ML20056F309
| ML20056F309 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 08/23/1993 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| CON-#393-14265 OLA, OLA-2, NUDOCS 9308260354 | |
| Download: ML20056F309 (200) | |
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-OFFICIAL TRANSCIUPT OF PROCEEDINGS !
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.i Agency: NUCLEAR REGULATORY COM311SSION 'i ATOMIC SAFETY AND LICENSING BOARD i
Title:
In the Matter of:
PACIFIC GAS AND ELECTRIC COMAPNY !
(DIABLO CANYON NUCLEAR POWER PLANT O. UNITS 1 AND 2) !
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i Docket No. 50-275-OLA and 50-323-OLA !
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i LOCATION: San Luis Obispo, California l l
i- DATE: Monday, August 23,1993 PAGES: 1706 - 1924 )
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1706 1 UNITED STATES OF AMERICA 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 8 (Diablo Canyon Nuclear :
9 Power Plant, Units 1 and 2) :
10 - - - - - - - - - - - - - - - - -X 11 San Luis Obispo 12 County Library 13 995 Palm Street l
14 San Luis Obispo, CA 15 Monday, August 23, 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 24 25 ANN RILEY & ASSOCIATES, LTD.
Court Reporters l 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 i
(. !
1707 1 APPEARANCES: )
. O.. 2 On behalf of Pacific Gas & Electric: .
I i
3 DAVID A. REPKA, ESQ.
I 4 Winston & Strawn l 5 1400 L Street, N.W. ,
6 Washington, D.C. 20005-3502 l i
I 8 CHRISTOPHER J. WARNER, CHIEF COUNSEL .!
t 9 Pacific Gas & Electric i
10 77 Beale Street ;
i 11 San Francisco, California 94106 12 i 13 On behalf of the NRC Staff: !
ANN P. HODGDON, STAFF COUNSEL
() 14 ]
'i 15 ARLENE A. JORGENSEN, STAFF COUNSEL ;
16 U.S. Nuclear Regulatory Commission ;
l 17 office of General Counsel j 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 ,
ANN RILEY & ASSOCIATES, LTD. ,
i Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 N
1708 1 APPEARANCES (continued]:
O 2 On behalf of San Luis Obispo Mothers for Peace: _
3 JILL ZAMEK I
4 P.O. Box 164 l 1
5 Pismo Beach, California 93448 1 l
6 ;
e 7 On behalf of Pacific Gas & Electric Company, Diablo Canyon ;
8 Nuclear Power Plant, witness panel: !
10 BRYANT GIFFIN, MANAGER MAINTENANCE SERVICES 11 WILLIAM CROCKETT, MANAGER TECHNICAL SUPPORT )
6 12 STEVEN ORTORE, DIRECTOR ELECTRICAL MAINTENANCE 13 DAVID A. VOSBURG, DIRECTOR WORK PLANNING 1
14 ,
O 15 16 17 .)
18 l 19 j i
20 i j
21 22 23 24 25 ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 ]
I 1709 ;
1 INDEX ;
O 2 Direct Cross Redirect Recross i
3 WITNESSES for PG&E:
Bryant Giffin (
4 William Crockett l Steven Ortore i 5 David A._Vosburg i 6 (Re: MFP Exhibit 168) *
[By Mr. Repka] 1714 i 7 [By Ms. Curran] 1716 l
[By Ms. ZamEk] 1733 !
8 [By the Judges] 1742 i
[By Mr. Repka) 1744 [
9 (Re: MFP Exhibit 172 -
10 [By Mr. Repka] 1746
[By Ms. Curran] 1750 4 11 [By the Judges] 1751
[By Mr. Repka] 1752 12 4 (Re: MFP-Exhibit 178) 13 [By Mr. Repka] 1754 '
[By Ms. . Curran] 1761 14 [By Ms. Hodgdon] 1765 O 15
[By the Judges] 1767 (Re: MPP Exhibit 190-193) 16 [By Mr. Repka] 1771
[By Ms. Curran] 1780 17 [By Mr. Repka] 1785
[By Ms. Curran] 1785 18 [By the Judges] 1787
[By Ms. Curran] 1789 19 [By Mr. Repka] 1792
. [By the Judges] 1793 20 (Re: MFP Exhibit 197/NCR 215) 21 [By Mr. Repka] 1795 ,
[By Ms. Curran] 1799 i 22 [By the Judges] 1803 ;
[By Mr. Repka] 1805 j 23 24 25 ANN RILEY & ASSOCIATES., LTD.
Court Reportersi 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950
. - - ~. .
r t
1710 1 INDEX (continued) 2 Direct Cross Redirect Recross 3 (Re: MFP Exhibit 210)
[By Mr. Repka] 1808 4 [By Ms. Curran] 1811
[By the Judges] 1815 ;
5 [By Mr. Repka] 1816 j
[By Ms. Curran] 1817 i 6 i (Re: MFP Exhibit 216) 1 7 [By Mr. Repka] 1818
[By Ms. Curran] 1821 8 [By the Judges] 1823 9 (Re: PG&E Testimony)
[By Ms. Curran] 1826 10 [By Mr. Repka] 1830-
[By the Judges] 1830 11 [By Ms. Curran] 1834 12 13 14 15 16 17 l
18 l 19 l l
, 20 21 22 23 24 25 ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950
,, . . - . , , - )
. . - . . . . - ~ -
1711 1 EXHIBITS 2 EXHIBITS: Marked Received 3 MFP's:
4 Exhibit 168 1745' Exhibit 172 1753 5 Exhibit 178 1771 Exhibit 190-192 1795 6 Exhibit 196 1806 Exhibit 210 1818 7 Exhibit 216 1826 8 PG&E's:
9 Exhibit 28 1838 1839 Exhibit 23 1840 10 11 12 13 14 I O 15 i
16 17 18 19 20 21 22 23 24
.25 l
ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C 20006
'(202) 293-3950 l
t 1712 1 PROCEEDINGS 2 9:40 a.m. .;
3 JUDGE BECHHOEFER: Good morning ladies and 4 gentlemen, I hope you all had a nice weekend. Before we 5 begin this morning, are there preliminary matters that >
6 anyone wishes to raise?
7 MR. REPKA: Yes, Judge Bechhoefer, I had one 8 preliminary matter, but it turns out that there's not a lot >
9 we can do with it. I passed out this morning, a document ;
10 I've identified as PG&E Exhibit 23. And if we think back to i 11 the beginning of time, sometime last week, there was a I 12 document that has been admitted into evidence as MFP Exhibit 13 90, and at that time we promised to come back and offer into .
14 evidence a later version of that document, that was an NCR.
15 And that document will be PG&E Exhibit 23. 'But I jus
- 16 learned a minute or two ago that there may, in fact, be a
]
17 more recent version than the July 7th, 1993 version that I 18 passed out this morr.ing. So, I'll defer on that until I 19 make sure I hr.ie absolutely the most recent version.
20 JUDGE BECHHOEFER: Okay. I take it we're not just
- 21 building a historical' chronicle of everything.
22 MR. REPKA: Well, I'd like to. avoid that.
l 23 JUDGE BECHHOEFER: Yeah. One of the real 24 technical questions in this proceeding is how high this pile 25 can get without falling over.
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Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950
1713 ,
i 1 MR. REPKA: Well, we've done an analysis of that, ;
2 we'll let you know what the results are. !
3 MS. CURRAN: And I bet there was a personnel l 4 error.
5 MR. REPKA: That's a design issue.
i 6 MR. GIFFIN: That's because we have the same types ,
i 7 over and over though. j i
8 JUDGE BECHHOEFER: Beyond that, any further -
9 preliminary matters that any of the parties wish to raise?
10 [No audible response.] l 11 If not, we'll go back to Ms. Curran. Am I correct that 4 12 we're doing 168?
13 MS. CURRAN: That's right.
14 JUDGE BECHHOEFER: Okay.
15 MS. CURRAN: I think we had identified the
, 16 document, but I'll do it again just to make sure. It's NCR-17 DCO-91-EM-N009, dated November-22nd, 1991. And I think 18 that's where we left off, wasn't it?
19 MR. REPKA: That's where we left off. Have we 20 distributed all the documents for this morning?
21 MS. CURRAN: All the documents except for one.
22 MS. ZAMEK: I think Rochelle's doing that right 23 now.
24 MS. CURRAN: There's just one left so, at least 25 through the road map.
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1714 1 MR. REPKA: Okay. Let's proceed with that one 2 then.
3 [ Documents passed out.]
4 MR. GIFFIN: Mr. Repka, we're ready.
5 DIRECT EXAMINATION 6 BY MR. REPKA:
7 Q Okay, gentlemen, do you have the document in front 8 of you that's been identified as MFP Exhibit 168?
9 A (Witness Vosburg) Yes, we do.
10 Q Okay, Mr. Vosburg or Mr. Ortore, I'm not sure who 11 wants to take this, but would one of you describe what this 12 NCR concerns?
13 A (Witness Ortore) This NCR was an incident where 14 maintenance personnel, while doing some work down at the 15 intake structure, recognized that there was some corrosion 16 on a handwheel on valve 496, FCB-496, and we tried many 17 efforts to free the valve initially and it was a little 18 difficult. We tried to free the valve without disassembling-19 the valve because we didn't have all the parts we needed on 20 hand. And eventually we did free the valve, it became 21 operable. And, again, this was just the manual operation of I
22 the valve, the valve was in the surveillance program. It l 23 was capable of performing its function remotely, 24 electrically from the control room. It has been on the 25 surveillance program and it has been operated, I believe, ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 i
l 1715 1 every 92' days, but the actual manual turning of the j O 2 handwheel was frozan due to corrosion.
i 3 Q Okay. Let me go back over that a little more ,
l 4 slowly. The handwheel, the manual handwheel you're talking l 5 about is on the actuator for the valve?
6 A (Witness Ortore) It is directly on the actuator, l
7 yes.
8 Q And that's where the corrosion was, was on the 9 handwheel?
10 A (Witness Ortore) Correct, the connection of the 11 handwheel to the actuator.
12 Q But the valve itself or the actuator itself is 13 also electrically operated?
14 A (Witness Ortore) Correct.
O 15 Q And that function was available?
16 A (Witness Ortore) Yes, that was operational.
17 Q And the valve, the valve was in the surveillance 18 program?
19 A (Witness Ortore) Yes, it was in the surveillance 20 program.
21 Q Can you tell me if this is a safety related valve?
22 A (Witness Ortore) The valve itself is class one, 23 only to the extent of its pressure boundary. However, the ;
24 operator that operates the valve is class two, it is non-25 safety.
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1716 1 Q So, did this corrosion on the manual handwheel, 2 did that have safety significance?
3 A (Witness Ortore) No, it had no safety !
4 significance since operation of valve is not a safety 5 function.
6 Q And do you inspect that actuator now or that 7 handwheel now from time to time for corrosion? l 8 A (Witness Ortore) Yes, we now revised our 9 surveillance such that manual operation of that and other :
10 valves at the intake structure is included in the 11 surveillance and in the PM program. ]
12 MR. REPKA: Okay. I have no further questions. i 13 MS. CURRAN: Okay. ;
14 CROSS EXAMINATION l 15 BY MS. CURRAN:
16 Q Mr. Ortore, I'd just like to understand why is it j 17 that the valve is class one, but that the operation of the 18 valve is not safety related?
19 A (Witness Ortore) The line, the piping that this 20 valve is located in is safety related. However, the opening 21 or closing of this valve is not a safety function. So, 22 since the piping or the line is safety related we need to 23 maintain the integrity of that line. So, therefore, it's 24 actually the body of the valve and all the pressure 25 retaining parts of the valve is safety related, but not the ANN RILEY & ASSOCIATES, LTD.
Court Reporters .
l 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 l
l l
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1717 i
1 operation of the valve.
O. 2 Q But if the -- okay, if the line is safety related t 3 and the valve, say, had failed closed and blocked the line, 4 would that be a safety problem?
5 A (Witness Vosburg) This valve is a -- we have.two 6 separate trains of aux salt water and at the discharge of 7 the two pumps there's a cross-tie line, and there's two ,
8 valves in that cross-tie line, 495 and 496. This is one of- l 9 the two valves that cross-ties the two systems. The valves !
10 are normally open. The safety function is -- the way the ;
11 system is designed it's to assume an active failure, that's 12 a failure of a pump, a motor operated valve.
13 You have to assume that you have an active failure l 14 in the, following a design basis accident, in the cold leg ,
15 injection and cold leg recirc phases. About 13 and a half j i
16 hours after the event, by design, then you have to assume 17 that you could either have an active or a passive failure.
18 In other words, passive failure being a pipe break. So what 19 we do at that point, 13 and a half hours after the design 20 basis accident, we separate the two trains, so they're 21 completely independent. Normally we run with the lines 22 cross-tied so at that point you can separate the two trains 23 by closing either 495 or 496 in that cross-tie line, either 24 one will separate the trains.
25 Q So you're saying you need to be able to close off i
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1718 1 the cross-tie line after the LOCA? -
l 2 A (Witness Vosburg) That's right.
3 Q Okay. And is that a safety function, being able 4 to do that? !
5 A (Witness Vosburg) It's part of the design for the ,
6 long-term recirc capabilities. So I would say, I would ,
1 7 guess, yes, it is. And that's why the pressure boundary l l
8 only is class one. The operator does not have to be class l 9 one because you have the capability to manually close the 10 valve.
11 Q Okay, so the manual closing of the valve in the 12 post-LOCA condition is the safety function for that valve?
13 A (Witness Vosburg) Yes, we take credit in the 14 design for being able to manually close it. It's normally O 15 closed from the control room. It has vital power to both of I
l 16 the two valves and that's normally how it's operated.
17 However, we don't take credit for that in the analysis. So.
18 we -- that's why we take credit for being able to manually 19 close it, yes.
20 Q Okay.
21 A (Witness Vosburg) Either one of the two, yes.
22 Q So in terms of your accident ana -- just to make 23 sure I understand this,'in terms of your accident analysis 24 for the post-LOCA condition, you do not take credit in those 25 circumstances for the capability to electrically close the ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 r
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1719
'l valve from the control room? ;
2 A (Witness Vosburg) That is correct.
3 Q Okay. Turning to Exhibit 168, I think you said i
4 there was some corrosion on this handwheel, didn't you !
5 Mr. Ortore?
6' A (Witness Ortore) Yes, I did.
7 Q In the management summary on page one, it says, l 8 there was extensive rust build-up, would you agree with ;
9 that?
10 A (Witness Ortore) That's what it says. I 11 personally did not see the valve, but yes, I -- if that's -
12 what it says, yes, there was extensive rust build-up.
13 Q Okay. And it also says on page three, if you look 14 at the second paragraph, that, O 15 " Copious quantities of penetrating oil, !
16 picks, emery paper and hacksaw blades j l
17 were all used in a cautious and -j i
18 methodical effort to free the 19 handwheel." ,.
20 It sounds like this handwheel was pretty seized up, doesn't
{
21 it?
22 A (Witness Ortore) Yes, it was and additionally, it 23 says, 24 "This job was done cautiously and 25 methodically to avoid damage to the !
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i 1720 1 operator because spare parts were still ,
O-2 not available."
3 We could have disassembled the operator at that time and 4 freed it, but we -- all attempts were made not to {
5 disassemble it.
6 Q And why didn't you want to disassemble it? l 7 A (Witness Ortore) Because spare parts were not i i
8 available in case something, some damage was, you know, ,
9 caused by the disassembly of the valve.
?
10 Q I see. And this valve could be needed for safety 11 reasons so you didn't want to take it apart, is that right?
12 Because you might have to leave it out of service for a j 13 while while you waited for parts?
14 A (Witness Ortore) No, if we would have
'([]) 15 disassembled the valve we would have been able to manually 16 operate it.
]
17 Q You would have? ;
i 18 A (Witness Ortore) Yes, we would have.
l 19 Q Then why didn't you? I don't understand.
20 A (Witness Ortore) There was no reason to operate ]
21 the valve. At that time there was not a need to close the i 22 valve. These valves are normally open and we normally run a l
23 test to stroke them to make sure that they are operable.
24 And when we noticed the rust we attempted to close it 25 manually, which is now a part of our surveillance that we ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 l (202) 293-3950 j 1
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i 1721 i 1 normally do that. And we weren't able to close the valve ,
2 manually. If the need arose to close the valve, we would I 3 have been able to close it through disassembly of the 4 operator. .i 5 A (Witness Vosburg) And there was, again, I say, !
6 there were two valves in series 495 and 496, closing either 7 valve, either electrically or manually, would supply the 8 function that we needed for the long-term recirc mode. ]
9 Q Had any preventative maintenance been done on this 10 valve before it was found in this rusted condition?
11 A (Witness Giffin) The valve was not found in the i 12 rusted condition.
13 Q The handwheel was? l l
14 A (Witness Giffin) Yes. The preventative )
i 15 maintenance tasks that were done, it was looked at and as [
16 Mr. Ortore said, the valve was surveilled to operate ;
17 electrically from the control room. But the manual portion j l
18 of going down, taking the handwheel was not done. .)
19 [Pccse.]
20 Q On page two of the NCR, at the very bottom there's 21 a paragraph that says, I
l 22 "On January 16th, 1991, the NRC resident 23 noticed a relatively old AR tag on FCB-24 495 during a walk-down. The resident 25 was aware of the importance of manual ANN RILEY &. ASSOCIATES, LTD. 3
~ourt Reporters I 1612 K Street, N.W., Suite 300 l Washington, D.C. 20006 i (202) 293-3950 l
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1722 1 operation of FCB-495 and brought the 2 item to the plant manager's attention."
3 Is FCB-496 associated with this handwheel also? 1 4 A (Witness Ortore) Not with the same handwheel. ,
5 495 and 496, either valve could be operated to perform the 6 function.
l 7 Do you know what this AR was for? l Q
8 A (Witness Ortore) I'm not sure of the details of j 9 it, however, later in here there is mention that 495 10 appeared to be -- it appeared that it was unable to close 11 that. However, that was just due to some paint that painted 12 over the connection of the handwheel and that was freed 13 fairly easy on attempting to close the valve.
14 A (Witness Vosburg) It doesn't state which -- there l
15 are two FCB-495s, one on each unit. This doesn't state 16 which of the two valves that the NRC resident had found.
17 I'm not sure either which it was.
18 Q When you say it wouldn't close because there was 19 some paint in the way, are you saying that it wouldn't close 20 during surveillance testing?
21 A (Witness Ortore) No , all the valves were 22 electrically capable of being operated, all these specific 23 valves that are cited in the NCR in the intake structure.
24 All of the valves, with the exception of 496, which is, this 25 NCR, were capable of being closed manually at the actuator. l ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950
1723 1 A (Witness Vosburg) And the valve that --
2 A (Witness Ortore) 495 was just,_it appeared to be ;
3 stuck and that was due to when we performed some maintenance i 4 on the operator, evidently it was painted, there was too 5 much paint put on and it just stuck momentarily and they 6 were able to free that.
7 A (Witness Giffin) Essentially the valve -- the ,
8 handwheel and then some of the moving parts of the i 9 handwheel, like the stem I guess would be the easiest way, 10 the screw portion was painted so it looked like it wouldn't 11 operate. But it was easy to operate manually. So that that 12 valve would have in fact shut manually as well as it did 13 electrically.
14 Q So the AR was on it because someone had had O
t 15 trouble closing it? ,
16 A (Witness Ortore) I'm not sure. It's not 17 documented in here exactly why that AR tag was on there.
18 Q Yeah, I'm just unclear if there was -- it sounds 19 like you're saying there was no problem but there was an AR 20 on it, so I'm wondering what the problem was.
21 A (Witness Giffin) Well, we put action request tags 22 on something if -- if something indicated or looked like it 23 was painted and it shouldn't have, you're not supposed to 24 paint like the stem on the valve, it's not supposed to be 25 painted because it makes it operate harder. And the AR tag ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950
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1724 !
- I could have been as simple as that for the manual closing of l this valve. I 2
i 3 Q On page five of the NCR, under Section 3, 4 subparagraph B1, it states that, 5 "No surveillance is performed on the !
6 manual operator portion of this NOV." !
7 Is that true? !
8 A (Witness Ortore) That was true at that time. We 9 now do, but at that time no, as part of the surveillance we l 10 did not manually stroke the valve, we only stroked it .
1 11 electrically. i I
12 Q Was there a reason for not performing surveillance i 13 on the manual operator portion of the NOV?
14 A (Witness Ortore) I believe we were not aware that i l
15 it was necessary to operate this manually, that this was ,
16 included in part of the long-term cooling requirement. f 17 A (Witness Giffin) It's also the portion that 18 wasn't maintained was the manual operator, which was class .
19 two. So that the class two, if you have the priorities of 20 the work, you look at what's class one and class two and the .
21 class two gets a lower priority, and that's what happened in 22 this case. The manual operation of this valve is a class 23 two. So therefore, the AR tag that was on the valve that 24 the NRC inspector, it was old because it hadn't moved up in 25 the priority scheme to get the maintenance performed.
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Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. .20006 (202) 293-3950
t 1725 f 1 Q All right. Now I'm confused again. It was my -
2 understanding that the electrical operator was class two, j 3 but that's also true of the manual operator, is it? f 4 A (Witness Ortore) No, no, the whole -- the entire 5 operator is class two, including the electrical portion of l
6 it. !
7 Q Even though you need to be able to close the valve 8 in a post-LOCA condition to close that cross-tie valve? ;
9 A (Witness Giffin) That's correct. I 10 Q Even though it has a safety function? f i
11 A (Witness Ortore) It does not have a safety 1 12 function. That function of closing the valve is not J3 required to mitigate the accident. f 14 Q Okay. Moving on to page six of the NCR, there's a' l 15 Section 2 here that discusses equipment and material and i 16 says that, ,
17 "FCB-495 and FCB-496 are subject to j 18 extreme environmental conditions which !
19 are conducive to corrosion."
20 Could you describe those conditions? Describe the location )
21 of these valves and what the conditions are.
22 A (Witness Ortore) The conditions are due to the 23 fact that they are down in the intake structure and they are 24 subjected to salt air, being in a close vicinity to the 25 ocean.
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i 1726 l 1 Q Would you say that's an aging effect, the O 2 corrosion from the salt air? )
\
3 A (Witness Giffin) I would call corrosion an effect l 4 that has to do with if you put something in -- a material 5 that will corrode in a salt air environment. Whether that's l l
6 aging or not, I'm not making that call. It is definitely i 7 corrosion. l l
8 Q Okay. It also says there that, l 9 "Past incidents of material degradation 10 have been documented for SW1-FCB-495 on
. 11 August 28th, 1981. For SW1-FCB-496 on 12 May 23rd, 1989 and again on June 29, 13 1990, and for SW2-FCB-495 on July lith, 14 1988."
15 Would you say then that this is a recurring problem with r
16 these valves?
17 A (Witness Vosburg) Well, one of those four that 18 you referenced is this event. There were three others other 19 than this reference.
20 Q Okay.
21 A (Witness Vosburg) In the August 28th, '81 AR the 22 valve was operable both by the motor and handwheel. There 23 was an AR written to say that it was difficult to operate.
24 So there was no operability consideration there. I went 25 back and looked at the records on the May 23rd event and I ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950
A i
i 1727 I I
1 could not find any details as to what the May 23rd AR, it !
O 2 wasn't an AR it was a surveillance test. It did not f 3 reference any problems with it. So, on the July '88 f 4 reference, that was another case where the handwheel had to 5 be freed up, similar to this case. So there's, of those i'
6 there's one other case similar to this where we were unable 7 to move the handwheel. ,
8 A (Witness Giffin) I think if you step back and i
9 look at this, we recognize that there were cases as written j 10 in this non-conformance report where there was rust and 11 corrosion, rust on the manual valve actuator. And also 12 looking at the low safety significance and all of the i
13 probabilities that must occur, it didn't receive a lot of i 14 attention back then. As long as-it could be operated O 15 electrically, and even in fact, in this case, one of the two i 16~ in-series valves could be operating. So there was -- and 17 we've enhanced the program to make it better. I just think 18 that this one was a -- we could have looked at it, you know, 19 hindsight, we could have, but the maintenance programs for 20 the valves has been improved by what we did and what we 21 found in this non-conformance report.
22 Q You were saying, Mr. Giffin, as long as the valve 1 23 could be operated electrically that that was a reason why 24 you attributed low safety significance to the problem?
25 A (Witness Giffin) No, the low safety significance, ANN RILEY & ASSOCIATES, LTD.
Court Reporters j 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 t
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l 1728 1 as Mr. Vosburg said, what you have to have -- this valve is 2 two in-series, one in fact could be operated and as long as 1
3 one of the two could be operated there's no safety 4 significance as in the case that was described in here. But 5 all the events which must occur, you must have a design i 6 basis accident and then 13 and a half hours, then you go to 7 shut the valve --
8 A (Witness Vosburg) Electrically.
W 9 A (Witness Giffin) -- electrically. It won't shut 10 electrically and the electrical power supply is off a vital 11 bus. Then you go to the intake to shut it manually. Then 12 between that time now semething happens and this class one 13 pipe all of a sudden ruptures and you can't get either one 14 of the two valves to shut. I think those are very, very low 15 probabilities of occurrence. So therefore, those are the 16 reasons why I say there's low significance, and in this case, no significance. I 17 18 Q But this is, this scenario that you just described a
1 19 is part of your design basis, isn't it? l 20 A (Witness Giffin) Yes, it is and we were able to 4
21 shut one of the valves, so we met the design basis.
22 Q All right.
i 23 A (Witness Giffin) Because, where's the report here l 24 that -- l 25 Q But the idea is redundancy implies that both !
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Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 l
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I 1729 1 trains are capable of operating, isn't that right? ]
2 A (Witness Giffin) Well, the redundancy, there's j l
3 the redundancy of the trains and then there's the redundancy ;
J 4 of the valves, then there's the redundancy of the power :
1 5 supplies. So I think there's quite a few sets of )
6 circumstances that things would have to not operate to get j 7 in the situation where there was any significance of this !
1 8 event.
9 Q In paragraph 2E on page six of the exhibit, it-10 states that, j 11 "These valves are located at the intake 12 structure and are subject to harsh l i
13 environmental conditions. The frequency l 14 of preventative maintenance is too low :
'O 15 to prevent corrosion of the handwheel in
}
i 16 these environmental conditions."
4-17 A (Witness Giffin) As Mr. Ortore said, there was no 18 preventative maintenance done on the hand wheels, so I 19 therefore, the frequency wasn't adequate. Now the frequency l 20 of preventative maintenance for the handwheels is adequate. ;
4 21 [ Pause.)
22 Again, this document that we're referring to is a 23 non-conformance report. The technical review group reviewed ;
- 24 this and this was not reportable to the NRC.
25 [ Pause.] j t
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Court. Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950
1730 .j 1 Q Okay, I'm still -- on page 18 and page 19, again, l i
2 the frequency of the_ handwheel maintenance is discussed. In
{
3 subparagraph A at the very bottom of page 18, and then in l 4 subparagraph B of the -- on page 19. Again, it says, .
5 "The frequency of preventative handwheel I
?
6 maintenance is too low.
7 Then in paragraph B it says, 8 " Increase frequency of preventative 9 maintenance. {
10 So, you're just saying increase from zero to something, is I i
~
'll that right?
12 A (Witness Giffin) That section that she's 13 referring to are the minute meeting for the technical review j 14 group. The body of the NCR is going to say it, but the 15 information in the body of the~NCR comes from the minutes.
]
16 So you're going to find the same statement at least two or 17 three times in each non-conformance report. The issue was-18 we weren't maintaining the handwheels; we now are. No l
19 matter how you say it, three or four different ways, it's j I
20 the same issue. j i
21 Q I'm curious, this event happened in June of 1990 )
I 22 and the NCR is dated November 22nd, 1991, can you tell me 23 why this NCR was updated apparently? i 24 A (Witness Giffin) As we go through the 25 nonconformance process each time the technical review group l
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Court Reportcrs 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 l
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i 1731 l
l 1 meets then it adds a new date. So, I'm not sure when the '
O 2 first meeting of the nonconform -- or the TRG was or when --
3 we don't have the front page, so I don't know when it was ,
l 4 signed out. But the dates that are on it are the dates of !
5 the minute meeting for that version that we're looking at.
'l 6 Q Going back to the frequency of preventative 7 maintenance, can you -- do you have to wait until a a 4
8 refueling outage to go down to the intake structure and do 9 surveillance and preventative maintenance? How does that I l
10 work?
11 A (Witness Ortore) No, no , we would not need to j l
4 12 wait for an outage to perform PM or surveillances on this. l 1
, 13 Like I said, these valves have been stroked, have been i i
14 tested, every -- on a frequency of every 92 days.
~
15 Irrespective of the --
16 Q But when you say that they're stroked or tested, i
17 that means remotely from the control room, right? j la A (Witness Ortore) Yes.
19 Q But to go down -- to go down to where the 20 component is located and look and see if it's rusting, when 21 do you do that?
22 A (Witness Ortore) That is now done, in addition, 23 every 92 days. That has been added to the surveillance test 24 and in addition to stroking it electrically we now go down 25 and we verify that we can manually close those valves. And 4
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Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 l l
r 1732 1 that is done at the same -- for the same period.
O 2 Q What kind of other equipment is located in the i
i 3 intake structure? ,
4 A (Witness Vosburg) The large main circulating 5 water pumps. Again, the only safety related equipment 6 that's located at the intake structure are these pumps, 7 these auxiliary salt water pumps.
8 Q Uh-huh.
i 9 A (Witness Vosburg) There's the, you know, the main 10 circulators, there's a screen system that filters the kelp :
i 11 from the water that goes into the main circulators. There !
12 are, there's a cooling water system for the main 13 circulators. But as far as safety related equipment goes, 14 the auxiliary salt water system is the only sys"1m that's 1 O 15 safety related.
16 Q Have you found that there are erosion / corrosion 17 effects on the main circulator system?
18 A (Witness Vosburg) On the valves, any system ,
i 19 that's a salt water system will have corrosion effects. And 20 there are, you know, any valve operating in that environment i 21 has that possibility.
P 22 Q ind is that system also inspected at a frequency !
23 of 90 days? )
24 A (Witness Vosburg) The 90 day frequency that we're 25 talking about here is the surveillance test for the 4 I
i l
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Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 1
l
I r
I 1733 1 clectrical portion of the valves that's done on the 92 day -j
(- 2 frequency because other valves in the aux salt water system 3 that are required by tech specs have a 92 day frequency. So j 4 when the surveillance test to stroke these valves was ;
5 written they put the same frequency on these valves. That's !
?
6 the significance of the 92 day frequency. !
t I
7 Q Uh-huh.
8 A (Witness Vosburg) The other -- different ,
9 components have different frequencies of PM based on all l i
10 kinds of factors that feed into it. The amount that the !
11 component might be used, the wear that could be expected, so i
12 there's no set time period for the PMs or the STPs.
13 CROSS EXAMINATION 1 14 BY MS. ZAMEK: I 15 Q I was curious to know what else was happening in ;
t 16 the intake structure because Mr. Dillard made a reference to l 17 a lot of work being done there in his testimony and also in 18 the SALP report from 1991. So I was curious to know what i 19 else has been going on in that area?
20 A (Witness Vosburg) There's ali /s 3 i of work 21 going on. There's even -- we even have a maintenance 22 facility at the intake. There's the, like I said, there's 23 the large screens that filter the, essentially any debris 24 out of the ocean water that goes through the circulators.
25 There's about, I would guess, 12 different screens down i
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l 1734 1 there. They're very large components that take a lot of r
k-s 2 maintenance. There's the circulating water system, there's 3 the intake cooling water system for the circulators, so 4 there's --
)
5 Q What I'm -- ;
6 A (Witness Vosburg) -- a lot of equipment down 7 there so there's, you know, routine maintenance going on 8 down there all the time.
9 Q Well, what I'm specifically referring to in the 10 SALP report --
11 A (Witness Giffin) We don't have a copy of that. ,
12 Q I know, I have some, should I pass them out now? ,
13 MS. CURRAN: Sure.
- 14 MR. GIFFIN: If you're going to ask us questions O 15 from the SALP report, I would like to have it.
16 [ Document passed out.] ;
17 MS. ZAMEK: On page seven. ,
r 18 JUDGE BECHHOEFER: Ms. ZamEk, let me ask you, I i 19 know you're going to bring up, or I think you're going to 20 bring up this later as well on the other Contention, how do 21 you -- do you think it should be marked now or just used as 22 a -- or it may even be in evidence already, it's part of the ,
23 applicant's exhibit.
24 MR. REPKA: Which SALP are we talking about?
25 JUDGE BECHHOEFER: Which SALP are you talking ANN RILEY & ASSOCIATES, LTD. ;
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1 l
1735 1 about?
2 MS. ZAMEK: This is the 1990/'91.
3 MR. REPKA: This is not the most recent SALP [
4 report, it's the one previous to that. -
5 MS. HODGDON: Excuse me, Judge Bechhoefer, I f 6 didn't understand your reference to the other Contention? l 7 JUDGE BECHHOEFER: Well, I assume that the other :
8 unit, the third panel.
9 MS. HODGDON: Oh, oh.
10 JUDGE BECHHOEFER: I didn't mean to say other 11 Contention, but I sort of divided them by panel. The third 12 panel addresses SALP reports and I was just inquiring f 13 whether a document of this sort should be marked now or with I guess the number I 14 a later number or how we should do this.
O 15 on it refers to the later -- but it doesn't matter, we can 16 take it with the numbering -- !
. 17 MS. CURRAN: Why don't we just distribute it for {
i 18 purposes of examining it and I think we'll move it into i 19 evidence, if we need to, later on.
20 JUDGE BECHHOEFER: Well, it's a Staff document in ,
21 any event. l 22 MR. REPKA: Just one point of confusion, the 23 document we were just handed has been identified as MFP j 24 Exhibit 185, which is the SALP, NRC SALP for the period of 25 January 1st, 1990 through June 30th, 1991. That appears to ANN RILEY & ASSOCIATES, LTD.
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1736 1 be the document identified on the road map as MFP Exhibit O. 2 184.
3 MS. ZAMEK: We substituted. So we're not going to 4 be using the current 185.
5 MR. REPKA: Okay. So is this -- <
6 MS. ZAMEK: .Or the previous 185.
- 7 MR. REPKA: Is this new-185 different from what is 8 going to be 184?
- 9 MS. ZAMEK: 184 was the most recent SALP report ;
t 10 which you have in an exhibit already.
11 MR. REPKA: Which is PG&E 20. ;
i 12 MS. ZAMEK: Right. ;
l 13 MR. REPKA: That's right, okay. Now I'm cleac. l 14 MS. ZAMEK: Okay. In the second paragraph -- .!
O 15 JUDGE BECHHOEFER: But this.is 185?
i 16 MS. ZAMEK: This is 185. i 17 JUDGE BECHHOEFER: And notwithstanding the 185 i 18 here is an NCR.
I 19 MS. ZAMEK: But we're not going to be submitting i 20 that one on the road map, I've substituted.
21 JUDGE BECHHOEFER: Oh, okay.
22 MS. CURRAN: Yeah, when we -- we'll let you know 23; as we go through the road map what's been changed.
24 JUDGE BECHHOEFER: Okay.
25 MR. REPKA: It's sort of like you need AAA to-come j
O. - ANN RILEY & ASSOCIATES, LTD. l Court Reporters .
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i 1737 1 in here and help us out. Okay. ;
O 2 CROSS EXAMINATION (Resumed) i 3 BY MS. ZAMEK: ;
4 Q Okay. Page seven, paragraph two at the last few l
5 sentences, it says, ;
6 "The second example dating back to the 7 previous SALP was water intrusion and 8 component corrosion in the intake 9 structure. Conditions in the intake 10 have continued to worsen and now include 11 concrete spalling, re-enforcing bar l 12 corrosion and component corrosion 13 wastage."
l 14 I haven't found any current documents on this. Mr. Dillard O 15 inade reference to it in his testimony that there was ]
l 16' concrete work and stuff going on in there. So I was l 17 wondering what types of repairs are going on, what types of 18 corrosion is going on?
l 19 A (Witness Giffin) The easiest way to characterize 1 20 this is that the conditions that are listed in the SALP 21 report are cosmetic in nature. Concrete spalling occurs 22 when water gets into it and the rebar that's at the surface, i
d 23 if it has any rust, it will cause the concrete to spall.
24 Spalling means just raised a little bit and then you have 1
25 cracks in it. We've had extensive-reviews done of the I l
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I 1738 1 intake structure. The intake structure is sound.
2 So this is those where, I think it was Mr. Ortore 3 who was talking about, it's kind of a harsh environment down 4 there that were the words that were in the NCR. It's in a 5 salt water environment, there's pumps, service cooling water l 6 pumps, and it's sort of damp. It's, I think it's like 20 7 feet below sea level in the area where this dampness is, so 8 that the paint wasn't staying on the concrete and there was 9 indications that some of the concrete support for non-class l 10 one piping where spalling was occurring. And that's the 11 spalling. ;
l 12 And the re-enforcing bar, the corrosion is that 13 it's a rust of the rebar that's close to the surface of the 14 concrete inside the intake structure itself. So it was, we O 15 could have done more maintenance down thers in painting and i in cosmetic types and then to scrape away all the spalling l
16 1
17 of the concrete and put in new concrete, and that's what l 18 this refers to. And the programs that we've put in place l 19 since then have made improvements to the condition at the 20 intake, but structurally the intake is sound.
J 21 Q And what about the reference to component 22 corrosion wastage, what does that mean? l 23 A (Witness Giffin) I'm not sure without going back 24 and looking at some of the other documents back there. But ;
i 25 this was also in the same time frame as the 495 and 496, so ANN RILEY & ASSOCIATES, LTD. ,
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1739 1 that's sort of a corrosion issue and that may be included in O'
2 this. There's the non-safety related equipment could be 3 corrosion. Also, the screens that Mr. Vosburg was talking 4 about are outside and they're large structures and they j 5 require constant maintenance just because they're painted .
6 and scraped and that could also be some of the corrosion or l 7 wastage that they're talking about. Other than that I'm not ;
8 sure what the specifics of these are. But I do know that '
I 9 they were cosmetic in nature and not structural.
10 FURTHER CROSS EXAMINATION 11 BY MS. CURRAN: -
l 12 Q I'm assuming that the intake structure is where 13 the plant takes in cooling water from the ocean, is that ;
i 14 right? l I
15 A (Witness Giffin) Yes. 6 16 Q And that it has some safety function then, the 17 ability to take in this cooling water from the ocean, j 18 doesn't it?
l 19 A (Witness Giffin) The safety function of the '
l 20 intake structure is to maintain auxiliary salt water 21 suction. And that's so it provides water. That's the only 22 safety related components that are in the intake.
23 Q So the integrity of the concrete in this intake 24 structure would be a safety concern, wouldn't it?
25 A (Witness Giffin) If there was a structural.
I
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1 concern it would be a safety issue, but there is not one. !
0 2 There is not a structural concern at the intake.
3 Q Well you're -- isn't the rebar a structural 4 element of the concrete, the piping there, the concrete?
5 A (Witness Giffin) Concrete is supported by itself 6 and by rebar and depending upon what size rebar, how much j 7 rebar you put in, then you look at the strength and it 1
8 depends upon what the structure's going to be used for 9 determines the size and the location of the rebar. In this 10 case the corrosion that we saw in the rebar was that rebar 11 that was close to the surface of the concrete in the 12 interior of the intake structure and that was rusted. But 13 even that rebar that was rusted, it still had adequate 14 support to do what it was supposed to do.
15 So again, I say there was no structural problem 16 with the intake. It didn't look pretty, and that was a lot 17 of it, the cosmetics and the paint.
l l
18 Q Did you do an LER on that?
19 A (Witness Giffin) Off the top of my head, I do not i 20 believe so because there was nothing inoperable about it. ;
I 21 There may be a volunteer, but I do not remember an LER. !
22 [ Pause.] !
i 23 Q If the concrete were to go unmaintained in the l
24 intake structure and the rebar were to rust extensively !
25 would you say there could be a problem with safety !
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1741 1 significance, that could cause a problem of safety ;
O 2 significance?
3 A (Witness Giffin) Of course, if you don't maintain 4 your car it probably won't run 100,000 miles, but if you do j 5 maintain it it will. And just because there's a structure 6 there, we maintain the structure, we do maintenance on the ,
7 components that are in it, we do maintenance on the ,
8 concrete, so we have a maintenance program for the intake !
9 structure. If you don't do maintenance on it and you sit, l
10 it will probably corrode, something will happen to it in 50 11 or 60 years. But we do maintain the intake structure.
12 Q Do you anticipate at some point having to replace 13 the intake structure?
14 A (Witness Giffin) No, there are no plans because 15 the intake structure is designed to last a long time and I
16 there's no plans to replace the intake structure.
17 Q How long is it designed to last?
18 A (Witness Giffin) It's designed to last for the 19 operation of the plant. So, concrete that was built when 20 this one was is good for 40, 50, 60 years depending upon how 21 you maintain it. I mean we can go around and find some old 22 cement structures and concrete structures that don't have a 23 maintenance program that last 50, 60, 70 years.
24 Q But this particular one, in terms of the design, 25 when you built it it was designed to last 40 years?
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1 1742 i 1 A (Witness Giffin) It was built to last for the 2 life of the plant.
3 Q So that must -- I mean is there a time limit on 4 that, the life of the plant?
5 A (Witness Vosburg) No, when it's designed it's not 6 designed to say it will last exactly 40 years. It's 7 designed in such that if it's maintained it could last 8 indefinitely. So there's not -- you know, when you 9 initially design a structure like that there's not a set, ,
10 it's going to last 40 years and then it's not functional 11 anymore.
12 MS. CURRAN: I don't have any other questions on 13 this.
14 JUDGE BECHHOEFER: Staff?
O 15 MS. HODGDON: No, no questions.
16 [ Pause.]
I 17 QUESTIONS BY THE JUDGES 18 JUDGE BECHHOEFER: In the situation where this 19 handwheel might have to be manually operated, following a 20 LOCA, isn't there at least a degree of susceptibility of i 21 power supply sources at that particular time?
22 MR. VOSBURG: Is the question --
23 JUDGE BECHHOEFER: Is there not some likelihood 24 that power will not be available?
25 MR. VOSBURG: Oh, it's not impossible, no. It is 1
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i 1743 .
1 powered off of a vital source from a diesel off one of the 2 vital buses. But it is not impossible for, you know, for 3 that source not to be available.
4 MR. CROCKETT: Each of the two valves have a t 5 separate vital power supply.
6 MR. VOSBURG: No , I don't believe they do.
7 MR. CROCKETT: They have the same power supply?
i 8 MR. VOSBURG: Yeah, I believe the valves are 9 powered off of the same vital bus.
10 JUDGE BECHHOEFER: Given that at least 11 possibility, shouldn't the manual operation be given almost 12 a priority to make sure it's available?
13 MR. GIFFIN: It is now, sir. We did not, at that 14 time when this was written, we did not give the manual O 15 portion of the valve the significance that the electrical 1
16 portion did. Now since this nonconformance report they now 17 get the same, they're manually operated as well as l 18 electrically operated. So they both get the same amount of 19 significance where they go and they're tested every three 20 months. I 21 JUDGE BECHHOEFER: I see. I know you mentioned '
22 both preventative maintenance and surveillance, it's not all 23 formally part of both programs? Each program -- or is the 24 preventative maintenance considered the surveillance 25 program? You mentioned both.
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.l 1744 1 MR. GIFFIN: This probably is part -- the manual 2 operation and the electric operation of the valve is ,
l 3 included in the surveillance program. 1 4 MR. VOSBURG: The corrective actions listed in the 5 NCR include increasing the frequency of the preventative l 6 maintenance activities, as it's written here, and revising l i
7 the surveillance test to both electrically and manually :
8 stroke it. ,
9 [ Judges confer.] j
?
l 10 JUDGE BECHHOEFER: That's all the questions the j 1 l l 11 Board has. Any follow-up, follow-on questions? l l
12 MR. REPKA: Just one or two brief follow-ups.
l 13 REDIRECT EXAMINATION 14 BY MR. REPKA:
1 O 15 Q Mr. Giffin, last week you described the 16 preventative maintenance program as a living program. Do 17 you recall that?
18 A Yes, sir. 1 19 Q Is this an example of that philosophy?
20 A What we mean by that is when you find something 21 that doesn't or wasn't in a program or the frequency of 22 maintaining it to do preventative maintenance wasn't what 23 you would like, then you continually maintain and keep your 24 program updated and the lessons that you leal from yourself 25 or that you learn from others.
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1745 1 Q And in this case the NCR was initiated by PG&E, O 2 wasn't it?
3 A Oh, yes. .
4 A It was initiated at the plant.
5 Q So nobody told you you needed to look at this.
t 6 You took it upon yourself to look at this?
i 7 A (Witness Ortore) No. This problem was discovered 8 by maintenance personnel.
I 9 MR. REPKA: Okay. Have I no further questions.
10 MS. CURRAN: Well, if there are no other i
11 questions, we would move Exhibit 168 into evidence. !
4 12 MR. REPKA: No objection.
13 JUDGE BECHHOEFER: That's 160? !
i 14 MS. CURRAN: 168. !
O 15 JUDGE BECHHOEFER: Okay. Okay. I just want to be 16 sure I heard it correctly. Without objection, Exhibit 168 17 will be admitted. j 18 [MFP Exhibit Nos. 168 was ;
19 received in evidence.] l 20 MS. CURRAN: Okay. All right. Now we're going to .,
1 21 move to 172, and the intervening 169, 170 and 171 will not 22 be offered. Exhibit 172 is NCR DCO-91-MM-N049, dated 23 -October 2, 1991. i l
24 [ Pause.] l 25 MR. REPKA: Okay. Gentlemen, do you have a copy ANN RILEY & ASSOCIATES, LTD.
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l l
1746 1 of what's been identified as MFP Exhibit 172 in front of 2 you?
3 MR. GIFFIN: Yes, we do.
4 [ Pause.]
5 MR. GIFFIN: Yes, we're ready..
6 DIRECT EXAMINATION 7 BY MR. REPKA: i 8 Q Okay. Mr. Giffin, do you want to give me a brief 9 description of what this NCR involves?
10 A Yes. During testing of the diesel generator 13, i
11 maintenance personnel went down to tighten a test cock, -
12 which is a fitting on the cylinder head that you can correct 13 instrumentation to for compression readings in each j 14 cylinder, and a maintenance worker went down, and the diesel 15 has many cylinders, and he inadvertently went to the wrong 16 cylinder, and, when he tightened the test cock, it broke. .
i 17 It actually came out that he tightened the test
. 18 cock on cylinder 2, and the one that we'd replaced was in l
19 cylinder 8. So we went out to determine why did the test 20 cock break, and we addressed a personnel error as part of a 21 different quality evaluation, not as part of this 22 nonconformance.
5 23 We found out that the -- it was a fatigue failure 24 of the test cock caused it to break. When we took it out 25 and evaluated why did it break, we figured that there was ANN RILEY & ASSOCIATES, LTD. i Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 !
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1747 ,
1 vibration that loosened the test cock, and then it loosen --
2 after it was loosened, fatigue caused a crack, and, when the {
3 mechanic tightened it, it broke.
4 We talked to the vendor and asked him what about 5 this, what do we need to prevent it, and he was about ready 6 to put out a bulletin whereas a copper washer was going to 7 be used to -- for the test cock to attach it.
8 So we replaced and added copper watches to our 9 test cocks, and a test then done on the diesel tests 10 satisfactory. So this actually occurred during a 11 maintenance process and subsequent post-maintenance test to 12 determine that the maintenance had been done correctly when 13 he went down.
1 14 Q Let's take that a little more slowly. So it was O 15 during post-maintenance test a test was working on this test ;
1 16 cock?
17 A Right. The post-maintenance test was after the i
18 test cock was replaced on cylinder 8, and the mechanic went
]
19 down. They went to look to see if it was okay, and there .
I 20 was a leak seen on the test cock on cylinder 8. So he was I l
21 sent down, and he tightened the one after the diesel was 22 turned off. He went and tightened the one on cylinder 2.
23 Q Did he then go back and tighten the one on 24 cylinder 8?
25 A Oh, yes.
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1748 1 Q But it was when -- the test cocks are all the same 2 on the cylinder heads?
3 A Yes, I believe they are.
4 Q And with respect to the personnel error-here on 5 tightening the wrong one, was that addressed?
6 A Yes. That was addressed, as the nonconformance 7 says, in a quality evaluation. We have different levels of 8 quality paper. There's a problem that occurs. A 9 nonconformance report is one, and then, if the issue is not 10 as significant as what we would write a nonconformance 11 report on, but still a quality problem that we want 12 addressed, then we address that with a quality evaluation, ,
13 which, again, requires a root cause analysis, review and 14 action to be taken to prevent reoccurrence, but it doesn't O 15 have Technical Review Groups or the same review process that 16 a nonconformance report does.
17 Q Okay. And then the other half of this was that, 18 when he tighten it, it cracked, and that was the equipment 19 problem?
20 A Correct.
21 Q And they fixed that after consultations with the 22 vendor?
23 A Yes. l J
24 Q Did -- and I gather that it was a -- from the 25 words of NCR, a fatigue-induced crack may have caused it to l
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l 1749 l
1 break when was over-torqued?
O O A Yes.
- 2 3 Q And did that condition -- did you determine if 4 that condition existed in any of the other test cocks?
5 A How we did that, you make sure that the -- the 6 reason the crack occurred was because the test cock had 7 become loose, and then that allows the vibration, and the 8 way that you determine that the other test cocks are okay is 9 you go and you tap them, and you get a different -- if it's 10 tight, you get a ringing sound, and if they're loose it, 11 probably, is like a clunk.
12 So you can tell the tightness of the test cocks by 13 tapping it, and it's called, what's in here called 14 " ringing."
15 Q And did you test all the other test cocks?
16 A All test cocks on that diesel as well as the 17 others.
18 Q And did you find any other similar cracks?
19 A No, we did not.
20 Q Would the one you found on cylinder 2 that cracked 21 when he tightened it, did the condition as it existed, would l 22 it have affected the function of the diesel?
23 A It's not in the nonconformance report, but I 24 remember that this one test cock, what that would do is 25 reduce the compression in one of the 18 cylinders. So it ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1612 K Street, N.W., Suite 300 i Washington, D.C. 20006 l (202) 293-3950 j
4 1
I 1
1750 1 would have a slight effect on one cylinder but not have a 2 tremendous, large effect on the diesel.
3 Q Okay. And are you satisfied that this Iscue has 4 been resolved?
5 A Yes, I am.
6 MR. REPKA: I have no further questions.
7 MS. CURRAN: All right.
8 CROSS EXAMINATION 9 BY MS. CURRAN:
10 Q Do I gather that at some point somebody went 11 around and tapped all these test cocks to see if they were 12 making a funny noise that indicated they were a little '
13 loose?
14 A Yes.
15 Q Okay. And then they decided to go down and fix 16 number 8-R because it was loose?
17 A No. The nonconformance doesn't discuss why we L
18 were working on cylinder 8's test cock. I don't know what 19 the reason for working on that diesel. They may have been 20 checking compression, I don't know.
21 Q So you don't know if this tapping exercise was ,
22 done before 8-R was -- they decided to work on number 8-R?
23 A It was not done prior to that.
A 24 Q Okay. It, basically -- the weakness in number 2-R 25 was discovered only through the mistaken tightening of 2-R, l
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1751 i 1 right?
2 A That's correct. However, if it had been very l 3 loose when you started diesel and if the test cock wasn't ]
4 there, it, essentially, opens the~ cylinder to the 5 atmosphere, and you see that it shoots out smoke, and you 6 can see that there's not a test cock there, and each time a 7 diesel would run, somebody goes and inspects it.
8 So, if the test cock had failed, it would have t
9 been seen during the next time the diesel was running.
10 MS. CURRAN: I don't have any other questions on 11 this one.
12 QUESTIONS BY THE JUDGES 13 JUDGE BECHHOEFER: Is what's labeled STP N-81 part i 14 of maintenance program?
15 MR. GIFFIN: STP, that's surveillance Test -
16 Procedures. That's part of the surveillance program. One 17 additional thing, this is also our -- you know, we found 18 this. It's our nonconformance report. This was not 19 reportable.
20 JUDGE BECHHOEFER: Okay. But this STP M-81, the 21 surveillance program, then, was modified? I'm reading from 22 page 8. I think it appears elsewhere. It appears on the ;
23 cover sheet as well, pages 1 and 8.
.24 MR. GIFFIN: Yes. It says that as well as 25 changing the maintenance program the surveillance test was !
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1752 1 also done so that you go down and you ring to make sure that 2 the test cocks are, in fact, tight.
I 3 JUDGE BECHHOEFER: That is not done previously?
4 MR. GIFFIN: No, it was not.
5 JUDGE BECHHOEFER: If it had been, would you have i 6 prevented the break that occurred? Or might it have?
7 MR. GIFFIN: Depending -- yes, because if we had 8 gone down and checked that all the components on the diesel 9 were tight prior to, then we would have found that this one 10 was loose prior to the start of the diesel. So we could 11 have detected it that way, yes. ,
12 JUDGE KLINE: But actually, if you use this ring 13 test where you hit it and listen to it. Would have gone t
14 clunk, and the fellow probably would have tried to tighten i
I 15 it, and it would have broke it off anyway, wouldn't it?
l 16 MR. GIFFIN: Oh, I think the same results would 1 17 have occurred-only at a different time for a different 18 reason.
19 JUDGE BECHHOEFER: That's all the Board has at 20 this time. Follow-up? I 21 MR. REPKA: One follow-up.
22 REDIRECT EXAMINATION 23 BY MR. REPKA: l 24 Q Mr. Giffin, in response to Judge Bechhoefer's 25 . question about if the surveillance had included the test k ANN RILEY & ASSOCIATES, LTD.
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1753 1 earlier you would have found it earlier, I think was the 2 question or the implication, could you address for me 3 generally the idea that can you have -- conceptually, can 4 you have a surveillance test that picks up an equipment 5 problem or an equipment failure before you have the 6 experience that would indicate that you should do that kind 7 of test? I mean, does that sound logical to you 8 A (Witness Giffin) Well, no. It doesn't sound 9 logical to me, but if it had been in a program, we could 10 have found it. In this particular case and in discussions-11 with the vendor, this they thought was a very unique and 12 unusual occurrence. So with today's, you know, hindsight, 13 we could have. At that time I don't believe either us or 14 the vendors, and there's a lot of experience on'these 15 diesels, would have thought to check this.
16 MR. REPKA: Okay. Thank you.
17 MS. CURRAN: Well, if there's no other questions, 18 we move Exhibit 172 into evidence.
19 MR. REPKA: No objection.
20 JUDGE BECHHOEFER: Exhibit 172 will be admitted 21 into evidence.
22 [MFP Exhibit No. 172 was 23 received in evidence.]
24 MS. CURRAN: We are not going to be offering 25 Exhibits 173 through 177, and the next exhibit is Exhibit ANN RILEY & ASSOCIATES, LTD.
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1754 1 178, which is NCR CO-91-TR-N044, dated September 26, 1991, 2 and Exhibit 179, which is an NCR Human Factors Study Report, 3 Diablo Canyon 1, dated August 23, 1991. '
4 MR. REPKA: Gentlemen. Do you have copies of 5 those two exhibits? ,
6 MR. GIFFIN: Yes, we do.
7 MR. REPKA: I think I'm going to want to address 8 those one by one. So let me know when you're ready with 9 178.
10 [ Pause.]
11 MR. REPKA: Okay?
12 MR. GIFFIN: Yes.
13 DIRECT EXAMINATION l u
14 BY MR. REPKA: 1 15 Q Gentlemen, in your direct testimony, at pages 29 16 to 34, you may recall you discuss at length a training and 17 qualifications of maintenance personnel. Do you recollect 18 that testimony? !
i 19 A (Witness G'iffin) Yes. I was just recollecting I
20 the pages. .
l 21 Q You can take my word for it? ;
22 A I believe you. l l
23 Q The document you've been handed marked as MFP l
24 Exhibit 178. That seems to be an NCR related to ;
i 25 . qualifications of maintenance personnel; is that correct?
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f 1755 1 A Yes. We don't have the first page of the NCR.
O 2 Q Do you'have the management summary page?
i l
3 A No. The first page of the NCR where it's signed !
i 4 and people who signed it, but I believe -- the cover page, ,
i 5 but I believe how you spoke is correct.
6 Q Okay. Does this NCR, on your review, seem to ,
7 alter anything you stated in your direct testimony?
8 A No, it does not. j i
9 Q Would you like to give me a brief description of 10 what this NCR was about?
11 A Yes.
12 Q If you'd said no, I would have been worried, but 13 go ahead.
14 A Just a little background, and some of it's in my 15 testimony, and I will try to be brief, but the way our 16 training program works at Diablo Canyon, in order for anyone 17 to be assigned to work on a component, they must be a 18 journeyman, and, depending upon which journeyman, the 19 apprentice program varies from two to four years and is a 20 state-approved -- when he finishes his journeyman training, 21 he is a state-approved journeyman.
22 In addition to the state-approved journeyman i
23 program, we then go and increase the training requirements j i
24 for each individual to include those that are in INPO, and 25 our INPO accreditation requirements say what we're going
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1756
)
1 to - prior to sending someone out, he'll be qualified on :
O 2 that particular piece of equipment.
l 3 What was happening -- and we directed this 4 nonconformance, because there was really no nonconforming 5 condition. So it was our decision let's look at this, 6 because I believe it was during a QC surveillance they found 7 that there were cases where the foremen were sending 8 journeymen out to work without referring to the 9 qualification matrix.
10 What the matrix was, it listed all the journeymen 11 assigned to that particular discipline and all the 12 particular tasks that could be performed, and then they'd go 13 in and say, "Is he qualified to work on this item?"
14 So there were cases where that wasn't being done.
O 15 Each discipline was trying to come up with ways to make it 16 easier for him to follow the intent of only making sure that 17 qualified people went out to work. So the mechanical and 18 electrical and INC sections, they had different matrices, 19 and they were implementing the requirements a little 20 differently.
21 So what we did is we formed this nonconformance 22 report to get all those disciplines together to come up with 23 a way to simplify the job for the foreman, make his task 24 easier so that it was easier for him to assure systems that, 4
25 when he sent someone out to work, he was qualified to work l ) ANN RILEY & ASSOCIATES, LTD.
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l 1757 :
i 1 on that task. l O 2 In some of the cases, the foremen weren't 1
3 checking, because they'd been working with this particular [
4 journeymen for ten years or for. So they know. The foremen 5 know their people and what the qualifications of those f 6 individuals are. So there were some cases where, if he knew j 7 the person and he'd known him for years and worked with him, 8 that he didn't necessarily refer to the matrices. 4 9 So we had this nonconformance, and I believe -- it 10 is. We put it under training. We asked a training director 11 to chair this particular TRG with inputs from all of the i 12 people and to assure ourselves that we could get one simple ,
13 system that the foremen could use.
i 14 Q so you say that there were cases where the matrix l O 15 was not reviewed prior to sending the worker out. Can you i
16 give me a sense of was that widespread? j 17 A I'm sorry. I was Icoking at my testimony. Would 18 you please repeat the question?
19 Q Well, you said there were cases. Was this )l 20 widespread, or was it just a few cases? j l
21 A There were -- I'm not sure how many. There were !
I 22 enough that, during a QC surveillance, when he came back and )
- 1 23 talked to us about it, we believed that we needed to do l l
24 something to rectify that. I imagine if it had been one or ;
i 25 two cases, I wouldn't have had or recommended that we have '
l l
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l l
1758 i 1 this group get together to look into it. I don't know how 2 many there were, however.
3 Q But was there any indication that unqualified 4 workers were, in fact, being used, notwithstanding this )
5 process?
6 A No. No. .
7 Q Was there any indication that any particular work .
8 was compromised?
9 A No, there was not. This is a documentation issue 10 to try to make sure that those INPO requirements that we 11 added above and beyond the journeymen training that we were 12 documenting them the same way so that we can go back and 13 look at the record.
14 Q Is this an example of improvement --
15 self-improvement in the process?
16 A Oh, yes. We saw that there was an issue, and we 17 got everybody that was a stake holder in this and got them 18 together and asked -- the way that this was formed is that 19 the people who worked with a system were asked, "What could 20 we do to make this system better for you?" Questionnaires 21 were given out to try to get everybody that worked with a 22 system's input so that we'd have a better system.
23 Q So this would appear to me to be an example of 24 your continuing improvement philosophy that you talk about?
25 A Yes.
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1759 1 Q Is that true?
2 A Yes.
3 Q Have corrective actions resulted from this effort?
4 A (Witness Crockett) Yeah. In fact, if you looked: l l
5 at page 30 of our written testimony and you look up at the l 6 top, there's a statement about a self -- it says, 7 "In the last NCR, systematic assessment and j 8 performance report on maintenance area at 9 DCCP the NCR, listed as a noteworthy strength 10 that the qualifications of training and 11 qualification programs for maintenance 12 personnel is strong, well-maintained training 13 facilities and a dedicated training staff, 14 were significant factors in good performance O 15 as was the sense of ownership by the f 16 maintenance personnel."
17 Q So, Mr. Giffin, are you satisfied with the way the .
18 process works now?
19 A (Witness Giffin) Oh, yes. I think that we 20 recognized there was some way that we could improve. We ,
21 implemented those improvements, and those improvements have 22 been recognized.
l 23 Q Okay. Let me turn now to the document that's been 24 identified as MFP Exhibit 179.
25 A Yes.
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1760 1 Q This is an NCR Human Factor Study Report, and it 2 appears to me to speak to an incident where a technician was 1 3 performing work he was unqualified to do. Do you recall 4 that?
5 A I read what it says. I disagree that the 6 technician was not qualified to do the task in which he was ;
7 doing.
l 8 Q In my opinion, he was qualified to do the work. !
, 9 He'd been he plant site for eight years, and this was the l 1
10 final thing. He'd had the drawer pulled out. He'd been 11 performing maintenance on the drawer. He knew which drawer 12 he was doing maintenance on, and he went to another drawer 13 and pullvd fuses.
14 I don't believe that -- the training was not an 15 issue in this case. We disagree.
16 Q The distinction you're drawing here is that his 17 qualifications were sufficient, but he still made a mistake?
18 A Yes, he did.
19 A (Witness Crockett) In fact, I talked to him the 20 same day that he made the error, and that morning -- and we 21 went into the control room and went right where he had his 22 equipment set up in the drawer, and I asked him about 23 self-verification, if he knew about self-verification and 24 the requirements of that, and he said yes. He said he knew 25 it.
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. _ _ . _ . _ . _ ~. . _
1761 1 In fact, as Bryant said, when he pulled the 2 fuses -- the drawer and test that he was working on was i 3 pulled out with test leads going into that drawer. I asked
, 4 him to show me how he would do it, how he pulled the fuses, 5 and he did it exactly -- he said, "This is exactly what I j 6 did." He leaned, put his arm on the drawer that he was 7 working on and pulled fuses on the next drawer, and I said, 8 "What happened?" He says, "I just wasn't thinking."
i 9 A (Witness Giffin) It wasn't like it was the first ;
i 10 step in the procedure. They were almost finished.
l 11 A (Witness Crockett) He'd pulled the correct fuses l 12 earlier in the procedure. {
1 13 Q So he was qualified?
i 14 A It wasn't the first time he'd pulled those fuses. !
' O 15 He had pulled the fuses on that door correctly earlier in f i
16 the shift. !
i-17 Q He was qualified. He just screwed up? !
t 18 A He was qualified. He screwed up.
19 A (Witness Giffin) Just turned off. ,
20 Q Is he still around the site, do you know? i 21 A He does not work at the plant anymore. }
i 22 MR. REPKA: I have no further questions. [
I 23 CROSS EXAMINATION i 24 BY MS. CURRAN ,
25 Q To stay with this example, on page 2 of Exhibit j t
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?
1762 1 179 --
O 2 A (Witness Giffin) Which 2, please.
3 Q Oh, I guess it's the cover letter. Page 2 of the 4 cover letter.
i 5 Q Thank you. ;
6 A Or cover memo. In the first paragraph there under .i l
7 Shift Structure," it says, 8 "The license control room operators felt 9 their performance was adversely affected -
1 10 by the limited capabilities of the ;
11 unlicensed assistant control operator 12 who does not receive reactor operator 13 training and does no training with the 14 crew on the simulator." i O 15 Is that true?
16 A (Witness Giffin) I'll pass that one to 17 Mr. Vosburg.
18 A (Witness Vosburg) The tech spec requires a 19 minimum number of licensed operators in the control room.
20 At Diablo Canyon, we typically have more than what the tech 21 spec requires in the way of licensed operators in the 22 control room. In addition, there are unlicensed auxiliary 23 control operators in the control room. I 24 An auxiliary control operator is, basically, an j 25 assistant to the control operator. Under federal law, there ANN RILEY & ASSOCIATES, LTD.
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1763
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1 are certain things that -- certain controls that license O 2 personnel can only operate, and those are, basically, ;
r l
3 anything that directly affects the reactivity of the ;
4 reactor. ,
5 There are many controls in the control room that 6 are operated by the assistant control operator. In this !
i 7 case, after this trip, the assistant control operator, if I l 8 remember right, was instructed to go over and close a F 9 particular valve by number. He used to go close FCV 249, ;
10 whatever the number was. l
^
11 He did not know exactly where that was in the 12 control room, and the CO had to point -- you know, point it j 13 out to him. That was the particular example that was -l 14 pointed out here. Auxiliary control operators that are O 15 nonlicensed -- we have both licensed and nonlicensed --
i l 16 typically do not train on the simulator at the same time the 17 normal crew does, and that was the comment. [
18 When this team came into the plant, they !
19 interviewed a lot of the operators, and this operator felt 20 that he should be training on the simulator with the rest of 21 the crew, and he made that comment to the inspector, and it 22 was incorporated in the report.
23 A (Witness Crockett) Let me add also that this j 24 report doesn't just look at the maintenance side of this ;
I 25 issue. It came and evaluated the operations staff to see if j O ANN RILEY & ASSOCIATES, LTD.
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t 1764
- - 1 they responded properly to the event, and the only part that 2 really deals with the maintenance issue was the second item 3 on page 2 of that where it says, l
4 " Human factors of surveillance testing."
5 The other paragraphs in that cover letter are !
6 dealing with operation's response to that event.
7 A (Witness Vosburg) Yes. The question you just l 8 asked is an operations issue. It has nothing to do with T
9 maintenance. ,
10 Q On page 13 of Exhibit 178, paragraph F, 11 subparagraph 1, it states, 12 "The maintenance personnel f
13 qualifications for all tasks are not 14 proceduralized."
15 Has this been done? l 16 A (Witness Crockett) Well, you know, I'm not quite 17 sure what that statement refers to, because the maintenance l l
18 personnel qualifications, the procedure for that, they've 19 been in existence for a long time, and they were at that l 20 time prior to and still are. So we have -- we have 21 procedures that govern that.
22 In fact, that's part of the accreditation process 23 is that you have to have procedures that control and 24 evaluate those kinds of tasks. So I don't know what the --
25 I don't know what that statement's referring to, because Os ANN RILEY & ASSOCIATES, LTD.
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l 1
1765 ,
t 1 that's part of our accreditation requirements. !
O' 2 A (Witness Giffin) And it's also, if you read it, !
3 it says, 4 "The following additional perceived 5 contributory causes were brought up."
6 So I'm not sure what way the perceived comment is.
7 This is just -- because we asked them to look in depth at 8 this, and they talked to all the individuals, these are some 9 of these perceptions. :
10 Q And just to go back to page 1 of the 11 maintenance, it says, " Management Summary," on Exhibit 178.
12 It appears, from paragraph 1, that this particular concern !
13 about maintenance personnel qualifications was raised by ]
i 14 INPO in an accreditation evaluation; is that right? ]
O 15 A That's what the first paragraph says, yes, but -- t 16 the maintenance program is c credited by INPO and was
- 17 re-accredited by INPO. :
18 MS. CURRAN: I~ don't have any other questions on 19 this one.
20 MS. HODGDON: I have a question. I'm not sure ,
21 that I heard Mr. Crockett's answer completely.
22 CROSS EXAMINATION 23 BY MS. HODGDON:
24 Q Mr. Crockett, you said that the NCR Human Factors 25 Study Report, Exhibit 179, does not state that either the ANN RILEY & ASSOCIATES, LTD.
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1766 I 1 technician, the INC technician or the unlicensed assistant O-2 control operate for was unqualified; isn't that correct?
3 A (Witness Crockett) No. What the report says is ,
4 is that it thinks one of the contributory causes was that a 5 technician that was doing the calibration did not have a 6 specific documented qualification for self-verification, and 7 that might be true.
8 That technician might not have had a documented, l
9 official record that he had specific training in 10 self-verification, but I know myself, when I asked him that 11 morning of that trip, I asked him if he was aware of the l l 12 requirements, and he said, "Yes. I knew what I was supposed 13 to do."
14 Q Are we, then, arguing about what " qualification" l O 15 means here?
16 A (Witness Giffin) I think what we're saying is 17 that we, regardless of what it says in here, in the Exhibit 18 179, we felt that that technician was qualified.
19 Mr. Crockett talked to him, and the qualification issue is 20 self-verification.
21 Mr. Crockett talked to him, and I talked to him 22 after the event as well, and there is no doubt in my mind 23 that that technician that we asked to do that task knew how 24 to do it, had done it before, and it was not a qualification 25 issue.
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1767 1 Whether it had self-verification signed off in his l
\- 2 qualification record or not, he knew what he was supposed to 3 have done, and he did not do that. So I don't think that we l l
4 ere in disagreement. :
5 MS. HODGDON: Thank you.
6 MS. CURRAN: If there's no further questions --
7 JUDGE BECHHOEFER: Well, there's at least one.
8 MS. CURRAN: Okay.
9 QUESTIONS BY THE JUDGES 10 JUDGE BECHHOEFER: In terms of qualification, are .
11 there not technically specified or. written specifications !
J2 for qualifications for particular tasks? ,
13 MR. CROCKETT: That's correct. ,
14 MR. GIFFIN: There are.
15 JUDGE BECHHOEFER: Now, if this particular person 16 we're talking about -- I believe there's testimony that he 17 was known to be qualified -- well, my question is, is that 18 good enough. Doesn't there have to be -- doesn't he have to .
t 19 also meet the technical specifications, the written 20 requirements for the particular task? ;
21 I mean, the fact that one said, "Oh, he could do ;
22 it. He's well-qualified," is that good enough?
23 MR. GIFFIN: No. Just to say, "I know how to do 24 it," that's not good enough. However -- well, let's :
l 25 separate the two. The technical specifications, there is no O. ANN RILEY & ASSOCIATES, LTD.
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t 1 requirement for his training in the technical specifications.
2 So that's -- separate those issues.
I 3 I believe it was a few days ago, I can't remember 4 which day last week, we talked about this event, and another 5 NCR addressed this same event that the Exhibit 179 was i
6 talking about.
7 The corrective action out of that was we 8 formalized the self-verification part of the training ;
i 9 program. Before, it had not been written down that people {
10 were trained on, and self-verification was discussed with l 11 people, but there was no record and no, you know, formalized 12 part of the training program.
13 After this event, we included self-verification 14 training as part of laboratory hands-on mockup training. So O 15 there was no " requirement" anywhere to have this type of i
16 training. We added it ourselves.
17 JUDGE BECHHOEFER: And now that you've added it, 18 if someone gets assigned to do something and doesn't meet 19 all of those requirements, self-verification, et al., that 20 would come up as what, another nonconformance?
21 MR. GIFFIN: No, sir. He just wouldn't be 22 assigned to do the work by himself. He'd have to go with a l 23 qualified individual. We use, as part of our training ;
24 program --
25 JUDGE BECHHOEFER: Well, I was hypothesizing the s
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- w
I 1769 1 situation where he was told -- notwithstanding his failure O 2 to meet all the technically established requirements, 3 written requirements, notwithstanding that failure, he was 4 told by someone, "Well, you know how to do it. Go do it."
5 Would that be some sort of a nonconformance?
6 MR. GIFFIN: If what you said occurred, then we ,
I 7 would evaluate what he was being sent to do, how he 8 performed it. So I can't say that it would be a QE or a ,
9 nonconformance report. It would depend upon the 10 circumstance.
11 Each type of a personnel error, which I would call 12 that, if I sent someone out to do a task he wasn't 13 qualified, that would be a personnel error, and then we'd. j 14 look at those to determine what -- why that happened, and 15 then we would then have paper that would address that, 16 depending upon those particular circumstances.
17 So I can't say I don't know what I'd do. It would 18 depend upon what would happen. If it involved safety 19 related equipment and maintenance work was done or 20 operations work was done incorrectly, then there would 21 probably be at least a quality evaluation or, perhaps, a 22 nonconformance report.
23 If it was of a nonsafety significance, it may have l
l 24 something else. It may have a bulletin to the other folks l
l 25 in that section telling them what happened and what we need l
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1770 1 to do about it.
2 JUDGE BECHHOEFER: Okay. Thank you. Any follow-3 up?
4 MR. REPKA: No.
5 MS. CURRAN: Then, if there's no further 6 questions, Mothers for Peace moves Exhibits 178 and 179 into 7 evidence. Oh, there I go again.
8 JUDGE BECHHOEFER: One's a Staff document.
9 MS. CURRAN: I didn't mean to do that. Just 178.
10 MR. REPKA: No objection to 178.
11 JUDGE BECHHOEFER: The Board admits MFP Exhibit 12 178. Point of inquiry, is it crucial that the cover page is 13 missing, or would that not affect anything that we talked 14 about?
15 MR. REPKA: I don't believe so. I don't think 16 we've had cover pages on a lot of these, but let me ask 17 Mr. Giffin.
18 MR. REPKA: Do you feel the need to have the cover 19 page on that NCR?
20 MR. GIFFIN: No, I do not. I'll go back and look 21 at it, and if I decide that it adds something, I'll bring it 22 back.
23 [ Pause.]
24 JUDGE BECHHOEFER: Okay. Thank you. The exhibit 25 will be admitted.
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i 1771 1 [MFP Exhibit _No. 178 was 2 received in evidence.]
l l 3 MS. CURRAN: Before we go on to the next exhibit, 4 we'd like to ask for a 5- or 10-minute break.
5 JUDGE BECHHOEFER: Yeah. I was just going to say 6 it's getting to that time. Why don't we take our -- take 7 our usual 15-minute break.
8 [A brief recess was taken.]
l 9 JUDGE BECHHOEFER: Back on the record.
10 MS. CURRAN: Okay. We are not going to be 11 offering Exhibits 180 through 189. The next exhibits are 12 Exhibit 190, which is NCR DC 1-91-TN-N002, dated February 13 18, 1991; Exhibit 191, which is NCR DC 1-90-0P-N083, dated 14 February 8, 1991; Exhibit 192, which is LER 1-91-015-01, 15 dated January 25, 1991; and Exhibit 193, which is NRC Review 16 of LER 1-90-015-00, dated January 18, 1991.
17 MR. REPKA: Okay. Gentlemen, do you have copies 18 of those documents?
19 MR. VOSBURG: Yes, we do. l 20 DIRECT EXAMINATION !
21 BY MR. REPKA:
22 Q These appear to not be in chronological order. So 23 maybe the easiest way to take this is if you start with 24 what's been identified as MFP Exhibit 191 and give us a 25 brief chronology of what these documents relate to.
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i 1772 1 A (Witness Vosburg) Yes. Exhibit 191 was a l t
- 2 nonconformance report written to address an Engineered i 3 Safeguards Feature actuation that occurred on December 8, 4 1990. The particular ESF that was actuated in this case was 5 the feedwater isolation system.
6 This occurred during -- there was a reactor trip 7 on 12/5/90, and this occurred on the start-up following that [
8 reactor trip. In the period that the reactor was operating ,
9 prior to that trip, there, apparently, was some drift in the 10 controllers for the feedwater reg valves, such that, when 11 you had zero demand on the controller, the valve wasn't 12 fully shut.
i 13 This causes no problems while you're operating, ;
14 since the valves are open. However, on a start-up, you 15 initially start with those valves closed. What you have 16 was, as the operators were starting up the reactor, bringing ,
27 the power level up, at about 3 percent hour, you bring up j 18 the main feedwater pumps, and they start supplying the 19 generators.
20 Until that point in time, feedwater is being 21 supplied to the steam generators by the auxiliary feedwater 1 22 system. So there's a transition from the aux feedwater 23 system to the main feedwater system at about that point.
24 What happened is, when the operators brought up 25 the main feedwater pump, the leakage through the valves that ANN RILEY & ASSOCIATES, LTD.
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l
l 1773 1 had the positioner shift during the last period of operation 2 became a factor, and it caused a large increase in feedwater 3 flow to the steam generators.
l 4 One of the features that's designed into the plant 1
5 to protect the turbine, the main turbine and the main feed 6 pump turbines, is called a P-14, and that's what's 7 referenced in the title, and what that is is, if the level l 8 in the steam generate force, the water level, gets too high, 9 it trips those turbines to protect from a potential 10 situation where water could be carried into the turbines.
11 Part of that is all since the water level is high l 12 in the steam generators, the other thing a P-14 does is l 13 isolate the feedwater system, and that portion of the l l
14 function is an ESF system, and that's why it was reportable- j O 15 That's, basically, what occurred in this NRC.
l 16 Q The NRC -- or the ESF actuation, I think, was 17 also, was it not, itself subject of the original LER 1 18 015-00? That was the rationale for the LER, wasn't it?
19 A Yes. I believe we have revision one of that LER 20 here, and that is entitled, yeah, ESF Actuation P-14.
21 Q Now, what was the subject, then, of the second NRC 22 here, what's been identified as MFP Eyhibit 190? That's the 23 February 18, 1991, NRC.
24 A Exhibit 190, which is an NRC that we initiated to 25 address a problem we had had with a feedwater check valve O ANN RILEY L ASSOCIATES, LTD.
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1774 i i leaking, this first occurred, I believe, back in February of l 2 1990, when, following a trip, operations noted that there l
3 was some back-leakage through that check valve.
4 It was evaluated at that time as to not being a 5 concern with respect to safety, and it was evaluated by )
6 operations as to would it cause any problems to the l i
7 operators in operating the plant, and it was evaluated that. l I 8 it was not a problem in either case. l 9 So it was planned, then, to go in and work on that 10 valve during the next refueling outage. .
11 Q So are you referring to the valve, I think it's 12 referred to as 531?
13 A Yes. This is FW-1-531.
14 Q And it was leaking?
15 A Yes.
16 Q And that was a known condition?
17 A Yes, it was. There were -- between February of 18 '90 and this particular event, there was another trip in 19 June of 1990, when operations again noted the same leakage 20 through the check valve, and it was documented at that time.
21 Q But I believe you stated, did you not, that 22 operations just determined that that was an acceptable 23 operating condition?
24 A That's true, yes.
25 Q Now, when the LER, what's been identified as MFP ANN RILEY & ASSOCIATES, LTD.
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1775 1 Exhibit 192 was revised in 1990, that's the LER 1-91-015-01, O 2 that's the exhibit here --
3 A Yes. ;
4 Q What was the reason for the revision of the LER? ;
5 A One of the things that came up in the NRC, and I'm 6 not sure of the sequencing between the NRCs and the LERs, 7 but one of the issues that came up relative to the leaking ,
8 check valve was that the way the operators note that there was some leakage through the valve is that, when the aux !
9 l
10 feedwater system's in service, a portion of the aux 11 feedwater flow to the stream generator would leak back 12 through that check valve. l 13 So you have four steam generators that should, 14 basically, all have the same aux feed flow, except this one 15 had higher aux feed flow, because part of the aux feed flow 16 would go back through that check valve. So, to maintain the 17 net flow to the steam generator, you know, to maintain the ,
18 level in the steam generator constant, it took more feed l
19 flow, and that's how they noted the flow back through the 20 check valve.
21 Part of the evaluation that's performed in these 22 NRCs is to evaluate the effect of a portion of the aux flow ,
23 going back through that check valve. ,
24 Q Okay. And, as part of those evaluations, there 25 were other leaky check valves that were identified?
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i l I
! l 1776 1
1 A Well another -- there was another -- well, once O 2 that was evaluated, and it was evaluated that that was not a 3 safety concern, the question arose as to the water that 4 leaked back through the check valve, where was it going. i 5 When you go back and follow it back through the 6 system, there is another valve, it's not a check valve, but 7 it's FCV 420 that's in the second system. It's a nonsafety l 8 related valve for the water to have a place to go. Once it 9 leaked through the check valve, it had to leak.back through 10 420.
11 So, initially, I believe, when we wrote the NRC, 12 we addressed the safety significance of the leaky check 13 valve, but we didr.'t address where the water was going and i
14 point cut that this other valve in the secondary system also l
15 would have had to have had a leak for the water to get back l
16 to the condenser.
17 Q And that was the subject --
18 A And that was, I believe, the subject of the NRC's i 19 responsibility to the -- the first LER and prompted the j i
20 revision to the LER to respond to the NRC's letter.
21 Q The NRC's response is the document that's been 22 identified here as MFP Exhibit 193?
23 A Okay. In looking at the Exhibit 193, which was 24 the NRC's response to the first LER, the other issue was it 25 says, O ANN RILEY & ASSOCIATES, LTD.
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1777 1 "It appears that a lack of operator I 2 knowledge should be considered as a root 3 cause, and appropriate corrective action l
4 considered."
5 The issue here was, back -- as I said, it was l 6 known that the feedwater check valve had some leakage back 7 in February of '90. Operations evaluated it that it was not !
8 a concern to them in starting up the plant. However, we 9 didn't go into our operating procedure and put a note in it 10 telling the operators of this condition. .
11 So -- ard it was put out, I believe, in incident i 12 summaries, but our procedure wasn't formally changed, and I l 13 think, in some of the debriefings following the trip on 12/5 14 that the cperators stated they weren't aware of this leakage 0 15 through the check valve.
j i
j i
16 That's why it was an issue. So it was pointing 17 out that operations did not update their procedures to 18 identify this to be sure that everybody of would know it.
19 Q With respect to the leaky feedwater check valve, j 20 has that been repaired? l 21 A Yes, it has.
I 22 Q And with respect to -- you mentioned that there 23 was another valve subsequently identified as having --
24 A That was FCV 420, and that has also been repaired.
25 Q Okay.
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1778 1 A And the operating procedures have additionally 2 been changed to require not only that that valve be closed 3 but that manual valves associated with it on either side be 4 closed to ensure that there's no leak path.
5 Q Now, are you satisfied that the surveillance in 6 maintenance processes that were involved here were 7 adequately invoked to identify the valves and evaluate them 8 and address them in a timely fashion?
9 A Yes, I am. With respect to the check valve, it 10 was known and evaluated from the start. With respect to the 11 first incident where the feedwater reg valves had a shift on 12 their positioner, that was corrected at that time, and the 13 FCV 420, once it was identified -- and identifying it would 14 not be a maintenance function, but certainly correcting it 15 would. That was corrected at that time.
16 I'm not certain if FCV 420 was corrected right 17 then or whether we closed additional valves in that line and 18 then fixed 420 in the recollection refueling outage. I'm 19 not -- I don't remember all the details from back then, but 20 it is corrected now.
21 [ Pause.]
22 Q Mr. Vosburg, let me direct your attention to 23 what's been marked as Exhibit 192, on page 5 of 11.
24 A I'm still looking. Okay.
25 Q Paragraph C-4.
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Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950
1779
- 1 A Yes. ,
2 Q It refers to.the feedwater valve. Is that FW 1-3 531 that's being referred to?
4 A No, it's not. That particular valve is -- 531 is ;
I 5 the check valve. 530 is the feedwater reg valve, and it 6 states that, on start-up of the plant that the procedures 7 for putting the system in service didn't provide guidance a for actions to investigate, you know, feedwater reg valve 9 leakage. I don't know what to say, other than that.
10 Q Well, it speaks here to, 11 "a failure to provide direction for a 12 timely repair of the feedwater valves."
13 Do you know what that's referring to?
14 A Let me read it here.
O 15 A (Witness Vosburg) That one probably is talking I 16 about the check valve 531, and we did talk about and agree l 17 when that valve was going to be overhauled. So I'm not 18 sure -- I'm not sure what this refers to. It starts with 19 . procedures, and it looks like it's missing -- or mixing a 20 couple of trains of thought in that one paragraph.
21 Q With respect to 531, that was a case where ops was 22 aware, but they just made a decision to operate with the 23 leaky valve, if I understand Mr. Vosburg.
24 A Yes. With respect to 531, the check valve, that's 25 the case, yes. ,
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I 1780 l 1 Q And do you know if corrective actions have been ,
2 taken for any of the issues identified in the LER?
3 A Yes. Corrective actions have been taken. I think 4 we just went through the corrective actions for the valves ;
5 involved. Operations, procedures, I think I also stated, t 6 with rerpect to 420, were revised, and also the operations j i
7 procedures with respect to transitioning from ops to main 8 feed have cautions in there now to identify any ,
9 possibilities like this, the actions that you might take 10 should you see something like this. I l
11 MR. REPKA: Okay. I have no further questions.
12 CROSS EXAMINATION -
13 BY MS. CURRAN:
14 Q Mr. Vosburg, in hindsight do you feel that there 15 was anything inadequate about the PG&E's program for
. i 16 evaluating the significance of the check valve leakage that l 17 was noticed in November 1989?
~
18 A (Witness Vesburg) No, I don't. It was evaluated t
19 at that time on both the safety aspect, I believe, and the 20 effect on operations, and there was a conscious decision
, 21 made that the leakage through the check valve would not pose 22 any burden on the operators in operating the plant, and I ;
23 still believe that's the case. '
24 Q And you feel that way even though the leakage, the 25 back leakage, of the check valve contributed to the -- to i
l O ANN RILEY & ASSOCIATES, LTD.
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1612 K Street, N.W., Suite'300 Washington, D.C. 20006 (202) 293-3950 l l
1 1781 1 the reactor trip on December 5, 1990? i l
\ 2 A No. The back leakage through the check valve had ;
3 absolutely nothing to do with the reactor trip, reactor -- )
4 there has not been a reactor trip associated with the leaky l 5 check valve or the feed reg valve here. The trip that we !
6 were discussing here that occurred on 12/5 was not related l 7 to any of these valves. i 8 [ Pause.] :
9 Q What would you say were the consequences of the l 10 combined leakage of the feedwater check and regulating 11 valves in the event on December 8, 1990?
12 A The initial NCR that reviewed that, I believe, 13 concurred that the root cause for the trip was the leakage 14 through the feedwater reg valves due to the positioner shift !
15 while the unit was operating. Give me a second and I'll 16 find it here.
17 Yes. The root cause was attributed to the leakage 18 through the feedwater reg valves. It was not attributed to 19 the leakage through the check valve. If you remember, this 20 event, this ESF actuation, was caused by having too much 21 water in the steam generators.
22 The leaking check valve served to remove water 23 from the steam generators, not to add more. I think, if you 24 also look on Exhibit 190 on page 3 of 13, the very last 25 sentence in that NCR, which was subsequent to the first one O ANN RILEY & ASSOCIATES, LTD.
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l 1782 ,
- 1 states that, !
2 "Therefore Valve FW 531,"
3 which was the check valve, 4 "did not directly contribute to ESFAS 5 actuation." 1 6 Q But the leaking regulating valve did?
7 A Yes, it did. t 8 Q And was the leakage in the regulating valve )
9 observed prior to the event?
10 A No. As I said earlier, the fact that the t 11 positioner shifted on the regulating valve could not be ;
12 noticed while the unit was on-line because the valve's l
13 normally open, and the fact that it's shifted a little from '
14 its demand position, you can't tell that.
15 However, when the unit was tripped, that valve 16 should have been fully closed. However, because the '
17 positioner, the controller had shifted a little bit, it :)
18 was cracked open a little bit. So then, on the start-up, 19 when you put the main feedwater pumps in service, now there 20 was -- because that valve wasn't fully closed, and at that 21 point it was expected to be, you got additional feed flow to 22 the steam generator, which added too much water to it and 23 caused the level to go too high.
24 Q So, in short, the fact that that valve was 25 slightly open could not have been detected through O ANN RILEY & ASSOCIATES, LTD.
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1783 l-l 1 surveillance? Or maybe I described the problem --
l 2 A I don't know what, you know, exactly what specific )
i l
3 surveillances INC performs on the positioners. We probably l 4 have a surveillance that would check the positioner.
5 However, it's done at a certain frequency, and there was no ]
6 reason to expect that shift to occur. ;
I 7 It, apparently, happened while the unit was on 8 line during the operating period prior to the trip. So 9 there was no reason to -- you know, to expect that that i 10 would occur. So there was nothing to trigger maintenance to 11 go in and check the positioners. However, I do believe --
12 A (Witness Giffin) At that time, the test to verify j
\
13 that the positioner was set up correctly -- the positioner l 14 regulates air flow to the actuator of the valve, and it has 15 a feedback mechanism, and it has an input that says for this ;
16 amount of valve position you need between 20 and 100 pounds
- 17 of air.
18 So the positioner sends the valve to actuator, and 19 then, when the actuator moves the valve to the correct 20 position. There's a feedback so that ycu maintain the air 21 pressure in the actuator.
22 We set those up on an 18-month interval, and you'd 23 overhaul the positioners and make sure that they were 24 correct, that the valve was -- we had the correct signal 25 that says when the valve's supposed to be shut, the correct ;
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1 air signal is there and when it's supposed to be 100 percent C) 2 open.
I 3 After this occurred, we then went back in, and any 4 time that the unit is off-line prior to-bringing it back up, f 5 we will again make sure that that valve, that positioner is f 6 set up, but at the time we were only looking at it from what 7 our experience accepted we needed to every 18 months.
8 Since then, we've gone back and enhanced the ,
t 9 program so that the positioners are looked at any time prior 1
1 10 to start-up, t I i 11 MS. CURRAN: That's all the questions I have on ;
t 12 this. ,
j 13 JUDGE BECHHOEFER: Staff?
14 MS. HODGDON: No questions.
O 15 MR. REPKA: I think I would like to ask a 16 question. I would like to ask for what purpose this 17 document is going to be offered so that the record is clear 18 as to that point, because right now I don't understand what 19 it's going to be offered for. ,
20 MS. CURRAN: The documents are being offered for 21 the purpose of demonstrating that the Applicant had a l
- 22 leaking check valve which it knew was leaking a year before
[
23 the check valve was repaired and that there was -- ,
24 MR. REPKA: You're referring to the valve that's 25 been identified as 531?
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.- - - ~ . - . -
-1785 i 1 MS. CURRAN: 531, that there were two other check O. 2 valves that were also leaking and that there was another i
3 valve, I can't remember exactly what it's called all of a 4 sudden, that was also leaking, and that the -- there was not 5 a means of detecting the leakage of this other valve until J 6 it failed. REDIRECT EXAMINATION l 7 BY MR. REPKA:
8 Q Well, I'll follow-up to the witnesses, then, and 9 ask, with respect to 531, should this have been detected and i 10 repaired sooner?
11 A (Witness Vosburg) 531 was detected back in at l
12 least February of '90, and I believe once late '89, and it l 13 was evaluated at that time to not require maintenance at 14 that time, that it was acceptable.
15 You also stated that there were two other check 16 valves leaking. FW 531 is the only check valve associated j 17 with either of these NCRs that I'm aware of. !
l 18 MS. CURRAN: Okay. Let me just go back to the 19 LER, and maybe we can clear it up.
20 RECROSS EXAMINATION 21 BY MS. CURRAN:
22 Q If you look at page -- why don't you look at page 23 5 of the LER, which is Exhibit 192, paragraph C-1. I 24 thought this was raised in Mr. Repka's questions, but 25 apparently not. It refers in that paragraph to leakage ANN RILEY & ASSOCIATES, LTD.
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o ,
t 1786 1 through valve 530 and 1530.
2 A 530 and 1530 are the feedwater reg valves that we i 3 were talking about that had the positioner shift. .
4 Q Okay.
i 5 A Those aren't check valves. ,
6 Q All right.
7 FURTHER REDIRECT 8 BY MR. REPKA:
9 Q With respect to the feedwater valves 530 and 1530, 10 should they have been surveilled or maintained earlier?
11 A (Witness Vosburg) There's no way ro really do 12 that with the unit on-line, and because of the past 13 operating experience with the valves, as Mr. Giffin stated, 14 the frequency was at 18 months to check the positioner. ,
15 Since then, we've evaluated, .ind now we check all of them 16 after -- you know, after any trip before we start the plant 17 up at any time.
18 So I don't see where it could have been found, 19 because it was the act of starting up the plant that 20 identified it.
21 Q And once it's at power, you can't check it any 22 more until the unit comes down again?
23 A Well, the valve -- the valve would have to be 24 closed to verify it was zero demand from the controller that 25 the valve was indeed 100 percent closed, and you can't close O ANN RILEY & ASSOCIATES, LTD.
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r 1787 1 the valve with the unit on-line.
O 2 Q And what's the significance if it experiences 3 leakage while at power? ,
4 A There's no significance at all with the plant 5 operating to the shift in that positioner as described here.
I 6 QUESTIONS BY THE JUDGES 7 JUDGE BECHHOEFER: I have a further question on 8 what I think is the check valve matter. On Exhibit 190, 9 page 5 of 13, really 5 of 6, there's a discussion of root 10 cause. ,
11 MR. VOSBURG: Is that at the bottom of the page?
12 JUDGE BECHHOEFER: Yes.
13 MR. VOSBURG: Okay.
14 JUDGE BECHHOEFER: It goes over to the next page -
15 -
16 MR. VOSBURG: Okay. !
17 JUDGE BECHHOEFER: -- where they talk about valve I l
18 design, where the document talks about valve design that !
I 19 demands additional caution during final assembly after 1 20 repairs or inspection had steps -- and I assume this is the 21 check valve?
22 MR. VOSBURG: Yes, sir. This is the check valve.
23 JUDGE BECHHOEFER: Have steps to remedy this root 24 cause actually been taken? Has inspection or surveillance 25 systems been modified or maintenance systems as the case may i
O l
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1 be?
2 MR. GIFFIN: I'll try and get all your questions. l 3 JUDGE BECHHOEFER: Well, I'm not sure --
l 4 MR. GIFFIN: Okay. The check valve --
5 JUDGE BECHHOEFER: -- whether I'm pinpointing 6 surveillance or maintenance here.
i 7 MR. GIFFIN: We'll cover them both, sir.
8 JUDGE BECHHOEFER: Right.
9 MR. GIFFIN: The check valve 531 was repaired.
10 Our procedures have been updated to show how to do it. This 11 was not -- this is a very large valve, and we had set it up i 12 before, and then it leaked, and we went back, and we did all 13 that we thought was expected by doing blue checks, 14 machining.
15 So we brought the vendor in -- and when we i
16 reviewed his information, we brought the vendor in, and he 17 gave us another technique that was not written anywhere to ;
18 assure that the valve wouldn't leak. :
19 The function of this valve is to shut if there's a ,
20 pipe rupture downstream or upstream of the valve towards the 21 feed pumps with a very high DP across the valve. That's the 22 surveillance test that we perform.
23 We found that this valve was leaking with a low DP 24 across it. So it's safety function was to shut with a high 25 DP, and even while it was leaking we felt -hat that would ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 !
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1 occur. J O 2 So now, the maintenance procedures have been )
i 3 re-advised to assure this new technique called " tissue 4 paper" -- we actually take a piece of tissue paper and this 5 24-inch valve and make sure that it shuts and is held in 6 place. So corrections have been made to our maintenance j l
7 program, and their surveillance was adequate the way that it 8 was written.
I 9 [ Judges confer.] !
10 MS. CURRAN: I have one -- another follow-up l 11 question. l l
12 JUDGE BECHHOEFER: Go ahead. I f
13 FURTHER RECROSS EXAMINATION 14 BY MS. CURRAN:
. 15 Q I believe Mr. Repka asked you about the safety :
1 16 significance of the leaking check valve during normal l l
operation, and you said it didn't have any; is that right? I 17 I
18 MR. REPKA: I think we were talking about the j l
19 feedwater reg valve.
I
~
20 MS. CURRAN: Oh, the feedwater. Okay.
21 BY MS. CURRAN: l J
22 Q Did those feedwater reg valves have any safety l
23 significance under accident conditions?
24 A (Witness Giffin) The only thing that they have is 25 that they must trip shut, if you get an isolation signal and ANN RILEY & ASSOCIATES, LTD.
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1790 1 they trip shut within five seconds, and the positioners that 2 we were talking about don't come into play.
3 When the valve is told to trip shut, two .
4 solenoids, redundant power supply solenoids are energized or 5 de-energized, I forget which right now, but what they do is j i
6 they vent the air off the top of the actuator, and when the )
7 air goes away, then a large spring shuts the valve, and )
8 that's surveilled, and that's required to shut within -- >
9 within or less than five seconds.
10 That's the only safety feature that it has, and it l
?
11 would -- the positioner, in the normal operation, different i 12 trip mechanism, different way that'it works. .
13 Q And the recirculation control valve Number 420 !
14 that was also identified on page 5 of the LER, paragraph 2, {
O 15 C-2?
t i
i 16 A That valve has no safety significance. It's a j i
17 nonsafety-related valve in the balance of plant.
18 Q Well, could you look at the discussion on the top ,
i 19 of page 7 and tell me whether you agree with what it says 20 there? I'll read the sentence.
21 JUDGE BECHHOEFER: Page 7 of which exhibit?
22 MS. CURRAN: I'm sorry, Exhibit 192, the LER. :
23 BY MS. CURRAN: ;
24 Q It says, !
25 "Without power, the feedwater isolation ANN RILEY & ASSOCIATES, LTD. )
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1791 1 valve FW-1-FCV 440 would not close on a O 2 safety injection signal and would not 3 isolate the check valve leak. With the .
4 leak not isolated, full AFW delivery to l 5 SG ' , and, consequently, FSAR update 6 flow requirements may not be satisfied."
7 Would you agree with that analysis? !
A (Witness Vosburg) Well, what you're reading from '
8 9 is a very long analysis that we did to show to determine :
10 whether or not the leak through the check valve had any 11 safety significance. So one of the things they assumed is 12 that this SCV 440, which is another valve that isolates the 13 feedwater line automatically fails. ,
l 14 Okay. If that failed, what would be the '
15 significance of the leakage through the check valve, and it 16 goes through a long, you know, two, three pages of the 17 safety analysis and shows that the plant is within its 18 design basis with the leakage through the check valve.
19 When you said 440, were you thinking that was the 20 420 that was referenced elsewhere.
21 Q Oh, I am. Yeah. I have the wrong number.
22 A That's a different valve. This is very difficult 23 without drawings.
24 JUDGE BECHHOEFER: Ms. Curran, on the back of that ,
25 LER is a diagram showing all of these valves and their ANN RILEY & ASSOCIATES, LTD.
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l 1792 1 positions and functions. I think you might be able to see 0 2 from that that 440, 420 and all of them.
i i
l 3 MS. CURRAN: Yeah. I had my numbers transposed. j 4 Okay. I don't have any other questions. l 5 MR. REPKA: Let me follow-up quickly with i i
6 Mr. Giffin on the feedwater reg valves. l l
7 FURTHER REDIRECT EXAMINATION 8 BY MR. REPKA: i 9 Q When you were talking about the safety j 10 significance of the leaks under accident conditions, do you i 11 recollect that, the answer to Ms. Curran's question? i 12 A (Witness Giffin) I remember discussing it.
13 Q Okay. Let me direct your attention to page 5 of !
I 14 that LER Exhibit 192, section Roman IV-A, Leaking Feedwater 15 Regulating Valves. ;
16 A Yes. ,
17 Q And its conclusic there. I believe the last -l i
18 sentence is, i 19 " Leakage past the feedwater regulating f i
20 valves is bounded by the analyzed event 21 of a failed full open feedwater l 22 regulating valve." l 23 Does that conclusion support what you were trying 24 to say about the feedwater reg valve safety significance?
25 A No. This is in addition to, that the way that O ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1612 K Street,_N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 i
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it's designed is to trip it shut, and it uses a different
() 1 ;
2 position or a different equipment, and this says even if it )
1 3 doesn't-trip shut and over-fills, it's still bounded. So l 4 there's two issues, because there's another valve that also 5 will trip in the line upstream. i 6 [ Judges confer.) I I
7 QUESTIONS BY THE JUDGES l 8 JUDGE BECHHOEFER: Just turning back to the check l 1
9 valve, I don't know if this is on the record or not, it 10 might be already, does the particular valve,.the check valve 11 in question, is there safety significance to any problems 12 with that valve?
13 The way I read the bottom of page 6 of Exhibit 190 14 it says there may be, but I'd like to get the witnesses to 15 address that.
16 MR. GIFFIN: Yes, sir. In case there is a main 17 feedwater pipe rupture between that valve and the feedwater 18 pumps, then there would be backflow from the steam generator j i
19 through the check valve and out.
20 So the purpose of the check valve is to isolate 21 the Class 1 section of main feedwater piping from the 22 downstream Class 2 section of piping. So as the reverse 23 flow, then the valve shuts, and the surveillance test that 24 we did prior to this and after demonstrated that this 25 particular valve would perform that function.
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1794 1 JUDGE BECHHOEFER: Anything further on this one O 2 now?
r l
3 MS. CURRAN: Not from us. If there are no further ;
4 questions, we would move Exhibits 190, 191 and 192 into 5 evidence, 193 being an NRC document.
6 MR. REPKA: Have I no objection. I will state 7 that I think the record is clear that as it relates to f 8 maintenance and surveillance programs, these documents 9 should have no weight.
10 JUDGE BECHHOEFER: Okay. Exhibits 190, 191 and 11 192 will be admitted into evidence.
12 [MFP Exhibit Nos.
13 190, 191 and 192 14 were received in ]
15 evidence.] i i
16 MS. CURRAN: All right. The next exhibit is -- i 17 let's see, we're skipping again, on the road map. Exhibits ;
18 194 and 195 will not be offered, and the next exhibit being 19 offered is Number 196, which is NCR DCO-91-MM-N067D6, dated' 20 January 15, 1991.
21 MR. REPKA: Actually, I believe Exhibit 213 that 22 was handed out appears to be the same NCR.
23 [ Pause.]
24 MS. CURRAN: That's what your 213 is. We'd better I
25 talk about vacuum and control after the next break, but )
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1795 1 we'll deal with that later, okay?
O 2 MR. REPKA: Seems like a clear breakdown. Okay.
3 But if the witnesces could just refer to a copy of what was 4 distributed as Exhibit 196 and/or 213, and it should be an 5 NCR on ASW pump vault drain check valves. Am I right, 6 Ms. Curran.
7 MS. CURRAN: That's right.
8 MR. REPKA: Is that the subject we want to talk 9 about.
10 MR. GIFFIN: NO 67.
11 MR. REPKA: NO 67, January 15, '91.
12 MR. GIFFIN: We have that.
13 MR. REPKA: Okay.
14 DIRECT EXAMINATION 15 BY MR. REPKA:
16 Q Are you familiar with this document?
17 A Yes, we are.
18 Q Okay. Mr. Giffin, would you like to explain what 19 this NCR relates to?
20 A (Witness Giffin) One second, please.
21 [ Pause.)
22 We're now ready. At least I am.
23 Q Okay. Would you like to explain this NCR?
24 A This NCR, if you read on the management summary, 25 it was determined not to be a nonconformance report. The O ANN RILEY & ASSOCIATES, LTD, Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950
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1796 ,
i 1 reason that this particular nonconformance report was O 2 written was at my direction. They went down to perform 3 maintenance on an ASW floor drain. -
4 There's a check valve in the floor drain in the 5 ASW vaults, and they went down to perform an inspection of 6 these floor drains to check valve downstream in the floor 7 drains, and they came back and told me that they had gone .
8 and looked at both of these at the anme time. .
9 So we get engineering involved to determine L
10 whether I have an operability issue. Because I'm working in 11 both ASW vaults on these floor drains, have I in any way -
12 affected the operability of either of the two auxiliary salt ,
13 water pumps.
14 Engineering and operations both agreed that there 15 was no operability concern, and because of that it, one, 16 didn't meet our requirements to be a nonconformance, and, of 17 course, it's not reportability to the NRC, but we did 18 follow-up to see what we could learn from that.
19 So even though it wasn't a nonconfor.:.ance, we 20 continued through the process.
21 Q So you were doing maintenance on these floor 22 drains, and there's two in the area?
23 A Well, there's two auxiliary salt water pumps per 24 unit, and each of the vaults has a drain. In the downstream 25 of the drain, there's a'little check valve to prevent ANN RILEY & ASSOCIATES, LTD.
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1797 1 reverse flow, and, you know, cause water to go back up into 2- the room. It's designed to drain water out of the vault.
1 3 They went down, and they started working on both 4 of them at the same time, and because of that I asked them
, 5 to look into this.
l 6 Q And it was determined that that was not a problem?
7 A It was determined that that was not a problem.
8 What they did was not a problem, did not affect the 9 operability of either of the salt water pumps.
10 Q Was there any breach of procedures or process in 11 performing the maintenance on both drain check valves at the 12 same time?
13 A It's debatable. As they went through the process, 14 the work order required or said get a clearance, and it was 15 determined that they didn't need a clearance, and they 16 should have gone back at that point and made an 17 administrative change, which the foreman can do in his work 18 order saying a clearance is not required to perform these 19 activities.
20 It's, sort of, a stock, you know, line that goes 21 into a work package, you know, get a clearance, make sure 22 that the work is safe, and they did not get the clearance, 23 but, in this case, there was nothing to clear. There was no 24 clearance required. So they should have lined through it 25 and said not required, and they did not do that.
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1798 l 1 Q Was there anything done to clarify the process or 2 procedures in the future? i 3 A Sometimes, on ones that are not a real 4 nonconformance, we don't have corrective actions, but -- as 5 in this case -- but it does go through and said what the i I
6 immediate corrective action. So we reinstalled the check i
7 valves, and we corrected the error in the library work order ;
8 so that the work order now says that a clearance is not 9 required, you should only work on one at a time, and then it 10 lists a bunch of investigative actions that were done as a 11 result of this activity. 1 12 Q As sort of an unrelated point, it appears to me, 13 the NCR also refers to some trash and cigarette butts and 14 things found in or near the check valves in these drains.
15 Do you recollect that?
16 A Yes. Apparently, the way I read it is that the 17 check valve was stuck partially open on trash that, 18 apparently, was on the floor and got down the deck drain.
19 Q So that was identified during the maintenance on 20 the check valve?
21 A Identified-during and corrected.
22 Q And should it have been identified earlier?
23 A Well, it should have been identified that there l I
24 was debris about, but if debris is down inside the pipe i 25 there's no way to do that until the next inspection. We 1
i l
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1799 1 don't really.want to have debris laying about. So it should 2 have been seen and observed but not -- once it's in the 3 pipes, then the inspection would have pointed that out.
4 Q Are you comfortable with the inspection interval?
5 A Yes.
6 Q Would the type of deb)is found have affected the 7 operability of the valve?
8 A The way that the analysis or the engineering says 9 that it's not necessary in the first place. So therefore, 10 I'm not sure whether it's a pertinent question, but reading 11 what they say that it would have held the -- the valve was 12 held open, but there's also level indicators inside the pump 13 vault so that, if water level was inside tlie pump vault, 14 then the operators would be alerted to that situation by an 15 alarm in the control room.
16 MR. REPKA: I have no further questions.
17 CROSS EXAMINATION 18 BY MS. CURRAN:
19 Q So this check valve is supposed to prevent water 20 from getting into the AFW pump vault, is that it?
21 A In case of -- and I'm not sure what the postulated 22 reason is, but if there was water level where'the drain line 23 was connecting, it's to prevent back-flow from whatever 24 source of water into the pump vault, yes.
25 Q And the pump vault needs to be kept free of water, O ANN RILEY & ASSOCIATES, LTD.
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1800 1 doesn't it? f O 2 A Oh, yes. There's an operating motor and pump 3 inside the vault. The vault is a space with a closed door 4 on it. We just call it an ASW pump vault because of the way l 5 that the door looks, I guess. l 6 Q So you were saying that if there were water in the 7 vault, you'd have some way of knowing-it, right? There l 8 would be some kind of monitor that would tell you? !
9 A It's a level alarm switch in the pump vault that j 10 would alarm in the control room.
11 Q But if there were water in the ASW, would you be ;
12 needing the check valve to function at that point? $
1 1
13 A I'm not sure. Apparently, the way this is j 14 written -- well, let me re-answer it. The check valve is 15 not necessary. The major source of water and the reason for 16 the level alarm is if there was a problem with the piping on 17 the ASW vault, which would have a large flow, talking a 18 large piece of pipe that could put a lot of water into the ]
19 space; whereas, the check valve, not a very big pipe.
20 So I think that -- I believe that the alarm is in 21 there for a pipe leak in the ASW system, not for back-flow 22 up through the floor drains.-
23 Q But the check valve is something that you rely on 24 to -- one of the things you rely on to keep the ASW from 1
25 getting water in it? I ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950
1801 1 A No. l 2 Q No?
3 A The engineering evaluation says that even with it ,
4 not there, I was not in an inoperable condition. Therefore, 5 I don't need it. l 6 Q No. I'm not talking about whether you were in an i 7 inoperable condition. I'm asking you about whether you 8 could be in an inoperable condition due to the failure of ,
9 that check valve.
10 A I don't believe so, no. ,
11 On page 5 of the exhibit under section 2-E, it i Q
i 12 says, 13 " Preventative maintenance, no." i 14 Why is preventative maintenance not applicable to I 15 this particular check valve?
16 A The reason that this is "no," is that all those l 17 people that were involved in the Technical Review Group ,
. 18 determined that preventative maintenance had nothing to do ,
19 with the cause of this nonproblem.
20 A (Witness Vosburg) The list vou're referring to in ;
21 the NCR is a list of things that you go through to determine I t
22 if preventative maintenance had any cause on this particular !
23 event. In this case, the cause was the maintenance :
24 personnel removed the internals from the check valve. !
25 So it wasn't a lack of preventative maintenance.
l O
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il 1802 l
1 That's why it's checked "no," because it had nothing to do '
2 with the fact that they took the internals out. So that's, 3 kind of a check list you go through, human factors, 3 4 preventative maintenance, in determining what the causes 5 were as part of the NCR. )
1 6 Q I see.. But you don't disagree that if somebody l r
7 had cleaned out this trash in there that the check valve t
8 would have been able to move?
9 A (Witness Giffin) The check valves would have been j 10 able to move, but, as stated, it doesn't matter whether it 11 moved or not. -
12 Q On page 6 of the NCR, paragraph seven states that 13 there's no P&ID showing these valves. Is that an unusual 14 condition that there's no P&ID showing a valve in the plant?
O 15 A Where are you, please?
16 Q Paragraph 7 on page 6.
17 A Got it. No. For this case, there is no need for 18 the check valves, and small components are necessarily shown 19 on piping and instrument drawings. P&ID is piping and 20 instrumentation drawing, and if the -- in this case, I don't 21 believe that's surprising.
t 22 MS. CURRAN: I don't have any other questions on :
23 this.
24 MR. GIFFIN: Let me ask one -- add one thing. It 25 was referred to, and I don't know if I corrected. When she
?
)
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1803 1 said "this nonconformance," this, as stated, is not a 2 nonconformance.
3 JUDGE BECHHOEFER: Does the Staff have anything?
4 MS. HODGDON: No questions.
5 QUESTIONS BY THE JUDGES 6 JUDGE BECHHOEFER: I have, I guess, two questions.
7 On page 12, the very last page, what does it mean in 8 paragraph number 3, it's probably a letter preceding three, !
9 but -- AH 3, it turns out to be, 10 "Four distinct barriers that should have 1
11 prevented the event, were broken i I
12 through."
13 Can you explain what that means?
14 MR. GIFFIN: That's a terminology that we use.
15 It's a barrier -- a barrier analysis is used when you do a 16 root cause analysis. You look at what barriers whether they 17 can be a procedural barrier or a human factors barrier, that 1
18 if you had in place or if it had been used would have 19 prevented them going down and taking these two check valves 20 out at the same time.
21 So barriers are a type of analysis used to 22 determine root cause.
23 JUDGE BECHHOEFER: Has that analysis now been 24 done?
25 MR. GIFFIN: Well, we don't require that a formal ANN RILEY & ASSOCIATES, LTD.
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y i
1804 1 root cause analysis be performed for something which is not O 2 a nonconformance or a quality issue, but, apparently, they 1
3 want -- as this says, they did go through that process and 4 identify those barriers, but it was not required to be 5 performed.
6 JUDGE BECHHOEFER: I see. Okay. Now, on page 2,
'I 7 the references we've had to trash and that type of thing, 8 bottom of page 2, does that -- is that, sort of, aside from 9 the valves involved? Does that represent some sort of a ,
10 housekeeping problem?
11 MR. GIFFIN: Yes, sir, it does. People at a large 12 facility with a large number of people, we try very hard to 13 make people not drop wrappers or tie wraps around, and this 14 is a case where -- an instance where there was something O 15 that was washed down the floor drain, yes.
16 JUDGE BECHHOEFER: Is there anything further you 17 could do? I know we've had a lot of testimony about how 18 you've tried to overcome housekeeping problems.
19 MR. GIFFIN: Well, we've posted signs. You just 20 try to make people aware of the fact that we need to keep 1
21 this facility clean, and I believe the main way you do that i 22 is keep it clean so that it looks good so that, when there 23 is a piece of trash on the floor, it sticks out. It's 1
24 not commonplace. It doesn't get hidden with all of the !
i 25 others.
O ANN RILEY & ASSOCIATES, LTD.
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1805 1 So we have to continually stress to the people 2 let's keep the place clean. This is a cleanliness issue.
3 JUDGE BECHHOEFER: Would you have I -- pardon?
4 MR. GIFFIN: There's one other issue, and 5 Mr. Vosburg just reminded me, we have a procedure that 4 6 specifies area owners, and says that, "You're responsible 7 for this area, and you're to do a weekly walk-down of your i 8 area and go back and write things up, and then we'll have 9 the resources allocated to go clean that place."
10 JUDGE BECHHOEFER: That was almost my next 11 question.
12 MR. GIFFIN: Yes. We to have one of those.
13 JUDGE BECHHOEFER: Okay. Thank you. Any follow-14 up?
15 MR. REPKA: One follow-up question.
16 FURTHER DIRECT EXAMINATION 17 BY MR. REPKA:
18 Q Mr. Giffin, Judge Bechhoefer asked you about 19 housekeeping problems. Do you have a housekeeping problem 20 at Diablo Canyon?
21 A A housekeeping problem, no. I don't think so. I 22 believe that we have a very clean, well-maintained nuclear
. 23 power plant.
24 JUDGE BECHHOEFER: Maybe I should have used the 25 word " question" or " matter" or something like that.
(
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l i
l 1806 1 BY MR. REPKA:
O. . 2 Q I guess it's fair to say, Mr. Giffin, housekeeping j 3 is always an issue, is it not? :
4 A Oh, yes, and the reason it's an issue, if l 5 something's laying out, it's quite obvious. I mean, it's i 6 not hidden in the clutter, and with the walk-downs and -- a l i
7 lot of people have toured our plant both from in-company, j l
8 out-company, other utilities, and they've commented on the i l
9 cleanliness of our power plant.
10 MR. REPKA: No further questions.
11 JUDGE BECHHOEFER: Anything further? )
12 MS. CURRAN: Not from us. We move Exhibit 196 .j 13 into evidence.
14 MR. REPKA: No objection.
15 JUDGE BECHHOEFER: Okay. MFP Exhibit 196 will be 16 admitted.
17 [MFP Exhibit No. 196 was 18 received in evidence.]
19 [ Judges confer.]
l 20 JUDGE BECHHOEFER: I was just inquiring whether we 21 should break for lunch now or wait until we get through this 22 item, the next item. It depends on how --
l 23 MS. CURRAN: We can go on. I don't know about the 24 other parties. We're prepared to go on. We have have, 25 essentially, two exhibits left here. ;
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i 1807
)
1 JUDGE BECHHOEFER: For this entire panel?
-O 2 MS. CURRAN: No, for this particular -- we.have 3 more to do with the panel, but, in terms'of getting through 4 these exhibits, we have two left.
5 MR. REPKA: Is your next exhibit 203? ,
6 MS. CURRAN: I'm sorry. We have three.
{
7 MR. REPKA: Gee, did I make you add one? I was 8 going to ask about 203, because we're confused. It appears 9 to not raise anything that we haven't addressed elsewhere. ;
10 JUDGE BECHHOEFER: Well, why don't we -- +
11 MS. CURRAN: Well, okay. Well, then, let's --
12 JUDGE BECHHOEFER: I was going to say why don't we i 13 adjourn for lunch, and maybe during lunchtime you could 14 discuss it, and if you don't have to then have it offered, j O 15 so much the better. Well, I shouldn't say so much the !
l 16 better, but it would save some time. Why don't we break for l 17 an hour and be back at 1:30 or so.
18 [Whereupon at 12:30 p.m., a luncheon recess was 19 taken to resume at 1:30 p.m.]
20 l
21 22 l 1
23 i 24 4 1
25 I i
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1808 l l
1 A-F-T-E-R-N-O-O-N S-E-S-S-I-O-N f O 2 JUDGE BECHHOEFER: Okay, back on the record.
l 3 MS. CURRAN: All right. We are not going to be <
4 offering exhibits 198 through 209 and we'll go on with ;
I 5 number 210. We did pass out one number 203, but it turns i 6 out that most of those issues are addressed in previous 7 exhibits during the testimony and I may ask a few questions 8 about the testimony later, but we're not going to offer that 9 exhibit. So even though you have a copy of 203 you can just 10 disregard it.
11 Exhibit 210 is NCR DC2-90-EM-N042, dated June ;
12 27th, 1990.
t 13 [ Document reviewed.] l 1
14 DIRECT EXAMINATION j 0 15 BY MR. REPKA:
16 Q Mr. Ortore, do you have a copy of this document 17 that's been identified as MFP Exhibit 2107 18 A (Witness Ortore) Yes, I do.
19 Q Are you ready to discuss it?
20 A (Witness Ortore) Yes, I am.
21 Q Can you tell me what this NCR involves?
22 A (Witness Ortore) There was an attempt by control 23 room operators, although it's not specifically stated here, 24 it appears to be either a surveillance test or some other 25 test on the valve and they stroked the valve and the first ANN RILEY & ASSOCIATES, LTD.
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1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 {
f 1809 1 time the valve stroked open and stroked close. On a 2 subsequent attempt to stroke the valve the valve did not 3 open. There were a couple of more attempts to try to stroke 4 the valve again and these were unsuccessful also. An 5 electrician was dispatched and said that the motor of the 6 operator was continuing to run. It was disconnected. Some 7 troubleshooting was performed and it was discovered that the 8 declutch lever or fork in the operator was installed upside 9 down.
10 This incorrect installation caused stresses on 11 some of the internal components of the operator and 12 eventually the operator failed.
13 Q Okay. So this occurred during a preventative 14 maintenance testing, is that what you said?
15 A (Witness Ortore) It was probably a surveillance 16 test, although that's not specifically stated here.
17 Q Do you know what year that was?
18 A (Witness Ortore) In 1990.
19 Q And the cause of the failure was determined to be 20 that this declutch work was installed improperly?
21 A (Witness Ortore) That is correct.
22 Q When was that installation?
23 A (Witness Ortore) The history of the maintenance 24 on that operator show that it was overhauled in December of 25 1982.
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I
1810 1 Q So, can we infer from that that that's when this 1
>0 2 installation was done improperly?
3 A (Witness Ortore) That is correct.
4 Q Was the valve tested from the time 1982 to 1990 5 when it subsequently failed during the test? ,
6 A (Witness Ortore) Yes, for that eight year period 7 the valve was tested and performed as it should.
l '
8 Q Now was any effort made to -- in evaluating this 9 NCR to look at the original installation in 1982 and 10 determine why this declutch work was put in improperly?
11 A (Witness Ortore) At that time in 1982 the l
l 12 procedures were not up to the same standard that they were 13 in the 1990 or subsequent time frame. Also, we did not have 14 a formal training program for limitorque overhauls at that 15 time.
16 Q So did those exist by 1990?
17 A (Witness Ortore) Yes, they did. '
18 Q And what's in place now, are those work 19 instructions and procedures adequate?
20 A (Witness Ortore) Yes, yes. The training program 21 and the procedures are very extensive for the maintenance 22 and overhaul of limitorque operators.
23 MR. REPKA: Okay, I have no further questions.
24 [ Pause.]
25 CROSS EXAMINATION O ANN RILEY & ASSOCIATES, LTD.
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l 1811 ]
l 1 BY MS. CURRAN. >
2 Q Mr. Ortore, it states in Section 5, subparagraph i 3 B3 on page six that, 4 "Limitorque motor operators are 5 overhauled every four and a half years 6 as part of the preventative maintenance 7 program."
8 Has that four and a half year overhaul program been in 9 effect since the plant began operation?
10 A (Witness Ortore) Yes, it has.
11 Q Oh, I see. So this valve was overhauled in 1982 ,
I 12 before the plant began to operate? j t
13 A (Witness Ortore) Correct. There was preventative j I
14 maintenance even before the plant was operational.
O 15 Q Okay. But from the time that the plant was --
l l
l 16 that the valve was overhauled to the time that the 17 improperly installed component was discovered was eight 18 years, wasn't it?
19 A (Witness Ortore) Yes, according to this it took 20 that long for that incorrect installation to cause fatigue i 21 inside the operator. j 22 Q Would you say that this is an example of how aging 23 effects can take some years to show up in a nuclear power i
24 plant?
25 A (Witness Ortore) No, I don't believe so. The 'j l
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l 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950'
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1812 ,
1 i reason for the breakage was the incorrect installation and j O 2 there was stresses put on some of these components that if l
3 the operator was overhauled correctly and if it was 1
4 installed correctly these additional stresses would not be i 5 present.
l 6 Q All right. Then would you say that this is an l l
7 example of how aging effects on an incorrectly assembled ]
I 8 piece of equipment might take several years to show up?
9 A (Witness Ortore) No, I don't characterize this as l
I 10 being an aging problem at all. The failure was due to the 11 stresses that were put on these components and I don't see 12 aging being a factor.
13 Q Would you say that the stresses were cumulative on 14 this component? The effects of the stress were cumulative?
15 Don't coach him, okay, let him answer, Mr. Giffin.
16 MR. REPKA: The witnesses are entitled to confer.
17 MS. CURRAN: Well if Mr. Giffin has comething to 18 say he can say it. I don't mind him answering, but I'd like 19 Mr. Ortore to give an answer.
20 MR. REPKA: I think Mr. Ortore, if he feels the 21 need to confer with anybody on the panel, he can do that.
22 MS. CURRAN: Well I would object to-that. I want 23 to get the answers of the individuals, not an aggregate l 24 answer. And if someone has something else to say they're 25 welcome to say it. .j
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l 1813 1 JUDGE BECHHOEFER: Yeah, I believe that if Ms. ,
l l
l O 2 Curran wants to test a particular person's knowledge of l
3 something she may do so and then the other panel members may 1 4 fill in to the extent they have anything to add. We want to j 5 hear all views but if a question is directed at a particular '
6 person he should try to answer first and then we'll.see any fill-ins later. i 7
l 8 MR. REPKA: Maybe we need to repeat the question.
9 MS. CURRAN: Could you have the court reporter 10 read back the question?
11 MR. REPKA: The question was were the stresses on l 12 the components or on the equipment cumulative?
13 [Whereby the question was played back by the court
~
14 reporter.]
15 MR. ORTORE: The stresses were not cumulative but 16 the effects of the stress caused some, I guess, wear on some i
1 17 of the components that were probably accelerated because of 18 these accelerated stresses. So, I guess in that term, I 19 guess the et.c___' of these stresses were cumulative because 20 there was some wearing out of components, but the stresses !
l 21 were not cumulative.
22 MS. CURRAN: I don't have any other questions on !
23 it.
24 JUDGE BECHHOEFER: I was wondering if the other j 25 panel members, since there was some seeming desire to ANN RILEY & ASSOCIATES, LTD.
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l l
'1814 1 consult, do any of the other panel members have anything O. 2 further to say on that question?
3 MR. GIFFIN: Since I was the one who wanted to 4 consult, none of us are metallurgists and stress that's l 5 cumulative is cumulative in certain materials and not 6 cumulative in other materials. For example, titanium 7 stresses are cumulative, but most materials that valve j l
8 actuators are, stresses are not cumulative. And I just i 9 wanted to make sure that -- I was just going to tell Mr.
10 Ortore to make sure that he prefaced that, you know, that )
l 11 we're not metallurgist and that's a little bit out of our {
12 individual areas. But the question was fine, the way he 13 answered it was fine.
14 CROSS EXAMINATION (Resumed) 15 BY MS. CURRAN: i 16 Q Let me just follow up and ark Mr. Giffin if he 17 would disagree with the statement made at the top of page 18 two of the exhibit, 19 "It took eight years for the operator to 20 fail because of aging and stressing of 21 components."?
22 A (Witness Giffin) I disagree with that. I would 23 give the same answer to that that Mr. Ortore gave to that 24 same question. It failed because the mechanism was 25 installed upside down.
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1815 1 (Pause.] [
2 MR. REPKA: I would like to ask two follow-up 3 questions if you're done?
4 MS. CURRAN: Go ahead. ,
5 JUDGE BECHHOEFER: Do you want to do that prior to 6 our questions or not? Take your pick. I just have a couple 7 of minor details to go over.
8 MR. REPKA: Why don't you go ahead. !
9 JUDGE BECHHOEFER: Okay.
10 QUESTIONS BY THE JUDGES 11 JUDGE BECHHOEFER: On page six of Exhibit 210, i 12 there's a statement under paragraph B3 that, j 13 "Limitorque motor operators are )
14 overhauled every four and a half years 15 as part of preventative maintenance."
16 Well, checking back the dates here I think we heard that 17 there was an overhaul in 12/82, or the original
- 18 installation. My question is what happened in 6 or 7 '87?
19 Under this schedule it would seem that something would have 20 been done, I just wanted to see?
21 MR. ORTORE: Well the four and a half years 22 started when the plant went into operation.
23 JUDGE BECHHOEFER: That's 12/82.
24 MR. ORTORE: And that was not until 1985.
25 JUDGE BECHHOEFER: Oh, I see, okay. I see, okay.
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)
1 1816 l 1 Was this a situation then where the installation sometime 2 before plant -- the actual operation of the plant might have .
I 3 had an effect on whether maintenance should or shouldn't I 4 have been done earlier?
5 MR. ORTORE: Well the 1982 was a preventative j 6 maintenance tasP.. The limitorque operator was overhauled at 7 that point. So we were performing preventative maintenance l 8 even before operation, but not to the same frequency that we 9 did after operation.
10 JUDGE BECHHOEFER: I see, okay. So the four and a
! 11 half years didn't kick in until operations started?
12 MR. ORTORE: At some time after operation, yes.
13 JUDGE BECHHOEFER: I see, okay. I i
2 14 [ Pause.]
15 Okay, that's all I have. So, Mr. Repka?
16 REDIRECT EXAMINATION 17 BY MR. REPKA:
la Q Okay. Apart from the overhaul on the four and a
- 19 half year interval, was I correct in hearing earlier that 20 there were tests performed on the actuator or the valve?
21 A (Witness Ortore) Yes, there were surveillance
- 22 tests performed on these. Dave, I believe all these valves 23 are on a three month schedule for surveillance tests?
- 24 A (Witness Vosburg) Yeah, it's a 92 day frequency. l I 25 Q Now with respect to the root cause of this, when ANN RILEY & ASSOCIATES, LTD.
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1 1817 1 it finally failed during a surveillance test, in the NCR at 2 page five, Section IIID, can you tell from that whether 3 aging was ever considered to be part of the root cause of 4 this?
5 A (Witness Ortore) No root cause was procedure, 6 containing appropriate caution regarding the installation a 7 declutch fork did not exist and that there was insufficient 8 training back in 1982.
9 MR. REPKA: Okay. I have nothing further.
10 RECROSS EXAMINATION 11 BY MS. CURRAN:
12 Q You were saying that surveillance testing was done 13 on this motor operator, but it wasn't able to, it wouldn't 14 have been able -- or it wasn't able to identify the clutch 15 that had been installed upside down as any kind of a 16 problem, right?
17 A (Witness Ortore) No, it did not. The operator 18 did stroke successfully in a test for all those years.
19 Q Until 1990 when during a surveillance test it did 20 fail, is that right?
21 A (Witness Ortore) I believe that's what it says, 22 yes.
23 MS. CURRAN: That's all I have. And if there are 24 no other questions, we move Exhibit 210 into evidence?
25 MR. REPKA: No objection.
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1818 1 JUDGE BECHHOEFER: Okay,'without objection -- I O 2 assume the Staff has no objection?
3 MS. HODGDON: No objection.
4 JUDGE BECHHOEFER: Without objection, MFP Exhibit 5 210 is admitted.
6 [MFP Exhibit 210 was ;
7 received in evidence.]
8 MS. CURRAN: Okay. Then we will not be offering ,
9 Exhibits 211 through 215 and Exhibit 216 is NCR DCO-90-SE- ,
10 N080, dated January 28th, 1992.
11 [ Document passed out.]
12 DIRECT EXAMINATION i
13 BY MR. REPKA: -
14 Q Okay, does the panel have a copy of this document 15 that's been marked as Exhibit, MFP Exhibit 2167 l 16 A (Witness Crockett) Yes, we do.
17 Q Somebody on the panel prepared to address this 18 issue? ,
i 19 A (Witness Crockett) Yes. '
20 Q Mr. Crockett. Would you please describe what this 21 NCR relates to?
22 A (Witness Crockett) It refers to a fire that we 23 had on an electrical panel for security diesel system. And 24 I was the chairman of this NCR, this TRG. We -- the j 25 connection, I guess the cause of the fire was related to the l
l ANN RILEY & ASSOCIATES, LTD.
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4 1819 i r
i connection in the' panel from the cable to the breaker and j 2 what had happened is the connection became, for the lack of 3 a better word, degraded. You have an electrical resistance .
4 and when there's electrical resistance it heats up and with 5 enough heat to where it caused a fire. Really no flame, but 6 smoke and it melted the connection. ;
7 In our root cause we tried to identify what were 8 some possible reasons for that. The connection itself was l f 9 destroyed because of the incident. But in our history, when t
10 we looked into this, we saw that that connection was !
11 disassembled earlier in the year, around February, 1990, it 1 i
12 was disassembled for another modification by general l 13 construction and then reassembled and put back in. And then ,
l 14 the fire happened some months later. ;
15 Prior to that modification in 1990, early 1990, !
16 that connection, it's an impression kind of a connection, 3 17 was used for ten years and never had a problem with it. ;
1 18 Likewise, no other compression connection in the plant, 480 -
19 volt, had had problems. This was the first one and it's 20 been the only one. We assumed that the fitting or the 21 connection had worked good for ten years, it was 22 disassembled and reassembled in February 1990 and that 23 therefore the error had to be with the assembly of that 24 connection.
25 Q So the error was in the assembly of one specific t ANN RILEY & ASSOCIATES, LTD.
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l 1820 1 connection? l O 2 A (Witness Crockett) One connection.
i l
3 Q Now where this occurred was that in a safety 1
4 related panel?
5 A (Witness Crockett) No, it's in a panel for l 6 security diesels, it's called -- it might be confusing in j 7 here, but in the NCR it's referred to as a safeguard and 8 that refers to security equipment, not plant safety 9 equipment.
10 Q So it's the conclusion that the compression i 11 technique is okay but the application was not? )
12 A (Witness Crockett) Absolutely, no, I -- well, I 13 I'll explain that. There's a I-EEE standard, it's a code 14 allowable type of connection and it's used throughout not
-O 15 just our industry, it's used throughout non-nuclear ,
i 16 businesses. It's an electrical code acceptable connection. l 17 So it wasn't an inferior kind of connection, it was an 18 acceptable connection. !
19 Q Has there been any subsequent operating experience 20 that would suggest that this was not --
21 A (Witness Crockett) None at all.
22 Q -- acceptable?
'l 23 A (Witness Crockett) Not at all. As a corrective 1 24 action to this we -- up until this point it was assumed as 25 part of a journeyman's skill to make this kind of I
l ANN RILEY & ASSOCIATES, LTD.
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1821 !
1 connection. It's a -- essentially it's a -- you bend the 2 exposed wire around the lug and tighten the lug. There's 3 washers, it's a compression kind of a connection. Within 4 the skill of a journeyman electrician we decided as a ,
1 5 prudent action to minimize this ever happening again we !
6 constructed a procedure on how to do, not only this kind of I 7 connection, but also other types like a crimp and lug 8 connection.
9 Q Was the procedure inadequate before that?
10 A (Witness Crockett) There was no procedure for it i 11 because it's part of the skill of the journeyman to know how 12 to connect a piece of wire to a terminal strip. l 13 Q Well was that assumption unwarranted?
14 A (Witness Crockett) No, it was not. This was a --
15 we still believe that journeymen electricians know how to 16 make connections from cables to terminals, but as a, you 17 know, any attempt to try and clarify what our expectations 18 are we wrote a procedure and added it to the training.
19 MR. REPKA: I have nothing further.
20 CROSS EXAMINATION 21 BY MS. CURRAN:
22 Q Mr. Crockett, at page seven of the exhibit, in 23 Section SB-2, do I understand correctly that you upgraded 24 the connections that were used when you rebuilt the panel?
25 A (Witness Crockett) Yes, we did. We installed a ANN RILEY & ASSOCIATES, LTD.
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1 crimp and lug type connection. It is a better connection. l O 2 Q And are those class one connections --
l 3 A (Witness Crockett) No --
4 Q -- the ones that you put in?
5 A (Witness Crockett) No. It's just a -- it's a 6 crimp and a lug type of connection.
7 Q Uh-huh.
8 A (Witness Crockett) Was the connection a class 1?
9 Q Well, let me, why don't I refer back to this other 10 page in here that raises this question and maybe you can 11 explain. On page five, it says, under Section BE, 12 "An effort was made in the '70s to 13 change compression electrical 14 terminations in class one high voltage 15 equipment. A conscious economic ,
16 decision was made at'that time to not 17 change them in class two equipment." ;
18 A (Witness Crockett) That's correct.
19 Q So I guess it wasn't necessarily that the 20 terminations were class one, but that you weren't changing 21 them in class two equipment earlier, right?
22 A (Witness Crockett) That's right.
23 Q Okay. And this --
24 A (Witness Crockett) It's still an acceptable 25 connection and it was suitable for class two.
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1823 l 1 Q But the fire, after the fire you decided to
- C) 2 upgrade it to a better class of lug? ,
3 A (Witness Crockett) That's correct.
4 Q Okay. j i
5 A (Witness Crockett) We are redoing it and we'll 6 put in a crimp and lug style connection. But keep in mind !
7 the compression connection, there's nothing wrong with it.
8 MS. CURRAN: I don't have any other questions on 9 this.
10 JUDGE BECHHOEFER: Staff? l i
11 MS. HODGDON: No questions.
i 12 QUESTIONS B'x THE JUDGES j 13 JUDGE BECHHOEFER: There's a statement on page six 14 about the most probable root cause. Is that more or less --
15 does that most probable follow from the circumstance that a 16 lot of the physical evidence was destroyed and that you're 17 not likely to be able to get anything more precise?
18 MR. CROCKETT: Yeah, it melted.
19 JUDGE BECHHOEFER: Right.
20 MR. CROCKETT: But the connection itself melted, 21 but going back to when it when it was disturbed last, it was 22 disassembled and reinstalled. So that's why we say most 23 probable. The connection worked good for ten years and it's 24 worked good on all other applications at the plant.
25 I might add, one other thing that we do is a O ANN RILEY & ASSOCIATES, LTD.
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1824 ,
l 1 thermography inspection. You can remotely look at panels 2 and see if a connection is starting to loosen or you start 3 getting contact; resistance is increasing and a connection 4 will start heating up. We have a thermography program that 5 scans panels and looks for connections that are getting this 6 contact resistance, but you can catch it before it fails. !
l 7 JUDGE BECHHOEFER: Does this program apply to this 8 particular matter?
9 MR. CROCKETT: If you look and -- it does now.
We've always had the program for class one safetv , dated i 10 11 equipment, but I think if you'll look on page, under the !
12 corrective action, under -- on page seven, VB1, it's under 13 the corrective actions to prevent recurrence. B1 says, 14 "As a prudent action similar panels will 15 be scanned with infrared detectors to 16 identify any hot spots." i 17 JUDGE BECHHOEFER: Does that mean this one will be j 18 or the ones that are like this one? -
l 19 MR. CROCKETT: Yes, it's a similar panel. l 20 JUDGE BECHHOEFER: Well, is that this one or is 21 that just others that are like it? !
22 MR. CROCKETT: That's this one and others that are ;
23 like it. i I
24 JUDGE BECHHOEFER: Oh, okay. ,
25 MR. GIFFIN: Well, what this meant is we also O ANN RILEY & ASSOCIATES, LTD.
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1825 1 wanted to assure that there were no other panels out there O 2 at this time that could have had that condition in it. So i
3 we took the infrared thermography equipment to scan those at l
4 that time. So this means that we went out because it j 5 happened in this one, we wanted to make sure that there were j i
6 no other cabinets where this possibility existed. So we l 7 went out and looked in other cabinets at that time to see if 8 there was anything that we could detect.
9 JUDGE BECHHOEFER: Is the bullet discussed on page 10 eight generally applicable or just applicable to this 11 particular type of connection?
12 MR. GIFFIN: That would be, I'm guessing now, I 13 can't remember what -- you read it?
14 MR. CROCKETT: No I read it at the time. It's a O 15 general -- it talks about those two types of connections, l
l l
16 the crimp lug type and the compression type and it's a l 17 detailed instruction on how to do those types of 18 connections, whether they be for a 480 volt panel or a 19 different voltage sizes for all different kinds of voltage 20 levels, but it's the same kind of process, the technique for 21 all those kinds of connections.
22 JUDGE BECHHOEFER: All right. So it is broader 23 than this --
24 MR. CROCKETT: That's correct.
25 JUDGE BECHHOEFER: -- particular instance.
I i
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1826 1 MR. CROCKETT: That's correct.
2 JUDGE BECHHOEFER: Anything further, follow-up?
3 MR. REPKA: No.
4 MR. GIFFIN: One thing, let me clarify something-5 that Mr. Crockett said. He said that we, and I think his i 6 words were something like, we've always been using 7 thermography, actually that's part of our preventative 8 maintenance program and we've been using that equipment, not 9 always, but for about the last three or four years. ,
10 JUDGE BECHHOEFER: Three or four years seems like i 11 always.
12 MS. CURRAN: Well, if there's no further questions 13 we move Exhibit 216 into evidence.
t 14 MR. REPKA: No objection. ;
15 JUDGE BECHHOEFER: Okay, MFP Exhibit 216 will be 16 admitted into evidence.
17 [MFP Exhibit 216 was 18 received in evidence.)
19 MS. CURRAN: Okay. We won't be offering the other 20 exhibits that are listed on the road map. We've come to the 21 end of the map. And now we'll just go on with some i.
22 questions about the PG&E testimony.
23 CROSS EXAMINATION 24 BY MS. CURRAN:
25 Q: At pages 100 through 102 of your testimony you ANN RILEY & ASSOCIATES, LTD.
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1827 1 discussed leakage of a valve bonnet on the chemical and 2 volume control system, is that right? ,
3 A (Witness Giffin) Actually, there's two instances 4 in the testimony that we discussed. I'm not sure which one >
5 you're -- l 6 Q That's right, there's two. One in June of 1992 7 and one in September of 1991, right? It's on page 101.
8 A (Witness Giffin) Yes, those are the two 9 instances.
10 Q Can you tell me what the CVCS valve bonnet does?
11 A (Witness Giffin) I'm trying to think of the 12 easiest way to answer this question. A valve is comprised 13 of parts, the bonnet, the body and then the internal. The 14 bonnet is like the top of the valve itself. l 15 Q So is the bonnet cupposed to be containing -- what 16 is the bonnet supposed to be containing, anything?
17 A (Witness Giffin) In this case the bonnets of ;
18 diaphragm valves and the bonnet holds the diaphragm over the 19 rest of the body and it's bolted down and hones the bonnet 20 and the bonnet hones the diaphragm down onto the valve body. '
21 So it's here's one part and here's the other part, it's like i
22 that. It's the lid so to speak. l l
23 Q And this event in June of 1992, it was leaking 24 radiation, is that it?
25 A (Witness Giffin) No, it was leaking fluid boric 1
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1828 l 1 acid -- or borated water was leaking from the valve bonnet.
O 2 And the person performing the radiation survey noticed the i I
3 leakage from the valve.
l 4 Q Oh, I see. Okay. So then the valve was l 5 tightened, the body to bonnet nuts were tightened?
6 A (Witness Giffin) Correct.
7 Q Okay. It says here, 8 "A similar leak occurred in September of 9 1991."
10 Was that discovered through any kind of testing or 11 maintenance activity?
12 A (Witness Giffin) I didn't put how it was detected ,
13 in the testimony, but I think it was the same way, by an 14 inspection or someone noticed that there was leakage.
15 Q You think but you're not sure?
16 A (Witness Giffin) I'm not correct on that -- I'm l 17 not sure because I didn't -- when I wrote this down I didn't 18 put the root cause or how it was found, whether it was found 19 by an RP tech or whether it was found during an inspection.
20 Q You say here, on page 102, the last sentence, 21 that, 22 "The analysis of the as found leakage in 23 both events determined that these events 24 were not safety significant."
25 Do you mean by safety significant that they didn't cause any O ANN RILEY & ASSOCIATES, LTD.
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1 1829
. 1 accident of any kind?
2 A (Witness Giffin) Well they did not do that. c 3 There was no actual safety consequences for these leaks in 4 that the analysis of -- what the concern is on the leakage l 5 of these valves that if you're in an accident situation, a 6 design basis accident, there's a certain amount of leakage 7 which can occur, which would be allowed to occur in the CVCS 8 system. If the leakage exceeded that amount, based upon the 9 worst conditions that can be postulated for the core 10 condition, then the radiation that could be seen in the 11 control room would exceed the limits. And so that was --
12 that's what the basis for'the leakage criteria is. And in 1
, 13 this case we determined that the leakage was that small and 14 we determined that it was not safety significant.
15 Q But would you say that leakage from a CVCS valve 16 bonnet could potentially be safety significant? ,
17 A (Witness Giffin) If the leakage was large enough 18 and the right circumstances existed, it could have the :
19 potential to be significant in that the dose in the control 20 room would be higher than what it is required by the 21 regulations to be.
22 MS. CURRAN: Do you have any follow-up on this 23 particular item, because I'm going to move on if you don't?
24 MR. REPKA: Sure.
25 [ Pause.]
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1830 -
1 REDIRECT EXAMINATION f n' ~
N- 2 BY MR. REPKA:
3 Q' With respect to the safety significance analysis t 4 did you determine in this case whether there was any 5 potential safety significance given the facts as you found 6 them?
7 A (Witness Giffin) No, we -- that's why we wrote 8 that they were not safety significant. We did not find that 9 in this case the potential had existed. But in the case !
10 that she asked me, there is, if you have the right l 11 conditions, could have -- the leakage could be large enough 12 to cause the dose rate in the control room to be exceeded.
13 Q Okay. i 14 QUESTIONS BY THE JUDGES ,
15 JUDGE SHON: Mr. Giffin, I noticed that on page
]
16 101, in the first complete paragraph of the page, middle j l
17 sentence of the paragraph, second sentence, 18 "This leakage was determined to be 19 outside the design basis for CDCS 20 leakage."
21 What determines the design basis for the CDCS leakage and if 22 this exceeded it why is it not a safety matter?
23 MR. GIFFIN: What determines it is the dose, the 24 leakage is based upon the dose rate in the' control room to 25 the operators. And in order to answer the rest of your ANN RILEY & ASSOCIATES, LTD.
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1831 1 question I'd have to -- I would like to go back and review 2 the LER that I wrote because the way that I remember it is 3 that when I prepared this those documents provided the input 4 with which to write this testimony. So I would like to go 5 back and look. But we apparently put in those that it was 6 not safety significant so I would have to go back and review 7 what the leak rates and what the other conditions that 8 existed were.
9 JUDGE SHON: Yes, it just seemed to strike me that 10 the flat statement that it's not safety significant when 11 some sort of leakage rate is exceeded might have some 12 internal conflict.
13 [ Pause.]
14 If you want to look at the LER, do you have it around or is 15 it readily available?
16 MR. GIFFIN: I think we're doing that as we speak.
17 MR. REPKA: We're doing that right now.
18 JUDGE SHON: I see. There's no great rush. I 19 mean you can go on and give us an answer on this later on.
20 JUDGE BECHHOEFER: Well I have a question about 21 this segment of the testimony. Starting with the earliest 22 leak, September 1991, there's a statement that the, well 23 that the incident or the matter involved was not adequately 24 included in the preventative maintenance program. At that 25 time were steps taken to include it or adequately include it i
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1832 1 in a preventative maintenance program?
2 MR. GIFFIN: Yes, sir, we included that in the PM 3 program.
4 JUDGE BECHHOEFER: So then, approximately nine 5 months later, another leak occurred and what happened then?
6 MR. GIFFIN: In the second case, in the June of 7 '92 case --
8 JUDGE BECHHOEFER: Yes.
9 MR. GIFFIN: -- that was where -- this is the case 10 where we have heat trace along some of the -- on the boric 11 acid, on the piping that carries fluid with boric acid in it 12 and it's maintained at, I think it was at that time about 13 140 degrees above that to keep the boric acid in solution.
14 And the thermostat for a particular piece of heat trace 15 failed which caused a failure -- it heated the temperature 16 of the valve to the point where the diaphragm of the valve 17 fails due to the failure of the heat trace system.
18 JUDGE BECHHOEFER: Now would that have been 19 included in the preventative maintenance program?
20 MR. GIFFIN: There's two root causes. The one in 21 September was we just hadn't looked at it, that particular 22 valve was omitted. We didn't look at it. So that failed 23 because we hadn't put that in the preventative maintenance 24 program. The other failure was as a result of this heater 25 control fail causing the heat trace to exceed the ANN RILEY & ASSOCIATES, LTD.
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-1 1
1833 1 temperature rating of this valve diaphragm. So that they're i O 2 not saying that any corrective actions out of September l'
3 would not have caught and correct or prevented the September j 4 or -- f 5 JUDGE BECHHOEFER: June one.
6 MR. GIFFIN: -- the June one.
7 JUDGE BECHHOEFER: Well was there any sort of ,
8 program from preventing the June one? ,
9 MR. GIFFIN: The June one was caused by an l 10 equipment failure that caused the second failure.
i 11 JUDGE BECHHOEFER: I know, but was there any }
12 program to prevent the equipment from failing?
13 MR. GIFFIN: We have, as I said before, during --
14 there are going to be things that break and I can't have a 0 15 program that prevents everything.
Some. corrective actions l
16 will be necessary to fix equipment problems. In this one 17 that's what it was. It was not something that I could have 1
18 foreseen. That is that a component failed and then that j i
19 failure resulted in the second failure. l 20 JUDGE BECHHOEFER: I see, well that's what I 21 wanted to find out.
22 [ Pause.]
23 MS. CURRAN: Is that all you have?
24 JUDGE BECHHOEFER: Yeah, that's all I have.
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1834 1 follow-up.
2 RECROSS EXAMINATION 3 BY MS. CURRAN:
4 Q In your testimony you say that you reviewed and i 5 upgraded the preventative maintenance program and I'd like 6 to find out did that -- did that involve some new measures f
7 to either look at the CVCS valve or test it to see if there 8 was leakage from the valve?
9 A (Witness Giffin) I think this one that we're i 10 talking about is to make sure that the valves are included 11 and that if there is a recommendation that the, I think it 12 had two issues, the torquing issue and a life and a 13 diaphragm replacement and that means upgrading the 14 preventative maintenance program to periodically replace 15 these diaphragms. t i
16 Q What's your -- what are the ways that you look for i
17 leakage from one of these valves? I see there's this 18 routine radiation survey that picked up a leakage in this :
19 instance in June of '92, are there other measures that you 20 used? !
i 21 A (Witness Giffin) Most of the time if it's leakage
- t 22 out of -- a very small amount of leakage out of a system i 23 we'd look at it mainly by people looking at systems. We j i
24 have the radiation techs doing their survey, look at valves 25 and when you have a valve that has boric acid in it or -- ;
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l 1835 )
1 then you can see boric acid crystals on the valve and O
i i
2 underneath it. So, that's one method. The main method is i 3 that you walk-down the RP techs doing surveys, the operators 4 when they take the tour of the auxiliary buildings, the 5 system engineer and design engineer program has a quarterly 6 walk-down where they walk down every aspect of their system 7 to look for leakages or anything that they see on their 8 systems that aren't up to par.
9 Q Do you know when, prior to this radiation survey 10 in June of 1992, this valve bonnet began to leak? !
11 A (Witness Giffin) No, I do not.
12 Q Had that valve bonnet been subject to any kind of i 13 a walk-down previous to June of 1992?
14 A (Witness Giffin) On a daily basis operators go 15 through the plant. The radiation protection technicians go 16 through on routine radiation surveys. System engineer walk-17 downs have been going on now for about three years. So I i j
18 imagine it had been looked at many times before this l 19 particular technician saw that it was leaking and reported l
20 it to the controller. ]
21 Q You imagine but you're not sure?
22 A (Witness Giffin) Well I know people have walked 23 down the system. I don't know how many times or who they 24 were. But system walk-downs are done on a daily basis and I 25 know that system engineers do a quarterly walk-down. So I O ANN RILEY & ASSOCIATES, LTD.
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i w- . --
1836 j i know the system has been walked down prior to June of 1992. l 2 MS. CURRAN: I don't have any other questions on 3 this. Do you all have the LER yet and do you want to --
1 4 MR. GIFFIN: We'll come back to it.
5 MS. CURRAN: Okay. You can have it if you want.
6 MR. GIFFIN: Oh.
7 MS. CURRAN: Why don't you -- why don't we just do 8 this.
9 [ Pause.]
10 JUDGE SHON: Is that one of the LERs that you 11 decided not to offer? -
12 MS. CURRAN: Yeah, apparently so. I have all i
13 these copies here if the Board and the parties would like to 14 look at them. I don't know if we'll need to introduce them 15 or not, but you're welcome to them if you want, j 16 MR. REPKA: I'd like the witness to read it and 17 tell us about it before I decide whether I want to introduce 18 it.
19 JUDGE SHON: Yeah, well which number is it, so we 20 can --
21 MS. ZAMEK: It doesn't have a number yet.
22 JUDGE SHON: Oh, I see, okay. It wasn't one of 23 these that you gave us and you withdrew?
l 24 MS. CURRAN: No.
I 25 JUDGE SHON: Oh, okay.
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l 1837 1 [ Document reviewed.] !
2 MR. REPKA: Mr. Giffin, before.you answer, could 3 you identify for the record what it is you're looking at?
4 MR. GIFFIN: We're looking at LER 92-009 revision ,
s 5 one, dated 1/11/93.
i 6 MR. REPKA: And I think the question before you 7 was the question Judge Shon asked, is that what you're r
8 looking for?
9 MR. GIFFIN: Yes, sir. The reason for my -- that ,
10 there was no safety significance is the analysis that was 11 done they used an expected -- now I've lost it. An analysis i
12 was performed using expected case LOCA assumptions with no t 13 fuel damage. The analysis determined that the nine gallon 14 per minute leak would result in the two hour site boundary O 15 in low population zone significantly less than the 10 CFR i
16 100 limits. And that's the reason I based that there was no j 17 safety significance.
18 The next sentence in the LER, 19 "Therefore this event did not adversely 20 affect the health and safety of the 21 public."
22 JUDGE SHON: I take it the limit for the CVCS l l
23 leakage was set originally on the basis of some sort of fuel i
24 damage? )
25 MR. GIFFIN: Yes, worse case LOCA. J
)
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1 1838 1 JUDGE SHON: Right. Well that explains it as far 2 as I'm concerned.
3 [ Pause.)
4 MR. REPKA: Since we have discussed it, I think I 5 would like to have marked for identification that LER as I l
6 PG&E Exhibit 28.
7 [PG&E Exhibit 28 was 8 marked for 9 identification.]
10 JUDGE SHON: Judge Bechhoefer would like to know, ;
11 would like to know -- I guess I'm sort of acting as an 12 intermediary here, whether there was any chance that leakage 13 from that particular valve, on the fluids that were in it, 14 could have exceeded either some 20 restrictions or appendix 15 I restrictions for the -- for release during normal ;
16 operations?
17 MR. GIFFIN: No, sir, not during normal 18 operations. It would only be in the event of an accident, a 19 design basis accident.
20 MR. REPKA: We will get copies of that document 21 the next chance -- 1 22 MS. CURRAN: I have it, I'm just writing --
23 MR. REPKA: Oh, okay. So we'll distribute those 24 and have those marked as PG&E Exhibit 28 and move that that )
25 be accepted into evidence. ]
1 l
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1839
. 1 MS. CURRAN: No objection.
2 JUDGE BECHHOEFER: The Board will admit PG&E l 3 Exhibit 28.
4 [PG&E Exhibit 28 was !
5 received in evidence.]
6 MR. REPKA: We can proceed.
7 MS. CURRAN: Yeah, I was just going to say that !
8 the next item that we want to question about is going to 9 take a little time and I wonder if we could take a five i
10 minute break? l l
11 JUDGE BECHHOEFER: We're certain you can take the 12 five, but should we take our mid afternoon break because we ,
13 have to stop sharp at 5:00 because of the limited 14 appearances.
15 MS. CURRAN: Sure.
16 JUDGE BECHHOEFER: If we take our 15 minute break 17 can we hold off then till five o' clock?
18 MS. CURRAN: Mr. Giffin's my canary in the coal 19 mine.
20 MR. GIFFIN: If she can make it I can make it.
21 JUDGE BECHHOEFER: I guess we'll take a five 22 minute break now and a slightly longer break later.
23 MS. CURRAN: All right.
24 [ Recess from 2:25 p.m. to 2:40 p.m.]
25 JUDGE BECHHOEFER: Back on the record.
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l 1840 1 MR. REPKA: Before we go on maybe I can take care 2 of a housekeeping matter from this morning?
3 JUDGE BECHHOEFER: Fine.
4 MR. REPKA: This morning I distributed the copy 5 that had been identified -- of a document that.had been 6 identified as a document PG&E Exhibit 23, which was the 7 update of the previous MFP Exhibit 90. And I withdrew it at 8 the time and said because there was another more recent 9 version and I now have gotten that more recent version and 10 distributed it at the break. So for the record I'd like to 11 identify as Exhibit, PG&E Exhibit 23, a document that has 12 the label DCO-93-TN-N006, dated August 23rd, 1993. And this 13 relates to design criteria memoranda, maintenance and 14 testing requirements. And we discussed that last week.
15 But for the sake of the record I'd just move this 16 into evidence right here.
17 JUDGE BECHHOEFER: Any objection?
18 MS. HODGDON: No objection.
19 MS. CURRAN: No objection.
20 JUDGE BECHHOEFER: Without objection PG&E Exhibit 21 23 will be admitted into evidence.
22 [PG&E Exhibit 23 was 23 received in evidence.)
24 CROSS EXAMINATION (Resumed) 25 BY MS. CURRAN:
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1841 1 Q Mr. Ortore, I'd like to turn to your testimony at !
2 page 79.
3 A (Witness Ortore) Yes.
4 Q And ask you -- well, is it not true that when ;
5 equipment, safety equipment is qualified that one of the 6 considerations in qualifying the equipment is the normal 7 service environment to which the equipment will be exposed? !
8 MR. REPKA: Let me object before we go too much 9 further. Let's just be clear here when we talk about 10 qualified, that's a term of art and I want to make it clear 11 that Ms. Curran is specifying what equipment she's talking 12 to. Do you maan here qualified per 10 CFR 50.49?
13 MS. CURRAN: That's what -- I mean environmental 14 qualification pursuant to 10 CFR Section 50.49.
15 MR. REPKA: Okay.
16 MR. ORTORE: Okay, I'm sorry, can you repeat the 17 question?
18 JUDGE BECHHOFFER: And the reference was to page 19 79 which deals with that.
20 MS. CURRAN: Okay. All right.
21 BY MS. CURRAN: )
i 22 Q That when -- is it true that when safety equipment j 23 is environmentally qualified under 10 CFR Section 50.49 that l 24 one of the considerations or parameters of its qualified l 25 life is the normal operating condition under which the piece i
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l 1842 )
i 1 of equipment is expected to operate? I O 2 A (Witness Ortore) That is correct.
3 Q And it's also true that one of these parameters is 4 temperature?
5 A (Witness Ortore) Correct.
6 Q Okay. So that when you say that a given piece of 7 safety equipment is-environmentally qualified pursuant to 10 l 8 CFR 50.49, qualified say for 40 years, that you're saying !
9 it's qualified for 40 years, assuming that it's exposed to a l 10 certain maximum operating temperature? l 11 A (Witness Ortore) When we say that an item is 12 qualified for any length of time that means that it has been 13 subjected to aging for that amount of time and then has been l
14 qualified to the local conditions subsequent to that aging.
O 15 Q So you say, when you do that aging of the i
16 equipment that you are -- you're assuming say that the !
17 equipment would be subject to certain normal operating-18 temperatures and that that assumption goes into the manner 19 in which you age the equipment? >
20 A (Witness Ortore) That's correct.
21 Q Okay. !
22 [ Pause.]
23 And is it not true that one of the ways that you maintain 24 environmentally qualified equipment at the Diablo Canyon 25 Nuclear Power Plant is to monitor the normal operating j I
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1 l
1843 l 1 temperature to which this equipment is exposed to determine 2 whether those temperatures stay within the limits that are 3 assumed in the -- that were assumed when the equipment was 1 4 qualified? I l
5 A (Witness Ortore) That is also correct.
6 Q And is it not also true that you have found 7 localized, so-called hot spots in the plant where the l
8 temperature to which some safety equipment is exposed is, in ;
l 9 fact, higher than the temperature -- the normal operating l 10 temperature for which it was originally qualified for a 11 given period of time?
12 A (Witness Ortore) No. We have found hot spots at 13 which temperatures are higher than we previously expected 14 those areas to be at.
O 15 Q That's right. And that, the temperature -- the 1
16 qualified life of a piece of equipment is based on the 17 temperature that you previously expected the component to 18 see? I 19 A (Witness ortore) That is correct.
20 Q And that if you -- if the normal operating :
l 21 temperature exceeds that assumed temperature then you may !
22 need to reduce the qualified life of that component?
i 23 A (Witness Ortore) That is also correct. !
24 Q And when you reduce the qualified life of a 25 component that means that for the maintenance program that ANN RILEY & ASSOCIATES, LTD.
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l 1844 i
1 changes the schedule for changing out that component? l
( i N 2 A (Witness Ortore) That is also correct. j 3 Q And are you familiar with NRC informaticn notice-4 number 89-30, which is Mothers For Peace Exhibit T-1, dated 5 March 15th, 1989, which discusses high temperature 6 environments at nuclear power plants?
7 A (Witness Ortore) Yes, I am.
8 Q Okay.
9 [ Pause.]
10 I note at page three of that information notice the NRC h
11 states that, 12 "It is important f;* licensees to be 13 aware that there are areae within the I
14 plant where the local terperature may
'T O 15 exceed equipment qualification l l
16 specifications even when the bulk l 17 temperature, as measured by a limited 18 number of sensurs, in indicating that it 19 is lower than the qualification
)
20 temperature."
4 21 Have you established a program for evaluatirig whether there 22 are local areas that are -- that have higher temperaturets 23 than the bulk ambient temperature measurements would show?
24 A (Witness Ortore) Yes, we have. The program 25 started well before issuance of this NRC document and we ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 l
1845 1 began monitoring potential areas in the plant where we felt 2 the temperatures might be higher them previously 3 anticipated. When we discovered that we had such a 4 situation we brought on consultants, Sergeant & Lundy to 5 help us in a study of these areas. We went in, took the !
l 6 information that we had available. We had been collecting l 7 this information on these hot spots just about since 8 operation of the plant began and we did an analysis on these 9 temperatures and used the temperatures that we found to make 10 any adjustments or to recalculate any qualified life of any !
11 EQ equipment, both inside containment and some outside 12 containment and recalculated the cualified life and made
- 13 those adjustments to the PM program such that we would l l
14 change out that equipment at the end of its calculated O 15 qualified life.
i 16 Q And you have also-developed a procedure for this ,
17 temperatura monitoring program, haven't you?
18 A (Witness Ortore) Yes, we have.
19 Q And is that MPE-57.8A, which is marked here as MFP l
20 Exhibit T-2?
21 A (Witness Ortore) Yes.
22 Q Okay. And does that procedure involve the i 23 placement of stickers called teletemp reporting stickers on 24 various pieces of safety related equipment?
25 A (Witness Ortore) Yes, we use these in areas and ANN RILEY & ASSOCIATES, LTD.
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1846 !
1 specifically on pieces of equipment. !
O 2 Q Can you tell us a little bit about how the i
i 3 teletemp stickers work?
(
4 A (Witness Ortore) Yes. Essentially they're tabs 5 with a mylar face and underneath there's certain squares -
c 6 that contain a chemical that is very sensitive to j 7 temperatures. When a temperature is reached it essentially 8 melts this chemical that gets absorbed into a pad and 9 therefore it would change the color of that padding. We 10 have done tests on these in our instrumentation lab in )
11 controlled ovens and found that these respond within one 12 second to within one degree of the labeled temperature for 13 that square.
/ 14 So by exposing these to a temperature it 15 permanently changes the color of the window and therefore, 16 it shows us the highest or the peak temperature that was 17 achieved in that area. Again, it is not -- it continuously 18 monitors the temperature of wherever they're placed or 19 whatever area they're in, but it only records the highest l 20 temperature that it's seen during that period of time.
21 Q And are the pieces of equipment to which these 22 teletemp stickers are affixed described in Appendix 8.2 to 23 this procedure?
24 A (Witness Ortore) Correct.
25 Q Okay.
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1847 (Witness Ortore)
() 1 2
A I believe that these are the pieces of equipment that require to have these stickers. In 3 addition, these stickers are used in various other places 4 too where we might even anticipate there being changes. . So. !
I 5 it's not just limited to these pieces of equipment, but 6 these are the minimum that we do monitor. ;
7 Q Is there another list of other pieces of equipment j 8 to which these stickers are affixed? f 9 A (Witness Ortore) I'm not aware if there is a
{
10 permanent list elsewhere.
i 11 Q When you -- when maintenance personnel go in on a i 12 refueling outage they read these stickers, do they? f i
13 A (Witness Ortore) They actually remove the !
14 stickers and they adhere them to a sheet. Occasionally the l 15 stickers could be damaged on removal. Fir.ct they're read 16 and the temperature is recorded on these forms and then the 17 sticker is removed and adhered to this data sheet also if f i
18 they can be removed.
i 19 Q In Appendix 8.1 on this procedure is a sample of f I
20 those data sheets that you use, isn't it? !
21 A (Witness Ortore) That is correct. ft 22 Okay. If a maintenance worker were going in to !
Q t
23 look for these teletemp stickers on a refueling outage would j 24 he use Appendix 8.2 to find those stickers?
25 A (Witness Ortore) That would initially be the list :
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1848 1 that that would be mandatory. However, if there were other 2 places that it was affixed'they'd also have that information 3 available to them so they'd remove them. They'd also take r 4 that information and remove the stickers. So, yes, this 5 would be at least a minimum of what they would look for.
6 Q Okay. And supposing that I were going in, looking 7 at the second page -- no, wait a minute. It's the one, 8 two -- looking at the third page of Appendix 8.2, supposing 9 I were a maintenance worker and I was going in to look for 10 the teletemp stickers and I was told to go into the general ,
11 area near FCV-38. Where would -- what is K6481, which is i
12 the top item described there?
13 A (Witness Ortore) I'm sorry, which page are you 14 reading? j O 15 Q I'm on the -- I'm on actually the last page of 16 Appendix 8.2. Oh, page eight of eight.
17 A (Witness Ortore) Okay.
18 Q Eight of eight, okay. And it says, in the first I 19 column, " Item Number General Area". Does that mean general 20 area of what?
21 A (Witness Ortore) Okay, general area, I believe i 22 that these are conduit numbers.
23 Q So is there -- this K6481, is that one conduit? !
24 A (Witness Ortore) Correct. 1 25 Q Okay. How long is the conduit, do you know?
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1849 3 1 A (Witness Ortore) It just passes through this area 2 and this area is the hot area. It may be very long and some 3 of it may be in this area, some not, but it's one cable run 4 through that piece of conduit.
5 Q If I went to the general area near FCV-38 and I 6 was looking for the teletemp stickers on K6481, in Unit 1, 7 how many places would I expect to find to teletemp stickers?
8 Would there be just one?
9 A (Witness Ortore) Well there would probably be 10 teletemp stickers on FCV-38 and in addition it would be in 11 that general area of that -- and it's a confined area where 12 the conduits would go through and that they'd be applied to 13 whatever surface they can.
14 Q But does this item here on the -- the very first 15 item on the top of this page, does that refer to one set of 16 teletemp stickers or would there be more than one in that 17 place?
18 A (Witness Ortore) Generally we put two stickers 19 for each item listed in the Appendix.
20 Q So there'd be two stickers on 6481?
21 A (Witness Ortore) Correct.
22 Q Okay. And for some of these areas it requires 23 more than one sticker, doesn't it? I mean it requires four 24 stickers, not just two?
25 A (Witness ortore) It all depends on the area, it ANN RILEY & ASSOCIATES, LTD.
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1850 1 all depends on the range of the stickers.
2 Q Okay. For instance, if you go to page six of 3 eight, looking at the second item there, FCV-38, it gives 4 two sticker ranges because apparently the temperature range 5 is quite high, is that correct?
6 A (Witness Ortore) It could possibly be.
7 Q So you'd need a total of four stickers on that l 8 valve?
9 A (Witness Ortore) Correct, two for each range.
10 Q And the procedure requires you to put a sticker on i
11 the top of the valve and on the bottom of the valve, isn't !
12 that right?
13 A (Witness Ortore) Correct. ;
14 Q Okay.
O 15 [ Pause.]
16 When you are evaluating the effect of these, if there's high :
17 temperatures, the effect on the qualified life, do you -
18 assume that the temperature was experienced for only a brief_ l 19 time or do you assume that it was experienced, the highest j 20 temperature was experienced throughout the period since the ,
t 21 last outage?
22 A (Witness Ortore) Well the maintenance department .
23 is only responsible for applying the stickers and collecting 24 the information. The actual analysis is done by the design !
25 engineering group in San Francisco.
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1851 1 Q So do you know anything about the analysis that 2 they performed?
3 A (Witness Ortore) I do know that these stickers --
4 the stickers that are used, this temperature is used into 5 the calculation and in general they use that highest 6 temperature that was seen on the sticker unless there is 7 some reason to the contrary that we know that there are 8 changing plant conditions that there's only a momentary high 9 temperature in that area. And that would be done by 10 analysis. In some cases we have even gone in with 11 continuous type recording devices for periods of time to 12 make sure that that was the case. So we've done analyses 13 and for the most part it's either assuming that that 14 temperature is the highest or if we can show through some 15 kind of analysis or further examination that there is only 16 very shert peaks of that high temperature then we would take 17 that into account.
18 JUDGE BECHHOEFER: One clarifying question. Are 19 the stickers at all time dependent? I mean do they take a 20 minimum amount of time to reach -- to record a particular 21 temperature?
22 MR. ORTORE: Like I said before, we've tested them 23 and they've shown that they will change temperature, they 24 will change color within one second of reaching that 25 temperature within one degree. So they change very -- they O ANN RILEY & ASSOCIATES, LTD.
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I 1852 1 react very, very fast to the temperature changes. And then 2 they essentially lock in at that temperature. So if the 3 temperature goes down it will still show that that highest 4 temperature was achieved.
5 JUDGE BECHHOEFER: I see.
6 BY MS. CURRAN: ,
7 Q Now you were saying that the engineering 8 department does these analyses of what is the effect of the 9 higher temperatures on the qualified life?
10 A (Witness Ortore) That is correct.
I 11 Q And then does some direction come back to you as 12 to what the new qualified life is? l 13 A (Witness Ortore) If for some reason their ;
/ 14 analysis showed that the temperature was higher than 15 originally anticipated and they calculate a shorter 16 qualified life, that information is transmitted down to us.
17 That information is then fed into our preventative 18 maintenance program and we would schedule an activity prior 19 to the end of that qualified life to change the item.
20 Q Okay. And your department is responsible then for 21 replacing the item at the end of its new qualified life?
22 A (Witness Ortore) That is correct. The 23 maintenance department performs that.
24 Q Okay. Let's turn to Mothers For Peace Exhibit 25 T-3, which is a report by Sergeant and Lundy Engineers in j i
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l 1853 1 Chicago, it's called, " Effective Localized High Temperatures 0-- 2 Upon EQ Components", and it's dated February 27th, 1990. I I
3 think you mentioned this report before?
4 A (Witness Ortore) Correct.
5 Q This report was prepared on behalf of PG&E to i
6 evaluate the effect of locali:ed high temperatures on the l 7 qualified life of safety equipment?
8 A (Witness Ortore) It was specifically -- we l 9 specifically brought them in to evaluate those areas where 10 we recognized that we did have high temperatures and an 11 analysis was done by them to determine, yes, the effect on 12 the qualified life. :
l 13 Q Okay. And as of 1990 when this study was done, 14 was this study used to re-evaluate the qualified life of O 15 various pieces of safety equipment at Diablo Canyon Nuclear 16 Power Plant?
17 A (Witness Ortore) I can't answer that, that's done 18 by the design engineering department and I don't have those 19 details on their analysis.
I 20 Q So for instance, would it be any concern of yours 21 that, at page six of the Sergeant and Lundy report, the 22 consultant states that, i
23 "The effect of humidity and radiation 24 upon the accuracy of the stickers - "
25 and they're referring to the teletemp stickers here, I O ANN RILEY & ASSOCIATES, LTD.
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l 1854 1 believe,
.O 2 "-- was discussed with the manufacturer.
I 3 The manufacturer replied that humidity 4 will have no effect. However, he has 5 insufficient experience or test data to j 6 respond as to whether radiation will 7 have any effect."
8 Is the integrity of the teletemp stickers a matter of l 9 concern to your department? i 10 A (Witness Ortore) We, in all the years we have I
11 been using them we have not had any problem. We have no l 12 reason, whatsoever, to believe that these teletemp stickers 13 are anything but accurate.
14 Q Okay.
]
15 [ Pause.] ;
16 Mr. Ortore, going from page six to page seven of this 17 report, I just want to discuss the assumptions made 18 regarding the use of the stickers as a means to determine 19 the ambient temperature or to determine that the ambient 20 temperature is conservative. First of all, the report says, 21 "The temperature used for evaluation 22 purposes is always higher than the peak 23 temperature actually experienced."
24 Do you agree with that?
25 A (Witness Ortore) I believe that what that states O ANN RILEY & ASSOCIATES, LTD.
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l 1855 1 is that it on these stickers a certain temperature was 4
O 2 reached the next highest temperature or the next highest l
1 3 window temperature would be the temperature that.would be 1
4 used since we're assured that the temperature did not reach l 5 that temperature and I think that's what they're explaining 6 here.
l 7 Q So, in other words, if the -- the temperature j 8 stickers will say, they'll go from say 120 degrees to 180 l l
9 degrees in ten degree intervals, and if 170 -- if the 170 10 block was effected and changed color then that tells you I 11 that the component reached somewhere between 170 and 179 12 degrees, is that right?
13 A (Witness Ortore) That's correct. It could be 14 anywhere in between there and we're not sure. Each window, 15 like I said, is ten degrees apart, and we only know that one 16 window changed at 170 degrees, it may have been higner, so 17 therefore, we would just assume the next window that did not 18 change color because we know that it did not achieve that 19 higher temperature.
20 Q And then in paragraph C on page seven, oh wait, 21 paragraph C states, l l
22 "The stickers measure peak, not average 23 temperature."
24 And I believe you've already stated that how these stickers i
25 work is they tell you the peak temperature that was hit for O ANN RILEY & ASSOCIATES, LTD.
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1856 1 that component, whether it lasted a second or two months?
2 A (Witness Ortore) Correct.
3 Q Okay.
4 JUDGE BECHHOEFER: For the purposes of the record 5 I think 4.3B and 4.3C are what was just referred to.
6 BY MS. CURRAN:
7 Q Then in paragraph 4.3C, in the last sentence it l
8 says, l 9 "Unless there was a sound basis to j 10 assume otherwise the peak temperatures ,
i 11 recorded by the stickers were assumed to 12 have existed continuously."
13 Is that correct?
14 A (Witness Ortore) That is what it says, yes.
15 Q But is it correct?
16 A (Witness Ortore) It is a correct assumption, yes. ,
i 17 Q Okay. All right. Now down at the bottom of that 18 page, in Section 5.1, it explains that, 19 "The environmental qualification Ll.. cree l l
20 are based upon the bulk ambient i 1
21 temperatures defined by DCMM-76."
22 And then it gives some temperatures beneath that. The issue 23 with respect to this particular program is that localized 24 temperatures may be higher than those ambient temperatures 25 as defined in the EQ binders, isn't that correct?
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1857 1 A (Witness Ortore) That is correct.
2 Q Okay. Can you tell me, in the equipment 3 qualification files, what is -- is there a standard 4 temperature that you see to which equipment is generally 5 qualified, say the bulk of this safety equipment, in terms 6 of normal operating temperatures?
7 A (Witness Ortore) I'm sorry, I don't understand 8 it.
9 Q Well for most equipment -- my understanding is 10 that most equipment say is qualified for a normal operating 11 environment of about 120 degrees, is that right? Or 120 to 12 140, somewhere in there?
13 A (Witness Ortore) That could possibly be. There's 14 no fixed temperature. It all depends on the procedure used 15 by the organization that did the qualification, the actual 16 lab, as to what temperature they used or what method they 17 used to age it.
18 Q Okay. Is it also true, as it states in Section 19 6.0, on page 12, that actual temperature data for a number 20 of components included in Table 2 was not available from the 21 temperature surveillance program?
22 A (Witness Ortore) That's what it says, yes.
23 Q Okay. And Table 2, just for clarification, 24 identifies the qualified service life based upon the design 25 ambient temperatures defined _in DCMM-76 and the qualified ANN RILEY & ASSOCIATES, LTD.
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l 1858 1 service life based upon the temperature determined via the i
O 2 temperature surveillance program, is that right?
3 A (Witness Ortore) That is right.
4 Q Okay. So just, in other words, Table 2 contains 5 information yielded from the teletemp program about the new 6 qualified life of some of these components, is that correct? l 7 A (Witness Ortore) That is correct. !
8 Q Okay.
9 [ Pause.] !
10 JUDGE BECHHOEFER: Well, just for clarification, 11 Table 2, when you say it has extrapolations, does that not 12 mean that something other than the actual data is being 13 used? I mean when you talk about extrapolations, what are
/ 14 you extrapolating?
15 [ Pause.] l l
16 Does this mean that the -- a component farther into the 17 plant, away from where we're talking about, might have a 18 temperature of "X", so therefore, we assume it's "X" for 19 this one? Or is there something a little more concrete that 20 -- to base the extrapolation on?
21 MR. ORTORE: I believe what this is saying is that 22 for certain components that are in the same vicinity, that 23 if we did not have the-teletemp stickers directly from it 1
24 that we extrapolated what those temperatures would be. And 25 again, I'm not the design, I'm not the EQ design engineer 1
1 e
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1859 1 and my best knowledge, based on here -- based on what I'm 2 reading here, it may be that a component is located, for l l
3 instance, below a known temperature and therefore we would 4 make-the assumption that the temperature would be lower than 5 that temperature above. So it's that type of extrapolation 6 that would be made.
7 JUDGE BECHHOEFER: It isn't for instance, well, a 8 component in Unit 1 is this and we don't have the record of 9 the sticker for Unit 2, but we'll assume it's the same, it's 10 something more concrete I take it?
11 MR. ORTORE: Yes, I believe so.
12 JUDGE BECHHOEFER: Right.
13 BY MS. CURRAN:
14 Q But you're not sure exactly what it is?
15 A (Witness Ortore) I can't possibly sit here and 16 tell you what all the extrapolations were, no.
17 Q Do you know how many components included in Table 18 2, for how many of those components the actual temperature 19 data was unavailable?
20 A (Witness Ortore) At the time the report was 21 generated, no, I don't know specifically how many.
22 [ Pause.)
23 -However, this was done in 1990 and we've continued to 24 monitor the equipment and since then we have gathered much 25 more temperature information than we had at that time and A
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l 1860 1 all this information is continually fed into our design 2 engineers. Every outage all this information is taken, it '
3 is given to the design engineers and an evaluation is made l
4 every outage as to assure that the temperatures recorded are 5 still within the expected values.
6 Q Mr. Ortore, was Table 2 used to determine which
, 7 components required teletemp stickers and needed to be 1
8 monitored in that manner?
l 9 A (Witness Ortore) That is part of the basis of the 10 EQ program and that is what we use as the basis for the 11 minimum of what we need to record.
12 Q Are you familiar with any instances where actual 13 temperature data was unavailable, but an extrapolation was 14 made to determine that localized monitoring through teletemp O 15 stickers wasn't necessary?
16 A (Witness Ortore) I believe we just discussed that 1
17 about the extrapolation --
18 Q Well could you answer the question?
19 A (Witness Ortore) I don't know the specific 20 instances but the report does say that that has happened.
21 Q Okay.
l l 22 [ Pause.] ]
23 Now, as we discussed earlier, when you use these teletemp :)
24 stickers they're used in a conservative manner, isn't that i 25 right?
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i 1861 1 A (Witness Ortore) They -- because of the way they 2 measure they are a conservative device.
3 Q But say, for instance, if you have a teletemp 4 sticker and you see that the block that says 150 got 5 changed, responded to that temperature, that it's black on i
6 the -- or whatever color it turns on the teletemp sticker, 7 when you're doing a calculation of how hot that component 8 got you assume that it got up to possibly 159 degrees?
9 A (Witness Ortore) I did not perform the 10 calculations, but yes, that sounds like a reasonable l l
11 assumption that should be made during that calculation. i 12 Q And do you agree that it is important for this 13 system to be conservative?
14 A (Witness Ortore) Yes.
15 Q Okay.
16 [ Pause.]
17 Just to refer back for a moment to Mothers For Peace Exhibit 18 T-1, at page two, under " Discussion", I'm wondering if you 19 agree that one of the reasons that a conservative approach i 20 is important is that as it says here, i 21 " Electrical cables are vulnerable to 22 degradation when exposed to high 23 temperatures that exceed their design EQ 24 temperature even for a short period."?
25 (Pause.]
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l 1862 l 1 A (Witness Ortore) That's what it says.
(~ l 2 Q Well do you agree that that's one reason why it I i
3 would be important to have a conservative program because l 4 components such as cables are -- may be sensitive to -- or 5 may be vulnerable to degradation even when exposed to high j l
6 temperatures for a short period? 1 7 A (Witness Ortore) Not being an expert in 8 environmental qualification I cannot answer that. But I do 9 agree that is what this document states.
10 Q Okay. All right, going on to Table 2, which Table 11 2, by the way, is Mothers For Peace Exhibit T-3A, it should 12 have been included in Mothers For Peace Exhibit 3, but we 13 discovered only last night that we were missing this table 14 and so we couldn't get it into the document in time. So
-O. 15 it's a separate document here, but it does belong as part of 16 this Exhibit 3.
17 In attachment to Table'2, which is part of Exhibit 18 T-3, Sergeant and Lundy provide the basis for the 19 temperatures used in their evaluation, isn't that correct?
20 A (Witness Ortore) Okay, we're back to the report?
21 Q I'm sorry, we're back to Exhibit T-3 --
22 A (Witness Ortore) Okay.
23 Q -- and we're at attachment 1 to Table 2, which is 24 toward the back.
25 A (Witness Ortore) Okay.
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1863 1 Q Okay. Now this attachment describes localized A
\-s 2 teletemp measurements and how they were used in Sergeant and 3 Lundy's evaluation of the effect of high temperatures on 4 qualifjed life, is that correct?
5 A (Witness Ortore) That is correct.
6 Q Okay. In basis 2, the Sergeant and Lundy provides 1
7 temperature surveillance measurements for operators 8 associated with FCV-95. And it says that, 9 " Temperature surveillance measurements 10 were only available for Unit 1."
11 They also, on the following page, state, in the very last 12 sentence that they assumed a temperature of 160 degrees. Do 13 you know what they assumed about Unit 2? Oh, I'm sorry, I 14 retract that, I didn't see that it was a different basis.
15 I'll restate the questions. Sergeant and Lundy 16 says that, use to peak value measured, which is 160 degrees.
17 But it also says that, la " Temperature surveillance measurements 19 were only available for Unit 1."
20 Is that correct?
21 A (Witness Ortore) That's what the document says, 22 yes.
23 Q Do you know what Sergeant and Lundy, what kind of 24 assumptions they made about Unit 2?
25 A (Witness Ortore) Specifically, no.
1 i
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i 1864 {
i 1 Q Okay. Would you say that it was conservative to l 2 use the peak value measured in Unit 1 for both units in this ,
i 3 case? t 4 A (Witness Ortore) Not being the author of this 5 document or involved with the analysis I really can't answer !
6 that and there may be other assumptions in here, I'm just l 7 not certain.
8 Q Okay. .
[ Pause.]
+
9 10 Moving on to basis three, which is the next one, there are i 11 figures for both Unit 1 and Unit 2. And you can see that 12 the peak figure for Unit 1 is 180 and the peak for Unit 2 is l 13 200, isn't that right?
14 A (Witness Ortore) That is correct.
15 Q Okay. But in this case, even though there were j 16 higher temperatures measured, Sergeant and Lundy chose to l 17 assume the lower temperature of 160 degrees Fahrenheit, f
18 isn't that correct? l t
19 A (Witness Ortore) Well I believe that this j l
20 experi -- this paragraph here goes on to explain that 21 because of certain plant conditions, because of downstream 22 cores are closed during normal power operation but 1
'1 23 momentarily opened during pressure transients, there should j 24 be significant temperature variations between the conditions 25 of flow and now flow through the process pipe. Essentially e
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1865 4
1 for those very brief periods of time when these valves are, 2 I think the expression is used, when they're burped, a very 3 high temperature is experienced for a very, very short .
4 amount of time.
5 I also know that this is one of the areas where 6 they have done additional temperature monitoring where 7 additional instrumentation was brought -- was installed so 8 that we can look at trends over a period of time. So there ,
9 was other information that supplemented this. I 10 Q Moving on to basis five, which refers to position ;
11 switches associated with FCV-22 and 23. It looks to me like 12 the peak temperature, at least the window that was changed ,
13 in this was at 140 degrees. But there's one sentence below l 14 that says the most probable temperature is 130 degrees plus j 15 a few degrees. So Sergeant and Lundy used 130 degrees. Do 16 you agree that that is a conservative assumption? {
17 A (Witness Ortore) I think in this case, if you'll 18 look at reference nine, we actually went in there and 19 measured the actual temperature there and that's where the 20 128 degrees came from and that's why the assumption of 130 ,
1 21 was made.
22 Q When you say you went in and measured the actual 23 temperature, what exactly did you do?
24 A (Witness Ortore) Well when I say we, I meant that 25 the plant, I didn't personally. I think it was -- I think O ANN RILEY & ASSOCIATES, LTD.
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1866 1 that's identified elsewhere in the document.
O 2 [ Pause.]
3 Q I'm not, is reference nine attached to this? I'm 4 not sure it is.
5 A (Witness Ortore) I don't believe so.
6 Q Well, I do have a copy of reference nine here that 7 I can show to you. It says, 8 "On November 14th and l'i h Mr. Bruce -
9 Smith of PG&E, Mr. Robert Sherland of 10 S&L and Ms. Ella Gils of S&L performed a 11 walk-down of Diablo Canyon Power Plant 12 operating Unit 2. The purpose of the 13 walk-down was to record readings from 14 teletemp temperature stickers that had 15 been previously placed on equipment and 16 also to record current temperatures by 17 taking measurements with a temperature 18 probe and an infrared temperature 19 monitor."
20 If you'd like to see it I'll pass it over.
21 A (Witness Ortore) Yes, please.
22 [ Pause.]
23 JUDGE BECHHOEFER: What's the page reference?
24 MS. CURRAN: I'm reading from reference nine,_
25 which is not attached to the exhibit that we --
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1867 1 JUDGE BECHHOEFER: Oh, oh. !
2 MS. CURRAN: -- gave you. It was inadvertently 3 omitted.
4 JUDGE BECHHOEFER: Oh, I couldn't find it 5 anywhere.
6 BY MS. CURRAN:
7 Q Let me just ask you a little bit about this. This 8 was a visit to Unit 2, right? The walk-down was of Unit 2?
i 9 A (Witness Ortore) I believe so.
10 Q Okay. It doesn't say here exactly, under basis 11 five, whether it's for one unit or two units, do you know?
12 A (Witness Ortore) I don't know specifically, no.
13 Q Okay. And there were two days here when this was 14 done and a temperature probe was used, can you tell me 15 exactly how that works?
16 A (Witness Ortore) It's instrumentation that's a 17 calibrated instrumentation that they would bring in and 18 record temperatures much like an electronic thermometer.
19 Q And an infrared temperature monitor, how does that 20 work?
l 21 A (Witness Ortore) I'm not specifically positive on 1 22 how that instrumentation work, but it's obviously reading 23 the infrared and'then translating that to a temperature.
24 Q Okay. And they just would have done this on those 25 two days that they went in there, right? They wouldn't have l
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1868 1 -- it doesn't look to me like they left these probes there, 2 they just went in and took some measurements?
3 A (Witness Ortore) I know that there was recording 4 information put in specific locations in the plant. I'm not 5 sure if that's what this is referring to.
6 Q Okay. Also, when I look at reference nine it 7 shows that the temperature was measured for FCB-23, I don't 8 see anything about FCB-22, which was the component with the 9 higher measurement. Would you like to look? Maybe I'm 10 missing something.
11 [ Pause.]
12 MR. REPKA: Ms. Curran, is the question here what 13 Mr. Ortore knows about what Sergeant Lundy did in 1990, is j i
14 that what we're trying to find out here? j O 15 MS. CURRAN: Well he just told me what happened i
16 and I'm trying to find out more about it. He said this was j 17 done and I'm following up.
18 MR. REPKA: The issue here is the maintenance
)
19 program and the maintenance program for EQ and equipment l 20 involves current day, teletemp stickers and I think Mr.
21 Ortore has testified as to how that is translated into j l
22 qualified life by engineering and sent back to maintenance. l 23 And in this historic document, which dates back to the 24 beginnina of the teletemps, I'm not sure why Mr. Ortore 25 needs to know what happened by EQ -- why that's significant ANN RILEY & ASSOCIATES, NTD.
Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 I
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1869 l 1 to the issue we're here today.
2 MS. CURRAN: Well for one thing this study done by i
3 Sergeant and Lundy was apparently used to establish what the l 4 list of components would be that would need teletemp 5 stickers. So the methodology that was used to make that ;
1 6 determination I think is an issue here. And second, the !
7 document relates to how this equipment was measure -- how 8 the temperature on this equipment was measured and then how l l
9 those measurements were used to determine the effect on i 10 qualified life, which in turn effects when the maintenance 11 program has to replace these pieces of safety equipment.
12 So the fact that one piece of this effort was done 13 by the engineering department I don't think detracts from 14 the relevance of this analysis to the adequacy of the 15 maintenance program.
- 16 MR. REPKA
- I think the question ought to be is 17 FCV-22 and 23 do they need teletemp stickers, do they have 18 teletemp stickers today? That ought to be a foundation 19 question.
20 MS. CURRAN: Well it's not just the question of 21 whether they need teletemp stickers but apparently this was 22 used to make some kind of assumption about what the proper 23 qualified life ought to be for this FCV.
24 MR. REPKA: Well again, that's a dynamic issue and 25 based on the most current temperature monitoring what the l l
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l 1870 1 qualified life is, not what happened in 1990.
0 2 JUDGE BECHHOEFER: Well let me raise -- what?
3 [ Judges confer.)
4 One matter of inquiry that comes to my mind, and I don't ,
1 l 5 even know whether it's in this Exhibit T-3, I guess it is, l l
6 is there any dealing with equipment for which, and this is 7 just a hypothesis because I haven't read this thoroughly ;
i 8 enough, the exhibit, to know whether it's so or not, l 1
l 9 equipment that Sergeant and Lundy thought should have i 10 teletemp stickers but from say 1982 to 1990, I guess the l
11 period of operation, or at least '85 to '90 didn't have l l
12 that. Is there any dealing with that issue in here? Absent i 13 some time the study of it, and I haven't had time to look 14 through it to know, and is that an issue, or should that be 15 an issue? l 16 MS. CURRAN: Uh-huh.
17 JUDGE BECHHOEFER: What does that -- does that ,
l 18 affect qualified life if during its first five years of I l
19 operation perhaps-there wasn't adequate temperature 20 information or control? Again, I'm hypothesizing, I don't 21 know that_that's the case because I haven't had a chance to 22 sit down and read this in any detail.
23 MS. CURRAN: I'm not sure I know the answer to i I
24 your question.
25 JUDGE BECHHOEFER: Was that something you were i
i O ANN RILEY & ASSOCIATES, LTD.
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1871 1 trying to drive at through your series of questions?
2 MS. CURRAN: What I am trying to get at here is 3 that this report was used in 1990 to make assumptions about 4 the qualified life of various pieces of equipment and that - l 5 - I guess -- l 6 JUDGE BECHHOEFER: Well, at least conceptually 7 that includes the point of my inquiry. l 8 MS. CURRAN: And as far as the effect of the --
9 the relationship between later monitoring programs than this
, 10 that we still have to develop that.
11 JUDGE BECHHOEFER: Well, I think the inquiry l l
12 itself is legitimate. Now, whether the witnesses can answer 13 your questions, that's a different question. If they don't I 14 know and say so, that may be the way the record has to stand 15 on that.
16 MS. CURRAN: Okay. Is there a question pending?
17 Okay. So shall I go on?
18 JUDGE BECHHOEFER: Yes.
19 MS. CURRAN: Okay. All right.
20 BY MS. CURRAN:
21 Q Okay. In basis 6, it discusses position switches 22 in pilot solenoid valves associated with FCV 4344. Again, 23 it's not clear to me whether this refers to one unit or both 24 units. Is it clear for you, Mr. Ortore?
I 25 A (Witness Ortore) No. It's not clear to me O ANN RILEY & ASSOCIATES, LTD.
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.1872 1 specifically.
Q And this is another case where'it appears that the 3 peak temperature here was for valve FCV 44, which was 130 4 degrees, and based on information provided in reference 9, ;
5 Sergeant and Lundy decided to " conservative use 125 6 degrees." i 7 I'm asking you again do you think that the use of 8 the lower temperature was a conservative approach?
9 A Lower temp (rature meaning lower than 130 degrees, 10 yes. I think they felt that this was conservative, and 11 also, I think, built into all these calculations are the 12 fact that these temperatures, although in all these ;
13 assumptions, it's assumed that that peak temperature is 14 maintained for the entire life of the component.
O 15 In actuality, we have refueling outages'in which f
l
{
16 the temperature comes down, and those are just used as 17 additional -- additional margin in these calculations. That 18 does not come into effect, and we just estimate that these 19 temperatures, these peak temperatures, were used during the 1 20 whole life of the component.
21 Q Wait a minute You say that you assume that the 22 peak temperatures existed during the whole life of the
)
- 23 component, right?
24 A Yes. In actuality, we have outages, you know, 25 periods of time when the temperature is much, much lower O ANN RILEY & ASSOCIATES, LTD.
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1873-1 than that same high temperature that we assume during the 2 whole qualified life.
3 Q So, in other words, this assumption that's used in 4 paragraph C on page 7 that, 5 "Unless there was a sound basis to 6 assume otherwise, the peak temperatures 7 recorded by the stickers were assumed to 8 have existed continuously,"
9 -- that you are into that assumption? You are building 10 something period for a lower temperature during outages?
11 A No. I'm saying, for calculation basis, that high 12 temperature was assumed to exist continuously. In 13 actuality, that was not the case. In actuality, these 14 experience much lower temperatures during outages, et 15 cetera.
16 Therefore, I'm saying that, even though 17 theoretically we could take that into account, we don't, and 18 that is just added margin into these calculations. I think 19 I want to clear up one thing also, when you said that we 20 used this report to determine where the teletemp stickers 21 are located.
22 We include teletemp stickers on all EQ equipment 23 in containment. Every piece of EQ equipment in containment 24 does have teletemp stickers. So it is more than just -- it 25 wasn't just Sergeant and Lundy that determined which O ANN RILEY & ASSOCIATES, LTD.
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l l
I 1874 l 1 components should have. I 2 In addition, those EQ components that are located j l
3 near high -- mostly near the main steam lines where they'd j 4 experienced higher temperatures also have the stickers. So 5 it is not just an S&L recommendation as to where to put the i 6 stickers.
7 Q Okay. Well, then help me clear something up here, f 8 because at the beginning of the Sergeant and Lundy report, )i 9 on page 3, section 3.1, Sergeant and Lundy says that when it i 10 was doing this investigation they put temperature stickers !
11 on approximately 147 components located inside the 12 containment and 12 components located outside the
]
13 containment, okay?
14 A I believe that 147 represent all the EQ components 15 in containment.
16 Q So, yeah. There must be at least 147 components 17 inside the containment?
18 A Correct.
19 Q I don't count 147 on this Appendix 8.2 to your o
20 procedure here, and can you explain that?
21 A Okay.
22 Q There's less than 40.
23 A These -- the components that are listed this 24 procedure are strictly those that are maintained by the 25 electrical maintenance section. In addition, there are ANN RILEY & ASSOCIATES, LTD.
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1875 1 instrumentation and control instrumentation. We have a 2 master equipment list cf all EQ equipment that contains 3 everything. This listing here is a subset of all the EQ 4 equipment in the plant. l 5 Q So you say there's this instrumentation and !
I 6 control equipment? That's not electrical equipment?
7 A They are instrumentation devices. They arc 8 electrical in the sense that they work with electricity, but i 9 they come under the responsibility of the INC section as l
10 opposed to the electrica] section. ;
i 11 Q So is there another procedure that we haven't !
i 12 gotten that results to that?
13 A There is a -- there is a lot document that lists ,
t 14 all the EQ items in the plant, yes. That is a requirement 15 of the program.
16 Q Well, that -- okay. All right. Well, what -- you 17 know, do you attach a procedure to that to describe how to i
18 do it? Is there a procedure equivalent to 57.8A that 19 applies to that, that other equipment?
20 A I believe that this procedure is the procedure i 21 used for the temperature monitoring, but this -- this
- 22 listing is not the complete list of equipment monitored. {;
23 That's why it says -- I think I did say before as a minimum.
24 There is other equipment that is monitored, and that's where l 25 the 147 plus 12 come from. !
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l 1876 1 So it is all EQ equipment in containment that's O 2 monitored irrespective of whether we think it's no a hot !
3 area or not.
4 JUDGE BECHHOEFER: Well, does this procedure 5 govern the other pieces of equipment making up the 147? I 6 mean, other than the specific pieces of equipment to which '
7 this applies by its charm, let us say, does this procedure 8 apply to the others, or does some other procedure?
9 MR. ORTORE: This same method, the same -- the l l
10 same method of monitoring that equipment is maintained -- is ,
11 used for all the equipment. '
12 JUDGE BECHHOEFER: Well, does that mean the same 13 procedure is used or something else is used? Method could
, 14 be more general.
15 MR. GIFFIN: We don't know the answer right now. ,
I 16 Mr. Crockett used to be the INC director. He remembers the j 17 program using a procedure. He doesn't remember if it was j i
18 this one or not. We believe that there's a procedure that 19 adds the stickers. We don't know which one it is. j 20 BY MS. CURRAN: ),
21 This other instrument and control equipment, is l Q
l 22 that equipment environmentally qualified?
23 A Yes, it is.
1 24 MS. CURRAN: I need to just take a minute here, 25 because it seems to me that we're discovering a whole body O ANN RILEY & ASSOCIATES, LTD.
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1877 l 1 of information that we had no idea existed, and it was my O 2 understanding that we asked in discovery for information 3 about how PG&E maintained environmental qualification of l 4 safety equipment in light of varying temperature conditions, 5 and now what I understand is that what we've gotten is only 6 a portion of the information about this program. :
7 This procedure was identified to us. The teletemp ,
l 8 record for these few pieces of equipment were identified to ]
9 us, and now I'm hearing there's all this other equipment l l
10 that we don't know about. '
11 MR. REPKA: Two responses. Number one, that, I 12 believe, is the formal procedure that governs teletemp 13 monitoring, but, number two, the discovery request on how 14 temperature is monitored for safety equipment was directed 15 at five specific or four specific components listed in the 16 interrogatory.
17 It was for check valves and cables. So I -- with 18 respect to what procedures might exist for other things, it 19 simply wasn't asked for. I think the discovery materials ;
1 20 here are not at all subject to interpretation. They were i 21 very clear as to what they were asking for, j 22 MS. CURRAN: Okay. Okay. Whern were we.
23 BY MS. CURRAN:
24 Q Okay. Going down to basis 7, it discusses 25 position switches and solenoid valves associated with the O ANN RILEY & ASSOCIATES, LTD.
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I 1878 !
l 1 PCV 455-C, 456 and 474. It's true, apparently, that no ,
2 temperature surveillance data was available for those l l
3 components? j 4 A (Witness Ortore) That's what the report states. l i
5 Q Okay. So that the temperatures defined in basis 3 i
'l 6 were used; is that correct?
7 A That's what -- yes. That's what it claims.
i 8 Q Okay. So this is another instance in which the :
9 temperature was extrapolated from a similarly located piece 10 of equipment?
11 A Yes, I believe because, based on their location, 12 which is downstream, they are in a much cooler location than 13 those assumed in basis 3. So therefore, to take a 14 conservative purchase, they used basis 3.
O 15 Q Okay. Then, in basis 8, it discusses position 16 switch associated with FCV 255. It says, 17 "Since no temperature surveillance data 18 .is available and this value is an ,
19 inboard containment isolation valve for 20 a reactor coolant drain tank vent line, l 21 max line temp for DCMM 46 is 266 degrees 4
l 22 Fahrenheit." ,
i 23 Then it says, l l
24 " Conservatively used containment open l
l 25 air ambient, 120 degrees Fahrenheit plus j O ANN RIIIY & ASSOCIATES, LTD.
Court Reporters 1612 K Street, N.W., Suite 300 l Washington, D.C. 20006 l (202) 293-3950 1
i l
l s
1879 1 10 degrees Fahrenheit equals 130 degrees 2 Fahrenheit."
3 Can you explain to me, Mr. Ortore, how you get- j 4 from 266 to 130 degrees? .
5 A No, I can't. I can't explain the basis for this.
6 However, what I do know is that since then we have been 7 monitoring this, and we have been -- we have -- we do have 8 temperature information available since then, and we have 9 been conferring that the temperature of these items do j 10 remain that's -- within what was estimated.
i 11 A (Witness Vosburg) Yeah. I believe the reactor 12 coolant drain tank, it's not continuously vented, nor is the 13 temperature in the RCDT 266 degrees normally. I think that ,
14 was probably an accident-type maximum condition.
O 15 Q You mean you think that the 266 is wrong?
i t
16 A Is not -- no, no. I said that is like a peak, 17 probably, under accident conditions. Under normal plant 18 operation, the RCDT vent is not continuously open. So l
19 there's not flow from the tank to that valve that's located 20 by the inner wall of the containment, SCV 255.
21 I think the reasoning, you know, for the lower 22 temperature is that the 266 that's stated here is not, in my 23 opinion, ever reached during normal operation, and I believe 24 it's probably a peak accident temperature that they 25 calculate for that tank, if you should vent it at that ANN RILEY & ASSOCIATES, LTD.
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1880 ,
1 point.
2 Normally, that temperature is -- the temperature 3 at 255 would be closer to containment ambient temperature.
4 Q But still there wasn't any surveillance data ;
5 available; isn't that right? l 6 A No. I think the question was how do you get from 7 266 to 130. That's the reasoning.
8 JUDGE BECHHOEFER: Well, is 130 a conservative ;
I 9 temperature to use? !
10 MR. VOSBURG: Again, not knowing what they, you ;
11 know, checked in their -- you know, when they went in and 12 walked it down, since it's an inside containment isolation 13 valve, it's most likely located very near the inside wall of ,
14 the containment, which is well away from the major heat O 15 sources, and it's generally a fairly cool area.
i l
1 16 So I will assume -- again, I wasn't involved in 17 this, but I would assume that they walked it down and l
18 verified that it was, you know, ambient temperature, but j 19 it's not documented here. So I can't say for sure that's 20 what it is.
21 MS. CURRAN: All right. Now I'd like to go to the 22 data sheets for the teletemp sticker measurements, and I'd 23 like to just pause here and note that we are missing the 24 data sheets for the fourth refueling outage for both Unit 1 25 and Unit 2, and PG&E has agreed to provide us with those l
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1881 !
1 documents, and we may need to review them briefly tomorrow, 2 but they won't be available until tomorrow. So we'll just 3 go ahead with what we have right now. !
4 MR. REPKA: That's fine.
5 JUDGE BECHHOEFER: Well, let us know if you need 6 time to do that.
7 MS. CURRAN: Okay.
8 JUDGE BECHHOEFER: I assume you're not going to do i l
9 it before 9:00 in the morning, or whenever we start.
10 MS. CURRAN: That we're not going to? i j 11 JUDGE BECHHOEFER: Do it prior to 9 a.m.
l l 12 MS. CURRAN: We'll wait until you get here. To 13 cross-examine on it? Yeah. Okay.
14 BY MS. CURRAN:
15 Q All right. Unfortunately, these don't have page 16 numbers. So I hope we can stay together.on this.
17 JUDGE BECHHOEFER: Is this T-47
, 18 MS, CURRAN: Yeah. We're looking at Exhibit T-4, I i 19 and there are one, two, three, four, five, there's six 20 separately stapled enclosures in this exhibit, and each of 21 them constitutes the teletemp sticker data that Mothers for 22 Peace obtained from PG&E through discovery for that 23 particular fuel outage for the components that are listed in 24 Appendix 8.2 to MPE-57.8A.
l 25 Maybe I should just establish with Mr. Ortore that l
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l 1882 l 1 that's correct. ,
2 MR. ORTORE: Yes, it is.
3 MS. CURRAN: All right. Okay. !
4 BY MS. CURRAN:
5 Q Turning over the first page, the second data !
6 sheet, which is for FCV 38, it's kind of hard to read this, '
7 but what it -- well, you can't read the sticker, but what it 8 says in the blank is that both stickers here went to 200 i1 9 degrees or more; isn't that right?
10 A (Witness Ortore) Yes.
11 Q Okay. So that you really don't know for this I
12 particular component how hot it got, do you?
13 A Possibly not, except that I do know that FCV 38 is 14 a valve that is excluded from the EQ program, although we do C 15 continue to monitor temperature for it. l 16 Q Why do you monitor the temperature for FCV 38?
17 A Just for information. Like I said, there are --
l 18 there are stickers in other areas of the plant besides those 19 on EQ equipment.
20 JUDGE BECHHOEFER: Could someone explain to me why 21 200 plus necessarily means 400, or did I misunderstand 22 somebody?
23 MR. ORTORE: I'm sorry. ,
l 24 JUDGE BECHHOEFER: I said can someone explain to l 25 me at least why 200 plus necessarily means 400?
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I 1883 1 MR. ORTORE: Means 400? No. No one said 400. It O 2 just means that it may be 200. ,
1 3 JUDGE BECHHOEFER: I see. I thought I heard the I l
4 tern 400.
BY MS. CURRAN: I 5
i 6 Q FCV 38 is listed on Appendix 8.22 MPE 37.8-A as I 7 needing stickers with ranges -- well, basically, two sets of i
8 stickers; isn't that right? l 9 A Correct.
10 Q Okay. All right. Now, skipping over the next one 11 to FCV 438, a pipe rack, there is a question mark under the 12 second sticker, isn't t ' ere?
13 A Yes, there is.
14 Q What does that mean?
15 A It probably means that they were not able to read 16 that sticker. Perhaps it was damaged while it was installed 17 or for some other reason.
18 Q Okay. Moving on, skipping another one and going 19 to FCV 440, if we go back to -- if we go back to the 20 procedure, on page 6, it indicates that this is another one 21 that ought to have two sets of stickers, doesn't it?
22 A Yes. It's included.
23 Q Okay. And the reason for that is that had the 24 temperature gone over 150 here, that these particular 25 stickers wouldn't have been able to read the higher J
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1884 1 temperature, would they? ;
O 2 A Correct.
3 Q Okay.
4 A (Witness Giffin) Can I interject.
5 Q Sure?
6 A The date of the data sheet that you were reading 7 was 1988. The date of the procedure is 1992. So, to make a 8 point from now it says four does not necessarily mean that 9 five years ago it meant four. Two may have been fine in 10 1988.
i 11 Q Okay.
12 A There are date differences. We continue to update-13 the procedures. l 14 Q If you skip over two more and go to FCV 6E9, you 15 see there is no second sticker for that one, don't you?
16 A (Witness Ortore) Okay. I'm sorry. When you said I i
17 "second sticker," you were meaning a --
18 Q Well, sticker --
1 19 A -- a second set of stickers for a different 20 range.
21 Q I'll say second set when I mean second set, and 22 I'll say second sticker when I mean second sticker, okay?
23 A Okay. I 24 JUDGE BECHHOEFER: Well, let me just ask -- you ]
I 25 asked about a second sticker. I think it was on FCV 440?
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1885 1 MS. CURRAN: I meant a second set of stickers.
2 JUDGE BECHHOEFER: Oh, okay. That's what I was 3 wondering, because there are two.
4 MR. ORTORE: I thought you asked a second sticker, 5 and I said yes because it was there. ,
6 MS. CURRAN: Oh. I had already moved on. I had 7 already moved.
8 MR. ORTORE: Okay.
9 MS. CURRAN: Okay.
10 JUDGE BECHHOEFER: Well, I just wanted to clarify 11 what we were talking about.
12 MS. CURRAN: All right.
13 JUDGE BECHHOEFER: So now we have.
14 MS. CURRAN: Now we're clear.
15 BY MS. CURRAN:
16 Q Okay. So we were on 659, and, in that case, 17 there's two stickers, but sticker number two is missing, or 18 the leading wasn't on there, on the sheet, right? Maybe it 19 couldn't be read or something?
20 A That's what it appears to me, that it couldn't be 21 read.
22 A (Witness Giffin) That sticker, if I can say, that 23 sticker, they were 100, was the lowest, the one that you 24 said one said 100 the other said nothing. It's very 25 possible that the reason there was nothing written down is i
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1886 1 because that one didn't see 100, depend.ing upon the 2 location.
3 Q Okay. Then, going on to the fifth one at that 4 have, which is item number 8000 C -- oh, never mind. Not 5 the fifth, but the seventh, which is SOV 8078B, a vent I i
6 valve?
7 A (Witness Ortore) Yes.
8 Q What do you think "N/A" means on the blank for l 9 sticker two?
]
10 A Probably means not available.
11 Q Oh, not available. Okay. So the one just before i
12 that has the same notation, doesn't it, for sticker two, not j l
13 available? That's SOV 8078A? That's the same thing? l 1
I 14 A I would assume so.
O 15 Q Okay. And then the one just after that, 8078C, 16 has the same not tion under sticker two, doesn't it, not 17 available? Isn't that right?
18 A Yes. That's what it says.
19 Q Yeah. Keep agreeing with me, and I'll go fast.
20 JUDGE BECHHOEFER: Well, to clarify something, I
21 what all of these ones that we've been asked about, the N/A, !
22 not available or not applicable, whatever, it says NA for 23 new equipment. Each of those sheets says that. Does that 24 have anything to do with the N/As that we see written in?
25 MR. ORTORE: No. That NA is not the same NA that ANN RILEY & ASSOCIATES, LTD.
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1887 j i
1 we're writing in. The box would be checked if it was new j O 2 equipment. If it was_new equipment, the box would be l 3 checked, and there would be no information. What this 4 probably means is that either there was only one sticker 5 found, or the other sticker, they couldn't read the 6 information, and there was no sticker below, because they :
7 probably couldn't move it without damaging it. ,
8 So that's why we're saying it's not available.
9 The sticker is not available, but we were able to read the 10 temperature off at least one of them.
4 11 JUDGE BECHHOEFER: I see. !
l 12 BY MS. CURRAN: i 13 Q For the next one, 8078D, this is the same thing. !
l 14 Sticker two says N/A, right?
O 15 A Yes, it does.
i 16 Q And would you say 160 degrees Fahrenheit is 17 relatively hot?
. 18 A Relative to what?
19 Relative to what equipment is generally qualified
) Q 1
l 20 to see.
}
21 A No. J l
22 Q Okay. j 23 A No, not necessarily.
24 JUDGE BECHHOEFER: Well, C said the same thing, l 25 MS. CURRAN: What?
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i 1888 1 JUDGE BECHHOEFER: C said the same thing.
2 MS. CURRAN: Right.
3 MR. ORTORE: Well, all four of these valves are - -
4 8078C says the same as D.
5 MS. CURRAN: Right.
6 MR. GIFFIN: Wnere the location of these valves 7 are is right on top of the reactor vessel head. I would 8 expect it to be 160 degrees. It's quite warm.
I 9 MS. CURRAN: Quite warm. Okay.
10 MR. GIFFIN: 160, quite warm.
11 MS. CURRAN: Okay.
12 MR. REPKA: Are we going to go through all the 13 NEs?
14 MS. CURRAN: Yeah, probably.
15 MR. REPKA: Are you planning to move the document j 16 into evidence?
17 MS. CURRAN: Yes.
18 MR. REPKA: Could we let the document speak for 19 itself, in the interest of time.
20 MS. CURRAN: Okay. Maybe what I should do is just 21 go through, and if there are examples that are different 22 that I need to ask Mr. Ortore about, that we can sort of 23 establish what something stands for when I see something a 24 little different. How about that?
25 MR. REPKA: Sounds fine.
O 4
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j 1889 l
'l 1 MS. CURRAN: Okay. I C) 2 MR. REPKA: Keeping in mind that this is 1988.
j 3 BY MS. CURRAN:
4 Q If you turn over a few to where it says, ;
5 " Conduit hangers near ceiling,"
6 Do you see that one?
7 A (Witness Ortore) Yes, j 8 Q Okay. I notice that sticker one -- for sticker I 9 one, the temperature is 160 degrees, and for sticker 2 it !
10 looks like 140 degrees. Those temperatures are different, l 11 right, for the top and the bottom of the component?
12 A That is correct.
13 Q And is that the reason for requiring two stickers, 14 one on the top and one on the bottom, because the i
/"]
km/
15 temperatures may be different -- 1 t
16 A That is correct. .
17 Q -- from top to bottom? Okay.
18 JUDGE BECHHOEFER: What's the-other number below l
19 the second?
20 MS. CURRAN: It looks like 120. 3 21 JUDGE BECHHOEFER: What's that mean? i 22 MR. ORTORE: I'm not sure what the 120 is in l
23 reference to.
24 MS. CURRAN: Okay.
25 BY MS. CURRAN:
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1890 l 1 Q All right. Well, we're done with 1 R-2 for the O- 2 moment. We'll go on to 1 R-3, and I'll just look through -;
l 3 and see if there is."anything different that needs to be i 4 pointed out.
5 [ Pause.] j i
6 Okay. Those are all pretty much the same. ;
7 JUDGE BECHHOEFER: Are you covering 2 R-2?
8 MS. CURRAN: I'm on 1 R-3 right now.
9 JUDGE BECHHOEFER: Oh, because that follows. Are 10 you skipping 2 R-2?
11 MS. CURRAN: I'm just going in the order in my 12 pile.
13 JUDGE BECHHOEFER: Because we're not -- I have a 14 question on one of the 2 R-2 ones, but go ahead and ask 15 yours.
16 MS. CURRAN: Mine are organized by Unit 1 and Unit 17 2.
18 JbDE-E BECHHOEFER: As long as you're going to come 1
19 back to that group,, that's all right.
20 MS. CURRAN: I'll get to it.
21 JUDGE BECHHOEFER: Okay.
22 BY MS. CURRAN:
23 Q Mr. Giffin, you had said this procedure requiring 24 the placement of four stickers was put in place in 1992?
25 A (Witness Giffin) No, I didn't say that. I said ANN RILEY & ASSOCIATES, LTD.
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1891 1 the date of the procedure, the last time it was revised was 2 in 1992.
3 Q Do you happen to know when the requirement was 4 established for putting four stickers on with_the ;
i S temperature ranges?
6 A Don't have the vaguest idea.
7 Q You don't know. Okay. All right. Well, I think 8 I've already pointed out places where the procedures say two 9 stickers -- four stickers, and the data sheets only have i
10 two.
11 A (Witness Ortore) Well, what Mr. Giffin said is .
12 this revision of the procedure was not in effect at that i 13 time, and it's very possible at that time that we were only 14 looking at one range.
O 15 Q Well, when do you think it went into effect? ;
16 A This procedure? ;
17 Q Yeah.
18 A Prior to doing these, because that's where these 19 sheets came from, but the procedures go through various 20 changes. This is the fourth revision of this procedure.
21 Q But I'm just trying to find out from you when one 22 could expect to see four stickers here when it was required.
I 23 A Probably when the procedure was changed to require 24 those.
25 A (Witness Vosburg) Here's an example in the last, i
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1892 1 or 1 R-5 that has four stickers on, FCV 441, on the back of 2 the second page.
1 3 BY MS. CURRAN:
I 4 Q So does that show you that that procedure must l 5 have been in effect by then? !
6 A It indicates that it's a definite possibility, 7 yes.
8 JUDGE BECHHOEFER: Are you now done with the --
9 MS. CURRAN: Now I'm on 1 R-5.
10 JUDGE BECHHOEFER: Okay. On 1 R-3, let me ask 11 just one question. I was just trying to keep it in the ;
12 order in which the questions are being asked. On 1 R-3,
{
13 there is a -- the item number 8000-C on page 3 of 6.
14 Now, that's the one where there's an NA for new O 15 equipment change.
i 16 [ Pause.)
17 Do you find my reference? ,
18 MR. ORTORE: No. This is not new equipment. ,
19 Perhaps that was inadvertently checked rather than writing i i
20 NA. ;
21 MR. VOSBURG: Well, could it be possible the 22 operator for was changed?
23 JUDGE BECHHOEFER: Well, what I was trying to find 24 out is when you get new equipment, what happens after that, 25 the next time around? Maybe this is not the one to j i
i i
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1893 ,
, 1 follow-up on that.
-\ 2 MR. VOSBURG: Well, this one has the note. It ,
3 says that -- by the journeyman and the foreman that they 4 only found one sticker. So they must have NA'd the second' 5 one, but that's not new equipment.
i 6 JUDGE SHON: I think it's true that are for l 7 8000-A, 8000-B and 8000C, they're all checked.
t
^
8 MR. GIFFIN: It might very well be that we changed 9 the operators at that time. I don't know.
10 JUDGE SHON: It looks to me as if Rex Williams did 11 all three of them, and I don't think I've seen his name on [
12 anything else. It may be that he checked that, thinking ,
13 that instructions, record sticker temperature reading, and 14 he checked it, assuming that the parentheses meant you 15 didn't have to do that for new equipment. ;
16 MR. GIFFIN: That very well may be true.
17 JUDGE SHON: He recorded the sticker temperature 18 reading, and he checked it off. ,
19 MR. ORTORE: Yes, he did.
20 JUDGE SHON: He fixed the stickers below, and he i 21 checked that off.
22 JUDGE BECHHOEFER: Right, but on the next one I ,
23 was referring to there's nothing checked on that, on the NA l 24 one. My follow-up would be, assuming it is a checked NA for 25 new equipment, properly checked, at what point does the ANN RILEY & ASSOCIATES, LTD.
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1894 1 sticker requirement then come into play?
2 When he checks NA for new equipment, does he put a 3 sticker on it at that point, or how does that work?
4 MR. ORTORE: No. I guess if it was new equipment, 5 I would expect that to be checked, and I would expect that 6 there would be no reading, because the sticker --
7 essentially, it was new equipment. So there were no 8 stickers on the item.
9 The fact that we do have information taken 10 explains that notice is not new equipment. This equipment 11 was instal' led. So I think it's just an inadvertent check of 12 the box.
13 JUDGE BECHHOEFER: Right. Well, what I was 14 referring to there is no information there now, 8000-C, and 15 what I was wondering is, in following that up, what happens 16 the next time around where they come to -- is there ever an 17 occasion when they stick a sticker on new equipment, 18 Assuming that one is, 8000-C says "new equipment, and 19 there's no figures listed?
20 MR. GIFFIN: I guess, when you put a new piece of 21 equipment in, if it fell under this program, it should get a 22 sticker prior to operation.
23 JUDGE BECHHOEFER: I see.
24 MR. GIFFIN: The way I look at this, it says, 25 " Record sticker temperature reading," and he put a O ANN RILEY & ASSOCIATES, LTD.
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1895 l 1 check there.
\'- 2 He was going to record the numbers below, and 3 affix the sticker. He checked that, and, if there were no 4 stickers, he'd either mark NA or write down a note or 5 something, and that's -- I think it's -- that's how I read 6 the procedure.
7 JUDGE SHON: I'm sure if I was given a form like 8 that that's the way I'd interpret it, but you're to check 9 this off when you take the reading and check that off when 10 you affix the sticker, and that neither of these things are i
11 applicable for new equipment because there isn't any sticker !
12 there?
13 MR. GIFFIN: That's how I read it as well.
1 14 JUDGE SHON: We've been interpreting it in rather 15 a gifferent way, but I think that's the reasonable way to l 16 read it.
17 JUDGE BECHHOEFER: Okay. You may proceed. Sorry 18 for the interruptions, but these are numbers in such a way 19 that coming back to it might be difficult.
20 MS. CURRAN: All right. I'm ready to go on to l
21 Unit 2?
22 MR. ORTORE: Which outage. j 23 MS. CURRAN: Outage Number 2, November '88.
24 JUDGE BECHHOEFER: Point of inquiry, is anyone 25 going to need a break in the next 40 minutes? We have to
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1896 '
1 quit pretty quickly at 5:00 because of limited appearances.
2 So unless somebody wants us to have a quick break, we'll 3 just go.
4 MS. CURRAN: No, not me. l l
5 JUDGE BECHHOEFER: Okay. l 6 MR. ORTORE: I'm sorry. We're in 1 R-2?
7 MS. CURRAN: Now we're in 2 R-2.
8 MR. ORTORE: 2 R-2.
9 BY MS. CURRAN:
10 Q Okay. If you could turn to FCV 438, which is ;
11 close to the front here, it's about the fourth one.
12 A FCV what? ,
i 13 Q 438.
14 A _Okay.
(~s 15 Q Okay. There's no stickers at all here, right?
16 A Down in " Comments," it says, 17 "No old stickers found. Affixed new ones." ,
P 18 MS. CURRAN: Okay. I don't have any more i 19 questions about this particular outage. So unless you have 20 questions, Judge Bechhoefer, I'll keep going.
21 [ Pause.]
22 JUDGE BECHHOEFER: Are you through with 1 R-3 as 23 well as 2, or are you coming back to 1 R-3?
24 MS. CURRAN: I may come back briefly, but I'm '
25 through walking through it.
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i l
1897 1 JUDGE BECHHOEFER: The 1 R-3?
2 MS. CURRAN: That's right.
3 JUDGE BECHHOEFER: Well, I had a question on, I 4 guess it's -- this may or may not be the only one, but on t
5 the one that's designated FCV 659, page 3 of 6 --
7 JUDGE BECHHOEFER: Oh, sorry. i 8 MR. GIFFIN: They're all 3 of 6.
9 JUDGE BECHHOEFER: They're all 3 of 6.
10 MR. ORTORE: Is this the one with the lower date?
11 The lower signature date is 11/23/89?
12 JUDGE BECHHOEFER: Yes.
13 MR. ORTORE: Okay.
14 JUDGE BECHHOEFER: But the reason I'm asking l O 15 questions I wondered -- both stickers there, apparently, say 16 "Less than 100." Now, is that accurate enough? Is anything i 1
17 under 100 okay for that?
18 MR. ORTORE: Yes. In-containment temperatures are 19 assumed to be 120 unless they are greater. The lowest ;
20 temperature we assume for an in-containment is 120 degrees.
21 So this would be -- even though the stickers have not 22 registered 100, the qualified life would be based on 120 23 degrees if it was inside containment and 104 degrees if it 24 was outside containment.
25 JUDGE BECHHOEFER: So --
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1898 ,
1 MR. ORTORE: Those are the minimum temperatures '
2 that he used.
3 JUDGE BECHHOEFER: So, if it's less than that, it 4 has no effect --
5 MR. ORTORE: Correct. .
6 JUDGE BECHHOEFER: -- in essence. Okay. That's 7 what I wanted to clarify. I think that's sufficient. You .!
8 can proceed. ;
9 [ Pause.]
10 BY MS. CURRAN:
11 Q When I go through the data sheets for 2 R-2, !
12 Mr. Ortore, I can't find quite a few of them, and I'm just i 13 wondering if we could review that. For instance, I can't 14 find general area near K6481, and I can't find general area 15 near K6126. I can't find general area on ceiling. I can't ,
16 find general area cable tray.
17 Why don't I just give you those examples, and if 18 you want me to give you the list again more slowly -- l 19 A (Witness Ortore) I can't answer. Where are these 20 coming from that you're reading from?
21 Q Okay. We were given these data sheets by PG&E, in 22 response to our discovery request, and these were the 23 teletemp data sheets that were done for this refueling 24 outage, and when we each took the procedures and tried to 25 compare the data sheets to the locations on Appendix 8.2, we ANN RILEY & ASSOCIATES, LTD.
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1899 -
1 came up short. ,
2 Well, why don't we just start with this. This 3 isn't the only refueling outage that that happened in, but j 4 at least I'd like to start here and discuss it.
5 A Which outage are you talking about?
6 Q 2 R-2: well, okay.
7 MR. REPKA: Maybe we can ask the witness if the 8 scope of the teletemp stickers expanded subsequent to 9 2 R-2.
10 MR. CIFFIN: Well, there's indication --
11 MR. ORTORE: It may have well.
12 MR. GIFFIN: -- on the procedures. The bar is on 13 the side of the procedures. If there's a bar beside a
?
14 number or beside something, that indicates something was 15 changed in that line in April of 1992.
16 MS. CURRAN: Oh, okay. !
17 MR. GIFFIN: So, depending upon what it is, it's 18 very possible it could get revised. Remember, these are 19 1988 and '89, and the procedure is 1992 and has gone through 20 four revisions. So it's very possible that it got changed.
21 We don't know.
22 MS. CURRAN: Okay. Okay.
23 MS. CURRAN: Okay. All right. I don't have 24 anymore specific questions on 2 R-2 unless the Board does.
25 We'll move on.
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I 1900 e 1 JUDGE BECHHOEFER: I would like to comment that my
(
2 packet here doesn't have 2 R-2 in it. I've borrowed Judge 3 Shon's, but the packet I'm reading from doesn't have 2 R-2. l 4 MS. CURRAN: Okay. We'll get you another copy.
5 JUDGE BECHHOEFER: Okay. I am using one. I don't ;
i 6 think I have any separate questions on it. ;
i 7 BY MS. CURRAN: !
8 Q Almost to the end of this 2 R-3 section you'll 9 find FCV 658, FCV 659, MOV 8112 and 8703. Well, there's 10 more of them. I just want to point out to your attention 11 that these -- these were areas where the temperature 12 couldn't be recorded; isn't that correct?
13 A (Witness Ortore) That's the comment written down j 14 here.
15 Q Okay. i 16 JUDGE BECHHOEFER: Was that with the "No IND on 17 stickers," means? 659 is the only one I've found so far. ,
18 So is 658 also.
19 MS. CURRAN: I don't see "No IND."
20 JUDGE BECHHOEFER: 659 says, "No - " probably IND 21 is indication or something, "on the stickers."
22 MR. ORTORE: Are you in 2 R-2?
23 MS. CURRAN: We're on 2 R-3, right?
24 JUDGE BECHHOEFER: 2 R-3, yeah.
25 MR. GIFFIN: On some of these, the temperature l
O i
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1901 1 that I look at on these teletickers the lowest temple is 100 0 2 degrees. It's possible that it says no temperature recorded ,
3 because it was not in excess of 100 degrees. .Therefore, 4 there was no te'mperature to record. l i
5 BY MS. CURRAN:
6 Q Well, it's possible, but you don't know; is that 7 correct?
8 A (Witness Giffin) Well, if you look at the 9 teletemps, it shows that none of the temperature is 10 blackened in. The blackening in of the temperature is j 11 what -- I don't know what the color is in real life,-but the j i
12 Xerox machine, when you Xerox these, if a temperature has 13 rolled, that temperature is dark, and the one that I just t
14 happened to look at that says, "I cannot record a correct i O 15 temperature," because it looks to me like there's no f 16 carkness in these teletemp stickers. So I would make -- f 17 Q Well, Mr. Giffin, if you want to get into how to -
l 18 read these Xerox copies, I'd be glad to do it with you, but
, 19 I found it impossible to really do it on a consistent basis.
1 4
20 So I'd refer to exclude any testimony about what these 21 Xeroxes show, because I think it's really, really hard to ;
22 read the Xerox? !
23 A All I stated is what I saw on this Xerox machine, i 24 I mean on this Xerox copy, not the Xerox machine.
25 MR. WARNER: I might just point out that I believe !
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I 1902 1 the originals were what was made available on discovery and 2 were reviewed in discovery and then copies were requested.
3 JUDGE BECHHOEFER: So, does this comment, "No IND 4 on stickers," does that just mean that there was nothing on 5 the stickers that could be read or --
6 MR. ORTORE: I guess the IND means no indication 7 on the sticker. So there was no temperature recorded, and 8 we would assume that it didn't reach 100 degrees.
9 JUDGE BECHHOEFER: Right. Okay. Had you covered 10 the FCV 750 yet?
11 MS. CURRAN: FCV 750?
12 MS. CURRAN: I hadn't, no.
13 JUDGE BECHHOEFER: Oh, okay. I just wondered how 14 far you had gone on that group.
15 MS. CURRAN: Well, I didn't -- is there something-16 new there, Judge Bechhoefer, that you wanted to point out?
17 I'm really just raising new problems, not going over the 18 same ground.
19 JUDGE BECHHOEFER: All right. Well, that was one 20 that says "No temperature stickers found on valve," and, 21 again, does that mean stickers couldn't be placed there, or 22 somebody forgot?
23 MR. ORTORE: Well, it could mean that they were l 24 removed during maintenance. It could mean that -- you know, i
25 there might have been painting going on, and they were 1
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b 1903 ,
i 1 removed from painting purposes. It could be operators 2 removed them. There's a number of reasons why they could 3 have been removed. f 4 MR. GIFFIN: I don't think that an operator would i
5 remove one of those stickers. It is possible, however, that 6 the operator on the valve could have been changed. j 7 [ Pause.] !
8 MS. CURRAN: Okay. Hold on one more minute.
9 [ Pause.]
10 BY MS. CURRAN: !
11 Q It we turn to 2 R-5, again, I am having trouble l
12 finding a data sheet for an area called General Area Near 13 FCV 38, GW 115.
14 A (Witness Giffin) What number did you say? I O 15 found one for GW 115 on --
i I
t 16 Q It says, " General Area Near FCV 38."
l 17 A (Witness Ortore) GW 115?
18 Q Yeah. It says "Near FCV 38."
l 19 MR. REPKA: Is there a question about it, or is !
20 the question whether it exists?
21 MS. CURRAN: Yeah.
22 BY MS. CURRAN:
23 Q The question is, can you find it?
24 A (Witness Ortore) Yes. I believe that -- oh it's 25 about, I guess, the third page in on the back. It says, ANN RILEY & ASSOCIATES, LTD.
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i 1904 1 " General Area K 6126," on the procedure that says, "Near FCV O 2 38," and the or one is 1296, which is the following data 1
3 sheet. So those are the two that say "Near FCV 38," for 4 that -- for Unit 2. I 5 Q Okay. Tell me again which one is this. It says 6 " General Area," what K -- .
7 A (Witness Crockett) Back of the third page.
8 Q One, two -- oh, the back of the third --
9 A No. Yeah. Count three pages.
10 Q Yeah. Okay. l 11 A Back side of that third page you'll see K 6126. 3 12 A (Witness Ortore) For the description. And then, ;
13 if you look at the procedure, the item description for Unit 14 2 is can 6126, the fourth line down. !
15 Q Okay. Maybe I'm missing a page here. Are you 16 on --
17 A 2 R-5. !
18 Q 2 R-5?
r 19 A Yes.
20 A (Witness Giffin) Hopefully, we're on the last 21 one, yes.
l 22 A (Witness Crockett) The next page has the other 23 one, 1296, l 24 [ Pause.)
25 Q Okay. All right. That question's been resolved.
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1905 1 Thank you. When you get this data in the refueling outage, 2 do you know whether these data that are -- that are a 3 obtained in each refueling outage are looked at 4 collectively, or is the environmental qualification 5 assessment of qualified life made after each examination 6 individually?
7 A (Witness Ortore) I believe, for each one of 8 these, that temperature would be looked at for that 9 component, and as long as that temperature recorded was 10 under the assumed temperature that the qualified life was 11 made, there would not be any change to the files to the ,
12 calculations.
13 If, for some reason that temperature was higher, l 14 then the analysis would be done. The calculation would be l 15 made, and if it affected the qualified life, then that I 16 information would be transmitted down to the plant, and that 17 would -- that information would be put into the preventative 18 maintenance program, and the proper date, prior to the end 1
19 of that qualified life, would be the dates to schedule the l 20 recurring task to change that component.
21 JUDGE BECHHOEFER: Now, is this procedure followed 22 for the situation I outlined earlier about the time period I 23 guess before the tag system was adopted, between the i 24 commencement of operation and the time when the tag system 25 began to be used? I had understood there was a four- or ANN RILEY & ASSOCIATES, LTD.
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1906 1 five-year gap.
2 MR. ORTORE: No, no. Not at all. These have l
3 been -- we have been recording these since very, very early ,
4 in the operation of the plant. As a matter of fact, this 5 was a plant initiative that we initiated monitoring these 6 temperatures, and it's when we noticed that there were 7 higher temperatures than what we anticipated that an NCR was 8 written, and that is what caused us to get the S&L report.
9 We then brought experts in, but we were monitoring ;
10 these temperatures since very, very early in operation. f 11 There was no extended gap. :
12 JUDGE BECHHOEFER: I see. It didn't initiate 13 following your receipt of the S&L report? j l
14 MR. ORTORE: Excuse me? j
' O 15 JUDGE BECHHOEFER: I say the monitoring did not 16 start up after you got the S&L report -- l 17 MR. ORTORE: No , no.
18 JUDGE BECHHOEFER: -- which is a four- or five-19 year gap, I'd guess.
20 MR. ORTORE: No. It was as a result of our 21 temperature monitoring that we had the S&L report performed.
22 JUDGE BECHHOEFER: I see. Okay.
23 MR. GIFFIN: Because the data sheets that have 24 been put into evidence start with the first set that we 25 have, and I'm not sure about 1 R-1, but these start in 6/88, ANN RILEY & ASSOCIATES, LTD.
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1907 1 which is, for Unit 1, three years after operation. So that 2 means they were put on one and a half years after operations 3 began, because they were reported at the end of the second 4 outage. So they were placed there after 18 months of --
5 less than 18 months of operation.
6 MR. ORTORE: And I believe we initiated an NCR in l 7 1989, and that is when we got Sergeant and Lundy in to help '
8 us and to prepare the report. '
9 JUDGE BECHHOEFER: I see. Thank you.
10 JUDGE KLINE: There seems to be a lot of missing .
11 data. What's the lapact of missing data on the computation i
12 of qualified life? '
13 MR. ORTORE: Missing data in --
14 JUDGE KLINE: Missing data, yeah.
O 15 MR. ORTORE: There may be -- the date of that is l
16 missing is missing in certain points in time, however, 17 monitoring is being done continuous over a long period of 18 time, and therefore we're able to say that, as long as the !
19 plant conditions haven't changed, the temperature remained ,
20 constant during that whole period. l 1
21 MS. CURRAN: I have a follow-up to Judge Kline's 22 question. I just have to find something in here.
23 [ Pause.)
24 FURTHER CROSS EXAMINATION 25 BY MS. CURRAN: I ANN RILEY & ASSOCIATES, LTD. !
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1908 1 Q To follow up on Judge Kline's question, at page 12 2 of the Sergeant and Lundy report, which is Exhibit T-3, at 3 the end of section 6.0 it states that, 4 " Table 2 shows that all affected EQ 5 components have a qualified life of 6 greater than six years."
7 Then it says, 8 "Therefore, no components require _
9 replacement prior to 1 R-4 and 2 R-4,"
10 -- page 12 of section 6.0, well, when I add 6 to 1983, I 11 get 1989, and when I add 6 to 1985, I get 1991. In light of 12 that, do you believe that the gaps in the data could have 13 had any effect on the safety of the plant?
14 A (Witness Ortore) I'm sorry. Where were these 15 dates coming from that you mentioned?
16 Q They're coming from Sergeant and Lundy.
17 A The dates.
18 Q Well, it says here that, 19 "All affected EQ components have a 20 qualified life greater than six years." ,
21 A Correct.
22 Q Well, if six years is your minimum number for how 23 long something has a qualified life, didn't you need to be 24 concerned in 1989 and 1991 as to whether some of these 25 components needed to be replaced?
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1909 1 A Okay. The shortest qualified life for any 2 component in the plant, I believe, is approximately 13 and a 3 half years. What this statement is saying is that at the 4 point that this report was made, looking back six years from l l
5 this report, is when it would have started seeing elevated l I
6 temperatures, and therefore it was safe to say that there 7 would be no concern prior to 1 R-4/2 R-4.
8 However, based on the information that was taken 9 from this report and based on calculations, the actual j l
10 number is 13 and a half years, not six years. This six 11 years was just strictly an estimate at that time just to say 12 that there was no reason to have changed out any equipment 13 prior to this report being issued.
14 JUDGE KLINE: For environmental qualified 15 equipment do you rely solely on a computed life in order to 16 change it out, or is it an objective surveillance or an 17 objective observation you can make on the equipment itself 18 to determine -- I mean, independent of the calculation to 19 determine when it should be changed out?
20 MR. ORTORE: No. It's completely based on the 21 computed life and is changed prior to that qualified life.
22 JUDGE KLINE: Okay.
23 JUDGE SHON: As a result of this surveillance 24 program and your review of the temperatures, it may be a 25 little difficult for you to answer this, but do you have any ANN RILEY & ASSOCIATES, LTD.
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1910 1 idea what fraction of your critical equipment of this sort 2 you've had to change your estimate of qualified life on --
3 chorten it, for example?
4 MR. ORTORE: I think that information is contained 5 here in table 2, but I don't think it was very much .
6 equipment, and, in some cases, the qualified life may have 7 been shortened, but it was still in excess of 40 years. So 8 there would not be an impact to change the equipment out.
9 JUDGE SHON: I see. Even including the data that i
10 you've gathered since that?
11 MR. ORTORE: Correct.
12 JUDGE SHON: Thank you. j 13 [ Pause.] ;
1 14 MS. CURRAN: Mr. Ortore, I just have a follow-up ;
15 question on this. This isn't part of an exhibit, but, in 16 discovery, we obtained a document that is entitled, "The 17 Valuation of Qualified Life of Okanite EPR Insulated Cables l 18 in the GEGW area, Elevation 115 Feet, Located Directly Above 19 the Main Steam Lines," the number is EH02, Reference 21,
- 20. page 1 of 2.
21 It's, apparently, a reference to an improvement 22 qualification file. It says -- the first sense of this 23 thing says, l
24 " Revision 6 of this EQ file determined 25 the qualified life of Okanite EPR ANN R1 LEY & ASSOCIATES, LTD.
Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950
1911 j 1 insulated cable to be in excess of 40 2 years except for those cables located in 3 the GE/GW area at elevation 115 feet ,
4 where the life was determined to be 7.72 5 years due to high ambient temperatures."
6 I'll show it to you if you like. Is your answer still the 7 same, in light of this, that the minimum qualified life is 8 13 and something years? :
9 A This is probably just a reference, and this might ,
10 have been of the case at the time. This is just -- you 11 probably need the entire EQ file to review this. I'm not
- 12 sure why this date is here. No, but that is not -- that is 13 not the official age calculation for that item in the EQ 14 file.
O 15 JUDGE BECHHOEFER: Well, you're saying official 16 age calculation. It seems to be -- I think I've seen that .
i 17 document before. I'm not sure why, but we may have had 18 reference to it in earlier phases of the proceeding, but I 19 was, sort of, wondering about that. It's somebody's 20 calculation.
21 MR. REPKA: Look, the witness is not an EQ ;
22 engineer. He said that repeatedly, and, you know, to 23 question him on the files, which are very complicated, I 24 think is putting him in a very unfair position.
25 I mean, the fact of the matter is we're here to ANN RILEY & ASSOCIATES, LTD.
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i
l l
l 1912 1 talk about the maintenance program, and the maintenance 2 program has been well-described as to what it is. What all 3 the various files say on all the various pieces of equipment 4 is just beyond the scope of his knowledge. He's said that !
5 repeatedly, and it's beyond the scope of the proceeding 6 here.
7 As recently as early this month, when MFP said 8 that they wanted to do discovery on EQ filing, we got into 9 this argument. MFP stated repeatedly that they didn't want 10 to litigate EQ, and I think that's what we're here talking 11 about today is EQ, not maintenance.
12 MS. Ci:LRAN: Well, the distinction that the 13 Mothers for Peace makes is that we are not interested in how 14 a piece of equipment was originally qualified to withstand 15 the accident environment, but it is of concern to us and we 16 think relevant to maintenance as to whether safety equipment 17 that's previously been environmentally qualified is ;
18 maintained in environmentally qualified condition.
19 One of the issues that's relevant to that is how 20 does PG&E determine the changes to qualified life as a 21 result of exposure to normal operating environment?
22 MR. REPKA: There's no evidence offered that it's 23 not. I mean, the witness has stated that the temperatures 24 are monitored. The latest data.is presented to the EQ 25 engineers who calculate a new qualified life. If there's O ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1612 K Street,-N.W., Suite 300 l Washington, D.C. 20006 (202) 293-3950 s
1913 1 any change, it goes on to the task scheduler, and that's how 2 the maintenance of the EQ equipment is performed.
3 How the EQ engineer arrives at the qualified life i
4 and what it is for the hundreds of components in the scope 5 of the EQ program, is simply just well beyond the scope of )
i 6 the contention and well beyond the scope of Mr. Ortore's 7 knowledge.
8 [ Judges confer.]
9 JUDGE BECHHOEFER: We believe that the question 10 may be asked. I guess if the witnesses say they don't know, 11 that, too, is part of the record, but I think the question :
12 is a legitimate one given the scope of the direct testimony.
13 Anyway, the exception is overruled, but if the witness says !
14 he doesn't know, so be it. That's the answer.
O 15 It may be that some witness some day will have to I
l 16 come up and explain, but, as of this date, that's all -- we l l
17 don't want the witnesses to speculate. They should say what j 18 they know or what they have a reasonable basis for saying.
19 You may wish to repeat the question, since I don't remember 20 every word.
21 MS. CURRAN: Oh, okay.
22 JUDGE BECHHOEFER: And I might say we only got 23 five minutes. So we should -- l 1
24 MS. CURRAN: I thought he answered the question. I i
25 JUDGE BECHHOEFER: Oh. It was my understanding )
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1914 1 that there was an objection, and he didn't.
2 MR. REPKA:- Well, let's ask him if he has 3 something to add. If he already answered it, I don't know.
4 MR. ORTORE: Yes. I'd like to just clarify that 1
5 reading on in that paragraph it says -- it says that, i
)
1 6 " Cables located at that area at !
l 7 elevation 115 where the life was 8 determined to be 7.72 years during high 9 ambient temperatures."
10 The next sentence says, 11 " Specific cables located in this hot 12 spot area were not identified at that 13 time,"
14 And I think what that means is that would be the shortest 15 life if that cable was in our worse case location. However, 16 these specific cables are not located in that worse case 17 location, and down at the end of paragraph 3 it says, 18 "Since the maximum ambient temperature 19 directly above the main steam lines is l 20 180 degrees and 160 degrees in Unit 1 21 and 2 respectively, normally de- l
)
22 energized power cables or control 1 23 instrumentation cables located in this ;
24 area have a qualified thermal life of 25 greater than 40 years with margin O ANN RILEY & ASSOCIATES, LTD.
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1915 l 1
1 greater than 10 percent as shown."
2 MS. CURRAN: All right. In the few remaining 3 minutes -- ;
4 MR. REPKA: I think that not only answers the 5 question, but that highlights the danger here and the 6 unfairness of plucking one thing out of a document, that the i 7 witness hadn't seen, is completely out of context. I'd just 8 make that observation. ]
9 JUDGE BECHHOEFER: I might say we're awfully close i 10 to 5 o' clock. So when you get to a convenient breaking 11 point, we ought to quit and come back tomorrow, just because i 12 we have to be back here by 7:00 for limited appearances. l 13 MS. CURRAN: Okay. Let's see, I have one more j 14 exhibit, and I can try to be brief. It's T-5. I am not 15 interested in exactly what happened to this particular 16 component where, apparently, the qualified life was 17 recalculated.
18 I am interested in this in discussing the 19 potential variations in the results of the application of j 20 the Arrenius equation, okay? So if we can just limit 21 ourselves to that.
22 MR. REPKA: Well be I'm going to object to that, 23 again, because I think the Arrenius calculations go to 24 calculating qualified life, and that calculation is pure EQ.
25 MS. CURRAN: Well, can I confirm with Mr. Ortore Os ANN RILEY & ASSOCIATES, LTD.
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1916
> 1 that the Arrenius equation is the equation used for purposes 2 of recalculating qualified life? !
l 3 MR. ORTORE: I believe it is, yes.
4 MS. CURRAN: Okay. This is the formula that is 5 applied, and I would like to ask the witness a few questions 6 about it.
7 MR. REPKA: Well, by definition, that's pure EQ, 8 and that's outside the scope of this Contention.
9 MS. CURRAN: Well, it's the manner in which the 10 new qualified life is established. 5 11 MR. REPKA: Again, that has nothing to do with 12 maintenance. That's an engineering function to establish 13 the qualified life. That's not a maintenance function.
14 MS. CURRAN: Well, it tells the maintenance O 15 program when to replace these components.
i 16 JUDGE SHON: But the maintenance people do not use f 17 the Arrenius equation to that this calculation. Someone 18 else does. 'Isn't that true? !
19 MR. ORTORE: That is correct.
20 MS. CURRAN: Well, whether someone else does or j l
21 not, it's how we get from here to there. It's how we get 22 from a piece of equipment that's allegedly qualified for 40 23 years, it gets exposed to a higher than expected 24 temperature, and then a new calculation takes to be made as 25 to whether it needs to be replaced.
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I 1917 1 Now, in our view, that bears on the adequacy of ,
_O 2 maintenance, whether or not the company has done a good job l
3 of determining when something needs to be replaced. Now, j 4 whether they farm this out to the engineering department or 5 not is not my concern, but I am concerned with the relevance 6 of this to maintenance.
7 MR. REPKA: Of which there is none. EQ is, 8 obviously, a very arcane science that has nothing to do with 9 maintenance, and the maintenance -- or the EQ contention on 10 cables was specifically rejected in this proceeding also.
11 MS. HODGDON: Excuse me. I was just going to join l 12 in an objection to this whole line of questioning. I was 13 just looking at the Board's second hearing conference order 14 where they say, 15 "It is clear that insofar as i l
i 16 environmental qualification is ;
1 17 concerned, this Contention lacks any l 18 basis that would indicate that there is 19 any such problem at Diablo Canyon. This 20 portion of the contention must therefore 21 be dismissed for lack of a viable 22 basis."
I 23 So we've all gone on that, and then, suddenly, we l 24 hear -- we're here litigating EQ. The very limited 25 testimony that'the Licensee put in regarding EQ related to O ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950
1 1918 1 maintaining environmental qualifications, certainly doesn't 2 invite this inquiry.
3 MS. CURRAN: Well, I'd like to respond to that, 4 because I believe our contention that was rejected went to 5 the adequacy of the original environmental qualification for i
6 various -- I believe it was cables whether the assumptions 7 that were originally made in qualifying that cable were 8 correct.
9 MS. HODGDON: But you're mistaken about the --
10 your characterization of that contention. j 11 MS. CURRAN: If I might finish.
12 MS. HODGDON: I'm sorry.
13 MS. CURRAN: What is at issue here is the ,
14 requalification for purposes of maintaining the plant, for :
15 purposes of an adequate maintenance program, and the l 16 Applicant, PG&E itself, says at page 10 of its testimony j i
17 that, 18 " Environmental qualification is one of ;
19 several programs or activities that ;
20 addresses a topic of maintenance in !
21 surveillance of safety-related 22 equipment."
23 MS. HODGDON: That's way outside the scope of the 24 Contention. The Contention -- the Board's analysis says, 25 "To the extent that degradation is -
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1
j 1919 1 subject to maintenance efficacy, the 2 subject will be examined."
3 That's what PG&E's testimony addresses. It does 4 not address EQ, which is, as Mr Repka states, a rather 5 arcane inquiry which has not been admitted here, and there 6 is no reason we should be pursuing this.
7 MR. REPKA: And the direct testimony that states l
8 that maintaining EQ equipment as part of maintenance hardly 9 means that we should sit here and review what appears to be ,
10 an original EQ calculation.
11 JUDGE SHON: Ms. Curran, under any circumstances, -
12 I want appears that the witnesses before us at this time are 13 not the experts on the Arrenius calculation that actually ,
14 do -- that do the magic between temperatures, times and I
15 qualified lifetime.
16 So that they could not reasonably be expected to 17 explain how it's done. Their notion of how it's done might l
18 not even be the correct one.
19 MS. CURRAN: Judge Shon, I understand that, but if .
20 the Board determines that this is relevant to the ;
21 Contention, I think I'm entitled to ask them the questions 22 and get on the record that they don't know the answers, and 23 the record can stand in that way.
24 JUDGE SHON: But they don't have to know the 25 answers. That isn't their job, is it?
O l
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1920 1 MS. CURRAN: Well, in our opinion, the answers are (2) 2 relevant to the Contention. So whatever they are --
i l
)
3 [ Judges confer.] ;
4 JUDGE BECHHOEFER: I guess we'll overrule the 5 objection for now, but just bear in mind that the question !
6 is based -- the Contention is based on maintenance.
7 MS. CURRAN: Okay.
8 JUDGE BECHHOEFER: And also look for a convenient 9 quitting place, because we don't have much time before we 10 get back here for limited appearances.
11 MS. CURRAN: Okay. ;
12 JUDGE BECHHOEFER: We would take it up first thing 13 in the morning if we don't get to it tonight.
14 MS. CURRAN: Well, this is going to take another 15 five or ten minutes. So would you like to go on, or would 16 you prefer to stop?
17 MR. REPKA: That doesn't sound like a limited 18 number of questions to me. ,
19 MS. CURRAN: Well, I don't know, the way we go at 20 things. ;
21 JUDGE BECHHOEFER: Okay. Just a few minutes. ;
22 MS. CURRAN: All right.
23 BY MS. CURRAN:
24 Q All right. This was -- I'm referring to something 25 called Reference 15, which discusses the use of the Arrenius i
i
-s j ANN RILEY & ASSOCIATES, LTD.
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1921 ,
1 O 2 equation to requalify a particular component.
to point to your attention that, I'd just like )
on page 3, the equation is 3
spelled out here using a number of assumptions, and the 4
qualified life comes out to 20.5 years. Then, just below 5 it, it says, 6
"It's highly unlikely and would violate 7 PG&E's - "
8 something that's blanked out here, that 9
" -- the cables are loaded to 100 of rating,"
10 which, apparently was the assumption in the first equation.
11
" Assuming a very conservative 90 percent 12 loading, the I 2-R rise may be 13 calculated,"
14 and then they different equation.
15 They go on to discuss this a little bit further, 16 and the qualified life in the second calculation comes out 17 to 57.8 years, which is almost three times as long as the 18 original calculation.
19 What I'd like to ask you here is that do you agree 20 that the Arrenius equation is rather sensitive to small 21 variations in input of the data?
22 JUDGE BECHHOEFER: Could you define what you mean 23 by "rather sensitive" and "small"?
24 MS. CURRAN: Well, this is the 10 percent 25 difference in what was assumed about the loading of this ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950
_ _ _ _ _ _ _ _ _ _ - - - - - - - - - - ~ ~~
1921 1 equation to requalify a particular component. I'd just like ]
O 2 to point to your attention that, on page 3, the equation is l l
3 spelled out here using a number of assumptions, and the l 4 qualified life comes out to 20.5 years. Then, just below )
it, it says, !
5 6 "It's highly unlikely and would violate 7 PG&E's - "
8 something that's blanked out here, that 9 " -- the cables are loaded to 100 of rating,"
which, apparently was the assumption in the first equation. l 10 11 " Assuming a very conservative 90 percent 12 loading, the I 2-R rise may be 13 calculated,"
14 and then they different equation.
15 They go on to discuss this a little bit further, 16 and the qualified life in the second calculation comes out i
17 to 57.8 years, which is almost three times as long as the ]
i 18 original calculation. l 19 What I'd like to ask you here is that do you_ agree 20 that the Arrenius equation is rather sensitive to small 21 variations in input of the data? !
22 JUDGE BECHHOEFER: Could you define what you mean 23 by "rather sensitive" and "small"?
l 24 MS. CURRAN: Well, this is the 10 percent 1 25 difference in what was assumed about the loading of this O- ANN RILEY & ASSOCIATES, LTD.
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1
1922 1 particular cable, 10 percent difference in the loading of 2 the cable. It was assumed, and correct me if I'm wrong, but 3 I believe it was assumed, in the first instance, that it was 4 100 percent, and it was assumed in the second instance that 5 it was 90 percent, and that changed by almost 40 years, the 6 estimated qualified life of the cable.
7 So I would say that's rather sensitive, and I'd 8 like to see if the witness agrees.
9 MR. REPKA: Is the argument here with the Arrenius 10 equation itself?
11 MS. CURRAN: No.
12 JUDGE SHON: There are two equations at issue 13 here, one of which is Arrenius equations and the other of 14 which is an equation used to calculate the estimated 15 temperature of the cable depending on its I squared R 16 loading. They're two different things. Is that correct? I 17 don't want to testify. ,
i 18 MR. ORTORE: That is correct. You are correct.
19 JUDGE SHON: And what they tried to do is guess 20 that, you know, this cable isn't loaded to 100 percent of ;
1 21 the current that it's going to carry all the time, and all 22 they said is even if it dropped to 90 percent, and it's 23 surely a lot less than that, the expected life would go up 24 very, very much.
25 It would go up to more than double, triple.
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l 1923 ;
i 1 They're simply trying to show that at the cable loading that 2 is really present, the current loading that is really -
1 3 present, the lifetime's a lot longer than was estimated. ,
4 Is this not correct, gentlemen? j 5 MR. ORTORE: Yes. That is correct.
6 JUDGE SHON: Are you trying to suggest that maybe I 7 the cable is really loaded to 150 percent, and therefore it I
8 would be a lot shorter or something?
9 MS. CURRAN: What I'm -- what I'm trying to !
10 suggest is that the principal method by which these 11 qualified lifetimes are evaluated or re-evaluated is an 12 approximation with some variability in it, sensitivity in i
13 the way that it's carried out, because it -- I don't want to 14 testify either.
O 15 JUDGE BECHHOEFER: Are you trying to suggest that l
1 16 the degree of maintenance has an effect on this, then? ,
17 MS. CURRAN: No, the other way around, that the -- ;
P 18 JUDGE BECHHOEFER: Because of their qualification i
19 they need special maintenance procedures or temperature i 20 control procedures?
21 MS. CURRAN: No. l l
22 JUDGE BECHHOEFER: I'm just trying to figure out 23 where you're going.
24 MS. CURRAN: That we start with a piece of 25 equipment that's been qualified by test, and then -- and the 1
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-. _ - a
1924 1 test assumes certain operating conditions, and then the O 2 operating conditions don't wind up conforming to the 3 conditions that were established in the test.
4 So how do you requalify the piece of equipment?
5 Well, PG&E isn't going to take it out of the plant and 6 retest it to see if it works. They use a mathematical ;
7 equation instead, and it adds an element of uncertainty to 8 the newly established qualified life, and that's my 9 testimony, which I am unable to elicit.
10 JUDGE BECHHOEFER: That's what you're trying to 11 prove, in other words.
12 MS. CURRAN: Right. '
13 MR. REPKA: I don't think you're going to get that Y
14 out of the witnesses.
15 MS. CURRAN: And I may try it tomorrow. ;
16 JUDGE SHON: Let's adjourn.
17 JUDGE BECHHOEFER: You haven't gotten it yet, but 18 maybe you could try again.
i 19 MS. CURRAN: Yeah.
20 JUDGE BECHHOEFER: With that, we'll close for the i 21 day except for the limited appearances, and we'll be back, ,
22 hopefully at least, by 7 o' clock right here for limited 23 appearances. Tomorrow we'll resume at 9 o' clock.
24 [Whereupon, at 5:10 p.m., the Public Hearing was !
I 25 recessed.)
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. -- . - _ __________.________o
REPORTER'S CERTIFICATE O
This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission l
In the Matter of: !
NAME OF PROCEEDING: In the Matter of: PACIFIC GAS &
ELECTRIC COMPANY (DIABLO CANYON, j UNITS 1 & 2)
DOCKET NUMBER: 50-275/323-OLA-2 i
()
i PLACE OF PROCEEDING: San Luis Obispo, California v
were held as herein appears, and that this is the >
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
{
i foregoing proceedings.
I P
f S 46' /
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'~ ' ;
i I
Official Reporter Ann Riley & Associates, Ltd.
F
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