ML20056F372
| ML20056F372 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 08/17/1993 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| CON-#393-14279 OLA, OLA-2, NUDOCS 9308270058 | |
| Download: ML20056F372 (200) | |
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ORIGLNAL FFICIAL TRANSCRIPT OF PROCEEDINGS O
1 r
Agency:
NUCLEAR REGULATORY CO31311SSION ATO31IC SAFETY AND LICENSING BOARD
Title:
In the 3Intter of:
PACIFIC GAS AND ELECTRIC CO31APNY (DIABLO CANYON NUCLEAR POWER PLANT Q
UNITS 1 AND 2) i Docket No.
50-275-OLA and 50-323-OLA l
LOCATION:
San Luis Obispo, California DATE:
Tuesday, August 17,1993 PAGES: 569 - 747 O
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UNITED STATES OF AMERICA
)
O 2
NUCLEAR REGULATORY COMMISSION 3
ATOMIC SAFETY AND LICENSING BOARD l
4
- - - - - - - - - - - - - - - - -X f
5 In the Matter of:
6 PACIFIC GAS AND ELECTRIC Docket Nos. 50-275-OLA-2 7
COMPANY 50-323-OLA-2 l
t
(
8 (Diablo Canyon Nuclear 9
Power Plant, Units 1 and 2)
{
10
- - - - - - - - - - - - - - - - -X t
11 San Luis Obispo 12 County Library j
i 13 995 Palm Street 14 San Luis Obispo, CA
{"
15 Tuesday, August 17, 1993 16 The above-entitled matter came on for pre-hearing l
17 conference, pursuant to notice, at 9:35.a.m.
I 1
18 BEFORE:
THE HONORABLE CHARLES BECHHOEFER, CHAIRMAN I
I 19 THE HONORABLE DR. JERRY KLINE, MEMBER l
I i
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 i
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APPEARANCES:
2 3
On behalf of Pacific Gas & Electric:
4 DAVID A.
REPKA, ESQ.
5 Winston & Strawn 6
1400 L Street, N.W.
7 Washington, D.C.
20005-3502 8
i 9
CHRISTOPHER J. WARNER, CHIEF COUNSEL 1
Pacific Gas & Electric 10 l
11 77 Beale Street i
12 San Francisco, California 94106 1
13 l
14 On behalf of the NRC Staff:
1 15 ANN P. HODGDON, STAFF COUNSEL 16 ARLENE A. JORGENSEN, STAFF COUNSEL 17 U.S. Nuclear Regulatory Commission 18 Office of General Counsel 19 Washington, D.C.
20555 20 21 On behalf of San Luis Obispo Mothers for Peace:
22 DIANE CURRAN 23 Harmon, Curran, Gallagher & Spielberg 24 2001 South S Street, N.W.,
Suite 430 25 Washington, D.C.
20009 ANN RILEY & ASSOCIATES, LTD.
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APPEARANCES [ continued]:
O 1
2 JILL ZAMEK 3
P.O.
Box 164 4
Pismo Beach, California 93448 5
6 On behalf of Pacific Gas & Electric Company, Diablo Canyon l
7 Nuclear Power Plant, witness panel:
j 8
BRYANT GIFFEN, MANAGER MAINTENANCE SERVICES 9
WILLIAM CROCKETT, MANAGER TECHNICAL SUPPORT 10 STEVEN ORTORE, DIRECTOR ELECTRICAL MAINTENANCE
)
11 DAVID A. VOSBOURG, DIRECTOR WORK PLANNING 12 13 15 16 l
17 l
18 19 20 j
21 22 23 24 l
25 l
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CONTENTS 2
WITNESS DIRECT CROSS REDIRECT RECROSS t
3 BRYANT GIFFEN, 4
WILLIAM CROCKETT, i
5 STEVEN'ORTORE, f
6 DAVID A. VOSBOURG 7
BY MS. ZAMEK 635 8
BY MR. REPKA 658 t
9 I
t i
10 EXHIBITS j
11 EXHIBIT NO.
IDENTIFIED RECEIVED l
12 1 - 11, 10 A
-589 589 i;
13 6 - 12 601 616 14 14 - 20 674 675 i
15 21 674 752 16 22, 23 676 686 17 24 694 695 18 25 700 725 19 26 700 20 27, 28 726 744 21 22 23 24 i
25 ANN RILEY & ASSOCIATES, LTD.
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PROCEEDINGS-2 3
[9:35 a.m.]
4 JUDGE BECHHOEFER:
Good morning, ladies and 5
gentlemen.
This proceeding involves -- is a so-called 6
recapture proceeding involving the extension of.the 7
operating licenses for the Diablo Canyon Nuclear Power Plant I
I 8
Units 1 and 2 to recover or recapture the period of l
i 9
construction.
This adds about 13 to 15 years to the current I
10 operating licenses of the licensee -- licensee or applicant.
{
11 To begin with, the licensing board with whom you j
12 all are probably reasonably familiar by this time, but on my j
t 13 left is Dr. Jerry Kline, an environmental scientist.
On my l
l 14 right is Frederich $ hon, a nuclear engineer, and my name is 15 Charles Bechhoefer.
I'm an attorney and c.hairman of the I
16 board.
j i
17 For the benefit of the record and for at least one i
18 person who hasn't made an appearance thus far on the record, l
i 19 let's introduce all the parties.
I'll go just from my left f
l 20 to right.
I'll start with Mr. Warner.
l 21 MR. WARNER:
Thank you, Judge Bechhoefer.
I am 1
l 22 Christopher J. Warner, and I am counsel for Pacific Gas and l
23 Electric Company.
i l
24 MR. REPKA:
I am David A. Repka with the law firm I
25 of Winston & Strawn, and I'm counsel for Pacific Gas and
()
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Electric Company.
2 MS. HODGDON:
I'm Ann P. Hodgdon, and I'm NRC 3
staff counsel.
With me at the table is Arlene A. Jorgensen 4
who is also staff counsel, an associate, and behind me we i
5 also have with us today, and I'm going to introduce Melinda 6
Mcdonald, who is a paralegal in our office, and Sheri 7
Peterson, the project manager, and Andrea Wilford, who also 8
works on this project with Sheri.
9 JUDGE BECHHOEFER:
Okay.
Ms. Curran.
i 10 MS. CURRAN:
Good morning.
My name is Diane 11 Curran.
I'm with the law firm of Harmon, Curran, Gallagher 12
& Spielberg.
I represent the San Luis Obispo Mothers for I
13 Peace, and with me today is Jill ZamEk of the Mothers for 14 Peace.
15 JUDGE BECHHOEFER:
For the reporter's benefit, 16 there's a capital "E"
in the middle of that.
Before we get 17 into the prehearing conference aspect of this, from which we 18 will go directly to the evidentiary hearing, I'd like to 19 announce that the -- after many shifting back and forth, 20 limited appearances are going to be held right in this room 21 tomorrow night at 7 o' clock.
We've had a number of 22 difficulties contracting for a larger space.
So we're going i
23 to do it here.
I hope we're not overwhelmed with people, 24 but we will try to keep things orderly anyway, and we will 25 try to hear everybody, but everybody may not be able to be ANN RILEY & ASSOCIATES, LTD.
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in the room at the same time.
Anyway, we will hold it right 2
here.
3 Now, to go into the prehearing conference aspect, 4
I first would like to inquire what has happened to the one 5
document that we asked that the Mothers for Peace be -- be 6
made available to the Mothers for Peace.
7 MS. HODGDON:
I have a copy of-that document as 8
per the Board's instructions.
t l
9 JUDGE BECHHOEFER:
Has that been made available?
]
l l
10 MS. HODGDON:
No, it has not.
It will be made l
l 11 available.
12 JUDGE BECHHOEFER:
I see.
Presumably before we l
13 get to any hearing on the question?
14 MS. HODGDON:
Yes.
l 15 MR. REPKA:
Judge Bechhoefer?
l i
16 JUDGE BECHHOEFER:
Yes.
17 MR. REPKA:
Conversations between myself and l
18 Ms. Curran for the Mothers for Peace yesterday, we 19 understand that the Mothers for Peace have an issue they I
20 would like to raise regarding that matter.
We've requested 21 that we do that in-camera at a side bar with the licensing 22 board, and we would like the opportunity to do that, perhaps 23 at the close of the hearing this afternoon with the Board.
24
[ Judges confer.]
25 JUDGE BECHHOEFER:
Would it be more convenient and ANN RILEY & ASSOCIATES, LTD.
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could enough people who are involved fit into the kitchen 2
back there?
At the end of the prehearing we could do it, 3
too.
4 MR. REPKA:
Whatever is convenient for the Board.
5 I suspect it would be more beneficial, though, to get going 6
with the hearing this morning rather than take t! e time --
7 take the time away.
I think it's best if we did it after 8
the close of business today.
9 JUDGE SHON:
But would it not, perhaps, influence 10 the course of the hearing?
l 11 MR. REPKA:
It will not influence the course of 12 the hearing on contention one, the maintenance contention, 13 and I also don't believe it should influence the course on 14 contention five, but that's a different matter.
I 15 MS. HODGDON:
Yes.
Also, Judge Bechhoefer, that 16 would be agreeable to the staff, because I have only one i
17 copy of the document which was faxed to me yesterday 1
18 afternoon, and I would like to make a copy.
So, if -- the 19 Board didn't say in its order when that copy was to be made 20 available, and therefore this afternoon would be more 21 agreeable, because I'd have a chance to make a copy.
22 JUDGE BECHHOEFER:
Right.
Well, that's okay.
How 23 much time should we figure for this, in terms of when we 24 break the regular hearing?
25 MR. REPKA:
I would suggest 15 or 20 minutes.
l l
j ANN RILEY & ASSOCIATES, LTD.
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MS. HODGDON:
Twenty minutes?
2 JUDGE BECHHOEFER:
Okay.
3 MS. ZAMEK:
Half an hour, I would say.
4 JUDGE BECHHOEFER:
Okay.. We'll probably try to 5
wind the hearing down by around 4:30 and see what happens 6
then, not that we have to quit at 5:00-everybody day, but 7
except for tomorrow we will.
Are there any further 8
preliminary type matters, prehearing conference type matters j
l 9
that the parties wish to raise or still have to resolve?
)
I 10 MR. REPKA:
Yes, Judge Bechhoefer.
You had, in
)
l 11 discussions last week and the weeks prior to this, we've j
-l 12 discussed authentication of documents and possible i
l 13 stipulations.
We have had some conversations with counsel 14 for the NRC staff and counsel for the Mothers for Peace, and O
15 we think we have worked out some procedural agreements as to 16 how to proceed.
1 17 The difficult issue here is that the Mothers for j
18 Peace wish to proceed with a number of documents, 19 nonconformance reports, licensee event reports and the like 20 that relate to isolated, individual incidents allegedly 21 related to the maintenance program.
We nave agreed, "we" 22 being PG&E have agreed to authenticate -- that we will not 23 make authentication of the documents an issue.
24 We've also agreed that the documents can speak for 25 themselves as to the existence of the incidents cited in the O
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documents.
We can stipulate also that the documents, at 2
least the PG&E documents that the Mothers for Peace are 3
relying upon, are true and accurate, at least as of the time j
4 that they were written.
5 So the existence of the events and the 6
authenticity of the documents will not be in dispute.
The i
7 real issue here is the relevance -- the materiality, 8
relevance and admissibility of the documents.
We do not 9
agree that -- at least with respect to many of these 10 documents -- that they are material, relevant, and i
l 11 admissible in this proceeding, that is, they're not 12 sufficiently related to maintenance and surveillance.
l 13 With those agreements and that one fundamental 14 dispute in mind, the issue that developed was how to proceed
\\~
15 on the individual incidents and to try to do it in as 16 efficient a way as possible.
The Mothers for Peace and --
17 would like to introduce these documents into evidence, and 18 since authenticity and accuracy is not an issue, really, as 19 I understand, don't have a lot of cross-examination on these 20 individual incidents.
That's not to say they don't in some 21 cases, but they do not have a lot.
22 We, on the other hand, would like the opportunity 23 in individual cases to ask redirect-type questions, to ask 24 the witnesses to explain the incident to put it into the 25 appropriate context.
Based upon that factual basis, we ANN RILEY & ASSOCIATES, LTD.
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believe we can then discuss with the Board evidentiary 2
objections for each one in turn, and then, based upon the 3
rulings of the Board, we can then proceed with the 4
subsequent incidents that we're relying upon.
f 5
This all requires a slightly different procedure 6
than the normal procedure, but I think it is the most 7
efficient way to proceed on these individual incidents, and 8
it's my hope that we can go through them fairly quickly.
9 MS. CURRAN:
If I might add to what Mr. Repka 10 said, we've made a road map of the 200-odd exhibits that 11 we'd like to put into evidence.
I think it will help 12 everybody to keep track of what they are, and let me just 13 give you all a copy.
As Mr. Repka was saying, the bulk of 14 these exhibits relate to individual instances of maintenance
(
15 problems that Mothers for Peace believe are relevant to the 16 contention.
You'll also notice there's a section in the 17 beginning of this document where a number of NRC and 18 industry documents that discuss the scope of the j
19 maintenance -- what maintenance means and discuss aging 20 concerns.
We've also included those as exhibits, and I'm 21 not sure exactly what order they'll be introduced, but 22 they're numbered here in the beginning of the document, but 23 after that you'll see that each separate document, each 24 licensee event report, each nonconformance report or 25 inspection report or enforcement action is separately
}
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numbered, and they're grouped under categories of what type
~,
2 of incident we're talking about.
3 We ordered them by date.
We took the latest date 4
of the documents that apply to any particular subject and 5
ordered them in that way.
So they start with 1993 and go 6
back in time.
7 MR. REPKA:
We certainly do not object to 8
following a road map.
We think the way to go through this i
9 is incident by incident, but I do have two general 10 objections to the approach.
One is, to the extent this 11 document, which I haven't had a chance to review, 12 characterizes the incident, we don't necessarily agree with 13 the characterization of the documents in here.
So I'm a 14 little -- I'm a little troubled by that, but I think we have O
15 to take that into account.
16 The second thing is I think that --
17 JUDGE BECHHOEFER:
Well, point of inquiry.
I take 18 it this document here is not going to be introduced into 19 evidence.
20 MS. CURRAN:
No.
It's just to help --
21 JUDGE BECHHOEFER:
Right.
22 MS. CURRAN:
-- the Board and the parties.
l 23 JUDGE BECHHOEFER:
Right.
24 MS. CURRAN:
The short summary was not intended to 25 be the last word on what's in it.
We just that it would be ANN RILEY & ASSOCIATES, LTD.
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helpful to just get a brief summary of what the documents
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2 are about.
3 MR. REPKA:
I have no objection to the order and 4
as long as the characterization is clear.
The second point 5
I wanted to make, though, was that for each of these 6
incidents there are often multiple documents of each 7
incident.
For example, one incident may be reported in a 8
nonconformance report, then in a subsequent licensee event 9
report filed with the NRC, then in a supplement -- a 10 subsequent inspection report that the NRC drafts.
11 To that extent, the documentation may be 12 cumulative, and what is really the important point here is 13 the incident itself, did it occur, and, as I said, that is 14 generally not in dispute.
The second point is, is that Cw 15 material and relevant to the contention that has been 16 admitted?
So I think that the cumulative nature of the documentation is something we object to generally.
17 18 Perhaps, as we go through this and go through 19 incident by incident, if there's one document that fairly 20 captures the incident that the Mothers for Peace would like 21 to rely upon, they ought to identify that document.
22 JUDGE BECHHOEFER:
I might add --
23 MS. CURRAN:
I'd just like to respond to that, if 24 I might.
25 JUDGE BECHHOEFER:
Yeah.
Sure.
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1 MS. CURRAN:
That.we did try not to be cumulative O
2 here, and sometimes the same incident is described in l
3 similar words in an LER and an NCR, but those documents have l
l 4
different legal significance.
An NCR is not considered to l
i 5
be worthy of reporting to the NRC, and an LER is, and we 6
felt that it was important.
Often, the LER makes the report I
7 of the factual event to the Nhu, and the NCR contains a more l
8 detailed analysis of what went wrong.
We also felt it was 9
legally significant when the NRC either cited a violation or 10 noted a maintenance problem, and we felt it'was important to
+
11 put those NRC documents in.
i 12 I agree sometimes the facts are stated more than l
l 13 once, but there is an issue of the legal significance of
{
14 those separate documents, and we've tried not to be 15 duplicative.
i 16 JUDGE BECHHOEFER:
Yeah.
I might add that the 17 Board has not seen many of the documents.
We don't have 18 access to NCRs in headquarters, at least, and I personally 19 have seen a few of the LERs, inspection reports, that type l
20 of thing.
The material that's been available on new does l
21 I've seen quite a bit of, but much of it isn't.
l 22 So the parties may have to take a minute or two 23 while we look at some of these things, if there's any 24 dispute as to what their significance is or whether they 25 should be admitted into evidence or not admitted.
So I sort i
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of excuse ourselves, but the way the system is set up, we O
2 don't get those documents.
So I think, as a convenience, l
3 the parties should mark their exhibits with their own party i
4 plus one up, either Applicant or Licensee 1, Staff 1, 2,
3, 5
et cetera, Intervener 1, 2,
3 or MFP 1, but be consistent i
6 the way the documents are marked.
I think that will help.
7 MS. CURRAN:
That was the intent of this so that I
i 8
there are a lot of documents, and we're trying'-- going to f
9 try to keep them well organized, and we will try.
i 10 JUDGE BECHHOEFER:
Okay.
l 11
[ Judges confer.]
I 12 JUDGE BECHHOEFER:
Are the proposed exhibits at 13 this point either bound or assembled, or have you made plans i
14 on how many copies?
O i
i 15 MS. CURRAN:
We have ten copies of each of these t
16 exhibits, and we have them here.
17 JUDGE BECHHOEFER:
Are they bound together or
(
i 18 what?
19 MS. CURRAN:
No, they're not.
l 20 JUDGE BECHHOEFER:
Okay.
Good.
21
[ Judges confer.)
l 22 JUDGE BECHHOEFER:
I think, as just a -- to help 23 keep the records clear, we have a legal assistant, Sherma 24 Donavan who is sitting in the back, and you might at least 25 give her the proposed -- every time you introduce something O
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give her a proposed exhibit number and just a two-word 2
description, if you can, writing it down to help keep track, 3
and then she could write, you know, " proposed," and then, if 4
it gets admitted, she can mark it as admitted.
5 So, then we will have a record prior to the l
6 reported version of what's admitted and what isn't.
l
\\
l 7
Sometimes that's useful during the day particularly.
So l
l 8
Sherma, if you could take that down when they're proposed l
l 9
and when they're admitted or not admitted.
You could write 10 that down, too.
Give Sherma just a brief description.
11 Now, we presume that the parties had in mind 1
l 12 proceeding contention by contention.
Contention 1, first l
13 the Applicant and the staff and any further testimony, and 14 then, after that, Contention 2.
In some cases, parties have 15 preferred to put everything that they have on first, and we i
16 prefer it to be kept by contention.
I hope that doesn't j
17 hurt anybody's scheduling of witnesses.
18 MR. REPKA:
That was our assumption.
That sounds 19 acceptable.
Oh, one other matter.
With respect to the 20 schedule, the NRC staff has asked us and the Mothers for l
21 Peace previously to try to set a date certain for the second 1
22 contention so that witnesses coming from the East Coast can 23 be arranged conveniently and not spend too much time 24 waiting.
25 We have agreed to that.
It's my understanding l
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1 Mothers for Peace have agreed to that also, and we have i
O-2 somewhat arbitrarily selected Friday as the day for 3
contention -- the second contention, and, if that's 4
acceptable to the Board, we'll proceed on that assumption.
5 JUDGE BECHHOEFER:
I would say, if attainable, 6
that's acceptable, but we don't know.
7 MR. REPKA:
Well, the concept, Judge Bechhoefer, 8
is that no matter where we are in contention 1, we'll stop 9
and Friday hear Contention 2 and then go back and finish l
10 whatever we were doing.
11 JUDGE BECHHOEFER:
Oh, okay.
i 12
[ Judges confer.]
13 JUDGE BECHHOEFER:
Well, one thing I wanted to 14 mention is that since we've had to move the limited i
- O 15 appearances back to this room, we have a much smaller 16 capacity.
We might have to consider a future date for more 17 limited appearance, and we were thinking, perhaps, :atin 18 short Saturday morning session could be changed to that.
19 That might affect the people who came on Friday, if they l
20 couldn't get done in a day.
It might mean they'd have to 21 stay through Monday rather than through Saturday.
l 22 MR. REPKA:
We would like to discuss that further i
l 23 at a later date when we know how we're going, but we have 1
24 some hopes that we may be able to complete this entire 25 hearing by Saturday.
So we may need the Saturday session to (b
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finish up the evidentiary hearing, and I would rather not
.j O
2 jeopardize that schedule if at all possible, but I think l
l 3
that we'll be in a better position to know if that's 4
attainable in a day or two.
f 5
JUDGE BECHHOEFER:
By tomorrow night, because we E
6 also don't know how many people will want to make limited 7
appearances.
I think we'll update it at the-end of every 8
day, but the Friday concept sounds fine to us, and we will, 9
if necessary, interrupt Contention 1.
We had thought 10 Contention 1 might take somewhat longer, but Friday is fine.
11 We will save Friday and don't know how long the Contention 5 f
12 will take, but probably a day should be enough for that.
I 13
[ Judges confer.]
14 JUDGE BECHHOEFER:
Okay.
We'll go along with 15 that.
We're not so sure that 200 exhibits or so with
{
16 possible redirect and cross-examination, that type of thing, l
t 17 we're not sure that won't take an awful long time, but we'll 18 see, but we will save Friday for the Contention 5.
[
19
[ Judges confer.]
i 20 JUDGE BECHHOEFER:
Is there anything further that 21 the parties wish to discuss in the prehearing conference 22 phase?
23
[No response.]
24 JUDGE BECHHOEFER:
I guess we're ready to proceed 25 to the evidentiary hearing phase.
Do parties wish to make ANN RILEY & ASSOCIATES, LTD.
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opening statements?
2 MS. CURRAN:
No.
We'd like to go straight to the 3
hearing.
4 KR. REPKA:
In that case, no.
5 MS. HODGDON:
No.
6 JUDGE BECHHOEFER:
I'm just giving you all a l
7 chance.
Mr. Warner or Repka, either one.
8 MR. REPKA:
We'll call our first witness panel on 9
Contention 1, Maintenance and Surveillance.
This is the 10 witness panel that consists of Bryant W. Giffen, William G.
l 11 Crockett, Steven R. Ortore, and David A. Vosbourg.
i 12 JUDGE BECHHOEFER:
I will swear the panel as a 13 panel.
f-14
[ Witness panel sworn.]
15 MR. REPKA:
Gentlemen, beginning on my left with 16 Mr. Vosbourg, could you please state your name for the 17 record?
MR. VOSBOURG:
My name is David A. Vosbourg.
18 MR. REPKA:
And before we go on could you also 19 tell me your affiliation?
20 MR. VOSBOURG:
Yes.
I am the director of the work 21 planning section at the Diablo Canyon Power Plant.
22 MR. CROCKETT:
I'm William G.
Crockett.
I'm the I
23 manager of Technical and Support Services at the plant.
l i
24 MR. GIFFEN:
My name is Bryant W. Giffen.
I'm the 25 manager of Maintenance Services at Diablo Canyon Power l ()
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587 1
Plant.
2 MR. ORTORE:
My name is Steven R. Ortore, and I am 3
the director of Electrical Maintenance at Diablo Canyon 4
Power Plant.
5 MR. REPKA:
Gentlemen, do you have in front of you a
6 a document titled " Testimony of Pacific Gas and Electric l
7 Company" addressing Contention 1, Maintenance and 8
Surveillance?
9 MR. GIFFEN:
Yes.
l 10 MR. CROCKETT:
Yes.
11 MR. ORTORE:
Yes.
12 MR. VOSBOURG:
Yes.
13 MR. REPKA:
Directing your attention to part one
~
14 of that document, did you assist in the preparation of that 15 testimony?
And I'll begin with Mr. Vosbourg.
16 MR. VOSBOURG:
Yes, I did.
17 MR. ORTORE:
Yes, I did.
18 MR. CROCKETT:
Yes, I did 19 MR. GIFFEN:
Yes, I did.
20 MR. REPKA:
Gentlemen, do you have any revisions 21 you would like to make to the pre-filed testimony this 22 morning?
Mr. Vosbourg.
23 MR. VOSBOURG:
Yes.
I have one correction on page j
24 95 of the testimony on line 1.
The last word in the first 25 line says, "Each shift."
It should say "Each day."
That's O
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i 588 1
my only correction.
2 MR. REPKA:
Mr. Giffen.
3 MR. GIFFEN:
Yes, I do.
On page 29 of the l
4 testimony in line 16 where it says "1976," that should be 5
"1978," and on line 19 again the "1976" should be "1978."
6 Those are the only corrections I have.
l 7
MR. REPKA:
Mr. Crockett and Mr. Ortore, do you l
8 have any corrections?
9 MR. CROCKETT:
No.
10 MR. ORTORE:
No corrections.
11 MR. REPKA:
Gentlemen, with those corrections, is 12 this testimony true and correct to the best of your 13 knowledge and belief?
14 MR. VOSBOURG:
Yes, sir.
O 1
l 15 MR. ORTORE:
Yes.
16 MR. CROCKETT:
Yes.
17 MR. GIFFEN:
Yes.
l l
18 MR. REPKA:
And do you adopt this as your t
19 testimony today in this proceeding?
I 20 MR. VOSBOURG:
I do.
21 MR. ORTORE:
Yes.
22 MR. CROCKETT:
Yes.
23 MR. GIFFEN:
Yes.
24 MR. REPKA:
With respect to the exhibits, do you 25 have in front of you a bound book called " Testimony of ANN RILEY & ASSOCIATES, LTD.
w Court Reporters 1612 K Street, N.W.,
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l 589 i
1 Pacific Gas and Electric Company" addressing Contention 1, j
l 2
Maintenance and Surveillance exhibits?
3 MR. GIFFEN:
Yes, we do.
t 4
MR. REPKA:
And at this time this part of the 5
witness panel, Judge Bechhoefer, is sponsoring witnesses --
6 Exhibits 1 through 11, and I would like to offer one 7
additional exhibit, which I'll have marked as Exhibit 10-A 8
at this time that was not available at the time we pre-filed 9
the direct testimony, and I need to get copies of this later i
10 at lunchtime, but I'll ask Mr. Giffen to identify the 11 document.
12 MR. GIFFEN:
This is an index of the list of loop 13 procedures that we use in the instrumentation and control 14 section at Diablo Canyon.
15 MR. REPKA:
And that testimony or that exhibit is 16 offered in connection with a prior Exhibit 10, which is a 17 list of other maintenance and surveillance procedures, is it 18 not?
19 MR. GIFFEN:
Yes, sir.
20 MR. REPKA:
At this time, therefore, I would like 21 to ask the Board to move into evidence or accept into 22 evidence the testimony of Bryant W.
Giffen, William G.
23 Crockett, Steven R. Ortore, David A. Vosbourg and the 24 related Exhibits 1 through 11 including the Exhibit 10-A.
25 JUDGE BECHHOEFER:
Any objections?
l l
l ANN RILEY & ASSOCIATES, LTD.
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MS. CURRAN:
No.
I 2
MS. HODGDON:
No 3
MS. CURRAN:
But we wish an opportunity to 4
cross-examine them.
5 JUDGE BECHHOEFER:
Of course.
Of course.
Do you 6
have any objection?
7 MS. HODGDON:
No objection.
8 JUDGE BECHHOEFER:
Okay.
Those documents will be i
i 9
admitted into evidence.
Off the record for a moment.
l 10
[Off the record.]
11 JUDGE BECHHOEFER:
We have decided not to bind 12 this testimony into the record but to have it accompany the 13 record because of its thickness and the difficulties of i
14 binding a document like this into the record.
So this will 15 accompany the record along with its attached exhibits.
So 16 you may proceed.
17 MR. REPKA:
With that, the panel is available for 18 cross-examination.
19
[ Recess taken from 10:10 a.m. to 10:30 a.m.]
i 20 JUDGE BECHHOEFER:
Back on the record.
21 Ms. Curran.
I 22 MS. CURRAN:
I'm ready.
Good morning, gentlemen.
23 MR. GIFFEN:
Good morning.
24 MR. CROCKETT:
Good morning.
l 25 MR. ORTORE:
Good morning.
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MR. VOSBOURG:
Good morning.
2 MS. CURRAN:
Since there are no many of you there, 3
I'd like to ask that if I direct a question to an 4
individual, that individual answer my question without I
5 consulting with other members of the panel.
If there's 6
another member of the panel that has something that he 7
wishes to add to the response, that's fine, but I'd 8
appreciate the person I direct the question to answering 9
first and then each of you answering individually.
All l
l 10 right?
11 Mr. Giffen, at page 41 of your testimony you 12 describe the importance of preventative maintenance in a 13 maintenance program for nuclear power plants; is that 14 correct?
MR. GIFFEN:
Whereabouts O
15 are you reading?
It'll make it quicker.
l 16 MS. CURRAN:
At the top of the page where it 17
- states, "Within the nuclear industry, a high 18 ratio of preventative maintenance, j
19 including surveillance to total 20 maintenance is indicative of an 21 efficiently managed maintenance program, l
22 which is effective in maintainlag a 23 plant in a safe and reliable condition."
24 25 MR. GIFFEN:
Yes, ma'am.
I 1
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MS. CURRAN:
Is that correct?
2 MR. GIFFEN:
Yes, ma'am.
3 MS. CURRAN:
And you also state.that your goal at 4
Diablo Canyon Nuclear Power Plant is to maintain a 5
percentage of preventative maintenance tasks above a level
[
6 of 60 percent of all maintenance tasks; is that right?
7 MR. GIFFEN:
That's correct.
l 8
MS. CURRAN:
Can you tell me what record you have
[
9 had from 1990 to 1993 for each year, in terms of the 10 percentage of preventative maintenance that you were able to 11 achieve?
12 MR. GIFFEN:
Yes, I can.
What we tracked this l
13 performance indicator for is based -- it's just a reference.
14 It's not a hard, fast indicator of whether you're good or O
t 15 bad.
It just tells you -- It's an indication of how your --
16 how your program is working.
INPO used to monitor this i
17 years ago, and they stopped because it was too subjective 18 from different utilities.
So it was hard to put a bound on.
19 20 So we've started -- we continued monitoring after 21 INPO stopped, and our records since 1990 has been above 60 22 percent.
The ratio of preventative maintenance to total 23 maintenance and surveillance has been above 60 percent for 24 our power plants.
25 MS. CURRAN:
So you add up all the maintenance ANN RILEY & ASSOCIATES, LTD.
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i 1
tasks that have been carried out at Diablo Canyon over a 2
year, and then you take the percentage of those that involve i
3 acts of preventative maintenance --
4 MR. GIFFEN:
Well, we --
5 MS. CURRAN:
Is that - -
6 MR. GIFFEN:
Go ahead.
I'm sorry.
7 MS. CURRAN:
I'm sorry.
Is that how you do it?
I 8
MR. GIFFEN:
Well, we don't do it for a yearly 9
basis.
We do it monthly.
We look at this indicator on a 10 monthly basis, and then -- so that we can see where we are 11 and report it quarterly.
12 MS. CURRAN:
And you add up all the tasks, all the 13 maintenance tasks that have been performed in that quarter, 14 and you find the percentage of those tasks that constituted l
15 preventative maintenance?
16 MR. GIFFEN:
Yes, ma'am.
17 MS. CURRAN:
So this means that for approximately i
18 30 percent of the maintenance tasks that were performed at 19 Diablo Canyon, they were not preventative maintenance tasks.
20 They were corrective maintenance tasks?
21 MR. GIFFEN:
Yeah.
That says that -- well, it's 22 whatever the numbers are.
A certain percentage of those 23 tasks that we perform at the plant on any given day or any 24 given period are, in fact, corrective maintenance.
Things 25 break, and they're fixed; and the ratio shows that it might O
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be nice not to have any corrective maintenance tasks.
Then
-Os i
1 2
everything would be preventative, but it shows that there l
3 are some things that have no significance, and, if they i
4 fail, you just repair them.
5 other things will just break, and they're caught i
i i
6 in the normal preventative maintenance program.
It shows I
l 7
that something is broken, and we fix it.
So you're going to 8
have corrective maintenance.
Things are going to break, and 9
you're going to have to fix it, and so we look for --
i l
10 MS. CURRAN:
Just to clarify, for approximately 30 l
11 percent, and it might vary from year to year, of the 12 equipment in the plant, you don't know that there's l
13 something wrong with it until it breaks?
14 MR. REPKA:
I object.
I don't think that's a fair 15 characterization of the testimony at all.
16 MS. CURRAN:
I'm asking Mr. Giffen to tell me 17 whether that's a correct statement.
18 MR. GIFFEN:
Could you repeat the question?
Would 19 you please repeat the question?
20 MS. CURRAN:
Is it true that for 30 percent, l
21 approximately 30 percent, of the equipment at the Diablo l
22 Canyon Nuclear Power Plant, that you don't know if there's 23 something wrong with it until it breaks?
24 MR. GIFFEN:
No.
I don't believe that's true.
I 25 don't think that that -- the ratio is not an indication of l
l ANN RILEY & ASSOCIATES, LTD.
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what I don't know that's broken.
It's an indicator that we O
2 monitor the effectiveness of our program.
It's just one key l
3 point, and just because a number -- you can't take this 4
number and say it means that 30 percent is broken.
That's 5
not true.
6 MS. CURRAN:
So, can you say that you can't take 7
this number and say that 60 percent of the tasks are 8
accomplished through preventative maintenance either?
l l
9 You're saying the n"mber is a little unreliable, or what are 10 you saying?
11 MR. GIFFEN:
Well, the question, I believe, that 1
12 you asked me was that at any given time I can't determine
)
i l
13 whether 30 percent of the equipment is broken, and that's
]
l 14 not true.
The numbers say that I do a certain amount of j
j O l
15 preventative maintenance.
I do a certain amount of l
r t
16 corrective maintenance, and I do a certain number of l
P 17 surveillances each year, and a certain percentage of those 18 will be corrective.
I 19 Based upon our performance for the last few years, l
20 we continue to monitor this, because the number of 21 corrective maintenance items continues to go down each year, 22 and the performance is still maintaining high.
So you can't 23 really -- you can't say what you were trying to say, I'm 24 afraid, in my opinion.
25 JUDGE SHON:
Mr. Giffen, this is strictly a matter ANN RILEY & ASSOCIATES, LTD.
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of number of tasks.
It has nothing to do with person hours l
fg i
2 expended or anything like that or number of pieces of 3
eqpipment.
4 MR. GIFFEN:
Oh, no.
Sheer numbers.
If I worked 5
the same preventative maintenance tasks on, like, ten on one 6
piece of equipment, that would equal ten.
So it's just 7
numbers.
It's not equipment.
8 JUDGE SHON:
Mr. Giffen, one more question.
If 9
you go out to fix something that's gone wrong, you fix it, I
I 10 and you fix it so that it's somewhat better than it was 11 before, then which is that?
Is that preventative, or is i
l 12 that corrective?
I 13 MR. GIFFEN:
It depends.
It could be -- it could 14 be either.
If, in a performance of a -- a preventative task
]
15 is you go out, and it's like changing the oil in your car is 16 a preventative task.
Corrective could be to fix the oil 17 pump.
If you go out and find something that's abnormal when 18 you're performing a preventative task, then you fix it, that 19 would be both preventative task and a corrective task.
20 JUDGE BECHHOEFER:
So does that count as two 21 tasks, then?
22 MR. GIFFEN:
Yes, sir.
23 JUDGE BECHHOEFER:
I see.
Okay.
Sorry for the l
24 interruption.
I 25 JUDGE SHON:
Excuse us.
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597 1
JUDGE BECHHOEFER:
Every now and then we do that.
2 MS. CURRAN:
All right.
I'd like to go on to the 3
issues for which we have presented exhibits.
At page 4 of 4
PG&E's testimony, at the top it is stated, 5
" contrary to MFP's claims, PG&E has 6
implemented its maintenance and j
i 7
surveillance programs in an effective 8
and often outstanding manner."
l l
9 The purpose of these exhibits that will now be introduced 10 and moved into evidence is to demonstrate that, in fact, 11 PG&E has had a significant number of maintenance and 12 surveillance problems over the last several years, that 13 these problems often present significant safety issues and i
14 that many of them are repetitive and represent occurrences 15 that could have been corrected earlier.
16 MR. REPKA:
I object, one, to that 17 characterization, and, number two, I object to the entire i
18 line of questioning.
The fact of the matter is the 19 contention at issue here is whether or not PG&E has a 20 comprehensive maintenance program that it has implemented 21 adequately.
The fact of the matter is there is 22 uncontroverted evidence in the direct testimony that PG&E l
23 does have a comprehensive maintenance program.
j i
24 With respect to the implementation of that 25 program, PG&E has also presented uncontroverted evidence ANN RILEY & ASSOCIATES, LTD.
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that that program has been implemented properly, evidence 2
that's been presented by this panel or will be presented by l
3 other panels.
The big picture programmatic indicators of l
4 the maintenance of that plant are very, very positive.
What i
5 Ms. Curran would like us to do here is focus on the minutia, 6
on the individual incidents that have been documented as 7
part of a normal and expected process for tracking 8
nonconformances documented in NCR and LERs.
9 There's a long line of Commission precedent in the 10 context of construction quality contentions that it is not 11 the focus of the Commission and a licensing board to look at 12 individual minor deficiencies.
The issue here is the 13 programmatic indicators, and all of these incidents that are 14 alleged to be problems, many of which are not, don't add up O
I 15 and do not suggest anything about the programmatic 16 conclusion.
Just a few of the cases 17 the Commission has stated it's standard here are the Long 18 Island Lighting Company case involving the Sherchen Nuclear 19 Plant, 18 NRC 445 at 579, the licensing board stated that, 20 "The Board is not about to engage in a 21 numbers game."
i l
22 And that's precisely what the Mothers for Peace would have 23 us do here.
That decision was affirmed by the appeal board 24 in ALAB 788, 20 NRC 1102 at 1142.
25 Similar precedent exists in the Union Electric ANN RILEY & ASSOCIATES, LTD.
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1 case involving the Calloway. Nuclear Power Plant, ALAB 740 at 2
18 NRC 343, and also, with respect to the Diablo Canyon 3
Plant, Pacific Gas and Electric Company, ALAB 756, 18 NRC 4
1340.
The fact of the matter is the issue here is the 5
program and whether or not PG&E has an adequate program and 6
has implemented that program.
l l
7 A numbers game of 10, 15, 100 incidents that are
{
l 8
normal, minor deviations from procedures simply do not l
l 9
suggest a programmatic problem, and therefore we object, A,
{
10 to the characterization, and, B,
to the whole line of o
i 11 questioning.
)
12
[ Judges confer.)
13 JUDGE BECHHOEFER:
I believe there's two matters l
l 14 about this objection.
The first is we, essentially, 15 rejected it when we let the contention in, but, second, 16 these are matters for the Board to decide, whether something 17 is minor or major.
This we'll decide on when we hear the 18 evidence.
So we overrule that objection.
19 MR. REPKA:
Judge Bechhoefer, just a point of 20 clarification.
Although you've overruled the general 21 objection, I still maintain that in many of these incidents I
22 which we're about to discuss, based on the facts of those I
23 specific incidents, the characterization, the global 24 characterization of the Mothers for Peace, is still simply 25 not warranted here based on the facts, and I think that the O
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discussions that will follow these documents will prove that 2
many simply are irrelevant to the point, even if we set l
l 3
aside the fact that out of 100,000 maintenance activities at 4
the power plant in a given year, the fact that 30 or 40 or 5
50 doesn't mean anything, it we set that aside, the fact is 6
that many of these simply do not fall within the scope of r
7 the assertion here.
8 So I continue to maintain that in individual 9
incidents the characterization is incorrect.
10 JUDGE BECHHOEFER:
Right.
We're going to decide 11 tliose matters as we get to them.
We're going to permit the i
12 line of questioning to be pursued, and we're certainly going 13 to permit you to object, snd wc'll listen to every one of f
O.-
14 them.
1 15 MR. REPKA:
Thank you.
16 MS. CURRAN:
At this time we'd like to provide the l
17 Board and the parties with copies of Exhibits 6, 7,
8, 9,
18 10, 11, 12, and 13, whidi all relate to deficiencies in j
19 check valve testing at Diaolo Canyon Nuclear Power Plant.
I 20 would just point out to the Board, for housekeeping 21 purposes, we will be, in this part of the testimony, moving 22 all of these exhibits, except for Number 12, into evidence.
23 Number 12 is an NRC document, and what we'd like to do is 24 just submit this exhibit for identification purposes at this 25 point and then move it into evidence when the NA' staff ANN RILEY & ASSOCIATES, LTD.
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panel goes on, and we can, if we need to, question the 2
witnesses about it at that point.
We would move these 3
exhibits -- I'm sorry.
4
[ Pause.
Exhibits being marked for 5
identification.]
6 JUDGE BECHHOEFER:
Exhibic-S through 12 are now 7
marked for identification.
8 MS. CURRAN:
I think we had agreed that Mr. Repka 9
would have an opportunity to question the witnesses, and 10 then we would move the documents into evidence.
11 MR. REPKA:
That's right.
12 JUDGE BECHHOEFER:
I'm sorry.
13.
13 MR. REPKA:
Is the Board prepared?
Ready?
14 JUDGE BECHHOEFER:
Yes.
I just wanted to correct.
15 I said 6 through 12.
It should be 6 through 13.
16 MR. REPKA:
Let me ask the witness panel, have you 17 had an opportunity to look at these documents that have been 18 marked for identification at this point?
19 MR. GIFFEN:
We've looked at them.
I don't think 20 that we said that we looked at them in detail yet.
I 21 MR. REPKA:
Are you prepared to talk about them?
22 MR. GIFFEN:
Yes.
23 MR. REPKA:
Mr. Crockett, would you care to 24 provide a brief discussion of check valve issues that are 25 suggested in these documents?
f_
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602 l
1 MR. CROCKETT:
Yes, I would.
Just to go back in l
2 history a little bit and what the requirements are, the ASME 3
code, it is a code that deals with valves and pumps and l
4 lines for Class 1, 2,
and 3 equipment.
And the Code for 5
many years had a requirement to test valves that had a j
6 safety function.
Specifically the Code said that if a valve j
7 was normally closed that the only requirement you had to do l
l 8
was stroke the valve in the open position.
9 So it was specifically written in the Code that i
10 you did not have to check a valve's leak tightness if it's 11 normal position was closed.
So the industry, along with us, l
12 wrote our IST programs based on that specific requirement.
i 13 In about the 1988 time frame, the NRC, after doing some j
14 specific inspections at three plants, noticed that there was O
15 a hole in the program, that there are some safety function 16 valves that should be, even though normally closed, that 17 should be tested in that closed position.
So they issued an i
18 information notice to warn plants about this potential i
t 19 problem.
20
-Shortly after that -- also, to keep in i
21 perspective, in 1988, the NRC issued us an SER, and that SER l
22 was a review of our IST program and fully approved and j
23 accepted all the specifics of our IST program.
There was j
24 some negotiations on waivers, but, in 1988, they looked at 25 our program and said it was a good program.
i ANN RILEY & ASSOCIATES, LTD.
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A few months later, in 1989, the NRC issued a 2
generic letter, and, in that generic letter --- it was also a i
3 follow-up to that 1988 information notice.
In that generic t
4 letter, they provided the industry with more specific 5
requirements on testing these types of valves, criteria,
[
l 6
what are alternate methods of testing the valves.
And there
{
7 was two tables in that bulletin.
l 8
One table was all the plants that the NRC knew 9
about that would have potential problems in this area, and f
10 the second table was a list of plants that they felt that
(
11 their IST programs were adequate and did not require a 12 follow-up, and we were in that second table.
NRC at that 13 time thought that we were -- we had met all the 14 requirements, but even so, as a response to that, we decided l
O l
15 to do a review anyway, and we had a review ongoing because l
l 16 of the 1988 information letter.
17 At that time, now that this issue is being i
18 elevated -- it's a generic problem.
The whole industry is l
19 coming up to speed on this issue -- we identified some 20 valves that weren't being tested, some check valves that 21 were not being tested in their closed positica, and we added
- i 22 it to the program we wrote in NCR.
Since then, we have l
23 found some new valves.
24 Sometimes we found the valves through Westinghouse 25 letters, and they are some valves that are peculiar.
They ANN RILEY & ASSOCIATES, LTD.
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aren't obvious that they have a safety function.
Things f
O 2
have to fail in order for that function to exist, and I can i
i 3
give you an example.
In one case,.there's a check valve 1
4 8440.
I don't know which exact document that is, but it's l
5 in a VCT.
6 MR. REPKA:
A VCT?
7 MR. CROCKETT:
Volume control tank.
Again, these 8
later check valves after this 8904 issue became apparent, j
9 the valves in question were more in post-LOCA recirculation.
]
10 VCT isolates during a safety injection, and later on in the
{
I f
i 11 post-LOCA phase of an accident you realign your RHR i
l 12 system.
RHR system is a system -- are you familiar with an l
13 RHR system?
MR. REPKA:
Yes.
i l
14 MR. CROCKETT:
Okay.
You realign the RHR system i
l 15 to supply water to the charging pumps, and the VCT is not i
16 part of that ECC function and is isolated by some motor
?
l I
17 operated valves.
Well, the engineer who caught this looked 18 at it pretty closely and said, "Well, let's see, the RHR is 19 taking suction from the containment recirc sump," and l
20 containment would have to be at an elevated pressuie, which 21 would force the suction pressure of the RHR pump to be 22 elevated, and then, therefore, there are some relief valves 23
'on the discharge of the RHR.
24 Those relief valves would have to -- would have to 25 lift -- let me get my facts straight again here.
If you've ANN RILEY & ASSOCIATES, LTD.
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got -- in fact, it might be better if you look at -- I'm 2
just trying to put this in perspective.
If you look at LER 3
9201, Exhibit 13.
There's a drawing on the last page, and I 4
want to clarify my facts here.
I was talking about the 5
wrong relief valves.
6 If lieu at the bottom of the page, you'll see RHR j
7 pumps during the ECCS recirculation to the centrifical l
8 charging pump suction.
That's a function of the -- to 9
supply now.
Instead of getting water from the RWST, it's j
I l
10 getting water from the RHR.
The check valve in question is 11 8440.
Okay.
Originally, when it was looked at, our IST 12 program, the original engineers thought that those LCV 112B 13 and 112C would isolate the VCT.
They'd automatically go 14 close and isolates the.VCT from the ECCS.
l 15 So we thought the VCT is isolated, but there is a j
16 path, if 8440 leaks in the closed position, it now has a I
17 safety function, because there is a pathway through the seal i
l 18 water heat exchanger up through a relief valve, 8123, and, l
I 19 in 8123 lifts at 150 pounds pressure, it'll go back to the 20 VCT.
So there is a sneak path back to the VCT.
I don't 21 want to say sneak path, but there is a' potential path back 22 to the VCT.
23 For that to lift, you have to have an elevated 24 temperature -- or elevated pressure in containment for a 25 long period of time.
The estimated leak rate of back O
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leakage of 8440, it has to go for, like, 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br />, when we
(
2 looked at our safety analysis.
Twenty-five hours to fill, 1
3 and this relief valve either stuck open or staying open 4
because of high pressure to fill the free volume in the VCT.
5 i
6 So 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br />.
Now, keep in mind that you're in 7
post-LOCA recirculation.
You're going through a cool-down 8
for 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br />, and it is thought that the containment will be i
9 depressurized, and the RCS will cooled down long before that 10 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br />.
One more added piece of information is that the 11 relief valve on a VCT, that does relief back to the liquid 12 holding tanks, but because the piping is non-seismic piping, 13 it's not required to be, no credit was taken for that relief 14 valve to divert that water back to the VCT.
l 15 So, in other words, it wasn't an obvious thing.
l l
16 Containment pressure would have to be elevated for an 17 unusual amount of time, and then you have to have back 18 leakage on that valve.
So it wasn't an obvious thing, and I 19 think it was a credit to the engineer who actually 20 identified that, and we added it to our program.
21 Another -- just one more example, just again to 22 put it in perspective.
There's one where we had discharge 23 check valves on safety injection.
This is Exhibit Number 6.
24 Just recently we found this one, and, again, it was one of 25 our engineers looking much closer after more training on the l
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8904 issue.
He notices that -- or he questions one of the O
2 accepted methods that we're using to test the tightness on a 3
discharged safety injection check valve.
4 The purpose of that check valve is when one pump 5
is shut down, the other pump won't go reverse flow back into 6
that other pump.
So it won't bypass flow during a ESF 7
actuation into the core.
So that check valve is to prevent 8
backflow through the other pump.
The method that we are 9
using and was the acceptable method at the time was that, 10 when we perform our surveillance test on that pump, that we 11 look at the other pump and make sure there's no backflow 12 rotation.
13 In other words, you run the parallel pump.
You 14 look at the other pump, and you make sure that there's no
(
15
_ reverse leakage, and that was an acceptable thing.
- Well, 16 the engineer who was reviewing that, he questioned about 17 whether that was adequate or not, and he called the vendor 18 of the pump, and he said, "Does that method totally prove 19 that that valve is seated?"
And the vendor said -- it's a 20 multi-stage pump.
The vendor said that, "No, you can't.
21 Just because it's not spinning backwards doesn't mean there l
22 isn't some leakage going through.
You could have some 23 reverse flow leakage, and the pump would never spin 24 backwards."
25 JUDGE SHON:
You just check for leakage by looking ANN RILEY & ASSOCIATES, LTD.
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at the rotation of the pump, in other words?
2 MR. CROCKETT:
That's right.
3 JUDGE SHON:
Now, if there's no rotation --
4 MR. CROCKETT:
If there's no rotation, then 5
there's no flow back.
6 JUDGE SHON:
No flow meter or anything like that.
7 MR. CROCKETT:
Yeah.
And that was an acceptable 8
method by the industry to check those valves.
We check --
9 we call other plants.
They're doing it the same way.
10 JUDGE SHON:
But it turns out you don't 11 necessarily --
12 MR. CROCKETT:
It turns out that you can't 13 necessarily prove it.
So immediately, right after we 14 discovered that, we got that word back from the vendor, ve 15 went out and tested the valves, and the valves tested set.
l 16 There was nothing wrong.
In every one of these cases, when 17 we went back and added it to the program and tested the leak 18 tightness of the valves, the valves were tight.
It was 19 never a problem that the valves were indeed leaking.
20 MR. REPKA:
You stated that they tested sat, and 21 by that you mean satisfactory?
22 MR. CROCKETT:
Satisfactory and that they did not.
23 24 MR. REPKA:
Let ne try to focus this a little bit.
25 Among all the exhibits that you've been handed, and I'll ANN RILEY & ASSOCIATES, LTD.
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refer to just the NCRs and LERs, are all of these related to O
l 2
the generic issue you described, the one as to looking for 3
more valves thtt maybe should be tested in a certain way in 4
accordance to the way you describe?
Are they all part of 5
the generic industry issre?
6 MR. CROCKETT:
These particular ones?
Yes.
Oh, l
7 wait a minute.
Is it '84 -- there's one back in 1984 before 8
we went commercial.
I'm not familiar Uith that one t'
9 specifically, but that is prior to this whole issue, this 10 generic issue coming up today.
So I'm not -- I'm not 11 exactly knowledgeable about that, but that was 1984 before 12 we went commercial.
13 MR. REPKA:
Do any of these NCRs and LERs suggest l
14 to you a problem in the surveillance -- maintenance and j
15 surveillance program?
16 MR. CROCKETT:
Nc.
I'd'say, if anything, it shows 17 a strength that we go beyond.
We use industry information.
18 We have some of them, but we've -- get information from 19 nuclear network, from INPO.
I mean, people across the 20 industry talk.
We've given our engineers some training to 21 raise their sensitivity to it, and they found -- and found 22 these problems.
So I'd say just the opposite.
I think our 23 program has some strength.
24 MR. GIFFEN:
One thing that Bill didn't say, that 25 Mr. Crockett doesn't say, these are cases of things that we ANN RILEY & ASSOCIATES, LTD.
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1 found, our own engineers found ourself.
So these were all j
O 2
self-identified.
3 MS. CURRAN:
I'd like to do some --
4 MR. REPKA:
Just a second.
5 MS. CURRAN:
I'm sorry.
I thought you were done.
6 MR. REPKA:
I'm not quite finished.
Let me call 7
your attention to Exhibit 6, which is an NCR, and Exhibit 7, 8
which~is a Licensee Event Report.
Could you tell me if, in 9
fact, those two documents report the same issue?
10 MR. CROCKETT:
I'm sorry.
Would you repeat that?
I 11 MR. REPKA:
Exhibit 6 and Exhibit 7.
One is an 12 NCR, and ona is an LER.
Do they report the same incident or i
13 issue?
MR. CROCKETT:
Yes.
Yes, that's right.
l i
14 MR. REPKA:
Is that a normal part of the process, I
O 15 processes established at Diablo Canyon to have two similar l
16 documents addressing the same issue?
i i
17 MR. CROCKETT:
Yeah.
That's true.
When we find a 18 potential nonconformance, we write a nonconformance, and it i
19 has special function in that it allows for a group of 20 experts to get together and review the information and make 21 determinations about operability, reportability, corrective 22 action, root cause, and then, as a result, if the -- if the 23 event is indeed reportable, then a License Event Report is 24 issued.
So they are two different -- one is an official 25 document to the NRC.
The other one is kind of an -- is an ANN RILEY & ASSOCIATES, LTD.
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in-house document that tracks the meeting minutes, all the 2
issues related to that technical review group meeting.
r 3
I wanted to say one other thing you asked me t
4 about.
There is one exhibit, Number 9.
This one is not
[
5 quite the same.
Although it involves the same issue, there 6
is -- this similar issue, it deals with a commitment letter, l
t 7
CMD, that was overlooked.
It was an error.
They forgot to f
8 add it to the program.
So it was a --
9 MR. REPKA:
A CMD?
f 10 MR. CROCKETT:
Commitment Management Database.
It 11 is a database at the plant that identifies and keeps track i
12 of all of our commitments, and an error was made in not --
i 13 not putting that commitment into the program.
l 14 MR. REPKA:
And the commitment was to do a certain 15 full flow stroke of the check valve.
i 16 MR. CROCKETT:
I'd have to see whether it was a I
i 17 full flow test or a closed, but it was a commitment either 18 full flow or tested in the closed position.
l 19 MR. REPKA:
Okay.
I think that's sufficient.
Let t
20 me focus your attention for a second on Exhibit 8, which is 21 an NCR, and particularly page 4 of 9.
Are you with me?
22 MR. CROCKETT:
Hold on for a second, please.
23 Okay.
24 MR. REPKA:
Now, in this case, was there a failure 25 to perform -- was there a failure to meet ASME section 11 O-ANN RILEY & ASSOCIATES, LTD.
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requirements?
2 MR. CROCKETT:
No, there was not.
It says the 3
evaluation showed that surveillances to perform were 4
sufficient to meet it and that the check valves were capable 5
of performing their function, and thus it was not 6
reportable.
7 MR. REPKA:
So this NCR did not suggest any 8
deficiency at all in the surveillance testing, does it?
9 MR. CROCKETT:
That's correct.
10 MR. VOSBOURG:
Often we'll have NCRs written for 11 any time we suspect a potential problem or we see something 12 that needs further research to determine whether or not we 13 actually have a problem.
So we have many nonconformance 14 reports written where the end result is that we did fully 15 meet the requirements, and there wasn't a problem to begin 16 with, but it's still documented as a nonconformance report.
17 MR. CROCKETT:
And we take these issues seriously, 18 strive to improve and enhance our programs.
19 MR. REPKA:
I have nothing further.
20 MS. CURRAN:
Why don't we star on Exhibit 9 for a 21 minute.
On page 2 of 9, there's -- in section II-A, the 22 event is described.
23 MR. CROCKETT:
I'm sorry.
Page 2 of?
24 MS. CURRAN:
9.
25 MR. CROCKETT:
On Exhibit 9?
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MS. CURRAN:
Yes.
Oh, I'm sorry.
I'm on the 2
wrong one.
Okay.
I'm sorry.
I was on the wrong exhibit.
3 Okay.
This discussion that we were just having was about l
I 4
Exhibit 9.
l 5
MR. CROCKETT:
Okay.
6 MS. CURRAN:
Right?
I'm sorry.
I was reading the 7
wrong exhibit.
I'd just like to clarify that it appears to 8
me on the first page, which is entitled, " Management 9
Summary," it says, 10 "During IR 5 STPV 4-A was revised, no r
11 longer providing assurance that a full
]
12 flow verification of SI 8981 was l
13 performed."
14 Apparently, this was found to be a personnel error.
Do you
)
15 disagree with the statement made there?
16 MR. CROCKETT:
No.
I didn't -- no.
There is a l
i 17 commitment to test it.
An individual didn't recognize that i
18 it needed to be tested.
It was a documentation -- it was an 19 omission out of the IST program to test that.
l 20 MS. CURRAN:
All right.
So there was --
21 MR. CROCKETT:
Then we went back and tested it, l
22 and it was satisfactory.
23 MS. CURRAN:
There was a problem in the 24 maintenance and surveillance program that is identified in 25 this NCR; is that correct?
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i j
1 MR. CROCKETT:
There was a personnel specific r
2 problem with respect to that but not a problem with the l
3 program.
The program -- the program worked.
4 MS. CURRAN:
A problem in implementing the j
l 5
program.
Would you agree with that?
i 6
MR. CROCKETT:
I would say a specific problem with j
7 implementing that commitment to test that valve.
i
+
l 8
MS. CURRAN:- All right.
Mr. Crockett, is it true 9
that most, if not all, of the check valves described in i
10 these exhibits are safety related?
i 11 MR. CROCKETT:
No.
That's true.
12 MS. CURRAN:
That's true.
i 13 MR. CROCKETT:
They have a safety function.
l 14 MS. CURRAN:
And is it true that until the i
i O' l
15 engineering analysis was made that these valves needed to be 16 tested they weren't tested at all --
l l
17 MR. CROCKETT:.That's correct.
j l
18 MS. CURRAN:
-- since the inception of operation J
19 of the plant?
1 20 MR. CROCKETT:
That's correct.
21 MS. CURRAN:
That's right.
22 MR. CROCKETT:
Per the Code requirement they were 23 not tested.
We were following tr.a specific requirements in 24 the Code, and we had a program that was approved by the NRC.
25 So you're absolutely right.
We weren't testing.
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MS. CURRAN:
In 1988, you were alerted that you 2
needed to reconsider and broaden your program for testing 3
check valves; is that correct?
4 MR. CROCKETT:
That's correct, '88 and
'89.
I I
5 MS. CURRAN:
And you commenced to do some 6
engineering judgment, some new engineering calculations or 7
reviews to determine whether additional check valves ought 8
to be tested; is that correct?
9 MR. CROCKETT:
Maybe not calculations but 10 reviewing the --
11 MS. CURRAN:
Review.
12 MR. CROCKETT:
-- potential valves that were not 13 recognized as having a safety function.
That's correct.
14 MS. CURRAN:
So would you agree that in 15 determining the proper scope of a maintenance program that l
16 some engineering judgments are involved?
17 MR. CROCKETT:
That's correct, but more 18 specifically what are you getting at?
19 MS. CURRAN:
I'm sorry?
20 MR. CROCKETT:
I didn't really, kind of, 21 understand the question.
You said we use engineering I
22 judgments to make decisions.
That's true.
23 MS. CURRAN:
That's right.
24 MR. CROCKETT:
Yeah.
25 MS. CURRAN:
I don't have any further questions ANN RILEY & ASSOCIATES, LTD.
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about this, and we would --
2 MR. CROCKETT:
But also let me add that that's not 3
the only -- we just don't use engineering judgments.
We use 4
many things to make our decisions about whatever.
5 MS. CURRAN:
We have no further questions, and we 6
would like to move these exhibits with the exception of 7
Exhibit 12 into evidence.
8 MR. REPKA:
We object to the admissibility of 9
these documents, because they do not suggest a problem in 10 the surveillance program.
Most of the incidents documented l
11 here relate to an evolving generic issue which was being l
l 12 tracked and which was responded to appropriately, and, in 13 all cases, in any event, the valves were determined to be 14 set.
1 15 In addition, at least with respect to Exhibit 8, l
16 the document, on its face, states that the NCR was resolved 17 by determining that there was not a problem with this 18 specific surveillance test involved.
In addition, with 19 respect to Exhibit 13, this, I believe, is a preconstruction 20 design issue, not a maintenance and surveillance issue.
21 Finally, Exhibits 6 and 7 relate to exactly the 22 same issue and, therefore, are cumulative.
In toto, we 23 object to these as not probative to the issue that is at 24 stake here, which is the implementation of the maintenance 25 and surveillance program.
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617 1
MS. CURRAN:
I'd like to responsibility, if I 2
might?
I'd like to respond to Mr.
-- at your convenience.
3 Are you ready?
4 JUDGE BECHHOEFER:
Why don't you respond.
I may 5
have a question, but maybe I won't after you respond.
6 MS. CURRAN:
In our view, the fact that this 7
program may be evolving is an indication that it isn't 8
evolved enough and that there are check valves in this plant 9
that have gone untested for their operability since the day 10 the plant was built, that were never tested until a new 11 engineering judgment was belatedly made to determine that 12 they, in fact, should be tested, and this goes to the 13 adequacy of PG&E's program for evaluating what is the proper 14 scope of its maintenance program.
15 MR. REPKA:
But the fact of the matter is, as I 16 stated before, this is an issue that related to further l
17 inquiry into the scope of the surveillance program and was 18 adequately responded to.
Now, number one, it's not 19 therefore probative as to the existence of a problem.
l 20 Number two, Ms. Curran now makes the leap of faith to say 21 that this past issue somehow has some bearing on what the 22 current scope of the surveillance testing might be, and l
23 there is absolutely no basis to support that hypothesis, 24 that leap of faith.
25 The fact of the matter is even if there was an l
v ANN RILEY & ASSOCIATES, LTD.
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issue that evolved and was addressed by the company, which 2
is what the evidence states, that has no bearing on the 3
current state of the surveillance program.
j 4
MS. CURRAN:
Well, we have -- this set of exhibits 5
shows that periodically PG&E identifies a new check valve or 6
set of check valves that should have been included in its 7
testing program, and there's no indication of when that 8
process will end, of when they will stop discovering check 9
valves that need to be included in the -- in the program.
10 This, to us, is an indication that a timely response was not 11 made to the Board notification, and that there is an 12 inadequate program for identifying check valves that need to 13 be tested.
/
14 As far as the individual exhibits go, in Exhibit i
15 Number 8, the management summary states that the valve was 1
16 not tested at an appropriate flow rate, and that was part of 17 the problem for which the NCR was written.
That was not 18 changed.
That was not corrected.
That is a problem that 19 existed.
An improper maintenance procedure was followed, or l
20 there was a failure to follow a procedure.
21 With respect to Exhibit Number 13, I believe the 22 argument is that this is a design issue.
Well, as l
23 Mr. Crockett stated, the question of what the scope of the 24 maintenance program ought to be isn't partly an engineering 25 question.
It is a design question.
It's something that has ANN RILEY & ASSOCIATES, LTD.
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to be reexamined as part of the maintenance program.
PG&E 2
was asked to go back and look at the assumptions it made in 3
designing the plant, in engineering the plant and review and 4
see whether or not they were correct and whether indeed the 5
maintenance program should be expanded-to cover new check 6
valves as a result of those judgments.
This is not just a 7
design issue.
It's an issue of the adequacy of the scope of l
)
8 the maintenance program.
9 MR. REPKA:
There is no evidence, again, to i
10 suggest that these are problems in the implementation of the 11 program, but, more importantly, if the Mothers for Peace 12 believe that there is a problem in the existing check valve 13 surveillance program, they need evidence to support that.
14 None of these documents provides that evidence.
This is O
15 evidence that the program has been addressed, has been l
l 16 revised to address new information.
It is not evidence that i
17 there is any existing problem in the program.
18 So the Mothers for Peace simply don't have i
l l
19 evidence, and this is not it, to support the conjecture.
i i
20
[ Judges confer.]
]
i 21 MS. CURRAN:
Mr. Chairman, I don't want to 22 interrupt, but I would like to address the Board in response 23 to Mr. Repka.
24 JUDGE BECHHOEFER:
Okay.
25
[ Judges confer.]
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1 MS. CURRAN:
I would like to respond to Mr.
O 2
Repka's argument.
In our view, the record of how a plant i
3 operates is one of the best ways of judging whether its 4
maintenance program is effective.
The record of the -- the j
i 5
repetitive of occurrence of maintenance problems in the same l
3 6
area, especially in this case after there's been some 7
notification of a need to re-examine the scope of'the i
l 8
maintenance program, that's extremely probative of how 9
adequate the maintenance program is.
i l
10 I would also like to read a section from the INPO t
11 guidance that PG&E adopts or relies on for its own
{
12 maintenance program which explains the relationship between i
13 engineering issues and maintenance issues.
l l
14 JUDGE BECHHOEFER:
Yeah, is this eventually going
{
\\
\\
l 15 to be offered for the records?
l 16 MS. CURRAN:
Yes, it is.
17 JUDGE BECHHOEFER:
Okay.
18 MS. CURRAN:
In Section 3, entitled, " Activities 19 Supporting Maintenance", one of the categories is Section 20 3.2 is " Engineering Support".
The document states that, 21
" Plant engineering support activities 22 play a key role in an effective 23 maintenance program.
Engineering 24 support personnel monitor and evaluate 25 the performance of plant systems and j
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components.
This includes reviewing O_
2 past and present maintenance activities i
3 to identify and resolve chronic problems 4
in addition to trending results from 5
tests and routine operations to identify i
6 equipment degradation before failure.
7
" Engineering analysis can lead to 8
changes in the scope or frequency of 9
preventive maintenance activities, 10 changes in the method of equipment 11 operation or maintenance or equipment 1
12 modifications to improve equipment 13 reliability."
s 14 This document indicates that engineering analysis, 15 the kind of design issues that were dealt with with some of 16 these check valves are directly relevant to the question of i
17 the adequacy of the scope of PG&E's maintenance program.
1 18 MR. REPKA:
The objection here is not any of what i
j 19 Ms. Curran was just talking about.
The fact of the matter J
i 20 is the documents do not suggest that there was a problem in 21 any of those areas that she just described.
And number two, 22 they don't suggest any current problem.
23 MS. CURRAN:
I'd just like to point out in terms 24 of currency, the most recent NCR that we have --
25 JUDGE BECHHOEFER:
Ms. Curran?
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MS. CURRAN:
I'm sorry.
2 JUDGE BECHHOEFER:
I think -- well, let me just 3
cut you off for a minute.
You've won, we're going to allow 4
all of them in.
So, you better not say anything that will 5
make things worse.
We've decided to let all the documents 6
in.
And the first two, 6 and 7, we think are more important 7
collectively than individually even though they talk about 8
the same incident.
So, we are going to allow all of them 9
in, with the exception of the staff document, which I guess 10 has not been offered yet, which is number 12.
So, it's 6, 11 let's see, 6 through 11 and 13 and 14 are -- is that right?
12 I'm sorry, 6 through 11 and 13 are admitted.
13
[ Pause.]
14 I might add, to just explain the basis for our
' O l
15 ruling, we think that the -- while every incident in itself 16 may have been handled properly, the cumulative nature of 17 various incidents could, could, I don't say they will, but 18 could lead to conclusions that the program itself is somehow 19 deficient or is being implemented improperly.
So, on that 20 basis we will allow evidence of this type to be admitted, 21 just as an explanation.
We think that collectively the j
22 incidents may be more important than they are individually.
23 It could be, I'm not saying it will be, but it could be.
)
24 You can proceed.
l l
25 MS. CURRAN:
All right, we'll move to the next ANN RILEY & ASSOCIATES, LTD.
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623 j
1 section, which is entitled, " Cable Failures".
There are O
2 eight exhibits in this category, Exhibits 14 through 21.
3 These all relate to the failure of 12kV and-4kV cable at the l
4 Diablo Canyon Nuclear Power Plant, some of it is safety 5
related.
And it's going to take a minute to get all these 6
documents out to you, but --
7 MS. ZAMEK:
We've got it, they're organized now.
8 MS. CURRAN:
Okay.
9
[ Documents _ passed out.]
10 MS. CURRAN:
This one --
11 JUDGE BECHHOEFER:
Yeah, I understand, this is the 12 incident where one of the more effective surveillance 13 systems ever devised has been used, smoke.
If there's 14 enough of it you might find that there's something wrong.
15 MR. REPKA:
I object to that.
16 JUDGE BECHHOEFER:
Okay, I'm sorry, f
17 MR. REPKA:
I think that's unnecessary.
18 MS. CURRAN:
I'd like to make a request that 19 Mr. Repka, as we go through these and we go through each 20 exhibit, if you have questions, can we do the recross on 21 the -- you know, go exhibit by exhibit, because I frankly 22 have a hard time keeping track of all the discussion, 23 technical discussion that's gone on five minutes ago or ten 24 minutes ago?
25
-)m. REPKA:
We'll try to do that --
O ANN RILEY & ASSOCIATES, LTD.
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MS. CURRAN:
Okay.
2 MR. REPKA:
-- where it's meaningful.
3
[ Pause.]
l 4
JUDGE BECHHOEFER:
I might add on that, if there l
t 5
are two that are very closely related --
I 6
MS. CURRAN:
Right.
7 JUDGE BECHHOEFER:
-- such as 6 and 7, it might be 8
better to discuss those together.
9 MS. CURRAN:
Oh, that's fine, yeah.
10 JUDGE BECHHOEFER:
Yeah.
I -- having not looked 11 at these yet, I don't know.
12
[ Pause.]
l 13 MS. CURRAN:
Whenever you're ready?
14 MR. REPKA:
Oh, I'm sorry.
Gentlemen, have you l
15 had a chance to skin through these documents?
i 16 MR. ORTORE:
Yes, we have.
17 MR. REPKA:
Do you -- all of these documents, in 18 fact, relate to five incidents involving 12kV and 4kV i
l 19 occurrences?
20 MR. ORTORE:
Correct.
There were two safety 21 related 4kV incidences, one non-safety 4kV incident and two 22 12kV incidences.
)
23 MR. REPKA:
And these documents all relate --
i i
24 strike that.
25 And these incidents have been addressed in your O
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direct testimony, have they not?
i O
2 MR. ORTORE:
Yes, they have.
1 1
3 MR. REPKA:
Are any of these documents you're t
4 unfamiliar with?
5 MR. ORTORE:
No.
6 MR. REPKA:
With respect to the 12kV failures that 7
we've -- or indications involved here, you stated that 8
neither are safety related cables, isn't that correct?
9 MR. ORTORE:
Correct.
All 12kV circuits at the 10 site are non-safety.
11 MR. REPKA:
With respect to the 4kV cables, isn't 12 it correct that no root cause for those incidents has yet 13 been determined?
14 MR. ORTORE:
No, we have done extensive O
1 15 investigations, extensive tests of all the 4kV failures and i
16 we have not been able to determine a root cause.
We have i
i 17 eliminated certain possibilities, such as, water intrusion 18 into the cable, such as aging, such as misinstallation of 19 the cable, we've looked into the design of the cable and we 20 have ruled out those possibilities.
21 MR. REPKA:
Of these documents, which one is --
i 22 reflects the current status of the PG&E's understanding of l
23 these cable issues?
24 MR. ORTORE:
There has been a lot of ongoing 25 investigation and I do not believe that any of these O
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1 documents fully contain all the results of the 2
investigations or the analysis that have been performed.
)
i 3
MR. REPKA:
So, the last word, from the company's 4
perspective, on these issues, is contained in the direct 5
testimony, is it not?
6 MR. ORTORE:
That's correct.
7 JUDGE BECHHOEFER:
Have the documents that you 8
just referred to been included in applicant's exhibits that 9
have been admitted thus far or offered, I'm sorry, offered?
i 10 MR. REPKA:
They have not been, Judge Bechhoefer.
l l
11 JUDGE BECHHOEFER:
Okay.
12
[ Pause.]
13 MR. REPKA:
With respect to Exhibit 16, that I
14 exhibit refers to chemical attack on the cable jackets?
^
l 15 MR. ORTORE:
I believe this was a recommendation 16 to look into a possible spill that occurred at the site that 17 could have possibly been the chemical attack.
We've gone 18 through the history of all chemical spills out at the site I
19 and none of the spills that we can find, including the one i
20 referenced in this E-Mail, could have possibly been the 21 contaminate that caused the degradation to the cable.
22 MR. REPKA:
And this E-Mail relates only to the 23 12kV cables, does it not?
24 MR. ORTORE:
Strictly to the 12kV, yes.
25 MR. REPKA:
I have no further questions on these O
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documents.
I do object to their admissibility on the basis 2
that we have stipulated and testified in direct testimony 3
that these incidents occurred and to the extent the Mothers 4
For Peace want to rely upon the mere occurrence, that's not 5
an issue.
But the current understanding of what happened, 6
in the company's perspective, that these incidents do not 7
suggest a problem in the maintenance and surveillance area, i
8 is addressed in the direct testimony and that's the best i
9 evidence here.
There is no need for all this historical 10 documentation in the record, most of which has, in fact, i
i 11 been superseded.
j 12 MS. CURRAN:
Well, all of these documents that are j
13 included here describe the factual circumstances of the l
14 discovery of the degraded cable, the circumstances, the 15 company's root cause analyses, the issue of the fact that i
16 the sump pump was in the area where the cables were located 17 was not working and was not included in the PG&E's 18 maintenance program.
They are all relevant to the question 19 of whether PG&E's maintenance program was adequate to detect 20 the degradation of this cable.
And therefore, we believe 21 they should all be admitted.
22 MR. REPKA:
We don't agree that any of these are 1
23 necessarily relevant to the adequacy of the maintenance 24 program.
The 4kV incidents in particular, there has never 25 been a tie between the incident and maintenance.
But be ANN RILEY & ASSOCIATES, LTD.
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that as it may, the fact of the matter is, all of the above 2
is addressed in the direct testimony of the witnesses, 3
including the sump pumps and the root cause analyses and the 4
occurrence of events.
5 There is a tendency here to confuse the issue by 6
going to the earlier documents that represent an ongoing 7
analysis.
And for the sake of a fair record, the more 8
focused approach is to look at the direct testimony which 9
presents the current state of knowledge.
10 JUDGE KLINE:
Ms. Curran, are you going to 11 cross-examine the direct testimony?
12 MS. CURRAN:
Not on this.
13 JUDGE KLINE:
On this subject?
14 MS. CURRAN:
No.
15 JUDGE KLINE:
Okay.
16 MS. CURRAN:
We're letting these documents speak 17 for themselves.
If there is a question about whether 18 these -- all these documents should go in, we would like a 19 moment to go through them all and discuss their -- the 20 relevance of each document.
21 MR. RE?KA:
Again, the relevancy of the individual 22 documents is not the objection here, it's the cumulative 23 nature of it and the lack of probativity given its unrelated 24 to what's at issue here.
The direct testimony much more 25 aptly provides that.
Particularly if the Mothers for Peace ANN RILEY & ASSOCIATES, LTD.
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are simply trying to conduct a bean counting of incidents at 2
the plant, that argument can well be supported, to the 3
extent it can be made, I suppose, by the testimony in PG&E's 4
direct testimony.
1 5
MS. CURRAN:
Well, if it would be--- I don't think
)
6 it would be an efficient way to go about this, but we could 1
. -l l
7 cross-examine PG&E on the direct testimony and add relevant 8
information from these documents through that.
I was hoping i
9 that we could all save time by just putting these documents, 10 which are clearly relevant, into the record, and additional 1
11 information that's not in this testimony and there is some j
12 information that is not, can just be gleaned from the l
13 docunents.
But whichever way, I'd like the opportunity to i
t 14 go through and get relevant information in these documents 15 into the record.
l I
i l
16
[ Judges confer.]
17 JUDGE BECHHOEFER:
Ms. Curran, I'm not -- we're i
l 18 thinking that there's going to be too much open-ended to do 19 it that way and that cross-examination of the witnesses l
20 based on the documents would be desirable and perhaps the 21 documents should, as well, go in the record after you get 22 done cross-examining them because if there's additional 23 information in the document, I'm not sure we don't have to 24 do both to have an adequate record for us to resolve.
25 MS. CURRAN:
Well, what I was trying to avoid was J
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having to say, isn't it true that, et cetera, and wasting 2
everyone's time just getting the witness to agree with a 3
sentence that's written down in a document.
That's what I 4
want to avoid.
5 MR. REPKA:
Well, I think we would like to avoid 6
that, too.
And I guess the question becomes what is the 7
isn't it true that's not already in the direct testimony?
8 MS. CURRAN:
Well, if this is an issue I'd liKe to 9
at least take 15 minutes and go over this and identify those 10 particular parts of the documents and go through the process 11 of identifying them through cross-examination.
12 JUDGE BECHHOEFER:
Yeah, we could quit for lunch 13 and you can have some time to do that.
14 MS. CURRAN:
All right.
15 JUDGE BECHHOEFER:
We think that perhaps some 16 documentation on some of the information on the direct 17 testimony would be desirable.
So, I don't know how that 18 will be handled.
And if you have additional information 19 that's in those documents, it certainly should be stressed 20 so that we could understand the issue better.
21 MS. CURRAN:
All right.
I 22 JUDGE BECHHOEFER:
So, it may not be the most time 23 saving, but we want to make sure the record has got enough 24 in it so that we can resolve the matter.
You know besides i
l 25 us looking through and saying, well, this says this and this j
l ANN RILEY & ASSOCIATES, LTD.
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says something a little bit different and maybe we should O
I 2
need some explanation of the differences and either you or 3
we would have tv ask that.
3 4
MS. C.URRAN:
All right.
5 JUDGE BECHHOEFER:
So, it might be better for you 6
to try to do that, at least the major issues.
There may be i
7 minute details that can stay in the document if they're i
8 supportive of the general result, but not having' looked at l
9 all these documents I can't tell you right now.
But I think f
t 10 it would help us to have the parties bring out differences 11 and emphasis certainly on certain parts of the document.
[
12 MS. CURRAN:
All right.
We'll do that, if we i
13 could just have a little bit of time to prepare.
j 14 JUDGE BECEMOEFER:
Well, why don't we break for j
O 15 lunch until one o' clock, even a little later perhaps.
I i
16 don't know how much time you'll need.
j 17 MR. REPKA:
I would prefer to press on and i
18 certainly, if we're going to break for lunch I wouldn't want l
19 it to be more than hour.
20 JUDGE BECHHOEFER:
Well, that depends in part on 21 how easily you can get lunch around here.
I mean if we have 22 to walk six blocks to get a decent lunch and wait for 15 23 minutes to get a table, then you're hour has fallen sort of 24 short.
25 MR. WARNER:
Judge Bechhoefer, there are many O
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restaurants just in the immediate vicinity.
2 JUDGE BECHHOEFER:
Okay.
3
[ Judges confer.]
4 We've decided that since you'll probably have to 5
do a little calculation beyond what you normally expected, 6
we will have a long lunch hour today, maybe an hour -- till 7
i:15 actually, and then we'll -- I hope that gives you 8
enough time to -- because I do think some cross-examination 9
would help us.
10 MS. CURRAN:
All right.
11 JUDGE BECHHOEFER:
So, let's adjourn till 1:15.
12
[ Recess from 11:50 a.m. to 1:15 p.m.]
l 13 JUDGE BECHHOEFER:
Back on the record.
I note 14 we've received copies of PG&E's Exhibit 10A, which, as I 15 recollect, has been admitted already.
Correct me if I'm 16 wrong.
l 17 MR. REPKA:
That's the document we added to our 18 exhibit book this morning and it has --
19 JUDGE BECHHOEFER:
Right.
20 MR. REPKA:
-- been admitted and I just 21 distributed copies to all the parties on the Board.
22 JUDGE BECHHOEFER:
I have one question; for what 23 period of time is Unit 0 seeking an extension?
24 MR. REPKA:
Excuse me?
25 JUDGE BECHHOEFER:
Read the front page.
O ANN RILEY & ASSOCIATES, LTD.
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=
. = -
i
.633 1
MR. REPKA:
Unit 0, I understand signifies both l
O 2
Units, but I would ask Mr. Giffen to confirm that.
l t
3 JUDGE BECHHOEFER:
Okay, I would like the record f
4 to reflect what 0 means.
l 5
MR. REPKA:
Mr. Giffen?
6 MR. GIFFEN:
Are we talking about the list of j
7 procedures?
I 8
MR. REPKA:
Exhibit 10A, the loop tests.
j 9
MR. GIFFEN:
Yeah, the loop.
If there's a o it's
(
10 for both Units 1 and 2.
i 11 JUDGE BECHHOEFER:
Okay.
(
12 MR. REPKA:
I note at the back of that there are i
13 some that are listed as number 3 also.
What does that mean?
l l
14 MR. GIFFEN:
The same thing, different time frame.
I 15
[ Pause.]
l i
16 JUDGE BECHHOEFER:
Ms. Curran?
l t
17 MS. CURRAN:
Yeah, before we start, while we were j
18 in the course of preparing for cross-examination on the l
19 cable issue we found two exhibits that could go out and we l
?
20 also found two other documents that we wanted to put in.
l 21 Sc, we'd like to make a substitution and we're going to 22 provide copies to the Board and the parties here.
23 The Exhibit 16, which was a memo from Rich McCurdy 24 to Wells Fargo dated March 18th, 1993, should be stricken 25 from this list and what should be substituted is a letter ANN RILEY & ASSOCIATES, LTD.
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1 from Mr. V. Wyman of the Okonite Company to Mr. Bush, Ron 2
Bush of PG&E dated February 12, 1990.
Then Exhibit 21, 3
which on the list we provided you is something called 4
" Technical and Ecological Services Report No. 420DC-92.856" 5
dated September 10th, 1992 should be stricken from that list 6
and what should be substituted for that is -- yeah, it's 7
called, "ALTRAN Materials Engineering, Inc.",
it's actually 8
a fax and the cover page is a fax transmittal sheet and on 9
the next page it's clear that it's a draft letter from a Mr.
i 10 Joseph Groger at ALTRAN to Wells B.
Fargo at PG&E, and the-11 date on that is May 6th, 1993.
12 JUDGE BECHHOEFER:
Do these relate to the same i
13 general issue?
14 MS. CURRAN:
They relate to the same issue.
l O
l 15 JUDGE BECHHOEFER:
Okay.
l 16 MS. CURRAN:
The same cable issue.
17
[ Pause.]
18 And finally, before we begin, I'd like to ask the 19 Board, please, that Jill ZamEk, who has compiled much of 20 this information and who is extremely familiar with these 21 documents, be given leave to conduct the cross-examination 22 on this issue?
23 MR. REPKA:
We have no objection.
l 24 MS. HODGDON:
No objection.
25 JUDGE BECHHOEFER:
You'll be permitted to do that.
l l
l i
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MS. ZAMEK:
Okay.
Let's start with Exhibit 14, O
2 page 7.
I would like to verify the dates of the cable 3
failures in this document, and anyone on the panel may 4
answer that.
On page 7, please verify that the first cable 1
5 failure occurred in 1989.
]
6 MR. GIFFEN:
We're having an exhibit problem here.
7 MR. ORTORE:
Which exhibit, 14?
I 8
MS. ZAMEK:
You have Exhibit 7?
I mean 14?
9 MR. GIFFEN:
Which exhibit again, please?
10 MS. ZAMEK:
14.
11 MR. GIFFEN:
We have Exhibit 14, DCl-93-EM-N010?
l 12 MS. ZAMEK:
That's right.
I may have the wrong f
13 page, let me check?
Excuse me, it was page 11, under 14
" Determination of Cause".
15 MR. GIFFEN:
Paragraph 3, yeah, I see where it is.
16 MS. ZAMEK:
I would just like a year of the first 17 cable failure, that's all.
18 MR. GIFFEN:
Well, the date, the 1989, we believe 19 that to be a 4kV cable failure.
20 MS. ZAMEK:
Okay.
And on page 1 it talks about 21 the dates on the second and third cable failures and those l
22 dates, do you verify them to be February 5th, '93 and March l
l 23 12th, '93?
24 MR. ORTORE:
This document only covers the 12kV 25 failures, both of which happened in 1993.
The reference to O
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1989 was just reference to another incident that's not O
2 covered by this document.
l 3
MS. ZAMEK:
But it was a 4kV cable, is that 4
correct?
I 5
MR. GIFFEN:
Correct.
We believe, it doesn't say 6
that in that paragraph, but there was a 4kV failure in 1989 7
so we assume that's what that's referring to.
I 8
MS. ZAMEK:
Okay.
i 9
MR. GIFFEN:
But this NCR is for the 12kV
]
10 failures, the non-safety related.
l 11 MS. ZAMEK:
Okay.
On Exhibit 15, page 7, the 4
l 12 testimony -- in your testimony you said that the, you know, l
13 that you claimed knowledge of the sump pump problems but you f
I le don't give a lot of information about how long that it was 15 not functional.
Can you tell me what year that was the last j
16 time it was functional in this -- it says, l
f 17 "For a period of time preceding the 18 cable failure events on this page, 19 investigation determined that water had i
20 accumulated in the pull boxes as a I
l 21 result of the pull box drain systems and 1
22 associated sump pumps not being 1
23 functional for a period of time I
24 preceding the cable failure events."
25 I saw a period of time, I see 1987, I've seen 20 years, are s
1
/~
3 l
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you gentlemen aware of how long it was inoperable?
2 MR. GIFFEN:
Off the top of my head, no, I cannot 3
give you the dates when it was or wasn't.
I'm looking at 1
4 testimony to see.
5 MS. ZAMEK:
Well, I didn't find it in the 6
testimony either, that's why I asked you.
Can we move on to 7
the next question while you're -- somebody's looking?
Okay.
8 Exhibit 16, which is the new one on the Okonite, 9
on page 6.
I'd like to read that last paragraph.
10 "Since the cable of 1972, which when it 11 was put in, in the as new state was not 12 up to standards of performance in terms 13 of testing, moisture stability and i
14 dielectric strength of current cables, 15 not were the methods of production in 16 1972 as reliable as today's production 17 methods.
We feel it would be prudent to 18 replace the medium voltage cables known 19 to be in areas subject to water 20 submergence under normal conditions with 21 cables of today's production methods, 22 materials and design.
This could be 23 done on a regular maintenance schedule.
l 24 It is by no means implied that an 25 emergency situation exists."
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~ _ _ _ _. _ _ _. _ _ _
i i
l l
([)
638-1 I'd like to note that this document was written in 1990.
My i
2 question is, was that done?
Were these cables replaced f
3 then?
i
- i 4
MR. ORTORE:
No, these cables were not replaced j
5 then and I don't think that the document implies that
[
i 6
there's any reason to believe that there's any deficiency in j
7 the cables that were installed in'1972, nor does it say that l
l 8
they will not meet their intended service.
All iti states is i
9 that the cables manufactured today might be better than 10 those manufactured in 1972.
11 MS. ZAMEK:
Was there any plan put in place to
{
12 follow their recommendatica?
This is an engineering report j
13 and this is part of their summary and recommendations.
Was 14 there any plan like tLcf recommended to start planning for i
15 the replacement?
I 16 MR. ORTORE:
We have done an extensive investigation in these cables incidents and this is only one 17 18 small piece of the puzzle.
This was a recommendation from 19 the manufacturer of the cable and we have information from 20 various labs, we are still compiling the information and in 21 the case of the 4kV cable we have not been able to determine 22 a root cause yet and we have ruled out many, many i
23 possibilities.
One possibility that's stated in this 24 summary, about it possibly being caused by installation 25 damage, was ruled out.
i ANN RILEY & ASSOCIATES, LTD.
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.m-=~,r.-w,-e+w w e m e % men - m e e e--, t we w -, e c.= e v--mewe ww
639 1
MS. ZAMEK:
Thank you.
Let's move to Exhibit 17, 2
page 7.
3
[ Pause.]
4 Just a minute, I'm confused again.
5
[ Pause.]
j 6
Okay, that's right.
On number 2, on 7, as part of 7
the NCR, part of the corrective actions it says, 8
" Establish a preventative maintenance 9
program for the sump pumps and drains 10 associated with the Unit 1 cable vaults 11 located outside the turbine building, i
12 12kV switch gear cable spreading rooms."
r 13 Am I to understant uhen that there was no preventative L
14 maintenance program for the sump pumps and the drains prior 15 to this?
16 MR. ORTORE:
That's correct.
17 MS. ZAMEK:
Okay and then --
18 MR. ORTORE:
The preventative maintenance program 19 is -- involves recommendations from the vendor, it involves 20 recommendations from our staff and recommendations from 21 different things that happen in the industry.
And based on
)
22 these recommendations it is a selection of components 23 contained in the plant that's included in the program.
j l
I 24 These items, these small sump pumps were not included in the 25 preventative maintenance program.
Not all components in the ANN RILEY & ASSOCIATES, LTD.
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plant are included in the program.
2 MS. ZAMEK:
Okay.
And on the next page, number --
3 let's see, where is that, number four, it says, 4
" Establish a preventative maintenance 5
program for the sump pumps and drains 6
associated with Unit 2 cable vaults 7
located outside the turbine building 8
12kV switch gear cable spreading room."
9 It's my same question.
10 MR. GIFFEN:
It's the same answer.
11 MS. ZAMEK:
Same answer.
12 MR. GIFFEN:
We didn't have it on one unit and we 13 didn't have it on the other.
14 MS. ZAMEK:
Okay, thanks.
15 MR. GIFFEN:
They now both, however, are included 16 in the program.
17 MS. ZAMEK:
On page 9, the same document, in the 18 middle of the page, under "NRC Information Notices", it 19 refers to an information notice 8649 and regarding an event 20 that happened at San Onofre Unit 1, November 21st, 1985.
21 And it cautioned the industry to take notice of problems, 22 potential environmental -- with potential environmental l
23 conditions like water intrusion as, you know, this emergence 24 has happened at Diablo.
Was anything done at that time in 25 response to that information notice?
O ANN RILEY & ASSOCIATES, LTD.
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1 MR. ORTORE:
I think right down in the second O
2 paragraph, 3
"PG&E's response to this notice was that 4
DCPP's class 1E cable outside of the 5
spreading areas and switch gear rooms is 6
run inside rigid iron conduit and is 7
properly grouted away from high 8
temperature piping and equipment."
9 MS. ZAMEK:
But still, the sump pumps were not i
10 monitored and the cables got submerged.
Isn't that correct?
11 MR. GIFFEN:
Excuse me, I'm having trouble hearing 12 you.
I'm sorry.
+
13 MS. ZAMEK:
Never mind, that's okay.
Let's go to 14 18.
15 JUDGE BECHHOEFER:
What page?
16 MS. ZAMEK:
Page 15.
17 JUDGE BECHHOEFER:
And it's Exhibit?
18 MS. ZAMEK:
Exhibit 18.
19 JUDGE BECHHOEFER:
Oh, okay.
20 MS. ZAMEK:
Page 15.
21 JUDGE BECHHOEFER:
Okay.
22
[ Pause.]
23 MS. ZAMEK:
This is an analytical investigation 2a produced by TES, and in the recommendations under the SkV 25 cable they state that the next cable failure cannot be ANN RILEY & ASSOCIATES, LTD.
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predicted and it may be prudent to consider an emergency 2
response plan and cable replacement in priority circuits.
3 This was recommended just recently.
And please tell me 4
about the cable replacements that have occurred?
5 MR. ORTORE:
We have replaced all sections of 6
cable that have failed.
We have also replaced additional 7
sections of cable to help in our investigation by looking at 8
cables in other sections of the conduit.
This 9
recommendation here is to take the replacement into account 10 and start doing planning, which we are doing.
We are taking 11 that under consideration.
Just before that, I think it 12
- states, 13
" Based on the good test results the 14 cable will operate normally and O
j 15 immediate replacement is not necessary."
16 And we are taking that into account and we are taking that 17 under advisement and yes, we are, in our analysis, 18 considering replacement of some or all of that cable.
i 19 MS. ZAMEK:
Okay, can you tell me what --
20 MR. GIFFEN:
Excuse me, can I?
It depends upon --
21 as you notice, this is a draft, at least the copy that we 22 have is a draft result, so, to me that means that TES has 23 not completed their investigation, that's a draft i
24 recommendation.
We still don't know the root cause of the 25 4kV failure.
We may not ever know the root cause of the 4kV O-ANN RILEY & ASSOCIATES, LTD.
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failure.
But, as we continue the anaaysis, we'll do more 2
and that time do what we consider to be prudent.
3 MS. ZAMEK:
Okay.
My next question then is what i
4 did-you replace it with?
j 5
JUDGE BECHHOEFER:
Could I interrupt a minute?
l 6
MR. GIFFEN:
Yes, sir.
7 JUDGE BECHHOEFER:
The earlier we heard'about 4kV l
8 cables, these are apparently SkV cables?
i 9
MR. GIFFEN:
Same thing.
It's rated as SkV, it's i
10 4kV cable.
I 11 JUDGE BECHHOEFER:
Oh, okay.
Same for 15 and 12, 12 I take it?
13 MR. GIFFEN:
Correct.
It's a 15K cable used in a l
14 12kV application and a SkV cable used in a 4kV application.
i i
15 JUDGE BECHHOEFER:
Okay, thank you.
j l
16 MS. ZAMEK:
What did you replace the cable with?
l 17 MR. ORTORE:
It was replaced with similar i
I 18 construction cable.
19 MS. ZAMEK:
The same?
20 MR. ORTORE:
Not the same vintage, the same I
i 21 construction cable.
i l
22 MS. ZAMEK:
Yeah, what does that mean?
Same l
23 vintage?
Same material, the EPR, the same stuff?
24 MR. ORTORE:
- Correct, l
25 MS. ZAMEK:
Okay.
Let's see, on Exhibit 19, is l
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the Region 5 Morning Report.
I'd like you to verify that k
2 it's true that this report states that the degradation that 3
they found at Diablo is unprecedented and has not been seen 4
by the industry previously.
Is that true to your knowledge?
5 Have you heard of other --
6 MR. ORTORE:
This document only covers the 12kV 7
cables.
8 MS. ZAMEK:
12kV, okay.
9 MR. ORTORE:
And I --
10 MS. ZAMEK:
Right, because that's the only one 11 that was degraded.
12 MR. ORTORE:
We have done much investigation, 13 including contacting other utilities that have similar type 14 installations and no, we have not come across this 15 degradation that we've seen in the 12kV cable before.
16 MS. ZAMEK:
Okay, thank you.
Exhibit 20, the on-17 site review group, this takes me back to one of my original 18 questions.
On page 2, at the top, first paragraph, 19 "The cable is not designed for 20 submergence but is being exposed to this 21 condition."
l I
22 And on the second paragraph it says, l
23 "The cable has been degraded due to 24 repeated submergence over the past 20 25 years."
("C)/
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]
1 I understand that this was -- they were just starting their i
2 investigation, but I get the 20 years and I got the 1987 and 3
has anybody located that information yet, about how long --
4 MR. REPKA:
Before the witness answers that, I 5
want to ask Ms. ZamEk to t'ry to be clear which cable we're 6
talking about because there are several different cables 7
involved here.
And when we refer to the cable loosely we're 8
-- it's just confusing the record.
7 9
MS. ZAMEK:
Well, there seems to be, there's only 10 one cable that had trouble with -- that continued 11 submergence.
12 MR. GIFFEN:
The none safety related cable.
i 13 MS. ZAMEK:
Okay.
14 MR. GIFFEN:
That's the one that had a submergence i
O 15 issue.
16 MS. ZAMEK:
This one is the 4kV.
i 17 MR. GIFFEN:
That's safety related cable.
The 18 submergence issue is concerning the 12kV cable.
We looked 19 at it and the analysis is that that cable was probably 20 submerged and that's what might have been carrying a 21 contaminate that caused the chemical attack to the cable.
22 The 4kV cable, we looked at it and there was no indication 23 that water had anything to do with the issue.
l 24 MS. ZAMEK:
Well, in the OSRG then on page 2 it 25 looks as though they're referring to the 4kV cable.
l ANN RILEY & ASSOCIATES, LTD.
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MR. GIFFEN:
They probably were.
But they also --
2 that was -- I think there's another OSRG report that goes on 3
and talks about where the problem, they're not really sure 4
that what they said here was correct.
5 MS. ZAMEK:
So, were both the 4kV and the 12 kV 6
both have the submergence problem, is that correct?
7 MR. GIFFEN:
No.
12kV cable had a submergence 8
problem.
9 MS. ZAMEK:
And the 12kV does not?
10 MR. GIFFEN:
12kV had a submergence problem.
11 MS. ZAMEK:
But you still don't know the root 12 cause?
13 JUDGE BECHHOEFER:
Did you mean to ask whether the 14 4kV had --
k_"
15 MS. ZAMEK:
Pardon?
16 JUDGE BECHHOEFER:
Did you mean to ask -- you 17 repeated the 12 twice.
18 MS. ZAMEK:
Oh, did I?
19 JUDGE BECHHOEFER:
Yes.
Did you mean to ask about 20 the 4?
21 MS. ZAMEK:
Yes.
22 JUDGE BECHHOEFER:
Well, feel free.
l 23 MR. REPKA:
I believe the question is, did the 4kV 24 cables have a submergence problem?
25 MR. ORTORE:
There was no submergence problem.
i ANN RILEY & ASSOCIATES, LTD.
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Yes, they may have been -- they may have been submerged-in 2
water for some period of time.
But all of our investigation 3
showed that there was no indication of any water intrusion 4
into the installation.
So, we don't see that as being a 5
problem.
j 6
MS. ZAMEK:
But you don't know the root cause yet i
7 though, for sure, right?
?
8 MR. ORTORE:
We have ruled out many, many.
('
9 possibilities, but we have not been able to detect one, or, 10 as Mr. Giffen said, we may never be able to find the root 11 cause.
12 MR. GIFFEN:
But the indication that we get from i
i 13 the different labs don't -- they don't lend themselves to i
14 say that it's a water intrusion issue when they dissected l
15 and bisected the cables and looked at the pieces, there was' l
t 16 no indication of water damage to any of the cable, the 4kV i
17 cable.
i 18 MS. ZAMEK:
Okay.
Now one of my original l
19 questions was how long these cables, any of them, have been 20 submerged?
Are they always submerged?
One said 20 years, i
21 periodic, repeated submergence over 20 years, could that be l
22 possible?
l l
23 MR. ORTORE:
Based on some of the experience that 24 we have within PG&E we have installed over 5 million feet of i
i 25 very, very similar cable, if not the same cable, in these i
O.
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i i
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.i 1
similar applications throughout PG&E and they have been 3
O 2
installed for much longer periods than 20 years without any 3
degradation and based on that type of input, based on what
.j 4
all our contractors and test facilities have told us, we 5
just -- we don't think -- we don't see the possibility of 6
water creating the problems in the 4kV cable.
7 MR. GIFFEN:
But the question -- the way I thought t
8 you asked the question, could the cable have been submerged 9
for 20 years, my answer to that would be no because we have 10 inspected the pull box, there wasn't water in it all the 11 time.
What happened is the sump pumps didn't work.
They i
12 got inadvertently left out of our preventive maintenance
{
13 program.
When it rained the sump would fill up with water i
14 and if it would fill up to the points where the conduit i
15 would run then the conduits would get water in them and i
1 16 after then the drains, the water would drain out of the sump 17 and then the water would drain out of the conduit.
So, it 18 was a rain problem.
19 MS. ZAMEK:
And how long were these sump pumps --
20 MR. GIFFEN:
As I told you, I don't remember off l
21 the top of my head.
I can get it for you and get back to I
l 22 you after the break.
j l
23 MS. ZAMEK:
I read 1987 at one point, would have 24 been --
25 MR. GIFFEN:
Pardon?
j O
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MS. ZAMEK:
I read-1987, they'd been inoperable.
O 2
MR. GIFFEN:
I'm not going to speculate, I'll get j
l 3
the answer for you.
1 4
MS. ZAMEK:
Okay.
Let's move to Exhibit 21, page 5
four.
i 6
JUDGE BECHHOEFER:
One clarification, has water r
7 exposure been one of the methods formerly ruled out of your l
8 root cause analysis?
9 MR. ORTORE:
Just to recap this, the 12kV cable 10 was -- there was degradation of the 12kV cable.
We believe 11 that that was formed by some contaminate that was carried to 12 the cable by water.
The cable then, the jacket, by being l
13 submerged in this water, there was degradation of the outer 14 jacket which allowed chlorides that were contained in the
,O i
l 15 salt water that was washed into the conduits to attack the i
16 shielding, copper shielding.
This created uneven electrical l
17 stresses on the cable which caused a fault.
This was only
[
l 18 in the 12kV cable, f
i l
19 In the 4kV cable there was no degradation of the
(
20 cable whatsoever.
It was inspected, and in some cases it's 21 electrical properties were as new.
And it is the 4kV cables 22 that we have been unable to determine the root cause.
We 23 know that the root cause was definitely contamination to the 24 12kV cables.
25 MR. GIFFEN:
And that the water was the medium ANN RILEY & ASSOCIATES, LTD.
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7 - _. - ~. _.
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1 that carried the contaminate to the 12kV cables.
2 JUDGE BECHHOEFER:
Right.
Water has not been 3
ruled out for the 4kV cables?
4 MR. ORTORE:
It has definitely been ruled out as 5
water intrusion into the cable causing the faults, yes.
6 JUDGE BECHHOEFER:
Oh, okay.. Because you had said 7
there was some methods that had been ruled out.
8 MR. ORTORE:
Water's one of them.
9 JUDGE BECHHOEFER:
Okay, that's what I was trying 10 to find out.
11 MS. ZAMEK:
Okay, Exhibit 21 is an engineering 12 report from ALTRAN and May 6th, 1993.
I'd like you to look 13 at the top of page four.
In the_first paragraph _it says, i
14 "Though water has not been specifically O
15 implicated as the cause for-the 4kV l
16 cable failures, the use of neoprene or 17 Hypalon jacketing materials is not what 18 we would suggest.
Instead, the cables 19 should be protected with a lead moisture 20 barrier with an overall linear low 21 density polyethylene jacket.
If this 22 cannot be accommodated due to 23 installation and/or engineering l
24 constraints, an LLDPE - "
l l
25 which is the polyethylene jacket, ANN RILEY & ASSOCIATES, LTD.
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"-- should be used in placed of the 2
Hypalon.
Careful monitoring of the 3
installed Hypalon jacketed cables i
4 through the next outage is suggested."
5 So, I would like to know two things.
One, why you chose to 6
replace the cable with the original material that failed and 7
why did --
8 MR. GIFFEN:
Let's stop there and answer that 9
question first.
I 10 JUDGE BECHHOEFER:
Yeah, let's do one at a time.
11 MS. ZAMEK:
Okay.
12 MR. ORTORE:
Could you repeat the question, 13 please?
14 MS. ZAMEK:
Why did you choose to replace the 15 failed cables with the same material despite the 16 recommendation to do otherwise?
17 MR. ORTORE:
Again, there is no reason to believe 18 that there is any deficiency in the cable that we used in 19 1972, although some products that are created today may be 20 of better quality.
Therefore, we have used the same cable j
21 that was specified in our design as a replacement cable.
22 MR. GIFFEN:
In addition, the cable lasts a long 23 time and there's no imminent failure, no one thinks that 24 there's any reason why that we have an imminent problem with 25 these cables.
And to answer your -- this came after the ANN RILEY & ASSOCIATES, LTD.
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l l
1 cable failure.
So, the recommendation that you're saying, i
l i
2 why didn't you use it, it was after the cable had already 3
been replaced.
This is dated in May of
'93.
4 MS. ZAMEK:
Okay, that leads me to my next l
5 question, how are you monitoring the cables now?
6 MR. ORTORE:
All our cables are periodically i
i 7
tested, usually at an outage in combination with testing the 1
8 equipment load that's connected to it.
We do various tests 9
of the cable.
As a matter of fact, in two of these cable 10 failures these failures were not actual failures that 11 occurred while the equipment was in service.
Two of them 12 were identified by our testing.
One in the 12kV and one in 13 the 4kV.
So, we do periodic testing on these cables to 14 insure their ability to do their function and that's how we 15 detected some of these failures.
l 16 MR. GIFFEN:
On the 4kV cable there's a ground 17 systems installed.
And there was an indication on both 18 failures of the safety related 4kV cable, there was an 19 indication in the control room that there was a momentary 20 ground on these cables.
The pump was taken out of service, 21 declared inoperable.
We went then to try to find how the 22 cable failed.
Cable normally runs at 4,000 volts.
We did a 23 hi pot on it of greater than 6,000 volts in an attempt to 1
24 find the location of the fault.
So, that the cable failed 25 while we were trying to find the failure point.
So, it did ANN RILEY & ASSOCIATES, LTD.
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not fail in service.
l O
2 MS. CURRAN:
I'd like to ask a follow-up question 3
on this, Mr. Giffen.
If a cable is going to fail will that 4
always be indicated by a grounding signal?
Let me put that 5
another way.
If a safety related cable, if its safety l
l 6
function is somehow compromised by degradation or some 7
design fault, will the lack of -- will the incompetence of 8
the cable to function during an accident always be revealed j
9 by a ground signal?
10 MR. GIFFEN:
In this, the way that this one failed l
r 11 if it failed --
12 MS. CURRAN:
I'm asking -- could you answer that 13 question, I'm asking a hypothetical question,-not about this i
14 example?
l 15 MR. GIFFEN:
That's what I'm trying to figure out.
16 I'm trying to answer your hypothetical question.
If the t
l 17 cable failed due to a ground there would be a ground alarm, i
18 would come in first, yes.
If it did fail then the alternate i
19 pump would start.
But this cable, if it failed, just, I'm 20 not sure if it would have a ground come in or not.
21 MS. CURRAN:
But what I'm --
22 MR. ORTORE:
The groundings -- can I please?
23 MS. CURRAN:
Okay.
24 MR. ORTORE:
The grounding system, more the medium 25 voltage cable, does -- is designed to operate for a minimum O
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of one hour after a ground fault is alarmed, or is l
2 discovered.
l 3
MS. CURRAN:
What I am asking is that whether 4
grounding alarms will necessarily be sounded for cable that l
5 is incompetent or unqualified in some respect?
l 6
MR. GIFFEN:
I can't answer that question.
7 MS. CURRAN:
You don't know?
That's -- it's not 8
necessarily --
l 9
MR. VOSBOURG:
Well, I think our experience has 10 been that we --
11 MS. CURRAN:
-- true, is it?
f 12 MR. VOSBOURG:
Our experience has been that we 13 have received ground alarms when the cable has degraded.
It 14 has not failed, it was still performing its function, the 15 pump was running and we did receive ground alarms.
So, the 16 alarms are capable of detecting a degradation of the cable 17 installation prior to it failing.
18 JUDGE SHON:
But there are modes of failure.
For 1
19 example, an open cable or a shorted cable across the 20 conductors that wouldn't give you a ground alarm and it 21 would still be a failed cable, wouldn't it be?
I mean there 22 are ways it could fail without giving a ground alarm.
23 MR. GIFFEN:
Yeah, that's why I say, I can't 24 answer that question because you could have a face to face -
25
[)
(s ANN RILEY & ASSOCIATES, LTD.
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JUDGE SHON:
Yeah.
O 2
MR. GIFFEN:
-- that would ruin the cable and 3
there would be no ground, but if there was a ground in the i
4 cable it would be detected and alarmed in the control room i
5 prior to failing.
6 MS. CURRAN:
Or in other words, another way of l
7 putting the question is, the cable that performs adequately l
i 8
during normal operation may nevertheless fail under accident
{
9 conditions, is that correct?
10 MR. GIFFEN:
I don't think that -- I mean that's j
11 just another hypothetical question.
If this happened that i
12 would happen.
I can't answer the question if the cable --
13 when-it's going to fail and how it fails.
v 14 MR. VOSBOURG:
Well, additionally, there's no f
O-15 difference between normal operation and when the pump would 16 be functioning in a safety related mode.
The pump's running 17 or it's not.
The current through the cable is the same.
l l
18 So, there's nothing that would suggest that if we were in a 19 situation where the pumps were required to operate in a 20 safety related mode that there would be any reason that the 21 cable would fail at that point.
It's no different than its l
l 22 normal operating condition.
And one of those pumps is i
23 operating continuously.
24 MS. CURRAN:
Is this 4kV cable for which you don't 25 know the root cause of the failure, is it used in other ANN RILEY & ASSOCIATES, LTD.
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applications, safety applications in the plant?
l 2
MR. ORTORE:
Yes, it is.
3 MS. CURRAN:
Is it used in safety applications in 4
a harsh environment?
5 MR. ORTORE:
Yes, it is.
6 MS. CURRAN:
All right.
7 MR. ORTORE:
And it has been qualified for those 8
environments.
9 MS. CURRAN:
But you do not know the root cause of 10 why this particular cable failed, that's right?
11 MR. GIFFEN:
That's correct, we do not know.
12 MR. ORTORE:
Correct.
13 MS. CURRAN:
And this root cause could be common 14 to any of the 4kV cable of that type that's installed in the 15 plant, is that correct?
i t
16 MR. ORTORE:
Again, we have locked at many 17 possibilities of what if can be that would lead to this 18 failure and we have not been able to -- we have ruled out 19 many, many possible failures.
And these may just be 20 isolated point failures that occurred and we may never see 21 one of these again.
That is a possibility.
22 MS. CURRAN:
Or it could be that this is a 23 common -- this is a failure mode, a cause that's common to 24 all of the 4kV cable and you just don't know the answer?
25 MR. GIFFEN:
We don't -- I don't believe that's ANN RILEY & ASSOCIATES, LTD.
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l 1
the case.
I mean based upon the inspection, the evaluation, 2
going back to the vendor, looking at the cable, chopping it 3
up, in order to make some of this cable fail we'had to have 4
the vendor take it in excess of 60,000 volts.
We don't 5
think there's an imminent problem with this cable.
And i*
l 6
may be there were two' failures, two grounds, cause unknown, I
7 separated by several years, but I don't really believe that 1
8 there's a serious issue.
We're taking it seriously, we're j
l 9
looking at new cables, we're going to look at monitoring 10 techniques, but I don't think that there's a generic issue i
11 of why that happens, that's in my opinion.
l 12 MS. ZAMEK:
I had one more question on the
[
13 monitoring.
I heard how you monitored, has there been a
{
14 change, as of now, from what you -- how you monitored the 15 cables before you experienced the cable failures and now
{
l 1
l 16 after, and you've replaced the cables, is the monitoring i
17 system the same or has it changed?
i 18 MR. ORTORE:
We have not changed our current 19 methods, however, there are various considerations that are 20 being looked at in our study.
21 MS. ZAMEK:
Okay, thank you.
22 JUDGE BECHHOEFER:
Let me interject something.
23 Does the matter like the 4kV cable, the failure to find a 24 root cause, does that get carried, something like an 25 unresolved safety issue, and if not, why not?
()
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MR. GIFFEN:
We're tracking -- our method of 2
tracking things that are of concern to us were non-3 conformance reports.
We've also written a voluntary LAR to 4
the NRC explaining this and it's being tracked through both 5
those mechanisms.
So, we are tracking it and following it.
6 We haven't given up hope yet that we will find the answer to 7
the problems and be able to address it if it becomes a 8
concern.
9 JUDGE BECHHOEFER:
All right.
So, it is 10 essentially carried as an unresolved question?
11 MR. GIFFEN:
It's an unresolved issue, a 12 non-conformance report.
13 JUDGE BECHHOEFER:
Yeah, right.
14 MS. CURRAN:
That concludes our qpestioning on the l
15 cables.
l l
16 JUDGE BECHHOEFER:
Do you have rebuttal?
l l
17 MR. REPKA:
Just a couple questions.
Number one, 18 of the 4kV cable failures and the 12kV cable failures that 19 have been discussed, or incidents, not all are failures, 20 were any detected solely by observing smoke?
21 MR. VOSBOURG:
No, the first indication in all 22 cases was a ground alarm in the control room.
The design of l
23 the -- in the case of the 12kV, it has a high resistance 24 ground system, such that if there is a ground fault there's 25 a resistor bank located in the plant that's designed to heat ANN RILEY & ASSOCIATES, LTD.
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up and dissipate the ground current to limit the ground 2
current.
So, there was not a fire, but when you have a hard 3
ground on the 12kV system these resistors heat up as 4
designed and usually if there's any dust that collected on 5
them it does produce smoke in the room.
There is a smoke 6
detector in the room and in the case of this event it was 7
set off by the smoke from the ground bank resistors 8
functioning as they were designed.
9 MR. REPKA:
And that was for one of the 12kV 10 incidents?
11 MR. VOSBOURG:
That was the 12kV, yeah.
12 MR. REPKA:
Focusing on the 4kV failures, or 4kV 13 incidents, two of the three were safety related, is that 14 correct?
15 MR. VOSBOURG:
Yes.
16 MR. REPKA:
And one of the three was the result of 17 high potential testing, is that correct?
18 MR. ORTORE:
Correct.
It failed while we. were 19 testing the cable.
20 MR. REPKA:
So, there are two in-service safety 21 related cable incidents involving ground fault indications, 22 is that correct?
23 MR. ORTORE:
Two that occurred while the pump was 24 operating.
The ground fault came in, we were able to start 25 the redundant pump and then secure the pump that the ground O
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1 floor came in on.
l 2
MR. REPKA:
So, when these -- if something were to 3
happen to these cables there are systems in place, back-ups 4
to serve the safety function?
5 MR. ORTORE:
Correct.
The redundant pumps were l
6 started to do that.
7 MR. VOSBOURG:
Additionally, in the case of the 8
auxiliary salt water system, in. addition to a redundant i
i 1
9 safety related train, there is a cross tie to the other unit j
1 10 that would also make the other units pumps available to the 11 other unit.
So, you can supply either Unit 1 or Unit 2 from l
12 the other unit in addition to having two trains on each 13 unit.
l I
14 MR. REPKA:
So, in looking at corrective actions l
15 it's fair to say you look not only at the root causes that j
16 have been identified, but you look at the configurations and j
l 17 the applications of the cable, isn't that correct?
i l
18 MR. ORTORE:
Yes, that is correct.
1 l
19 MR. REPKA:
With respect to the 4kV failures, as I l
}
20 understand it there are two incidents separated by at least 21 a couple of years.
Could you explain to me why that gives 22 you confidence that you can study this issue further without 23 taking immediate action?
24 MR. GIFFEN:
Because I believe that the cable that 25 had failed, the first cable that failed, that failed on Unit ANN RILEY & ASSOCIATES, LTD.
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2, we looked, we couldn't find any immediate cause.
We 2
continued to investigate.
When the second cable failure 3
happened three years apart, it didn't seem like that 4
immediate action had to be done right vay, that we could 5
look at it and try to figure out what the cause was and then 6
perform the action that makes sense for the circumstances.
7 And we wanted to really make sure that we understood and we 8
didn't believe that we were placing the plant in any bad 9
condition by waiting and trying to determine the root cause.
10 MR. REPKA:
Now the 4kV cable that has been 11 replaced, Mr. Ortore you said that it's been replaced by 12 cable of different vintage.
Can you explain what you mean i
13 by that?
14 MR. ORTORE:
Meaning it was not replaced by cable 15 that we procured in 1972, that it was of the same type cable 16 that we have purchased subsequent to the original 17 construction of the plant.
18 MR. REPKA:
Of more recent manufacture?
19 MR. ORTORE:
Correct.
20 MR. REPKA:
Is manufacturing -- a manufacturing 21 defect, is that one of the root causes, potential root 22 causes you've analyzed?
23 MR. ORTORE:
That has been ruled out, after 24 extensive tests of the cable by various labs, by the cable 25 manufacturer, we have ruled out that there was any failure ANN RILEY & ASSOCIATES, LTD.
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1 due to any manufacturing defects.
s 2
MR. REPKA:
With respect to the sump pumps, the 3
inoperability of the sump pumps relates only to the 12kV 4
failures, does it not?
5 MR. GIFFEN:
Yes, but the fact that the 4kV cable i
6 runs in the same duct work, in the same bank, higher up, we 7
did -- it's -- you can't just say that the sump pumps were i
8 only related to 12kV.
Because the pump -- the 4kV cable 9
runs in the same duct work.
10 MR. REPKA:
But since moisture wasn't a cause of 11 the 4kV --
12 MR. GIFFEN:
Yeah, we don't believe that the fact l
13 that the sump pumps didn't work was a problem for the 4kV, l
14 but because they're in the same location I wanted to answer.
(
l 15 MR. REPKA:
Now are the sump pumps safety related 16 equipment?
17 MR. GIFFEN:
No, they're not.
18 MR. REPKA:
And there was an organization 19 responsible, was there not, for the sump pumps prior --
20 MR. GIFFEN:
Yeah, there was an organization at 21 the plant that was responsible for the maintenance.
It was 22 not included in my maintenance program.
l 23 MR. REPKA:
But it now is?
24 MR. GIFFEN:
Yes, it is.
25
[ Pause.]
l ANN RILEY & ASSOCIATES, LTD.
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MR. REPKA:
Ms. Curran asked you about other N/
2 applications of the 4kV cables, do you recall that j
3 discussion?
4 MR. ORTORE:
Yes.
5 MR. REPKA:
And are any of these other 6
applications in submerged conditions, potentially submerged 7
conditions?
8 MR. ORTORE:
No, not that we are aware of.
There 9
are no other applications that would be submerged.
10 MR. REPKA:
We discussed the ALTRAN recommendation 11 for the 4tV cables, do you recall that discussion?
12 MR. ORTORE:
Yes.
13 MR. REPKA:
And will PG&E consider that I
l g
recommendation after it completes its recommendation of 14 V
l 15 these incidents?
l 16 MR. ORTORE:
Yes, that is all information that we 17 have received from various test labs will be considered and 18 yes, we will consider that in our final decision.
19 MR. REPKA:
Okay.
Now there's -- with respect to 20 Exhibit 20, that's a November 1992 OSRG and in there, in 21 that document -- there was some discussion in that document j
22 regarding these incidents and the causes, possible causes.
l 23 Do you recall that?
l 24 MR. ORTORE:
Yes.
25 MR. REPKA:
Now is it fair to say that that
)
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l l
664 discussion has been superseded by more recent investigation?
1 2
MR. ORTORE:
Yes, the OSRG issued a subsequent 3
report that stated that these statements here were probably 4
premature and said that the action being taken by the ETRG 5
and by the follow-up investigation team was proper and that 6
they would rely on their efforts.
7 MR. REPKA:
I have no further questions.
8 MS. CURRAN:
I'd like to ask one follow-up 9
question, if I might, to Mr. Repka's question?
Earlier you 10 were asked about back-up systems in the event that the 4kV cable failed, could you describe those back-ups again?
11 12 MR. GIFFEN:
For the auxiliary salt water system?
13 MS. CURRAN:
That's what the 4kV cable serves, g
14 right?
(
15 MR. GIFFEN:
Yes, ma'am.
16 MS. CURRAN:
Uh huh.
17 MR. VOSBOURG:
Well, basically, on each unit there's two trains of auxiliary salt water, two complete 18 19 trains.
Each one of those trains can be cross-tied.
Say on 20 Unit 1 there's train A and train B, there's a cross-tie between those trains such that either pump can supply either 21 22 heat exchanger.
In addition, there's a cross-tie between the two units such that I could take the B train from Unit 2 23 24 and supply either train, A or B, on Unit 1 or vice versa.
25 So, if I were to lose, for some reason, both trains on one ANN RILEY & ASSOCIATES, LTD.
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i 1
unit and that unit needed auxiliary salt water, I would have j
2 the capability to use one train from the other Unit to l
t 3
supply that Unit.
l i
4 MS. CURRAN:
Are all four of those trains served
\\
5 by the 4kV cable?
f f
6 MR. VOSBOURG:
Yes, the same cable is used in all 7
four.
8 MS. CURRAN:
So, if this unknown cause of the 4kV-l l
I 9
cable was affecting all four of them you could have a l
l 10 potential common mode failure in that safety system, could 11 you not?
12 MR. VOSBOURG:
I don't believe so,"because again, i
13 there's no event that would cause -- that would trigger the 14 common mode failure.
If these are related, you know, in 15 time, you would have to have the same failure on four cables 16 randomly at the same point in time to have an effect.
And j
g t
17 there's no difference --
i 18 MS. CURRAN:
You're saying that's impossible, is 19 that what you're saying?
l 20 MR. VOSBOURG:
I'm sorry?
21 MS. CURRAN:
You're saying that's just not 22 possible, is that what you're telling me?
23 MR. VOSBOURG:
It's extremely unlikely.
Over 24 the -- you know, in the course of years we've had two 25 indications of degradation of the cable years apart, to O
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1 postulate that four cables would have failures at the same 2
point in time with no other factor causing -- influencing 3
the failure mechanism I think it's pretty much impossible, 4
yes.
5 MS. CURRAN:
But the fact remains that you do not 6
know what caused that failure in the 4kV cable?
7 MR. REPKA:
Objection, argumentative.
8 MS. CURRAN:
All right.
9 MR. VOSBOURG:
Just to answer that though, 10 however, there is no difference between the pump operating 11 in its normal mode, which it does continually, and its 12 safety related mode.
So, I mean it's not like you challenge 13 the cable, you don't put any additional stress on it at any 14 point in time when you have a safety injection.
One of the i' (
15 pumps is always running, so, there would be no difference to t
16 that pump to cause something else to fail.
17 MR. GIFFEN:
We were also concerned with the cable J
18 failures, two failures in three years.
So, we did a -- we
)
19 took our plant, probabilistic risk assessment, and we
)
20 plugged those two failures into the model to determine if 21 there was any change and there was hardly any change in the l
22 results of the PRI.
So, we are looking at the questions 23 that are being raised.
24 MS. CURRAN:
That's all.
25
[ Judges confer.]
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i 667 1
JUDGE BECHHOEFER:
First, we have a few follow-up 2
questions, but first an inquiry.
Does anybody, and I'm 3
leaving it open because I don't know, does anyone plan to 4
put into the record the LSRG report that, the follow-up on 5
Exhibit 20, the one that supersedes Exhibit 20?
We had 6
testimony that it was superseded so, I wondered whether 7
anyc.ne plans to offer that because I think for a complete 8
record we ought to have that.
9 MR. REPKA:
We would be willing to offer that.
I 10 don't have copies right at this instant.
11 JUDGE BECHHOEFER:
Well, no, I'm not expecting 12 that.
13 MR. REPKA:
We'll take that as a follow-up later.
14 JUDGE BECHHOEFER:
With respect to the questions 15 you were asked about whether four failures might be 16 considered a common mode failure.
Is it conservative not to 17 consider it a common mode failure absent the finding of a 18 root cause for the failures that occurred?
Can it be 19 conservative, just sort of write it off and say it can't be i
20 a common mode failure before you find out what caused it?
l 21 MR. GIFFEN:
Well, first, there's only two failures of the 4kV cable not four, of the safety related 22 23 cable.
24 JUDGE BECHHOEFER:
The way I understood the 25 question was there were four.
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MR. GIFFEN:
Yeah, there's two failures of the i
2 safety related cable occurred and based upon the fact that l
3 they were three years separated is the reason that -- you 4
know if they had both occurred within 15 minutes or a day of l
l 5
each other, a short period of time I think that how we 6
approached it would have been tremendously different.
But 7
to be-a common mode failure I don't think it can be 8
separated by three years apart.
f 9
JUDGE BECHHOEFER:
I see, okay.
I 10 MR. VOSBOURG:
And again, to put it in.
11 perspective, the first pump that had an_ indication of a 12 ground or degradation was on-line at the time.
The second
{
13 4kV cable that dealt with the salt water pump was found 14 while we were doing hi-pot testing, well the pump was 15 cleared for another reason, it didn't occur on-line.
And 16 the cable did not have any indications on-line of having a 17 problem.
When we did the hi-pot test and stressed the l
l 18 insulation at that point, I believe it was at 6,000 volts, l
19 that we saw an indication of the cable breakdown at that, 20 and there's some thought that it's possible that the hi-pot l
21 test itself can cause a degradation in the cable.
22 JUDGE KLINE:
We've been proffered a number of 23 NCRs, a number of which have been labeled draft.
And I'm 24 wondering what your custom is at the plant as far as 25 labeling these things draft.
Does that-imply that there's a ANN RILEY & ASSOCIATES, LTD.
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669 i
l 1
subsequent version of the same NCR to be published or likely j
l
\\>
2 to be published or likely to be prepared?
3 MR. GIFFEN:
When we start -- just a little of how 4
this process works.
After something occurs which requires a 5
non-conformance, whatever it is, within five days a i
6 technical review group %ill convene and they'll start 7
talking about what happened, figure out how we're going to 8
do the root cause anulysis, just have an overview of what 9
happened.
And then someone goes away and writes it.
And 10 that comes back and it's a draft, and I don't think any of 11 these -- but there's a place in one of the forms for 12 signatures --
13 JUDGE KLINE:
Well, Exhibit 17, in the latest 14 group is labeled draft, March 12, 1993.
15 MR. GIFFEN:
There's another page that goes on 16 this that has a signature sheet.
And so,-when the NCR is 17 completed then it's signed on the front by the chairman and 18 all the members.
So, this is missing one page of the non-19 conformance report.
20 JUDGE KLINE:
So, the text would remain 21 essentially the same in whatever your final version, is that i
22 right?
23 MR. GIFFEN:
Yeah, and each time, if they have a 24 meeting, then they go back and new information comes in and 25 then they change the written word.
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JUDGE KLINE:
Yeah, I'm just trying to clarify 2
what the Board should do, you know, in evaluating these 3
things whether or not we should have in mind that some 4
subsequent version may have been prepared or not.
And my 5
understanding now is that likely not, even though it's 6
labeled draft, 7
MR. GIFFEN:
There may be changes in fact --
8 JUDGE KLINE:
-- this is the final views?
I l
9 MR. GIFFEN:
At that time.
l 10 JUDGE KLINE:
Yeah.
Well, now I'm still confused.
11 MR. ORTORE:
This document is essentially still 12 open.
The document will be closed --
13 JUDGE KLINE:
It's still open?
14 MR. ORTORE:
-- it will be finalized and it will i
15 be -- every NCR is eventually closed.
There is no intention 16 to leave this open.
It is just a draft while the 17 investigation is ongoing.
18 MR. VOSBOURG:
And it may change between now, the 19 document you're looking at, and what the final -- there may 20 be information --
21 JUDGE KLINE:
So, we can't look at this --
l 22 MR. VOSBOURG:
-- information added.
23 JUDGE KLINE:
-- as your final word on your own i
24 analysis, is that correct?
25 MR. VOSBOURG:
Correct.
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(
s 1
JUDGE KLINE:
I'm still confused on the nature of 2
the contaminate intrusion.
And on page 109, in the middle i
3 of your page there of your testimony you speak in sort of 4
general terms of contaminates.
In some of your previous 5
testimony you mentioned chloride intrusion and yet somewhere 6
in this group of exhibits was mentioned a sulfuric acid 7
sodium hydroxide neutralization incident.
I guess I'd just 8
like to clarify where we stand on that.
9 MR. ORTORE:
Okay.
That letter that was 10 originally an exhibit and then was withdrawn was just one 11 engineer writing to another with a suggestion, a possibility 12 of a spill that we might have had that could have gotten 13 into the conduit.
We've, again, we've investigated all the 14 spills, the history of spills in that area that could have 15 possibly got into the conduit and none of the identified 16 spills was the contaminate that caused it.
We believe it 17 was some sort of cleaning agent that somehow got into the 18 conduit.
And there was sort of a one-two punch, the fatty i
19 acid that was in this cleaning agent over a long period of 20 time degraded the jacket of the cable.
Once the jacket was 21 degraded that allowed the chlorides from the washed off salt 22 water to get in and damage the copper shield.
Once the 23 copper shield was damaged that created uneven electrical 24 stresses that caused default.
25 JUDGE KLINE:
I might point out, again, in Exhibit ANN RILEY & ASSOCIATES, LTD.
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~j 672 l
1 21 that letter reappears as an attachment, j
2 MS. ZAMEK:
That was a mistake.
3 JUDGE KLINE: -Are you withdrawing that?
t l
4 MS. ZAMEK:
Yes.
t 5
JUDGE KLINE:
Okay.
6 MS. ZAMEK:
That was just inadvertently stapled i
7 together.
~;
l 8
JUDGE KLINE:
You don't want that in the record, l
l 9
is that correct?
l i
i 10 MS. ZAMEK:
No, that's correct.
I I
I 11 JUDGE KLINE:
The letter that indicates the 12 sulfuric acid contamination, my understanding now is that f
13 sulfuric acid is out of the picture, is that right?
14 MR. ORTORE:
Yes.
15 JUDGE KLINE:
But the rest of 21 you still want?
l l
16 MS. ZAMEK:
Yes.
l 17
[ Pause.]
18 JUDGE KLINE:
When you speak of four trains 19 involving 4kV cable, my understanding is that there are four l
20 different installations of 4kV cable, is that correct?
l 21 MR. VOSBOURG:
Two auxiliary salt water pumps.
22 JUDGE KLINE:
And they are not running through the 23 same physical structures?
24 MR. VOSBOURG:
That's correct.
25
[ Pause.]
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MS. CURRAN:
Your question, Judge Kline, just 2
raised another one in my mind.
3 JUDGE BECHHOEFER:
That's all right.
I was just 4
going to --
5 MS. CURRAN:
I don't know the answer to this and 6
perhaps you all know, can Unit 2 safety components be 7
credited for accident mitigation in Unit I?
Suppose there 8
is an earthquake or something that affected both units, you 9
can't really credit --
10 MR. VOSBOURG:
No, we don't take credit in our 11 design basis for the other units' auxiliary salt water 12 pumps.
That was just -- that was an indication of the level 13 of redundancy that we have.
Again, you didn't postulate a 14 particular event, but that was giving you the level of 15 redundancy that we would have for the aux salt water pumps 16 in making, you know, some of our determinations on prudency 17 in looking at these cables.
18 MR. REPKA:
Can I follow-up on that?
You don't 19 take credit for it in licensing terms, correct?
20 MR. GIFFEN:
Yes.
21 MR. REPKA:
But that does not mean the cross-tie 22 that you just talked about, that does in fact exist?
23 MR. VOSBOURG:
It exists, yes.
24 MR. GIFFEN:
Well, and the operators, as Dave was 25 one, knows that if he had to get auxiliary salt water ANN RILEY & ASSOCIATES, LTD.
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i somewhere and he has the capability of getting it from the O
l 2
other Unit, but you can't take credit for it.
j 3
[ Pause.]
4 JUDGE BECHHOEFER:
Do you have any further follow-5 up questions?
I 6
MS. CURRAN:
No.
We're ready to move on.
]
7 JUDGE LECHHOEFER:
Okay.
Do you have any further l
8 follow-up?
9 MR. REPKA:
No, at this time are we going to move 10 the documents into evidence or --
11 MS. CURRAN:
Yes, we need to move these exhibits, 12 which are numbers 14 through 21 into evidence.
13 MR. REPKA:
That's 14 through --
1 14 JUDGE BECHHOEFER:
Each with the amended numbers -
0-15
- each with the -- the two substitutes?
16 MS. CURRAN:
Yes, including the substitutes that 17 were previously identified.
i 18 JUDGE BECHHOEFER:
All right.
19 MS. CURRAN:
And that includes number 21.
20 MR. REPKA:
I'll withdraw my earlier objection and 21 not object to these documents and --
l 22 JUDGE BECHHOEFER:
The last page of 21 being 23 stricken?
24 MR. REPKA:
The last page of 21 being stricken and 25 we will, at some convenient time, bring the subsequent OSRG ANN RILEY & ASSOCIATES, LTD.
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1 that supersedes Exhibit 20 and we will offer that into N-)
2 evidence when we have that available.
3 JUDGE BECHHOEFER:
That's okay with us, we accept l
4 that.
5 MR. REPKA:
Now we can move on.
6 MS. CURRAN:
All right.
7 JUDGE BECHHOEFER:
And, as stated, those documents l
8 are now admitted.
9 MS. CURRAN:
The next category involves anchor 10 darling check dowel cover dowels and the exhibits related to 11 that topic are Exhibit 22, LER 2-93-006-007 dated July 28th, l
12
'93 and NCR DCO-93-MM-N016 dated July 15th, 1993, and 1
13 they're being passed out to you now.
Both of these 14 documents discuss the same events which was the discovery of l
l 15
-- that bonnet dowel pins were basically not long enough as l
16 installed and that they were not sufficiently long to meet 17 their -- to provide an assurance that they could meet their l
18 design function.
19 MR. REPKA:
I think it's enough to say that they 20 relate to the same incident.
I don't think we need counsel 21 testifying as to what the documents say or what they -- what 22 they represent.
I think I'm prepared to follow-up to the 23 offer of the exhibits and ask the witnesses what they 24 involve, and I would prefer that characterization to l
I 25 counsel's characterization.
j l
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JUDGE BECHHOEFER:
I think you should identify 22 lC:)
l 2
and 23.
I thought you just said 22.
3 MS. CURRAN:
Oh, I'm sorry.
That's correct.
22 l
i 4
and 23.
(
5 JUDGE SHON:
Okay.
Ms. Curran, on your little 6
road map here with the list of exhibits --
7 MS. CURRAN:
Yeah.
I 8
JUDGE SHON:
At page 4.
l 9
MS. CURRAN:
Yes.
i 10 JUDGE SHON:
At the bottom of the page, these are i
11 Exhibits 22 and 23, are they not.
12 MS. CURRAN:
Oh, it says Exhibits 9 and 10.
13 JUDGE SHON:
Yes.
14 MS. CURRAN:
That was early in the evening.
It O
15 should have been changed to 22 and 23.
Thank you for j
t 16 pointing that out.
l i
1 17 MR. REPKA:
Does everybody have copies of the i
18 documents?
l 19 MR. GIFFEN:
Yes, we do.
i 20 MR. REPKA:
Are you prepared to discuss them?
21 MR. GIFFEN:
Yes.
Yes, I am.
l 22 MR. REPKA:
Briefly, what do these documents 23 report?
MR. GIFFEN:
These report the same event.
We were 24 in the process of doing preventative maintenance on a check j
25 valve in the plant, and we initial thought a dowel pin was j
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677 1
missing, and, in fact, the dowel pin was too short, and the O'
1 2
dowel pins are on the top of the valve on the bonnet, and 3
they hold the swing arm assembly down, and there was an 4
error on the -- the way that they were supplied to us the l
5 dowel pins were too short, and we found it, fixed the 6
problem and did a -- looked at where those valves were 7
used, where could the problem have -- how could the problem j
8 have occurred.
9 It was one that we found during maintenance, and i
10 even -- and as the Licensing Zvent Report -- it's a 1
11 voluntary LER again.
It says that, l
12 "The root cause of these events was l
13 manufacturer error and that the j
14 manufacturer supplied PG&E with l
15 equipment and drawings that did not l
l 16 comply with the original design 17 requirements."
18 For that reason, I don't really believe that this 19 is a maintenance issue.
20 MR. REPKA:
Well, does this incident represent a 21 problem with maintenance and surveillance?
22 MR. GIFFEN:
Well, it shows that, when you're 23 doing maintenance and surveillance, you could find if other 24 problems exist and then correct them.
So it shows that a l
25 maintenance program worked.
l ANN RILEY & ASSOCIATES, LTD.
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l 678 1
MR. REPKA:
And this was found during maintenance 2
and surveillance activities?
3 MR. GIFFEN:
Yes, it was.
4 MR. REPKA:
That's all the questions I have, and I 5
will object to admissibility of these documents, because the 6
incident does not reflect a problem in maintenance and 7
surveillance.
8 JUDGE KLINE:
I take it you have no pre-filed 9
testimony on this.
10 MR. GIFFEN:
No, sir.
11 JUDGE KLINE:
Is that correct?
l i
12 MS. CURRAN:
In your opinion, did the improper
{
(
13 length of the dowel pins compromise the reliability of the-l 14 check valve in any way?
15 MR. GIFFEN:
No.
We had an engineering analysis 16 done, and let me try to read that or find it in the LER.
17 "In April, we did an operability 18 evaluation, cone.luded that the check 19 valves of concern did not pose a 20 non-reviewed safety question."
21 MS. CURRAN:
I'm sorry.
I didn't hear that.
22 MR. GIFFEN:
I'm sorry.
In your Exhibit 23, on 1
23 page 5 at the top of the page, it talks where.we did an 24 operability evaluation.
It said that it wasn't a non-25 reviewed safety question.
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MS. CURRAN:
But it does say there that it poses a Os 2
concern for a seismic event, doesn't it, on the top of page 3
5?
4 MR. GIFFEN:
Yes, it does.
It says --
l l
5 MR. REPKA:
Again, whether or not it does, doesn't I
1 6
bear on the issue here, which is the adequacy of the 7
maintenance and surveillance program, and if maintenance 8
detects an equipment problem that shows the maintenance 9
program working, not a problem with a maintenance and 10 surveillance program.
11 MS. CURRAN:
If I could just finish my i
12 questioning, I'll get to that in a minute.
Page 7, section 13 4,
there's a section called " Analysis of the Event."
It
{
14 says that, 15 "The described condition of bonnet dowel I
16 pins of incorrect length creates the 17 potential for valve disk to seat 18 misalignment from a seismic event of 0.2 19 g ground acceleration or greater.
Valve 20 disk misalignment would result in i
21 reverse flow leakage but would not 22 affect the ability of the valve to pass 23 flow in the forward direction.
l 24
" Reverse flow leakage poses a potential 25 issue with respect to the ability of the ANN RILEY & ASSOCIATES, LTD.
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valve and associated system to perform 2
their design function."
3 Do you agree with that statement?
4 MR. GIFFEN:
Yes.
5 MS. CURRAN:
Okay.
You're familiar with the INPO 6
guidance document Number 90-008 entitled, " Maintenance 7
Programs in the Nuclear Power Industry," aren't you?
8 MR. GIFFEN:
Yes, I am.
9 MS. CURRAN:
And your program, essentially, relies 10 on this as a blueprint for your own maintenance program?
11 MR. GIFFEN:
We have the same elements in our l
12 program that goes through and are described in INPO 90-008.
13 MS. CURRAN:
Okay.
Do you agree with section 3.2, 14 which is entitled, " Engineering Support"?
Would you like me 15 to just show you --
16 MR. GIFFEN:
I can't say -- if you're reading from 17 INPO, I don't have it memorized.
18 MR. REPKA:
Again, this is not even the issue, 19 though.
It's not an engineering support issue.
It's a 20 piece of equipment that --
21 MR. GIFFEN:
The valve came from the manufacturer 22 with dowel pins of incorrect length.
It came from a safety 23 qualified supplier.
We found the valves during maintenance.
24 25 MS. CURRAN:
Okay.
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MR. REPKA:
And it was a voluntary LER, which, O
2 Mr. Giffen, what is the meaning of a voluntary LER?
l 3
MR. GIFFEN:
There's no -- there was no 4
requirement for us to submit this in any of -- in the new 5
reg, I think it's 1022.
However, because it was something 6
that could be of interest to the rest of the industry on 7
these particular valves, we issued this LER so the NRC then 8
could give it to whoever they wanted and do with it what 9
they wished, but it was to let the rest of the industry know 10 that there was a particular issue with these check valves.
I 11 MS. CURRAN:
Mr. Giffen, I'd like to read you the 12 first paragraph of section 1 of INPO 9F-008, which is 13 called, " Elements of Maintenance."
It says, 14
" Maintenance is considered to be the 15 aggregate of those actions that prevent 16 the degradation or failure of and that 4
17 promptly restore the intended functions 18 of structures, systems and components.
19 As such, maintenance includes not only 20 the activities traditionally associated 21 with identifying and correcting actual l
22 or potential degraded conditions, that 23 is, repair, surveillance and other 24 preventative measures but also extends 25 to supporting functions for the conduct ANN RILEY F ASSOCIATES, LTD.
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of these activities.
2
" Examples of these functions include 3
engineering support of maintenance, 4
operator identification of material 5
deficiencies and some aspects of 6
chemistry controlled radiological 7
protection and training."
8 Would you agree that this particular incident 9
falls under the category of operator identification of 10 material deficiencies?
l 11 MR. GIFFEN:
No.
" Operator" is a word meaning a 12 operator.
This was an event that was found during 13 maintenance by a maintenance, by a journeyman, by a i
14 craftsman, not by an operator.
I can say that it was found l
15 during a maintenance and during performance of our I
l 16 maintenance program we found this problem.
If that's l
17 maintenance, then it's a maintenance issue, but I believe 18 that the valve was supplied from the vendor this way, and we 19 installed it, and then my maintenance program determined i
20 that the vendor had given us one with dowel pins that were 21 inadequate length, and we rectified the problem.
l 22 MS. CURRAN:
Do you agree that it's one of the 23 responsibilities of the maintenance program to attempt to 24 detect problems with installation or incorrect parts as 25 installed equipment?
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1 MR. GIFFEN:
Oh, yes.
I really do, and, in fact, 2
we did.
3 MS. CURRAN:
That's right.
But it didn't happen 4
until quite a while after the original valve was installed,-
5 did it?
i 6
MR. GIFFEN:
It happened when the valve was-taken i
7 apart.
8 MS. CURRAN:
That's right.
9 MR. GIFFEN:
These dowel pins are inside the 10 valve, and then our check valve program says at a certain i
11 frequency we look at valves, and we take them apart to do i
12 that, and when we took this valve apart, we found the 13 problem.
l l
14 MS. CURRAN:
Was that the first time that valve i
15 had ever been taken apart?
16 MR. GIFFEN:
I'm not sure.
This probably was 17 because the pin was -- they thought was missing.
Some of l
18 the pins were short, but in order to -- they wouldn't move 19 in the hole.
You had to hit them with a hammer to determine 20 whether the pin was actually too short or not.
In this l
j 21 case, the pin fell out.
22 MS. CURRAN:
But this defect was visually apparent i
23 when the valve was taken apart?
l 24 MR. GIFFEN:
In this case, yes.
25 JUDGE BECHHOEFER:
Was this installed in, like, O
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1 1972?
i 1
l 2
MR. GIFFEN:
Probably.
I'm not sure, sir.
3 TUDGE BECHHOEFER:
And would you have had -- well, 4
you said you didn't know, but I wondered whether there would 5
hav.e been inspections subsequent to that but prior to the E
1993 one.
7 MR. GIFFEN:
And I'm not sure when and if that 8
valve had been disassembled in the past.
f l
9 JUDGE BECHHOEFER:
All right.
10 MS. CURRAN:
That's all my questions on this.
l l
11 MR. REPKA:
Just one other question, Mr. Giffen.
i 12 Would it be normal in the case of a valve of this type to l
13 disassemble it before installation?
14 MR. GIFFEN:
No.
When you buy a valve from a 15 qualified supplier, you're buying safety -- he has this 16 quality assurance program.
Then, when you receive the 17 component, you verify that it's what you got, but you do not 18 disassemble it to see that all the parts are what's 19 specified.
JUDGE KLINE:
So there is
)
20 no surveillance, let's say, of incoming spare parts?
I l
21 MR. GIFFEN:
There is if you buy them -- if we buy l
r 22 a part that's not from a qualified supplier that doesn't go i
23 to Appendix B criteria, then we specify what inspections 24 will be done, and we look at each component and pick the 25 critical function, and then we inspect those parts that make i
4
(
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1 l
1 sure'that it would do its function but not~from~a' qualified 1
'I 2
supplier routinely.
3 MS. CURRAN:
Is there_any. reason that one would l
4 take apart one of these valves other than if it were broken?
5 I
'I 6
MR. GIFFEN:
We take it apart to inspect it to j
7 make sure as a preventative maintenance item.
You can look l
8 at -- the check valve's function is to shut on reverse flow l
9 and past flow in the direction that you wish it to.
So some
{
t
]
10 of the ones we'd look at to make sure that all of the 11 components inside aren't wearing and then replace any l
12 component that indicates that it's wearing.
13 Another way you could do it, you could use -- you
{
14 can't put a fiber optic in some sort of opening in the valve i
15 and look at the internal, but, in this particu2ar case, the 16 only way that we had was to disassemble the valve.
17 MS. CURRAN:
So your preventative maintenance 18 program does include disassembling valves to look at them?
19 MR. GIFFEN:
Yes, it does.
20 MS. CURRAN:
But, in this case, that either had 21 not been done before or --
22 MR. GIFFEN:
It wasn't seen.
]
23 MS. CURRAN:-
It wasn't seen, j
24 MR. GIFFEN:
Or hadn't been done.
25 MS. CURRAN:
One or the other?
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1 MR. GIFFEN:
Yeah.
And I said I'm not sure 2
whether this valve had been taken apart, but also some of i
3 the ones that even when we took them apart and you looked at
{
4 the dowel pins on the bonnet, they looked fine, and, in j
5 order to determine whether they were short or not, we rapped l
6 them with a hammer, and then -- because it was almost like a i
7 press fit.
t 8
It's possible that you could have taken a valve 9
apart and not detected that because that wouldn't be l
t 10 something that you would normally do in a preventative l
i 11 maintenance to look and wear of a check valve.
l 12 MS. CURRAN:
That's all from me.
We'd like to 13 move these Exhibits 22 and 23 into evidence.
14
[ Judges confer.]
O 15 JUDGE KLINE:
Does one expect double pins to be
)
16 subject to wear in service?
I 17 MR. GIFFEN:
Oh, no, sir.
They should be a press
{
1 18 fit that they go in a bonnet all the way up in, and then 19 they rest against the hinge pin or the hinge plate, I think f
20 it's called.
21 JUDGE KLINE:
So that any protocol for inspection l
l 22 would not normally include inspection of --
23 MR. GIFFEN:
Well, you would make sure that they 24 were there.
25 JUDGE KLINE:
Yeah.
I understand that, but not --
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in the normal sense of inspecting for wear or inspecting for l
l 2
breakage, you would not normally inspect that?
3 MR. GIFFEN:
I don't believe so, no.
We'd inspect 4
to make sure that the components of the valves are there and 5
then also, when you take apart a valve, depending upon what j
6 it is, it can be done either by a qualified journeyman, or l
l 7
it can be done with a journeyman with an engineer present, 8
depending upon what we're looking for.
So that you've got 9
two sets of experienced eyes looking to see what the 10 condition of the valve is, and that's how this one was f
11 caught.
12 JUDGE SHON:
And the period that you'd normally l
i 13 allow between inspections for something like a check valve
{
14 wouldn't have anything to do with this, would it?
i O
t 15 MR. GIFFEN:
I'm talking of the -- no, I don't I
l 16 think it would, depending upon the --
17 JUDGE SHON:
It would probably be something like I
18 deterioration of the valve seat or wear in the hinge pin, or j
i 19 something like that?
20 MR. GIFFEN:
We look at -- we look at check valves 21 for that type of reason -- is there wear.
It may fall in 22 the IST program that requires at a certain frequency we 23 inspect the valve, and one of the ways that we do have to 24 use -- and we have to open it up instead of, you know, using 25 nonintrusive means.
I'm not sure what the frequency of this i
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one is.
O-2 JUDGE SHON:
But you wouldn't periodically inspect 3
or suspect manufacturing defects like this, it would seem.
4 MR. GIFFEN:
Not unless we were told about it, and 5
then we do.
l 6
JUDGE SHON:
Yeah.
l 7
MR. VOSBOURG:
And this valve is in the l
8 containment spray system, which is never actuated.
There is 9
never -- this valve isn't normally in service.
So there 10 would be no reason to have a short PM frequency like we 4
11 would for a valve that constantly had flow and would be 12 exercised and subject to wear.
13 MR. CROCKETT:
Generally, when we take those 14 valves apart, they're pristine.
We t ake them apart, and 15 there is absolutely no wear because they have no service.
16
[ Judges confer.]
17 JUDGE KLINE:
Is there a prescribed frequency for l
18 the inspection of these valves?
19 MR. GIFFEN:
Yes, sir, there is, but I don't know 20 what it is off the top of my head, different valves and 21 different applications.
Different sizes will have a 1
l 22 different frequency, and I'm not sure what the frequency of 23 this one is.
JUDGE KLINE:
Does anybody 24 on the panel know what the frequency is?
25 MR. GIFFEN:
We can get that, but I think we'd be ANN RILEY & ASSOCIATES, LTD.
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l i
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guessing if we --
l 2
[ Judges confer.)
3 JUDGE BECHHOEFER:
The Board has decided not to 4
accept these two exhibits.
We don't have enough to show 5
that there was any fault in the maintenance system or 6
surveillance system for at least this matter here.
7 MS. CURRAN:
We would like to offer the exhibit as 8
a proffer.
We believe that it's probative of a deficiency 9
in PG&E's ability to identify material deficiencies as 10 contemplated in the concept of maintenance as explained in 11 the INPO Document Number 90-008, both in the introduction 12 and at page 14, which discusses maintenance of plant 13 material conditions and requires the identification of 14 material deficiencies.
So we will offer it for that 15 purpose.
16 JUDGE BECHHOEFER:
Okay.
Well, that will be 17 fairly noted.
18 MS. CURRAN:
So noted.
All right.
The next 19 category is wrong size motor installed on SI-2-8974A.
20 There's only one exhibit here.
It's Exhibit 24, NCR DC2 21 EM-NO31 dated July 28, 1993.
I won't describe what happened 22 this time.
23 MR. REPKA:
Mr. Giffen, whenever you're ready.
24 MR. GIFFEN:
I think I can characterize this.
25 This was an event where, during maintenance on the limit O'
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1 torque during the outage the motor was to be replaced.
When-2 the work order was prepared to replace the motor, the 3
individual preparing the work order made an error in reading l
4 the motor size off of a table and specified on the work i
l 5
order a motor with a different torque value than what was l
6 supposed to be put in.
l 7
The work order was then sent out to the field, and 1
8 the incorrect motor was installed.
I do believe, however, i
9 they did do an evaluation on the motor that_was installed, J
i 10 and it was shown to be adequate for the safety function.
i i
11 However, I'd like to verify that.
That's my recollection of j
l 12 this, though.
13 MR. REPKA:
The wrong motor was installed?
)
14 MR. GIFFEN:
The wrong motor was installed.
And l
15 the root cause was?
16 MR. GIFFEN:
The root cause was personal error in 17 that the person preparing the work package -- when he 18 prepares the work package, he looks -- it was a design 19 change.
So it was a change, and he gets the design package, l
20 and, in the preparation of his work package from the design 21 document, he made a mistake, and then the mistake was j
22 carried through, and the wrong motor was installed in the 23 valves in the field.
24 Then, subsequent, as the NCR says, it was tested 25 and determined to De able to shut, which was its safety l
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function.
2 MR. REPKA:
So there was no safety significance?
l 3
MR. GIFFEN:
There was no safety significance.
l l
4 MR. REPKA:
And the error was identified?
l l
5 MR. GIFFEN:
Yes.
6 MR. VOSBOURG:
And we did go down and walk the 7
other -- I think there were ten to 13 other motors that had I
8 similar other work performed on them to verify that they 9
were all the correct size, that this was the only case where 10 this error was made.
11 MR. REPKA:
Mr. Giffen, would you address for me 12 briefly the subject of personnel errors in conducting 13 maintenance, and what is your reaction?
What is the context 14 of this personnel error, and what is your reaction to it?
15 MR. GIFFEN:
Well, we don't want to have personnel 16 errors.
It would be nice if we could overcome that human 17 shortcoming which causes humans to make mistakes.
So each' 18 time that there's a personnel error, we look at it to 19 determine why it happened and try to put in place something 20 that could prevent it from occurring if someone else was led I
l 21 down the same road about to make the same mistake.
l l
22 In cases where it's a blatant -- we even look at i
i 23 our discipline procedure to see if, when people make 24 mistakes, they need to be disciplined or not.
I guess that 25 the way that the plant's designed-and with the redundancy O
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l 1
and with as much effort as we put in our procedures and our f
2 work orders so that, when someone goes out to do something, 3
there's a testing requirement to be done after.
4 Hopefully, we will find the majority of personnel 5
errors, but those that don't, because of the way the plant's l
6 designed a minimal effect on plant operation.
We.look at 7
each one.
de don't like personnel errors.
8 MR. REPKA:
I have no further questions on this.
l 9
I do object to the admissibility of this, and there are many i
p 10 other documents that we are going to go through on this list i
11 that are simply a root cause personnel error.
The personnel i
12 error contention originally proposed by the Mothers for 13 Peace was rejected by the licensing board for admission into 14 this proceeding, and I don't think we should reintroduce O
15 that contention here.
I 16 Secondly, in the context of maintenance and 17 surveillance, we can stipulate that personnel errors will 18 occur, but these errors do not reflect on the overall 19 program.
The evidence -- the evidence that's important here 20 are the programmatic indicators.
So I don't believe this 1
21 and the other personnel error incidents that we will see 1
l 22 really are admissible here.
l 23 JUDGE BECHHOEFER:
Wouldn't you agree that at some 24 point you have had so many personnel errors that something 25 is wrong with the system or the implementation of the
(
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-693 l
1 system?
l O
t 2
MR. REPKA:
With the Board's leave, I'll let 3
Mr. Giffen respond to that.
4 JUDGE BECHHOEFER:
Would the witnesses agree?
5 MR. GIFFEN:
Yes, sir.
As.I said, we're really
{
6 concerned about reducing personnel errors, and so we even i
7 track them to see what progress we're making in preventing-f 8
personnel errors.
j i
l 9
We don't just say that a person made a mistake.and i
10 then do nothing about it.
You'll find examples where we 11 could have improved of the labeling; the labeling wasn't 12 really quite clear.. So we look at the human factors that 13 led this person down the path to make a mistake.
14 Then we change the plant.
We change the O
15 procedures, and the tracking that we've done on personnel I
16 errors over the last three years has shown a steady decrease 17 in the number of LERs that have personnel errors and the 1
18 number of nonconformances and even the number of quality i
19 evaluation.
20 So the efforts that we're putting in place at the 21 plant to reduce personnel errors not only in maintenance but 22 in every discipline at the site are working to reduce the 23 errors that are being made, but, as counsel said,. errors are 24 going to happen.
We just have to be able to look at those, 25 learn from them so that someone won't make, hopefully, the 1
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1 same mistake again.
O 2
MR. REPKA:
And the point for admissibility here
[
3 is it's highly inefficient to try to make a case that there
[
i 4
are so many incidents by going through 20. cur 25 examples, 5
which is what the Mothers for Peace propose.
In the context 6
here of the hundreds of thousands of maintenance tasks that 7
happen, that simply has no bearing.
8 If there is a suggestion by the Mothers for Peace 9
that there's a programmatic problem of personnel errors, f
i 10 this is not the way to do it.
There are other programmatic j
11 indicators that might support that kind of assertion, but.to 12 sit and go through one by one routine, very minor examples
)
13 of personnel errors that have been identified and are j
14 tracked in the normal process simply is -- it's not only not 15 probative, it's downright inefficient.and, of course, 1
16 previously rejected as a contention.
I 17 MS. CURRAN:
May I respond to that?
18
[ Judges confer.]
19 JUDGE BECHHOEFER:
The Board will admit this 20 document.
We rejected the other contention, as we believe 21 the material was, in large part, covered by Contention 1.
I 22 That was our major reason for rejecting it.
We think that 23 the matter of the significance of each of these errors and 24 the significance of them collectively is one that only the f
25 Board can decide in the context of litigation.
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So we will admit Exhibit 24.
2 MR. REPKA:
With that ruling, Judge Bechhoefer, I 3
would propose that at the break or maybe after the session 4
tonight that Ms. Curran and I go through this list of 5
documents and identify those that are personnel errors.
We 6
can then stipulate that there are X-number of personnel I
i 7
error incidents in these documents and put them into the l
8 record and then move on and obviate the discussion at each 9
one of these errors.
t 10
[ Judges confer.]
{
i 11 JUDGE BECHHOEFER:
Ms. Curran, do you have 12 objection to proceeding that way?
13 MS. CURRAN:
No.
No.
14 JUDGE BECHHOEFER*
We wouldn't have any objection, 15 but, you know, if there's anything in the individual l
16 documents that you think must be brought out, you should-
{
17 make sure that that happens, though, I think, other than 18 pure personnel error.
l 19 MR. REPKA:
We can then argue as to the meaning of l
20 the total number.
21 MS. CURRAN:
Yeah.
There are many examples that i
(
22 have -- that are significant for more than one reason, and j
l 23 personnel error may be one of them.
So, for those, we may 24 need to do something else, but --
i 25 MR. REPKA:
We will try to sort through that.
l 1
l O
v ANN RILEY & ASSOCIATES, LTD.
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t
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1 MS. CURRAN:
-- if there's something that's pure l'
2 personnel error, we can probably just_ stipulate that they go i
3 in.
'l i
4 JUDGE KLINE:
I might just comment, though, that,
+
5 when a document like this comes in, the whole document comes 6
in.
This Exhibit 24 gives, on page 2, an account of how the 7
error was introduced, the personnel error, and, in the 8
following paragraph, how it was remedied.
So the document J
9 contains both the error and the remedy.
10 At some point we need to, probably, have more 11 development of the record than just the fact that personnel j
12 errors occurred.
It isn't clear to me yet.
I mean, I don't 13 want to go after your strategy.
You can conduct your case 14 any way you want to, but I do have a little trouble seeing 15 where we're going with this.
16 With this document containing both the error and 17 the remedy, what is it the Board should make of this?
What 18 relief do you seek?
What inference should we draw from it?
i 19 I just don't know how it's going to be helpful, but at some 20 point we should develop the record in such a way that it's l
21 going to be helpful when findings are written, and right now i
22 it strikes me that we're not getting a really sharp or crisp 23 development with this.
So that's just a comment which I 24 think needs some -- you know, it should be addressed 25 somehow.
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1 JUDGE BECHHOEFER:
Well, for instance, this 2
document, apparently, says it involves several personnel 3
errors.
At what point does a series of personnel errors 4
become something more significant?
On page 2 under C, 5
second paragraph under C says, "Several personnel errors."
6 It describes -- well, it describes the first and then goes 7
on to talk about other ones.
i l
8 At some point personnel errors were multiplied.
9 It might be more than a personnel error, in terms of l
10 evaluation.
11 MS. CURRAN:
Yes.
Maybe I should obtain 12 clarification right now regarding the Board's treatment of 13 these documents.
It's our intention to discuss both -- in j
14 most of these NCRs, there's always a category for previous O
i 15 similar occurrences, and it's your intention to discuss in 16 our proposed finding the incident and the previous similar 17 occurrences.
18 We believe there is a pattern of repetitive 19 problems in many categories, including this one of personnel 20 error, and this pattern of error raises significant doubt 21 about the validity of PG&E's ae
- NRC's conclusions that the 22 maintenance program is adequate.
23 JUDGE KLINE:
Well, I understand that's your view 24 of it.
My problem is, in developing a record that contains 25 a lot of raw data in it someplace and leaving it to the ANN RILEY & ASSOCIATES, LTD.
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Board to reconstruct what your view may well be.
O 2
I think that you really do have some burden of-3
-showing us what your view is as you develop the record, and 4
you just can't rely on us to comb through this record and 5
reconstruct a theory for you out of a voluminous, sort of, 6
raw data.
7 JUDGE BECHHOEFER:
Well, for instance, you might j
1 8
have asked the witnesses whether a series of personnel 9
errors like this one is any different in significance to l
l 10 just a single personnel error, that type of thing, to give 11 us a record.
12 MS. CURRAN:
All right.
13 JUDGE BECHHOEFER:
Because,,if we see an error --
14 MS. CURRAN:.Then I'll ask it.
f 0
15 JUDGE BECHHOEFER:
-- and then a corrective
.j 16 action.
Well, I don't want to formulate your. questions, i
17 particularly.
)
18 JUDGE KLINE:
But I am having trouble with 19 constructing a record that contains a lot of what you might 20 call raw, undigested data, as far as this record is i
21 concerned and then later having findings selected out of I
l 22 that all from the paragraph that outlines the error and not 23 taking account of any of the paragraphs that outline the 24 remedies.
25 If we're going to have to see -- or, if we're i
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being asked to see programmatic defects, we're going to have 2
to see why there are programmatic defects given that some 3
remedy occurred.
Why was that remedy inadequate?
Why is it 4
that the overall program, given that it makes errors to 5
start with and it finds them later, why is it that that 6
program is bad, and why is it that the Board should order 7
some form of improvement?
8 So we have to have -- we have to have a theory or 9
some basis developed in this record that shows why the 10 program, in its entirety, including both introduction of 11 error and introduction of remedy is somehow faulty.
i 12 Right now I'm not seeing that moving in that 13 direction, and I have a feeling that just giving us 200-some 14 odd NCRs or exhibits without that added development isn't 15 going to be very helpful.
I don't know how to -- you know, 16 I don't want to instruct you on how to proceed, but I am 17 seeing a problem here.
18 MR. REPKA:
I suggest we proceed to the next 19 incident.
20 JUDGE BECHHOEFER:
Or even further questions on 21 this.
22 MR. REPKA:
Oh, I thought we were done with this 23 one.
24 JUDGE BECHHOEFER:
Well, we're not sure.
(
25 MS. CURRAN:
We're finished with this.
l l
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JUDGE-BECHHOEFER:
Oh, okay.
2
[ Judges confer.)
3 JUDGE BECHHOEFER:
I think we'll take about a ten-4 minute break before we get spoke the next incident series.
5
[ Recess taken from 3:00 p.m. to 3:21 p.m.)
6 JUDGE BECHHOEFER:
Back on the record.
7 Ms. Curran.
l 8
MS. CURRAN:
All right.
The next category is-9 entitled, "High Radiation Area Entry."
Exhibit 25 is NCR 10 DCO-93-AP-NO29 dated July 27, 1993.
Exhibit 26 is NRC l
11 Inspection Report 93-11 dated May 13, 1993.
Those are being 12 passed out.
13 Since Exhibit 16 is an NRC document, we would i
14 identify that at this point and reserve moving it into the l
15 record until the NRC witnesses go on.
[
16 MR. REPKA:
Whenever the witnesses are ready.
l 17
[ Pause.]
18 MR. REPKA:
These two documents that have been 19 marked for identification as Exhibit 25 and Exhibit 26, do 20 they both relate to the same --
21 MR. GIFFEN:
Appear to relate to the same series l
22 of occurrences.
23 MR. REPKA:
Can you please describe briefly for me 24 what that series of occurrences was?
25 MR. GIFFEN:
There are cases where personnel ANN RILEY & ASSOCIATES, LTD.
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-entered-a high radiation area without the required 2
continuous monitoring along the dosimetry.
It's the first j
i 3
paragraph on the management summary of the attachment that 4
they passed out.
It says, essentially, what happened.
5 This is personnel error, and, in looking at it 6
from the point of view of what the corrective actions are, 7
there's nothing involved in this that appears to be 8
associated with maintaining or surveilling the power plant.
9 MR. REPKA:
Were these maintenance personnel?
10 MR. GIFFEN:
I don't think it says.
11 MR. REPKA:
Were they involved in any way in 12 maintenance activities?
13 MR. GIFFEN:
They could have been.
It doesn't --
14 in skimming it, I don't see -- it says, " Workers," but
\\
15 workers at the power plant can be operations people.
They 16 can be people from general construction.
It doesn't 17 necessarily mean maintenance workers.
So I'm not sure who 18 it is.
19 MR. REPKA:
And the issue here involved has 20 nothing to do with their work?
It has to do with their i
21 entering and exiting the high radiation area?
22 MR. GIFFEN:
Yes, that's correct.
23 MR. REPKA:
So did this incident, this series of 24 incidences -- well, let me back up before I ask that 25 question.
When you say, "a series cf instances," how many k
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instanccc are we talking about?
2 MR. GIFFEN:
Well, this says four.
1 3
MR. REPKA:
Okay.
Do these four instances of l
1 4
personnel entering areas posted as high radiation areas, do l
5 they reflect at all on the adequacy of maintenance and j
t l
6 surveillance or on the maintenance and surveillance program?.
l 7
I 8
MR. GIFFEN:
No.
They just show that persons j
f 9
going in to do something, and I see a couple of'them.
A l
10 contract carpenter during an outage went into an area 11 without reading the sign on the door.
12
" Contract worker entered a refueling i
13 bridge posted to look at the vessel and i
i 14 service inspection tool without having 15 the appropriate coverage for radiation i
16 protection."
)
l 17 MR. REPKA:
Have actions been taken to' minimize l
l l
18 this kind of occurrence in the future?
19 MR. GIFFEN:
Yes.
As was stated, when we do one I
l 20 of these nonconformance report, when an issue is raised, we l
21 look at what happened and what can we do to prevent 22 reoccurrence, and the exhibit does show those things that we 23 did.
24 We issued a letter saying what our expectations 25 are, making sure that the people working in the power plant O
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understand management's expectations, and also we're going O
2 to change the general employee training to make sure that l
3 everyone gets to go through the training will review these 4
events, and there's a couple of other things as well.
5 MR. REPKA:
Based on that testimony, I object to 6
admission of this document.
It has no probativity or 7
materiality with respect to the adequacy of maintenance and 8
surveillance tasks or to the maintenance and surveillance 9
program.
i 10 The fact of the matter is it involves an action 11 unrelated to maintenance and surveillance; that is, entering 12 and exiting the high radiation area.
It's clearly a 13 personnel error and outside of maintenance and surveillance
]
J 14 and is a very good example of a personnel error -- of the O
15 type of personnel error that was rejected for admission 16 under Contention 1 where -- or Contention 2.
17 In addition, Contention 6, as originally proposed, 18 related to occupational exposures and radiation protection, 19 and that contention was also denied admission.
20 MS. CURRAN:
All right.
Are you finished?
21 MR. REPKA:
Yes.
22 MS. CURRAN:
Okay.
Mr. Giffen, in the NCR, on j
23 page 2, example E-1 refers to an in-service inspection j
f 24 worker.
Could that have been a maintenance worker?
That I
i 25 was October 2, 1992.
l O.
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1 MR. GIFFEN:
It could have been a Westinghouse l
2 employee, a contract employee.
Westinghouse did our 3
in-service inspection.
So it was probably -- if they say an
)
4 in-service inspection worker, it probably referred to_him.
5 Normally, if it's a mechanical, electrical or an INC worker, l
6 they specify who that employee is.
So, in this case, I 7
would be surmising that it would be a Westinghouse employee.
j 8
l l
9 MS. CURRAN:
And on page 3, can you tell me what a 1
10 scaffold worker is --
11 MR. GIFFEN:
A scaffold -- I'm sorry.
12 MS. CURRAN:
I'm sorry.
On the top of the page.
13 MR. GIFFEN:
During an outage period, we augment 14 the maintenance staff and the construction staff and the-15 plant staff with several -- with several hundred people, and 16 probably a scaffold worker would be a person that would be 17 hired for the duration of the outage to come in and to help 18 erect scaffolding that would be needed to perform 19 maintenance or inspection of a component.
20 MS. CURRAN:
So at least two of these workers 21 could have been maintenance workers?
22 MR. GIFFEN:
They could have been, but I'm 23 guessing that the in-service guy was Westinghouse.
The 24 scaffolding worker was probably working for General j
25 Construction and was a temporary employee hired for the l
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outage.
O 2
MS. CURRAN:
But would they not be covered by 3
PG&E's maintenance program?
4.
MR. GIFFEN:
They would be covered by our l
5 maintenance program as well as our rules.
All the rules, if 6
you're doing -- the maintenance program, if you're doing 7
something, then that would be a way to say they're covered i
8 by the program.
9 MS. CURRAN:
Okay.
I'd like to -- oh, I'd like to 10 ask another question about the NCR.
I flipped through this 11 a couple times, and I can't find a section that says 12
" previous occurrences."
I'm probably missing it, but can 13 you tell me if there is such a section in here?
14 MR. GIFFEN:
Page 9.
15 MS. CURRAN:
Okay.
Page 9.
So these both discuss 16 incidents that involved -- had something to do with 17 radiation protection; is that correct?
18 MR. GIFFEN:
On the first case, it looked like a 19 radiation protection technician left the door unlocked.
The 20 next case where boundaries were crossed.
21 MS. CURRAN:
What does that mean?
22 MR. GIFFEN:
When you have a high radiation area, 23 you put a boundary.
You put tape on the floor.
You put 24 blinking lights.
You put a sign on the door, and before 25 crossing that boundary, you're supposed to use some sort of t
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a -- depending upon the levels of the radiation'-- some sort I
i 2
of symmetry, and it appears just from skimming this that it
{
3 said in this NCR that that didn't occur in 1991.
i l
4 MS. CURRAN:
So these were two other instances in i
5 which there was a problem with radiation protection for.
l 6
workers in the plant?
Is that right?
l 7
MR. GIFFEN:
If these are what it says they are,
.i l
8 yes.
l 9
MS. CURRAN:
Okay.
You're familiar with the INPO.
-l 10 maintenance guidelines90-008?
We've been over this before, 11 right?
12 MR. GIFFEN:
I think I said yes.
13 MS. CURRAN:
Okay.
On page 36, there's a whole 14 section called " Internal Radiation Exposure," and the 15 performance objective is, 16
" External radiation exposure control 17 should minimize personnel radiation 18 exposure."
19 There is no qualification in here that says that 20 this only applies to maintenance activities or maintenance 21 workers.
Would you agree with me that this section of the 22 info guidance covers -- generally covers protection from i
l 23 radiation exposure?
{
i 24 MR. GIFFEN:
In this case, I would like to read i
25 what you're reading.
In the last case, I was a little more i
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l familiar than-with-this-case.
J 2
MS. CURRAN:
Okay.
Do we have the INPO document?
l 3
JUDGE BECHHOEFER:
You can show a copy to the 4
witness.
5 MS. CURRAN:
Beg your pardon?
l 6
JUDGE BECHHOEFER:
You can show a copy to the
}
i 7
witness.
I 8
MS. CURRAN:
Okay.
F 9
JUDGE BECHHOEFER:
Point of inquiry is, is this 1
10 INPO document one for which there should be some
~
11 confidentiality afforded?
12 MR. REPKA:
No, it is not.
It has been made l
13 available to all parties.
j 14 JUDGE BECHHOEFER:
Okay.
I just wanted to 15 inquire.
I 16 MS. CURRAN:
At this point I would like to just 17 give a copy of this INPO document to all the parties and the j
l 18 Board.
There's another document I also gave you, which is a 19 piece of NRC guidance on maintenance that I'd like to go to 20 next.
l 21 MR. REPKA:
That needs to be marked for 22 identification, if you're going to give it to the Board.
23 MS. CURRAN:
That's right.
All right.
Okay.
The 24 document that we're talking about right now is Mothers for 25 Peace Exhibit 4, INPO 90-008, Revision 01, March 1990, and ANN RILEY & ASSOCIATES, LTD.
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1 it's entitled, " Maintenance-Programs-in-the Nuclear Power 2
Industry."
3 MR. GIFFEN:
You're on page 36, if I remember 4
correctly?
5 MS. CURRAN:
That's right.
l 6
MR. GIFFEN:
Could you repeat your question for 7
me?
8 MS. CURRAN:
My question to you was the guidance 9
for external radiation exposure in this INPO document does l
10 not appear to be limited to limiting radiation exposure or
)
11 protecting workers only during maintenance activities, does
]
l 1
12 it?
j 13 MR. GIFFEN:
It says, j
14 "Should minimize personnel radiation exposure,"
l 15 is what the performance objective states at the top of the 16 page.
17 MS. CURRAN:
That's right.
And that part of 18 maintaining a nuclear -- would you agree that part of 19 maintaining a nuclear power plant involving maintaining the l
20 safety of the workers in the plant?
21 MR. GIFFEN:
Oh, most definitely, and let me get -
22
- later on we'll go over.
We do as a practice, and the 23 maintenance department have set goals and objectives for the 24 radiation exposure of our people.
25 MS. CURRAN:
Do you have something you want to O
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add?
2 MR. GIFFEN:
No.
I was waiting for you.
3 MS. CURRAN:
Oh, you were waiting for me.
Okay.
4 The next document I want to go to is -- well, the cover 5
letter is a letter from Donald E. Hickman of the NRC to Greg 6
M.
Rueger dated June 18, 1992, and it encloses e document 7
- entitled, "A Nuclear Regulatory Commission's Performance 8
Indicator Program."
9 In section 3.8.4, the document discusses 10 maintenance problems.
11 MR. GIFFEN:
I'm sorry.
I'm just -- with the 12 amount of paper, I've lost it.
13 MS. CURRAN:
Well, look for a document -- it 14 should say Exhibit 1 at the top right-hand corner.
15 MR. GIFFEN:
Exhibit 26?
16 MS. CURRAN:
Exhibit 1 dated June 18, 1992.
Do 17 you have another copy?
I just gave it to you.
18 MR. GIFFEN:
3.8.4?
19 MS. CURRAN:
Right.
The first paragraph says, i
20 "The intent of the maintenance problems l
21 cause category is to capture the full l
22 range of problems which can be l
23 attributed in any way to programmatic l
24 deficiencies in the maintenance I
25 functional organization.
l l
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" Activities included in this category 2
are maintenance, testing, surveillance, l
3 calibration and radiation protection."
4 Do you agree with that statement.
5 MR. GIFFEN:
I agree that that statement is 6
written.
MS. CURRAN:
Do you agree 7
that radiation protection is an appropriate category of 8
maintenance issues?
9 MR. GIFFEN:
I believe that maintenance must have 10 adequate radiation protection and specified when they go out l
11 to do work.
The controls must be there.
We must understand l
I 12 what radiation protection requires us to do and to follow 13 the appropriate rules; yes, I do.
14 MS. CURRAN:
But you don't believe that 15 maintenance necessarily embraces radiation protection for l
16 all aspects of the operation of the plant?
17 MR. GIFFEN:
I didn't say that.
I just said that 18 this is what it says.
You asked me if I agreed with it.
I 19 haven't had time to read the whole thing.
Reading that one 20 sentence, I agree that that's what that one sentence says.
21 MR. VOSBOURG:
We have a radiation protection 22 program at the plant as a operate program.
It encompasses 23 all of the different departments at the plant, all the 24 people working at the plant.
It's not specific to 25 maintenance or to any other group.
It applies to all the ANN RILEY & ASSOCIATES, LTD.
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groups the same.
It's a separate program other than the
~
2 maintenance program, but it's a program that applies to all 3
of the departments at the plant.
4 MS. CURRAN:
But, in designing your maintenance 5
program, to you attempt to comply with the guidance provided 6
at pages 36 and 37 of INPO 90-008?
7 MR. GIFFEN:
Yes.
Yes, we do.
i 8
MS. CURRAN:
Okay.
I'll leave it at that.
- Well, 9
we believe that this particular incident is relevant to the 10 maintenance of the plant.
For one thing, there are at least l
11 two examples and possibly more that involved workers who 12 were involved in maintenance activities in the plant.
I 13 We also believe the category of radiation i
14 protection is embraced by the maintenance program and that 15 maintenance involves maintaining safe conditions for the j
16 workers at the plant.
17 MR. GIFFEN:
I agree with most of what she said.
18 However, nowhere did I hear anyone say that the workers were 19 maintenance workers.
I said I believed them to be 20 Westinghouse employees most probably, because they did 21 in-service inspection, and the other is a contractor l
l 22 probably with general construction.
23 So I guess I disagree with the way you 24 characterize what I said.
25 MR. REPKA:
Thank you, Mr. Giffen, and with that ANN RILEY & ASSOCIATES, LTD.
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1 let me respond to Ms. Curran's argument.
The fact of the 2
matter is we're talking about the admissibility of one 3
specific NCR, and to say that this NCR has any weight to 4
Contention 1 is an incredible stretch.
5 We have no idea who these workers were or what i
6 they were doing.
It goes to their passing through a 7
radiation -- into a radiation area.
It has nothing to do 1
8 with maintenance work, performing maintenance work, the j
9 quality of maintenance work.
10 The contention, as stated by the Mothers for I
11 Peace, is, 12 "PG&E lacks a sufficiently effective and 13 comprehensive maintenance and i
l i
14 surveillance program to justify the l
15 operating license amendment here at 16 issue."
17 This simply has nothing to do with that.
What 18 INPO 90-008 may say, that's not the contention.
The generic 19 personnel error contention has been ruled out as has the 20 contention specifically directed to the radiation protection l
2 21 program.
22
[ Judges confer.]
23 JUDGE KLINE:
Even if a person or a worker is a l
24 surveillance or maintenance worker, whose responsibility is l
l 25 it within the organization of the plant to assure radiation ANN RILEY & ASSOCIATES, LTD.
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safety?
Does that responsibility lodge in the maintenance 2
and surveillance department?
3 MR. GIFFEN:
It lodges with the individual.
We 4
try to teach that the radiation protection and safety is 5
really the individual's responsibility to understand the 6
rules and to comply with those, you know, for industrial 7
safety and radiation protection, 8
The radiation protection, if a problem occurs 9
because of a maintenance worker, then the nonconformance 10 would probably be under mine and maintenance services.
This 11 nonconformance was under radiation protection.
So it could 12 have been -- it depends on who it was, who would take the 13 nonconformance report, and this one, I believe, was not a 14 maintenance nonconformance.
It was a radiation protection, 15 and the way you tell that is by the numbering system on the 16 nonconformance, HP, Health Physics.
17 JUDGE SHON:
What I hear you saying is that this 18 set of four incidents, walking past a radiation area or l
19 walking into a marked radiation area without proper 20 equipment is the equivalent of, say, walking into a hard hat 21 area without a hard hat on and that that isn't a maintenance 22 matter.
Is that right?
23 MR. GIFFEN:
That is one way to say this.
There's 24 a safety rule, whether it be industrial safety for hard 25 hats, ears or eyes is the same as you should have a l
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dosimeter and anticontamination clothing when you go into
)
O t
2 concern areas, yes, sir.
3 JUDGE SHON:
And if you don't, you don't regard 4
this as an error in maintenance and surveillance; is that i
i 5
right?
l 6
MR. GIFFEN:
If it happens with a maintenance 7
services person, I take it, and we talk to him, and we try 8
to figure out why he did what he did, and we take it as we j
1 9
would any safety or anything that could hurt the person to 10 try -- and, in some cases, when we blatantly -- if a person l
11 blatantly does not follow a rule, then disciplinary action f
12 will be taken against him.
l
+
13 He's supposed to understand that.
In the training
{
}
l 14 we cover that.
"This is so serious that if you don't follow l
l l
15 the rules, disciplinary action will be taken."
\\
16 JUDGE KLINE:
Who takes the disciplinary or i
17 corrective action, radiation safety or surveillance and i
18 maintenance?
19 MR. GIFFEN:
The person who, if he's an employee 20 of electrical maintenance, then the electrical director.
If 21 he is an employee of radiation protection, then that 22 particular supervisor would do that.
23 JUDGE KLINE:
It isn't clear to me how the 24 radiation responsibilities are separated out.
I mean, above 25 the individual level where the individual is suppose to take ANN RILEY & ASSOCIATES, LTD.
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responsibility for himself, what happens at the 2
institutional level?
I mean, you come up with somebody has 3
done something wrong.
Does it follow a path up to radiation 4
safety department, or does it follow a path up to you?
l 5
MR. GIFFEN:
It follows -- it goes both ways.
6 JUDGE KLINE:
Oh, it goes -- okay.
7 MR. GIFFEN:
Because we look at it from the i
8 radiation protection are the ones who have the 9
responsibility to assure that the radiation work permits are 10 filled out correctly, that the survey information on it, if 11 there's any surface contamination, that's on it.
j i
12 So they're responsible for the technical adequacy i
13 of the work document and the boundaries that are 1
14 established.
They also have radiation protection 15 technicians that work inside containment, and I think these 16 are all outage-related, during the performance of an outage 17 to assist the workers in following the different rules, 18 making sure if they go into an area they have the right 19 dosimetry.
20 So radiation protection is required to do the l
21 technical aspect and implement the guidance that the rest of l
22 us will follow, and then each individual --
23 JUDGE KLINE:
But you have some institutional 24 responsibility for radiation safety, then; isn't that 25 correct?
MR. GIFFEN:
Yes.
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JUDGE KLINE:
On the two-channel scheme.
Now, if 2
that responsibility were part of the root cause, would 2t 3
appear in an NCR like this?
4 MR. GIFFEN:
Yes.
It would still be --
5 JUDGE KLINE:
I mean, it's your institutional 6
responsibility, not radiation safety or radiation 7
protection, but your surveillance --
8 MR. GIFFEN:
We would look at the individual event 9
to determine where it should be, and then it would go with 10 that manager.
So I can't say they would be in mine.
If the 11 boundary wasn't established correctly, it could be in RPs.
12 JUDGE KLINE:
Well, that's what I'm trying to 13 determine, what such -- what an NCR would r,how if the error f-s 14 was assigned to you rather than to radiation protection, I U
15 mean the institutional response, not the individual --
16 MR. GIFFEN:
Basically, the NCR would say the same 17 thing.
We'd look at it, and it just -- who has it, who has 18 the responsibility for it.
19 JUDGE KLINE:
Okay.
Let me ask, on page 7 of this 20 NCR is a paragraph labeled, " Corrective Actions to Prevent 21 Occurrence," and there are some four numbered paragraphs 22 carrying over to the next page, and, in each case, it 23 follows a similar format assigning a responsibility to do 24 something to an individual and to a department.
25 In each case, it appears the department is ANN RILEY & ASSOCIATES, LTD.
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radiation protection.
Is Mr. Grey in radiation protection 2
as well?
3 MR. GIFFEN:
Art Grey is the director of radiation 4
protection.
5 JUDGE KLINE:
Okay.
And if there were some 6
institutional responsibility --
7 MR. GIFFEN:
Then I would --
8 JUDGE KLINE:
-- in the opinion of the writer i
9 lodging with surveillance and maintenance, would it appear 10 in a paragraph like this?
11 MR. GIFFEN:
I would expect that one of the 12 directors or senior engineers in maintenance would be t
13 indicated as responsible to perform some corrective action.
14 There is one other.
That's Al Dame on the bottom of page 8.
15 He is not in radiation protection.
He is responsible for 16 access, which is when we bring in people for outages, they 17 go through this training program.
18 JUDGE KLINE:
With that testimony, Ms. Curran, 19 would you link it up to the surveillance department, then, 20 or the radiation safety -- I mean the maintenance and 21 surveillance?
Because this document, on its face, appears 22 to assign responsibility to the radiation safety department 23 or radiation protection.
24 MS. CURRAN:
Well, I think there's a question here 25 as to whether it should have been assigned, at least in some
(_)
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respect, to the maintenance department, because the 2
maintenance program clearly has responsibility for l
3 protecting workers from radiation.
l 4
JUDGE KLINE:
Well, that's what I was trying to 5
get out of these witnesses, whether if there was an 6
institutional responsibility lodging with surveillance, 7
would such an NCR show it, and my understanding is that it 8
would if, within the organizational scheme, that 9
responsibility was there, but at least I don't see it.
10 So I guess -- I guess I'm having trouble seeing 11 how we can use this.
l 12 MS. CURRAN:
All right.
There's two ways or two 13 issues here.
First of all, it appears, from what Mr. Giffen 14 said, that at least some of these employees, although they l 6 i
15 may not have -- or contract workers, whoever they were, they 16 may not have been plant employees, but, in all likelihood, 17 they are engaged in some kind of maintenance-related l
18 activities, and I believe, you can correct me if I'm wrong, 19 Mr. Giffen, but I believe Mr. Giffen said that the l
20 maintenance prograr does have responsibility for protecting i
l 21 the safety of these people.
22 Now, the fact that maintenance, the maintenance 23 department didn't show up in this NCR is, to us, an 24 indication that there is some problem in the system, not 25 that maintenance doesn't have an institutional ANN RILEY & ASSOCIATES, LTD.
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responsibility, but that the institutional responsibility 2
was overlooked, and that this is a defect in the program.
3 MR. REPKA:
But there's no evidence to support 4
that.
The document speaks for itself, and to say that it i
5 doesn't say something without any evidence to suggest that-6 it should and just to assert that it should, that's l
7 ridiculous.
8 MS. CURRAN:
Well, the evidence we have that it j
9 should is, first of all, the INPO guidance document on which j
10 PG&E relied, and second the fact that maintenance activities 11 were involved in these incidents of radiation exposure, and l
12 there's no indication that the maintenance department became 13 involved.
l 14 MR. WARNER:
Ms. Curran, we are-speaking of two j
l 15 documents here that, on their face, are related to the l
l 16 radiation protection program, both of them.
The NRC 17 inspection report refers to a radiological protection 18 inspection in which the discussions by the inspector were 19 with the radiation protection department head.
i 20 The NCR, on its face, assigns corrective actions 21 for my deficiencies to the radiation protection director.
I 1
22 think it's just, on its face, unrelated to maintenance.
23 MS. CURRAN:
Well, in this case, there were a 24 number of workers.
We don't know what all of them were 25 doing, but some of them were working on maintenance-related ANN RILEY & ASSOCIATES, LTD.
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activities who did not follow procedures and, accordingly, 0
2 did not take appropriate measures to protect themselves from f
3 radiation.
That's a serious matter.
l 4
I would assume that radiation exposure is a i
5 routine concern in maintenance activities, and we believe j
i 6
it's relevant.
i 7
MR. REPKA:
That contention was not admitted.
The j
8 fact of the matter is we're here talking about CP recapture S
and which, presumably, the nexus is the maintenance and l
t 10 surveillance of equipment, and that speculation is just so l
I 11 far off the point, it's inadmissible.
1 12 JUDGE BECHHOEFER:
I'd like to ask a couple of i
t 13 questions about Event Number 4.
Who was responsible for l
l' J
14 training workers to ask for alarming dosimeters in l
[
t 15 particular situations where the worker might need them?
I'm l
4 16 referring to page 6, item D-2.
Oh, I'm sorry, of MFP l
17 Exhibit 25, the NCR.
18 MR. GIFFEN:
On page 6, D-2, sir?
l 19 JUDGE BECHHOEFER:
Yes, and really it's the last 20 sentence of D-2.
Who would be responsible for making sure 21 that workers know that they should have asked for the 22 dosimeters in this circumstance?
Would that be anything 4
23 related to the maintenance program or not?
l r
i 24 MR. GIFFEN:
Before a person goes in to work in a j
i 25 radiation area, they have the responsibility to read a j
4 a
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radiation work permit, and the radiation work permit will 2
tell them on there what -- where they can go, what the 3
maximum dose that they can get, what dosimetry they're 4
' supposed to wear, whether it-be an alarming dosimeter or 5
just a regular dosimeter and what they're suppose to do, 6
protective clothing.
So they read that.
So the 7
onus is upon that person to understand.
He signs that he i
8 knows what he's supposed to have..Then he goes into work, i
9 and, in this case, he's supposed to check him as he did, 10 apparently, with the RP technician, the radiation protection I
11 technician, at the work site and say what he was going to 12 do.
l 13 So, in this case, it's each of -- the worker -- we 14 feel that the worker has the responsibility.
You're 15 responsible to wear your safety equipment, your dosimetry.
j i
16 It's up to you to understand what you need and to do it, and 17 the program is established that way, and then the RP tech in 18 the field is supposed to work with and understand when a j
19 person goes in -- I mean, he's the expert in radiation 20 protection.
[
l l
21 So when he goes into a high radiation area, he l
22 knows that you are supposed to have an alarming dosireter or l
23 an RP tech with you.
So the worker's suppose to say, "I
24 read the work permit.
I'm supposed to have an alarming 25 dosimeter," but we put the RP tech in the field to make sure l
i l
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1 that the people understand and follow that particular rule.
O 2
MR. CROCKETT:
And those radiation work permits 3
are written by the radiation protection department based on 4
the condition in the field at that particular location.
l 5
They're written by rad protection.
l 6
JUDGE KLINE:
Arc any or all of you familiar with 7
the four incidents?
I mean, did you have any part in the
]
l 8
remedy or institutional response to the four incidents?
9 MR. GIFFEN:
Not to my recollection.
10 JUDGE KLINE:
Okay.
So, in these four instances, 11 you weren't required to do anything, is that correct, even 12 though, in theory, some responsibility flows in your 13 direction, in this particular case --
14 MR. GIFFEN:
Neither I or any of my directors had J
15 anything to do --
1 16 JUDGE KLINE:
You didn't respond at all; is that 17 correct?
l 18 MR. GIFFEN:
Mr. Crockett has the training 19 department, not maintenance.
He's the manager of that.
l 20 JUDGE KLINE:
Okay.
Do you have something to say 21 or add?
22 MR. CROCKETT:
No.
Just your question was did we 23 have anything to do with it.
Other than Al Dame works for a 24 director who works for me.
25 JUDGE KLINE:
Oh, 1 see.
D ANN RILEY & ASSOCIATES, LTD.
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1 MR. CROCKETT:
But me specifically having anything
[
O I
2 to do with this event.
3 MR. GIFFEN:
But that's from the manager of 4
support services not the manager of maintenance, 5
JUDGE BECHHOEFER:
Ms. Curran, in view of the 6
various responses, could you give us anything more about 7
linking this up?
Because we're having trouble seeing any 8
meaningful relationship to just maintenance or surveillance i
9 on this particular matter.
10 MS. CURRAN:
Well, PG&E may have its way of 11 compartmentalizing responsibilities eccording to various 12 departments, delegating responsibilities, but that doesn't 13 necessarily dispose of the question of whether those 14 delegated departments are responsible for maintenance.
O t
15 We think you have to look to what is the 16 understood definition of maintenance as it has been l
l 17 established by the industry and by the NRC, and that if you
(
18 go back and look at the INPO document that we've identified l
l 19 at the NRC guidance document, that the concept of 20 maintaining a nuclear power plant includes the concept of 21 protecting workers from radiation, of maintaining safe 22 conditions in the plant, and that's clear throughout the 23 guidance documents.
24 Now, whether PG&E calls it the radiation 25 protection department or whether they call it the 4
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maintenance department, it's a maintenance-related issue, 2
and that these examples demonstrate a representative pattern 3
in which workers did not follow correct procedures and did 4
not protect themselves against radiation.
1 5
We feel that this is sufficient to raise a 6
question about the adequacy of PG&E's program for --
7 maintenance program for protecting -- for maintaining safe i
8 conditions in the plant.
9 JUDGE BECHHOEFER:
So-you're saying that the 10 maintenance program should include, even though it doesn't, i
11 should include matters of this sort?
12 MS. CURRAN:
Yes, and that it, in fact -- PG&E has 13 stated that this guidance document governs its own 14 interpretation of what's constituted by maintenance.
We're 15 not making this up.
We're looking at what the industry --
16 the industry's own view of the scope of maintenance is, and 17 that's in PG&E's testimony.
18 MR. REPKA:
The problem is there's no evidence to 19 support any of that speech, and to the extent it's 20 challenging radiation protection, there's no evidence to 21 support that either.
This isn't a radiation protection 22 contention, and it's simply irrelevant.
23
[ Judges confer.)
24 JUDGE BECHHOEFER:
The Board has decided that we 25 will accept 25 and 26.
The contention includes what should i
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725 be the proper scope of the maintenance program, and whether 1
1 2
they should or shouldn't be in the program is an issue i
3 before us, and, on that basis at least, we will accept that i
4 evidence.
We give no information or inclination as to what i
5 weight we will give it, but we will accept it into evidence.
6
'l 7
MS. HODGDON:
I wanted to make clear that Exhibit 8
26 wasn't offered.
9 JUDGE BECHHOEFER:
Oh, I'm sorry.
I just asked --
10 MS. CURRAN:
Oh, that's right.
We offered it for 11 identification --
l 12 JUDGE BECHHOEFER:
Oh, okay.
Oh, okay.
That's a 13 staff document.
Okay.
j 14 MS. CURRAN:
So we're talking about Exhibit 25.
I i
O 15 just need some clarification from the Board ---
f 16 JUDGE BECHHOEFER:
Okay.
26 will stay marked as l
17 26.
25 we will admit.
18 MS. CURRAN:
I'd like to get some clarification 19 from the Board, because one of the purposes for which we're 20 introducing this evidence is to demonstrate the problems in 21 maintenance with respect to radiation protection, and I'd 22 like to clarify that that has been acknowledged as a 23 relevant purpose of the testimony or not.
24 MR. REPKA:
That's an argument, and I think 25 Ms. Curran can make that argument --
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JUDGE BECHHOEFER:
We're not including it, but 2
you'll have to argue later on that it should be used that 3
way.
MS. CURRAN:
All right.
I just didn't -- wanted 4
to make clear it hadn't been limited that I was not allowed l
l l
5 to make that argument.
6 JUDGE BECHHOEFER:
No.
I 7
MS. CURRAN:
Okay.
8 JUDGE BECHHOEFER:
Not to our knowledge.
9 MS. CURRAN:
All right.
Well, shall we move on to 10 the next category, which is --
11 JUDGE BECHHOEFER:
Yeah.
Wait a minute.
I'm 12 remind you that in about 23 minutes we've agreed to start 13 considering the --
14 MS. CURRAN:
All right.
15 JUDGE BECHHOEFER:
-- the other document.
So just 16 gauge -- considering the next one you pursue, gauge how much 17 time it's likely to take.
18 MS. CURRAN:
All right.
We'll try it.
These are l
19 Exhibits 27, which is NRC DCO-93-MF-9039 dated July 27, l
20 1992, and Exhibit 28, which is NCR DCO-91-MM-N061 dated i
21 October 25, 1991, and Ms. ZamEk will conduct our cross-22 examination on this one also.
23
[ Pause.]
24 MS. CURRAN:
Whenever you --
25 MR. REPKA:
Well, was Ms. ZamEk going to conduct t
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some cross-examination first, or -- I'll be glad to proceed.
2 3
JUDGE BECHHOEFER:
Do you prefer to proceed and 4
ask --
5 MR. REPKA:
I would prefer to proceed.
6 JUDGE BECHHOEFER:
Yeah.
Right.
7 MS. CURRAN:
Oh, okay.
8 JUDGE BECHHOEFER:
Why don't you go ahead.
9 MS. CURRAN:
Yeah.
That's how I was assuming we 10 would do it.
11 MR. REPKA:
Whenever the panel is ready, just let 12 me know.
13 JUDGE BECHHOEFER:
Well, when I referred to 14 Mothers for Peace, I just meant they should move on to the 15 next one.
We're using the procedure we approved earlier.
16 MR. REPKA:
Let me direct your attention first to 17 Exhibit 27, NCR DCO-93-MF-NO39.
Can you tell me what issue 18 is addressed in this NCR?
19 MR. GIFFEN:
That's the intake structure for the 20 auxiliary salt water pumps and motors are located.
During a 21 walk-down, it was found that there was a container, and it 22 said on it, "For ASW oil," and I'm not sure where in here it 23 says that, but this is how it goes.
24 We looked, and the oil in that container was not 25 the correct oil for auxiliary salt water pump motor.
We O
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were doing maintenance on one pump.
We were.doing a PM on 2
one the motors, changed the oil.
We analyzed the oil in the 3
can.
It wasn't the right oil.
4 We also took a sample to determine if the oil had l
5 been added to the motor, and it came back that there was a l
6 small amount of this incorrect oil in the auxiliary salt l
l 7
water pump motor.
The amount of oil that was there was less l
8 than 10 percent.
i i
9 Right now, we haven't figured out how the oil was j
l i
10 added to -- the incorrect oil was added to the motors.
We l
l 11 believe that after a motor is started up, after its had its l
12 oil change and started up, then the oil settles down in the l
13 components, and this small amount was used to v.op.off the 14 oil in the motor.
15 We did an analysis.
We talked to Chevron, the oil 16 supplier, and asked them if there was any problems mixing l
17 these two types of oils, and he said, "In the amounts that l
18 you mixed, there was no problem or concern with i
19 compatibility.
20 An engineer who is more familiar with oils than I 21 am said for the amounts that we had, it would be similar to 22 taking, maybe, running 40 weight in the machine and adding a 23 little bit of 10 wait to top it off.
24 So we looked at the oil.
We found out that oil 25 was also added to two other pumps, so that three pumps had j
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incorrect oil added, and we took the auxiliary salt water s
2 pumps that were operating off line and changed the oil, and 3
we have a nonconformance to try to figure out who added the 4
oil.
5 MR. REPKA:
Now, this oil can that was in the area 6
of the auxiliary assault water pump was labeled oil for 7
the --
8 MR. GIFFEN:
It said ASW pump motor oil.
9 MR. REPKA:
Okay.
So you found that there?
10 MR. GIFFEN:
Yeah, during the walk-around.
11 MR. REPKA:
During the walk-around, and then, in 12 the first auxiliary salt water pump motor where there was j
13 this 10 percent oil, did you find that doing the PM before 14 or after you found the can that was marked auxiliary salt O's 15 water pump oil?
Was that a respond -- doing the PM to look 16 at the oil, was that a response to finding this can?
17 MR. GIFFEN:
Yes.
18 MR. REPKA:
And in the first pump it was, you 19 said, about 10 percent of the --
20 MR. GIFFEN:
Yes.
The numbers that I have been 21 given are about 10 percent oil was added.
22 MR. REPKA:
What about the other two pumps?
23 MR. GIFFEN:
About the same numbers, I believe.
24 MR. REPKA:
So for all three pumps that wouldn't 25 have affected operability?
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MR. GIFFEN:
No.
No -- for those small amounts, l
l 2
no incompatibilities of the oils in any of the three motors.
3 4
MR. REPKA:
Now, normally, where is the oil for 5
these motors kept?
6 MR. GIFFEN:
It's in the turbine building, which 7
is a ways away from the intake.
So someone took oil down to 8
the intake to add to the pumps.
I O
MR. REPKA:
The turbine building is located?
10 MR. GIFFEN:
Probably it's at elevation 85.
The 11 intake's down at elevation of about 20, and it's probably 12 about 1,600, 1,600 yards.
l 13 MR. REPKA:
Now, the oil --
O 14 MR. GIFFEN:
1,600 feet.
15 MR. REPKA:
The oil near the -- where it's 16 normally kept in the turbine building, is it controlled in l
l 17 any way?
l l
18 MR. GIFFEN:
Yeah.
The methodology we use to 1
19 control the oil, and, as you see, there's another instance 20 that the Mothers of Peace gave as an exhibit, there's two l
21 concerns about lubricants.
l 22 MR. REPKA:
Well, let's not talk about that issue 1
l 23 yet.
24 MR. GIFFEN:
The lubricants are kept on the 85-25 foot level of the turbine building, and it's, sort of, an 1
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honor system,that we use.
People that are supposed to add 0
2 oil to rotating equipment are required to know the procedure 3
that we use and how you add oil and that there are certain i
4 pieces of equipment that require special oils.
l 5
So all these oils and greases are kept in one 6
space in the turbine building, and there's a procedure in 7
there, check-out log, and, in the procedure, it says for i
8 each equipment what oils you're supposed to use or what 9
grease that you're supposed to use.
l 10 So, apparently, someone got the wrong one, either l
11 that or put it in something that was marked something else, 12 and it got at the in-take structure and was used and added
(
13 to the motors.
I i
14 MR. REPKA:
But they left this marked can down at
~
i 15 the in-take structure?
16 MR. GIFFEN:
Yes, they did.
17 MR. REPKA:
Do you know why they would have done 18 that?
19 MR. GIFFEN:
Probably didn't think they had done 20 anything wrong.
21 MR. REPKA:
In this case, has the control over the 22 oil, has that problem been fixed?
23 MR. GIFFEN:
I still -- I think that there's still 24 an issue that we need to address.
I mean, this happencd, 25 and I directed a different director to be responsible for O.
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1 the oil.
We're going to -- instead of going on the honor 2
system, we're going to look at a methodology whereas, if you 3
need oil for an auxiliary salt water pump motor, you come up 4
and say, "I need oil for this," and then that will be issued 5
by a person that works in the maintenance organization l
6 that's familiar with the procedures.
7 MR. REPKA:
Okay.
Let's look at the second 8
incident that's addressed in Exhibit 28.
Can you describe i
9 this incident?
10 MR. GIFFEN:
Well, that one it looks like that 11 when grease guns were used, and we have it labeled to only 12 use this grease gun for this type of grease, and then they 13 put a cartridge of different. type of grease in it.
There's 14 several examples of where gresse guns, a regular grease gun
)
i l
15 with a tube on it, and then the hose had the wrong tubes in 16 it, or there was different greases in it than were supposed 17 to be.
l 18 Again, an analysis was performed that, for the PMs 19 that would be required to be done that the small amounts of l
20 grease that would be left in the tube or the hose of the 21 grease gun wouldn't have had any safety significance on the 22 operation of the components.
l 23 MR. REPKA:
So, is there any suggestion that the 24 wrong grease cartridge was used?
25 MR. GIFFEN:
No.
The indication is that we ANN RILEY & ASSOCIATES, LTD.
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probably put the wrong cartridge in the wrong gun.
O 2
MR. REPKA:
The right --
3 MR. GIFFEN:
They used the right grease on the 4
component, but we should have had the right component, the l
5 right grease and the right gun.
It looks like we probably 6
have two out of three.
7 MR. REPKA:
In how many cases?
8 MR. GIFFEN:
Looks like six.
9 MR. REPKA:
And so the issue here was that it's l
10 the little bit of grease left in the hose of the grease gun 11 that might have been mixed?
12 MR. GIFFEN:
That's how I understand that this 13 occurred, yes.
14 MR. REPKA:
Right.
And this didn't have any 15 safety significance?
16 MR. GIFFEN:
No, it did not.
17 MR. REPKA:
Because of the quantities of grease 18 being mixed were very small?
19 MR. GIFFEN:
Yeah, and that's in -- in the 20 analysis of the event on page 5.
21 MR. REPKA:
Has this incident been addressed?
22 MR. GIFFEN:
Well, this one has been addressed, 23 and then we hadn't had any issues for the last three years, 24 and then we have another oil problem, and it's a lubricant, l
25 and so I'm considering what I need to do to make sure that I ANN RILEY & ASSOCIATES, LTD.
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don't have it again.
O-2 We thought that we had had a handle on it and that 3
posting the procedure and having the rules posted and giving l
4 training to those people that use oils would have resolved
)
5 this, but it, apparently, didn't.
6 MR. REPKA:
So you took corrective actions for the 7
grease gun --
8 MR. GIFFEN:
Yes.
9 MR. REPKA:
-- and were satisfied with the 10 results, and then this second -- the oil problem you l
11 referred to is the problem you just discussed, the incident i
i 12 of the --
j 13 MR. GIFFEN:
Yes.
14 MR. REPKA:
-- can down in the in-take.
And 15 you're still evaluating further, correct?
16 MR. GIFFEN:
Yes, I am.
We have not -- on the l
17 newest nonconformance report, we have not finished it.
It l
18 occurred in July of this year.
19 MR. REPKA:
Does any of this suggest to you a 20 pervssive problem with maintenance and surveillance?
21 MR. GIFFEN:
No.
It indicates that I have had a 22 couple of problens with oil over the last three years.
i 23 MR. R2PKA:
I have no further questions, and I 24 have no objection to admissibility of these documents.
25 MS. ZAMEK:
In your testimony on page 37, it ANN RILEY & ASSOCIATES, LTD.
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describes all the wonderful supports, the machine shops, the 2
telecommunication, INC, the tool storage, the repair 3
stations and all that.
So when he read these documents, 4
these exhibits here, I was concerned about the control of 5
the lubricants as a support to maintenance.
6 I would like to turn first to the Exhibit 28.
7 MR. REPKA:
Was that a statement or a question 8
they're leading up to?
9 MS. ZAMEK:
Well, the question is, if everything 10 is so wonderful, why does there exist this long-standing 11 problem?
And maybe I need to ask some other questions 12 first.
13 MR. REPKA:
Well, I'm not sure there's a 14 foundation for, A, wonderful and, B,
long-standing problem.
15 MR. GIFFEN:
I had a problem in 1991 that was 16 lubricants that was we self-identified with our quality 17 insurance department.
We had a problem in 1993, which we 18 identified and we're still investigating.
I'm sorry I can't 19 agree with your terminology.
20 MS. ZAMEK:
Okay.
All right.
Then turn to page -
21
- Exhibit 28, page 8, and there maybe you can tell me about 22 a previous similar event.
23 MR. GIFFEN:
Not without it in front of me, no, 24 but if I had a problem before 1991, then I took corrective 25 action.
A system went out and found problems, and we put in ANN RILEY & ASSOCIATES, LTD.
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places to fix it, and then something happens again.
We'll l
2 look at those corrective actions we've put in place and j
-I 3
refine them and, hopefully, we won't have-a personnel error i
4 in the issuing of oil.
l 5
MS. ZAMEK:
So you don't know what happened in the 6
previous --
l 7
MR. GIFFEN:
No.
j 8
MS. ZAMEK:
-- similar event?
9 MR. GIFFEN:
No, not without having --
10 MS. ZAMEK:
But you can tell that there was a f
11 violation issued; is that correct?
t 12 MR. GIFFEN:
It says there was a notice of l
C 13 violation, yes.
t 14 MS. ZAMEK:
Right.
Okay.
So there --
O-I l
15 MR. GIFFEN:
And it says it was in 1987.
16 MS. ZAMEK:
Correct.
17 MR. GIFFEN:
I think that's what the terminology 18 was.
i i
l 19 MS. ZAMEK:
Okay.
And so were you happy with the 20 corrective actions taken in 1991?
i f
21 MR. GIFFEN:
Am I happy with them?
i 22 MS. ZAMEK:
Do you.think they were effective?
l 1
23 MR. GIFFEN:
They were effective with grease.
I 24 am still concerned that I had a problem, and each time that i
25 we have a problem, whether it be an isolated event that i
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occurs this year or one that occurs three years ago, we try
{
O i
2 to -- we address them using our nonconformance system and l
3 look to see what we can do to prevent them from happening i
4 again.
I'm not happy when I have a personal error, no.
I 5
stated that before.
MR. VOSBOURG:
I think in
[
6 the 1991 NCR there were several cases where we found, you 7
know, grease guns being misused, some containers that were 8
left in the oil storage facility not being marked, and those 9
are all violations of our administrative procedure.
10 The oil storage facility is located the way it is 11 because it's not just maintenance that uses the oil and f
i 5
l 12 lubricants.
Operations uses, routinely uses both the oil 13 and the lubricants in that facility as they do their rounds.
r i
14 They may find that a condensate pump needs, you know, a j
O 15 quart of oil added to the upper bearing..
I l
16 So they'll go to that facility, find out what oil l
17 they need to use, log it out and add it.
Because we have --
6 18 we leave it on the honor system because, if you make it too 19 hard to get the oil, human nature is that, well, you may i
20 wait -- you know, you may wait until tomorrow, you know, to I
l l
21 go and get the oil, because, well, it's late.
l l
22 We want to keep the oil available~to the operators l
23 to use in the plant.
After '91, we tightened up the 24 requirements on using the oil.
We train the operators.
We 25 train the maintenance personnel, and we haven't had any O
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1 other events like this until just this recent case where we l
2 found this container of oil down at the in-take facility.
3 So I think that the program has improved, and I 4
think that, you know, in this event, we're going to look l
5 further and find out if we can determine how the oil got 6
there and take further corrective actions, but I think, in t
7 general, there has been a big improvement in the control 8
program for the oils.
9 MS. ZAMEK:
In what way did you tighten up?
I 10 thought it was an honor system, and what way did you tighten 11 up the control of the lubricants?
12 MR. VOSBOURG:
Mainly in the training of the i
i 13 individuals using it.
A lot of the things that were found l
14 by the quality assurance department in '91 were small I
15 violations of the procedure where you don't leave unmarked 16 containers anywhere, and you don't reuse containers.
17 If an operator is going to add oil to a pump, he l
18 has to get a fresh, clean container.
When he's done, he 19 disposes of that container.
There were cases where people 20 may bring a container that they use back and leave it inside 21 the facility.
They didn't dispose of it.
That could then 22 be used by the next person thinking it was a clean 23 container.
24 They were minor things like that, and there were 25 times that we found that the oil was added, and it wasn't
{
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logged out in the log book there, as required.
Again, it's 2
an administrative requirement to be able to track where we 3
use lubricants.
4 So there were things like that.
So we did a lot 5
of training with the operations personnel and with the 6
maintenance personnel so that everybody, we made sure, was i
7 familiar with the requirements on the control of the 8
lubricants, and I think it was fairly effective.
We have i
9 haven't seen the same type of general small mistakes 10 occurring since
'91.
j i
I 11 MR. GIFFEN:
And if you'll look at the corrective I
i 12 actions that are specified on the nonconformance report also 13 goes into a little more detail of things other than the 14 training that David talked about is that the maintenance 15 department looked -- they appointed a foreman.
16 We did weekly and monthly reviews of the facility
]
17 to see if it was being -- if the grease was being handled 18 correctly.
So we did -- we did make corrective actions to 19 try to prevent reoccurrence, any problem that we'll address.
20 21 MS. ZAMEK:
Okay.
I'd like to move to Exhibit 27 22 now.
23 MR. GIFFEN:
The
'93.
I 24 MR. REPKA:
Just a point on that road map the 25 Mothers handed out.
It puts a date there, 7/27/92.
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l 1
believe that should be
'93, the date of the NCR.
l
-s l \\~-)
i i
i 2
MS. ZAMEK:
Yeah.
It should be
'93.
On page 8, 3
in those cases --
4 MR. GIFFEN:
I'm sorry.
I didn't hear you.
5 MS. ZAMEK:
Wait a minute.
I didn't finish.
In 6
both events you stated that this was not a problem at all, 7
but it does describe the worse case scenario on this page.
l 8
Can you explain that to me?
9 MR. GIFFEN:
It says that the worse case scenario 10 that it would eventually cause increased wear and subsequent 11 failure if it wasn't detected through normal means.
In the 12 worst case, is you just say it's just like the hypothetical 13 example.
You put the wrong oil in at the worse case and let 14 it run without looking at it or monitoring the temperature, j
15 just allow it to run, that eventually will fail.
That's 16 what this says.
17 MS. ZAMEK:
So that could be a problem?
18 MR. GIFFEN:
Yeah, but it's also an assumption i
19 that nothing would be monitored, no temperatures, no l
20 vibration, no flow, that you just let it run forever.
21 MR. VOSBOURG:
And we do have a program that 22 routinely samples the oil on these particular components 23 that looks for evidence of excessive wear.
So it would be 24 picked up there.
1 25 MR. GIFFEN:
But it also said that considering the ANN RILEY & ASSOCIATES, LTD.
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1 worse scenario that it would be capable of performing its 2
safety function.
That's the next paragraph below the one l
I 3
that you were reading.
4 MS. ZAMEK:
I would like to get back a little bit 5
to the honor system, my last question, I think.
Mr. Giffen 6
mentioned abandoning the honor system, perhaps.
When might 7
that occur?
8 MR. GIFFEN:
I don't know if we're going to do 9
that, and that's what Mr. Vosbourg was talkf. 7 We have to 10 be very careful that we don't put a system in p.- e that's 11 too onerous for people to use.
So we need to look at what i
12 we're doing to make sure that it makes sense.
13 If it mates sense to have, you kr4ow, quart oil 14 cans stay beside pumps and a little signs that says, "These l
15 are for this," we may do that, and for the large bulk 4
16 lubricants still stay on the -- then control those a little 17 tighter.
18 My initial reaction was we might want to get away 19 with it, but we always listen to the other side of the story 20 to see what we can do that makes the most sense.
In this 21 case, we have not decided what course of actions we're going 22 to take based upon this occurrence.
l 23 JUDGE KLINE:
I guess l'm a little confused, S4 because I thought I heard you say before that you had 25 implemented a system of issuance of --
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MR. GIFFEN:
No, sir..
0 2
JUDGE KLINE:
Or you're contemplating doing that, i
3 but you haven't implemented it?
- l 4
MR. GIFFEN:
No, we have not.
5 JUDGE KLINE:
Okay.
6 MR. GIFFEN:
And the reason is because someone, as 7
Mr. Vosbourg -- some of those concerns are some of the i
8 reasons that we're still discussing.
9 JUDGE BECHHOEFER:
How was this oil labeled?
10 MR. GIFFEN:
There was a container, and on the 11 container it had written, " ASW pump motor oil."
That's how 12 it was --
13 MR. VOSBOURG:
So, apparently, somebody had gotten l
14 a can to take some oil down to the in-take and filled it 15 with the incorrect oil, taken the can down to the in-take, 16 added oil and left it there, and'it was found by the 17 maintenance personnel later.
i 18 First of all, there shouldn't have been a 19 container at the in-take with oil in it.
It should have l
20 been used once and then disposed of.
21 JUDGE BECHHOEFER:
Is there any connection, 22 similarity of the activities encompassed by this NCR and 23 those which were the subject of -- the description is a 24 March 26,
'87, a notice of violation issued by the NRC.
Is 25 there any relationship at all, and, if so, can you explain ANN RILEY & ASSOCIATES, LTD.
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it?
That's-referenced on page 2 of the' document.
O 2
- MR. GIFFEN:
I'm not sure.
This says that, 3
" Contrary to the requirements of our own 4
procedure, a one-gallon unlabeled 5
container filled with oil was in the 6
tool shed, and another unlabeled 1
7 container filled with oil was in a 5
8 storage cabinet.
9 So this is'that -- not that it was added.
10 This, apparently, seelas to be a failure to follow j
11 administrative procedure on_D753."
i 12 JUDGE BECHHOEFER:
Well, could the current 13 incident also be characterized as failure to follow that i
14 particular procedure?
l 15 MR. GIFFEN:
Yes, because that procedure dictates 16 what oil you're supposed to add to what components.
17
[ Judges confer.]
18 JUDGE BECHHOEFER:
What do you now wish to -- I l
l 19 guess --
t 20 MS. CURRAN:
Well, we nude to move Exhibits 27 and j
\\
21 28 into the record.
22 MR. REPKA:
Well, before you do that, may I ask 23 one follow-up question?
l 24 JUDGE BECHHOEFER:
Of course.
Of course.
25 MR. REPKA:
Mr. Giffen, could-you give us a 1
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1 qualitative assessment of how many times a day a year a 7--
2 month, whatever you might be able to, somebody uses grease 3
or oil or a lubricant of any kind from the grease and 4
lubricant oil storage area?
5 MR. GIFFEN:
I'd say daily.
Mr. Vosbourg --
6 MR. VOSBOURG:
I would say, speaking from the 7
cperations area, who is the other group that primarily uses 8
the facility, probably a couple times a day somebody might 9
use some oil from the area.
10 MR. REPKA:
So, if it's a couple times a day, 11 that's 700 and some-odd times a year?
12 MR. VOSBOURG:
Yes, and, in addition, you know, 13 our preventative maintenance activities that we perform on 14 motors and pumps -- we change oil periodically, and so there 15 will be more times uhen people are using the facility.
I 16 also stated before we have a sampling program where we 17 monitor the oil for any wear products as part of our 18 predictive maintenance program.
19 That, of course, you would have to add oil after 20 removing oil for a sample.
So, you know, it's used fairly 21 frequently.
22 MR. REPKA:
Nothing further.
23 JUDGE BECHHOEFER:
In responding to the NRC's 24 Notice of Violation, did the licensee or did PG&E make any 25 commitments in this area?
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1 MR. GIFFEN:
I'm not familiar with any
' O 1
2 commitments.
I don't have the Notice of Violation.
i 1
I 3
JUDGE BECHHOEFER:
Now, I'm talking about the one 4
on page 2.
5 MR. GIFFEN:
I understand.
That's the 1987?
6 JUDGE BECHHOEFER:
March 26, 1987.
7 MR. GIFFEN:
Yeah.
I don't have a copy of that --
i 8
or that Notice of Violation.
So I don't know what l
l l
9 commitments were made.
I l
10 JUDGE BECHHOEFER:
I see.
i l
11 MR. GIFFEN:
But, as a routine course, when we do l
l 12 have -- report to the NRC, and we do make commitments on 13 what we're going to do, and then the NRC routinely closes "T
14 those reports, and this Notice of Violation isn't open.
So, 15 therefore, any commitments that we made would have also been 16 closed.
i 17 JUDGE BECHHOEFER:
Okay.
These documents have 18 been moved for admission.
Any opposition to these?
l l
19 MR. REPKA:
No.
As I stated before, no 20 opposition.
21 JUDGE BECHHOEFER:
Oh, okay.
Without opposition 22 to these exhibits, which are 27 and 28 are admitted into i
l 23 evidence, and with that I think we've reached the time when 24 we should go into closed session.
25 MS. CURRAN:
I have one more thing that I'd like ANN RILEY & ASSOCIATES, LTD.
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to raise, and that is that we have passed out and identified 2
Exhibits 1 and 4.
1 is an NRC document, and 4 is an INPO 3
document that discussed the scope of maintenance programs.
4 They may be used throughout this proceeding, and I wasn't 5
sure when I should move them into the record.
6 We may also use other -- there's a couple other 7
documents that describe definitions of scope.
I don't know 8
whether that was proper to do that now or to wait.
9 MR. REPKA:
I think we should wait until -- see
{
10 how they're used and see if any relevance is established, 11 and then we can deal with that at the end of the Mothers 12 case.
13 JUDGE BECHHOEFER:
Right.
I think we don't gain 14 anything particular by dealing with it now.
It might --
15 there may be more connections with relevance as we go on.
16 So I don't think it could hurt you, and we'll promise not to 17 lose our copy.
So why don't we at least close the open 18 record for the day and adjourn maybe for five minutes and 19 then come back.
MS. CURRAN:
Could we have 20 ten minutes?
21 JUDGE BECHHOEFER:
Yeah.
We have to figure out 22 how we close the room, and I guess we'll get some help.
23 MR. REPKA:
I thought we were going to meet in the 24 kitchen or something.
25 JUDGE BECHHOEFER:
No.
That's a little small and O
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a little uncomfortable, but the parties will have to decide 2
which person should be privy to this next discussion.
With 3
that, let's adjourn and come back in ten minutes, which will 4
be a quarter to 5:00 for an in-camera session.
5
[Whereupon, at 4:45 p.m. the public hearing was 6
recessed.]
7 8
9 10 11 12 13 15 16 17 18 19 20 21 i
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REPORTER'S CERTIFICATE O
This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission In the Matter of:
NAME OF PROCEEDING:
In the Matter of:
PACIFIC GAS &
ELECTRIC COMPANY (DIABLO CANYON, UNITS 1 & 2)
DOCKET NUMBER:
50-275/323-OLA-2 l
l PLACE OF PROCEEDING:
San Luis Obispo, California-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 l
transcript is a true and accurate record of the l
foregoing proceedings.
Wik / / ftW O
~~
t Official Reporter l
Ann Riley & Associates, Ltd.