ML20056E456

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Transcript of 930821 Proceedings in San Luis Obispo,Ca Re PG&E (Diablo Canyon Nuclear Power Plant,Units 1 & 2).Pp 1,498-1,705
ML20056E456
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 08/21/1993
From:
Atomic Safety and Licensing Board Panel
To:
References
CON-#393-14250 OLA, OLA-2, NUDOCS 9308240079
Download: ML20056E456 (200)


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~ .,f _ 5 n D i r'?, ; .  ! Uisiviimt OFFICIAL TRANSCRIPT OF PROCEEDINGS I Agency: NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD

Title:

In the Matter of:

PACIFIC GAS AND ELECTRIC COMAPNY (DIABLO CANYON NUCLEAR POWER PLANT UNITS 1 AND 2)

Docket No. 50-275-OLA and 50-323-OLA LOCATION: San Luis Obispo, r elifornia DATE: Saturday, August 21,1993 PAGES: 1498 - 1705 l

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1498 UNITED STATES OF AMERICA 1

k NUCLEAR REGULATORY COMMISSION 2

3 ATOMIC SAFETY AND LICENSING BOARD

-X 4

5 In the Matter of:

Docket Nos. 50-275-OLA-2 6 PACIFIC GAS AND ELECTRIC 50-323-OLA-2 7 COMPANY f 8 (Diablo Canyon Nuclear l  :

l 9 Power Plant, Units 1 and 2) 10


X San Luis Obispo 11 County Library 12 995 Palm Street 13 San Luis Obispo, CA 14 Saturday, 21, 1993 O 15 The above-entitled matter came on for evidentiary 16 at 9:10 a.m.

17 hearing, pursuant to notice, CHAIRMAN THE HONORABLE CHARLES BECHHOEFER, 18 BEFORE:

JERRY KLINE, MEMBER THE HONORABLE DR.

l 19 SHON, MEMBER 20 THE HONORABLE FREDERICK J.

Atomic Safety and Licensing Board 21 U.S. Nuclear Regulatory Commission 22 Washington, D.C. 20555 23 24 25 ANN RILEY & ASSOCIATES, LTD.

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1498 1 UNITED STATES OF AMERICA k

2 NUCLEAR REGULATORY COMMISSION 3 ATOMIC SAFETY AND LICENSING BOARD 4 - - - - - - - - - - - - - - - - -X 5 In the Matter of:  :

6 PACIFIC GAS AND ELECTRIC  : Docket Nos. 50-275-OLA-2 7 COMPANY  : 50-323-OLA-2 i 8 (Diablo Canyon Nuclear  :

9 Power Plant, Units 1 and 2)  :

10 - - - - - - - - - - - - - - - - -X 11 San Luis Obispo 12 County Library 13 995 Palm Street 14 San Luis Obispo, CA 15 Saturday, 21, 1993 16 The above-entitled matter came on for evidentiary 17 hearing, pursuant to notice, at 9:10 a.m.

18 BEFORE: THE HONORABLE CHARLES BECHHOEFER, CHAIRMAN 19 THE HONORABLE DR. JERRY KLINE, MEMBER 20 THE HONORABLE FREDERICK J. SHON, MEMBER (

21 Atomic Safety and Licensing Board 22 U.S. Nuclear Regulatory Commission 23 Washington, D.C. 20555 21, 25 I ANN RILEY & ASSOCIATES, LTD.

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1499 1 APPEARANCES:

I 2 On behalf of Pacific Gas & Electric:

3 DAVID A. REPKA, ESQ.

4 Winston & Strawn 5 1400 L Street, N.W.

6 Washington, D.C. 20005-3502 7

8 CHRISTOPHER J. WARNER, CHIEF COUNSEL 9 Pacific Gas & Electric 10 77 Beale Street 11 San Francisco, California 94106 12 13 On behalf of the NRC Staff:

14 ANN P. HODGDON, STAFF COUNSEL 15 ARLENE A. JORGENSEN, STAFF COUNSEL 16 U.S. Nuclear Regulatory Commission 17 Office of General Counsel i 18 Washington, D.C. 20555 19 20 On behalf of San Luis Obispo Mothers for Peace:

21 DIANE CURRAN 22 Harmon, Curran, Gallagher & Spielberg 23 2001 South S Street, N.W., Suite 430 24 Washington, D.C. 20009 25 APPEARANCES [ continued):

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1500

- 1 On behalf of San Luis Obispo Mothers for Peace:

2 JILL ZAMEK 3 P.O. Box 164 4 Pismo Beach, California 93448 5

6 On behalf of Pacific Gas & Electric Company, Diablo Canyon 7 Nuclear Power Plant, witness panel:

8 9 BRYANT GIFFIN, MANAGER MAINTENANCE SERVICES 10 WILLIAM CROCKETT, MANAGER TECHNICAL SUPPORT 11 STEVEN ORTORE, DIRECTOR ELECTRICAL MAINTENANCE 12 DAVID A. VOSBURG, DIRECTOR WORK PLANNING 13 15 16 17 18 19 20 21 22 23 r* 24 25

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1501 i l

1 INDEX l I

- 2 Direct Cross Redirect Recross 3 WITNESSES for PG&E: i Bryant Giffin  !

4 William Crockett Steven Ortore 5 David A. Vosburg ,

I 6 (Re: MFP Exhibit 105-113)

[By Mr. Repka) 1507 ,

7 [By the Judges] 1519 l l [By Ms. ZamEk] 1522 l 8 [By the Judges] 1524 9 (Re: MFP Exhibit 116-117

[By Mr. Repka] 1535 I

10 [By Ms. Curran] 1538

[By the Judges] 1550 11 [By Mr. Repka] 1556 12 (Re: MFP Exhibit 118)  !

i (By Mr. Repka] 1558 13 [By Ms. Curran) 1561 I

i 14 (Re: MFP Exhibit 119-127)

! [By Mr. ZamEk] 1563 l('

I 15 [By Ms. Curran] 1576 l 16 (Re: MFP Exhibit 128-129)

[By Mr. Repka] 1589 17 [By Ms. Curran) 1590

[By Mr. Repka] 1591 18 (Re: MFP Exhibit 130) 19 [By Mr. Repka] 1593

[By Ms. Curran] 1595 20 [By the Judges] 1596

[By Mr. Repka] 1597 l 21 (Re: MFP Exhibit 131) i 22 [By Mr. Repka] 1598

[By Ms. Curran] 1600 l 23 [By Mr. Repka] 1609 l

[By Ms. Curran] 1610 24 [By the Judges] 1610 l 25 l

(

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1502 1 INDEX (continued) 2 Direct Cross Redirect Recross 3 (Re: MFP Exhibit 132)

[By Mr. Repka] 1615 4 [By Ms. Curran] 1617

[By Mr. Repka] 1622 5 [By the Judges] 1622

[By Ms. Curran] 1625 6

(Re: MFP Exhibit 135-137) 7 (Re: PG&E Exhibit 27)

[By Mr. Repka) 1627 8 [By Ms. ZamEk] 1630 9 (Re: MFP Exhibit 138-142; 140-A) 10 [By Mr. Repka] 1649

[By Ms. Curran] 1654 11 [By Mr. Repka] 1663 12 (Re: MFP Exhibit 144; 149-151A)  !

[By Mr. Repka] 1668 l 13 [By Ms. ZamEk] 1674

[By the Judges] 1680 14 0 15 (Re: MFP Exhibit 154)

[By Mr. Repka]

[By Ms. Curran]

1682 1687 16 [By the Judges] 1688 17 (Re: MFP Exhibit 155-156)

[By Mr. Repka] 1692 18 [By Ms. Curran] 1693 19 20 21 22 23 24 25 (C j\ ANN RILEY & ASSOCIATES, LTD.

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1503

,. 1 EXHIBITS k-- 2 EXHIBITS: Marked Received 3 PG&E's:

4 Exhibit 25 & 26 1518 Exhibit 22 1566 5 Exhibit 27 1646 6 MFP's:

7 Exhibit 109 1519 Exhibit 110 8 Exhibit 111 Exhibit 113 9 Exhibit 117 1556 Exhibit 119-124 1588 10 Exhibit 126-127 1588 Exhibit 128-129 1592 11 Exhibit 130 1598 Exhibit 132 1625 12 Exhibit 135-136 1646 Exhibit 138-140A 1666 13 Exhibit 144 1682 Exhibit 146-151A 1682 14 Exhibit 154 1691 l Exhibit 155-156 1703 15 16 17 18 19 20 21 22 23 24 25 ANN RILEY & ASSOCIATES, LTD.

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1504 1 PROCEEDINGS O 2 [9:10 a.m.)

3 JUDGE BECHHOEFER: Good morning, ladies and 4 gentlemen. We're back on the record. As you can observe, 5 it's permissible not to wear coats. I think most of you 6 aren't. We're resuming the original panel that we started 7 with before we interrupted yesterday prior.

8 Are there any preliminary matters before we start?

9 [No audible response.]

10 JUDGE BECHHOEFER: If not, I would like to comment 11 we're allowed to go to precisely 11:30. The whole room has 12 to be cleared for some other function by 12:00, but we will 13 be able, though, to just cart stuff across the hall, and 14 that room, I guess, will be available starting at about 15 10:30.

16 I'm told we can lock stuff there or have stuff 17 watched during lunch, and that type of thing. So before 18 lunch we'll to some transporting and have the room from 1:00 19 to 5:00 this afternoon. It's a little crowded, but there 20 are some chairs there.

21 Okay. Ms. Curran, are you ready to proceed?

22 MS. CURRAN: Yes. We're on page ld of our road 23 map, and the category we're under now is control of Foreign 24 Material /Housekeep.ing.

25 The exhibits here are Exhibit 105 NCR-Inspection.

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1505 1 Report 92-31, dated December 11, 1992; Exhibit 106, NCR I

f-)s

\ 2 Diablo Canyon Shutdown Risk and Outage Management 3 Inspection, NCR Inspection Report 50-275/92-201, dated 4 December 8, '92; Exhibit 107, which is Inspection Reports 5 88-10 and 88-11, which is dated June 17, 3988; Exhibit 108,  ;

l 6 which is NCR NOV and Inspection Reports 88-07 dated May 5, i

j 7 1988, 88-10 and 88-11, dated June 17, 1988; Exhibit 109, i

8 which is NCR DC 2-91-TN-N102-RT, dated November 11, 1992, 9 Exhibit 110, which is NCR DCO-91-MM-NO42, dated 10 May 19, 1992; Exhibit 111, which is LER 2-91-012-00, dated I

l 11 March 5, 1929; Exhibit 112, which is PG&E Reply to NCREA 89-i 12 241; and Exhibit 113, which is PG&E Letter Number DCL .

1 13 070, dated March 12, 1990.

14 [ Judges confer.]

15 MR. REPKA: Okay. Does everybody have copies of 16 all of those documents?  !

17 MR. GIFFIN: We have one copy at this table, yes.

18 MR. REPKA: What's been marked as Exhibits -- MFP 19 Exhibits 105-113?

20 MR. GIFFIN: Yes, but it seems like 112 and 113 21 are the same thing.

22 MS. CURRAN: Weren't you going to give us new 23 copies of those?

24 MR. REPKA: Were we going to do that?

25 MS. CURRAN: Yeah.

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1506 1 MR. REPKA: We forgot.

2 MS. CURRAN: I knew it wasn't me. Yeah. You I 3 volunteered to get new copies, because they were messed up 4 in some way.

5 MR. REPKA: Okay. We'll get new copies, but let 6 me ask the witnesses, are 112 and 113, in fact, the same 7 document?

8 MR. GIFFIN: Yes.  !

9 MR. CROCKETT: The documents that we were issued 10 are the same document.

11 MR. REPKA: Okay. So what I would propose is that 12 we deplete 113, and 112 we'll get a fresh copy somewhere 13 along the line. Okay. We'll provide for the record later a 14 clean copy of MFP Exhibit 112, and, for now, we'll work with 15 what we have.

16 JUDGE BECHHOEFER: Are you withdrawing 113, just 17 as a matter of information?

l 18 MS. CURRAN: Yes. PG&E will provide it.

19 JUDGE BECHHOEFER: I take it they're not --

20 they're different versions of the same document.

! 21 MS. CURRAN: We'll consolidate 113 into 112. I l 22 don't think all the information is under 112 there.

23 JUDGE BECHHOEFER: Well, aren't they identical?

24 MS. CURRAN: As I identified the document, I don't 25 think I gave the date. I guess what I abould do is just

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i 1507 2

l 1 withdraw 112, because the information that we gave the court

  • ' reporter for the description of 113 is a more complete 2 ,

l 3 description of the document.

j 4 MR. REPKA: That's fine. Whatever.

5 JUDGE BECHHOEFER: They seem identical. So I'm 3

6 not sure --

4 7 MR. REPKA: Right. I don't care which number he

! 8 gets.  !

9 JUDGE BECHHOEFER: What I wanted to make sure is l l 10 that there wasn't, like, a -1, -2, -3 so that s'e was a 11 later version of the other one. So, if they're identical --

12 they appear to be the same.

4 13 MR. REPKA: Okay. Let's --

14 JUDGE BECHHOEFER: Okay. We'll treat 112 as being i 0 15 withdrawn, then.

I i

16 MR. REPKA
Okay. Let's press on, then.

i 17 DIRECT EXAMINATION 18 BY MR. REPKA: ,

4  !

19 Q Gentlemen, are you familiar with the documents

~

20 that have been identified as MFP Exhibits 105 through 111 21 and then MFP Exhibit 113?

i 22 A (Witness Giffin) Yes.

23 A (Witness Crockett) Yes, I am.

24 Q Mr. Crockett, these documents appear to mix 25 several disparate debris issues, am I correct?  ;

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1508 l 1 A That's correct. I l

~

2 Q What are those issues?

3 A There's, basically, three issues. There's one -

4 issue of material inside the RHR sump, which is inside 5 containment, and there is an issue of material inside 6 containment but outside the RHR sump, and then there's a  !

l 7 FMEA issue, Foreign Material Exclusion issue.

8 Q Let me take those three issues one by one. The 1

9 first issue you mentioned is the debris in the RHR recirc ,

10 sump. Which of these documents relates to that issue?

11 A Exhibit 113.

12 Q And that -- were you finished?

13 A Yeah. Exhibit 113.

( 14 Q Okay. And that issue arose when? l t I 15 A During Unit l's third refueling outage in 1989.

16 Q Is that issue addressed in your direct testimony?

17 A Yes, it is.

I 18 Q Would that be the testimony at page 105?

19 A That's correct, on page 105.

20 Q And that issue was resolved?

I l 21 A Yes, it was. Corrective hetions were taken.

l l 22 Q Have there been instan:es of debris in the RHR 23 recirc since that time?

24 A Since we modified the procedures to control 25 material inside the sump, we have not had any recurring

,~,

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1509 1 problems.

2 Q Okay. Let me move to the second of the three 3 issues, the debris in the containment outside the RHR sump.

4 What do you mean by that issue?

5 A Here we're talking about materials such as some 6 rags, papers, test equipment, some miscellaneous tools that 7 were discovered outside the RHR sump but inside containment, 8 generally during mode 4 operations while we're heating in 9 the plant.

10 Q These instances of these kinds of materials being i 11 identified, when did they occur?  !

I 12 A 2 R-4 in particular, we have an NCR and an LER 13 with 2 R-4. That's Unit 2's fourth refueling outage, and 14 again in 1 R-5, Unit l's fifth refueling outage.

15 Q Okay. Which of these documents that have been i 16 identified by MFP relate to this second debris issue?

I 17 A I think Exhibit 105,. NRC Inspection Report 92-31 18 and Exhibit 109. That's the NCR DC 2-91-TN-N102, and l 19 Exhibit 111. It's the LER 2-91-012.

I 20 Q Following these instances, which you said were 21 identified during 2 R-4 and 1 R-5, were actions taken to 22 address the issue?

23 A Yeah. Yes, they were. In particular, the kind of 24 actions that we took were we -- I think one of the most 25 important ones was that, in each work order that goes into

\

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1510 1 containment, we now have specific instructions in that work 2 order that tell the individual worker their responsibilities i 3 and the procedures they need to do to conform with material l

l 4 inside containment, control of that material. {

5 Q Has that been successful? -

i 6 A Well, 2 R-4, during one of our inspections in-mode j 7 4, we did find some, on a few occasions, some material 8 inside containment. We made some corrections to that 9 procedure. I think it improved it a lot; improved the i

10 wearness of the requirements, and 1 R-5, the site inspector t

11 on a survey with our QC inspectors to monitor and look for l l 12 material that was unattended, we found some more occasions,- j 13 and we strengthened the program from that and improved it 14 even further.  !

O 15 Q How did you do during 2 R-5, which is --

l 16 A 4 or 5 we had no findings. {

17 Q Now, this is issue of. debris in the containment 18 outside the RHR sump, is this addressed in your' direct 19 testimony also?

20 A Yes, it is.

21 Q Would that be your testimony at page 97?

22 A That's correct.

23 Q Now, we just talked about two of these issues, the 24 debris inside containment in the RHR sump and the debris in 25 containment outside the RHR sump, Mr. Vosburg, can you give-i l

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1511 1 me a sense of how they correlate, if at all?

2 A Well, there's -- in terms of significance, theta's 3 really two issues. The intent of the RHR sump is in the 4 post-LOCA recirculation mode. The RHR system takes suction 5 from the research sump inside of the containment. l 6 In terms of having debris inside of the research 7 sump -- I guess describing the research sump generally, ,

8 it's, of course, a sump condition the containment, and 9 outside that sump it's covered by structure, a screen i

10 structure that's intended to keep any material from flowing j 11 inside the screens, getting inside the sump and then getting j 12 to the suction of the RHR pumps.

13 In terms of having debris inside the sump, the i

14 concern is that that debris could get, then, sucked into the  ;

15 RHR suction line and either have an impact on the RHR pump  !

16 directly or pass through the RHR pump and then, potentially, 17 block some of the tubes in the RHR heat exchanger.

18 The concern with debris outside of the sump is 19 that, if there was a large amount of debris in the general 20 containment area, it's possible that that debris could be i 21 transported to the screens, the screens outside the research 22 sump, and plug the screens such that the flow into the sump 23 would be restricted.

24 However, this is a very large structure, and it 25 would take a very large amount of debris to have any ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 l

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1512

-- 1 significant effect on the RHR pumps for debris outside of

~ '

2 the sump.

3 Q But, nonetheless, you'll remain vigilant to both of these issues? i 4

5 A Oh, absolutely.

6 Q Now, with respect to the third of the issues

. 7 that's mixed into this grouping of documents, that's, 8 Mr. Crockett, what I believe you referred to as foreign 9 material exclusion; is that correct?

10 A That's correct.

11 Q What do you mean by that terminology?

12 A Well, that's just a -- a process, a program that 13 you try to prevent an object from entering a system when you

~

14 take it apart and disassemble it.

15 Q So this relates to specific activities on specific l 16 items of equipment?  !

I 17 A That's correct. 1 J

18 Q And which of the documents identified here this 1 19 morning relate to that issue?

20 A It's Exhibit 106. That's the Diablo Canyon 21 Shutdown Risk Outage Management Inspection Report, Exhibits 22 107 and 108. Those are inspection reports that occurred 23 during the second refueling outage on Unit 1.

24 Q The second refueling outage was when?

25 A Second refueling outage on Unit 1. Exhibits 107 O ANN RILEY & ASSOCIATES, LTD.

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1513

. 1 and 108 are two inspection reports from that outage.

2 Q Right. That's 1 R-2 in what year?

3 A That's 1 R-2 1988.

4 Q Okay. Go ahead. Which other documents?

I 5 A Exhibit 110, which is an NCR DCO-19-MM-N042. ,

l 6 That's it.

( 7 Q Okay. Now, Exhibits 107 and 108, you said, l

8 related to the 1 R-2 outage in 1987, '88, I think you said.

9 A 1988.

10 Q Were actions taken to address those issues at that 11 time? ,

12 A Yes, they were. )

1 l 13 MR. REPKA: I have marked for identification two l '

l 14 documents, PG&E Exhibits 25 and 26. l l

15 BY MR. REPKA: I 16 Q The document I have identified as PG&E Exhibit 25 l l

17 is a June 6, 1988 letter from J.D. Shiffer of PG&E to the l

18 U.S. Nuclear Regulatory Commission, and the document that 19 I've identified as PG&E Exhibit 26 is a letter from J.D.

20 Shiffer, PG&E, to the Nuclear Regulatory Commission, dated l

l 21 July 18, 1988, 22 A That's correct.

i 1

l 23 Q Mr. Crockett, do these documents represent PG&E's 24 responses to Exhibits 107 and 108?

25 A That's correct.

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! Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 l

1514 1 Q And they include the actions taken in -- at that O- 2 time to address this issue?

l l

3 A That's correct. j l

4 Q Have those actions, with respect to foreign l l

5 material exclusion, have they been successful?

6 A Yeah, I think they've been -- they've really ]

1 7 helped a lot. Let me say one thing. I think our program --

8 we have a good. program to begin with. I mean, it's the same.

9 process that other utilities, including ourselves, we use --

10 we've been using for as long as my_ years of experience.

11 It's a program that we're using. When you 12 disassemble a component, you try to keep things from falling 13 inside of it. We have disassembled -- for years we have 14 been disassembling things like our turbines, lots and lots 15 of parts in it, 6,000 horsepower reactor coolant pump motors 16 and seals, 12,000 horsepower circulating water pump motors 17 and pumps.

18 We've been doing this for a long time, and we've ,

1 19 been doing it very successfully, and I think what this 20 pointed out is that the weakness is that not everybody is 21 familiar with some of the specific requirements, but, in l

22 general, we have a good program. j 23 We've been taking things apart and keeping foreign 1

24 objects out for a long time, and I think what happened, as 25 part of these corrective actions, I think we strengthened O ANN RILEY & ASSOCIATES, LTD.

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l 1612 K Street, N.W., Suite 300  !

Washington, D.C. 20006 (202) 293-3950

~ .- -- - -- - - .. . -

1515 1 the program. We improved the procedures. We improved the 2 understanding by plant staff about what their individual I I

3 responsibilities are.

4 Q And yet Exhibit 110 appears to be a subsequent NCR  !

i 5 that relates to foreign naterial exclusion. Does that i 6 undermine your confidence in any way in the program? j 7 A Not at all. I think -- again, like I said, I 8 think we had a pretty good program. We made some pretty  :

9 good improvements after the_NOVs.in 1988, but we still found.

10 where some people didn't understand their responsibilities, l l

11 and we had some problems with FMEA control, but, again, you i 12 know, I can go on. l l

13 When we disassemble our reactor and look at -- +

14 inside the vessel, we do a thorough examination very outage.

O i

15 We have a submarine that goes in. We inspect our fuel, and  ;

16 we don't find -- we have not had problems with foreign l 17 materials causing damage, but I think we got a good program, j i

i 18 and we made some improvements.

19 Q And does that include -- does that reflect your 20 experience in the most recent 2 R-5 outage?

21 A That's right. 2 R-5, no problems. One of the 22 things we did in 110, it was a -- it was an NRC that lasted 23 over 2 R-4 and 1 R-5. We did some things to improve the 24 understanding of the system, things like we clarified 25 procedures. We provided some more training. We included in i

O ANN RILEY & ASSOCIATES, LTD.

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1612 X Street, N.W., Suite 300 l Washington, D.C. 20006 L (202)'293-3950

1516 1 work orders specific requirements for FMEA control, and what 2 I thought was another really significant improvement is that 3 we now have a FMEA coordinator and FMEA monitors and QC 4 inspections of work in FMEA areas, in areas to minimize any 5 problems with foreign materials.

6 Q Does all this guarantee that you'll never find 7 foreign material in equipment?

8 A You know, we have a good program, but, you.know, I 9 couldn't guarantee, but if the situation happened where 10 someone violated an administrative part of the procedure or, 11 you know, we would identify it, document it, and correct the 12 action and improve the program more.

13 Q Now, let me turn your attention to the document 14 that's be identified as MFP Exhibit 106, and particularly to 15 page 21. On that page, the NCR appears to identify a 16 particular instance related to foreign material. Do you 17 have a reaction to that?

18 A Yeah. This was an inspection team by the NRC, and 19 they identified a -- I'd say a part of our FMEA process that 20 didn't include instrument tubing, and instrument tubing, you 21 know, three-eights instrument tubing, that supplies signals 22 to our pressure transmitters. We didn't have provisions in 23 our procedures to cap that off.

24 You've got to keep in mind the likelihood of 25 foreign materials going into an instrument tap.

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! 1517

~ 1 Q What is that likelihood? It's low?

?

2 A It's not very likely. It's very low, but it was a 3 weakness in the program, and we corrected and added it to 4 our procedures for instrumentation.

5 Q What did the NCR say about housekeeping in i 6 general?

7 A If you look -- what I thought was interesting, on 8 page 21, the -- in the middle where it says -- middle ,

9 paragraph, where it says, j 10 "Aside from the above deficiency,"

11 it says, 12 "the team included that material i

13 condition and housekeeping throughout 14 the plant and the Licensee's policies 15 and procedures regarding housekeeping, 16 tool control and equipment and material 17 control as implemented were a strength."

18 MR. REPKA: I have no further questions 19 on this group of documents. I'll 20 stipulate to the admissibility of MFP 21 Exhibit 105, 106, 107, 108, 109, 110, 22 and 111, and 113, and I'll move into 23 evidence the docu.nents I've identified 24 as PGLE Exhibits 25 and 26.

25 MS. ZAMEK: No objection.

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1 JUDGE BECHHOEFER: I'm assuming you're moving in i f-2 the MFP exhibits that --

1 4

3 MS. ZAMEK: That he just mentioned.

i i 4 JUDGE BECHHOEFER: -- Mr. Repka stipulated to?

i 5 MS. ZAMEK: That's correct, although I still have 6 some questions.

j 7 JUDGE BECHHOEFER: Oh, yes. We do, too. Those ,

I I 8 documents will be admitted into evidence. l 9 [PG&E Exhibit Nos. 25 and

10 26 were received in

) 11 evidence.]

12 JUDGE BECHHOEFER: I'm including both the MFP and 2

13 the PG&E documents. Does PG&E -- the MFP documents that are 14 Staff documents, I guess we probably should wait. Let's see  !

15 which ones those are for the benefit of the reporter.

16 MS. ZAMEK: 106 is a staff document, and 107 and 17 108 and 105. i l'

18 JUDGE BECHHOEFER: So 105, 6, 7 and 87 l l

l 19 MS. ZAMEK: Yes.

20 JUDGE BECHHOEFER: Okay. Those documents, I 21 guess, are not admitted at this time. You can change that, 22 if there is no objection, and when these Staff witnesses 23 identify them as Staff Inspection Reports, I'm sure it'll 24 follow that they will be admitted then, but, as of the 25 moment, they're not.

i ,

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Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 1

1519

- 1 [MFP Exhibit Nos. 109-111 l

2 and 113 were received in 3 evidence.] i l

4 QUESTIONS BY THE JUDGES j 5 JUDGE BECHHOEFER: Before we get into further 1

6 questions, I just have a personal clarification question, l l

i 7 which stems from PG&E Exhibit 26. Was there any -- and any I

8 individual may answer this, but was there any point in time l

9 when cleanliness controls were discontinued so that none In existed?  ;

11 MR. CROCKETT: I'm not sure I understand your j 12 question.

13 JUDGE BECHHOEFER: Well, my question arises, if 14 you turn to page 1 of the enclosure in PG&E Exhibit 26, 15 where, under " Reason for the violation," it says, 16 "Immediate corrective actions were to 17 reestablish cleanliness controls."

18 I just wondered what that meant. Does that mean 19 you didn't have any at some point in time? This I didn't 20 understand from the other testimony. i 21 MR. CROCKETT: No. I don't think that's -- I 22 think -- I think this is referring to controls on top of the 1

'. 3 reactor vessel head. j 24 MR. GIFFIN: If I remember from the nonconformance 25 report, the foreign material axclusion was removed while the

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Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

i 1520 1 work that this is discussing was in progress. When it was 7-s 2 identified, then it was reestablished, and that's what this 3 is.

4 JUDGE BECHHOEFER: I see. Well, isn't the 5 guideline or the control an overall-type of program that you 6 don't remove or put on? Isn't it always applicable? If a 7 particular action false within the program, then it's 8 covered. Isn't it a continuing program?

9 MR. CROCKETT: Oh, certainly. It's a continuing 10 program.

l

! 11 JUDGE BECHHOEFER: So that was why I raised the 12 question about the word " reestablish." Should it ever have 13 been disestablished?

N 14 MR. CROCKETT: No. It should never have been 15 disestablished.

l 16 MR. GIFFIN: I guess I'm -- I think that this is 17 talking about one specific event where they had foreign 18 material exclusion in place, and then it was inadvertently 19 removed while the job was still in progress, and then, when 20 it was realized that the exclusion area was removed, it was 21 reestablished, and that's why -- that's what this Notice of 22 Violation addresses respect that specific instance, not that 23 we had a program in place and then stopped it for a while 24 and then reinstituted the program.

25 This is one moment in time for one particular i

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1521 l

1 task, and they should have continued it, but they didn't, i 1

~

2 and that's -- that's what this is talking about. This 3 Notice of Violation is discussing that event.

4 4 JUDGE BECHHOEFER: Well, should that have been 5 more a reference to not the controls but the implementing  !

l 6 activities? Because, as I say, if it's an overall guideline r

7 or rule or probably not a tech spec, but I don't think it 8 would be -- I don't think it gets removed and put on again.

! 9 MR. GIFFIN: It wasn't done on -- it was error.

10 It should have been left in p.' ace, and then the barrier was i 11 removed, and then that's why this Notice of Violation 12 occurs, because that particular job inadvertently removed 13 the foreign material exclusion and then reinstalled it, I 14 believe. I'll have to check.

15 MR. REPKA: Mr. Giffin, it might help if you can l l

l 16 tell me, when you're talking about a specific job and you l i

17 say a control or a barrier, what do you mean? 1 18 MR. GIFFIN: If you are doing a job that you want 19 to establish foreign material exclusion, then you'll 4

20 establish barriers. The procedure says go into this area.

21 You must log in tools and equipment. You must have things 22 that can fall off -- out of your pocket or something, or 23 hard hats or glasses must be tied, secured so that, if you 24 bend over, the material doesn't -- you know, as you bend 25 over, you don't drop your glasses into the pool, and that's ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

l I

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1522 ,

I 1 what I mean by the controls that are in place for foreign

]

- 2 material inclusion.

3 The way I read this is that we had those controls 4 in place for this task, and then they were removed. They 5 stopped requiring them, and they should have -- they 6 shouldn't have done that.

7 JUDGE BECHHOEFER: So that was contrary to your 8 overall --

9 MR. GIFFIN: Oh, yes.

1 10 JUDGE BECHHOEFER: -- rule or guideline, whatever 11 it is. Okay. That's the end of my inquiry. We can go 12 back.

13 CROSS EXAMINATION

-, 14 BY MS. ZAMEK:

15 Q Mr. Dillard yesterday was quite impressed with the I

16 cleanliness of the plant, but isn't it true that all these 17 documents here show a similar problem with a lack of 1 18 cleanliness, debris left here and there and controls out of 19 place.

20 A (Witness Crockett) No, I wouldn't say that.

21 Q They don't -- l

)

22 A No. I'm saying they deal with -- I think you were ,

l 23 trying to say generally that cleanliness of a plant is not 24 good, and I --

25 Q I didn't say that. I said do they all deal with ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

l l 1523 l

1 the cleanliness issue? Whether it's called housekeeping or 2 whether it's called foreign material control, is it all l 3 dealing with the control of materials to keep the place i

l 4 clean?

l l 5 A I think it's your use of the word " cleanliness."

l l 6 This is more to deal with control of unattended materials l

l 7 that are inside cantainment or in FMEA boundary areas.

8 Q Would you say that this issue has some potential {

( 9 safety significance?

10 A I'd say the issue, back in the RHR sump, if you  !

l 11 read the exhibits, I think the safety analysis shows on )

i 12 those that they are very low safety significance, in some  !

i l 13 cases, none. The enforcement action really dealt with more 3 i

14 of our administrative and procedural requirements and not j 15 the safety significance.

16 In fac,t, the RHR samp was capable and functional 17 of performing its intended function. Materials outside the 18 RHR sump, due to the nature of those materials, their weight 19 and where they were located, that'even during a LOCA that 20 many of those -- those articles could not be carried away.

21 The flow velocity of the water to the sump in 22 containment is slow enough to where it wouldn't make it to 23 the _ amp, and even if they did make it to the sump, the sump 24 is a hardened, screen-protected sump that would ha're 25 prevented-that debris from going into the sump.

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Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 l - - - - - . - .

L l i

1524 l l

1 The sump is also located in the annulus area in 2 the bottom of containment, which is -- which is very t f

3 advantageous, because the high density -- I mean high energy 4 lines are inside a wall called a missile barrier.  !

5 So, I mean, the access, the potential for getting j i

6 debris into the sump is very, very small, and, like I said, 7 the nature and amount of materials that were in containment  !

l 8 were not enough to have prevented the RHR from performing  ;

9 its intended function. So, the safety' significance was very ,

I 10 low.

11 QUESTIONS BY THE JUDGES l l

12 JUDGE P.MCHHOEFER: Was the latter point $

13 fortuitous?- I mean -- l l

14 MR. CROCKETT: Paroon me?

O

)

15 JUDGE BECHHOEFER: Is the latter point, sort of,  !

i 16 fortuitous? l l

17 MR. CROCKETT: You mean where the sump is? No, l 18 it's by design.

19 JUDGE BECHHOEFER: If the person or whoever had 20 violated the loose materials had left more there --

21 MR. CROCKETT: You're saying the amount?.

l 22 JUDGE BECHHOEFEI: i-.'!

23 MR. CROCKETT: Yoa H + 3 1.19 the amount of 24 material.

25 JUDGE . BECHHOEFER: Yeah. Isn't that just-i ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1612 K Street, N.W., Suite 300 l l

Washington, D.C. 200c4 l

l. (202) 293-3950 i L

1 1525 1 fortuitous, if a person has --

2 MR. CROCKETT: No, absolutely not. I -- you know, 3 mode, that's when we establish containment integrity, and 4 there is exhaustive efforts to control that material, to 5 keep it down to a minimum and to control it. I mean, it's 6 an hourly, minute-by-minute attempt to control the amount.

7 So we minimize that. So it wasn't just by luck 8 there was only --

9 JUDGE BECHHOEFER: But it doesn't depend on the 10 amount of food the person was going to have for lunch that 11 day or whatever, soft drinks?

12 JUDGE SHON: Just to put it in perspective, 13 Mr. Crockett, we say if the person had brought in more. ,

14 Just magnitude, the kind of thing it would take to plug the l

15 RHR recirc sump, could a person take it in and leave it

, i 16 there? l 17 MR. CROCKETT: No. Well, first of all, you know, I l

18 the kind of things that people take in is not their lunch l 19 bag. You don't eat inside containment. The things you take 20 inside there is a procedure. You take in your toole and 21 yourself.

22 MR. GIFFIN: When we go from after an outage --

l 23 during an outage, there's a lot of material that's kept and 24 a lot of activities that go on in containment. When we get 25 ready to change modes at the end of the outage, then a big l

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Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 l

l 1526 1 effort is done to remove all of those things out of 1

l O 2 containment. I i

3 Then, there's a walk-down by our quality control i i 4 organization. There's walk-downs by our RPs and maintenance I

5 and ops, going through all the little places inside 6 containment to assure that there are no -- there is no 7 debris left. ,

I Then, every once in a while, after we have  ;

i 8 9 finisned that, when we continue to walk down to make sure ]

10 that the equipment in containment is in great condition, we 11 find something that we might have to go back in and do, a j i

12 precedure. I 13 So when the mechanic and an operator and the RP l 14 tech go in, they take the procedures, the work package and  ;

l 15 the tools that are necessary to perform that function, and i 16 then, in the case -- some of the cases watere things were 17 left in containment, they exited containment and went back 1

l 18 in.

19 So the issue was, while they weren't there, this 20 material was left unattended. What they should have done is 21 take it out with them or leave someone there, but the other 22 question is that that's the type of material that's taken 23 into a containment, not food wrappers. You can't eat in 24 there. You can't smoke in there. You can't chew gum in 25 there.

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l 1527 l l

1 So the only things that are taken into that space 2 are those things that you need to perform the task that 3 you're going in for. So it's -- so, in order to block the 4 sump, that wouldn't be what you would expect during that 5 maintenance procedure. It would be during large maintenance 6 activities, which are done on the sump's not needed.

7 JUDGE BECHHOEFER: In the latter situation, can 8 more or different types of material be brought in?

9 MR. GIFFIN: Oh, yes, sir. The sumps are required 10 in modes 4 and above. So, in modes 5 and 6, the sump has no 11 function. So, therefore, we perform activities that -- a 12 lot of work is going on in containment at that time.

13 We take in shielding and then, as we change uodes, 14 we remove those items from containment.

15 MR. CROCKETT: Let me add one more thing. Once we 16 establish containment integrity and prior to go into mode 4, 17 the jobs that are going to take place in containment while i 18 we're in mode 4 and mode 3 are evaluated by our on-site 19 engineering group to ensure that -- and they look at the job I

20 that's being done, the process, and they're, kind of, an '

21 over-site group to ensure that material, the type that we 22 bring in and the way we stage it will prevent the sump from 23 being affected.

24 BY MS. ZAMEK: )

l l

25 Q Isn't it true that PG&E received a violation and a l ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006  !

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I 1528 l

l l 1 $50,000 civil penalty -- this is Exhibit 113 -- for failure

! t 2 to take -- this is page -- well, this is the Notification of l, 3 Significant Enforcement Action, near the end of-the t f

I I

4 document, ,

5 "for failure to take adequate corrective i l

6 actions for gaps'in the sumps, trash screens 7 just identified in 1985, opening sump access 8 hatches on a number of occasions for time 9 periods exceeding technical specification .

10 limits and the failure to do adequate 11 surveillance inspection resulting in l 12 operation with debris inside the sump 13 screens."

14 MR. REPKA: Ms. ZamEk, are you reading from 15 Exhibit 113? Is that your reference?

16 MS. ZAMEK: Yes.

17 MR. CROCKETT: That described -- that's described

[ 18 in our written testimony, but, you know, let me -- let me l

l 19 clarify the reason for the enforcement action was not i 20 because of the inability of the pump to pe.rform its intended 21 function.

l 22 BY MS. ZAMEK:

23 Q In Exhibit 110, on page 4, under " Safety i 24 Analysis," it says, 25 "The presence of a loose part in the

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Court Reporters 1612 K Street,-N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

l i

i 1529 1 primary coolant system can be indicative +

\ 2 of degraded reactor safety, resulting .!

3 from failure or weakening of the safety l 4 related component."  !

5 Would you agree with that. f 6 A (Witness Crockett) I'd agree that a loose part in 1

7 the -- in the fuel assembly can have potential. problems, but 8 let me say again, we haven't seen it. We've inspected our 9 fuel. We inspect it every outage. In fact, we have been ,

10 noted to have -- our fuel integrity is one of the.best in l

11 the U.S. i 12 One of the other things that we have-done for our 13 fuel is that we have what they call Vantage 5 fuel that we .

fst 14 put in recently, and one of the unique advantages of Vantage ,

Q 15 5 fuel assemblies is that it has the bottom nozzle acts aus a 16 screen to prevent even very small debris from going up'into 17 and affecting the fuel assemblies.

i 18 Q But, on page 3, doesn't it, in fact, say, 19 "The root cause is management failure to 20 implement the FMEA program as described 21 in applicable administrative procedures, 22 and, as a contributory cause, there's ,

23 also an overall lack of ownership for 24 the program."

25 A I've got to disagree with the root cause. I. agree

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Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

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l 4

1530 1 with the corrective actions of this NRC, but I disagree with l j 2 the root cause. As I stated earlier, we've had FMEA control 1 3 programs for PG&E and Diablo Canyon for a long time,'and the )

i 4 basic process is to protect equipment that you disassemble, l 5 protect it from foreign objects falling in it. ,

I 6 We take apart 12,000 horsepower motors and'6,000 I a

7 horsepower motors, lots of equipment, and we've had a good i 8 program. We had a good program before. We had a good 9 program now. I think any time that we can improve that_ i a l 10 understanding -- I think that was kind of the root cause in  ;

11 this thing is a lack of understanding, and I think the I i

12 corrective actions that came out of this NRC helped improve l

13 that understanding of.the program.

t 14 Q Okay. I'd like to bring-your attention to the i

O 15 same Exhibit 110, page 14, under " Previous Similar Events."

i

)

i l

! 16 I'd like to point out that the first previous event was i l

17 noted in 1986 and also note that this is a 1992 document.

18 Based on that, would you say that this is a long-standing 19 problem?

20 A (Witness Giffin) I think that what we'd like to 1

21 characterize it as, as Mr. Crockett said before, we do a~

l 22 tremendous amount -- number of activities. As he said, j 23 there will be times when a foreign material exclusionary is )

i 24 not established as we, management, would like it to be.

4 25 We continue to improve in the performance in this O- ANN RILEY.& ASSOCIATES, LTD.

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1531 1

1 area, but, as he said, there will be problems, and it showed l 73

\ )

2 in 1986 there was a problem. There probably will be l 3 problems in the future, but we're addressing it.

4 We're looking to assure that our program is set up 5 so that there is not damage to the fuel, that there's not 6 damage to equipment. It makes sense to implement a good 7 program, and that's what we are trying to do.

8 Q Is the debris that we discussed in ASW and CO2 and 9 the DFO trenches, do you recall is talking about that a few 10 days ago, the debris that was found and the standing water 11 that was created from the debris? Would you relate those 12 types of -- could you relate those types of activities, the 13 failure to remove debris and control material?

r^x) 14 A (Witness Giffin) The debris -- the trenches were

~

15 outside. The debris that we were talking about is called 16 dust and dirt and leaves --

17 Q And wood.

I 18 A a?.nd wood that's blown around and moved around. l 19 The debris that they're talking about in containment were 20 things that people took in and left. There's a difference.

21 The trenches were outside. You know, that's -- and what was 22 inside were those things needed to perform work. Outside it 23 was just what was blowing around in the wind.

24 MS. ZAMEK: I don't have any further questions.

25 MR. GIFFIN: I'd like to add one comment. The way 7-( )

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1532 i j 1 that it seemed when I first heard one of the questions was j 2 that there was a housekeeping issue, and it doubted what 3 Mr. Dillard said yesterday, but I think that the general 4 housekeeping for the plant is very, very good.

5 There have been several plants, both fossil and 6 nuclear, and the way that we keep the housekeeping at our i

-l 7 plant is very good. The NRC and that inspection report that l

8 was used as an exhibit, I believe it's 106 that Mr. Crockett l i

9 read from, also -- the NRC also said that the housekeeping 10 was good.

11 So, I think that -- I just wanted to add that I l

12 statement.

13 JUDGE BECHHOEFER: Does the Staff have any 14 questions?  ;

15 MS. HODGDON: No.

J 16 [ Pause.]

17 QUESTIONS BY THE JUDGES 18 JUDGE BECHHOEFER: I have one question, and I have 19 to -- let's see. Well, without tracing it through the ,

l 20 documents, when you get a housekeeping error, let's say Unit l 21 1 -- I'm just being arbitrary right now, but assuming you 22 find one in Unit 1 during an outage and you impose l

23 additional controls, would those controls also govern Unit 24 2? Because then I noticed later on you had Unit 2 problems.

25 Whether it was 1 or 2 or 2 or 1, I'm not sure, but O_ ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1612 K Street, N.W., Suite 300 l Washington, D.C. 20006 j (202) 293-3950 l

1533 1

1 I'm just wondering about the relationship between these 2 controls for one reactor where a problem may arise and the f 3 other reactor, which would be scheduled, say, for a shutdown 4 at a later -- a different date. Because I assume they're .

5 all shut down at different dates to the extent practicable.

6 MR. CROCKETT: Is your question, does the programs 7 and rules apply to both units?

8 JUDGE BECHHOEFER: Yeah. When you establish 9 controls for this type of thing, housekeeping controls, 10 would it apply for both as well?

11 MR. CROCKETT: Yes. We don't differentiate 12 between -- in these areas between the two units. Any 13 controls or administrative procedures put in place would l

14 definitely apply the same for both units.

l l

15 In fact, you know, we have often learned lessons l

16 while one unit's in an outage, and we may have an outage on 17 the next unit just a few months later. We are very diligent 18 in making sure that any corrective actions that we've 19 learned from experience on the first unit are -- that the i

! 20 changes are put in place prior to going into the outage.

21 The answer is yes, that the same programs apply to 22 both units. We don't differentiate.

l 23 MR. GIFFIN: And probably the reaeta that it goes 24 from Unit 1 to 2 or 2 to 1 is that the majority of the 25 activities that we perform would be during an outage period, O

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l 1534 i

~, 1 and because, you know, we have one outage then another,

\ 2 that's why it's a Unit 1 or Unit 2 or 2 and 1.

3 JUDGE BECHHOEFER: Now, referencing Exhibit 105, j l

4 the cover letter at this point, third paragraph down, where 5 they comment that corrective actions had not addressed this 6 weakness sufficiently or a sufficiently comprehensive 7 manner, this document represents, I believe, a different ,

8 unit than the previous one that was cited.

9 MR. CROCKETT: I'm sorry, a different what?

l 10 JUDGE BECHHOEFER: Different unit than tFa i l  !

11 previous one that was cited. That was the basis, really, l 12 for my question does one apply to the other. So I take it l 13 that any further strengthening as a result of the inspection g- 14 in Exhibit 105 would also be carried through to both units?

~'

15 MR. CROCKETT: That's correct. In fact, in that 16 same paragraph, in you read the second to the last sentence, 17 "Before the completion of the inspection, the l l

18 inspectors confirm that PG&E had initiated '

19 corrective actions which satisfactorily 20 addressed the concern." l l 21 So before the inspection was over, the NRC 22 inspectors confirmed that our corrective actions were --

1 23 addressed their concerns.

24 JUDGE BECHHOEFER: Right. I noticed that as well.

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i 1535 1 questions?

O' 2 MR. REPKA: No.

3 JUDGE BECHHOEFER: Okay. I guess we're ready to 4 go on to the next group. j 5 [ Pause.]

6 MS. CURRAN: Okay. We're going to pass over 7 Exhibit 114 for the moment. l 8 MS. HODGDON: May I ask a question? Isn't it the 9 same as 106?

10 MS. CURRAN: It is. That's right.  ;

11 MS. HODGDON: Oh, okay.

12 MS. CURRAN: We're going to -- not going to be I

13 offering Exhibit 115. So we'll move on to Exhibits 116 and fg 14 117. Exhibit 116 is NRC Summary of October 20, 1992, Public

\

\)

15 Meeting to Discuss Steam Generator Feed Water Nozzle  !

16 Cracking, dated November 23, 1992; and Exhibit 117 is LER 1-17 92-022-00, dated October 30, 1992.

18 On the road map, there's a reference to Event l 19 24304, and that's not included here.

20 DIRECT EXAMINATION 21 BY MR. REPKA:

22 Q Gentlemen, are you familiar with these documents? l 23 A (Witness Giffin) Not completely.

24 [ Pause.]

25 Q Okay, are you now familiar with these documents?

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l l l

i 1536 )

, l l 1 A (Witness Crockett) Yes, I am.

Q Isn't it true these documents both relate to the  ;

3 same issue?

4 A (Witness Crockett) That's correct.

! 5 Q And this is an issue identified by PG&E in a 6 voluntary LER?

7 A (Witness Crockett) That's correct.

8 Q And briefly, what was that issue?

9 A (Witness Crockett) Briefly, we had an engineer 10 who was at a refueling outage at Sequoia, another power 11 plant, and during that outage that plant had some problems 12 with a through-wall small leak in their feed water nozzles, 13 their pipe to nozzle welds. And he came back to our plant 14 and made recommendations to Mr. Giffin that we, in our 15 upcoming outage, that we perform a surveillance to see if we  ;

16 had any effect on our nozzle welds.

17 When we did that, we performed the inspection and 18 our first indications, I think it was -- and it was i

19 primarily due to the sensitivity of the instrument, it's a j 20 UT ultrasonic test probe that is designed for intergranular 21 stress corrosion cracking. It's a new technology and a very 22 sensitive instrument. And during our first inspections of l 23 those nozzles we found what we thought were indications of 24 cracks that in, I think in one situation, on one steam 25 generator weld that was beyond the code allowable crack.

O l

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t 1537

( 1 And in that outage we took actions, we cut that section of i

2 pipe out and reweld it and repaired the pipe and also sent 3 that section of pipe for metallurgical analysis to determine 4 the root cause.

5 But subsequent to that, well, we repaired the 6 pipe, but after the analysis we found out that the 7 indications were not at the depths that we originally l 8 thought. We thought they were like pretty much like-.37, 9 that was the worst one, .37 of an inch, a little over a l i

10 third of an inch. And in fact, after the analysis, they 11 really were a factor _of ten less, .035, in other words about ,

I 12 35 mils was the deepest crack that we had.- In fact it was j I

13 35 mils is a few sheets of paper. l 14 Q Okay, when you first identified this issue you 15 wrote a voluntary LER to the NCR?

16 A (Witness Crockett) That's correct.

17 Q And that's the document that's been identified as 18 MFP Exhibit 1177 19 A (Witness Crockett) That's correct.

20 Q And Exhibit 116, that reflects the fact that you 21 went to the NRC to brief them on the issue, does it not?

l 22 A (Witness Crockett) That's correct.

23 Q And this issue has also been addressed in your 24 direct testimony, hasn't it?

25 A (Witness Crockett) That's correct.

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i 4

1538 1 Q And would that be your testimony at pages 91 to j O 2 93?

l 3 A (Witness Crockett) That is also correct.

^

4 Q In that testimony you conclude that -- you say, 4

1

} 5 "In retrospect this is an excellent 6 example of the proper functioning of the 1

! 7 DCPP maintenance and surveillance 8 program, especially in assimilating i

9 industry experience and pro-actively j 10 initiating repairs even where existing

! 11 standards do not require such repairs."?

! 12 A (Witness Crockett) That's correct.  ;

13 Q Do you still agree with that?

l i

14 A (Witness Crockett) I still agree with that.

15 MR. REPKA: I have no further questions on these ,

N j 16 documents. )

i l i 17 CROSS EXAMINATION l I

! 18 BY MS. CURRAN:

l j 19 Q Mr. Crockett, how any nozzles are on a steam 20 generator,-these particular nozzles?

)

21 A (Witness Crockett) There's just one feed water 22 nozzle per steam generator.

l 23 Q On each steam generator?

24 A (Witness Crockett) On each steam generator.

25 0 .And where you found the cracking was -- the nozzle i

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1539 1 is the connector to the steam generator, right? The place 2 where the --

3 A (Witness Crockett) That's where the feed water 4 piping connects up to --

5 Q -- is welded to the steam generator?

6 A (Witness Crockett) It's welded to the steam 7 generator.

8 Q And you found cracking in the nozzle and in the 9 feed water pipe as well?

10 A (Witness Crockett) No. Let me say again, the 11 cracking that we found, the deepest one was 37 mils.

12 Q Uh-huh.

i 13 A (Witness Crockett) We found that in the weld 14 area, that's the pipe to nozzle weld area.

%,) i 15 Q Oh, so it's where the pipe meets the nozzle? i 16 A (Witness Crockett) That's correct.

i l

17 Q Okay.

l 18 A (Witness Crockett) And, as I said, you know, the l 19 cracking, we're talking micro cracking, 37 mils.

20 Q Uh-huh.

21 A (Witness Crockett) And I might add, we inspected 22 not just that weld, we went upstream and we went into the 1

23 nozzle itself and we saw no cracking inside the nozzle area.

24 Q So, upstream is away from the steam generator?

25 A (Witness Crockett) That's right, i l

l l

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i l 1540 l l l
1 Q Okay. .

l 2 A (Witness Crockett) And downstream of the weld. j i

d l l 3 Q Uh-huh. l

! I i 4 A (Witness Crockett) In the nozzle area, we  !

! 5 inspected that also and found a crack. l A \

l 6 Q Okay. And this problem wasn't something that you

! I t 7 had previously known about, was it? ~

l 8 A (Witness Crockett) No. Our tenure, our ASME ,

9 inspection process requires us to look at those nozzles'once  !

, 10 in ten years, every ten years we take a look at the nozzle.

11 And the next -- the following outage, we would have looked- l l

12 at that nozzle on our normal inspection program. )

i 13 Q Uh-huh. Would you say that with Westinghouse i ,

14 pressurized water reactors there are new issues coming up i

! I

] 15 all the time about aging of steam generators and steam i

j 16 generator parts? Or maybe I'll, I'll retract that. Would f 17 you say that there has been -- that in recent years new 18 issues have come up regarding the aging of steam generators 19 and steam generator parts in Westinghouse pressurized water l

20 reactors?

21 A (Witness Giffin) I'm not.sure if it's an aging 22 issue. There have been, over the years, things that are 23 being discovered in Westinghouse steam generators, depending 24 upon the model, that's correct.

25 Q Well, what do you think causes this cracking?

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1541 ,

! 1 A (Witness Giffin) Which cracking?

O 2 Q The cracking that was found in the welds? l i

i l 3 A (Witness Crockett) Well, first of all, you know, I  !

,- 4 when -- you have to put in perspective the depths of the

5 cracks. I mean we're_ talking about a two inch thick pipe, i

) 6 this is 37 mils, way below the code allowable. In fact, q 7 based on -- I'll explain, I'll answer your question here 8 right now, but the mechanism that.would propagate the crack, y i

9 had seven years worth, at least, before the crack would 10 propagate to beyond code.

11 The mechanism that made it, that created it is a 12 thermal fatigue cycling issue that's created when we're'in i 13 modes three and mode two we use aux speed water. That's 14 another, it's not main feed water, it's our low power level O' 15 hot shut-down source of feed water and it's cold' water. And 4 16 due to the cyclic flow of that. aux speed water to that 17 nozzle, it has a phenomena, it's a thermal fatigue factor 18 that creates and then propagates cracks. So, it's a 19 different issue than what you're -- than you're_ referring to 20 with the steam generators in general. It's this nozzle ,

21 area. l 22 Q Okay. And it's this phenomena, the cyclic change 23 in temperatures, that's something occurs over and over over 24 time, is that right?

25 A (Witness Crockett) During certain modes of the ANN RILEY & ASSOCIATES, LTD.

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l l

1542 1 plant.

2 Q That's right.

l 3 A (Witness Crockett) Just during certain modes.

4 Q And each time it occurs it puts additional stress 5 on the nozzle, is that right?

6 A (Witness Crockett) It's a gradual effect. If you l

7 look in the reports, based on that thermal fatigue factor l 8 that the conclusion was the integrity of the nozzles would l l

9 be maintained over the next several years. So, what I'm --

10 the point I'm trying to make is that there really wasn't a '

11 problem.

I 12 Q Uh-huh.

13 A (Witness Crockett) We inspected it, we thought it 14 was bigger because of the sensitivity of the instrument. We 15 went and replaced it, but in retrospect it was not a 1

16 problem.

17 Q And can you just explain a little bit, how you 18 inspect these pipes? Go through radiography and ultrasound j i

19 testing.

20 A (Witness Crockett) In the early stages of I 21 utilities, we're talking in the '70s, the accepted technique 22 was radiography. Now in the -- we have more modern 23 state-of-the-art techniques, ultver.onic testing is much more 24 conclusive in characterizing any flaws. And we use UT to 25 look at those welds.

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i 1543 j i

. 1 Q You say you think it's conclusive?

2 A (Witness Crockett) UT?

! 3 Q Uh-huh.

a 4 A (Witness Crockett) Yeah, it's more sensitive, it

] 5 helps more characterize the shape and the depth of the ,

l 6 crack. Whereas in radiography you have to be exactly right j

. 7 over a crack.

8 Q With ultrasound you put a probe inside the pipe i

9 and --

10 A (Witness Crockett) No, you can do it externally; 11 you can do it externally and internally. I 12 Q Uh-huh. How did you do it in this case? Both?

13 A (Witness Crockett) I think it's external.

i 14 Q It's external, okay. So, you don't go inside the

>O 15 pipe. For one thing you can't see inside the pipe, right?

16 A (Witness Crockett) It's an enclosed pipe. l l

l 1 17 Q It's an enclosed pipe so you can't see what i 18 cracking there might be inside?

l 19 A (Witness Crockett) No , but the UT examination 20 looks at the -- it's the entire length. It doesn't look at 21 the surface for cracks, it looks over the entire thickness .

l 22 of the wall of a pipe. And it can see any internal cracks 23 or external.

24 Q Uh-huh.

25 A (Witness Giffin) But one thing else, you can also j l

i

(~

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j . __ _

1 l

1544 s 1 look inside the pipe. And you do that with a baroscope. J l I i 2 There's a, you know, there's places where you can put a i 3 small camera in. So, we did look inside the pipe for the
4 visual, but the non-destructive examination technique, that j 5 UT, then goes through the metal so'that you don't have to

)

4 6 open it. But we also went through a place in the pipe where l

l 7 we could stick a camera to look at it visually, as well.

2

8 Q Oh, there was one place where you could look at it  !

j  !

i 9 with a camera?

i  !

10 A (Witness Giffin) Yes, there's a place that has a  ;

i ~

i 11 cap. You can take the cap off and put in the' camera on a l l 1 12 long cable.  !

' 1) l 13 A (Witness Crockett) It's called a gamma plug. I l

i J e- 14 Q But that doesn't show you the entire area, does I i l

{ 15 it?

f 16 A (Witness Giffin) It shows what you want to look l

} 17 at. I mean the camera has about a, was is it,.20 or 40

18 foot, so, if you have-a specific area that you wish to look 19 then you just put the camera in and look at that area.

But j j 20 what is used to determine the acceptance of the pipe is not I i

I 21 the camera, it's the ultrasonic testing device.

! 22 Q These view graphs that are attached to the NRC i- 23 report,-Exhibit 116, to me they look like some kind of joint I 24 preparation of PG&E and NRC, is that true?

25 A- (Witness Crockett) These ---  !

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1

{

! 1545 l

7- 1 Q I thought I saw Mr. Crockett's name on one, you

( )

k/ 2 know, and now I can't find it.

3 A (Witness Crockett) Yeah, this is -- when we gave 4 a presentation to the NRC these were the overheads, these i 5 were the transparencies.

l 6 Q Okay. Oh, that you presented to the NCR, okay.

7 A (Witness Crockett) Yeah.

8 Q On, let's see --

9 A (Witness Crockett) Both in Walnut Creek and 10 Washington, D.C., Bethesda.

11 Q Let's see, on enclosure one, which starts the view

( 12 graphs, on the one, two, three, four, five, six, seven, 1 13 eight, on the ninth page there's a page that says, " Elbow (q

'~')

14 Examination Summary".

\

15 MR. REPKA: The pages do seem to be duplicated l

16 twice, but --

17 MS. CURRAN: They're duplicated?

I 18 MR. REPKA: Yeah. It looks like a printing error, r e-19 a personnel error.

20 MS. CURRAN: Oh, no, a personnel error.

21 BY MS. CURRAN:

22 Q Well, why don't I just try asking you about this 23 and if we need to -- it's pretty brief. I just want to ask 24 you what is the elbow?

25 A (Witness Crockett) Let's see if we can refer to k_,) ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

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.t j 1546  !

i' 1 one of these other drawings, I think if you just, if you l i

O 2 look like about the second page back, you see kind of a

3 cross-section of a pipe?

a i l 4 Q Uh-huh. f 5 A (Witness Crockett) I think it's like, just, on.

6 the second page.- l

' l 7 Q Oh, uh huh.  !

8 A (Witness Crockett) Okay?

9 Q Okay.

10 A (Witness Crockett) The nozzle is this 11 cross-section part. The pipe, when it makes that first t i

12 bend, that first bend in the pipe is called the elbow. j 13 Q Where is it, right there, okay.

14 A (Witness Crockett) Right there where it makes the

{

([) 15 first bend. There's a horizontal run of the pipe and then l 16 it makes a turn.

l 17 Q Okay. Well, I just want to ask you about, there's 18 one page on the view graph, well, of course, these are all 19 just little phrases with bullets and it says, 20 " Elbow examination summary",

21 and there's a bullet and it says, i l

22 " Access for prep / exam difficult."

23 What does that mean, can you tell me? And I'll give you a 24 copy of it, if you don't have it. I 25 A (Witness Crockett) I think that was referring-to l

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Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950  ;

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) 1547 l

1 4

_s 1 the physical access to the, to that well. l.

2 Q Was there any difficulty in doing the test on it?  !

3 A (Witness Crockett) No.

4 Q Okay. Now further down in here there's a page [

l j_ 5 that says, " nozzle / pipe crack and conclusions", and it says, [

l 4

6 " Observed crack in the unit - "  !

j 7 A (Witness Crockett) Wait a minute, I have to find l i

j 8 where -- J i

9 Q Well, why don't I just try asking you because you  ;

10 may be able to clear it up? (

i  !

11 A (Witness Crockett) Okay.

a 12 Q It says, [

j 13 " Observed cracking in Unit 1 i

i 14 significantly below code allowables." h 15 Is that before you -- is that what you concluded before you  !

i j 16 did the other test that you made think -- i 17 A (Witness Crockett) No, we -- when we looked at it I I

i .

18 with the first examination, with the first UT examination, 19 because of the sensitivity of it, it showed that the crap -- f i

20 the crack -- strike t hat.

21 [ Laughter.)

22 The crack depth was, I think in the worst case was .37 l

23 inches, and based on that one of those was beyond code and j 24 we cut the pipe out and replaced it.- Subsequent to that, a

25 when we had it analyzed in the lab, the crack depth was not' 4

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Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202)-293-3950

1548 1 that deep, it was a tenth --

2 Q Okay.

3 A (Witness Crockett) -- in fact it was a tenth I 4 less.

5 Q All right, I just wanted to clarify that. Now you 6 say somewhere here that you're planning to put sleeves 7 inside all of these pipes, inside the nozzles?

8 A (Witness Crockett) That's correct. i l

9 Q Okay. Are you at all concerned about the I

l 10 intersection of the sleeve, the edge of the sleeve and how 11 that may corrode because there's now this new surface --

12 A (Witness Crockett) Well, it isn't, yeah, it isn't 13 corrosion, it's --

14 Q Or is there a water --

15 A (Witness Crockett) -- an erosion -- yeah. Well, 16 you want me to answer the first question about --

17 Q Yeah.

l 18 A (Witness Crockett) -- the sleeve? When we 19 inspected Unit 1 the first time, as Bryant said, to have the 20 gamma plug, it's an access that you can get into the pipe l

21 and put a camera downstream into the pipe. And we had 1

22 noticed some, an erosion / corrosion effect on the leading

, 23 edge of the thermal sleeve. Thermal sleeve, if you want to l

24 look at the same picture, if you look at that second page, 25 thermal sleeve is a sleeve inside the nozzle and it protects O

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Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

i 1549-

) 1 the nozzle from temperature gradients. And the leading edge

+ ,

i 2 of that thermal sleeve, we identified it looked like it had 3 some erosion / corrosion effects, that is a flow induced.

4 It's not corrosion, it's erosion of the pipe. .j i

5 And we did an analysis of.it -- l j 6 Q I'm sorry, what did you say? It's.not a what-7 effect?  ;

A (Witness Crockett) It's not an eros -- it8s not'a 8

9 corrosion effect, it's an erosion effect.

10 Q Could you explain the difference?

11 A (Witness Crockett) Well, corrosion, in terms of 12 galvanic corrosion, it wasn't a galvanic corrosion-like 1 -!

13 rust, it's not rust. It was flow induced erosion.

I -

14 Q The water wears the metal away?

l 15 A (Witness Crockett) That's right.

16 Q Okay.  !

17 A (Witness Crockett) On the leading edge we saw '

18 some evidence of that. We did an analysis that said that j 19 the thermal sleeve was still protecting the nozzle and we l 20 established a plan to replace that thermal sleeve and put a I- 21 more improved design. In fact, it's connected a little bit i 22 different so that there wouldn't be anymore erosion, 23 _ potential erosion.

4 24 Q How long do you expect those thermal sleeves to 25 last?

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1550 i 7, 1 A (Witness Crockett) The ones that are in there?

\' Uh-huh.

2 Q 3 A (Witness Crockett) We found the same thing on l 4 unit two, to a smaller extent. But at least the analysis, f

! 5 as a minimum, said they would last another cycle. So, this

6 coming refueling outage on Unit 1 we're going to replace 7 those thermal sleeves.

8 [ Pause.]

9 MS. CURRAN: I don't have anymore questions on 10 this.

11 JUDGE BECHHOEFER: Staff?

12 MS. HODGDON: No, no questions.

13 QUESTIONS BY THE JUDGES ,

14 JUDGE BECHHOEFER: I would just like to pose what

, 15 I would call maybe a worst case hypothetical. I believe, l

16 Mr. Crockett testified that it would be another seven years, l  ;

17 is that correct, before the code allowables would be 18 exceeded? I want to make sure I understood your testimony

19 correctly.

I 20 MR. CROCKETT: That's correct.

21 JUDGE BECHHOEFER: Maybe it wasn't you, maybe it 22 was somabody else.

23 MR. CROCKETT: It's in the document also. It says 24 there's -- I have to correct myself. It isn't -- it says, 25 next soveral years, but I think specifically it says --

1

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1551 1 JUDGE BECHHOEFER: I thought someone had commented 2 that --

f 3 MR. CROCKETT: It said four years --

4 JUDGE BECHHOEFER: Pardon?

5 MR. CROCKETT: It says several years, and  ;

6 specifically it says four years.

7 JUDGE BECHHOEFER: Right. I see. Now I take it 8 that the next required inspection would have been within 9 four years't 10 MR. CROCKETT: It was the next refueling outage.

11 JUDGE BECdHOEFER: Yeah. But I would say that is 12 within four years. Now if you start at the beginning, 13 however, say you replace it, and some -- there vas testimony -

14 that this would be looked at only once every ten years. Now I? maybe I'm misunderstanding something, but as a worst case, 15 could not the same circumstances arise again and escape 17 detection prior to the time when they could have -- when 18 they would exceed the code allowables?

19 MR. CROCKETT: The way the ASME code is set up, 20 it's over the 40 year lifetime of the plant, there are some 21 wells, and every -- it's really split up into four 22 intervals, four ten year intervals, and the interval for 23 this particular well was, that we had to test it in that 24 first ten year interval. The growth of the cracks are slow 25 enough, or the growth of the effect, or the cause and effect ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

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l 1552 l

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l .

1 is so slow that the code, ASME, allows us to only inspect it l l

! 2 once every ten years. So, we've already had, we are at the  :

3 end of this interval and that inspection was coming do.

4 JUDGE BECHHOEFER: Right. Assuming that 5 everything gets replaced then, and if it's possible to 6 exceed -- four to five years, maybe I'm misunderstanding t

7 something, before the next inspection, could not the code  !

8 allowables be exceeded?

9 MR. GIFFIN: No. And the reason is, if you'd look ,

10 at the Exhibit marked 117, it says that,  !

11 "We have conservatively decided to  :

12 perform NDE during each refueling outage 13 on the MFW, which 1:1 main feed water l 14 piping, adjacent to and including the O 15 steam generator, feed water. pipe to 16 nozzle welds." .

l 17 So, we've conservatively decided to continue to look at that I

18 and make sure that it could not happen again.

19 JUDGE BECHHOEFER: So, it wouldn't go another ten 20 years?

21 MR. GIFFIN: No, sir,'it would be looked at each 22 18 --

l 23 JUDGE BECHHOEFER: Oh, I understand.

24 MR. GIFFIN: Each 18 months we have our normal 25 refueling outage.

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l 1553 1 JUDGE BECHHOEFER: Right, correct.

2 MR. GIFFIN: So, each 18 months we will look at 3 these wells.

4 JUDGE BECHHOEFER: But absent something like this 5 you would only go back every ten years, presumably, during a 6 refueling outage. So, this really supersedes the ten year i

7 criteria for your facility?

8 MR. GIFFIN: Correct. But it's an example how 9 that we don't only look at just what happens at Diablo 10 Canyon, we try to look at what's occurring in the industry-11 and then bring that experience back. So, if another unit 12 was doing their 40 year or their,_you kno7, ten _ year, ten 13 year inspections and they saw a problem that they thought j i

14 was worthy of note, then the industry shares that )

O 15 information, then you determine whether maybe you want to 16 change your program as well. So, it's not -- we're not just 17 in this little island by ourselves.

18 JUDGE BECHHOEFER: And if your engineer happened 19 not to have gone to Sequoia, I guess you said, or --

20 MR. GIFFIN: It was Sequoia.

21 JUDGE BECHHOEFER: Yeah, if happened not to have 22 gone there, you still, by the time you inspected your's l 23 would not have gone below the code allowable, above or 24 below, however you look at it?

l 25 MR. GIFFIN: We would not have exceeded it, yes, l

i ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950-  !

1554 1 sir.

2 JUDGE BECHHOEFER: Exceeded it, that's correct.

3 MR. GIFFIN: That's correct.

4 JUDGE BECHHOEFER: Right.

5 BY MS. CURRAN:

6 Q So, you would not have exceeded it because you i

7 were going to be examining it at the refueling outage? j j

8 A (Witness Giffin) Well, the next refueling outage i

j 9 it was scheduled. We inspected the piping one outage early  !

10 because of what my engineer saw at Sequoia.  !

11 Q Right. l l

12 A (Witness Giffin) So, if he hadn't of gone, which  !

13 he did, so, it's kind of hypothetical, if he hadn't have. l 14 gone we still would have found out when we inspected it in  ;

l

! 15 18 months. So, that the way that the code was established, j 16 the inspection frequency would have caught it.  ;

I  !

! 17 *Q Assuming that the rate of propagation of the crack l 18 was constant over time, is that what you're saying? i i

19 A (Witness Giffin) . Based upon the analysis that l

20 were performed, yes.

21 Q I have a follow-up question. I'm a little bit 22 confused about the sleeve issue. You were planning'to put 23 sleeves into these nozzles at the next refueling outage, 24 right?

l .25 A (Witness Crockett) That's correct.

i ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 l

1555 1 Q Okay. It says, at the top of page 93, 2 "To minimize future potential problems l

3 in this area a design change is being l

i 4 developed to install a thermal sleeve 5 device inside the pipe and nozzle 6 connection."

7 Is that the same sleeve you were talking about?

8 A (Witness Crockett) That's the same sleeve, yeah.

9 Q But it sounds like you don't have the design 10 developed yet, is that right?

11 A (Witness Crockett) The design is developed.

12 Q It is, okay.

13 A (Witness Giffin) And it's really immaterial 14 whether the design is developed or not, we said that we're 15 going to put in new sleeves and there are several different 16 design options. There's several ways that you can go to do 17 it. So, that we are going to install one of them, and right 18 now I'm not sure which of the designs or which of the types 19 of thermal sleeves will be installed.

20 Q Okay.

21 [ Pause.]

22 MS. CURRAN: I don't have any other questions. We 23 -- if the Board has no more questions, we'd move Exhibits 24 116 and 117 into evidence.

25 [ Judges confer.]

k ANN RILEY & ASSOCIATES, LTD.

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1556 1 And we will provide corrected copies of the view graphs to 2 everyone if there's a problem.

3 MR. REPKA: That's not really necessary.

4 JUDGE BECHHOEFER: Yeah, the Board has no further l j

5 questions. So, I --

6 MR. REPKA: One follow-up question real quick? i i

7 JUDGE BECHHOEFER: Oh, sure, I'm sorry.

8 REDIRECT EXAMINATION' l l

9 BY MR. REPKA.  ;

I 10 Q Gentlemen, when you presented your analysis of  !

11 this issue-to the NRC did they conclude that it was 12 reasonable?

13 A (Witness Crockett) That's correct. j l

14 MR. REPKA: I have no further questions'and I have l

O 15 no objection to these documents.  !

i 16 MS. HODGDON: No objection, no questions. l l

17 JUDGE BECHHOEFER: We'll withhold ruling on the I 18 Staff --

19 MS. c.6RRAN: Oh, yeah.

20 JUDGE BECHHOEFER: -- document, but 117 is 21 admitted at this time, 116 we'll hold for later.:

22 [MFP Exhibit 117 was 23 received in evidence.]

24 MS. CURRAN: I don't know if we need to deal with l

l 25 this, but the view graphs that are attached to 117 are not ANN RILEY & ASSOCIATES, LTD.

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-(202).293-3950 l

l 1557 1 the NCR's.

2 JUDGE BECHHOEFER: I think the NRC could affirm 3 that those were' attached to its --

4 MS. CURRAN: Okay. j 5 MR. REPKA: I think that's clear on the-face of  !

6 the exhibit because it's a cover letter transmitting-the ,

7 view graphs from the meeting. i 1

1 8 MS. CURRAN: Okay. j 9 MR. REPKA: So, I don't think that's an issue.  !

10 JUDGE BECHHOEFER: I think the most important 11 thing is we're not going to require you to set up a slide  !

12 projector, let us look directly.

13 MS. CURRAN: Okay.  :

14 JUDGE BECHHOEFER: 117 is admitted. Why don't we f O 15 take a fairly short break before-we get into the next one.

i 16 Let's try to take a ten minute break, we don't have an awful t

i 17 lot of time. j 18 [A brief recess from 10:40 a.m. to 10:55 a.m.] )

I 1 19 JUDGE BECHHOEFER: We're back on the record.

I 20 JUDGE BECHHOEFER: Ms. Curran, are you ready?

21 MS. CURRAN: Yes. Okay. All right. The next ,

1 22 category is procedural controls during shop cleaning l 23 operations, and the Exhibit is 118 NCR NOV and NRC 24 Inspection Report 92-26, dated November 13, 1992.

l 25 [ Pause.]

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Court Reporters 1612'K Street, N.W., Suite 300 j

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l 1558

, 1 MR. REPKA: Whenever you're ready, gentlemen, just l

(~')

\>

I 2 give me a signal.

3 [ Pause.]

4 DIRECT EXAMINATIION I 5 BY MR. REPKA:

6 Q Okay. This document that's been identified as MFP 7 Exhibit 118 appears to be an NRC Inspection Report?

i

! 8 A (Witness Giffin) That's correct. l l

l l 9 Q And do you know what the focus of that inspection l 1

j 10 was? And let me direct your attention to -- wel_, it's l

11 Bates page 119363, the summary, " Areas Inspected."

12 A Yes, j i

13 Q It states, l 14 "As a routine inspection of occupational i' l

15 exposure controls"?

i 16 A Yes.

17 Q What did the NRC state about occupation l 18 radiological controls in general, based on this inspection?

19 A This inspection report, the cover sheet --

20 Q Well, let me direct your attention to the results I

21 page on that same page, the results paragraph. It says, l 22 "The overall degree of radiological 23 controls in place to safely perform l 1

24 major outage tasks was exemplary"?

l 25 A That's the same that's on the cover sheet.

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l 1612 K Street, N.W., Suite 300 ,

Washington, D.C. 20006 l (202) 293-3950 I i

1559 1 Q Oh, okay.

2 A In both places. The NRC -- this is a routine 3 radiological inspection, which occurred during two weeks l l 4 during our outage, and on the first page and also on the 5 summary page it says that, 6 "Your overall control of radiological 7 hazards encountered during steam i

8 generator work in Unit 1 outage appears i

9 exemplary."

10 However, they were concerned about one incident 11 which came up, and that's where --  ;

12 Q That was the one violation cited regarding i l

13 radiological controls during a shot peening operation?

l 14 A That's correct.

l 15 Q Now, did that violation affect in any way the 16 maintenance and surveillance of that equipment?

17 A No, it did not. It was -- it was how some of the 18 equipment was blowing air through the generator, but it 19 didn't have anything to do with the shot peening or the eddy i

20 current examinations that were in progress.

21 Q So this doesn't reflect on the success of the shot

{

22 peening in any way?

23 A No, it does not.

24 Q During the last break, I identified and passed out i

25 to all, a document which I've marked as PG&E Exhibit 22. Do l l

l l

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Court Reporters 1612 K Street, N.W., Suite 300 i Washington, D.C. 20006 (202) 293-3950 l l

l

1560 1 you have that in front of you, Mr. Giffin?

O 2 A Yes, I do.

3 Q That's a document that is a December 14, 1992, j 4 letter from Gregory M. Rueger of PG&E to the USNCR, PG&E 5 Letter Number DCL 92-275. Does this document represent ,

I 6 PG&E's response to this one violation? l 7 A Yes. .It's a reply to the Notice of Violation. I l

8 Q Okay. And it included corrective actions?  !

9 A Yes, it does. i 1

10 Q Now, during the next outage following the one j i

11 where this violation occurred, did you do any shot peening?  !

l 12 A Yes. Shot peening was we're going to.do -- we did I

13 it twice, once on Unit 1, once on Unit 2. The first time i

14 that we had the problem that was in the Notice of Violation, 15 the corrective actions that we put in place after Unit l's l i

16 outage were implemented successfully in Unit 2's outage, and 17 we will not do this evolution again. i l

18 Q Okay. And that was a -- l 19 A One time for each unit. f 20 Q Okay. .And during the second execution of this 21 evolution, you didn't have anymore of these radiological ,

l 22 controls problems?

i 23 A No, I did not. i 24 MR. REPKA: I have ao further questions. i 25 MS. CURRAN: Okay. j O ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1612 K. Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950- ,

I i

1561 1 CROSS EXAMINATION 2 BY MS. CURRAN: l 3 Q On page 9 of the inspection report, it refers to 1

4 three incidents that happened during this shot peening .

i 5 operation, doesn't it?

6 A That's correct, it does.

7 Q And after the first two incidents, according to f 8 PG&E Exhibit 22, which.we've just been provided, on page 3, i

l 9 you took some corrective actions, didn't you? )

! i 10 A Yes, we did. i 11 Q Okay.

12 A And we also go on to say if we had done what we 13 wanted, after the first incident, the corrective actions we  ;

i 14 put in place was adequate, if the people had followed the 15 procedures that we gave them. After the second time, we i l

16 changed. We added more corrective actions, but if they had j 17 followed the procedures, we would not have had the other 18 incident.

19 Q .So you made some changes after the first 20 incident --

21 A Yes, we did.

22 Q The next day there was another incident, and you made some more corrective actions? I 23 24 A Yes, we did.

25 Q And then a third incident happened on October 2nd?  !

l N ANN RILEY & ASSOCIATES, LTD.

Court Reporters i 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

1562 l i

1 A Yes, it did. At that point -- i O 2 Q And the problem was that the people carrying out i

3 the operation didn't follow directions? ,

4 A I'm not sure if they didn't follow directions. l t

5 There was two groups performing work. One group was doing ,

6 sludge -- or eddy current inspections, and one was 7 performing the shot peening, and that was, sort of, an 8 interface problem that occurred between the two groups where l

9 they weren't talking to each'other. j 10 So, after the third time, we stopped, got {

11 everybody together and said, "Okay. This particular- l 12 supervisor is responsible for this evolution, and let's 13 finish it with no further incident."

14 Q And is it true that after the second -- during the O 15 second incident, several workers received up-takes of l

?

i 16 radiation? That's also on page 9 of the --  !

17 A That's on page 9, and it says, 'I

! 18 "Several workers received up-takes from this l

l 19 incident. The highest up-take was l

20 approximately 15 MPC hours. Containment was i

21 at a negative pressure relative to the 22 outside atmosphere, and no release occurred 23 to the outside atmosphere."

24 MS. CURRAN: That's all the questions I have.

25 If there's no other questions, we --  ;

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1 1 JUDGE BECHHOEFER: Does the Staff-have any?

2 MS. HODGDON: No questions.

3 MS. CURRAN: Does the Board have any questions?

l 4 JUDGE BECHHOEFER: No, we don't.

i'

) 5 MS. CURRAN: If there are none, we move Exhibit f .

6 118 into evidence.

7 MR. REPKA: I will not object but I'll point out

?

8 that the witnesses have testified that this violation has no j 9 bearing on the maintenance and surveillance of equipment, l

10 and, number two, the contention on radiological protections 11 for occupational exposures was ruled inadmissible.

9 12 So the relevance to this particular Contention 1 <

13 appears to be have from nonexistent to tenuous, but.I don't 4

i 14 object.

15 MS. CURRAN: Well, maybe I need to get some

, 16 clarification as to whether shot peening constitutes 1

17 maintenance work.

i 18 MS. CURRAN: Wasn't maintenance work performed on 19 the steam generators? And maybe Mr. Giffin can clarify that 20 for us.

, 21 MR. REPKA: I think he stated that it was during a

22 shot peening activity, but it was --

i

, 23 JUDGE BECHHOEFER: I think the question is, is i

24 shot peening a maintenance activity?

25 MS. HODGDON: Judge Bechhoefer, I thought that the 4

i

~

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j. ' Washington, D.C. 20006 (202) 293-3950 gw' e M - -

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i 1564 1 answer -- the Staff said they had no questions. The Staff 2 didn't say that they didn't object to the introduction of 3 this document. This is a Staff document and should not --

4 JUDGE BECHHOEFER: No, no, no. We realize that.

5 MS. HODGDON: Oh, okay.

6 MS. CURRAN: Oh, that was my mistake. I'm sorry.

7 Yeah.

8 MS. HODGDON: We have an agreement that they'll 9 come in through the Staff.

10 MS. CURRAN: Yeah.

11 MS. HODGDON: So I don't know what the argument is 12 about.

13 MS. CURRAN: Yeah.

14 MR. REPKA: Actually, I don't think there is an 15 argument, because I didn't object to the document. I --

16 JUDGE BECHHOEFER: Well, I think the witnesses l 17 ought to at least state whether they believe that shot i

18 peening is a maintenance-type activity or operation.

19 MR. GIFFIN: I believe that the performance of 20 shot peening was a maintenance activity. I contracted it.

21 I had someone do it to resolve an issue, and so it's a 22 maintenance activity.

23 I would also like to clarify one thing. On the 24 inspection report, in the same paragraph, where it says, 25 "Several workers received up-takes.

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Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

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l 1565 :

i 1 Highest up-take was 15 MPC,"

+ l

\

2 In order for 15 MPC -- the Maximum Permissible j 3 Concentration, depending upon what the nucleate is, an l

4 individual can work in that environment for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> prior i

5 to any limits exceeded. So this is 15 of 40, so there were 6 no limits exceeded. We don't like to have up-takes, but 7 there were no limits exceeded.

i 8 [ Judges confer.]

9 MS. CURRAN: Shall we go on. l 10 JUDGE BECHHOEFER: Okay. Does PG&E wish to move 11 in --

12 MR. REPKA: Yes.

l 13 MS. CURRAN: Oh. 1 (O

-) 14 JUDGE BECHHOEFER: We'll hold the other.

15 MS. CURRAN: Okay.

16 JUDGE BECHHOEFER: We'll rule on the other, but I 17 think at this point, if PG&E wishes that document in --

18 MR. REPKA: Yes. We'll move into evidence PG&E 19 Exhibit 22. That's the December 14, 1992, letter from PG&E 20 to the NCR.

21 JUDGE BECHHOEFER: Any objection to that?

22 MS. CURRAN: No.

23 THE COURT: So at this point PG&E Exhibit 22 will be 24 accepted into evidence. We'll withhold on the other until 25 the Staff witnesses get here.

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1566 .

I 1 [PG&E Exhibit No. 22 was 2 received in evidence.]

3 MS. CURRAN: The next category is unplanned ESF  !

4 actuation, and the exhibits are 119, which is NCR DC 1 '

5 TI-NO39, dated October 2, 1992. Exhibit 120, which is LER 6 1-92-013-00, dated October 2, 1992; Exhibit 121, which is 7 NCR DC 1-91-0P-N038, dated May 3, 1991.

8 Exhibit 122, which is LER 1-91-011-00, dated 9 August 1, 1991; Exhibit 123, which is LER 1-91-009-00, which

$ 10 is dated June 17, '91, and Exhibit 124, which is NCR DC 1-J 11 91-TI-N047D4, which is dated January 24, 1992, and Exhibit

, 12 125, which is LER 2-91-006, dated November 1, 1991.

13 Exhibit 126, which is NCR DC 2-91-TI-N088D2, dated 14 October 30, 1991; Exhibit 127, which is LER 2-91-007-00, 15 dated November 1, 1991.

16 MR. REPKA: Okay. Do we have them all? No.  ;

l 17 [ Pause.]

18 MR. REPKA: Mr. Vosburg, I think you're the 19 designated respondee on these?

l 20 MR. VOSBURG: Yes. I'll respond to these. l 21 DIRECT EXAMINATION 22 BY MR. REPKA:

23 Q Are you familiar with these documents?

24 A Yes, I am. In general, I've reviewed them.

25 Q Let's see if we can cut through this pile of ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

i 1567

I documents pretty quickly. Let me start by asking you, what 2 is an unplanned ESF actuation?

3 A Well, an ES? is an Engineered Safeguards Feature, 4 and those are, basically, systems at the plant that were 5 part of the plant design to specifically deal with l 4 I 6 postulated accidents that are in the FSAR accident analysis. I I

i 7 At Diablo Canyon those would be systems like the

]

8 fuel handling building ventilation system, the containment ,

)

9 ventilation isolation system, the safety injection system, 10 the emergency diesel generators, several systems like that.

11 Q And, in general, what is the significance or l 12 importance of an unplanned ESF actuation?

13 A That would depend on the particular engineered 14 safeguards feature that you're discussing. In general, 15 actuation of an ESF feature at Diablo Canyon has little or 16 no effect on the plant.

17 The one exception that would come to mind would 18 be, of course, the safety injection system, and an unplanned i

19 actuation of a safety injection system would not be a -- it 20 would cause a reactor trip, and then the operators would 21 have to deal with the plant trans income, but, in general, 22 ESF systems like the ventilation systems are benign with 23 respect to challenging the operators.

24 Q But are unplanned actuations reportable to the NRC 25 and LERs?

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1568 l

1 A Yes. Any time that you have an unplanned 2 actuation of an Engineered Safeguards Feature, it's required 3 to be reported to the NRC.

4 Q Now, have you reviewed'these documents, which )

5 appear to list several unland ESF actuations?- Have you' .l 6 reviewed the documents?

7 A Yes. I've been through them, and, in general,

~

8 there's, I believe, about nine documents here that deal with l 9 six different unplanned ESF actuations. Three of the --  ;

10 three of the six events dealt with maintenance personnel l 11 performing surveillance tests and actuating an incorrect 12 opponent.

i

~

13 Two of the tests or the events here dealt with I l

14 operations ' personnel performing a surveillance test, and j O 15 similar personnel errors were made in which a wrong

)

j l

16 component was actuated, and the last event here dealt with  ;

)

17 operations clearing a piece of equipment, and they cleared 18 the wrong piece of equipment and caused an-ESF actuation.

19 In that case, it did not involve-surveillance 20 testing or maintenance in any way.

21 Q So we have six ESF actuations, three by 22 maintenance during surveillance, two by ops doing 23 surveillance and one by-ops with nothing to do with --

24 A Totally unrelated, yes.

25 Q I don't want to get into the details of each one l

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l 1569 l

1 of these at all, but just for the record the sake of the 2 record, could you try to correlate the nine documents into 3 the six incidents starting with, I think, Exhibits 119 and l

4 120 relating to the first one?

L 5 A Oh, yes. Documents 119 and 120 relate to the same l

)

6 incident.

7 Q And that was an incident of an ESF actuation 8 caused by a maintenance person doing a surveillance?

9 A That was an INC technician performing a 10 surveillance test, yes.

11 Q What is the second one?

12 A Document Exhibit 121, that dealt with an 13 operations person performing a surveillance test on the j 14 solid state protection system in which the operator simply L

15 actuated -- in the solid state protection system, there's a 16 bank of switches on the output panel that, basically, allows 17 you to test the equipment in place.

18 The operator for performing the test turned the

]

19 switch adjacent to the one he had intended to turn and l 20 started a piece of equipment other than what-he had planned l 21 to do. I think, in reviewing this, it was found that there 22 was -- there was no problem with the surveillance test ,

1 23 itself or the surveillance program. l J

24 It was simply the operator turned the wrong i

25 switch, and there are no corrective actions to be taken l

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4 1570 l 1 other than counseling the operator -- there were no 2 corrective actions found here necessary to the surveillance  !

1  !

3 program to enhance it in any way such that this would not 4 happen again.

5 Q Okay. Let's on to the third. Is that'in Exhibit  !

6 1227

~

7 A Let's see, the third, yes, is Exhibit 122, and I -

8 guess 122-A. That was another event where -- let me get j i i 9 these straight. There's a lot of them -- where-operations  !

10 was performing again a' test in the solid state protection 11 system. j i

i 12 In this case, the operators did part of the test  :

13 in train A of solid state protection system.- They stopped. i

() 14 They came back to perform the rest of.the test, and 5

15 inadvertently went to train B of the solid state protection

]

16 system, again actuated a wrong switch. l 17 In this case, the same as the last, there were no 18 problems with the surveillance procedure. There were no 19 corrective actions relative to their surveillance program. l 20 It was purely an operations error.

21 Q The fourth one appears to be in Exhibits 123 and 4

22 124, am I right? )

I 23 A Yes. 123 and 124 deal with the same event, yes.

24 Q And this one is one of the three maintenance 25 personnel?

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i  !

1571 1 1 A Yes. This was an incident where an INC technician  !

/~

. 2 had pulled a fuse on one of the channels of nuclear 3 instrumentation and initiated a reactor trip.  :

r 4 Q Okay. And the fifth one is in Exhibit 125; is 5 that correct?  ;

6 A Yes. The last one is -- I guess not the last 7 but -- yeah. The next one was Exhibit 125, and that 8 dealt -- this is the one that dealt with operators clearing 9 a piece of equipment. It was an inverter, one of the vital i

10 instrument inverters.  ;

I  !

11 The operators, when they cleared it, they went to 12 the inverter adjacent to the one they were intending to ,

13 clear, and, again, they weren't performing a surveillance.

t 14 They were just clearing the equipment. They went to the 15 wrong inverter, inadvertently de-energized it, and that j 16 caused an ESF actuation.

17 Q Okay. This is the one, then, that had no 18 connection at all to either a maintenance or a surveillance 19 test?

20 A In any way.

21 Q The test he was doing was not an STP?

22 A No. It was not a surveillance test.

23 Q Okay. Exhibits 126 and 127, do they describe the 24 last ESF actuation?

25 A Yes. This dealt with INC technician who were ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

1572 1 working again on the solid state protection system. They 2 are reconfiguring the system for procedure. They failed to 3 correctly follow the procedures and, again, initiated.--

4 actuated an Engineered Safeguards Feature.

5 Q Okay. In total, these six unplanned ESF 6 actuations, do they suggest a systemic problem in this area?

7 A No, I don't believe so. They were personnel 8 errors. Looking at the volume of surveillance test, in this 9 case, equipment clearances that are processed in the plant, 10 I think the number of events cited here is relatively low, 11 and there is little relationship between the events, other 12 than that they involve personnel errors, and, in this case, 13 they involve actuations of ESF equipment. I 14 Q When the company analyzes an unplanned ESF l

15 actuation, for example, in an NCR --

l  ;

l 16 A Yes. '

l 17 Q Do you look at all aspects of the problem and ways l 18 to minimize personnel errors in the future?-

l 19 A Yeah. We go through, generally, quite extensive  !

20 evaluations. Actually, any nonconformance report results in 21 a Technical Review Group, what we referred to as a TRG here, l 22 that looks into all the possible causes.

I 23 Especially when there's personnel error, it's very  :

l 24 hard to, you know, to make sure you found all the factors l 25 that could contribute to this. As an example, one of these O ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 i

. ._. . , _ . l

)

l 4

i 1573  !

l 1 that we just discussed, I believe it was the first event, l

2 where an INC technician had gone.to a wrong rad monitor, he .
i was performing a test.  !

) 3 4 We have two rad monitors that monitor the fuel  !

5 handling building area, and they will transfer the fuel l

6 handling building ventilation system from the normal mode to  !

i i i

? 7 the iodine removal mode.

) l l 8 All that does is, basically, route the exhaust 9 flow from the system through a charcoal filter. The INC l l

10 technician was performing the test. You do two checks on l

11 the rad monitor. You de-energize it to verify that, if it l l i 12 fails, the system will transfer it to the iodine removal l

i 13 mode.

14 The procedure then had operations reset the

! 15 ventilation system, and then he would come back and give it l

j 16 a high radiation signal and again verify that that one rad )

4 J 17 monitor would transfer the system.

l 18 One of the things that came out, in going through 19 this, is that the INC technician felt that, by him having to 20 stop -- he went to RM 58, initiated the test, then he had to 1 21 stop and wait for ops to reset the system.

1 i 22 So he had to -- he felt that having to stop 1

i 23 contributed to him getting back into it and going to the i

24 wrong monitor. It gave him a chance to fail. So we went 25 ahead, and we changed that surveillance test such that we

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} Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

l 1574 1 would perform all the tests on that particular rad monitor O 2 before we stopped and had operations reset the system.

1

)

3 So even small things like that we take into 4 account and make changes in the procedures in the plant.

5 Q It didn't mean the procedure was defective the way l:

6 it was before? l 7 A No, it wasn't, but, as part of'the investigation, l 8 the individual felt that might help. So we went ahead and 9 changed the procedure accordingly.  !

10 Q Can you give me one other example of how personnel i l

11 error created similar -- f i

12 A I can think of one from several years ago 13 involving operations. Operations -- again, this dealt with I

14 the four channels of nuclear instrumentation, the power O 15 range channels. Between the racks where these four channels

{

l 16 are, there's a -- there's about a two and a half, three-foot j i

17 area, and right behind there there's a. wall.  !

18 The operator was performing a test on one of the j i

19 channels and, in doing his self-verification, he would put  !

20 his hand -- he'd read the procedure, figure out which switch [

i 21 he needed, put his hand on it, verified that he had the .

22 correct switch per the procedure, and then actuate it. -

i 23 As he was doing that, he grabbed the switch, >

24 looked at the procedure, and, as he did it, he stooped down,  ;

i 25 and he hit his back on the wall, and there was a bolt head '

O ANN RILEY & ASSOCIATES, LTD.

Court Reporters

-j i

1612 K Street, N.W., Suite 300 i Washington, D.C. 20006  !

(202) 293-3950  !

I t

-.,->-v -g.- -n ,e s,-,- --, ,,v--te - -amg-- w,,o-

i 1575 l 1 protruding from the wall. When he bumped it, he stood back i

2 up let go of the switch.

i I 3 When he went back down again, he grabbed the wrong

)

4 switch. Because of something that simple, we actually went

5 and did a design change in the plant to put covers over 6 those bolt heads so something hike that couldn't happen

! 7 again. So I think it shows to the degree that we will go 1

1 8 to to try to prevent these personnel errors.

9 MR. REPKA: I have no further questions on these 10 documents.

l 11 JUDGE BECHHOEFER: I'd like to inquire, does 12 Mothers for Peace have extensive examination, because we're

< r 13 getting very close to the time when we have to break. We 14 could resume cross-examination on these documents across the  !

15 hall at 1 o' clock.

I 16 MS. ZAMEK: I'd say it would be about five or ten 17 minutes.

18 JUDGE BECHHOEFER: I think we'd better not run f 19 that risk, because we have to clear out and have everything 20 out of here prior to 12 o' clock.

21 MR. REPKA: If it's five minutes, I'd love to 22 finish this one.

23 MS. CURRAN: It depends how long we -- one word 24 answers will be great, but --

25 MR. VOSBURG: I'll try, but I can't promise.

1 C,,,/ ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

i 1576 1 JUDGE BECHHOEFER: Well, we have three minutes  !,

l 2 legitimate anyway.

3 MS. ZAMEK: So we're stopping?

4 MR. REPKA: We're going. [

i 5 MS. ZAMEK: Oh, we're going. i 6 JUDGE BECHHOEFER: We're going to try and do this 7 one. ,

! 8 CROSS EXAMINATION  :

9 BY MS. ZAMEK: l 10 Q Is an unplanned ESF something that a nuclear power 11 plant tries to avoid, then? ,

12 A Oh, absolutely, yes.

13 Q And why is that?

14 A Well, it depends, again, on the particular safety 15 function you're actuating. Certainly, a safety injunction 16 is something you would never want to inadvertently have j 17 actuate. With regards to the bulk of the Engineered i

18 Safeguards Feature at Diablo Canyon, actuating them simply 19 puts a system in a more conservative mode. I 20 The containment ventilation isolation, for 21 example, there's about eight valves that penetrate 22 containment. When you get a CVI, it simply closes those 23 valves.

24 At power, all but a couple of those valves are 25 normally closed. The only ones that are open are the ones ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 l-t (202) 293-3950

1577 i

i that go to the radiation monitor outside containment that's 2 monitoring inside containment.

3 So all that happens when you actuate it is those 4 valves close. You reset the CVI signal, and you open the 5 valves to the rad monitor again. There's no challenge to 6 the operate force. It doesn't cause a plant transient.

7 Q Right. You mentioned that before, that there's no 8 challenge to the operators, then it's little significance, 9 it's benign, but what about the effect on the equipment?

10 A Well, for example, the inadvertent actuation of 11 the fuel handling building ventilation system, that was the l

12 next -- you know, he went from RM 58 to RM 59, got the urong l l

13 rad monitor. That would have been the next rad monitor he I s 14 tested in that procedure. You normally test both of them.

d 15 He did them out of sequence. That's an error. He i 16 inadvertently actuated it. That was called an ESF 17 actuation. He was going to do it anyway in the -- you know, l

18 the next rad monitor. I i 19 Q But it wouldn't have caused the ESF actuation?

20 A It wouldn't have caused? Oh, yes. He would have 21 done exactly what he did later on, but he did it when he l

l 22 didn't intend to. Therefore, was an error, and it actuated 23 an Engineered Safeguards Feature. j 24 So it was reportable, and that's another reason 25 that we, you know, definitely don't want to have these l

l l r ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

1578

(~'g 1 happen, because it does cause, you know, TRGs, NCRs, C/ 2 reportability, and it deals with personnel errors. We take 3 it very seriously, and we put a lot of work into trying to 4 find out the causes for these and correct them. So it takes 5 a lot of resources from the plant whenever this happens, 6 too.

7 Q In Exhibits 123 and 124, discuss the incident with )

8 the safety injection, which you were saying is absolutely 9 horrible, and you don't ever want to do. Is that --

10 A No. I didn't say absolutely horrible.

Il Q But you try to avoid. I'll rephrase that.

12 A Definitely, we try to avoir tripping the plant.

13 MS. ZAMEK: I don't know if we should stop here, 14 or if I should go on a few more minutes.

15 BY MS. ZAMEK:

16 Q On page 7 of Exhibit 124 discusses of overcooling 17 problems that occurred in that event. Can this have --

18 A Well, this was the event where the INC technician 19 caused a reactor trip by pulling the wrong fuse on the NI 20 channel. After the reactor tripped, the normal response of 21 the steam dump system is, since the turbine's tripped, the 22 steam then bypasses the system, and it's dumped into the l 23 condenser.

24 Two of the valves in that steam dump system had a i

25 problem that allowed them to leak excessively, and it l

l l

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Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 t

1 i

l l 1579 l

1 resulted in not -- you know, it resulted in excessive  !

l 2 cooling to the point where the cool-down caused the safety i l

i 3 injection in the ESF actuation. I 4 The direct action of the tech didn't cause it, but 5 it was a result of the reactor trip, which the technician 6 did cause.

7 2 And are you aware --

8 A So it was an equipment problem that existed in the 9 plant that, you know, that was found, you know, after the ,

10 plant trip due to the INC technician's actions.

11 Q But the root cause is on page 6, and it says it 12 was determined to be, again, personnel error. The INC 13 technicians did not perform self-verification.

t

()

%J 14 A Yes. That was the -- the INC technician did not 15 perform self-verification. He was working on --

i 16 Q Which caused the reactor trip? i 17 A Which caused the reactor trip, then. The i 18 cool-down and the safety injection was caused by the valves j l

19 in the steam dump system failing, not directly from the 20 tech's actions. He caused the reactor trip. l 21 Q Okay. And each time -- is it true that each time 23 you have an unplanned ESF and the safety injection that it l

23 puts wear and tear on the system?

24 A It causes components to operate that generally 25 aren't operating. I wouldn't -- you know, safety injection l l I r

i (O

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Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 I (202) 293-3950 l

1580 1 pumps start. RHR pumps start. Those pumps don't normally 2 run, and once you have an inadvertent safety injection, they 3 may run for a few minutes before it's reset and the pumps 4 are shut down, and there's really no significant wear in -

l 5 that time period relative to the pumps. ,

6 Q After multiple or repeated actuations, does the l 7 reliability of these components decrease at all, then, do ,

8 you think?

l 9 A No, it does not.

10 Q And after many years of this, is there any kind of 11 procedure or any provision you have of maintaining, 12 increasing the maintenance because of the repeated l

l 13 actuations?

i 14 A No. There are very few actuations here. I think l

15 starting a pump that -- an SI pump that normally does not 16 run this number of times certainly did not increase the wear 17 on that pump to the point where a maintenance program would 18 be enhanced, you know, for wear-related causes.

19 Q Okay. I'd like you to turn your attention to 20 Exhibit 124, pages 14 and 15.  ;

l 21 A I'm sorry.  !

1 22 Q Exhibit 124, pages 14 and 15. It's the very last l

23 sentence of page 14 that goes into 15.

24 "The root cause of the event was a lack 25 of self-verification on the part of an O._ ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

l t l

1581 i

, I

{ 1 INC technician during the performance of  !

l i 2 a SGP. This has been a generic problem  ;

I 3 at DCCP and in the rest of the  !

4 industry." .

5 Would you agree with that statement?  !

6 A- Well, I don't agree that -- well, let me put it in l c

7 perspective. We have a procedure at the plant that deals 8 with independent verification, and'it applies to everybody, j 9 maintenance personnel, operations personnel,-and it, I 10 basically, says that -- well, there's three times of 11 verification.

12 There's self-verification where an individual  ;

13 working alone goes through a' set -- it's a pattern you go 14 through. In other words, if I'm going to actuate this

.l 15 switch by this procedure, I look at the procedure. I find l

)

16 the correct switch. I put my hand on that switch. I then f

.I 17 verify, yes, that is the switch the procedure'says.

L 18 I anticipate what I expect to happen when I. turn, j l .

19 actuate the switch. I actuate it, and then I verify what I 20 expected to happen actually did happen. So we have a l l

l- 21 procedure that applies to everyone so that any time a l

22 personnel makes an error -- person makes an error where he 23 actuates a wrong opponent, you can go back and say, "He 24 didn't follow the independent verification procedure, or 25 that wouldn't have happened."

r ANN RILEY & ASSOCIATES, LTD. i Court Reporters l L

l 1612 K Street, N.W.,-Suite 300 l Washington, D.C. 20006 (202) 293-3950

1582

, 1 So, because of the large, extremely large number l

i 2 of activities where you can have that happen, yes, there are 3 cases where people simply do not remember to do the right 4 thing, and had they do it it wouldn't have happened. So 5 there will be cases --

6 Q Well, based on the number of previous similar 7 events, would you say that the existence of the self- and 8 concurrent verification program that you have is effective?

9 A Yes, I believe it is. We continually -- you know, 10 any time -- we watch the number of times this occurs. If it 11 looks like there's a trend where there's been a few cases 12 where it's happened recently, we do a lot of things to make 13 sure that the people are aware that they have to perform 14 this.

15 There's an example in here, where, when an INC --

16 I forget which one it is -- an INC tech made an independent 17 verification error. We stopped all the work in the plant 18 that the INC techs were doing. Stopped everything, got 19 everybody together -- I wasn't there, because I wasn't in 20 the INC department.

21 They got everybody together to tailboard everybody 22 in the department to make sure that everybody understood 23 that it was required to do this, which caused, again, delays 24 in work. So that's the extent that they take this 25 seriously.

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Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

l 1583 1 Q I think I just have one more question, and it has l 2 to do with your statement about the bolts when you, you 3 know, that you put a barrier to prevent these things. i 4 A Yes.

5 Q On page 7 of Exhibit 119, there was a -- this was 6 where there was a problem operating the wrong channel, and  ;

7 at the bottom of.the page it says, the last paragraph, j 8 "The TRG discussed and decided not to ,

l 9 implement physical barriers over the  ;

i

~

10 switches similar to those installed over  :

11 many of the other radiation monitors as  ;

12 a result of previous wrong channel 13 personnel errors."

l 14 So would you still say-that PG&E implements every l.

15 possible -- {

j 16 A Yes, we do. The TRG, this is one of things -- ,

17 these, again, are the TRG minutes, and they looked at --

18 they looked at all the possible things they can do. _ Putting 19 physical barriers over the front of these-rad monitors, for 20 one, obscures -- you know, any time an operator-wants to 21 read it, then he's got to remove this barrier to look to see 22 it.

23 So it's a balancing act, and, in terms of thel fuel 24 handling building ventilation system,.the consequences of R25 having, again, an ESF actuation _in the fuel handling ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1612 K Street, N.W., Suite 300 Washington,-D.C. 20006 (202) 293-3950 l

1584 1 building ventilation system is simply that the system 2 transfers to a more conservative mode.

! 3 All that happens is dampers open, and it reroutes 4 the exhaust flow through a charcoal filter. The only -- you i 5 know, the reason we do that is the charcoal filter has to be 6 replaced based'on how much flow it's had through it. I

]

7 mean, it gets used up.

8 Q So there is some increased maintenance required, l

! 9 then? ,

10 A Well, no. That's why the system's designed l 11 normally not to put flow through it. So had that not been a 12 problem, we would always have flow through it, and there 13 wouldn't be any actuation required.  ;

14 A (Witness Giffin) The statement that causes 15 increased maintenance. So it causes increased maintenance 16 does not necessarily degrade. It just makes sure that the 17 equipment is again looked at and make sure that it's good.

18 So causing increased maintenance is just a burden upon me l

t l 19 and my people. It doesn't have anything to do with the j 20 efficiency or the operating of a piece of equipment.

21 Q Okay. I have --

22 A (Witness-Vosburg) Well, and I'd like to finish, 23 because your question dealt with the barriers, and not only 24 -is it -- you know, it inhibits people looking at those 25 monitors, but you have to remove the barrier.

i l

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1

-1585 1 There were -- part of the considerations, when we O 2 put barriers in front of the power range channels.that cause j 3 some of these other problems is that you may -- just i 4 removing the barrier potentially cause something to go l 5 wrong. j 6 So you weigh all -- you weigh the benefits and the 7 risks. In this case, we were replacing those rad monitors {

8 in the future, and because of the absolute lack of l 9 significance to having an ESF on that particular system, it 10 was -- it was deemed that it was not the correct thing to  :

11 do, and that's why it was written down here in the minutes.

12 MS. ZAMEK: Okay. Thank you. Are there any i

13 further questions from the Board? r 14 JUDGE BECHHOEFER: Does the Staff have any 15 questions?  :

l l 16 MS. HODGDON: No, I don't think so. Not at this l 17 time. ]

? I i

18 JUDGE BECHHOEFER: I have one. We got to go. I i 19 only have one question. I hope we don't have a big argument 20 over documents. On Exhibit 124, page 8, under item 5-B, has 21 this particular investigation been carried out, and has any j

22 result -- is there any results or have any_ changes been made 23 as a result? It's paragraph 5-B on page 8.

24 MR. GIFFIN: I know that we have done an_

l i

25 investigation on how can we improve the performance to make ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 l .

_ ~ ._.

, y 1586 1 sure that people use self-verification. In a training 2 class, when an INC tech goes through training and using 3 mockups, the instructors watch him to make sure that he uses 4 self-verification techniques in the training building.

5 So it's included now as part of the training to 6 make sure that he demonstrates to his instructor that he's 7 demonstrating self-verification. Also, in my testimony, it 8 talks about errors and the personnel errors, that we are j l 9 trending these errors -- the errors in personnel are I

10 trending down.  !

l . I 11 So we're seeing personnel verification, if you i i

12 don't do it, you can errors, and the number of errors are )

13 decreasing. So we believe that what we're doing is quite  ;

14 adequate.  ;

O- 15 JUDGE BECHHOEFER: Did the change in training that 16 you just described follow this particular matter? j i

17 MR. VOSBURG: That particular change he described

18 is in one or two of these events as a corrective action that 19 I remember reading --

1 20 MR. GIFFIN: It's in this particular event that 21 we're talking. It's item 4, bottom of page 9.

22 JUDGE BECHHOEFER: I see. And that item for has 23 been done?

l 24 MR. GIFFIN: Yes, sir.

l l 25 JUDGE BECHHOEFER: That's all I have. I guess

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Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202).293-3950 l

I i

l i 1587 1 that's all the Board has. Any follow-up questions? ,

l O.

2 MR. REPKA: None here.

3 MS. ZAMEK: Then I'd like to offer these exhibits.

4 JUDGE.BECHHOEFER: Well, are you offering 125? I j 5 have somewhat of a problem with 125, just offhand. The 6 others -- well, we'll have to hear what the partjus say, but 7 125, I --

8 MR. REPKA: I have no objection to any of these:

9 except for 125. So maybe -- I mean, that's the one that has 10 no --

11 JUDGE BECHHOEFER: Yeah, I see some problems.with j 12 125, and-I wondered you're still going to offer it, given 13 the testimony about it.

14 MS. ZAMEK: I don't have a problem with removing 15 this.

16 JUDGE BECHHOEFER: With removing? Okay. Let me 17 get my numbers straight. So MFP is offering 119 through 18 127, but minus 125, not including 125, and there's no 19 objection to that, it take it?

20 MR. REPKA: Right. No objection.

21 JUDGE BECHHOEFER: Okay. Staff doesn't object?

22 MS. HODGDON: No objection.

23 JUDGE BECHHOEFER: Those documents other than 125,

4 2 which has been withdrawn, those documents will be admitted 25 into evidence.

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Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

I l

l l

1588 )

i s 1 [MFP Exhibit Nos. 119 5 i 2 through 124 and 126 l

3 through 127 were received 4 in evidence.]

5 JUDGE BECHHOEFER: We'll break now for lunch but 6 more significantly for a little moving work.

7 [Whereupon, a luncheon recess was taken.]

8 i

9 10 1 11 i

12 l 13 l i

15 16 l

17 l

18 1 i  !

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l 19 j l

20 21 22 l'

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Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

I 1589 1 1 AFTERNOON SESSION- l O- 2 JUDGE BECHHOEFER: Okay. If you can't hear me, l

just scream or shout. Okay. Since we don't have I 3

4 microphones, if you can't hear me or anybody else here, let j i

5 me know. We're back on the record. We're in the alternate  !

6 location that we published in our notice several days ago. j 7 Mothers for Peace may proceed. i l

8 MS. CURRAN: All right. We're moving on to 9 Exhibits 128 and 129. Exhibit 128 is NCR DC 2-92-EM-N026- ,

10 D8, dated September 17, 1992, and Exhibit 129 is IIR 1  ;

11 010-00, dated October 15, 1992.

12 DIRECT EXAMINATION 13 BY MR. REPKA:  !

14 Q Mr. Ortore, do you have a copy of those 15 documents?

16 A (Witness.Ortore) Yes, I do.

17 Q And are you prepared to discuss them?

18 A Yes, I am.

19 Q Do these two documents relate to one instance of a 20 Limittorque valve operator failure?

21 A Yes. .They refer to the same incident.

l 22 Q Okay. And this was an incident of an operator 23 failure during the performance of a MOV test?

24 A Yes, a failure of a motor operated -- motor 25 operator, yes.

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Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

1590 1 Q Of a motor operator during the test?

2 A Yes. This was a part of the DCPP's MOV testing 3 program.

l l 4 Q Okay. And it failed, it was determined 5 subsequently, due to improper assembly of the operator?

6 A That is correct.

7 Q And was there a root cause determination made as 8 to why it was assembled improperly?

9 A Yes. The root cause was due to personnel error l

l 10 during the assembly.  ;

i 11 Q And was the situation corrected?

12 A Yes. There was corrective actions, and it was I

13 corrected.

( 14 Q Do you have confidence that other similar l 15 components have been assembled correctly?

16 A Yes. We have looked at those that were assembled l 17 by that individual, and they have all been corrected. I 1

18 MR. REPKA: I have no further questions. ,

l 19 CROSS EXAMINATION i i

20 BY MS. CURRAN:

21 Q Mr. Ortore, I just want to clarify that these i l 22 Limittorque motor operators were -- they weren't originally i 23 installed in the plant, right? These were replacement 24 components, weren't they?

25 A No. It was only -- we only preassembled the L. ANN RILEY & ASSOCIATES, LTD.

l Court Reporters l 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 1

I

1591 1 spring pack assembly, and those were installed in the l 2 operators. The operator itself was in the plant, and we 3 installed assemblies.

4 Q And you installed the assemblies during the second 5 refueling outage? Was that -- let me see where I --

6 A It was Unit 2. It was during the fourth refueling 7 outage.

8 Q Okay. All right. So a mistake was made during

! 9 this assembly of the -- of the motor -- motor -- of the  !

)

10 motor, right? l 11 A Yes. l l

l 12 Q Of the motor operator. Okay. 1 13 MS. CURRAN: I don't have any other questions.

l l

(

! 14 MR. REPKA: Let me just follow-up on that qpickly.

O} 15 REDIRECT EXAMINATION  ;

l l 16 BY MR. REPKA: l 17 Q It was installed during 2 R-4?

18 A Correct.

l 19 Q And it was picked up in a test when?

20 A Sometime after the outage.

! 21 Q The outage being 2 R-4?

l l 22 A Right.

23 BY MS. CURRAN
,

i l 24 Q Can I ask how long after the outage? It says on 25 June 2nd. .

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i l

1592 1 A Right. And I'm not sure when the outage was  !

0 2 completed. I'm not positive how long that was.

i 3 MR. REPKA: I think the documents can speak to 4 that.

5 MS. CURRAN: Okay.  !

6 MR. REPKA: Okay. I have no objection to {

7 admissibility.

8 MS. CURRAN: Okay. We move Exhibits 128 and 129  !

9 into evidence, unless the Board has questions. l 10 JUDGE BECHHOEFER: Well, I have a minor clarifying j i

11 question. What is signature testing, as distinguished from 12 some other kind of testing?

13 MR. ORTORE: As part of our MOV program, that is 14 where we would get a phrase of the valve as a signature for 15 the -- to document as part of our MOV testing program the 16 performance of the -- of the valve, of the operator and the 17 valve.

l l

18 JUDGE BECHHOEFER: The Board has no further 19 questions. Any follow-up?

i l 20 MS. CURRAN: No.

I 21 JUDGE BECHHOEFER: ' If not, Documents MFP Exhibits 22 128 and 129 will be admitted into evidence.

i 23 [MFP Exhibit Nos. 128 and 24 129 were received in 25 evidence.]

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1 MS. CURRAN: Okay. Exhibit 130 is NCR DC 2-91-EM-O 2 N095-G6, dated September 24, 1992. ,

i 3 [ Pause.] l 4 DIRECT EXAMINATION i 5 BY MR. REPKA:  ;

6 Q Okay. Gentlemen, do you have that document, MFP l l

7 Exhibit 130?  ;

1 8 A (Witness Otore) Yes, I do. j i

9 Q Mr. Ortore, are you prepared to talk about it?  !

10 A (Witness Ortore) Yes, I am.

11 Q This was a case where a particular aux feeder 12 breaker failed to open?

13 A (Witness Ortore) That is correct. j 14 Q And that occurred during a test or during )

(g- l 15 operation?

)

16 A (Witness Ortore) That occurred while we were 17 aligning the power towards the end of the second -- the 18 fourth refueling outage for Unit 2, 2R4.

19 Q And you -- after it failed you disassembled the 20 component?

21 A (Witness Ortore) Yes, we did.

22 Q And did you determine a root cause?

23 A (Witness Ortore) Yes, it was -- it appeared to be l 24 a misalignment of the trip-coil.

25 Q And how did that misalignment occur?

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i 1594 1 A That occurred during reassembly of the breaker 2 when it was overhauled.

3 Q Now the documentation I believe states that there

4 was a -- the procedure was not clear in some way as to how

! S that alignment should be done, is that true?

i 6 A (Witness Ortore) Yes, the root cause was I

7 determined to be insufficient information in the procedure.

8 However, this is an activity that's been performed many,

9 many times at the plant and this was the first time that 10 we've had a misalignment.

11 Q Okay. So, even though this procedure has been 12 successfully applied many times you revised the procedure to 4 13 make it more clear?

4

. 14 A (Witness ortore) That is correct.

15 Q Mr. Vosburg, did you have something to add to J

16 that? {

17 A (Witness Vosburg) Well, the point that I wanted 18 to make was that sometimes you write procedures that are 19 used repetitively correctly and what maybe correct to the 20 majority of the people may not be completely clear to an

. \

21 individual. And I think in this case, where the procedure I l

22 had been used repeatedly and correctly in the past, there 23 was one individual using it who -- there was not enough  !

24 detail probably in the procedure for him to understand 25 exactly how to set it up. I believe that's what occurred l

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1595 i 1 here.

2 Q So, that detail was provided?

l 3 A (Witness Vosburg) Right. So, we went back and l

4 enhanced the procedures to try to cover all the j 5 possibilities.

6 MR. REPKA: Okay. I have no further questions.

7 CROSS EXAMINATION 8 BY MS. CURRAN: l 9 Q Mr. Vosburg, it states at page five of the exhibit 10 that MPE-63.18 does not discuss a method for alignment of 11 the breaker trip-coil. Do you -- does that seem correct to 12 you?

13 A (Witness Vosburg) This statement?

(~g 14 Q Yeah.

O 15 A (Witness Vosburg) Yes, well, I --

16 Q Okay.

17 A (Witness Vosburg) -- I believe it's correct as 18 written here, yes.

1 19 Q And can you tell me, in the summary of this 20 document the word " vital" was used. Let's see, it's called 21 a " vital bus H auxiliary feeder breaker", can you tell me 22 why the word " vital" is used?

23 A (Witness Vosburg) Yes, we have three what we call l

24 the safety related buses-that supply power to the plant. We 25 have a bus F, bus G and bus H. Those buses have essentially l I'd

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1 three power sources, what we call the auxiliary power

[

l O 2 source, a diesel generator and then a start-up power source. [

3 And " vital" is a term that we use synonymous with safety i 4 related in this case.

5 Q Okay.

6 MS. CURRAN: I don't have any other questions. 1

( 7 [ Pause.]

l I

8 If the Board has no questions, --

9 JUDGE BECHHOEFER: Yeah, I have one.

l l 10 QUESTIONS BY THE JUDGES 11 JUDGE BECHHOEFER: Maybe just to clarify whether 12 there's a difference between a couple of numbers here. On i 13 page five, the statement is that, l /"' 14 "MPE 63.1A fails to discuss certain 15 things." i I

16 On page 11, it seems to say that MPE 63.1C is going to be 17 revised. I wondered why when there's a problem with 18 whatever procedure 1A is you revise procedure 1C?

19 MR. ORTORE: On page 11, 1 think if you read down 20 further there is a reference to 63.A and when the corrective 21 action was actually performed they realized that that was l 22 the proper procedure. The procedure for overhauling rather 23 than performing the maintenance.

24 JUDGE BECHHOEFER: Yeah. Well, will it become 25 clear to the people who have to carry out the functions O- ANN RILEY & ASSOCIATES, LTD.

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l l 1597 L 1 then?

O f

2 MR. ORTORE: I'm sorry, it all --

I x 3 JUDGE BECHHOEFER: Pardon?

l 4 MR. ORTORE: It says down at the bottom that both j 5 procedures, it says, 63.1C and 63.1A will also be revised i 6 JUDGE BECHHOEFER: Oh, okay.

j 7 [ Pause.)

l 8 MS. CURRAN: Oh, this document is moved'into i

i 9 evidence.

10 MR. REPKA
Oh, before I answer that, can I ask l

11 one more follow-up? j

< l j 12 JUDGE BECHHOEFER: Oh, certainly, I'm sorry. {

l 13 REDIRECT EXAMINATION i  !

i 14 BY MR. REPKA: i i  !

15 Q Mr. Vosburg, was the procedure for this adequate, )

i  !

j 16 or Mr. Ortore, prior to that revision or inadequate? i i

y 17 A (Witness Ortore) In my opinion the procedure was j 4 i 18 adequate. This was performed many, many times like I said, 19 without any problem. However, as Mr. Vosburg explained

]

l 20 before, during our root cause analysis sometimes we tried to j 21 take, to look at every single possibility and make the i

J 22 procedures as good as they can possibly be.

j 23 MR. REPKA: Okay, I have no objection to 24 admissibility.

1 i

25 JUDGE BECHHOEFER: Okay. -Staff, no objection?

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4 l a

i a

1598 1 MS. HODGDON: No, objection.

\- 2 JUDGE BECHHOEFER: Exhibit 130 will be admitted j 3 into evidence.  !

4 [MFP Exhibit 130 5 was received in 6 evidence.]

7 MS. CURRAN: Our next exhibit is number 131, which 4

8 is LER 1-92-015-00, dated September lith, 1992.

9 DIRECT EXAMINATION 10 BY MR. REPKA: l

11 Q Mr. Giffin, are you prepared to address this a

12 document?

13 A (Witness Giffin) Yes, sir.

14 Q Does this LER address a maintenance issue?

. C

15 A (Witness Giffin) No, this LER does not address a 16 maintenance issue.

17 Q What was the issue addressed in this LER?

f 4

18 A (Witness Giffin) The issue is that qualification

19 files were not updated and maintained by the design 20 engineering group.

21 Q So, was there any impact on any piece of 22 equipment? Let me strike that.

23 Did this reflect any design problem with respect 24 to a piece of equipment?

25 A (Witness Giffin) The way that I read this it is i

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1 1599 1 i l 1 all maintaining and updating seismic files, not with putting

] 2 and changing equipment in the plant. i i

i 3 Q Maintaining and updating seismic files, is that a 4 responsibility of the maintenance department or -- l l 5 A (Witness Giffin) That's the responsibility of the

6 design engineering organization in San Francisco._ l

- 7 Q Now this particular case where the derign j l 8 documentation needed to be updated, was the. design of the as j 9 installed component acceptable?  !

i 10 A (Witness Giffin) .In this partidular - -they're ,

l 11 talking about a boric acid tank level transmitter and the j j .

j 12 way I read this is that the transmitters were qualified when- l 13 they went back and looked at them. {

i 14 So, they just needed to update _the qualification )

Q i

j 15 file, the documents to reflect that qualification? .

j 16 A (Witness Giffin) That's correct.

2 .

17 Q You said that's correct?  !

18 A (Witness Giffin) Yes, I did. )

19 Q Are there, as a result of this LER, are there any l l

20 changes you could make to your maintenance or surveillance j 21 program that would prevent a similar recurrence?

j 22 A (Witness Giffin) No, there is not.

4

23 Q And would this qualification documentation issue 1

4 24 in any way affect your maintenance on the piece of equipment 25 that was at issue?

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i 1600 l 1 A (Witness Giffin) No, the files have nothing to do j O 2 with how we maintain or keep something operating. It's just j

i 3 to make sure that the qualification file states what's in f i

4 the plant.  ;

5 Q Does this LER in any way have anything to do with f

6 plant material conditions?  !

7 A (Witness Giffin) In my opinion this has nothing f 8 to do with plant material conditions. It only has to do 9 with paper files that are located in San Francisco, nothing t i

10 to do with what's installed at the plant.  :

11 MR. REPKA: I don't have any further questions.

12 MS. CURRAN: Okay.  !

13 CROSS EXAMINATION .

i 14 BY MS. CURRAN:

O 15 Q Yes -- was it yesterday or the day before i

16 yesterday, we were talking about the program at Diablo l l

17 Canyon for reviewing DCM category 1 equipment and '

18 determining whether there were changes to the -- any changes-19 to the maintenance program that needed to be made as a  ;

20 result. Isn't that true?  !

l 21 A (Witness Giffin) I believe we were talking about  !

22 design criteria, yes.

23 Q Right. And let me just paraphrase it and you can 24 correct me, that in effect the program is to review 25 equipment specifications for class one equipment to make O ANN RILEY & ASSOCIATES, LTD.

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! l 1 1601 ,

i

! I sure that you haven't missed anything in there that would I i 2 relate to maintenance and surveillance, is that a correct -- l l

3 A (Witness Giffin) That's one of the reasons why [

4 the review is being done is the reconstitution or the design l 5 criteria being reviewed and looked at. One of the things l 6 that we're looking at is to make sure that the maintenance i 7 activities and surveillance activities go between the two.

8 And say for this class one equipment, isn't the  !

Q 9 starting place for making that kind of a review the 10 equipment qualification records that are kept on the class 11 one equipment?  !

12 A (Witness Giffin) I'm not sure how the engineering 13 department is doing the review in San Francisco. They 14 caught this themselves, so, apparently in their review O 15 process they found the error in their files and corrected 16 it. So, they did find it.

17 Q What error are you speaking about?

18 A (Witness Giffin) The LER that you gave us for-19 PG&E determined that the boric acid tank level transmitter 20 was --

21 Q Oh, that's not what I was asking you about right 22 now. I was just trying to -- l 23 A (Witness Giffin) Oh, I thought we were still 24 talking about the exhibit.

25 Q Well, no, I'm trying to get a little more ANN RILEY & ASSOCIATES, LTD.

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i i 1602 I

l

} 1 information about this review program that you've already i i

) 2 instituted on the class one equipment. So, when you did l

i i 3 that review, the DCM review, or in the process of doing that ,

4 review, isn't the source of the information that's relevant j i  !

j 5 to you documentation that's kept by PG&E regarding the i 1

] 6 qualification of that equipment?

7 A (Witness Giffin) No.

i 8 Q No. What is it? i i

i 9 A (Witness Giffin) This documentation, in this  !

l'  !

] 10 particular example or exhibit --

j 11 Q I'm not talking about this particular exhibit, I'm i

I 12 asking you something else.

I i

13 A (Witness Giffin) You're asking me a general ,

14 question about all design criteria?

j 15 Q Yes. I'm asking you about the review that was I

16 referenced in your testimony on Thursday.

4 l l 17 MR. REPKA: I think the question ought to be  !

l 18 directed to this example, and the question ought to be as in t

19 this example is, we're trying to see if this example affects 20 the maintenance schedule for the equipment at issue. That

21 ought to be what the question is. Let's stick to the i 22 subject at hand here.

23 BY MS. CURRAN:

24 Q Well, what I'm trying to find out is whether or q 25 not there's a similar program in effect for seismically I

i J

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I 1603 j 1 qualified equipment as there is for class one electrical i

2 equipment as was discussed on Thursday? Maybe you can just l

4

3 tell ne that?

1

) 4 A (Witness Giffin) So, the question is again, i

5 please?

! 6 Q Is there a program for review of seismic equipment I

7 of what do you call it, seismically qualified equipment that 8 is comparable to the review program that was referenced in

{ 9 your testimony on Thursday with regard to MCR DCO-93-TNN-006?

) 10 11 A (Witness Giffin) I'm not sure if there's any 12 programs such as you speak, but if you read the corrective 1

$ 13 actions in the exhibit --

i i 14 MR. REPKA: Which exhibit, Mr. Giffin?

! 15 MR. GIFFIN: 131, the one we were talking about.

16 It says, 4

! 17 "The Hosberry Report was reviewed to i

! 18 identify any other seismic qualification f 19 commitments. Files demonstrating.

l 20 qualification to the Hosberry earthquake i .

j 21 have been established or updated as 1-l 22 necessary."

I J- 23 So, I believe the engineering department has looked at the i 24 particular files that.are referenced in this exhibit and j

25 this voluntary license event report.

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1  !

! 1 Q But that was -- it was seen as a problem that that  ;

t i

l 2 wasn't done immediately as it needed to be done, isn't that l 1 i i 3 right?  ;

r j 4 A (Witness Giffin) It was determined that there was 5 no problem. The problem was that the files weren't  ;

4  :

i 6 maintained. There was no problem in the equipment that was maintained and installed in the plant.  !

j 7 i i

! 8 Q That's right, I'm not referring to that problem, l I i 9 I'm referring to the documentation problem?

i

! 10 A (Witness Giffin) Apparently there's a, as stated j

! 11 in the licensing event report, there was a concern that the {

l j 12 files were not being maintained by the engineering j i I j 13 department in San Francisco. j i l

j. 14 Q How would you get information, if you needed to do 'l 4
15 any kind of additional maintenance on a piece of seismically 16 qualified equipment as a result of changes in seismic 17 qualification, how would you get thht information? Who l 18 would give it to you?

j 19 A (Witness Giffin) If -- to do normal maintenance i

20 on a piece of equipment doesn't make a difference whether 21 it's seismic or not. Maintenance procedures will specify l

]

3 22 how to take it apart and how to put it back together. So, 23 the seismic qualification does not matter when you're taking-24 something apart or putting it back together. If I needed

~

25 information I would contact the engineering department. But i

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1 l 1605 4

l 1 I don't need it - that type of information I don't need in 2 determining what maintenance is to be conducted.  ;

3 Q Even if you found out that perhaps the wrong

! 4 material had been used and needed to be replaced because it >

i 5 wasn't seismically qualified?

1 6 MR. REPKA: There's no foundation that that 7 occurred here, so --

8 JUDGE BECHHOEFER: I'm not sure I understand that [

i 9 question.

10 MS. CURRAN: Uh-huh.

11 JUDGE BECHHOEFER: If the wrong material were i 12 found in a piece of equipment it would be the wrong material 13 and they would replace it, wouldn't it?

14 MR. GIFFIN: Yes, sir, and in order to do that the i

15 engineering department would issue a design change 16 memorandum that would tell me that what was in it should be 17 replaced with that. And that's how I get information from 18 engineering.

I 19 JUDGE BECHHOEFER: And you wouldn't have any way 20 of saying, oh, gee, this thing has the wrong kind of 1

21 stainless steel, it's obviously not seismically qualified, 22 you wouldn't be able to tell it by looking at it, would you?

23 MR. GIFFIN: No, sir, I would not. I rely upon 24 the engineering department.

25 MS. CURRAN: Well, that's the point, he couldn't ANN RILEY & ASSOCIATES, LTD.

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1 tell. That's the point that I think is important here, is

] O-2 that he needs to get that information from engineering which 3 keeps this documentation.

4 MR. CROCKETT: Let me try to clear this up again.

f If there's a change to a piece of equipment that might

) 5

} 6 affect its seismic qualification, that change is transmitted 7 down to the plant through a DCN, design change --

8 JUDGE BECHHOEFER: Ms. Curran?

i 4

9 MR. CROCKETT: With this --

i j 10 JUDGE BECHHOEFER: Ms. Curran, why would the j 11 maintenance person need to know anything about seismic 12 qualification to know that it's the' wrong piece of i 13 equipment?

i 14 MS. CURRAN: Well, shall we take an example, maybe i

I 15 it would help to go through a. example?

j 16 JUDGE BECHHOEFER: Yeah.

1 j 17 MS. CURRAN: Okay.

18 BY MS. CURRAN:

, 19 Q Let me find one and then maybe we can -- okay, all i

i i 20 right. On page five of 12, under "Other Issues", second 1

4 21 bullet, it says, j 22 " Position switches internal to various i

23 safety related valve motor operators

24 were' inappropriately designated as 25 design class two."

i-

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1607 ,

1 And they should have been design class one, okay. Are your' 2 maintenance procedures different for class one equipment i I

3 sometimes and for class two? Are they any,v;e rigorous?

4 A (Witness Giffin) Yes, the procedures are f 5 different in some cases for class one and class two  !

l 6 equipment due to the purchasing of spare parts, that's the j 7 only difference between the two procedures. .

8 Q Would you explain that? f i

9 A (Witness Giffin) If you have a class one j 10 component and you're going to replace something in it you I 11 need to replace that with a class one component.

12 Q All right. So, this is information that whether <

13 something was class one or class two is information that you i

14 would want to have from the -- wherever you got it? l

( 15 A (Witness Giffin) It's information that I get from j

16 the enginee 'ng department, yes. '

17 Q Right. But if the engineering department had not j 18 kept this record correctly then you wouldn't have the l 19 information, isn't that right?

20 A (Witness Giffin) It is possible that, but in this 21 case I believe that this issue is not -- does not impact the 22 seismic qualification. So, in this issue it was not. In l

23 the last sentence in your paragraph.

24 Q Uh-huh.

25 [ Pause.]

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1608 1 Well, how about the next bullet, let's go on to that one?

2 JUDGE BECHHOEFER: Where is it?

3 MR. GIFFIN: Still on page five?

4 MS. CURRAN: Yes.

5 JUDGE BECHHOEFER: Okay.

6 [ Pause.] .;

7 MR. GIFFIN: Last sentence, _

8 "This issue was not discussed further in j 9 this LER as there is no evidence that i 10 maintenance practices have impacted the ,

t 11 seismic qualification of these i 12 operators." .{

13 BY MS. CURRAN:  ;

14 Q But it also says that, 15 "As part of the design change process j 16 .PG&E will-verify the appropriate 17 maintenance activities have been ,

18 performed on these valve operators.",

19 doesn't it?

(Witness Giffin) 20 A That's what it says.

21 Q So, that the failure of the engineering department l 22 to timely update the seismic qualification records on these l

I 23 components could have had an impact on your maintenance of 24 those seismic components, isn't that true?

25 A (Witness Giffin) They could'have, yes, but as O ANN RILEY & ASSOCIATES, LTD.

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[' 1609 1 evidenced by this report, they did not.

2 Q Okay.

3 MS. CURRAN: I don't have any other questions on j i

4 this.  !

5 JUDGE BECHHOEFER: Staff?

l 6 MS. HODGDON: No, I have no questions.

7 REDIRECT EXAMINATION l 8 BY MR. REPKA: $

i I 9 Q Mr. Giffin, where was the responsibility for -

10 closing out this LER? l l

i 11 A (Witness Giffin) This is an engineering LER and }

t l

12 an engineering non-conformance report and responsibility for j i

13 closing this out was with the engineering foreman, j 14 Q Okay and just to make sure I'm entirely clear 15 here, the equipment that was installed in the plant was l l

16 appropriate? j l

17 A (Witness Giffin) That's correct.

18 Q And the equipment was appropriately maintained? ,

1 19 A (Witness Giffin) That's also correct.

20 Q And the designation of seismic qualification was, 21 as far as your treatment was concerned, it was appropriate?

22 A (Witness Giffin) That's also correct.

23 Q It's just a matter of the documentation file 24 needed to be updated?

25 A (Witness Giffin) That's also correct.

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I 1610 I

1 MR. REPKA: I have no further questions. l 7-r 2 MS. CURRAN: I'd like to ask a follow-up question 3 to that.

4 RECROSS EXAMINATION

, 5 BY MS. CURRAN:

6 Q Isn't it true, Mr. Giffin, that this review l

7 involved more than mere documentation, that some analysis l l

8 had to be done to verify that this equipment was seismically 9 qualified, isn't that right?

10 A (Witness Giffin) That's also correct.

11 Q Okay. So, it wasn't just a matter of writing  ;

12 something down that was already somewhere else, someone had 13 to do a calculation and make a determination?

l 14 A (Witness Giffin) That's --

l 15 Q At least in some of the cases?

16 A (Witness Giffin) That's also correct.

I i

! 17 QUESTIONS BY THE JUDGES 18 JUDGE BECHHOEFER: In terms of operation, 19 operational activity, is there any use made at all by the 20 company of the seismic qualification files for a particular l

l 21 piece of equipment? In terms of every day running of the 1

22 plant? I l

23 MR. GIFFIN: Every day running of the plant, from i

24 an operations point of view or a maintenance point of view, 25 not to my knowledge. The engineering department may do 1

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1611 l

l 1 something with the files that I'm not aware of. I know that O- 2 when you order a replacement part you check the files to 3 insure that whatever requirements that were unique to that 4 analysis were incorporated in the piece of -- or the 5 components you bought. But the day to day operation, no, it 6 could be used, however, when you replaced something.

7 JUDGE BECHHOEFER: Does the NCR staff ever audit 8 the files that you referred to?

9 MR. GIFFIN: I don't know the answer to that.

10 JUDGE BECHHOEFER: The ones in San Francisco?

11 MR. GIFFIN: I don't know the answer to that.

12 JUDGE BECHHOEFER: Yeah.

l 13 JUDGE KLINE: If you'd been called upon to repair i

14 one of these level transmitters prior to the time that the 15 seismic qualification documentation was remedied, would that 16 have handicapped your repair effort in any way?

17 MR. GIFFIN: No, we would have repaired it using 18 the equipment that was installed. I can't go out and do

19 maintenance on something and change a component without the 20 engineering department's approval. I can change like for l 21 like, part for part. So, in this case, if I had to replace 22 one I would have had to have replaced it like for like. And 23 if I --

24 JUDGE KLINE: You didn't need this documentation 25 in order to do a repair?

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1612 1 MR. GIFFIN: 'That is correct, I did not.

2 JUDGE BECHHOEFER: Well, if you were replacing 3 something part for part would it matter then what was listed 4 as the proper part in your qualification files? If you'had 5 the wrong listing and you were replacing part for part, 6 would you might order the wrong part? ']

7 MR. GIFFIN: Well, I -- if it's installed,.as t

8 these were, and determined to be qualified, as'long as I l l

9 maintain those level transmitters the way they were it was j 10 all right. If I wanted to order a different level-11 transmitter I couldn't do that, I'd have to get engineering 12 approval and then they would have had to go through their i

13 files and tell me what else to buy.

14 JUDGE BECHHOEFER: Right. But if you wanted to O 15 order the same one and you picked -- happened to pick the i

i 16 one that was in your qualification file and ordered whatever .

17 it listed in that file, could that amount to a mistake l -

18 because it might be different from the item actually in l 19 service?

20 MR. GIFFIN: Well, I don't usually -- when I order i 21 something --

l 22 JUDGE BECHHOEFER: Let's say you had to replace it 23 or --

24 MR. GIFFIN: -- I don't go to the file, I go to 25 what's in the plant and then I try to order that component.

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1613 j i

1 And if for some reason somebody doesn't make that anymore  :

O 2 then I find out what's a substitute, then I work with l

j 3 engineering to determine what's a valid substitute. So, I 4 replace, try to replace what's in the plant. So, I -- the 5 only time the file would be used would be if engineering was 6 trying to find a substitute.

7 JUDGE BECHHOEFER: I see, okay. Do you have 8 anything further? Any follow-up?

9 MS. CURRAN: Just one minute. ]

10 JUDGE BECHHOEFER: Okay.  ;

i l 11 [ Pause.] ]

12 MS. CURRAN: I don't have any other questions and 13 unless there are other questions we would move Exhibit 131  ;

"' 14 into evidence?

i 15 MR. REPKA: I'll oppose admission of this exhibit 16 as having no bearing on maintenance.  ;

17 MS. CURRAN: Well --  ;

l I 18 JUDGE BECHHOEFER: I want to hear what you have to 19 say.

20 MS. CURRAN: Okay. In the LER itself, at least j i

21 for one of the examples, it says that as part of the design j 22 change process PG&E will verify that appropriate maintenance 23 activities have been performed on these valve operators.

24 Now it may be that for in this particular instance that  ;

25 nothing changed in the maintenance program because it turned

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1614 l

! 1 out that the equipment was seismically qualified anyway.

2 I think the point here is that PG&E needs to have ,

3 some process for incorporating this information into the 4 maintenance program and verifying whether changes do indeed 5 need to be made and that there is a shortfall here, a 6 failing in that the engineering department did not do this 7 in a timely manner. And there's no evidence that there's 8 any systematic program to do a kind of review, the same kind 9 of review that was done for the class one electrical 10 equipment.

11 MR. REPKA: There's no evidence here of any 12 maintenance failing and there's no evidence that says that 13 the files are important to the day to day maintenance of the 14 equipment.

15 [ Pause.]

16 JUDGE BECHHOEFER: This one we don't think is 17 relevant to the Contention, so, we will not admit this l 18 document. '

I 19 MS. CURRAN: We would like to object to your 20 ruling and offer this as a proffer of evidence of the 21 inadequacy of the maintenance program at Diablo Canyon for 22 the reasons that I stated a minute ago.

23 JUDGE BECHHOEFER: Right. Yeah, that's, I think i

24 anytime we reject a document I don't think you have to l 25 repeat it for the record, but you're welcome to.

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- 1 MS. CURRAN: Okay.  !

I s You automatically can take 2 JUDGE BECHHOEFER: l

)

3 exception to that without your so noting on the record.

4 MS. CURRAN: All right. The next category -- l l l I well, the next Exhibit is number 132, which is LER 1-91-021-5  ;

6 00, August 28th, 1992.

7 JUDGE BECHHOEFER: Do we have this one?

8 MS. CURRAN: Oh, we don't have it?

l 9 [ Exhibit 132 passed out.]

1 10 MR. REPKA: Does everyone have that? l 11 MR. ORTORE: We're ready.

l 12 DIRECT EXAMINATION 13 BY MR. REPKA:

I /" N 14 Q Okay, Mr. Ortore, this LER reports, does it not, l

15 an incident of a sheared motor pinion key in a Limittorque 16 motor operator?

17 A (Witness Ortore) That is correct. ,

l 18 Q When did that sheared key incident occur? Not so  !

19 much in time, but was it during a test or during operation  !

20 of the operators?  !

21 A (Witness Ortore) That was found during a test 22 while the unit was shut down for refueling outage.

23 Q And do we know why that the key sheared?

24 A (Witness ortore) Yes, it appears that the key 25 material was not hard enough or did not have enough

(.

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i  !

i l' 1616 I  !

I 1 strength. In further discussions with the vendor the vendor *

<O 2 believes that the key was of the proper material but has 3 changed their design and is now using a harder or stronger l 4 material.

5 Q Did you look for any other'similar sheared keys 6 when this occurred?  !

7 A (Witness Ortore) Yes, we did look at other 8 similar type actuators that could possibly have-the same key l 9 and we changed all the Unit 2 keys as appropriate. ,

10 Q Did you find any more that were sheared?

11 A (Witness Ortore) Yes, we did, there were two I

12 other actuators that did have sheared keys and we did 13 replace those.

14 Q Were those actuators operating or operable?

15 A (Witness ortore) Yes, we found after our analysis 16 that all the operators were operable.to perform their safety 17 function.

18 Q Indeed this was a voluntary LER, was it not?

19 A (Witness Ortore) Yes, this was voluntary. _Again, 20 sometimes we submit voluntary LERs just to let the NRC know 21 what's happening in the different plants so that if they 22 need to inform anybody they can.

l 23 Q Because of the generic implications where l 24 equipment is involved? l 1

25 A (Witness Ortore) Correct. )

i

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1617

1 MR. REPKA
I have no further questions.

f--

li 2 MS. CURRAN: Okay. j i

3 CROSS EXAMINATION l I

4 BY MS. CURRAN:

l ,

5 Q Mr. Ortore, isn't it true that this defective key l 6 was only found through a mistake in the test -- the way the

]

7 test was done, isn't that so?

1 i 8 A (Witness Ortore) The scenario that we went

! 9 through that there was a miscommunication between the 10 maintenance personnel performing the test and the operations 11 personnel in the control room and as a result a much higher 12 stress was put on this key than would normally be put on j i

13 during normal operations. l l

f-~ 14 Q So, that's true, it was a mistake in the test that I i 15 led to this discovery?

l

! 16 A (Witness ortore) I believe it was called a 17 miscommunication.

l l 18 The other motor operators that were also Q

19 discovered to have defective keys, did they perform the same 20 function or a redundant function to valve SI28809B?

l l 21 A (Witness Ortore) No, they performed a completely 22 different function.

l 23 Q Okay.

24 A (Witness Ortore) And they were found to be 25 operable even with a sheared key.

r l

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I 1618

-s 1 Q Okay. On page three, it describes the -- how you

\ 2 determine that the motor operators, these other two motor 3 operators were operable and it says, 4 "The motor operators were still capable 5 of stroking the valves due to friction 6 caused by contact between the motor 7 drive shaft and a pinion gear."

8 Was that how the valve was supposed to work?

9 A (Witness Ortore) I guess the key actually just 10 increases that friction, it just -- it's just a more 11 positive lock for that -- where the pinion gear is around 12 the shaft. And that's why I stated before that the valve 13 operated even with the sheared key.

14 Q Right. And when you test these valves there was 15 no pressure differential across the valves, right?

16 A (Witness Ortore) These particular valves are open 17 prior to operation and they are -- the breakers are racked 18 out, power is removed from the breaker and these valves are w

19 not used during operation of the plant.

20 Q They're just safety, they're just for use during i 21 an accident?

l l 22 A (Witness Ortore) No, they are not used during an 23 accident. They have no use during plant operation.

24 A (Witness Vosburg) They have no automatic t

25 function. If you had a large break LOCA, at some point

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1619 1 operators may want to close the valves after the O

\- 2 accumulators had discharged. However, at that point there  !

i 3 would be no difference in the pressure. So, it would be i

4 operating under the same conditions of no DP that were 5 described here.

6 Q Are there any accident conditions under which 7 these valves might be operated under high pressure?

8 A (Witness Vosburg) Not that I know of. As Steve l

9 stated, these valves at normal operation are open and the l l

10 breakers for the -- just to insure that they don't close,  ;

11 the breakers for these valves are open. So, when the 12 plant's normally operating there's no power to these valves 13 to operate, to insure that they can operate. '

t 14 Q So during, say a main steam line break, would that 15 be the kind of accident where you might see high pressure 16 through these valves? l l l' l 17 A (Witness Vosburg) No, these valves -- on a main 18 steam line break these valves wouldn't be operated.

19 Q Okay.

20 A (Witness Vosburg) Now we are talking about 8808A i

21 and B here, right? Okay, I just wanted to --

22 JUDGE KLINE: It's accumulator discharge --  ;

1 23 MR. VOSBURG: Yes, 8808A, yes. l l 24 JUDGE KLINE: That's not true of 8809B.

I 25 BY MS. CURRAN:

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l-l 1620 1 Q Wait a minute. I'm talking about the ones that i 0 2 are mentioned on page three, which is -- which are SI28808B i

3 and 8808D.

4 A (Witness Vosburg) Yeah, those are the accumulator 5 outlet valves, yes.

6 Q Okay. And what you said applies to those valves?

7 A (Witness Vosburg) -Yes, that's what I was talking 8 about when I said that, yes.

9 Q Okay. But as far as the first one that was found, 10 is the same thing applicable to that? The sana -- that it 11 wouldn't be subject to high pressure during an accident?  ;

12 A (Witness Vosburg) And the first one was?

13 Q 8809B.

14 [ Pause.]

15 Oh, wait, I guess that -- now I'm confused because I' thought 16 there were two -- I thought there were three altogether.

I 17 JUDGE KLINE: It's a cold -- like isolation valve, j 18 8809B.

L 19 MR. VOSBURG: There's a long analyis on 8809B in 20 the back I wanted to do.

l 21 [ Pause.)

22 Well, the function of 8809B is to close when'we're l

23 transferring from a cold leg injection to a hot leg recirc 1

24 mode. And to determine whether or not there's -- or any l l

25 flow through the valve at that point, I'd have to review the j i

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1621

}

i j~ 1 operating procedure to be sure, I believe the flow is i' 2 secured when it's closed, but I can't state that for sure.

3 I'd have to review that. I think the analysis.however, ,

4 shows that the torque that's applied to the pinion gear on i

j 5 the shaft that had the sheared key, to evaluate it'that the f l 6 force on the pinion and shaft would not be applied until the f 7 valve had closed. It was when the valve would then torque.

4

8 close, tightly close that the force would be applied and it

) i j 9 could potentially slip. However, at that point the valve i 10 would be-fully closed. So, I think that the analysis shows

) 11 that the valve would close. As far as the DP, I would have ,

4  !

l 12 to review the procedures to answer that for sure. l 3 I

13 BY MS. CURRAN. ,

i i 14 Q Okay. And finally, I'd just like to clarify that

, 15 the sheared pins found on these valves were not found i j 16 until -- well, let me retract that, were these valves the l 17 valves originally, or these motor operators.the motor 5 18 operators originally installed on this valve?  ;

1 i 19 A (Witness Ortore) Yes, they were.  !

20 Q They were, okay. So, that the defect.wasn't found l

{

i 21 until sometime later?

i  ;

(Witness Ortore) 22 A The sheared key was not, again, l a

1 23 the vendor does not think that there was a defect there.

i 24 Q Right. Okay, the. sheared key was not found. l i

25 MS. CURRAN: That's all the questions I have on i .

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j 1622

1 this. And if there are no --

s 2 MR. REPKA: A quick follow-up, just to put a coin ,

I 3 on it.

] ,

i 4 REDIRECT EXAMINATION +

i 5 BY MR. REPKA: l 6 Q Does this voluntary LER reflect, in your opinion, j i

7 a maintenance deficiency in any way? l 8 A (Witness Ortore) No,_not'at all. With the {

9 exception of the miscommunication with operations during the  ;

a i j 10 test. i I-  ;

i 11 Q Thank you.

l 12 MR. REPKA: No further questions. j j .

i 13 JUDGE BECHHOEFER: Staff? l 1 l l 14 MS. HODGDON: No questions. l l 15 JUDGE BECHHOEFER: I have a-couple, f l 16 QUESTIONS BY_THE JUDGES i i I

.. 17 JUDGE BECHHOEFER: There's a statement first, page  ;

I l l 18 two, I guess, the second page that I got anyway, where it l e

l 19 says that the miscommunication resulted from inadequate l 20 procedures. And then later on there's a statemt ' on the d

l 21 last page, page 7 of 7, it's the last one, 22 "That maintenance procedures will be

, 23 revised."

=

24 Could -- can any of you explain what the problem was with 25 the procedures and how, if at all, they are or will be l

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l 1623

! I revised? l

! l 2 MR. VOSBURG: Remembering back, I believe what the 3 problems with the procedures was is that the control 4 switches for these motors are the type that have a closed 5 and then a center neutral position and then an open 6 position. And the switch does not return to neutral but can 7 be left in either the closed or the open position.

]

8 Normally, when you close say for one of these valves, you f 9 close this valve, operators are supposed to return the 10 control switch to the center position. If they leave it.in i 11 the closed position, what happens is the valve closes and. i 12 then it torques and the torque switches pick up and stop the 13 valve from closing. f 14 If you leave the control switch in the closed ,

O- 15 position and then go down to the valve and try to manually j

16 operato it, the first thing you do is, is on a Limittorque,

l. 17 is you lift the lever that disengages it and puts it in a l 18 manual operation mode. When you lift that lever, it relaxes l l 19 those torque switches. So, if that switch is still in the l 20 closed position, it immediately picks up and tries to close 21 the valve again. Well, the valve was already fully closed, 22 so now it tries to drive it in a little further and it puts 23 additional pressure on the key and that's where they feel 24 the key was sheared from.

25 And so, I don't remember if there was a ANN RILEY & ASSOCIATES, LTD.

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i  !

i 1624 ,

1 maintenance procedure that coordinated the box that they ,

O 2 changed to put this caution in. I remember that, I don't l

3 know if we changed the procedure, or put something out in 4 our -- in what we call our standing orders on operation of  :

5 these valves to highlight that point to the operators that  !

6 these switches have to be left in the neutral position. So, f 7 I believe those are the procedures. l 8 MR. GIFFIN: So, it's a note in both procedures.so  ;

1 9 that it won't happen again. It's a note in the maintenance f i

10 procedure to remind and also in the operator's procedure. i 11 JUDGE BECHHOEFER: Right. And that has been done?

i 12 MR. ORTORE: Yes, that has been done. l t

13 JUDGE BECHHOEFER: I'm just wondering about some l 14 language on page 4 of 7, in paragraph 3B. There's a 15 statement that the key material is inadequate. The key  ;

16 material is outdated, but it's still acceptable. Now isn't l

l 17 that somewhat of an inconsistency? It's all in the same 18 paragraph.

19 MR. ORTORE: I think the reason is that the vendor l

l 20 -- they no longer use this material; however, they felt that l 21 it was still sufficient to perform its function. The 22 outdated part was that that material is no longer used.

23 MR. GIFFIN: We felt that it wasn't strong enough 24 and when we talked to the vendor he said it was, but he 25 doesn't use that anymore, he uses a stronger material. But l

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I 1625 1 he'd never say that the material that was in there wasn't 2 strong enough. So, it is kind of confusing, but that's what l

I 3 it means.

4 JUDGE BECHHOEFER: Okay, thank you. Any follow-up l 5 on my questions? )

l 6 MR. REPKA: No.  ;

7 MS. CURRAN: One more question. f I

8 RECROSS EXAMINATION j 9 BY MS. CURRAN:

10 Q Have you done investigations to determine whether  ;

1 11 these defective pins exist in any of the other motor  ;

12 operators? .

13 A (Witness Ortore) We examined the design to make l 14 sure that this material was not used any place else and 15 those operators that did have this material -- did have keys 16 made of this material, all the keys were changed.

17 JUDGE BECHHOEFER: I guess we're through with 18 that.

19 MS. CURRAN: Okay. If there's no other questions 20 then we move Exhibit 132 into evidence.

21 MR. REPKA: No objection. i 1

22 JUDGE BECHHOEFER: Okay. MFP Exhibit 132 will be l 23 admitted into evidence. i l

24 [MFP Exhibit 132 was 25 received in evidence.]

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l 1626

-~g 1 MS. CURRAN: Okay. The next set of exhibits are, '

2 Exhibit 134, -- oh do you have -- you don't have -- you do 3 have them?  ;

, 4 JUDGE BECHHOEFER: Yes, we have that.

5 MS. CURRAN: Which is PG&E's reply to NOV dated P

6 August 5th, 1992. Exhibit 135, which is LER 1-91-004-02, j 7 special report 91-02-R1, diesel generator 1-1 failure to l 8 load within TS limits, dated July 29th, 1992. And Exhibit 9 136, which is NCR DCl-91-MM-N028, which is dated October 10 23rd, 1991. And then Exhibit 137, which is inspection 11 report 92-16, dated July 7th, 1992. And Exhibit 137 was 12 passed out yesterday in connection with the thermolag issue 13 and so --

4 14 MR. REPKA: Does it have a thermolag number?

! 15 MS. ZAMEK: No, it's 137.

1 16 MS. CURRAN: Passed out as 137.

i 17 MS. ZAMEK: And I have one extra.

18 MS, CURRAN: Would you like to look at our extra 19 copy? Okay.

20 [ Document reviewed.]

21 JUDGE BECHHOEFER: Would the Mothers of Peace 22 check Exhibit 134, we're not sure whether it's a missing 23 page or whether page three should be page --

W 24 [off the record.]

25 JUDGE BECHHOEFER: Back on the record.

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i  !

1627 j 1 MR. REPKA
Okay, MFP has introduced what's been -

2 identified as MFP Exhibits 135, 136 and 137. And.the_way I l 1

l 3 understand it, what was previously identified as MFP Exhibit

4 134, the PG&E reply to an NOV, that that document dated
  • 5 August 5th, 1992, MFP is withdrawing that one. And what I'd j 6 like to do is identify that document previously identified i j

i 7 as MFP Exhibit 134 as PG&E Exhibit 27. And do the witnesses .

i. I i 8 have a copy of all four of those exhibits in front of them? i 9 MR. GIFFIN: Yes, we do.  !

t 10 MR. REPKA: Is everyone ready?

s 11 MR. GIFFIN: We, think so. I

12 DIRECT EXAMINATION {

j 13 BY MR. REPKA: .

J l i 14 Q Okay, gentlemen, these documents together appear lO i l 15 to address two separate issues, is that correct? I 1

16 A (Witness Giffin) Yes, they do.

17 Q What are those two issues?

18 A (Witness Giffin) The two incidents are a 1991 l 19 loss of off-site power caused by a mobile crane coming in

20 close proximity with a 500 kV line that was energized. The j 21 second is the final rigging and adjusting the lid on a rig i

i 22 shipping cast, and those are rigging incidents.

J 23 Q Okay, with respect to the first of those.

5 24 incidents, the 1991 loss of off-site power, was that event 25 the result of a personnel error?

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i i

1628 l 1 A (Witness Giffin) Yes, it was.

lO i

2 Q And was the error made by a person in performing maintenance work?

3

)

l 4 A (Witness Giffin) _Yes, it was.

f 5 Q And were corrective actions _taken?

6 A (Witness Giffin) Yes, they were.

l 7 Q Have you had any subsequent losses of off-site 4

2 8 power?

j 2

9 A (Witness Giffin) No, we have not.

l 10 Q Or any subsequent cases of mobile crane booms l-j 11 coming too close to power lines?

j 12 A (Witness Giffin) No, we have not.

13 Q Did PG&E receive a notice of violation for that 14 loss of off-site power event?

15 A (Witness Giffin) No , we did not.

1 .

16 Q Let me turn to the second of the two incidents, l

! 17 the incorrect chain-fall incident?.

i j 18 A (Witness Giffin) Yes.

i

! 19 Q Was that also an instance of personnel error?

! 20 A (Witness Giffin) That was an instance of i

j 21 personnel error.

f l 22 Q Was that error made in the conduct of maintenance t

i 23 activities?

I 24 A (Witness Giffin) Actually not.. They were --

l 25 there was a cask and they were putting the lid on it and l ANN RILEY & ASSOCIATES, LTD.

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I I

l 1629 l l

1 getting it ready for shipping. So, it was not performing-  !

i  !

2 maintenance on a plant system, on a -- no plant SSEs were i 3 having maintenance performed on them when this occurred. j t

4 Q And it was a case where the seating of the cask 5 lid was not performed correctly? l l

6 A (Witness Giffin) Yes, what the.-- the shipping j l

7 cask has a lid that goes on it and it's a tight fit, it's  !

l 1 I 8 like putting a glass stopper in a bottle and if it goes in l

l 9 at an angle then it won't, but it's a real tight fit. And  :

10 they were putting it down and they had slings on it and the ,

11 slings didn't have the cask lid level. It was sitting on it-12 and they took two of the slings off and put two chain-falls j 13 on it to level it and then put it down in place. And it  !

i 14 only had two more inches to go'to seat. j Ow 15 Q So, was that two inch discrepency then identified? ,

16 A (Witness Giffin) Yes, it was. The issue was that 17 the two chain-falls that were being used were one ton chain-18 falls and after we went back and looked at it they probably l 19 had about 2400 pounds on them, each, instead'of the 2,000 l

20 pounds that the chain-falls were -- that the basic rating of 21 the chain-fall.

22 Q And that error was the subject of a notice of 23 violation from NRC?

24 A (Witness Giffin) Yes, it was.

25 Q And was PG&E's reply to that NOV, was that the

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Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 l (202) 293-3950 I-

-!i l l j

1630

{ 1 document that we've identified as PG&E Exhibit 277 f 4 )

8 2 A (Witness Giffin) Yes, it is.  !

i 3 Q Now standing back and looking at.these two  !

i 1

i 4 separate incidents, the loss of off-site power-and the l 6

ll 5 incorrect chain-fall episode, are they related to each other

! 6 in any way? j i i 7 A (Witness Giffin) I don't believe they are. When l l 8 we answered the notice of violation we added an enclosure l t i d

9 where we stated that we did not believe that the two were I i  !

l 10 related.

i 11 MR. REPKA: I have no further questions.

-f i

- 12 CROSS EXAMINATION

- i 13 BY MS. ZAMEK:

2 l

$ l J 14 Q I'd like-to bring your attention to Exhibit 136,  ;

j 15 page 10. j 4  !

! 16 A (Witness Giffin) Yes.

}

i 17 Q Mr. Giffin, you mentioned that the incident was i i' 18 the result of personnel error, but doesn't it also say that l

) 19 the foreman did not follow the accident prevention rules and 20 did not recognize the electrical safety issues during job i

! 21 planning and execution?

! 22 MR. REPKA: So that the record is clear, can I ask j 23 what incident we're referring to specifically here?

24 MS. ZAMEK: The one in Exhibit 136, it's the loss

] 25 of off-site power.

i i

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l 1631 5

_, 1 MR. GIFFIN: It's loss of off-site power, October, A- 2 '91.

3 MR. REPKA: Thank you.

4 MR. GIFFIN: Or March of '91. It says the root i 5 cause is personnel error in that. I still stand by it was l

l 6 personnel error on the part of the foreman, crane operator 1

  • 7 mainly. The rigger just happened to be there. Regardless  ;

l

! 8 of what this says, it was the foreman and the crane l

, i l 9 operator's fault, not the riggers.

10 BY MS. ZAMEK:

11 Q Okay. And under contributory causes, the foreman 12 was not adequately involved in the task. Would you consider l

l 13 that as part of the root cause? ,

I 14 A (Witness Giffin) We consider that as a l

O 15 contributory cause. So, --

l l 16 Q So, they're different? )

i 17 A (Witness Giffin) Yes.

18 Q I noticed in that event that there were other l 19 systems that were affected?

l 20 A (Witness Giffin) Oh, yes, when you lose off-site l

l 21 power, a lot of systems are affected. We lose all non-vital 22 -- lights go out, things don't -- that used to be working, i

23 stop working because it doesn't have power.

24 Q There's a list here, I'm trying to find it on page 25 five, under "D",

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1632 1 "Other systems or secondary functions 2 affected."

3 It lists on the next few pages, up through page nine, it 4 lists 18 affected systems. Can you read through them and 5 then tell me which ones are significant to safety?

6 A (Witness Giffin) Sure. l l

7 [ Pause.)

8 A (Witness Vosburg) Well, the first system listed i

9 is the auxiliary building ventilation system. That system's  !

i 10 primary function is to, in the event of an accident, provide i 11 cooling to safety related pumps and motors located in the ]

12 auxiliary building. In this case there was a failure of a l

l 13 capacitor in a power supply and I believe it's in the logic i

14 panel that controls that ventilation system and so the ,

15 system did not restart when power was restored.

16 Q And that also is a safety significant --

17 A (Witness Vosburg) In this case there was no ,

18 accident and there was a loss of off-site power, there was 19 not an accident where you had to operate ECCS pumps and l

l 20 motors at all, let alone for long-term, long time periods l

21 with hot fluid in them. So, there was no safety connection l 22 there.

23 A (Witness Giffin) The second issue is not a safety 24 issue even though the system is safety related, but 25 ventilation mode just shifted to another mode.

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1633 s

i 1 [ Pause.]

O 2 A (Witness Vosburg) In the control -- there's the 3 emergency lighting system in the control room, there's a 4 seprate inverter that feeds the emergency lighting for both i

5 Unit 1 and a different one for Unit 2. When this happened, 6 and non-vital power was lost, the lighting on the unit, this ,

7 is a common control room, and the lighting on the half of

)

I 8 the control room that unit one is on, the emergency lighting 9 did not come on. So that would be normal lighting supplied 10 from that inverter. So there are, the lighting on the other 11 side of the room was on, there was plenty of light in the 12 control room and there was additional emergency lighting, 13 battery operated lights that all come on in the control room 14 when the back-up emergency isn't there.

15 MR. REPKA: Ms. ZamEk, do you really want to go 16 down all of these?

17 BY MS. ZAMEK:

18 Q No, I do not want to go -- I just wanted you to 19 kind of briefly go through and just say numbers one and five 20 and six and -- <

21 A (Witness Giffin) In order for me to do that, or -

22 for Mr. Vosburg, we're going to read each paragraph, 23 determine what the plant was doing and then make the 24 decision. i 25 A (Witness Vosburg) Some of them may be quicker.

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i  !

.l l 1634 l 1 Q All right, so maybe you can just get back with me i i 2 tomorrow on that?  :

i 8

3 A (Witness Giffin) The licensing event report goes  ;

j 4 through the safety analysis and does what we're doing now.  !

5 We can -- I'll go through it one at a time I guess, j

+

l 6 Q All'right.  !

i 7 A (Witness Giffin) Whatever.

I i

) 8 MR. REPKA: I suggest we just let the document  ;

! i 9 speak for itself on that because the safaty analysis is  ;

j t  :

j 10 there and --  !

1 11 MS. ZAMEK: There is a safety analysis here, so, i i

j 12 okay, let's move on.

l l 13 BY MS. ZAMEK: .

3 .

l

] 14 Q Let's turn to Exhibit 137, regarding the chain- '

15 fall incident on page three. Well, I'd like to point out i i

l~ 16 something on page four.

17- [ Pause.]  ;

i 18 Somebody said that these two incidents weren't related but I .

2  :

I 19 related them because in this inspection report, I quote, 20 "The inspector acknowledged that two l 21 different groups of personnel were i

{ 22 involved, but noted that both events i

I 23 appeared to involve weakness in the pre-4 24 planning and control of lifting or.

t 25 rigging activities."

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~

l 1635 1 Would you agree with that, that they are connected in that 2 way?

3 A (Witness Giffin) No, I do not. And as I stated 4 in our reply to the notice of violation, we took exception 5 with that. And if you'll read even in this document it says 6 the manager of maintenance services disagreed with that. I 7 disagreed with it then, we disagreed with it when we sent in 8 the notice of violation response and I disagree with it 9 today.

10 Q Okay.

11 MS. ZAMEK: I don't have any further questions.

12 [ Pause.)

13 MR. GIFFIN: There's one thing I'd like to add 14 about this and it's the first event, the loss'of'off-site 15 power event. As you go through that we did'a couple of 16 really -- we looked at this as soon as it happened, we were 17 really concerned about the usage of cranes, that people 18 could really be hurt. I mean 500,000 volts is a tremendous 19 problem. We were in the middle of an outage. We stopped 20 work on the outage for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and made the crews and their 21 foremen get together and talk about safety. So, in the 22 middle of this outage that we wanted to complete in 60 days 23 or so, we stopped all the work so that we could stress the 24 importance of safety and following the rules. ,

i 25 The plant manager and I and the outage' manager all ANN RILEY &_ ASSOCIATES, LTD.

Court Reporters I 1612 K Street, N.W., Suite 300 Washington, D.C. 20006

'(202) 293-3950 l.

I 1636 1 talked to all supervisors that day and told htem how we O 2 wanted to get that information to their people. We l 3 instituted an event incident plan, I think, an EIT we call 1 1

4 it, where we have a senior manager come down and look into l

5 this. The NRC sent an AIT to look into this. 'And when the I 6 AIT got on the site almost all the work had already been ,

7 done for them so it made the investigation a lot easier. {

8 We took this very seriously and I think that the l 9 corrective actions that we've implemented have.been very i 10 good. j l

11 [ Judges confer.] l i

12 JUDGE BECHHOEFER: Are these, any of these being I 13 offered at this time?

l. 14 MS. ZAMEK: Yes, I was waiting to see if you had l

l 15 any questions. Yes, --

16 JUDGE BECHHOEFER: Pardon?

17 MS. ZAMEK: -- they're being offered into 18 evidence.

19 JUDGE BECHHOEFER: Yeah, all except, I guess l

20 there's a Staff, 137 is a Staff.

l 21 MR. REPKA: I'd like to also offer PG&E Exhibit L 22- 27.

t i 23 JUDGE BECHHOEFER:-'So, we have 134,.5 and'6 and l i

I 24 PG&E 27.

25 MS. HODGDON: Judge Bechhoefer, I'd like to make  ;

! i

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1637 1 a --

2 JUDGE BECHHOEFER: Oh, no, not 130 -- let's see, 3 135 through 137, plus PG&E 27.

4 MS. HODGDON: Except not 137, it's a Staff ,

1 5 document.

6 JUDGE BECHHOEFER: Yeah, yeah. 137 is still 7 before us but it is not offered at this time.

8 MS. HODGDON: Judge Bechhoefer, I'd just would 9 like to make an observation and that is with regard to the 10 extended questioning about these incidents being related or 11 unrelated. And that is in the Board's pre-hearing 12 conference order of January 21st, 1993 in which it rejected 13 Mothers For Peace Contention Two regarding personnel errors.

14 That the Board made the observation -- the basis, amongst i

^

15 other things was this document that's offered in evidence as 16 Exhibit 137, the Staff notice of violation.

17 It says that we agree that these incidents or 18 statements represent unrelated and widely diperate personnel 19 incidents that collectively do not appear to amount to a f 20 failure of either the personnel program or related training 21 programs. Unlike the numerous incidents cited in Contention 22 One that relate, for the most part, to the specific 23 maintenance and surveillance programs, the incidents cited 24 here have no apparent common focus. For that reason, we are 25 rejecting Contention Two.

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)

i 1638 l 1 That's, I mean I don't know how the rule of the j 2 case applys to this, but it was and in any event all of f

l 3 these incidents were rejected as a basis for Contention Two.

l l

4 [ Pause.] r 5 JUDGE BECHHOEFER: I was trying to see if we said 6 anything about ones that might also be applicable to One.  !

7 MS. HODGDON: You did, but it didn't include 1 8 those. You said -- ,

i 9 JUDGE BECHHOEFER: That's what I wanted to check. l 10 MS. HODGDON: -- to the extent that the CFCU was 11 in maintenance but the personnel mistakes there should be' )

12 considered in Contention One. Did you want a -- I have the ,

13 unpublished version, I can't remember what page it was on. l 1

14 JUDGE BECHHOEFER: That's what I'm reading.

15 MS. HODGDON: It's on page 26. What I was reading (

I 16 from is on page 30 and the part you want to find is right, j 17 the next sentence, "we note however". The second full 18 paragraph on page 30.

19 JUDGE BECHHOEFER: Yeah, the note however is.what 20 I want to see what I said.

21 MS. HODGDON: Yeah, the note however is where you 22 want it to start, I think.

23 JUDGE BECHHOEFER: Yeah.

24 MS. HODGDON: Where I left off.

25 [ Judges confer.]

l l

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[

i 1639 ,

1 JUDGE BECHHOEFER: I'd like to inquire whether the i

2 Staff, in particular, but any party is objecting to these l l

3 documents being put in under Contention One, notwithstanding  ;

4 the fact that we did not accept them as a basis for a l 5 separate contention and we did not specifically mention them (

6 either? ..

7 MS. HODGDON: You did not specifically mention? I 8 JUDGE BECHHOEFER: These as specifically litigable l i

j 9 under One.

10 MS. HODGDON: No, they were specifically i 11 excludable under Two, was my point.  ;

12 JUDGE BECHHOEFER: Right. l l

13 MS. HODGDON: Not that they were specifically j l

14 admissible under One.

l ,

15 JUDGE BECHHOEFER: Right, but this is sort of a l l I 16 grey area. I guess we just --  !

17 MS. HODGDON: My point was that it was not a grey i i

18 area, that this Contention hasn't been rejected on -- for '

19 the rationale that because these documents did not support 20 the theory now offered by Mothers For Peace. That's the 21 reason this Contention Two was rejected. It seems odd that 22 they should now come in for another when'it's already 23 specifically been found that these incidents were not 24 related, particularly the one that's now said to be, the two I 25 that are now said to be related, the chain-fall incident and l 1

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-- . . . = _ - . . - - , . .. - - - -

l l

l t

1640 l 1 the loss of off-site power event. Those were two of the s 2 incidents already considered by the Board and the Board 3 found that there was no relationship between them.

l 4 JUDGE BECHHOEFER: To each other, but is there a 5 relationship to maintenance and surveillance?

l 6 MS. HODGDON: I don't see it.

l 7 JUDGE BECHHOEFER: That's the question I'm I

8 raising, because it bears upon whether we admit the 4 l

9 documents or not.

! 10 MR. REPKA: Let me state for the record that the 11 witnesses have already testified that the incident regarding 12 the chain-falls has no bearing on maintenance, it wasn't 13 maintenance personnel and it wasn't a maintenance activity.

s 14 The loss of off-site power did involve maintenance 15 personnel. And I think the record is also clear that 16 there's no relationship between the two events.

i 17 In the interest of time here, I'm not objecting to 18 the admissibility of these documents and in fact move also l

19 that PG&E Exhibit 27 be admitted, but I would like to I

20 reserve the opportunity in findings to cite to the Board's j 21 prior ruling with respect to these events as an additional ,

22 factor to be considered in addressing these particular 23 documents.

24 JUDGE KLINE: I want to just observe that we are 25 being flooded here with literally hundreds of pages of ANN RILEY & ASSOCIATES, LTD.

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l l 1641 1 documents a day. There isn't the remotest possibility that 2 we can digest these documents as they're presented. And for

! 3 that reason I would just prefer to be liberal in accepting l

l 4 them and not get into an argument. We are not screening '

(

5 effectively these documents, we understand that. There  ;

6 isn't any possibility that we could. So, my inclination is 7 that unless they're just utterly out of the picture is to go 8 ahead and take them. We're going to have to screen them ,

9 later anyway. ,

I 10 JUDGE BECHHOEFER: Yeah, I might add that --

11 JUDGE KLINE: We're at a terrible disadvantage 12 here because we've never seen these things before.

13 MS. HODGDON: Neither have we.

14 JUDGE KLINE: Yeah. And there's hundreds of pages 15 a day. So, there's no point in making a pretense that we're 16 really analyzing these things'as they come in. We just 17 can't be doing that.

l 18 JUDGE BECHHOEFER: Right. We are asking questions 19 occasionally to see how they tie in to surveillance, 20 maintenance, et cetera, which is the subject of the 21 contention.

22 MR. REPKA: I would like to also state for the 23 record, though, that the conduct of the proceeding is not 24 exactly how we would have foreseen it back in January. I l

l 25 think it was clear that at that time that the incidents to

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1642 1 be relied upon would have been identified much earlier in .

l O 2 the process so that we could have prepared direct testimony l 3 on those, l

I 4 We are faced with a lot of information, a lot of 5 documents. The witnesses have been doing a yeoman's effort  !

i 6 not only on the witness stand but in advance and preparation  !

7 for these hearings to filter through these documents and try  ;

8 to understand what they are. I 9 We are trying, through as brief a cross  !

10 examination as we can do, to do some kind of screening for 11 the Board, but he also feel we are at a bit of a  !

12 disadvantage by the conduct-of the proceeding.

13 MS. CURRAN: Well, as long as yeoman's efforts are-14 at issue here, I would like to -- I would like to commend 15 Ms. ZamEk who has, as a nontechnical person, singlehandedly l l

16 reviewed this mountain of documents in what I must say is a )

17 very short period of time.

18 Was not -- this schedule was not Mothers for i

19 Peace's choosing. We accepted it. It was a very limited 20 schedule, and Mothers for Peace has attempted to collect and 21 digest this massive information as quickly as they could.

22 It was not our choice to do it in'such a rushed manner, but i

23 PGEE seemed to be in a hurry to get this decision made. i 24 The Board wanted to make a decision, and here we are.

25 [ Applause.)

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i

l 1643 1 JUDGE KLINE: All my comment is that we're making l

2 decisions that favor Mothers for Peace, I think, by liberal l

l 3 admission of documents, and I don't see how we can screen 1

4 them more critically. However, I believe that had there 5 been time we could have screened them more critically.

6 MS. HODGDON: Excuse me. If I may, just one other 1

l 7 observation from the Board's pre-hearing conference order, 8 and that is the sentence at_the bottom of page 25 at the end 9 of the ruling on Contention 1 where it says, 10 "To the extent that MFP is asked to do 11 so, however, it must identify prior to 12 hearing all of the incidents on which it 1

13 intends to rely on advancing and going

]

14 forward with its contention."  ;

i 15 MS. CURRAN: And that Mothers for Peace did.

16 JUDGE BECHHOEFER: Yeah. I did receive a very 17 lengthy list of documents, which I didn't get through most 18 of.

19 MS. CURRAN: And the' documents were organized 20 according to incident, and later on we provided -- i l

21 JUDGE BECHHOEFER: To some extent. )

22 MS. CURRAN: As soon as we could after that, we 23 provided PG&E with a list of exactly what in those 24 documents. ,

! 25 MR. REPKA: Just so the record is clear,-I'm not ANN RILEY & ASSOCIATES, LTD.

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l I i

1644 j i

1 questioning anybody's effort by the Board, PG&E, the NRC 2 Staff or anybody. The fact is we asked for an  ;

l I

3 identification of incidents in our discovery requests very 4 early in this proceeding. We were told on several occasions  ;

5 by Mothers for Peace that that couldn't be done yet, and we  ;

i 6 heard that several times.  !

7 'In June, we received a list of documents, a very l l

i 8 lengthy list of documents with no effort to show what

\

9 exactly the incidents were. We could prepare our direct i

10 testimony only on the incidents-we knew of. l 11 With respect to the later identification of what 12 the incidents were and how the documents related to those 13 incidents, we got that only last week. Now, that document 14 did, in fact, represent a tremendous effort by Ms. Curran, .

15 and we've noted that amongst ourselves many times, but the 16 fact of the matter is we only got that last week and  ;

i 17 couldn't address them in direct testimony. So, you know, j i

18 that's just the reason why~we are where we are. t l 19 JUDGE BECHHOEFER: Right. And, of course, we 20 didn't get'this until we showed up here.

21 MS. HODGDON: Neither did we.

22 JUDGE BECHHOEFER: Right. So I'm not trying to 23 fault or blame anybody, but we've tried to do our best in a

! 24 very short time before the questioning to digest these 25 documents. We would not have succeeded by any means, and l

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l 1645 1 the questions we asked are often just what we see on the O~ 2 face real quick, and, if we thought about it a little more, 3 we might have more. So that's the way --

4 MR. WARNER: And PG&E certainly concurs with Judge 5 Kline's and the Board's sentiment, in terms of moving this 6 process forward, and it's really only wherc the Board itself 7 may identify on the face of a document that it does not 8 relate to maintenance such as maybe in this chain-falls case 9 that the Board itself may want to take that approach, but, 10 Mr. Repka stated, it's important just to move forward, and 11 we understand the approach in order to do this in as 12 efficient a manner as possible.

13 JUDGE BECHHOEFER: All right.

14 [ Judges confer.)

15 MS. CURRAN: Is there an objection on the table?

16 MR. REPKA: Not from me. I stated my position. I 17 have no objection subject to the right to use the Board's 18 decision later as a basis to argue as to the relevance and 19 weight of the evidence.

20 MS. HODGDON: Well, I understood the Board to say 21 that they would rather admit a relatively worthless document 22 than to reject one that might not have anything in it that 23 was relevant, and, on that understanding, I wouldn't object 24 either with the caveat recited by Mr. Repka.

25 JUDGE BECHHOEFER: Well, the Board has decided to f

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Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

t l

J 1646

{

1 accept this package, but note that we do perceive certain j O 2 differences, particularly between loss of off-site i

1 3 chain-fall, and we may well treat them differently, i 4 notwithstanding that we're not going to take the scissors ,

5 and try to cut out paragraphs dealing with one or the other. l l

6 We do find a difference and, of course, in  !

7 proposed findings, the parties can deal with that. So  :

l 8 subject to that, perhaps, caveat, we accepted those into  ;

9 evidence. Well, the Staff report is not before us right 10 now, but, other than that.  !

j 11 Let me just go over the ones we're accepting.  !

i 12 We're accepting PG&E 27,.and I guess Mothers for Peace 135 l l

13 and 136. Those documents are admitted into evidence.  ;

I 14 [PG&E Exhibit No. 27 was O 15 received in evidence.]

j 1

16 [MFP Exhibit Nos. 135 and 17 136 were received in 18 evidence.]

19 MS. CURRA.i: Judge Bechhoefer, I just want to let 20 you know, there's quite a few documents in the next topic.

21 So, in you want to take a break now or later, it just may 22 take a little while to get through the next topic.

23 JUDGE BECHHOEFER: Let's take our afternoon --

24 let's take our break for 15 minutes.

25 [ Recess taken from 2:55 p.m. to 3:10 p.m.]

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1647 1 JUDGE BECHHOEFER: Are you, Mothers for Peace, 2 going to rely now on more than -- I was looking at your road 3 map -- 138 to 140?

4 MS. CURRAN: That's where I'm headed next?

5 JUDGE BECHHOEFER: Or does it go through 142?

6 MS. CURRAN: I'm sorry. Did you say?

7 JUDGE BECHHOEFER: It's 138 through, what is it, 8 142, the group?

I j 9 M3. ZAMEK: Yes.

10 JUDGE BECHHOEFER: Okay. I just wanted to l

l 11 determine that.

12 MS. CURRAN: Yeah. Okay.

13 [ Pause.)

(N 14 MS. CURRAN: So let me go through these.' The 15 exhibits are Number 138, which is NCR DC 1-92-EM-N010, dated 16 July 29, 1992; Exhibit 139, which is Inspection Report 92-l 17 05, dated April 17, 1992; Exhibit 140, a letter from l

18 Zimmerman to Rueger, dated April 16, 1992, enclosing 19 Inspection Report 92-13, dated April 15, 1992; Exhibit 140-20 A, which is LER 1-92-002-00, dated April 3, 1992, and 21 Exhibit 142, which is NCR DC 1-91-TI-N045, dated June 10, j 22 '91.

23 Exhibit 141 turned out to be a duplicate, so we 24 admitted it.

25 MR. REPKA: Okay. We have those documents, and

[~)

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i i

1648 1 I'd just like to point out for the record that Exhibit 140 2 is not an inspection report. It's a summary of a management l l

3 meeting.

4 MS. CURRAN: Okay. Let's see. Oh, well, let's j 5 see here. Yeah. The reason that we called it an inspection 6 report was it gave a report number, but maybe that's not an 7 inspection report.

8 MR. REPKA: It has a report numbered 92-13, but 9 it's not an inspection report.

10 MS. CURRAN: Oh, see here, over on the enclosure 11 list on the back of the letter, on the back of the enclosure 12 letter, it called it an inspection report.

13 MR. REPKA: Well, whatever. The cover letter 14 says -- j

\~ 15 MS. CURRAN: I don't care what you call it.

16 MR. REPKA: The NRC can tell us what to call it, 17 but --

18 MS. CURRAN: We don't care what you call it. Why 19 don't you tell us, Ms. Hodgdon, what we call it?

t 20 MS. HODGDON: Excuse me?

21 MS. CURRAN: Why don't you tell us what we call l 22 this.

23 MS. HODGDON: Ms. Miller knows about this. I l 24 don't. What do you call this?

l 25 MS. MILLER: It's a management meeting, but our ANN RILEY & ASSOCIATES, LTD.

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I I

1649 j

, 1 tracking system is our writings on the document.

2 MS. CURRAN: Okay. So it's an inspection report. f I

3 Can it be identified as an inspection report? Okay.  !

t 4 MS. HODGDON: It's, apparently, just a 5 convenience.  !

6 MS. CURRAN: All right. With that in mind, let's 7 move on to --

i 8 MS. HODGDON: It's an administrative detail. l 9 MR. REPKA: Okay. Gentlemen, do you have those ,

10 documents in front of you that Ms. Curran has identified? j 11 MR. GIFFIN: I think so. j Whenever you're prepared to address i 12 MR. REPKA:

13 them, you can give me a high sign. f 14 [ Pause.)

15 MR. REPKA: Who wants to take ownership? i 16 MR. GIFFIN: I will.

17 MR. REPKA: Okay.

18 DIRECT EXAMINATION 19 BY MR. REPKA:

20 Q Mr. Giffin, there's a mass of documents here and a 21 lot of pages. Is there a way you can spare us all a lot of  !

22 reading and try to characterize what this all relates to?

23 A (Witness _Giffin) There's two events that are in 24 these documents. Including'het management meeting,-the 25 management meeting is -- as you know, it's where we go and ANN RILEY & ASSOCIATES, LTD.

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4 1650

( 1 talk to the NCR, and there's several issues, but there's one N~/

2 issue in here that corresponds to the others.

3 So that's in the main feedwater pump trip issue.

4 So that these documents refer to main feedwater pump trip 5 issues, a nonsafety-related piece of equipment, and there 6 are two particular problems, one with the inverter for the 1'

7 power supply to the speed probes and one failure of a track 8 and hold board so that if you lose, it will stay at the same 9 speed. So those are the issues that are in these documents.

10 Q The second was a failure of a what?

11 A Track and hold board. I don't know what the J

12 number is. I guess it's 142, Nonconformance Report DC 1 13 TI-N045 142. That nonconformance report is -- because it's 14 not a safety-related system, if we want to have a 15 nonconformance, then, by management direction, in this case 16 I directed that a nonconformance be written.

17 Q Okay. Was the problem with the track and hold 18 board resolved?

19 A Yes, it was. It was just a component failure.

20 Q Now, with respect to the inverter to the power 21 supply, I gather that that has a little more of a convoluted 22 history?

23 A Yes, it does. There were several cases where --

24 I'm looking, trying to find a list of dates.

25 A (Witness Vosburg) Look at 138.

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1 1651 1 Q Well, forget the dates for right now. Just tell

} f-( 2 us, you know, in general terms what was the history of this 1

) 3 inverter.

4 A (Witness Giffin) The diverter is a power supply i l

5 to the speed probes for the feedwater pump, and, in an j 6 effort to make the pump more reliable sometime in the early j 7 '90s, late '80s, probably 1989, we put a modification in to 8 have a power supply that had an inverter so it was a more 9 reliable power supply.

10 There were several failures with this system, and 11 we determined that it was less reliable. Then, the last i

12 time that it failed, we made some modifications so that it 13 is a more reliable power supply now, but, in the  ;

(" 14 management --

\m)] 15 Q So what you have -- before you go on, what you had 16 was we're trying to make a modification to make the

]

17 component more reliable?

i 18 A Yes.

19 Q And then it turned out subsequent to that 20 modification it, in fact, failed on more than one occasion?

) 21 A Correct.

1 22 Q And so, then, you continued to work on it until it 23 was resolved?

24 A That's also correct.  ;

1 25 Q And then did you ultimately achieve where you ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

l 1652 1 wented to be with that component?

2 A Yes. We have it now so that the power supply is l 3 redundant to the speed probes and from two different 4 redundant -- to the speed probe -- the speed probes are j 5 redundant and a power supply for the speed probes is also i 6 redundant, and, if you lose power supplies from one pump, 7 you can then use the power supply from the other pump.

8 So we finally got to where we wanted it to be.

l 9 Q So, could I characterize this as putting in a --

10 making a component modification and then troubleshooting 11 that component?

12 A Yeah. Yes. There was a tendency to try to 13 make the design work instead of looking and reassessing the l

14 design. We waited too long and continued to try to fix it 15 when it failed instead of just putting in a new design.  !

l 16 Q Was it a design issue with a revived component, l 17 then?

18 A Yes. It was a design issue. l i l 19 Q Okay. And then you were going to refer to the '

20 management meeting. I think maybe --

21 A Yeah, It's the Mothers for Peace Exhibit 140, on l

22 page 3, section B, first paragraph, last sentence, '

23 Mr. Fujimoto, who is the vice president of our nuclear l

24 engineering construction services department noted that, 25 "Since the equipment had been redesigned l

l-l ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 l (202) 293-3950 i

I

j -!

i 1653 l l

l 1 in February of 1989, there was a 2 tendency to continue to try to make the  ;

1 3 new design work rather than reassess the i 4 design."  ;

I 5 Q Did this whole -- this whole chronology with the [

]

l 6 inverter to the power supply, did that reflect a maintenance

]

]

7 and surveillance issue in any way?

l j 8 A Not in my opinion. It was that we just tried to 1 i

! 9 make the design work, replacing components and l 1 '

10 troubleshooting and trying to find why it wasn't working.

! i

} 11 Q Did you work with the vendor on this issue? i j 12 A Yes, we did. -After about the second or third i l 13 failure, we got the vendor' involved, and he said, oh,-there l-1 14 was a problem with the board. So he redesigned the board.

O 15 Then we get involved with the vendor again, and he gave us j

\

j 16 another component and some more things to do. So we worked j 17 with him throughout this evaluations or throughout these

) 18 evolutions.

i i 19 Q Was there safety significance to the inverter 20 failures along the way?

21 A No. The main feedwater pump is a nonsafety

{ 22 related piece of equipment.

j 23 Q So, was that part of the equation in deciding that I

24 you could continue to work on this' design?

l l

25 A .No, I don't think so. We still wanted to make the J

i l 4

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j 1654

[ l feed pump work. I mean, you do that for plant reliability.

l 2 So the issue of whether it was safety related or not didn't ,

I 3 come into play in how we addressed it.

i 4 MR. REPKA: Okay. I don't have new further i

4 5 questions.

{

i 6 MS. CURRAN: Okay.

7 CROSS EXAMINATION  !

4  :

4 8 BY MS. CURRAN:  ;

I i 9 Q You were saying, Mr. Giffin, that you installed '

1 10 this component, this inverter, as a means of improvir.s ,

i 11 the reliability or the operability of the -- I guess the l 12 feedwater system. Is that it?

i

13 A The reliability of the speed control for the main ,

f j 14 feedwater pump. t

;7  !

j 15 Q Okay. But when the component failed, when the  :

) 16 inverter failed, it wasn't just that it failed and the plant. l 4

j 17 continued to do what it needed to do, that there was --

4 18 power was lost to the main feedwater pump, right?  :

19 A (Witness Vosburg) Well, in one instance -- I 4

j 20 believe there were two instances in there there are two 21 inverters. If one fails, it will transfer to the other, j 22 There were two cases, I believe, there, where it did not j

23 transfer.

24 In the other failures, there was no real effect on l 25 the operation of the unit. One inverter failed. It ANN RILEY & ASSOCIATES, LTD.  ;

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$ 1 2

1 1655 I 1 transferred to the other successfully, and there wasn't an iO l

2 impact other than the inverter failure, fixing the first 3 inverter.

i j 4 Q So, in other words, in this instance, there were j i

5 two serial failures here? One thing failed, and then the i 1 i i 6 next thing was supposed to -- l I

7 A Yeah. The design is that such that if one f i

j 8 inverter loses power, it will automatically transfer to the 1 9 inverter for the other pump. There's two main feed pumps. l f

j 10 Q So they both went down? ,

11 A (Witness Giffin) No. ,

12 A (Witness Vosburg) Not both inverters. .The one l

' 13 pump area inverter failed, and the transfer scheme to 14 transfer the power to the other -- to the other inverter as  !

l l 15 a power source, the transfer mechanism didn't work.

i l i 16 Q Okay. '

1 1 17 A So the one pump lost power'to its speed probes. l l 18 Q And isn't it also true, as stated on pages 2 to 4 1 19 of Exhibit 138 that there are nine other occasions in which 1 20 this inverter failed between 1990 and 1992.

l 21 A (Witness Giffin) Yes. It says there were nine l 22 failures.

23 Q Okay. And on December 3, 1991, it-states on page 24 3, wasn't the seventh failurc, didn't that also include a 3 25 failure to transfer, just as had happened on the March 6, l'

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1656

-s 1 '92 event?

j 2 A (Witness Vosburg) Well, the December 3rd event i

3 was 1991.

4 Q Uh-huh.

5 A Yes. And that was the first event where it failed 4

a 6 to transfer to the other inverter.

7 Q So there was more than one event where there was a 8 failure of an inverter and also a failure to transfer to the -

9 other inverter?

10 A Yes.

11 A (Witness Giffin) That's correct.

i 12 A (Witness Vosburg) Different causes, but, yes, 13 there were two times when the transfer was not successful.

~

14 Q And that happened again -- oh, no. Never mind.

15 Okay. Isn't it also true, as stated in section E on the l 16 bottom of page 10 of Exhibit 138, that a letter was written 17 in February of 1986 addressing the potential for loss of l

18 both speed channels due to the loss of a single power l I

19 supply? l

20 A In 19 -- I'm sorry, where are you referring to?

3 21 Q I'm referring to section E on page 10 of Exhibit 22 138, which is at the bottom of the page.

I 23 A Yes. That was prior -- see, the initial design 24 feed pumps, the power supplies, there were no inverters. It 25 was just the power was supplied from a non-vital bus,

[

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Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

l 4

1657 1 essentially, a lighting panel in the turbine building. That 2 was recognized, and it's documented here, and that was one 3 of the reasons that we looked at improving the power supply 4 or the reliability of the design to put in inverters and i

5 this transfer capability to make it more reliability.

6 That's one of the things that went to -- you know, l

7 inputted to the decision to grade the power supply system. I l

s Q Oh, okay.

l

, 9 A (Witness Giffin) Because the one that failed 1 I

10 isn't the 1986 edition. It's the 1989 '90 edition.  ;

4 i

11 A (Witness Vosburg) Right.

I i 12 Q Do you agree with the NCR in Exhibit 139, page 6,  !

13 that the invei-ter failure, the history of inverter failures 14 is a long-standing problem at Diablo Canyon?

i 15 A (Witness Giffin) Where are you?

'l 16 Q I'm in paragraph 3 under " Inspector Findings," in ,

17 Exhibit 139 on page 6.

't i

18 A Well, I can't find it, but I agree, as I said, 1

19 there was -- we have nine failures. So it was a 20 long-standing problem from 1990, when it first had a 21 failure. The first failure was in May of 1990.

22 So, from then, until we replaced it, I'm not sure 23 I'd say long-standing, but that's the period of time that we 24 were having problems with the inverters.

. 25 [ Pause.)

('

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i  !

l l

l 1658 1 Q You were saying before that you kept trying to lO 2 make this component work, right?

3 A That's correct.

4 Q Uh-huh. Do you have some kind of criteria for 5 when you keep trying to make something work and when you l

6 start to take a work and reevaluate whether the component 7 should be replaced?

8 A We don't have a criteria, per se, but if we have a l

9 problem that -- make sure that the engineering department, l

10 that the design engineers get involved quicker so that they l l

11 can help us in this and work with the plant engineers.

l l 12 In this case, the first two or three failures ,

l 13 were -- the first failure wasn't a problem with the design. I i

14 It was a problem of water intrusion. So that one we just j l

15 said, okay. That's -- water got inside of it and failed.

16 The second one was a -- there was a fire or a high 17 temperature inside that melted something, and we considered 18 that that was an isolated event. So we really should have 19 been more -- after the third failure is when we got the 20 vendor involved, and that's when we started to think that we <

l 21 had an issue with the inverters.  !

l 22 Q So you agree this issue should have been dealt )

23 with earlier?

l 24 A Hindsight is 20/20, and if I had to look back at  !

l 25 what I was going to do then now, I would have made a  :

l l

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Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 l

4 1659 4

i 1 different decision, yes.

\- 2 A (Witness Vosburg) I guess, you know, dealt with ,

l 3 earlier, it was being dealt with all along. We were working i 4 with the vendor and actively looking at a resolution to -

5 these power supply problems. I mean, the feedwater pumps 6 and the feedwater control system is probably the single most 7 cause of trips throughout the nuclear power industry.

]

fi 8 So we're very sensitive to making sure that the P 9 pumps are as reliable as possible.

10 Q You ultimately replaced these inverters?

, 11 A (Witness Vosburg) No, we did not. We changed t

12 where the inverters were getting their power from. The 13 power supplies we made the source of, essentially, where you l

-)

'~

14 plug into the wall redundant. So it was a redundancy in the l 15 power supplies. We also the location of some of the l I

16 components to assist the design better.

1 17 Q Was that an expensive change to make? l l  !

i 18 A I don't know whether it was expensive or not. I i 19 don't know how much it cost. I don't have the vaguest idea.

20 Q Do you agree with the TRG, which says on page 18 i 21 of 25 of Exhibit 138 that, 22 "In the previous failures, the reason 23 that the power supply wasn't changed was 24 because of money."

25 A I'm sorry. I'm try'ng to find where you are.

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Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

1660 1 Q Page 18, Exhibit 138.

O 2 A I'm on page 18.

3 Q Paragraph L.

4 A I disagree with that. That's the minutes of the

, 5 TRG, and that -- they don't make decisions on money. I make 6 decisions on money, and the other managers make decision, 7 not members of the TRG. That's just a comment that's not 8 true.

9 JUDGE BECHHOEFER: Even if they don't make 10 decisions, do they report what they believe is the case?.

11 MR. GIFFIN: We expect them to do that, and we 12 expect it to be an open discussion, and people put down what 13 they think, and then we review that to determine what makes 14 sense, and those that do get implemented, and those that 15 don't, don't.

16 Sometimes, we're not -- we don't go back in and 17 say that we disagree with these statements. They just -- it 18 stays as it is.

19 JUDGE BECHHOEFER: I see. Okay.

20 MR. REPKA: Just so the record it clear, we're 21 referring to minutes of the TRG meeting, and the items -- it 22 states that they were the items. "We considered the 23 following items." It didn't say that that's what they 24 decided. If you look on page 17 of 25, the lead-in number 2 25 there, ANN RILEY & ASSOCIATES, LTD.-

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i' i

1661 f 1 "On March 19, 1992, at 9 a.m., the TRG i

I 2 reconvened and considered the following i 3 items."

4 MS. CURRAN: Mr. Giffin.

5 MR. REPKA: Excuse me for a second.

, i 1

6 MS. CURRAN
I'm sorry. j 4

j 7 [ Pause.]

8 MR. REPKA: Go ahead.- l l

9 BY MS. CURRAN
,

10 Q Have there been any systematic or procedural j 11 changes made in response to -- as a means of correcting the  ;

i 4 '

j 12 delay in changing the' power supply for this pump, for this 13 inverter? j

i

, 14 A (Witness Giffin) I don't believe there are any 1

4 a 15 procedures involved. It's more of an education process that  ;

1 l 16 we need to make sure that our engineers understand that i

{ 17 they're not there by themselves be that we have a complete,

! 18 large organization that's there that exists to help.

1 19 So it's more of a reemphasizing that it's

! 20 necessary to get the design engineering organization in a j

21 little quicker just because -- don't treat it that -- don't  !

I I 22 try to make something work that's not deserving to be made i-23 to work.

]

24 In other words, get some other people and say, j I

25 "This doesn't.look like it's worth -- let's try to get it l 1

i

\

i a

l .

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l I

l l 1662 i

i 1 fixed." So it's not a procedural thing. It's more of a I l

l 2 want my engineers and my senior engineers to work more  ;

. 3 closely with the design engineering organization, and by 4 doing that these types of timeliness issues don't come up as i

! 5 much.

i  !

, 6 Q When you refer to engineers, which engineers? Are i

! 7 they engineers in the maintenance department?  !

i 8 A I have engineers in the maintenance department as 4

9 well -- then there are the design engineers as well. So my  ;

i j 10 engineers in the maintenance organization work with the 1 i j 11 craft to assist the craft in the technical parts of their I  !

4 12 job.

i 13 The design engineering organization is in San 14 Francisco, and they're responsible for designing and

)

l 15 providing the plant staff and different design, and by l 5

16 having the two organizations work together, then we can get
17 a new design in quicker.

18 Q That's kind of an informal process at this point.

1

19 The change is an informal one. You've. spoken tv your staff, i l 20 is that it? .

) 21 A We continue to emphasize the necessity of working

.i 22 with the two -- the organizations working'with each other to j i

t 23 ~try to improve communications. We do it at the. plant staff 1

24 as well as the engineering department does it in their 25 organization.

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Court Reporters

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-,--r--m y * -w-r

i l' l l

t 1663

? l 1 MS. CURRAN: Okay. Thank you. I don't have any O 2 other questions.

3 MR. REPKA: I'd like to follow-up quickly.

4 MR. GIFFIN: Before you -- there may be, and we'll 5 check on this, but there's -- I think I said that we kept i 6 the inverters and tried to fix them. Dave was looking 7 through this. We probably replaced them with something 8 else, but we'll check to make sure, but, in either case, 9 whether we did major repairs on the inverters or replaced 10 them, the problem has been resolved.

11 REDIRECT EXAMINATION 12 BY MR. REPKA:

13 Q Mr. Giffin, Ms. Curran characterized the history j l

14 of this issue as involving a delay. The way I understand 15 it, couldn't it be better or differently characterized as --

]

16 strike that. l f 17 Throughout the course of this, isn't it true that

! 18 you were working on it'all the time?

19 A Oh, yes, we were. If you go through the 20 chronology, each time that it failed, we worked on it; we

! 21 worked with the vendor, trying to figure out what cnd why 22 and what we had to do to make the system work as we wished l 23 it to.  !

l 24 So it wasn't that we were sitting waiting for it i 25 to fail again. Like I said, I guess, in hindsight, I would

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Court Reporters 1612 K Street, N.W.,-Suite'300 Washington, D.C. 20006 (202) 293-3950-l

1664 1 have done something different.

!O l

I 2 A (Witness Vosburg) I think, yeah, the shortcoming 3 was not giving up on those inverters soon enough. We kept 4 working with the vendor trying to fix the problem thinking 5 we had, and we didn't.

6 Q The engineers working on this issue, you've 7 referred to the two engineering organizations. We they your 8 maintenance engineers or the engineering department in San l l

9 Francisco?

10 A (Witness Vosburg) Initially, they are the 11 engineers in the plant, the plant maintenance engineers, and 12 then, as we got more into it, after about the third failure, 13 that's when we involved the design engineers in it as well.

14 The first failure was, you know, the water intrusion. The 15 second failure we believed to be an isolated event.

16 Then, after that is when we got the design l 17 engineers, and the two groups worked together. It's not 18 that the engineering organization was not aware of it.

19 MR. REPKA: On the document that's been identified I 20 as MFP Exhibit 138, page 24, item G, it states that, i

! 21 "Any CS electric engineering will issue 22 a departmental memo to describe the l 23 event as a lesson learned."

l 24 Do you know if that's been done?

25 A It says that -- ECD is Estimated Completion Date.

[

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i i

1665 1 The estimated completion date was over a year ago. So I

, 2 would assume that that action had been completed. j l  :

l 3 MR. REPKA: I don't have any further questions. 3 4 JUDGE BECHHOEFER: Staff have any questions?

I 5 MS. HODGDON: No questions.

J 6 JUDGE BECHHOEFER: I'm not sure whether I missed j f

i 7 something here, but, on Exhibit 139, the cover.

l l 8 MR. GIFFIN: 139, yes, sir. Just the cover  !

9 letter, the Staff talks about apparent weaknesses in  !

10 maintenance. Now, can those weaknesses be traced to a j 11 programmatic weakness.  ;

12 MR. REPKA: That reference is to the backdraft l 13 damper issue, which is a different issue. l 14 JUDGE BECHHOEFER: Oh. _

O 15 MR. REPKA: Which we addressed elsewhere.

i i

16 MR. GIFFIN: We talked about that one yesterday, I 17 believe two days ago. ,

i l 18 JUDGE BECHHOEFER: Oh, oka}. Okay. Forget that 19 question, then. I didn't track it.

20 [ Judges confer.]

21 JUDGE SECHHOEFER: Okay. I guess the Board i

t 22 doesn't have any further questions, since my question relate 23 to an earlier topic. What does -- some of these are staff 24 documents, but what does -- do you plan to move in the 25 others?

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Court Reporters 1612 K Street, N.W., Suite 300 l l

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i

I l

l 1666

. 1 MS. HODGDON: We're moving in Exhibits 138 and 2 140-A.

3 MR. REPKA: And 142 also? 4 l

l 4 MS. HODGDON: No. 142 we're not going to move.

l 5 MR. REPKA: In the interest of time and i l 6 expediency, I'm not going to object to these.- With respect ,

, t l 7 to the weight of the exhibits, however, I would point out .

l 8 that this is primarily, as the witnesses have testified, a 9 design issue and one that relates to a nonsafety-related 10 system. ,

j 11 MS. HODGDON: Whenever you're ready to move on, 12 Judge Bechhoefer. Oh, I'm sorry. You haven't ruled on 13 these.

l 14 JUDGE BECHHOEFER: I haven't ruled yet. I guess i 15 it's only two documents I've ruled on right now, 138 and ,

16 140-A, and absent a formal, express objection, at least, we l I

17 accept those two documents into evidence. i i

18 MS. HODGDON: Okay.

19 [MFP Exhibit Nos. 138 and l I

20 140-A were received in I l 21 evidence.]

l l 22 MS. HODGDON: All right. The next exhibits are l

! 23 Exhibit 100, which is NCR DCO-92-MM-NO22, dated January 4 --

24 oh, my goodness. I'm in the wrong place. Okay.

25 MR. REPKA: Backwards is one direction I don't l

l I

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I i

l 1667 I 1 want to go.

2 MS. HODGDON: No. Believe me, I don't want to go 3 that way either. Okay. I'm on Exhibit 144, which is LER 1-4 92-005-01, dated July 20, 1992; Exhibit 145, which is NCR DC 5 1-92-PI-N020, dated June 24, 1992; Exhibit 146, which is LER 6 1-91-013-00, dated September 6, 1991.

7 Exhibit 147, wr.ich is LER 2-91-001-00, which is 8 dated August 13, 1991; Exhibit 148, which is NCR DC 2-91-TI-9 N062, dated August 9, 1991; Exhibit'149, which is LER 1 10 006-00, which is dated April 25, 1991, and I'm reading the j 11 road map. This must be 149-A? Okay. 149-A, which is NCR l

12 DC 1-91-EM-N041, dated April 25, 1991; Exhibit 150, which is .

13 LER 1-90-019-00, dated January 28, 1991, and Exhibit 151, i

f-' 14 which is LER 2-90-004-00, dated May 17, 1990.

( i 15 JUDGE BECHHOEFER: Are you doing anything about l 5

l 16 150-A?

i 17 MS. CURRAN: I must have missed that. Exhibit 18 150-A is NCR DC 1-90-WP-N093, dated January 18, 1991. I 19 read 151. Oh, there's a 151-A? Okay. Exhibit 151-A is NCR

! 20 DC 2-90-TI-N025, which is dated October 11, 1990.

21 JUDGE BECHHOEFER: So we've got 11 documents right 22 now. Oh, the reporter advises us that you did not mention l 23 146-A.

i 24 MS. ZAMEK: 146-A is NCR DC 1-91-TI-N068, October 25 3, 1991.

l ANN RILEY & ASSOCIATES, LTD. l l Court Reporters 1612 K Street, N.W., Suite 300 I Washington, D.C. 20006 (202) 293-3950 1

i 1668 1 [ Pause.]

O 2 JUDGE BECHHOEFER: So my earlier remarks are 3 changed to make it 12 documents. It's better than 11.

l i l 4 [ Pause.]

5 MR. REPKA: Whoever gets the short straw over 6 there.

7 MR. VOSBURG: Yeah. I think I'n, in general, 8 familiar with the majority of the documents.

i 9 DIRECT EXAMINATION 10 BY MR. REPKA:

11 Q Okay. These documents seem to relate to a number l' l 12 of Containment Ventilation Isolation or CVI signals? '

13 A (Witness Vosburg) Yes, they do. They're all l 14 related to events that caused a Containment Ventilation 15 Isolation.

16 Q So every time this occurs, that's reportable by an 17 LER to the NRC? l i

18 A Under present day -- under 10 CFR 5072 and 73, as j l

19 it stands today, not all of these would necessarily be 20 reportable. During the time that these occurred, however, 21 they were reportable. There was a change to the law last 22 year, I believe in October, that changed the threshold for 1

23 reporting CVIs due to the -- again, as we discussed earlier, l 24 it's a fairly benign event, and the number of reporting 25 events throughout the industry that I think were being sent Os ANN RILEY & ASSOCIATES, LTD.

Court Reporters i 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 l (202) 293-3950 j

1 i

i

~1669 1 into the NRC.

O 2 Q So each time you had a CVI, there was an LER and l 3 also an NCR that corresponds? ,

4 A An NCR, yes. A TRG and an LER.

5 Q So, if I'm reading this correctly, the 12 6 documents, then, would equal six separate CVIs? There seems 7 to be one LER and one NCR for each? -;

i 8 A I count of seven separate events that are covered l i

t 9 by these --  !

10 Q Okay. So it's a number of events, but they're all  ;

i 11 unrelated?  :

12 A Yes. They are all unrelated, other than that they 13 all deal with CVIs. Of the seven events, six of the events l 14 dealt with personnel working in the plant and causing an arc  ;

\ l 15 to be generated on one of the vital instrument buses.

16 Anywhere in the plant it can occur, and these rad monitors 17 that put this system into its safety-related mode are 18 extremely sensitive. j 19 They're extremely sensitive to the power supplied l

20 to them, and if there is any noise, electrical noise, l 21 generated, it can cause them to go into their safety-related l

l 22 mode and cause a CVI, and most of these, except for one 23 case, were related to personnel working in the plant, both 24 maintenance personnel and general construction personnel and 25 things like they're working inside a panel. They have a l

t

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l Court Reporters l 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

1670 1 pair of pliers, and they purp a te T 1al, and it causes a i O 2 little spark, and that sets.the rad monitor off and causes a l

l

)

3 CVI.

4 The only one that doesn't really, I guess, fall 5 into that category is of a personnel error where they were 6 working was Exhibit 149, and that simply dealt with a 7 failure of the motor that's associated with.RM 11, which is  !

8 one of the-rad monitors that actuates the system. l 9 When they started the motor, the pump that the 10 motor deprive seized, there was an arc in the motor, and, i

11 again, it spuriously initiated a Containment Ventilation  !

12 Isolation. l 13 Q That arc rated some electrical noises,-which 14 causes --  ;

i 15 A Again electrical noise, yeah. i l

16 Q -- the CVI?  !

17 A For example, even normal operations such as l 18 switching in the 500 yard, it's probably three-quarters of a 19 mile from the plant -- these~are the big breakers that 20 control the routing of the power leaving the plant, just 21 opening and closing those breakers that far away in the past 22 has set these rad monitors off.

23 Q You've stated before that a CVI is relatively l 24 benign? i 25 A Yes.

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1 1671 i

, I l 1 Q What do you mean by that? l f l 2 A In terms of any significance to -- with respect to l 3 safety or a challenge to the operations crew, as I stated j 4 before, there's about eight or ten valves associated with a l 5 CVI. They're all containment isolation valves, one in -- )

j 6 every penetration that goes through the containment has a l 7 valve on the inside and the outside that closes when it'gets 8 his CVI signal to close off the containment.  ;

9 Normally, the-majority of these valves are closed 1

10 when the unit's at power. The only ones that we operate l l

11 with open are the ones that supply a' sample of the i l

12 containment atmosphere outside to these rad monitors that l 13 we're talking about. j l

14 When you have a CVI, it closes those valves, and-l 15 that's, really, the only active component that moves in the  !

i l

16 plant when you have those. l l

17 Q Could a CVI cause a transient? l I

18 A No, it could not.

19 Q And do these CVIs, could they result in any wear 20 and tear on equipment?

21 A No. Again, the valves are designed to actuate 22 hundreds of times, and probably a valve that sits there'and 23 is never stroked is probably less likely to perform 24 correctly than one that is actuated periodically. So 25 there's really no significance as far as wear and tear on l

Ts ANN RILEY & ASSOCIATES, LTD. ,

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! 1672 l

1 the equipment from these CVIs.

2 Q At Diablo Canyon do we have a problem with 3 personnel errors causing CVIs, a systemic problem in any I

l 4 way?

l  !

5 A We had had cases where people working in the plant  ;

l l I

6 have caused CVIs. If you read through these there's things 7 like they're working in a panel, and they have a l 8 screwdriver. It's a type of screwdriver that's designed to ,

9 hold the screws so they can put it in. It falls, and it  ;

i 10 hits something in the panel and causes a little arc on the  ;

11 terminal strip.

12 There were cases, as I talked about, where a GC l 13 personnel was working, and he accidental bumped the terminal 14 strip with his pliers. So there are those type of 15 occurrences. INC does an awful lot of. work in the plant 16 where they are working on energized instrumentation, and, l

17 inside the panels, there are places where you have to be 18 careful that you don't, you know, draw an arc anywhere and 19 touch anything, and, occasionally, it does happen.

20 Q Is there training or any other measures to try to 21 minimize CVIs?

22 A Well, it's in the training of, you know, the 23 general work practices that people are expected to follow 24 when working inside these panels. There are policies, for 25 example, the reason some of these are deemed to be personnel ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 1

1

1673 3

1 errors is that, normally, when you work inside a panel with'  :

O 2 a pair of pliers, you'll tape the pliers to keep this from i

3 happening.

4 In this one case, the GC, General Construction i

5 person who is working there, did not take the pliers. So l

6 this happened. So there are -- as part of the training of ] !

7 INC techs, maybe one of you can speak more-authoritatively. j 8 A (Witness Giffin) After one of these things j

9 occurs, as Mr. Vosburg said, we have a nonconformance'  ;

10 report, which generates why did it happen. Then we lcok at those root causes and try to implement some corrective  !

11 12 actions to prevent it.  !

13 We include those items if it's of interest-to the i

14 entire INC department. Then.we issue a bulletin, and we .

15 talk to the department about it. Routinely during quarterly 16 updates, we train maintenance personnel about those events 6

17 which would go on in the plant,.and give them the lessons 18 and what could we do and things like taping -- taping 19 pliers, if -- you know, put some rubber barricades.

20 We've also, besides just training, the rad 21 monitors that are in here that causs the CVI, as David said, 22 were kind of sensitive. We have ans we're in the process of 23 installing a new digital radiation monitoring system, and 24 these components, RM 14, 28 and 11, which were causing these 25 CVIs, no longer do that function anymore, and a more easier.

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  • y e +-ya
  • vs M 'it

1674 1 to work on more sensitive RM 44 and 44-A are now the

! 2 instruments that cause it.

3 So'some of these problems with the sensitivity to 4 voltage transients that were causing CVIs before won't cause 5 the CVI again.

6 JUDGE SHON: What were they earlier, just count 7 rate meters? Were they just count rate meters or, things 8 like that?

! 1 9 MR. VOSBURG: Yes. They are radiation monitors 10 that have -- i l

11 JUDGE SHON: Yeah. The CRM. i i

12 MR. GIFFIN: Yes. Right, f 13 JUDGE SHON: It's a CRM with some sort of a relay 14 on it?

15 MR. GIFFIN: Yes. ,

l l 16 MR. VOSBURG: Yes.

l 17 JUDGE SHON: They bounce all around.- l 18 MR. VOSBURG: They bounce.around, and if_they I

! 19 happen to hit an alarm setpoint, it trips a bi-stable, and 20 it initiates the CVR.

21 MR. REPKA: I have no further questions.

22 MS. ZAMEK: I do. l 23 CROSS EXAMINATION 24 BY MS. ZAMEK:

25 Q Mr. Vosburg, are you trying to tell.me, then,.that O ANN RILEY & ASSOCIATES,.LTD.

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i i  !

i 1675 4

1 CVIs are no problem whatsoever, and it doesn't matter 2 whether they occur or not?

l l 3 A (Witness Vosburg) No, I'm not. We take all these  !

4 very seriously. Again, as you look at the documentation, a ,

i

5 lot of it produced as a result of a Technical Review Group i

6 that met to determine the causes of these personnel errors  !

1 >

s 7 and inadvertent CVIs, we do spend a lot of time looking  :

8 spoke this and trying to come up with root causes and j t

l 9 corrective actions to prevent it. j

< r l 10 Q Okay. Is it an ESF?

4 t

! 11 A Yes, it is.  ;

1 i l 12 Q And similar to the other ones we were talking l

. 13 about?

2  :

l 14 A Similar in what way? There are various Engineered j 15 Safeguards Features destined into the plant. This is a i  ;

16 ventilation cystem. l i

17 Q Okay. You said earlier about the ESF, the earlier 18 ESF being a problem was that, because, when'it happened, you

! 19 had to fill out all these forms, the NCRs, the LERs, and the

20 TRGs, and now you say that you don't ever have to do that j 21 for the CVIs. Is that true?

1

! 22 A Spurious -- as I said, the federal law was changed i

23 last year to reduce the threshold for which you have to

  • 24 report these, and it was mainly changed, to, I believe, 25 eliminate the reporting of spurious CVIs. I'm not sure what i4

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1676

, 1 exactly without reading the Code of Federal Regulations, how f 2 they define " spurious," but I know they did relax the report 3 requirements.

4 Q So that means if it's a personnel error it's no- l 5 longer reported?'

6 A No. I can't say that. I don't know if that --

7 exactly what the records are in the Code of Federal ,

i 8 Regulations. l 9 A (Witness Giffin) Let me interject one thing.

10 Whether it's reportable if we have a personnel error that .

11 causes an actuation of something, it doesn't matter whether  ;

12 it's reportable or not. We will still investigate why a 13 person made a mistake and make whatever changes are ,

i 14 necessary.

15 Reportability are not -- because, as you know,

  • 16 most of these issues that are being brought forward today l 17 are not items that are reportability to the NRC.

18 Most of these.are all documents which we do 19 ourselves, and we don't have to -- no reportability is 20 required, but we still take actions ourselves. So 21 reportability is not an issue.

22 JUDGE BECHHOEFER: So you prepare an NRC if 23 something like that happened?

24 MR. GIFFIN: Yes.

25 MR. VOSBURG: One of the -- yeah. Any time you ANN RILEY & ASSOCIATES, LTD.

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t 1677 .

l l 1 have to make a report or write an LER,-you will.always have  !

i O 2 an NCR, but we have NCRs --

-I I

l 3 JUDGE BECHHOEFER: Yeah. But this where you don't j l

4 need an LER, presumably.  ;

5 MR. VOSBURG: Yes. We write NCRsLfor many other. l 6 things that aren't reportable, though. t s

7 JUDGE BECHHOEFER: Yeah. And this would continue f i

8 to be one. l 9 MR. VOSBURG: Yes.

l 10 MR. GIFFIN: Yes.

I 11 MR. REPKA: And that should be quite clear from q 12 all the conduct of the proceeding. There are many,'many i

I

( 13 NRCs.  ;

14 JUDGE BECHHOEFER: But I was just conferring that ,

O 15 these type continued'to be prepared.  !

i 16 MS. CURRAN: You're not testifying,-are you, l l i' 17 Mr. Repka.

1 18 MR. REPKA:- Just observing.

l l 19 BY MS. ZAMEK: f l

l 20 Q You made mention of the overly-sensitive system.  !

! I

! 21 Is it in your testimony -- I was looking on page 69 on the ,

i l 22 radiation monitoring system, the upgrade. Does that have  !

i 23 anything to do with this system? j i

24 A .(Witness Giffin) That's the -- when I said that j 25 we were replacing; we're putting in a new radiation  ;

I l

i i

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1678  ;

1 monitoring system?

2 Q Uh-huh. j 3 A This project, yes.

4 Q And that's scheduled to be completed by 1995?

i 5 A Yes.

6 A (Witness Vosburg) Well, there are many rad f 7 monitors in that system that are being replaced. .Some have .

8 already'been replaced. Some are being replaced now. The-  !

t 9 rad monitors associated with the CVI, RM 11 and 12 in l 10 particular that we're talking about, I believe, are already  ;

11 replaced. j l

12 A (Witness Giffin) RM 44 and 4-A have been 13 installed.

14 A (Witness Vosburg) Now have the CVI function, but 15 not with the old monitors.  ;

16 Q Exhibit 146-A on page 11, on the very first 17 sentence, it says that,  :

l 18 "It'was determined that CVIs occur more ] J 19 frequently at DCCP than at any.other i

20 U.S. power reactor. HowcVer,.due to 21 differences in reporting and 22 interpretation of an ESF, the number of 23 other CVIs at other plants may not 24 directly correlate to the number of CVIs 25 at DCCP."

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i 1679 1 A (Witness Vosburg) Well, I' guess that tells me l O 2 that there is some' room for interpretation of 10 CFR 5072

]

3 and 73, and that we tend to report more of our CVIs than, j

4 maybe, other plants. They may interpret the regulations j t

5 differently and'not have the same threshold for reporting we i l

6 do. I don't know if that's true, but that's what that says {

l 7 to me.  ;

I 8 Q But can I assume, then,.that there are numerous j 9 CVIs that have occurred at DCNPP?

10 A Oh, yes. I mean, we just looked at several here, i

11 and, as I stated, there are others in the past history, and  !

l 12 simply switching in the 500 kV arc can set off the old j 13- monitors. That can't happen.now, but, historically, years 14 ago, that did occur. -)

(::) 15 Q In Exhibit 150-A, page 7, under " Previous Similar l

16 Events," can you assume that this has been in occurrence I

17 since 1986?

18 A Well, this specific event, I don't know what .

19 caused it. I assume it to be similar as the other l

l 20 inadvertent CVIs we're talking about, and yes, you can-21 assume that.

22 MS. ZAMEK: I don't have any further questions.

23 JUDGE BECHHOEFER:- Staff?

24 MS. HODGDON:- No. No questions 25 [ Pause.] _;

i

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i l l l l I

1680 1 QUESTIONS BY THE JUDGES 2 JUDGE BECHHOEFER: Let me ask one question here 3 of, perhaps Mr. Giffin but maybe not. On Exhibit 150-A, l

4 front page last paragraph, first sentence, what's the 1

1 5 significance of the nondistribution that was referred to in 6 that paragraph? Does that in itself constitute a problem?

7 MR. GIFFIN: Let me look and see what --

l 8 MR. VOSBURG: This was the event I referred to l l l l 9 where a general construction person was working and caused a l l l 10 particular CVI, and rather than -- I think what we did here l l

11 is we went back and took some of the previous maintenance i l

12 bulletins that the plant had written concerning some of its i l

13 CVIs and made sure that the GC personnel had those so they )

l 14 could also learn from past experience.

T- l 15 MR. GIFFIN: During the performance of this one, 16 this work that occurred while this CVI happened was the 17 modifications for -- to put in the new radiation monitoring 18 system. That work the maintenance crew did not do. That 19 work we had general construction contract electricians do.  !

20 After this occurred, like Mr. Vosburg said, they 21 had one. We wanted them to be able to benefit from all of 22 the lessons that we had learned instead of learning each one 23 by themselves.

l 24 JUDGE BECHHOEFER: I see. So, is your general 25 construction division or office now on the general ANN RILEY & ASSOCIATES, LTD.

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i l

l 1681 l

_ 1 distribution list for maintenance bulletins. ,

\ 2 MR. GIFFIN: Yes, they are.

3 [ Judges confer.]

4 JUDGE BECHHOEFER: That's all the questions the ,

5 Board has on these.

l 6 MR. VOSBURG: I would like to just make, as a 1

7 clarification, I'm not sure it matters or not --

8 JUDGE BECHHOEFER: Please do.

9 MR. VOSBURG: When I said earlier that there were ,

10 seven events, I counted the first one twice. It was on two 11 pages, and there were really six events.

12 JUDGE BECHHOEFER: I think that confirms Judge 13 Shon's earlier observation.

14 MS. ZAMEK: At this time the Mothers for Peace 15 would like to offer the following exhibits into evidence:

16 144, 145, 146, and 146-A, 147, 148, 149, 149-A, 150, 150-A, 17 151, and 151-A.

18 MR. REPKA: No objection.

19 MS. CURRAN: No objection.

20 JUDGE BECHHOEFER: I'm just checking. None of 21 these are Staff documents.

22 MR. REPKA: There are not.

23 [ Pause]

24 JUDGE BECHHOEFER: Okay. Okay. The Board will 25 accept those documents into evidence.

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Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

, i i

1682 1 [MFP Exhibit Nos.

(s 2 144-151-A were received in 3 evidence.] j l

4 MS. CURRAN: Okay. Shall we go on? The next 5 exhibit is 154, which is LER 1-92-004-00, dated May 20, ]

6 1992, i i

)

(

7 [ Pause.] i l

l 8 JUDGE BECHHOEFER: There's just one.

9 MS. CURRAN: There's just one piece of paper, I

l 10 Exhibit 154.

l l

( 11 JUDGE BECHHOEFER: Oh, okay. -)

l l l 12 [ Pause.]

13 MR. REPKA: Mr. Vosburg, are you ready?

<- s 14 MR. VOSBURG: I'm close.

/ )

~# 15 MR. REPKA: Okay. This looks like one of your 16 issues to me.

17 MR. VOSBURG: Operations.

18 [ Pause.)

19 MR. VOSBURG: Okay. I think I can discuss this.

l 20 DIRECT EXAMINATION 4 21 BY MR. REPKA:

22 Q This exhibit that's been identified as MFP Exhibit 23 154 is an LER?

24 A (Witness Vosburg) Yes, it is.

25 Q And it addresses a turbine trip subsequent reactor ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

s i 1683 j 1 trip?

N 2 A Yes, it does.

i j 3 Q Can you tell me a little bit about what happened 2

j 4 here?

5 A Yes. Unit 1 was curtailed to 50 percent power to

{

I 6 do some, I believe, work on a main feedwater pump. In the 1

7 process of clearing the main feedwater pump, operations had  !

< l 8 trouble with taking the pump out the service such'that they I

{

$ 9 started to lose vacuum in the main condenser.

f 10 .The main feedwater pumps exhaust the steam that )

11 drives the turbine exhaust to the main condenser,.and 12 there's a ceiling steam system on the shafts of that

13 turbine. When they were taking that ceiling steam system

] . 14 out of service, they began to experience air leakage into i ,

15 the turbine -- or into the condenser, I'm sorry.  !

16 If you -- and that causes a degradation in the 17 vacuum in the condenser. If the degradation continues to a 18 certain point, it will cause a turbine trip and a reactor

. 19 trip. Operations was concerned. They thought that they may f 20 have a trip about to happen.

j 21 We have a backup pump called a Nash vacuum pump.

) 22 It's a motor-driven pump that will pull a vacuum on the main

! 23 turbine. They sent an operator down there to put that pump i

24 in service as soon as possible.

25 The way that pump operates, it has a ceiling water l

l

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Court Reporters l 1612 K Street, N.W., Suite 300 i Washington, D.C. 20006 '

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I l

1684 1 system in it that without that ceiling water system it won't 2 function as a vacuum pump. The-operators went down to put 3 the pump in service. They did not cut in the ceiling water 4 to the vacuum pump, and when they then open up the line from 5 the condenser to that vacuum pump, it allowed air to be 6 drawn back through the vacuum pump.into the condenser, made 7 conditions worse. Vacuum continued to degrade &it caused a 8 turbine trip reactor trip. ,

9 Q So this trip occurred because of the actions of I 10 operations?

11 A Yes, I did.

12 Q And were those actions in any way related to 13 maintenance and surveillance activities?

14 A No, they were not.

15 Q So they weren't performing maintenance?

16 A No. They were placing the Nash vacuum pump.into 17 service and they did it incorrectly.  ;

18 Q Were they performing an STP?

19 A No, they were not. j.

20 JUDGE SHON: What started the degrading that 21 connects the vacuum to begin with?' Do you know -- that 22 happened during maintenance, didn't it?

23 MR. VOSBURG: No. It doesn't happen during 24 maintenance. It happened while operations was clearing -- l 25 to pre. .re for maintenance, they have to shut it down. They l l'

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1 1685

1 have to close the large butterfly valve in the discharge of l 2 the turbine to the condenser and take the shaft ceiling 3 steam out of service, and it was during that. operation, and ,

4 I don't know exactly what problem they had had caused it.  !

, 5 They began to -- they created an air-in leakage ,

-i

6 path into the condenser while clearing the-turbine.

i .

l 7 JUDGE BECHHOEFER: The air ejector couldn't keep e

! 8 up with it,.so you started -- {

9 MR. VOSBURG: Oh, yeah. This was a fairly large

~

10 unit. Yeah. The air ejectors'did not keep up. So they had 2

~

11 a degrading vacuum condition in the condenser.- So they sent ,

! 12 the operator down to put the vacuum pump in service. '

.l l t i 13 BY MR. REPKA:  !

14 Q In this chronology of events, were there any  ;

l 2

15 component failures that occurred?  !

4  :

. 16 A There is a -- on the line that goes-from the i

j. 17 ccadenser to the Nash vacuum pump, there is a' check valve in i ,

i 18 that line to prevent flow of air back to the condenser'from l

+

l 19 the Nash vacuum pump. That valve was determined to be  !

l 20 leaky, and so when they improperly placed th'e-Nash vacuum '

i 21 pump into service, it allowed air, of course, to flow back i

22 through the pump.to the condenser through that check valve,  ;

23 through the leaky check valve.

i-j 24 So it contributed, then, to letting more air into 25 the condenser.

l t

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1686 l

{ 1 Q Was the leaky check valve operable?  !

, 2 A Operable -- it's not a safety-related component.  !

i a

3 It did leak. There's no what's operable, what's not.-

l t

j 4 There's not a surveillance test that you would perform on'a  !

j 5 component like that. It did not -- you.know, it allowed air l i 1 j 6 to flow back through it to the condenser.  ;

i  ;

} 7 Q Do you think there should have been any- l 4

l 8 surveillance performed on that valve?  !

i- i

, 9 A On the check valve? i l 10 Q Right. i

J 11 A A surveillance test?

12 Q Or any other kind of test? [

I 13 A It's a secondary nonsafety-related component.. You

} 14 don't normally ever use a Nash vacuum pump. As the Judge ,

5 l 15 stated, we have steam air ejectors that are normally in  ;

4 16 service to maintain the vacuum in the condenser. So it's ]

17 not a component that you'd expect to rely on.at the plant {

f 18 operating.

} 19 It's used mainly for start-up, when you first 20 start up the-plant to initially pull a vacuum into the j 21 condenser, and it alone is not. capable of maintaining vacuum i 22 low enough in the condenser to operate the plant. You still

23 need the-steam air ejectors.

l 24 Q Following this incident, was the check valve 25 fixed?

]

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-i l

1687 i 1 A Yes, I -- J 2 A (Witness Giffin) In-both units, they're inspected

(

3 and repaired.

4 Q Okay. Does this LER in any way undermine your  ;

5 confidence in maintenance and surveillance activities at the j i

6 plant? l 7 A (Witness Vosburg) No. f 8 .A (Witness Giffin) No, it does not.- l 9 MR. REPKA: I don't have any further questions.  ;

i 10 CROSS EXAMINATION i I

11 BY MS. CURRAN:

12 Q Was the condenser vacuum pump being used when this  ;

i 13 event occurred? l l

14 A (Witness Vosburg) At the beginning, when they O 15 were clearing the main turbine or the feed pump turbine? l I

16 Q Uh-huh. i 17 A No, it was not. It's not normally used when the 18 unit's on-line.

19 Q Was it used at any time during this event?

20 A They attempted to use it, but because they 21 improperly put it in service, all they did was make the 22 situation much worse.

23 Q They shouldn't have tried to use it?

24 A Oh, no. It wasn't a bad idea not to try to use 25 it, because they had a degrading condition going on, but l

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Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202)'293-3950-

t i

1688-1 they did not follow the procedure for placing it in service,  ;

O 2 and, essentially, all they did was open up another hole to l l

3 -the condenser by not having the seal water on the pump.

4 Q So did it make any difference that it was leaking?

i I 5 A Are you referring to the check valve? l 6 Q Yeah. l 7 A I can't say for certain. They were losing vacuum 8 at the time with problems at the feed pump. This 9 contributed to, you know, exacerbating the problem even r 10 further. It certainly didn't help.

I 11 Q Sometimes you'll use a piece of equipment that  !

, 12 you're not necessarily meant to use, but you might wind up l i

13 relying on it anyway, right?  !

14 A It's not that you're not necessarily meant to use  ;

O 15 it. It is there to remove noncondensable gas from the i

r 16 condenser. In normal operations, you use the steam jet air  !

l 17 ejectors. It can be used, but, again, as I.said, it alone 18 won't support operation of the plant. It won't maintain a 19 low enough vacuum to operate the plant.

l 20 MS. CURRAN: I don't have any other questions. If {

e 21 the Board has no questions, I'll move Exhibit 154. l 22 JUDGE BECHHOEFER: One minute.

23 MS. CURRAN: Okay. I 24 QUESTIONS BY THE JUDGES 25 JUDGE BECHHOEFER: Ist me ask you one. thing.

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(202) 293-3950 i

I 1689 l

1 You've probably been asked this before by Judge Shon, but  ;

2 when it says on page 2 of 6 of the LER under 2-A, the second  !

! 3 paragraph, it says,  !

4 "MFP 11 was secured for maintenance."  !

l  !

5 I think you were asked before whether it was in l 6 maintenance or whether it was in service, but does this  ;

1 7 " secured for maintenance" mean that it was going to be in 8 maintenance or -- l

~!

9 MR. GIFFIN: It was going to be, yes. We were -- j 10 we brought the unit down to 50 percent, and then they were i

11 in the process -- when I say -- when Mr. Vosburg says 12 " clearing it," that means we have operations line it up so l 13 then they can turn that piece of equipment over to i

14 maintenance to work on.  ;

15 We were looking at a lube oil issue that was- ,

l l 16 bothering us. It wasn't -- the. pump was operable,_and, whan 17 we came down, we took it off to look at it to see what was [

18 wrong, and during the process of getting ready to isolate a 19 opponent is when the reactor -- the loss of vacuum occurred.

20 JUDGE BECHHOEFER: But the phrases " secured from 21 maintenance"?

22 MR. VOSBURG: That means -- I think what they mean 23 is the turbine was off-line. Each main -- we have two. main 24 feed pumps. Each one can support about 50 percent of full 25 power operation. So, at full power, you need both. So, to ANN RILEY & ASSOCIATES, LTD.

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' 1690-l l 1 secure and work on one of the pumps, you first come down to i

/~ ,

k-}/ 2 50 percent power, take the pump off line or secure the pump, 3 then you clear the pump, which takes all the steam sources

)

4 away, isolates it, makes it safe to work on. i i

5 Operations does all that. Once it's cleared, they j 6 turn it over to maintenance so.they can do the work on it.

7 JUDGE BECHHOEFER: The Board has no further 8 questions? f 9 MS. CURRAN: Then we'll move this exhibit into  !

i 10 evidence.

11 JUDGE BECHHOEFER: 154?  :

12 MS, CURRAN: Uh-huh.

13 MR. REPKA: Could I ask Ms. Curran to' state for j 14 what purpose she's moving it'into' evidence?-

15 MS. CURRAN: To demonstrate that there was a l 16 condenser vacuum pump that was, apparently, suffering-severe 17 leakage. l 18 MR. REPKA: May I ask the witness was there a 19 vacuum pump suffering severe leakage? l l 20 MS. CURRAN: Well, the check valve. I'm sorry.

l 21 MR. VOSBURG: There are two different components, f 22 There was no problem with the vacuum pump, other than the  :

I 23 way it was operated. Had it been operated correctly, there _

j 24 would have been no problem with this. l t

25 MR. GIFFIN: That's correct. The check valve, as ANN RILEY & ASSOCIATES, LTD.

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1691 1 Mr. Vosburg said, probably added to the problem because it 2 was leaking, but if the pump had been placed in service to 3 reduce vacuum correctly --

I 4 MR. VOSBURG: The check valve would have no 5 meaning.

6 MR. GIFFIN: It would make no difference. So I 7 guess there was a. component that needed repair, but the l 8 reason for the reactor trip was not a maintenance. issue. j 9 MR. REPKA: I think the witness has also j i

10 previously testified that there was no basis to believe the l 11 check valve was inadequately maintained, .but, having said 12 that, I won't -- in-the. interest of expediency, I won't 13 object to this document coming in, but I think it should be 14 entitled to little or no weight. i O 15 [ Judges confer.] l l

16 JUDGE BECHHOEFER: Absent objection, we will admit j l

17 154. I assume the Staff to not object? 1 18 MS. HODGDON: No. .

19 [MFP Exhibit No. 154Lwas 20 received in evidence.]

21 MS. CURRAN: The next exhibits are Exhibit 155, 22 which is LER 1-91-002-01, dated May 17, 1991; Exhibit 156, 23 which is NCR DC 1-91-WP-N012, dated May 13, 1991, and that's 24- it.

25 [ Pause.)

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1692 1 MR. REPKA: Ready, Mr. Giffin?

- 2 MR. GIFFIN: Yes, I'm ready.

3 DIRECT EXAMINATION 4 BY MR. REPKA: l 5 Q Do these two exhibits that have been identified as 6 Exhibits 155 and 156 relate to one incident?

7 A (Witness Giffin) Yes, they do.

8 Q And that was a reactor trip?

9 A It was a reactor trip, that's correct. ,

10 Q And what caused the trip? i 11 A The cause of the trip was a low steam generator 12 level in two steam generators, and that gave the necessary 13 input for a reactor trip. Now, the cause of the low steam ,

-- 14 generator level was caused by personnel error.

15 What happened, we were erecting a scaffold, and 16 the scaffolding was being erected near to the feed -- or 17 near one of the feedwater reg valves, and the carpenter who 18 was erected scaffolding was carrying six-foct planks, and, 19 as he was carrying it in the plant, he, apparently, turned  :

l 20 or moved somehow, and one end of the plank hit a very small l

l 21 valve; it has a little handle.

22 It was a 90 degree throw, and, when he hit that, 23 he didn't realize it because a small valve, large plank. I l

24 Later, when we talked to him, he said he heard a noise, and l

25 the noise he heard was the air escaping from the feed reg )

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1693 1

1 valve in the bypass.

2 So it secured -- it secured feed flow to two steam ,

i 3 generators. The operators recognized they had a decreasing 4 level, attempted to open the valve, but the air was secured, l 5 and then the reactor tripped.

l 6 Q I take it you looked into this? ]

I 7 A Yes, we have.

8 Q And identified some corrective actions?

l 9 A We've identified some corrective action which 10 include training and modifications as well to -- so that 11 this type of a personnel error -- try to minimize somebody 1

12 bumping into something that's sensitive causing a shutting a l l

valve or something that could cause an air supply to be shut l

13

! 14 or a reactor trip to occur. Yes. We've looked into it and i 15 done things. .

16 Q I would imagine you're particularly sensitive to j l

17 things that could lead to a reactor trip?  ;

18 A Oh, yes.

19 Q Are you satisfied with the corrective actions that l

20 have been taken here?

21 A Yes, I am.

22 MR. REPKA: I have no further questions. l l 23 CROSS EXAMINATION 24 BY MS. CURRAN:

25 Q Okay. Mr. Giffin, turning to the LER, which is.

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l i 1694 1 Exhibit 155, at page 3 describes four other systems or l O 2 secondary functions that were affected by this event, 3 doesn't it?

4 A (Witness Giffin) Yes, it does.

4 5 Q And those were, first -- well, I don't want to  ;

6 read it, but why don't I let you just explain each one 7 briefly.

8 A Circulating water pump of a nonsafety-related j 9 piece of equipment, when the reactor tripped, the pump 10 didn't automatically restart. The operator started it. 25 l 11 kV motor operator disconnect is something that connects the l 12 output of the main generator to the transformers, and i l

13 there's a -- it's a large thing that just opens to separate

, 14 the generator from the distribution system.

O 15 They had taped -- painters, in fact, had taped 16 pieces of plastic wrap on the drive shaft of this thing. So 17 when the operators went to open the disconnect, it didn't 18 open.

19 The second one was, again -- third one, rather, 20 was a nonsafety-related component that had-a fan fail.

21 There was some guess at what the reason was. Because it was 22 nonsafety-related, we just changed out all the starters, and 23 the third one -- the fourth one, rather, I'm sorry,.was a 24 main steam stop valve failed to close fully, and that was 25 determined.to be a brass bushing that was dry, and it was ANN RILEY & ASSOCIATES, LTD.

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1695 1 replaced.

2 Q So, as a result of this one person hitting the 3 valve with a beam, you had not just this event that that  !

4 caused, but you had a series of events that either. happened  ;

5 or were supposed to happen and didn't happen after that, 1 6 right?

7 A That's correct. There were these four incidents i 8 that we talked about or that I just briefly talked about. i 9 A' (Witness Vosburg) Well, actually, the motor 10 operator disconnect is not something that automatically i

11 happens --

t 12 A (Witness Giffin) Yeah, that was later.  !

i 13 A (Witness Vosburg) -- when_the reactor trips. ,

14 That's something that the operators do later on to realign .

O- 15 the off-site power source to the plant, and it wasn't- f 16 directly tied to the reactor trip. j i

17 Q It was done in response to the reactor trip, is 18 that what you're saying?- .l l 19 A Yes, at a later point in time.

l 20 Q Okay - Does this number of system failures give 21 you concern as a maintenance. manager? hten_the one person 22 makes one mistake, and it has all these ripple effects,_does 23 that give you a concern as to the adequacy of your 24 maintenance program?

!. 25 A- (Witness Giffin) No, it does not. It's l

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1696 1 nonsafety-related equipment. There were some problems, and O)

\- 2 we were able to deal with them appropriately. I don't see 3 that that's an issue.

4 Q Does this happen often?  !

5 A No. We don't have many reactor trips. In fact, l

6 we have a good operating record that we'll talk about later.  !

7 Q Would you say that these failures were random 8 failures, or were they related to the initial event, the 9 initial hitting of the valve with the beam?

10 A Of course they were all random. The shutting of i 11 air has to be a random event when a 12 kV motor doesn't ,

12 restart. So all of these were random occurrences. They  ;

13 just happened after the first one. The shutting off the air I

14 to the feed reg valves had nothing to do with any of the

('s 15 four events that occurred.

l 16 They happened because they happened but not -- l 17 they happened because the air was secured, but they don't --

l 18 there's no relation between the two.

I l 19 MS. HODGDON: I don't have anymore questions about 20 this.

21 JUDGE KLINE: I guess I didn't understand that l

22 last response, though. Why are they listed in this -- j 23 MR. GIFFIN: When we do a nonconformance or an 24 LER, we go through and before start-up, went to see how l 25 things -- what happened. When the unit tripped, there's a ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 l (202) 293-3950 l

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1697

( 1 lot of independent systems that are required to function, ,

l i

2 both safety-related and nonsafety-related things that you )

3 would expect to come back on line or do son'ething.

4 So, after each event like this, we take the 5 computer printout from the control room. We interview 6 operators. We interview maintenance people. We interview I 7 anybody that knows about it to determine if anything else 8 occurred after the unit tripped.

9 That's why that they're all listed. Each time 1

10 something failed, we'll look at it and investigate it to try 11 to determine why that did fail. The cause of the trip was l

l 12 the shuiting of the air supply, and then, after the unit 13 tripped, these other events occurred.

14 They weren't -- I mean, one didn't -- the air 15 didn't cause the motor. The motor caused from its own 16 separate reason.

17 FURTHER CROSS EXAMINATION 18 BY MS. CURRAN:

19 Q To follow-up on Judge Kline's question, you used 20 the term "other systems or secondary functions affected."

21 "Affected" implies there's a relationship between the first 22 event and the other event, but that's not really what you 23 mean; is that right?

24 A (Witness Giffin) I mean that because the unit 25 tripped the other thing failed, but, if I turned off air and 01

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1698 1 then turned it back on, nothing else would have failed.

2 Q Oh, I see. It was related to the trip?

3 A Yes. Not to the turning off of the air.

I 4 JUDGE KLINE: Yeah. Okay. I understand. ,

5 MS. CURRAN: I do have another question. I'm. l I

6 sorry. ]

7 JUDGE KLINE: Okay. And I do, too. l 8 MS. CURRAN: Okay.  !

9 BY MS. CURRAN: l f

10 Q In Exhibit 156 at page 9, under " Safety Analysis," t 11 it states that, l

12 "The failure of CWP 1-1 and other recent l 13 failures of the CWPs to auto restart 14 caused the reliability of the CWPs to be l O 15 questioned." i 16 Do you see that? It's in paragraph 4-A towards 17 the bottom. [

18 A (Witness Giffin) Yes.

19 Q Do you agree with that?

I 20 A Yes. And we went out and looked at it to try to i 21 figure out why didn't that circ water pump restart. It's 22 supposed to restart. There's a timer, and if it doesn't 23 start within five seconds by itself, it'll time out so it-24 on't start.

I 25 So we wanted to understand why that particular ANN RILEY & ASSOCIATES, LTD.

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i 1699 1 pump didn't start. So, yes, we were concerned with why 2 didn't it start.

3 Q Did you figure it out?

4 A (Witness Vosburg) Yes, we have, and that problem 5 has been fixed in the plant. l 6 Q What was the problem?  !

l 7 A It was a problem in an electrical relay. What 8 happens is, when the plant trips, the -- most of the l 9 operating loads in the plant are being supplied by the' main i 10 generator on the unit. When the plant trips, that power 11 source goes_ partnership, and the electric busses transfer 12 from the on-site power source to an off-site power source, 13 the start-up breaker we talked about earlier when one of the 14 ops breakers didn't open.

l O 15 Because -- the way the system is-designed, the 1

16 very large load on the bus, when that transfers to the

(

17 off-site power source, it trips off both of those large i

18 circulators and then allows one of them to re-start so you l 19 don't have an excessive load on the electrical bus.

20 So there's a relay, a timed delay relay, that has 21 to actuate to restart that one circulator, and there was a 22 problem with that timed delay relay they found that they 23 fixed and stopped it from restarting.

24 MS. CURRAN: Okay. I'm finished, j i

25 JUDGE BECHHOEFER: The LER, page 8 of 8, I guess.  !

l l

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i 1700 1 this concerned more the side effects, but does the statement 2 under paragraph 5 on that page indicate any deficiency in 3 the preventative maintenance program -- predeficiency before 4 this change in the preventative maintenance program? Take j l

5 your pick.

6 MR. VOSBURG: Well, I don't think it indicates a 7 deficiency. I think it's described in our testimony, when 8 we talk about the preventative maintenance program, it's  ;

I 9 described as a living program. As we operate the plant and l l

10 we find that, in cases like this, we found where a brass- l l

11 bushing had caused the valve to be slow to close.

i 12 We evaluate that, .and we look at the frequency 13 that we do maintenance, preventative maintenance, and we may 14 adjust that frequency based on operating experience, and O 15 this is an example of that. When we see things like this, i

i; 16 we will then go back and adjust the PM program to both

{ 17 in-plant operating experiences, things we -- information, l l 18 new information we may get from a vendor, experiences that .

l 19' we find from other power plants flout the industry.

20 So we are continually improving the~PM program,  :

1 21 and this is an example where we found the bushing probably

.{

22 should be lubricated for frequently, and we adjusted the PM  !

i 23 program to accommodate that.- l 24 JUDGE BECHHOEFER: Yeah. I take it the program f

1 25 did not cover this previously.  !

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1701 1 MR. GIFFIN: I read it the same way. I'm not 2 sure, but that's how I read it.

3 JUDGE BECHHOEFER: Now, is that the same thing 4 as -- well, this is will be a little different. I guess I'd 5 better ask that separately. Has this been done yet or not?

6 MR. GIFFIN: Yes, it has.

7 JUDGE BECHHOEFER: Okay. This next one may be 8 different. Maybe it isn't either, but, on page 7 of the 9 Exhibit 156, there's an indication that a particular form 10 has to be changed and should be changed.

11 I think APC 59 is a form -- maybe I'm wrong. It's 12 under paragraph B1-B of that document. My question is, what 13 does that involve, and has that been done?

14 MR. VOSBURG: I don't know specifically what 15 changes or improvements were made to APC 59. That's a 16 procedure that, whenever we go out to do-work in the plant 17 that involves putting up scaffolding to do the work, one of 18 the things it includes is a licensed operator or an 19 operations department person to go out.

20 They have a form they fill out that shows the area 21 in the plant where the scaffold needs to be built and a 22 description, a footprint where in the room it would be, how 23 tall it would be.

24 The operator then takes that form and goes out and 25 walks the area down and looks for things that could be

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l  !

I 1702 l 1

-, 1 bumped, valves that may need to be operated by operations 2 where the scaffolding might interfere with their ability to j 3 get to it and recommends changes to the scaffolding their ,

4 proposing based on those kind of things. i i

5 It also includes other things such a' probably 6 OSHA requirements on how the scaffold's built and tagged and 7 things like that, but as far as putting scaffolding in the  ;

l 8 plant for operational and safety reasons, there's an 9 operations representative that reviews that form, and, 10 apparently, at this point, that form -- I don't know what 11 the details are, but it said it wasn't completely filled .

?

12 out, and they made some procedure enhancements to that l 13 program to help correct that, but I don't know what the l 14 specifics are.  !

O 15 MR. GIFFIN: I think it was the sketch was missing a t

16 on the form showing how they were going to erect the j 17 scaffolding. If I remember correctly, that's the part that  !

18 was missing on the form and then enhance it so it requires a 19 better walk-down and sketch.  !

l 20 JUDGE BECHHOEFER: Has that been done? <

21 MR. GIFFIN: Yes, sir. C 59 has been revised.-

22 JUDGE BECHHOEFER: Any follow-up questions?  !

23 [No audible response.]

24 JUDGE BECHHOEFER: If not --

-25 MS. CURRAN: We'll move Exhibit 155 and Exhibit l

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7 i

i j 1703 i

j 1 156 into evidence. .

! l j 2 MR. REPKA: No objection. i 4 ,

i 3 JUDGE BECHHOEFER: Okay. Without objection, 155 i

j 4 and 156 will be admitted. .

5 [MFP Exhibit Nos. 155 and- i

! 6 156 were received in i l

7 evidence.] i

, 8 [ Pause.]  !

9 MS. CURRAN: We're skipping to 168.

10 JUDGE BECHHOEFER: Do we have time for one more? ,

l i

11 Because I gather they're going to close the building up at 12 5
00.

13 MS. CURRAN: Well, we can start. We're skipping

f. 14 all the way to 168 now. So we're on page'28 of the road 1

15 map, and the others are not -- the ones that precede that

+

16 are not going to be offered. Shall I try to get through i 17 this one?

18 JUDGE BECHHOEFER: Yeah. I was going to say, we 19 better have five minutes, though, to clear out. At least we l 20 were told they want'the building closed.

i 1 21 MR. VOSBURG: I am, I think, the one that was l'

22 designated to address this, and it'll take me a few minutes 1

23 to read through this. 168? Is that --

24 MR. REPKA: 168.

25 MR. VOSBURG: Yeah. .

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1704  !

1 [ Pause.]

2 MS. CUFOUdi: Exhibit 168 is NCR DCO-891-EM-N009, 3 dated November 22, 1991.

4 [ Pause.]

5 MR. REPKA: Mr. Vosburg, I understand you're going 6 to need some time to look at this?

7 MR. VOSBURG: Yes. You're jumping ahead. I 8 hadn't had time to try to get a little bit ahead here.

9 JUDGE BECHHOEFER: Maybe we should just close for 10 the day and start again --

11 MS. CURRAN: Do you want to start with that 12 Monday?

13 MR. REPKA: Let me just ask Mr. Vosburg. Would ,

l 14 you prefer to just --

15 JUDGE BECHHOEFER: Oh, okay. I'm -- ,

l 16 MR. VOSBURG: I would prefer it, yes.

17 JUDGE BECHHOEFER: I'm told the reporter needs ten I 18 minutes to clear the equipment out, too.

19 MR. REPKA: Let's break here, then. In view of 20 that last quantum leap, I'm willing to break here.

21 JUDGE BECHHOEFER: So we'll start with 168 I

22 tomorrow -- Monday morning. I might say that we'll start a 23 little later than I anticipated. I anticipated 9 o' clock 24 Monday. It looks like it'll take a few minutes for the 25 reporter to set up in a new location, and it might be

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1705 4 1 delayed a few minutes after 9:00, no later than 9:30.

2 MS. CURRAN: I'd like to ask, is it possible, on 4

3 Monday, if it looks like we're almost to the end but we're 4 going to go past 5 o' clock, is there somewhere to arrange to 5 stay there until we're finished?

6 JUDGE KLINE: No. The limited appearances are 7 Monday night.

8 MS. CURRAN: Oh, that's right. Okay.

9 JUDGE BECHHOEFER: And we're going to need at 10 least two hours for getting out of there and getting dinner 11 and getting back and all that.

12 MS. CURRAN: So are you going to stop at 5:00 13 Monday?

14 JUDGE BECHHOEFER: Yes, 5:00 or even slightly iO'. 15 before but no later, because we won't have time. It's

. 16 almost impossible to make it. We also have several other 17 panels and other witnesses, and by the time they get sworn 18 and get put on the stand -- I see some time taken on that, 19 and we have a Staff panel, which I have a few questions 20 already, some of which may be asked -- but, anyway, let's 21 adjourn until -- let's make it 9:30 sharp, though.

22 (Proceedings Concluded at 4:50 p.m.)

23 24 25

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REPORTER'S CERTIFICATE m

u) l This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission l In the Matter of:

l NAME OF PROCEEDING: In the Matter of: PACIFIC GAS &

l ELECTRIC COMPANY (DIABLO CANYON, UNITS 1 & 2) l DOCKET NUMBER: 50-275/323-OLA-2

(~N i

i j PLACE OF PROCEEDING: San Luis Obispo, California  !

were held as herein appears, and that this is the 1 original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and thereafter reduced to typewriting by me or under the direction of the court reporting company, and that the transcript is a true and accurate record of the foregoing proceedings.

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