18
= The blasting sequence and blasting procedure was s
19 8 primarily developed by the contractor Brown and Root with input 20 from this round-table discussion, from the then powder company 21 and the powder companies changed --
22 g
(]) That was a specific blasting procedure in the sense 23 l that an individual blasts?
i 24 BY WITNESS MASON:
25 A The individual blast?
i ALDERSON REPORTING COMPANY. INC.
1 I
..... 1 920 l 11- 0 That was for the entire reactor excavation, albeit j
2 there were two.
nop 3 g As I understand that:your firm had:develo~ ped the
() 4 recommendations to use this sequence and method; is that corre-t?
g 5 BY WITNESS MASON:
F.3 3 6 A Only to the extent of contributions to a round-table R
5 7 discussion, attended by the owners' representative, s
k 0 construction manager in that case, the contractor's 0 ;
o 9 administrative chief and superintendent of excavation, myself or o
10 h my representative, Mr. Croft, and from that evolved specific
=
k instructions, I'm sure, that went from Brown and Root's M
d 12 3 administration to the field superintendent, to the people on the
=
("h s> dg 13 machines that were doing the work.
m 5 14 g Okay.
E 15 That's all right for my purposes.
y 16 And that all was for the first excavation for Unit 17 A
h I7 l BY WITNESS MASON:
=
{ 18 A That is true.
A g I9 Now, in the first blasting and excavation for' Unit 1, n
G 20 as I understand it, took place in the,well, I'll call it --
21 well, the circle flat as originally designed, which was supposed
() to create the containment wall.
BY WITNESS MASON:
24 A In my testimony I termed it the.. parameter.line. .
25 1 drilling and blasting.
i
}
i ALDERSON REPORTING COMPANY, INC.
921.
11-11 1 Then'you said there was blasting in the middle.
(3 hop ' 2
- And.I got the impression ~thatlthat.. blasting was
! . . G 3 -senti ally complete t'rtake o th'elrobknout.
.c.
4 ,
5 BY WITNESS MASON:
9 h 0 A Well, that's true but that was done in sequence.
R b 4 Yes.
M k 8 The first area I want to get to is, according to d
q 9 your testimony, then, there seems to be a plateau at one level z
o 10 and then a smaller excavation in the middle of'that plateau that h
=
II
$ goes down to a lower level and that is where the reactor cavity a
f I2 will -- or where the reactor will eventually go; is that correct?
( 13 BY WITNESS MASON:
E 14 w A Yes. The two' exhibits', 21 an,d'22, illustrate that E
2 15 g better than my verbosity did.
! g 16 M
d 17 '
w G And the reactor cavitytexcavation'.was' '~
=
M *18
= done after the initial excavation through the first level?
19
{ BY WITNESS MASON:
20 A That is correct. The first level -- sorry, I do not 21 remember now the elevations but that first level was a uniform 22 (s[) grade from which the cavity excavation was shown by the blue 23 { concrete fill in place.
24 g
(]) And the first excavation went down to 40 feet?
25 l l
ALDERSON REPORTING COMPANY. INC.
922-
>l2 I BY WITNESS MASON:
h 2 A The total depth, Mr. Jordan, 40 feet would be 3 approximately somewhere from the plant grade to the bottom of 4 the cavity.
5 g Oh, I see.
g 9
h 0 So the first excavation was somewhat less than that?
- E 7
BY WITNESS MASON:
M i 8 N A Was less than that, yes, d
d 9
}- G And there was a second excavation. Did the second o
6 10 y excavation use the same process as in Unit 1?
=
II BY WITNESS MASON:
6 12 E A No. I don't think there was any blasting in the ll cdg 13 second unit -- I'm sorry. In the second level, as in the first E 14 y
level, the reason being, with all of the pain and suffering that 9 15 g had gone on with the overbreak from the first blasting process.
I 16
$ Now, my best memory of that one time was that there p 17 3 was no blasting at that lower level and that those walls were E 18
= created by a different technique, permitted in the specification
- 19
% called drilling and broaching.
20 The holes are now drilled tangent to one another to 21 create the vertical walls. A series of vertical holes are g 22 drilled that close and then an expansion tool is lowered and 23 ; creates a fracture.
24 g
25 l l
ALDERSON REPORTING COMPANY,INC.
I 923 11-13 I That is my best memory .
ho 2 g Do you know the date of the Unit 1 excavation? By 3
tha t I mean , the excavation's from1the original break.
D 4 BY WITNESS MASON:
5 A g No. I do not.
4 3 6 g could you tell me what the date of -- how much later E
6 7 Unit 2 excavation was made?
A S 8 M BY WITNESS MASON:
d o 9 j A I couldn't get within a year. I'm sorry. _ Hope you o
H 10
$ have a better ^ witness J on memory 1 than2I"do . " -
- - ~;
1-
=
E 11 g g How long after the Unit 1 excavation was done, was d 12 3 the Unit 2 excavation?
o Od@
s-13 BY WITNESS MASON:
E 14 y A Mr. Jordan, Case Exhibit 22, which is a copy of a e
9 15 y letter that was introduced, the Regulatory Commission stated that 16
$ Unit 2 blasting operations occurred in January 25, '75. As I l
@ 17 i
g recall, the Unit 1 blasting operation occurred in the first few M 18
= days of January, 1975.
g I9 g So, a few days later; correct?
n 20 BY WITNESS TOLSON:
1 21 1
A I think we need to talk from a common date base.
22 i
(u's) I. . . . That excavation goes on for a tremendous period l
\
l 23 ! of time or a significant period of time subsequent to the blasting l
c' 24 l
(sj ,
operations.
l 25 g I just wanted to get it clarified.
l ALDERSON REPORTING COMPANY,INC.
924 i
11-14 I BY WITNESS TOLSON: l hop 2 A. My date refers to blasting asfopposed to excavation. )
3 I do not have an end date in mind when the finish O < .
excavation. .
5 g So the days of blasting, if you can answer the y
9 3 6 question, on January 23, 1975, for Unit 1, when after that was R
S 7 the.upliftuoverbreak problem discovered?
s
- 8 M BY WITNESS TOLSON:
d 9
G Do you want me to continue with the thing?
o 10 JUDGE MILLER: Well, who is testifying?
h
=
. WITNESSiTOLSON: Again, the Unit 1 blast occurred d 12 g around January 5th, 1975, as stated in the letter I just referred to, CASE Exhibit 22.
l$ 14 The rock uplift became apparent January 23rd, 1975 g
15 as we were progressing on the excavation.
x j 16 The Unit 2 blast occurredron.' January . 22nd,T.1975.
us I7 MR'. JORDAN: Well, Mr. Chairman, I have distributed
{C 18 what I believe to be a document which.Mr. Tolson referred to, 19
$ which we would mark as CASE --
5 l 20 l JUDGE MILLER: CASE, I'm showing 4. Now, I presume 2I that we start numbering this 4 if our revised criteria are correct .
22 Q
MR. JORDAN: Four. All right.
23 BY MR. JORDAN:
24 g Mr. Tolson, would you look at this document and 25 l l
ALDERSON REPORTING COMPANY, INC.
l 925 11-15 1f describe it for us? l
- ho 2 BY WITNESS TOLSON
3 A. TXX-667 dated February 4, 1975 to the Nuclear 4 Regulatory Commission.
g 5 g Are you familiar with the subject discussed in here?
j 6 BY WITNESS TOLSON:
i:t
$ 7 A. Yes, sir.
A j 8 g Have you seen this letter before?
d ci 9 A. Yes, sir.
z o '
10 g MR. JORDAN: Your Honor, we move this CASE Exhibit
=
II
$ 4 be received in' evidence .
is f I2 JUDGE MILLER: Is there any objection?
O! m is MR. REYNOtDS: No os 3ecu .
E 14 g MS.ROTHSCHILD: No objection.
=
h JUDGE MILLER: There being no objection, CASE Exhibit
=
16
, 4 will be admitted into evidence.
II h
=
(The document referred to was marked M 18 CASE Exhibit No. 4 for identification k 19
{ and was received in evidence.)
20 JUDGE MILLER: By the way, have sufficient copies 2I been furnished to the Reporter in accordance with the rules?
22 O ey ,,. ,0,0,,,
23l g Mr. Mason, I believe you testified earlier that the 24 same problem arose at both of the two units as a result of a 25 i blasting excavation; is that correct?
I I ALDERSON REPORTING COMPANY,INC.
11-16 926-hop I BY WITNESS MASON:
O 2 A That is. correct. -
3 4 So, I believe you said that after blasting for Unit
() 4 1, the problem of the overbreak was discovered and the blasting 5
waF modified to some extent for the Unit 2 excavation; is that b 0 correct?
R E 7 BY WITNESS MASON:
s S 8 n A That is correct also, d
9 k I believe I stated earlier and need to state now, E
F 10
@ to complete my answer, the overbreak condition from the blast from
=
5' 3 Unit 1 was determined only after s"hsequent excavation.
d 12 3 We were suspicious,i. sver, that some similar
("1 $ 13
\/ j condition that was actually found might have increased, and as E 14 y a result, the contractor changed the pattern suppliers.
k 15 g The whole station was reduced approximately in half.
j 16 Powder charges were reduced and other remedial measures w
I7 that I do not now recall of that type.
h x
{ 18 And in containment 2, we detonated during the same E
g I9 4
week that we had been able to see the side walls of reactor n
20 one, which Mr. Tolson mentioned but the impact of that I need to 21 bring out.
22 Replyit.7 t.o one hour and then.the calendar,
(])
23 said you have blasted the second one. Of course, we'd only been 24
([) blind two days when that event occurred.
25 l
s ALDERSON REPORTING COMPANY, INC.
! 927.
l g.,1 I Yes, I need to repeat the time when we were able 10p t 2 to confirm the conditions on Reactor No. I went off.
3 4
e 5 It was only 24 to 48_ hours before it went off in b *
@ 6 Reactor 2 and that was subsequently determined to have been only R
$ 7 a half of a correction because it was-destroyed also.
A j8 G So, it was activated within-a day after the Unit 1 d e o 9 blast so that you could see the prob 1edis,T.
z q ~
h 10 -
II
$ BY WITNESS MASON:
a fa II A. No. It's the exact opposite.
f13 7.m trying to emphasize that the blast that took
$ 14 w place at Unit 2 was underway when we had the full story of what ,
U g 15 the walls looked like on Reactor 1. ,.
16 G Yes, I think I understood that.
hx
'*ou said that you really didn't know the full story M 18
- of Reactor 1 until only a day before the Reactor 2 blast and I 19 j infer from what you say that it was too late to fix up Unit-2 any more than you had already done; is that - -
21 BY WITNESS MASON:
s A. We had,already reduced .'
23 )
i for discharges, changed arms supplies,' powder suppliers, those
' ~
p 24 '
d precautions turned out to be inadequate to keep. rock damage 25 '! from occurring. ' -
ALDERSON REPORTING COMPANY,INC. j I
928
, ._a 11-18 1 g And you asnwered that substantially the same as Unit
- hch 2 2 would be --
3 BY WITNESS MASON:
4 A That is true.
5 y g And when did you, if you know -- how soon after the e
h 0 Unit 2 blasting was Unit 2 up for excavation?
BY WITNESS MASON:
s S 8 M A How long --
d d 9 g g Just to the same point you just described in knowing c
h
=
the rock --
h BY WITNESS MASON:
d 12 E A I do not know the time period.
B i - 13
/@ g Does anyone else know?
E 14 g BY WITNESS MASON:
2 15 g A I can assure you it was a lot longer than a day.
j 16 m
I7 0 No, in fact, it was your testimony that it was a lot h
x 18 longer than a day for the excavation of Unit 1 to reach the point 19 8 where you really knew how extensive the problem --
n 0
BY WITNESS MASON:
21 A Very definitely we knew. Yes, sir.
22
(]) g Can you give us a range of a week or more?
BY WITNESS MASON:
() A Several weeks. Possibly longer.
25 I Q Yet, in that several week period or possibly longer i
ALDERSON REPORTING COMPANY,INC.
9'29
- 11-19 1 brought you over to the threshhold of the Unit 2 tlast?
l 40 2 BY WITNESS MASON:
3 A. Before we understood the whole story -- this was my 4 previous testimony, now, and I'll repeat it.
- 5 Before we got the full story of the wall appearance b
$ 6 on Reactor One excavation, the blast for Reactor Two went off 7 within -- my memory says the next day but I'mm remembering too a
j 8 quickly here.
O c; 9 Probably two days, three days.
10 g I think you have CASE Exhibit 4 and I think if it II
$ become necessary perhaps Mr. Tolson can help you; it refers to is g 12 s-ructural excavation for Unit 1 having reached 793 on January Ol is 23, 1975.
lE 14 That number refers to blasting of Unit No. 1, the bI z
actual information?
f16 BY WITNESS MASON:
A. I think the letter states the excavation had reached a
M 18
- 793. I think they are talking about it in a general sense but 19 j l that's the final point. The letter is not specific as to what 20 point we are on on the 23rd of January.
21 0 Okay.
22 Q That letter states that on January 23rd, 1975,
- 23 structural excavation was approximately at elevation 793, for 24 Unit No. 1 containment began.
25 ! Does that mean that the blast occurred?
ALDERSON REPORTING COMPANY. INC.
1 930 L1-20 I BY WITNESS MASON:
O 2 A As I stat-d earlier, memory tells ne that the blast 3
for the Unit 1 occurred on January 5th,1975.
4 g That means then, -- what began then?
s 5 g BY WITNESS TOLSON:
. a 3 6 2 A The description Mr. Mason provided went into action E
on the front end loaders and conventional scrapers N
j 8 d
c; 9 g The actual digging out of materials?
z o
B 10 BY WITNESS TOL'S'ON :
II
'$ A That's correct.
s j 12 g Let me ask you this, Mr. Tolson.
( 13 Were you involved in the reporting of this matter to I4 the NRC, the rock overbreak report shown on the face of the report?
BY WITNESS.TOLSON:
6 17 w A I reviewed the letter, yes, sir.
=
5 18
= 0 You did.
j 19 In Mr. Mason's testimony that, in fact, the damage 20 at Unit 2 was approximately equal to the damage an Unit 1, why 21 did you report -- if you know, why did the company report to the
() NRC that after the blasted material was removed from Unit 2, 23 !
in that paragraph, visual inspections revealed little if any 24 O damage to the perimeter walls?
25 !
1 1
ALDERSON REPORTING COMPANY, INC,
?
-9 31(,
11-21 I>
ho BY WITNESS TOLSON:
2 A. Maybe we need to keep in mind that this is a 3 report to the Commission after the facts as we understand 4 them at that time.
5 I have no feel for the magnitude of the or the g
a 3 6 depth of the excavation on Unit 2 that had occurred on Fe bruary R
"- 7 4th.
A
- f. 8 Intuitively I would believe that it would be very U
". 9 little because we're only talking about, at most, a couple of 10 weeks between January 25th and February 4th when we sent the h
=
II is letter to the Commission.
12 (L Well, I'd like to follow that to get the full I
5 O sm is victure of thie.
l$ 14 We have Unit 1 blasted and excavated.during January.
15 Unit 2 blasted in late January and the excavation is y 16 beginning --
as I7 MR. REYNOLDS: Mr. Chairman, how many times are we
{ 18 going to have to go to t;hese facts?
is 9 I9 JUDGE MILLER: This is about the third or fourth M
20 time, I think. It's getting repetitious, Counsel.
2I MR. JORDAN: I just want it to be clear.
22 O ,,,,,szsses, you ,, ,,,the exhib1,. x,,,,, ,,,
23 l the witnesses, now, if you want to wrap up questions, you really O shouta move etoas-25 ! .
ALDERSON REPORTING COMPANY,INC.
932'.-
I BY MR. JORDAN:
.11
\ 2 g My question is, how would the fuel handling, building hop 3 let's say -- _.
O 4 eY WITNESS MASON:
5 A I'm sorry . Are you addressing me?
g 9
3 6 I'm addressing anyone..who knows.
G R
S 7 JUDGE MILLER: Does anyone know?
A
[ 8 BY MR. JORDAN:
d 9
]". O Does anyone know about the fuel handling building?
o 10 h JUDGE MILLER: Well, do all of you say you don't know?
=
hII Let's have an answer.
WITNESS MASON: I don't have any details.
o f') gd ss 13 WITNESS TOLSON: I don't have the details on it.
E 14 g JUDGE MILLER: Apparently the witnesses repond that x
g 15 they don't know.
x 16 MR. REYNOLDS: Well, could we clarify the question, d 17 a
. Mr. Chairman?
x
$ 18
= Is Counsel asking the question, how was the shattered C
19 j rock removed or is he asking how --
20 JUDGE MILLER: That's what he asked.
21 MR. REYNOLDS: Excavation is what he said. I don't 22 O know what that means.
23 JUDGE MILLER: He asked how was the excavation of the 24
(} fuel building handled and they said they don't know.
25 MR. JORDAN: That's right.
ALDERSON REPORTING COMPANY, INC.
933' !
11-23 ho JUDGE MILLER: All right.
2 Next question.
1 I
3 BY MR. JORDAN: ,
4 g I ask you where is the fuel handling building with 3
j respect to the two excavations that have been discussed so far.
e,i j 6 (No response.)
R
" 7 O Do any of you know?
e.
j 8 BY WITNESS TOLSON:
d 9
A. The fuel building is located approximately the center
'o 10 h of the two excavations, off to one side.
$ 11 g Mr. Mason, are you familiar with the excavation of a
y 12 where the fuel buildings are, are you aware of the removal of 5
Oi m
'3 damesed rock from the fue1 bui1ains foundeeson ere 2 5 I4 BY WITNESS MASON:
15 A. I cannot use your words, because to my knowledge 16 they're not true.
s[
as I7 Rock has been disturbed on the wall h
c:
that was intended
$ 18 to remain intact by the fuel building and it was my testimony this E
I9 morning, as I recall, perhaps immediately after lunch, when I 8
n 20 mentioned that I could walk through the crack that had been 21 created by impact rock being displaced horizontally, a gap of
(] 22 perhaps ten inches.
23 i So that, yes, I'm very well aware of that.
O g When did this impact displacement occur?
25 I ALDERSON REPORTING COMPANY,INC.
934 ,
l[f-24 i BY WITNESS MASON:
hM 2 A. It obviously had to have occurred during a blasting 3 operation in connection with the excavation for the fuel t
f O- 4 bu11 ding, which I.ve a1 ready reg 11ed in the negative that 1 do 5
g not have the details of it.
n 3 6 0 You don't know when this blasting occurred that R
" 7 caused this impact, do you?
j 8 BY WITNESS MASON:
O d 9
. A. I have in front of me something that would do nothing 5
10 more than frighten me for two years. I'll be happy to take a II
$ minute to look through this and answer as to the availability is fO I2 of my information here at the table, for a minute.
o 13 V g MR. JORDAN: Maybe we can cut this short a little l$ 14 bit. I will distribute this document --
15 I would like to mark this for identification as E
us Ib ' CASE Exhibit No. 5.
I7 JUDGE MILLER: It is exhibit 5.
5 18 BY MR. JORDAN:
19 g Is that what you were looking for, Mr. Mason?
, j }.e l/ 20 BY WITNESS MASON:
2I A. Right.
(D 22 JUDGE MILLER: Let me suggest this is getting very
%J 23 : tedious. If Counsel has the information from whatever source, i
/~'s 24 ! why don't you show it to the witnesses, if you're going to wind V l 25 up doing it, in the beginning and get on with the
! ALDERSON REPORTING COMPANY. INC.
935 11-25 j interrogation and the witnesses, if you have any memory at all or
- hc" ) 2 any documents that show the information, tell him about it.
3 We're wasting an awful lot of time just; dancing
() 4 around.
e 5 Proceed.
b
] 6 s. .
WITNESS MASON: I think your question to me was to R
$ 7 read something in this --
N j 8 BY MR. JORDAN:
0 o; 9 0 I don't want you to read it.
z o
10 k I want to ask you whether you've seen it?
E II 5 BY WITNESS MASON:
3 fo I2 A Yes, I have.
() I g JYou recognize it.7 E 14 w BY WITNESS MASON:
g 15 A Yes, I recognize it.
m j 6 e
g What is.it?
i d 17 a I don't want you to read it, I just want you to --
5 e 18
= BY WITNESS MASON:
e 19 g A It is entitled Memorandum: Addressed to Raymond C.
20 l Mason.
Subject:
Blast Over: break in Containments and Fuel 21 Building Excavations.
() It is signed by Herb Crowder, our staff geologist 23 assigned to the field. It's two pages in length and it has had 24 attachments --
(])
l 25 I g No attachments.
l l
l ALDERSON REPORTING COMPANY. INC.
93( .
kk-26 1 BY WITNESS MASON:
'ho' 2 A Beg pardon?
3 g 'There are no attachments to the exhibits, Mr. Mason.
( 4 JUDGE MILLER: Well, isn't there a third page after e 5 the letter which says References?
d
$ 6 That's on the copy you furnished the Board.
R
& 7 WITNESS MASON: The exhibit has a third -- excuse me, s
j 8 sir. May I comment?
d o 9 JUDGE MILLER: You may identify the document, yes, 5
10 g that's what you were asked.
=
$ II WITNESS MASON: A two-page memorandum. The third k
g 12 page 6f whiUh.is entitled References and it is a series of a
() j 13 References with Record Photographs No. so and so, Miscellaneous m
I4 Photographs of Containment No. 1. Record photographs of g 15 containment No. 2.
e Ib Proof Photographs of fracture removal et cetera.
I7 Now, on the original there were an additional h
x M 18 geology sheets and photographs.
C 19 MR. JORDAN: I have a copy of your original here.
g n
20 WITNESS MASON: Yes. I recognize the first three 21 sheets of your exhibit.
22 JUDGE MILLER: Well, this memorandum is addressed
[])
23 , to -- to whom is the memorandum addressed?
24 WITNESS MASON: It is addressed to Raymond C. Mason
[ 25 and I am Raymond C. Mason. ALDERSON REPORTING COMPANY. INC.
'11-27 937f hop 1 JUDGE MILLER: And you received this, diCn't you?
2 WITNESS MASON: I received this. 3 JUDGE MILLER: You don't have any problem, then, I 4 take it with identifying it-e 5 WITNESS MASON: That's correct.
] 6 JUDGE MILLER: Okay. Proceed.
E 6 7 BY MR. JORDAN: 3 - l 8 g Is this a report to you from one of your d d
~
9 geologists? o g 0 BY WITNESS MASON: 3
=
I 4 A That is correct. W I2 MR. JORDAN: N_ I would like to enter this as CASE rT 3 13 if s g Exhibit No. 5. lm 14 JUDGE MILLER: Any objection? g 15 (No response.) z j 16 JUDGE MILLER: CASE Exhibit 5 -- w I7 MR. REYNOLDS: Mr. Chairman, this exhibit does not h. M 18
- include the references on the reference page ~.andiwith::that 19 '
8 stipulation, we have no objection. t JUDGE MILLER: The exhibit does not include the 21 references? 1 (') MR. REYNOLDS: Evidently the memorandum contained 23 attachments to it. There was more to the memorandum that is 24 l presently -- 1 25 i JUDGE MILLER: Well, I don't know but the ALDERSON REPORTING COMPANY, INC.
938;; i 1 mem randum is addressed to your witness. Now, do you want to 11-28 2 make it complete? Do it. hop 3 We're going to admit the memorandum and what we have () 4 here is two pages of the memorandum signed by Mr. Crowder and e 5 Mr. Mason has identified it. h j 6 We've got a third page called References, Paragraphs R
& 7 Numbered 1 through 7. Now, that's what we have here. If there s
j 8 be more, let's have it produced and put in but we'll take what d q 9 we have here and I assume --
$ 10 MR. REYNOLDS: We would object unless the E
II
$ Intervenor intends to introduce the balance of the memorandum a
f I2 or we reserve the opportunity to do it ourselves. () of13 JUDGE MILLER: It will be admitted at this time l$ 14 because it is coming up in cross-examination end it is at the g 15 present time limited to the use of it in cross-examination.
=
y 16 Now, if someone wishes to use it affirmatively, A I7 you'll just have to do it in accordance with the rules of hx
$ 18 .
- practice.
H j 19 It's admitted for the limited purpose it has been 20 proffered and accepted by the Board. 21 (The document referred to was marked () CASE Exhibit No. 5 for identification 23 and was received in evidence.)
% 24 sj MR. JORDAN: Your Honor, I would say not only do we 25 have no objections to having the entire exhibit in.
ALDERSON REPORTING COMPANY. INC.
939S[ 11-29 1 We would prefer to have it. We got that in a pack of ho 2 exhibits. We would be happy to have that completed and would 3 stipulate the rest of it in with Counsel. () 4 JUDGE MILLER: Get together on it and if you want 5 to put in some more material, fine.
~
Let's just get on w th it. g
" i g 6 Mr. Mason,'you've already told me you are a se to
\
e7 y7 N identify this document. There's no question in your mind that j 8 you received it; is that right? O
~ 9 z WITNESS MASON: That is correct.
o 10 h JUDGE MILLER: And is it accurate, insofar as it goes
=
II
$ into the matters that occurred at the time to which it refers?
?
g 12 WITNESS MASON: That portion of it is accurate. It E () 13 is much more graphic and illustrative on the pages that are 5 I4 missing. jz 15 JUDGE MILLER: Well, where are the missing pages? d I6 WITNESS MASON: I don't know where they are. W I7 I have a copy from a previous -- h
=
M 18 JUDGE MILLER:
, All right.
E g I9 Let's have that marked as -- we will mark it e. 20 A pplicants, if you wish or we will mark it Board exhibit. 2I liR. REYNOLDS: l Applicants is fine. () 2 JUDGE MILLER: Applicants exhibit next in order. 23 l We will mark it for identification so we can refer () to it in the record.
/ 25 i! . 24. Okay. Would someone be good enough to take it i ALDERSON REPORTING COMPANY, INC.
, 940 11-30 1 to the Reporter so we could have it appropriately marked?
r hd 2 Thank you. 3 (The document referred to was marked 4 Applicant Exhilit No. 24 for 5 g identification.) e'
@ 6 . ._
JUDGE MILLER: I will say to Counsel, it may well be R
$ 7 you'll be able to look at thcse and agree because the witness j 8 certainly doesn't seem to have any trouble identifying it and d
2 9 there's no sense in doing things piecemeal but if we have a l= 10 continuing problem, then we will. rule on it. II k MR. JORDAN: As I say, we may have some rough spots
's fo I2 like this that need explaining. We got that in a package with O a a
I3 one steg1e throueh te. It 1ooked 1ike this, suse off this 14 package. We tried to separate out whatever possible. 15
$ BY MR. JORDAN:
x d I6 us Q. Now, Mr. Mason, did you provide this report to 17 h x the Applicants? CASE Exhibit 5. l0 BY WITNESS MASON: E g A. In order to answer your question as to what I did with 20 it, I need to review the records I have here in front of me 21 . one m2.nute. 2 O ,,,,, ,,,,,,, ,, ,,,,,. 23 ' (Short pause.) J WITNESS MASON: Mr. Jordan, I think I can answer your 25 question now. ALDERSON REPORTING COMPANY,INC.
941b 11-31 1 The memorandum is dated the 26th of November, which hob 2 you have just passed out. 3 On the 2nd of December -- I'm sorry. The year was 4 1975 -- on the 2nd of December, by letter identified as MJT-185, 5 g was transmitted this memorandum with attachments to TUSI. a
@ 6 a
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$ 10 a
I 11 (_ 12 O! , is h 14 m 2 15 j 16 us 6 17 Ci 18 l 19 8 n 20 21 i O 22 23 24 O 25 l ALDERSON REPORTING COMPANY, INC.
942': 12-1 Just to be clear, QC is -- 1 G 2 BY WITNESS SCHEPPELE: 3 A Texas Utilities Services, Inc., by date of O 4 2 December 19?s. e 5 G By letter of that date you transmitted CASE h 3 6 Exhibit 5, Applicants' Exhibit 24? R
$ 7 BY WITNESS SCHEPPELE:
N j 8 A. That is correct. d ci 9 MR. REYNOLDS: We will distribute now a document i h 10 which we have marked as CASE Exhibit 6. And we've had that 11 distributed to Mr. Tolson. is (5 12 BY MR. JORDAN: Q 13 G Sir, I would Tsk you if you recognize the copy
@ 14 before you of CASE exhibit.
15 BY WITNESS TOLSON: j 16 A. Yes, I do. us 17 { a: G It purports to be a letter from Mr. Caudel,, engineer { 18 in charge, to Mr. Madsen of the Nuclear Regulatory Commission. E 19 BY WITNESS TOLSON: g n 20 A. That's correct. 2I MR. JOP7AN: I mo're it be acInitted as CASE Exhibit 6. 22 JUDGE MILLER: Any objection? 23 MR. REYNOLDS: No objection. 24 JUDGE MILLER: No objection. All right. It will be 25 l admitted. I ALDERSON REPORTING COMPANY, INC.
i 943.: 52-2 1 (CASE Exhibit No. 6 was 2 admitted in evidense.) 3 BY MR. JORDAN: 4 O Mr. Tolson, is this-the, I believe a final report e 5 provided to the Nuclear Regulatory Commission by TUGCO with 8 3 6 respect to the rock over-break? N d, 7 BY WITNESS TOLSON: A l 8 A That's correct. d A 9 G Were there ever any supplements to this report, to E
$ 10 your knowledge?
E j 11 BY WITNESS TOLSON: is g 12 A Not to my knowledge. Ol12 o were enere ear revores to ene nac oa the son $eot
! 14 between the report of February 4th, which is CASE Exhibit 4, 15 and the report of December 12, 1975, which is CASE Exhibit 6?
;f 16 BY WITNESS TOLSON:
as N 17 A Not to my knowledge.
$ 18 O Mr. Tolson, I would ask you to turn to CASE Exhibit 5.
A 19 {n I believe Mr. Mason has it. 20 BY WITNESS TOLSON: 21 A I have the document. ! 22 O Sir, as I read CASE Exhibit 5 and CASE Exhibit 6, 23 the language describing the over-break situation is remarkably 24 similar but for the fact that toward the end of CASE Exhibit 5, 25 l which is Mr. Mason's report which is appended to it, there is a ALDERSON REPORTING COMPANY, INC.
944 12-3 1 paragraph which states that major cracks also occurred in the O 2)fuelbuildingfoundationareawhentheservicewaterintakepipe 1 3 funnel was blasted. This rock is being removed and will be O 4 , comg1eted es seeeed ebove. Ie then refers to ghetoerephs. e 5 That is not included on your report of December 12th, b
$ 6 1975. Mr. Tolson, was there ever reports to the Nuclear R
$ 7 Regulatory Commission under Section 50.55(e) of their regulations 3
j 8 or under any other Commission regulations, reporting that major d ci 9 fracturing in the fuel building formation? Y
$ 10 BY WITNESS TOLSON:
is 11 I've already referred to the letters, the two letters, h A. a y 12 the interim report and the final report thatrwere submitted to E Q 13 the Commission under 50.55(e). l$ 14 g And those, as I understand it, were reports on the 15 over-break in Containment 1 and 2 excavations, correct? ig 16 BY WITNESS TOLSON: us 6 17 A. It's not correct. Those are your words. The intent {g 18 of the reports was to report over-break in the Category 1 19 structure. M 20 g And the fuel handling building is a Category 1 2I structure, is it not? 22 BY WITNESS TOLSON: 23 j A. That is correct. I 24 G I see no reference to the fuel handling building in 25 your December 12th of February 4th letter to the Nuclear i I ALDERSON REPORTING COMPANY, INC.
945;, 12-4 1! Regulatory Commission, yet I see a separate paragraph in , O 2 Mr. Mason's report that was sent to TUGCO. Your testimony is 3 that there is no report from TUGCO to the Nuclear Regulator" b d 4 Commission that specifically informs that agency of the major e 5 fracturing that occurred in the fuel building -- h
@ 6 MR. REYNOLDS: Objection, Mr. Chairman. The witness R
$ 7 already answered that question.
A j 8 JUDGE MILLER: What did he answer? O 9 MR. REYNOLDS: He answered no. c} 2 o g 10 JUDGE MILLER: All right. It's been answered "no." II
$ If you'll accept that answer I believe we --
3 Y I2 MR. JORDAN: It wasn't clear to me that he answered c O im i3 no.- l$ 14 BY MR. JORDAN: g 15 Mr. Mason, I would like to get to this question of, G
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g 16 in essence, why the fracturing occurred despite your careful as I7 efforts. You testified that you had, I believe -- paraphrasing h a b I0 to say the least, but you had familiarity with limestone P 19 8 geological structures. n 20 BY WITNESS MASON: I A. That's correct. O 22 , ,1,yo, ,,x, 1,,, ,ccom,,yeo,x,,,1eag, of 23 geological structures in limestone in developing -- you and those i
] 24 who worked on it -- in developing the proposal for the perimeter 25 blasting for these containment excavations?
l ALDERSON REPORTING COMPANY, INC.
t 9.46,. 4 12-5 1 BY WITNESS MASON: 2 A We initially thought we had. 3 g You attempted to? r 4 BY WITNESS MASON: e 5 A We attempted to. U j 6 g So apparently this limestone turned out to be R { 7 different, or otherwise, or perhaps softer. I believe you used a l 8 the term softer, is that correct? d d 9 BY WITNESS MASON: 4 . E g 10 A I think I used the generic term weak rock as opposed E
~
j 11 to hard rock. k j 12 g Weak rock. My question, did you examine the question 5 (]) 13 of -- let me ask it this way.
!$ 14 In evaluating this limestone formation did you 15 examine whether'there existed an aquifer underneath the limestone j 16 in question?
W 6 17 BY WITNESS MASON:
} 18 A Our firm specifically was not charged with that item.
E 19 g We did, however, for our own edification and for that of some n 20 structural applications, installed observation wells which we 21 call piezometers. Other than that, we were not involved in the (} 22 determination of the aquifer at the Comanche Peak site. It was 23 performed by a different firm. j I 24 g []} I take it from your testimony that you were aware 25 that there existed an aquifer below the Comanche Peak site? ALDERSON REPORTING COMPANY,INC.
947,. 12-6 1 BY WITNESS MASON: ( 2 A There's an aquifer anywhere in the world if -- 3 JUDGE MILLER: Well, the answer is yes, you knew it I () 4 from your installed piezometers, isn't that right? e 5 WITNESS MASON: Yes. A 9 3 6 JUDGE MILLER: Go ahead. R S 7 BY MR. JORDAN: N j 8 0 What I'm trying to get to, sir, is whether, to your d d 9 knowledge, that was a difference in the limestone over-break in b 10 this case for such reasons as, because the limestone is soluble 11 and it could involve sink holes and solution channels with the 5 g 12 aquifer there; is that what caused your problem? E Oi m is 8Y W TNsSS a^ son: l$ 14 A No, sir, not at all. 15 g You said that.in excavating the Unit 1 and 2, I j 16 believe you were specifically talking about Unit 1 at the time, w d 17 that once the blasting had been done and you were taking out the 5 5 18 material you did some more blasting and ribbing. What is E g 19 ribbing? n 20 BY WITNESS MASON: 21 A The statement was in two areas. The blasting that (} 22 I mentioned in the earlier -- 23 JUDGE MILLER: Pardon me. He just asked you what's 24 ribbing. {]) 25 WITNESS MASON: I didn't understand his question ALDERSON REPORTING COMPANY. INC. l
9 4.8 .. . 12 ' I that way, sir. i O 2 JUDGE MILLER: Well, I did. l 3 You said what is ribbing, didn't you, Counsel? 4 MR. JORDAN: I said what is ribbing. e 5 JUDGE MILLER: All right. Answer what is ribbing. h 3 6 Answer in focus and then we'll move along. R
& 7 WITNESS MASON: I'm sorry.
A j 8 JUDGE MILLER: That's all right. Just tell him what d
@ 9 ribbing is and you used it.
z o
@ 10 WITNESS MASON: I used the term ribbing, but in a way E
j 11 I think is common to construction industry to describe a chisel y 12 like tool that is pulled by a tractor. 5 O g m is 8Y MR. JaDAN: h 14 G Is that in the sense of a sharp heavy plow that is 15 used to pull off the rock? y 16 BY WITNESS MASON: us 17 A. It's a sharpened member that much more resembles 18 a chisel than it does a plow. E 19 4 Well, if I heard you correctly, in discussing this g n 20 whole question of the blasting and the effects that it caused, 21 I believe you said that the crack is worst from closely spaced 22 Q impacts than from a single large jolt. Is that correct? 23 JUDGi:; MILLER: Do you understand the question, 24 Mr. Mason? 25 WITNESS MASON: With some assumptions, I can i ALDERSON REPORTING COMPANY, INC.
l - 9'4.9 12-8 1 understand the question. Let me try my version of your question 2 in my terms. J i 3 When I used that phrase we were describing modifi- 1 4 cations, or at least the principle of lime drilling and blacting e 5 so as to induce a perimeter crack, thereby separating one rock mas s h
, @ 6 from another.
57
$ 7 The propogation of that crack from one hole to j 8 another is much more controllable by a sequence of charges, time d
c; 9 delayed so as to propogate the crack in its intended direction. E
$ 10 I believe that was my testimony from this morning.
11 JUDGE MILLER: I think that's correct. is j 12 What was your next question, Counsel? 5 O sm is BY Ma. aOnonN: h 14 G You discussed, Mr. Mason, the testing to determine 15 just how extensive the cracking was, and in so doing you j 16 described that you had dug trenches some distance away back from w
!i 17 the perimeter to determine the extent of the crack, and you said E
$ 18 three feet. If you found a crack in a three-foot deep trench,
$ 19 l g then did you dig another trench beyond that some distance?
I n 20 BY WITNESS MASON: 21 A. Yes, my testimony was that if a crack was present on 22 Q both sides of the trench it meant that it still had.a distance 23 behind it, therefore another trench behind that, at a greater 24 distance from the excavation was made, and that was contingent 25 I until that crack disappeared. l ALDERSON REPORTING COMPANY, INC. i
950 12-9 1 g Until that particular crack disappeared? 2 BY WITNESS MASON: 3 A That's right. O 4 g Now, did you then also dig a deeper trench than you g 5 had originally dug? 9 3 6 BY WITNESS MASON:
- R b 7 A No, on no occasion.
E j 8 g None? d k 9 BY WITNESS MASON: 5 y 10 A None.that I can recall.
!.F
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11 4 I might add that your Exhibit 5 has the details of is g 12 that and the diagran, the three feet you didn't have, provided a O! i3 dieeram of the reeu1ts of thee. I4 g h Once you dug the first three-foot trench you found 15 the crack on the other side and you had gone beyond it. Do you y 16 then know -- strike that. s I7 h Is it the case that none of the cracking was lower x { 18 than three feet? A 19 g BY WITNESS MASON: n 20 A No, sir. This morning and again this afternoon I 21 have, by this line, tried to infer that the damaged rock was in 22 O te,_,,,, ,,1es,zome ,,,,the ehe,existimg e1e,,,1,,do m.,,d. 23 That is the area and depth that remedial measures and rock l - t ' 24 excavation took place. The radial distance behind the rock 25li varied depending on what the end of the cracks were, but got as
. ALDERSON REPORTING COMPANY, INC.
951 12-10 1 far as 20 feet, somewhere in that vicinity, so envision concrete O 2 with a deptn closer to ten feet and a width closer to 20 feet, 3 even though the trenching only went, as I earlier testified, we h 4 looked at the most critical area, that near the surface, and if e 5 they were there then we said it's that way all the way, it kept h
@ 6 j going.
R
& 7 G I think it's becoming clear. You dug a three-foot a
j8 trench and found a crack. You dug it down to ten feet, d d 9 BY WITNESS MASON:
?
g 10 A. The rock removed, not the trench. 11 0 You dug out the rock down to ten feet and you is y 12 expanded that whole patform?
$ 13 BY WITNESS MASON:
l$ 14 A. Yes. Then we looked at the bottom of the then 15 {::: resolving depth.
.j 16 0 Okay, until you got to a trench that had no crack us
,N I7 on the other side?
18 BY WITNESS MASON: E g I9 A. Precisely. n 20 0 Thank you. 21 You referred to some cracks that I believe you g 22 discovered after the excavations, at least after all of the 23 additional necessary excavation had been completed. Mine don't 24
$ show that you -- the larger ring, which is in effect the new 25 perimeter caused by the need to dig out the damaged rock. It was l
l ALDERSON REPORTING COMPANY. INC.
952 l12-11 1, examined and thought to be acceptable, but later other cracks 1 () 2 were found as one progressed. 1 3 Now, where exactly were those cracks? () 4 BY WITNESS MASON: e 5 A We have generated, or caused to be generated a stack U d 6 of correspondence between this firm and TUSI to define, and it I E 7 has been defined by coordinates, the location of all of these j 8 pipes that were installed for grouting the cracks, which is o d 9 contained in your question. i h 10 I do not have the coordinates of these 30-odd E j S 11 locations, but they are in existence. j 12 g can you give me just a general description? Were (]) c 13 they in the wall of the excavation? Were they in the base of the l$ 14 excavation? 2 15 BY WITNESS MASON: g 16 A I have one sheet that I can answer you from by a w 6 17 general description. For further detail, we'll have to get a
$ 18 different --
0 19
, G No, a general description will be fine.
M 20 BY WITNESS MASON: 21 A There are none to my sheet and information that I p') 22 have available at this time that indicates there are none in the
%s 23 , reactor foundation. There is a zone in the Reactor Building 24 No. 1 wall and/or the safeguard wall, and I've got X's here that
)
25 are common to both; it may be in one, it may be in the other, and ALDERSON REPORTING COMPANY. INC.
'953' 12-12 1 I cannot give you definitive information.
2 O You said there were none in the foundation, you meant 3 the bottom of the excavation? 4 BY WITNESS MASON: e 5 A That is correct. U
$ 6 0 You did not mean the walls?
R
$ 7 BY WITNESS MASON:
3 y, 8 A My positive statement is that there are none in the cJ c 9 base of the reactor building. There might be one in Reactor 1 5 8 10 because of scale when I graphed, it's either there or it's in 11 the safeguard room, and I cannot clarify that. There are others is j 12 in the safeguard building, or Reactor 1, some in the safeguard Q 13 building for Reactor 2, and a bunch in the field zoning. l$ 14 JUDGE MILLER: Counsel, let w.e ask you, do you have 15 any documents that bear on this? You've been turning them up j 16 so far. If you've got one, let's have it. v5 N 17 MR. JORDAN: I'm sorry for the delay. Y
!E 18 JUDGE MILLER: That's all right.
is g 19 MR. JORDAN: I was not pursuing something for which n 20 I think we really documents on. I was trying to get the 21 diagrams and all those things. I simply wanted to get -- 22 BY MR. JORDAN: 23 ; G You mentioned in your discussion of the repairs -- 24 let me be clear, you developed the repair procedure for these 25 cracks we've just been discussing? ALDERSON REPORTING COMPANY, INC.
954 ,; 12-13 1 BY WITNESS MASON: 2 A. Yes. That was done. 3 G That was done. Do you mean Mason and Johnson did it? 4 BY WITNESS MASON: e 5 A I'm getting out of my field of expertise now. In d
$ 6 this particular case we did prepare the work to be performed by G
$ 7 others, what I hopefully am correctly calling a construction s
j 8 procedure. d o 9 G My quest'on -- I'm sorry, did you have something more z o G 10 to say? E j 11 BY WITNESS MASON: a g 12 A. Yes. There's another input; a portion of that Oo!is coaeeructioa erocedure ce11ea for ea iaeue ero ciad e a111 h 14 for the very reason that in sealing an open crack by the grouting 15 process you must have resistance on top of the crack to keep the j 16 grout from coming up and failing to go where it's supposed to, ws ti 17 so the solution to this involved the two firms, with the M 18 structural pe.ople telling us what the confining pressure that P E 19 would be produced by this structure was so that we in turn could R 20 monitor and hold the grout pressure, as measured at the ground, 21 to a lower number so as to not in any way do anything except 22 Q force the grout into the ground, not propogata a crack or left up ,. 23 a building. ' s 24 G And you said in that connection -- I'm sorry, you 25 motioned as if you might have more to say. ALDERSON REPORTING COMPANY, INC.
l . 955. ., 1 12-14 1 BY WITNESS MASON: 4 ~ 2 A That's all. 3 G You mentioned, in connection with your preparation () 4 of this, that you had a time dilemma. Am I correct in under-o 5 standing that that means you had to work quickly and felt some M n
@ '6 time pressure because the construction was no longer going to R
{ 7 put the building on top of the grout? A j 8 BY WITNESS MASON: d d 9 A I think that was the exact reverse that I intended. i o
$ 10 The time dilemma was that we had to provide for something that i
E j 11 could not be repaired until after the building mat was on. That 3 g 12 was the dilemma in time. We could not repair the crcck until 3 (]) ym 13 the building mat had been completed, as I just expressed a l$ 14 moment ago. 15 g With respect to the dental concrete placement, you
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j 16 said in essence that you came as close to the strength of the A 17 existing rock as was economically possible, I believe. Is that 18 a fair representation? h E g 19 BY WITNESS MASON: n 20 A If it is, it's an incorrect one. I remember going 21 through the exercise of pointing out that the dental concrete 22 strength was less than that which was used for the structural (]) 23 concrete, and that certainly is true. 24 However, the ramifications of economy were simply (]) 25l stating that there was no point in exceeding the strength of the ALDERSON REPORTING COMPANY. INC. l
956 12-15 1 rock with the replacement concrete, but rather than go to the 2 equal strength of the rock, which was less than what we used, 3 we adopted 2,500 p.s.i. strength concrete, as measured in 28 days,
/~T U 4 as being a flexible, economical mix that was stronger than the e 5 rock, and the dental concrete is in fact stronger than the h
@ 6 Glen Rose limestone.
R
$ 7 0 You're the expert. You have to check me on this, M
l 8 BY WITNESS MASON: d - d 9 A. I'm also under oath. What I say is true.
$ 10 0 Well, tell me whether or not I'm off in right field, 11 as it were. Did you determine the p.s.i. of the limestone, or a
p 12 is that something that can be done? E Q 13 BY WITNESS MASON: h 14 A. Oh, yes, it can be done, and it was done. g 15 0 And it was, you say, less than the p.s.i. of the a: g 16 dental concrete? us ( 17 BY WITNESS MASON: 5 5 18 A. Ihat is correct. E 19 How much? g G n 20 BY WITNESS MASON: 21 A. All that data, and believe me, it's voluminous, is 22 contained in both the PSAR and the FSAR. I do not recall the 23 , exact numbers. There's a whole section. 24 p) s. G In makind the determination to go with the dental 25 concrete, did Mason and Johnson, or anyone else, to your ALDERSON REPORTING COMPANY. INC. l
'95,7f 12-16 1 knowledge, do a seismic reanalysis of the foundation? l 2 BY WITNESS MASON:
3 A That was one of the items considered by Mason and O 4 achnson. It was one of the items considered, to my personal e 5 knowledge, by Gibbs and Hill, and the conclusion to all of us 0
@ 6 that we had improved from the seismic standpoint in trans-R
$ 7 missibility of the foundation. So in essence by visual M
8 8 inspection and the thought process I just outlined, that was d c; 9 the re-examination. We had improved the conditions, and that's o
@ 10 true.
11 You had improved the conditions by having two
$ (L 3
12 separate materials now that presumably shifted differently in l 5 O im '3 the seismic event 2 l 14 BY WITNESS MASON:
,2 15 A. We had improved conditions in the foundation to the z
y 16 extent that the propogation of seiesmic forces, and the stronger v5 17 material was more desirable than a weaker material. Concrete is
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h I8 stronger than the Glen Rose limestone. P 19 But at the same time you've eliminated the uniformity g 0 n 20 of the Glen Rose limestone, correct? 2I BY WUTBESS MASON: 22 A. We certainly introduced a different material, but ky 23 no means is the Glen Rose limestone a uniform material. It 24 contains clay' stones, hard crystalling limestone layers, and it's I 25 as far from being uniform as any material you could possibly have ALDERSON REPORTING COMPANY, INC.
,958l L2-17 1 ! drug up. That's a terrible illustration. I'm sorry.
() 2 (Laughter.) 3 BY WITNESS SCHEPPELE: () 4 A I'd like to comment if I may, and that is that from s 5 the viewpoint of any reanalysis seismically, I think the only N
$ 6 place that would'have been warranted, frankly, I don't think it R
& 7 would have been seriously considered, would be if you put soils, s
j 8 for example, in quite an extended depth beneath the foundations, d d 9 benerath the concrete foundations and above the limestone surface, i o
@ 10 which would indeed change the mathematical model to a degree on 3_ -
g 11 a containment structure. s y 12 The basis hing we're talking about here is relatively 5 (]) ym 13 small differences, I think, in materials, which really would have l$ 14 no impact whatsoever on any seismic analysis where we're 2 15 considering, as Mr. Mason indicates, a non-homogenous material j 16 with regard to the limestone formations, so it should not have w p 17 an impact on the seismic analysis, unless, I say, you introduce 5
} 18 a very soft material such as soil, but certainly not concrete.
P
$ 19 BY MR. JORDAN:
n 20 g I would like to ask each of you, because I don't 21 think this is clear in the record, which ones of you actually 22 saw the crack. k)\ l 23 l JUDGE MILLER: Which cracks? , i 24 MR. JORDAN: I'm sorry. I'm just shifting gears t 25 i now to the crack in the containment wall. I believe it's been i . 1 ALDERSON REPORTING COMPANY. INC. I l i
~
959 c 12-18 1 referred to. 1 2 BY MR. JORDAN: 3 g I'm sorry, the cavity wall. O 4 eY WITNESS MASON: e 5 A I did not see the crack. A n
$ 6 BY WITNESS MERRITT:
E E 7 A I saw the repaired crack. E j 8 BY WITNESS McGRANE: 6 d 9 A I saw the repaired crack, i o
$ 10 BY WITNESS SCHEPPELE:
E j 11 A I did not see the crack, no, sir. k j 12 BY WITNESS TOLSON: 3 j 13 A I did not see the crack. ({} m h 14 S Mr. McGrane? g 15 Let me ask you. m g 16 There were two cracks, one on the north side and one e 6 17 I believe on the south side, is that correct so far? Y
- l5 18 BY WITNESS McGRANE:
A 19 A That's right. h n 20 g Will you describe for us, with respect to the crack 21 on the north side, what you could actually see? 22 BY WITNESS McGRANE: 23 A On the north side I could only see the top surface 24 of that crack. 25 I g The one side of the crack was covered by the steel ALDERSON REPORTING COMPANY, INC.
e 960: 12-19 1 liner, was it not? 2 BY WITNESS McGRANE: 3 A It was covered by the form work on the inside, and () { it was poured on top of other concrete. You didn't have access e 5 where you could see it. It was just concrete below it. H h 6 G Did you, or did anyone to your knowledge, dr,ill in R a 7 the crack or otherwise take some action to determine how deep 3 j 8 the crack was at that point? d d 9 BY WITNESS McGRANE: i o g 10 A No. Based on our experience and based on what we saw E g 11 on the other side, the south side, we thought the crack went 3 y 12 through the depth of the pour. 5 l (]) 13 G on the south side, looking at Applicant Exhibit 22,
- ! 14 I believe the south side shows a cavity beneath the pour that is E
2 15 cracked. W g 16 BY WITNESS McGRANE: M d 17 A That is correct. 5
$ 18 G What you're telling us is that you could see the 5
[ M 19 crack, standing inside and looking up? 20 BY WITNESS McGRANE: 21 A The crack was observable because at that time curing 22 water was still present, and so a little bit of water was i (]) ( 23 working its way through the crack. i 25 ' { ALDERSON REPORTING COMPANY. INC.
l l 961',1 L3-1 1 0 The forms had been taken off at t'lat point? 2 BY WITNESS McGRANE: I 3 A The forms had been taken off on that side, yes. l () 4 G Now, describe for us, Mr. Tolson -- I'm really
; 5 guessing; whoever on the panel knows the answer. I think perhaps 9
@ 6 Mr. Tolson. Does~TUGCO or any of its consultants have a drawing R
$ 7 or mappings of these two cracks that were done for any purpose, s
j 8 that is, before today? d d 9 BY WITNESS TOLSON: i o
$ 10 A A map similar to Applicant's Exhibit 22 or 23, the 5
j 11 one on the right -- 23, was prepared in response to a question 3 y 12 that was asked by CASE during the discovery period. Essentially 5 (]) $m 13 CASE's question was what are the horizontal dimensions of the h 14 crack. As we state in our response, the horizontal dimensions g 15 of the crack were not recorded, but the language and verbiage x j 16 uutilized in the documents that were available resulted in a e d 17 pictoral presentation of the planned view of the cracks that are 5 { 18 essentially similar to Applicant's Exhibit 23, similar to what P
"g 19 Applicant's Exhibit 23 reflects, n
20 To my knowledge, there is no other drawings 21 available. 22 G Mr. McGrane, did you have something to add to that (]) 23 response? i 24 BY WITNESS McGRANE: 25 A I note that you have a copy of it because I've seen it ALDERSON REPORTING COMPANY,INC.
962'. 7 13-2 1 in the material that was forwarded to you by TUSI. l ,\
\-) 2 g Mr. Scheppele, you testified that -- I'm sorry, I'm 3 not exactly clear on this, but somewhere in.the course of pour
() 4 in which these cracks arose, you stated you would have accepted e 5 a construction joint at that point. E n
@ 6 BY WITNESS SCHEPPELE:
R
$ 7 A That's correct.
A y 8 4 Where was that? d d 9 BY WITNESS SCHEPPELE:
$ 10 A Roughly at the location of the cracks. As a matter j 11 of fact, I believe that there was a contractor's drawing that t
j 12 showed optional drawings at that location. c Q y m 13 BY WITNESS MERRITT: l$ 14 A That is correct. 15 g Mr. Scheppele, you don't know whether there was a j 16 construction joint there or.not? W 17 BY WITNESS SCHEPPELE: h z { 18 A To the best of my knowledge, there was not. E l9 - BY WITNESS MERRITT: g
" l 20 ' A There is not a construction joint there.
2I MR. JORDAN: I'm distributing a document that we ask 22 (]) to be marked as CASE Exhibit 7. 23 ! JUDGE MILLER: Is this the drawing that was 24 referred to, CASE Exhibit 7? (]) 25 ! jff ALDERSON REPORTING COMPANY,INC.
963... ; l L3-2 1 BY MR. JORDAN: ( 2 g Mr. Tolson, you seem most familiar with it. Can you 3 tell us what that is? () 4 BY WITNESS TOLSON: e 5 A First of all, it's not the drawing that I referred to E 9 3 6 a few minutes ago. - R S 7 g No, it's not that drawing. E j 8 BY WITNESS TOLSON: d d 9 A Okay. I believe that this is, is a construction z o
@ 10 drawing, as Mr. McGrane mentioned, that shows the alternate g 11 construction which might be utilized for this particular
's j 12 placement.
3 13 g (]) Then the dark outlined areas are the full pour?
!= 14 BY WITNESS TOLSON:
2 15 A I would say the exterior, that's what it appears to j 16 be. It looks as though the exterior of the pour would extend to m l 6 17 the outside face of the steam generator part of the wall. i 5 18 g Was this poured as one pour, or was this poured in I : e 19
}n sections? According to what appear as joints on this document --
l 20 BY WITNESS TOLSON: i ! 21 A This, to my knowledge, was poured as a single pour. I 22 BY WITNESS MERRITT: (]) ! 23 , O Mr. Jordan, we have what are called pour isos, and t 24 I don't know if that's one of them or not. I'd just have to []} 25 look at it. I don't know where this came from.
- ALDERSON REPORTING COMPANY, INC.
964 - 13-4 1 MR. JORDAN : Thank you. I'll withdraw that. ( 2 JUDGE MILLER: It may be withdrawn. CASE's Exhibit 7 3 for identification is withdrawn. () 4 MR. JORDAN: Mr. Chairman, would it be your will to e 5 then number our next exhibit as CASE 7? A 9
@ 6 JUDGE MILLER: Better make it 8, since it's been R
& 7 referred to in the transcript, so we have no confusion.
A j 8 MR. JORDAN: I'm distributing a document marked for d d 9 identification CASE Exhibit 8, which purports to be a Brown & Root ,
$ 10 Inc., Quality Assurance Department nonconformance report.
E j l1 BY MR. JO.RDAN : j 12 g Mr. Tolson, do you have that in front of you? 5 (]) ya 13 BY WITNESS TOLSON:
! 14 A Yes, I do.
2 15 g Do you recognize the document? g 16 BY WITNESS TOLSON: M d 17 A Yes, I do. l l $ 18 % What is it?
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C g 19 BY WITNESS TOLSON: M 20 A It's a Brown & Root, Incorporated, nonconformance 21 report that we referred to about an hour ago. This is CASE (} 22 Exhibit 23. 1 23 MR. JORDAN : I would move that this be admitted as 24 Exhibit 8 into evidence.
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25 JUDGE MILLER: Any objections? 1 , ALDERSON REPORTING COMPANY. INC. , 1 L 1
965' 13-5 1 MR. JORDAN: Just to be clear for the record, CASE l 2 Exhibit 23 is numbered and comes from a different set of exhibits 3 that CASE filed in a different filing with the Board. () 4 WITNESS TOLSON: Now I understand that. Thank you. 5 JUDGE MILLER: CASE Exhibit 8 will be admitted into g 9 3 6 evidence. R
$ 7 (CASE Exhibit No. 8 was marked M
j 8 for identification and was d c; 9 received in evidence.) z o
@ 10 MR. JORDAN: Your Honor, if we can have perhaps just 11 a moment we'll distribute several documents at once.
E g 12 JUDGE MILLER: All right, and having done that, we c Q 13 will then probably recess for the day, h I4 MR. JORDAN: I believe we have admitted CASE j= 15 Exhibit 8, am I correct? d 16 JUDGE MILLER: Yes, CASE 8 has been admitted. W 17 BY MR. JORDAN: h
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18 g Mr. Tolson, I hope you have these in some reasonable b
- E 19 order. The document, if it hasn't been already marked for you, l g n
20 is CASE Exhibit 9. It's a five-page document. It appears to be 2I a Brown & Root Quality Assurance nonconformance report. Above () 22 the blocks that say RLS hold number code status, there are, about 23 ; a quarter of the way down the page, on the right-hand side, there 24 l (') is a number C-650Rl. Can you tell us what this document is? 25; JUDGE MILLER: Well, wait a minute. ALDERSON REPORTING COMPANY, INC.
966 !i3-6 1 BY MR. JORDAN: k'h/ 2 % I'm sorry, let me give you a little bit more here. 3 There's also above input date the number 042677. l 4 JUDGE MILLER: That input date, 042677, is that e 5 the one? h j 6 MR. JORDAN: Yes. That's the one. i R M 7 JUDGE MILLER: What's the number? E j 8 MR. JORDAN: CASE Exhibit 9. O o 9 BY MR. JORDAN: b g 10 g Do you have that, Mr. Tolson? E II BY WITNESS,TOLSON: B
$ I2 A Yes, I do.
(]) 3 13 g Is that not a revision to the nonconformance report
! I4 that was CASE Exhibit 8?
g 15 BY WITNESS TOLSON: b y 16 A That's correct. M i 17 MR. JORDAN: That's marked for identification as { 18 CASE Exhibit 10. E e l9 (CASE Exhibits 9 and 10 were n 20 marked for identification.) 2I MR. JORDAN: It's a similar document, some four pages, () 22 I think we can identify it by the numbers, above the block RLF 23 ; hold number code is the same number, C65 R1 -- C 6 50 Rl . Acove the 1 24 input date is 061978. (]) 25 ' ,,
, ALDERSON REPORTING COMPANY, INC.
- 967-13-7 1 BY MR. JORDAN:
2 G Do you have that document, Mr. Tolson? 3 BY WITNESS TOLSON: ( 4 A Yes, I do. e 5 JUDGE MILLER: I don't know, you've got a lot of h
$ 6 input dates here the same, but what about the RLS number?
R 7 MR. JORDAN: The RLS number, there are two more 3 [ 8 documonts that contain input dates, but only one that has that d d 9 input date of 6-19-78 and the number C650Rl.
! That's what, 10?
$ 10 JUDGE MILLER: Okay.
3 5 11 MR. JORDAN: That's CASE Exhibit 10. y 12 BY MR. JORDAN: (}3y 13 G Mr. Tolson, what is it? m l s 14 BY WITNESS TOLSON: 2 15 A It's a revision to the CASE Exhibit 8 that we 5 j 16 discussed earlier. w d 17 G So it's a further revision? 5 18 BY WITNESS TOLSON: 5 19 A Yes. [M 20 G Marked as CASE Exhibit 11, a similar document. 21 purporting to be a nonconformance report. It has the whole 22 number typed, C650R2, and appears to be then crossed out and it (]) 23 has an input date of 0611978 (sic.). 24 (CASE Exhibit No. 11 was []} 25 marked for identification.) ALDERSON REPORTING COMPANY, INC.
968' .-5 1.3-8 i MR. JORDAN: Do you have it, Mr. Chairman, CASE 2 Exhibit ll? 3 BY MR. JORDAN: 4 0 Mr. Tolson, is this a first revision to the NCR that 5 was previously CASE Exhibit 8? h 6 BY WITNESS TOLSON:
- E 6 7 A. That's correct.
M l 8 MR. JORDAN: The final document, CASE Exhibit 12, d d 9 marked for identification, has the RLS hold number C650R3, and z, o 3 10 input date of 06-19-78. E
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l $ II JUDGE MILLER: " Arms Indexed" at the top? is 12 MR. JORDAN: It says " Arms Indexed" at the top. N 5 Oi '3 JUDcE M1ttER: Okay. Whae s thae2 l$ 14 MR. JORDAN: CASE Exhibit 12. 15 (CASE Exhibit No. 12 was 16 ii[ marked for identification.) vi I7 BY MR. JORDAN: hc: { 18 g Mr. Tolson, is this indeed a further revision of P 19 what was originally CASE Exhibit No. 8? g n 20 BY WITNESS TOLSON: 2I A. That's correct. 22 O MR. ,ORDAN: your yomo,, I thinx we.,e co,ered No. e, 23 l and we ask that CASE Exhibits 9 through 12 be admitted into l C 24 e 1,emce.
'43 JUDGE MILLER: Any objection?
i' l l ALDERSON REPORTING COMPANY, INC.
969 13-9 1 MR. REYNOLDS: Mr. Chairman, since we just recieved 2 these we haven't had a chance to to verify that these attachments 3 are indeed the attachments to the reports. (~) (~/ 4 JUDGE MILLER: All right. We'll give you until g 5 9:00 o' clock in the morning. 0
@ 6 MR. REYNOLDS: Subject to verification, we have no R
$ 7 objection.
3 j 8 JUDGE MILLER: All right. We'll hold ruling upon the d q 9 tender until we have had a response, since you will have a z c
$ 10 chance overnight.
E 11 We'll stand in recess until 9:00 o' clock in the B 12 morning. l 5 a ('N 13 ()5m (Whereupon, at 5:45 p.m., a recess was taken until j 14 9:00 a.m., Tuesday, June 8, 1982. g 15 ___o00___
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i ALDERSON REPORTING COMPANY. INC.
/ l NUCLEAR REGULATORY COM4ISSION This is to certify that the attached proceedings before the l in the matter of: TEXAS UTILITIES GENERATING COMPANY, et al UNITS 1 & 2 Date of Proceeding: June 7, 1982 Docket liumber: 50-445 & 50-446 Place of Proceeding: Fort Worth, Texas were held as herein appears, and that this is the original transcript thereof for the file of the Commission. Judy Bradley Official Reporter (Typed)
,b k.)AAr A- r 1 8 d Official Reporter (Signature) t . }
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