ML20072A593

Supplemental Testimony of Ld Johnson Re Torrey Pines Technology Independent Verification.Rept Took Into Account Fact That More than One Discrepancy or Condition May Be Included in Discrepancy Rept.W/Certificate of Svc

ML20072A593
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	01/17/1983
From:	Johnson L LONG ISLAND LIGHTING CO.
To:
References
ISSUANCES-OL, NUDOCS 8301240071
Download: ML20072A593 (22)

Text

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. LILCO, Jenuary 17, 1983 DCLKETED UFC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

'83 JCl 21 N1 :20 Before the Atomic Safety and Licensing Board r

In the Matter of )

)

LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322 (OL)

)

(Shoreham Nuclear Power Station, )

Unit 1) )

SUPPLEMENTAL TESTIMONY OF LOUIS D. JOHNSON REGARDING TORREY PINES TECHNOLOGY'S INDEPENDENT VERIFICATION OF SHOREHAM NUCLEAR POWER STATION

1. Mr. Johnson, what is the purpose of this supplemen-tal testimony?

A. To respond to certain contentions in paragraph VI of the County's handwritten, undated memorandum entitled I "Suffolk County Torrey Pines Technology Examination" (County's Memorandum).

2. In paragraph VI(l) of the County's Memorandum, the County contends that a large number of Discrepancy Reports (DR's) contain more than one discrepancy. With respect to the first three DR's listed by the County, DR's 006, 023 and 035, have you examined these, Mr. Johnson, to determine whether r-~

8301240071'830117 PDR ADOCK 05000322 i T PDR

these first three on the County's list include more than one discrepancy?

A. Yes, I have examined those DRS for this purpose.

It is true that more than one specific condition or item is listed on each of the referenced DR's (006, 023, and 035).

There is, however, only one kind of dis'crepancy presented on each of the referenced DR's. As matters turned out the '

conditions or items noted on these J DR's, were not valid, i.e., they were not, in the final analysis, different from a requirement.

3. Please describe the nature and the contents of DR's 006, 023 and 035.

A. DR-006 identifies 14 missing radiation detectors, all in system Dll and of the same type. Six of the detectors are safety related and PFR-056 was generated for these six detectors. Our investigation disclosed that a Repair Rework Request existed which properly controlled the installation of all 14 detectors by the startup organization. They were also being tracked on the master punchlist. Accordingly, the PPR was invalidated because the observed condition was not dif fer-ent from a requirement. This item would have been invalidated at the DR stage had the TPT personnel been aware of the Repair Rework Request at that time. ,

DR-023 describes four identical pressure switches mistakenly thought to.be incorrectly located on the wrong side of a 2" crossover pipe between the 24" lines. The flow diagram used in this walkdown does not specify the exact location, but merely requires that the pressure switches be on the main steam line between the 36" header and the main steam control valves.

The flow diagram is not the installation drawing. Since these four pressure switches can be located anywhere along this line, the observed condition was not contrary to any requirement and the DR was therefore properly invalidated. Because the observed conditions were identical, they were logically put on one DR form.

DR-035 describes two identical discrepancies on loops A and B of system T48 at the hydrogen recombiners. At that time, the DR was thought to be valid an5 a PFR-001 generated. Our subsequent investigation disclosed that appro-priate repair / rework paper existed and was sufficient to invalidate the PFR because the observed condition was not contrary to a requirement. Here again, as in DR 006, these items would have been invalidated at the DR stage if TPT personnel had been aware of repair rework paper. These discrepancies were included in the same DR because they were identical and could logically be treated together.

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4. Mr. Johnson, is the inclusion of more than one item or condition in a single discrepancy report consistent with the i TPT procedures?

A. Yes.

5. In reaching the conclusions of the TPT independent verifichtion, did you and TPT take into account the fact that i more than one discrepancy or condition might be included in a DR?

A. Yes.

6. Does the fact that some or even many DR's may include multiple discrepancies change or affect the conclusions of the TPT independent verification report?

A. .No. -Let me explain the method we used to arrive at the conclusions presented in the report. In general, three basic questions were examined by competent and qualified engi- <

neering personnel: (1) Did LILCO have a satisfactory con-struction control program?, (2) Did LILCO implement the con-I struction control program?, and (3) Did the construction con-trol program result in sound safety related hardware? These questions are the underlying logic of the verification program as reflected in Tasks A through E. What we found as a result of our extensive efforts enabled TPT to answer the questions in the affirmative.

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7. Mr. Johnson, let us assume for the moment that it is relevant to count each condition or item listed in a DR as a or persons unider your supervision $

separate discrepancy, have you reviewed all of the DR's, A

including the 100 DR's listed in paragraph VI(l) in the County's Memorandum to determine the total number of separate, valid discrepant items or conditions listed in all DR's?

A. Yes. The total number is 303 separate items or i discrepant conditions out of the approximately 150,000 attributes or items inspected.

8.

You indicated earlier the fact that more than one discrepancy or condition might be included in a DR was taken '

into account by TPT in reaching its conclusions and that TPT's conclusions were not affected by that fact. Is the fact that there were 303 differences between observed conditions and requirements in all the DRs consistent with your answers to those questions?

A. Yes.

9. Mr. Johnson, at paragraph VI(2) of the County's Memorandum, the County notes that nine PPR's address more than one DR. With respect to the first three on the County's list, PPR's 016, 021 and 025, do these address more'than one DR?

A. Yes. PFR 016 incorporated DR's 063 and 104, PFR 021 incorporated DR's 114 and 141, and PFR 025 incorporated t

e DR's 032 and 033. However, each PFR dealt with only a single l l

potential safety concern although they referred to more than one DR.

10. Mr. Johnson, is the inclusion of more than one discrepancy report in a single potential finding report con-sistent with the TPT procedures?

A. Yes. A potential finding report relates to a sin-gle potential safety-concern. Each of the discrepancies referenced in the PFR is reviewed as a part of the PFR review process.

11. Would you please describe the contents and nature ,

of those PPR's?

A. PFR 016 dealt with valves that had not been installed in the control rod drive piping vent and drain lines.

DR 063 related to a missing valve in the drain line, and DR 104 related to a missing valve in a vent line in system Cll. PFR 021 dealt with an inability to verify that a valve 'as w the - '

correct hardware. DR 114 related to dimensional discrepancies on the valve and DR 141 related to a pressure rating discrepancy on the same valve. PFR 025 dealt with added relief valves in system P50.

DR's 032 and 033 related to an added r

1 relief valve in each of the legs of the system.

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< 12. What'was the disposition of the PFR's?

A. All three PFR's were invalidated based on addi-

, tional information (E&DCR's, Repair Rework Requests, and proper GE design definition document) provided by LILCO as part of the PPR review process. Thus, in each case the observed conditions were ultimately found to be in accord with the required c,nditions and therefore there was no safety concern so the PFR's were invalidated. .

13. Mr. Johnson, in your answers in this Supplemental Testimony, you have indicated that TPT personnel used addi-tional information such as E&DCR's, Repair Rework Requests and other documents in their ongoing consideration whether to invalidate or validate a PFR or DR. Did TPT take any steps to determine whether this additional information preexisted the inspection or was generated as a result of the inspection?

A. Yes we did. We were very sensitive to whether information that we received in terms of documents had been generated as a result of our activities or whether they preexisted. There was no case in which a DR or PFR was invalidated on the basis of information or documentation which i

did not preexist the inspection. Only in cases where the information preexisted was it used as a basis for reconsideration of the validity of discrepancies. In cases t

where the information was generated as a result of our activfties, the concerns were carried through the potential finding process and were classified as findings or observations depending on significance.

14. In paragraph VI(3)(a) of the County's Memorandum, the County contends that a number of DR's were improperly invalidated " generally for the reason that change from required condition did not affect system performance." With respect to the first three of these DR's,RD:R's 010, 011 and 012, do you agree that these were improperly invalidated as noted?

A. No. Those DR's involved branch line and drain line sequence and the reviewer in this walkdown was using flow diagrams. Flow diagrams, however, are not intended to specify the precise physical location of piping, but rather they present process system requirements in terms of function and system logic. These DR's relate to conditions addressing vents, drains and instrument lines or conditions relating to the precise sequence of branch lines in a process system, conditions that are not controlled by the flow diagram. When this use of flow diagrams in the Shoreham construction process was understood, the subject DR's were properly invalidated since there was no dif ference between the observed condition and the design requirements of the flow diagrams. Physical dimensional requirements for piping are specified in the piping isometric drawings, which were used appropriately in later walkdowns.

15. In paragraph VI(3)(b) of the County's Memorandum, the County contends that DR's 042 and 047 were improperly invalidated "because not within audit scope." Were these DR's improperly invalidated?

A. No. These DR's were properly invalidated because there was no difference between an observed condition and a requirement.

The particular walkdown from which the two DR's were written was to determine if major components were installed in the proper sequence in the system. The walkdown was carried out by comparing the hardware with the flow diagram.

The flow diagram may indicate the existence of 1

items like flanges or flex lines, but does not set the design requirements for these specific items. These items are specified on piping isometric drawings rather than in flow diagrams. The flow diagrams did not show the requirements for t' the flanges and flex lines that were the subject of DR's 42 and

47. Subsequent inspection of flanges and flex lines to the requirements specified on the piping isometrics showed that the flange and flex lines were properly installed.

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In paragr'ph VI(3)(c)cof the County's Memorandum,

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16. a the County contends that a number of DR's were improperly

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invalidated because DR "does not affect system performance."

with respect to the first three DR's in this group, DR's 9, 10 and 11, do you agree?

A. No. These DR's were properly invalidated because there was no difference between an observed condition and a requirement. The particular walkdown from which the two DR's were written was to determine if major components were installed in the proper sequence in the system.

The items in these DR's are not major components, but are items like vents and drains used in maintenance of system piping. Flow diagrams may indicate existence of these items but does not set the design requirements for these spe-cific items. These design requirements are specified on the piping isometric drawings, not flow diagrams. The reference to system performance merely indicates that the requirements for these items were not part of these particular walkdowns because the flow diagrams used did not have on them the requirements for these items. But the remark "Does not affect system per-formance" is not the reason for invalidating the DR. The reason for invalidating the DR is.that the observed condition was not different from any requirement.

17. In paragraph VI(3)(d) of the County's Memorandum, the County contends that DR's 186, 248 and 273 were improperly invalidated because "later review showed that discrepancy was resolved." Were these DR's improperly invalidated?

A. No. It is logical'to'use all the information available to determine validity of DR's. In these three cases, the supervising engineer was not satisfied that all information had been obtained and requested further investigation or walkdown. This was done routinely in evaluating validity of DR's. In these three cases it was clear that the additional information provided a firm basis for invalidating these three DR's.

18. In paragraph VI(3)(e).of .the County's Memorandum, the County contends that a number of DR's_were improperly invalidated because " secondary-pipe ~ support does not affect primary line." With respect'to the first three DR's in this group, DR's 245, 287.and 324, do'you agree?

A. No. We do not agree that these three DR's were improperly invalidated. The purpose of the pipe support s

walkdown that led to these DR's was to determine if the large bore pipe lines in the systems had supports which were located, oriented, and of the type required by the piping isometric drawing. The supports which are used to stiffen the vents and e

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A drains are clamped directly to the primary pipe line that the vents and drains serve. Requirements for precise locations of these supports are not specified on the large bore isometrics and therefore there was no difference between requirement and observed condition and the DR's were invalidated.

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I should note, though,-that an additional DR in the County's group 3(e), DR 328, related to a missing support.

This DR should have been valid, as was done on other DR's relating to missing secondary supports because a condition that met requirements was not observed. The existence of additional documentation controlling the observed condition was not then pursued because this DR presented no safety concern relating to the large bore' piping.

19. In paragraph VI(3)(f) of the County's Memorandum, the County contends that DR 25 was improperly invalidated because " circuit still functions properly." Was this DR improperly invalidated?

A. No. We do not agree that this DR was improperly invalidated because, as stated previously, the flow diagram does not dictate the location where piping should be interconnected other than between major components. Thus, there was no difference between a requirement of an observed condition. The note in the DR that states " circuit still

A functions properly" is not the reason the DR was invalidated but is merely a reminder that a discussion did take place. A flow diagram does not specify precise piping locations. This DR was properly invalidated because a requirement for the loca-tion did not exist at the flow diagram level.

20. In paragraph VI(4) of the County's memorandum, the County contends that the DR's listed in subparagraphs (a) through (f) were improperly invalidated because no PFR was written. ,

Is this correct?-

A. No. Based on a review of the first three DR's in each subparagraph, those DR's were not invalidated.- PFR's were not written because for each of'these reviewed DR's, there was

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no safety concern which Lwould ~ require the writing of a PPR.

J Valid DR's do not result in PFR.'s u'nless there-is a perceived-potential safety concern.

In paragraph 4(a)'of the County's memorandum, the

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County contends that a number of DR's, including DR's 144, 145 and 160, should have become PFR's. Da fou agree?

A. No. These were valid DR's, but under TPT's proce-dures they properly did not become PFR's because there was no safety concern. PFR's are not prepared unless there is a perceived safety concern by one of the reviewers that requires further evaluation. This group.of DR's represents valid

1 discrepancies of a minor nature or that do not affect the performance of the safety systems. For example, DR 144 indi-cates that a coupling on a line is located at a slightly dif-ferent location on the same line. Within a sequence of three supports, the coupling was actually located between the second and third supports, while the drawing showed it between the first and second supports. This had no effect on system opera-tion.

22. In paragraph 4(b) of the County's memorandum, the County contends that a number of DR's, including DR's 97, 106 and 108, should have become PFR's. Do you agree?

A. No. We disagree that these valid DR's should have generated a PFR since no safety problem was indicated. In each case, a difference between required and observed conditions is found, making the DR valid in the strictest sense. However, each of the discrepancies is trivial and in no way can be con-strued to be a safety problem. For example, DR 97 involved two non-safety related electrical items. One of these items was a non-safety related pressure differential transmitter providing l input to the startup transient monitoring system which was missing an identification tag. The only discrepancy was a missing identification tag. The transmitter itself does not affect safety because it merely provides a non-safety related measurement used to monitor startup.

23. In paragraph 4(c) of the County's memorandum, the County contends that a number of DR's, including 61, 298 and 306, should have become PFR's. Do you agree?

A. No. We disagree that these valid DR's should have resulted in a PFR since no safety problem was indicated. In each case, a difference between required and observed conditions was found, making the DR valid. In these cases, the items were mislabeled, but the proper equipment existed. For example, DR 81 was written because the diesel engine cooler for engine C was mislabeled. The mislabeling in no way presents a safety problem. The same is true for DR's 298 and 306.

24. In paragraph 4(d) of the County's memorandum, the County contends that a number of DR's, including DR's 120, 126 and 127, should have become PFR's. Do you agree?

A. No. These were valid DR's, but under TPT's proce-dures, they properly did not become PFR's because there was no safety concern. These DR's represent minor paperwerk discrepancies. In DR 120, the proper component checklist sign-off was not evident but the lack of this sign-off on a non-safety related level switch is not a safety concern. DR 126 records that a ch cklist should have required an N-2 data report in a package but did not do so. However, the N-2 data report was in the package. Thus, the DR was valid but does not E

constitute a safety problem so no PFR was required. On DR 127, a certificate of conformance for a pipe spool could not be located, but the proper piping material was confirmed through the material certification review and therefore a safety con-cern did not exist.

25. In paragraph 4(e) of the County's memorandum, the County contends that a number of DR's, including DR's 175, 180 ,

and 181, should have become PFR's. Do you agree?

A. No, we disagree. Procedures are written to provide guidance to the user. In other words, some items are more important than others. In the case of DR's 175, 180 and 181 which deal with the preoperational test package review, there were minor items that did not match the precise requirements of the procedures. TPT judged these items to be minor though valid and by evaluation of the remainder of the preoperational test report, TPT was able to establish that no safety concern 4 existed.

l 26. In paragraph 4(f) of the County's memorandum, the County contends that a number of DR's, including DR's 193, 244 l

and 312, should have become PFR's. Do you agree?

A. No. These were valid DR's but were properly not i

made PFR's because there was no safety concern. The particular vents and drains associated with these supports are located in L

d systems in which the failure of these drains will not impair their safety function. In addition, these supports do not support the primary line, but are merely there to stiffen the g

drain against seismic vibration. Thus, these DR's do not constitute a safety concern.

27. Paragraphs VI(5)(a)-(e) of the County's memorandum query the improper invalidation of PFR's. Were any PFR's t

identified by the County improperly invalidated?

A. No. On the basis of a review of the first three PPR's in paragraphs 5(a) through (e), no PPR's were improperly invalidated. Information was available and provided during the PFR evaluation stage that had not been identified at the DR '

stage. In all of these cases, the additional information dem-onstrated that the apparent discrepant conditions identified in the DR's had not in fact existed or had been corrected in the normal course of construction prior to issuance of the -BR-PFR Therefore, no discrepant conditions existed with respect to these PPR's and since no safety concerns were present, they were properly invalidated.

28. In paragraph 5(f) of the County's memorandum, the County contends that there was inconsistent application of invalidation criteria for a group of PPR's, including 063, 064

( and 085. Do you agree?  !

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i A. No. These PPR's were not invalidated. Therefore there could not be an inconsistent application of invalidation criteria. We assume that the County is questioning the fact that two of these PFR's became observations while the third became a finding on the temporary pipe supports. The reason for the difference is that PFR 064 was determined to be a finding under the multiple. discrepancy criteria and the other temporary pipe support concerns were classified as observations with a reference to PFR 064.

29. Paragraph VI(6) of the County's memorandum identifies a number of DR's, including DR's 105, 127 and 136, where documentation was not_readily available and could not be found. Do you agree that_for these three DR's, documentation was not readily available or could not be found?

A. No, we do not agree-that'the documentation was not readily available or could not be found. The initial reviewer was not able to identify independently the required docu-mentation for DR's 105, 127 and 136. Subsequent review by the team and task leaders, again acting independently, resulted in obtaining the required document on DR 105 to declare it properly invalid. In the case of DR 127, documentation was not found independently to invalidate the DR. Although it was left valid, a PFR was not issued since there was no safety concern.

4 Therefore, LILCO was never given the opportunity to provide additional documentation. It is not correct to say that "docu-mentation could not be found," without giving LILCO the oppor- q tunity to produce the document. In the case of DR 136, the required documentation was identified independently by TPT and the DR was properly invalidated.

In some cases, TPT had difficulty independently locating material because team members were initially unfamil- 4 iar with site document control. This in no way implies that LILCO is unable to identify readily the documentation and retrieve it. It must be noted that this was an independent review, and LILCO was not asked to find documentation about a ,.

perceived problem.c cept thrcugh the PFP accuracy reeicu prccecc. Du ring ibe review, LILCO provided o.ccess to documenlo: hon and , througk requests for informa4. on , provided spec [ic documenh.

Flow ever, LILCO wa.s not f_o(d t he re(son for a. documeni reguest.

or Ehe spectfic need -for a. d oc.umenk. L Sorne ca.se s, du r'ing ,

the PF R a.ccura.cj review process, LtLCO prodided a.d d de o n a.I documenkedi on which TPT hd not reguedecl oc hd not been 0.toa.re ex.isked c

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4 1 Respectfully submitted,  !

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LONG ISLAND LIGHTING COMPANY

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, T. S. Eldfs,III {

Anthony F[. Earley, Jr. I 1

i l Hunton & Williams I

Post Office Box 1535 Richmond, Virginia 23212 k

s l DATED: January 17, 1983 i i

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L1LCO, Januhry 17, 1983 o

00BEi,ED CERTIFICATE ~OF SERVICE

• g3 $ 1 21 M In the Matter of LONG ISLAND LIGHTING COMPANY ,qp-(Shoreham Nuclear Power Station,! Unit il-)VK' Docket No.' 50-322 (OL) " aR At1CH I hereby certify that c'opies of~ SUPPLEMENTAL TESTIMONY OF LOUIS D. JOHNSON REGAR' DING TORREY PINES TECHNOLOGY'S INDEPENDENT VERIFICATION OF SHOREHNM NUCLEAR POWER STATION were served by hand (as indicated: by two ' asterisks) on January 17, 1983, and upon the following by first-class mail, postage prepaid, or Federal Express _(as; indicated by an asterisk) on January 18, 1983: <

Lawrence Brenner, Esq.** Secretary of the Commission Administrative Judge U.S. Nuclear Regulatory Atomic Safety and Licensing . Commission Board Panel ' Washington, D.C. 20555 '

U.S. Nuclear Regulatory Commission

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Atomic Safety and Licensing Washington, D.C. 20555 Appeal Board Panel U.S. Nuclear Regulatory Dr. Peter A. Morris ** Commission Administrative Judge Washington, D.C. 20555 Atomic Safety and Licensing ~

Board Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Board Panel Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Dr. James H. Carpenter **

Administrative Judge Daniel F. Brown, Esq. i Atomic Safety and Licensing Attorney Board Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Board Panel Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555

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Bernard M. Bordenick, Esq.** David J. Gilmartin, Esq.

David A. Repka, Esq. Attn: Patricia A. Dempsey, Esq.

U.S. Nuclear Regulatory County Attorney Commission Suffolk County Department of Law Washington, D.C. 20555 Veterans Memorial Highway Hauppauge, New York 11787 Herbert H. Brown, Esq.** Stephen B. Latham, Esq.

Lawrence Coe Lanpher, Esq. Twomey, Latham & Shea Karla J. Letsche, Esq. 33 West Second Street Kirkpatrick, Lockhart, Hill,. P. O. Box 398 Christopher & Phillips Riverhead, New York 11901 8th Floor .

1900 M Street, N.W. ' Ralph Shapiro, Esq.*

Washington, D.C. 20036 Cammer and Shapiro, P.C.

9 East 40th Street Mr. Mark W. Goldsmith New York, New York 10016 Energy Research Group 4001 Totten Pond Road Howard L. Blau, Esq.

Waltham, Massachusetts 02154 217 Newbridge Road Hicksville, New York 11801 MHB Technical Associates 1723 Hamilton Avenue Matthew J. Kelly, Esq.

Suite K State of New York San Jose, California 95125 Department of Public Service Three Empire State Plaza Mr. Jay Dunkleberger Albany, New York 12223 New York State Energy Office Agency Building 2 Empire State Plaza Albany, New York 12223 C1 i

. ik26 T./gf>Ellis, III Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: January 17, 1983