ML20116A971

Transcript of 850314 Meeting W/Comanche Peak Response Team & NRC in San Francisco,Ca Re Independent Assessment Program Relevant to Issue of Design Adequacy of Facility.Pp 1-193. Supporting Documentation Encl

ML20116A971
Person / Time
Site:	Comanche Peak
Issue date:	03/14/1985
From:	CYGNA ENERGY SERVICES, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
References
NUDOCS 8504240657
Download: ML20116A971 (193)

Text

{{#Wiki_filter:_ oh *d fDF p-ws/wl 1 1 2 CERTIFIED COPY 3 4 5 6 TEXAS UTILITIES CPRT MEETING 7 8 THURSDAY, MARCH 14, 1985 9 9:30 A.M. 10 i ~ 11 CYGNA ENERGY SERVICES 12 101 CALIFORNIA STREET, SUITE 1000 13 SAN FRANCISCO, CALIFORNIA 14 '1 i 15 ATTENDEES: 16 HOWARD LEVIN, TERA CORP. DAVID L. SMEDLEY, CYGNA EDWARD BLACKWOOD, TERA CORP. JAMES J. OSZEWSKI, CYGNA 17 F. A. DOUGHERTY, TERA CORP. ROBERT E. NICKELL, CYGNA DOUGLAS M. WITT, TERA CORP. CONSULTANT 18 CHRIS MORTGAT, TERA CORP. ROBERT W. HESS, CYGNA I JOHN GUIBERT, TERA CORP. CRAIG KILLOUGH, CYGNA 19 TONY GUHL, ENERGEX DICK STUART, CYGNA ( TERRY G. TYLER, ENERGEX JOHN C. MINICHIELLO, CYGNA 20 JACK REDDING, TUGCO GORDON BJORKMAN, CYGNA WILLIAM R. HORSTMAN, TUGCO NANCY WILLIAMS, CYGNA 21 ROBERT C. 10TTI, EBASCO LEE J. WEINGART, CYGNA WILLIAM VAN METER, CASE WILLIAM R. HORSTMAN, CYGNA 22 JOHN FRENCH, DELIAN CORP. DARLENE K. LEONG, CYGNA SPOTTSWOOD B. BURWELL, NRC/NRR/DL JOHN P. RUSS, CYGNA ( 23 ANNETTE L. VI ETT I, NRC/NRR/DL SPENCER H. BUSH, REVIEW AND VINCENT S. NOONAN, NRC/ PROJECT SYNTHESIS ASSOCIATES 24 DIRECTOR ROBERT E. BALLARD, GIBBS ROBERT A. WOOLDRIDGE, & HILL, INC. 25 WORSHAM, FORSYTHE, SAMPEL & DAVID R. PIGOTT, ORRICK, l WOOLDP.IDGE HERRINGTON & SUTCLIFFE f 26 ARLENE G. MORRIS, CITIZEN 27 3 f 28 8504240657 850314 PDR ADOCK 05000445 T PDR f

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2 1 MR. LEVIN: I BELIEVE WE CAN GET STARTED. m .i 2 MY NAME IS HOWARD LEVIN. I'M REPRESENTING THE 3 COMANCHE PEAK RESPONSE TEAM. I'M CURRENTLY SERVING AS REVIEW 4 TEAM LEADER IN THE CIVIL, STRUCTURAL, MECHANICAL, AND DESIGN 5 ADE0UACY AREAS. 6 OUR MEETING TODAY IS BETWEEN CYGNA AND THE CPRT TO 7 DISCUSS FINDINGS FROM CYGNA'S ONGOING INDEPENDENT ASSESSMENT 8 PROGRAM RELEVANT TO THE ISSUE OF DESIGN ADEQUACY OF THE 9 COMANCHE PEAK STEAM ELECTRIC STATION. OBSERVERS OF THE MEETING 10 TODAY WHO WISH TO MAKE A STATEMENT MAY DO SO AT THE END OF THE 11 MEETING. 12 AS MANY OF YOU ARE AWARE, TUGCO RECENTLY MADE A 13 DECISION TO HAVE THE CPRT EXDEND ITS PROGRAM TO INCLUDE 14 RESOLUTION OF DESIGN ADE0VACY ISSUES. T 15 AT A FEBRUARY 26 PUBLIC MEETING, MY COLLEAGUES AND I 16 DESCRIBED AN OVERALL FRAMEWORK FOR DEALING WITH DESIGN ADEQUACY 17 ISSUES. SEVERAL KEY MEMBERS OF THE CPRT ARE HERE WITH ME TODAY. 18 THESE INDIVIDUALS WILL LEAD DISCUSSIONS IN THEIR RESPECTIVE 19 AREAS OF RESPONSIBILITIES, AND I WOULD LIKE TO INTRODUCE THEM 20 TO YOU. 21 TO MY LEFT IS FRANK DOUGHERTY, WHO WILL BE PLAYING A 22 KEY ROLE IN MANAGING THE DESIGN ADEOUACY EFFORTS. 23 TO HIS LEFT IS DOUG WITT, RESPONSIBILITY FOR PIPING 24 AND PIPE SUPPORTS AREA. 25 TO MY RIGHT IS ED BLACKWOOD, WHO WILL BE LOOKING AT 26 PROGRAMMATIC AND ENGINEER COMPLICATIONS ISSUES. 27 AND TO MY LEFT, AGAIN, IS CHRIS MORTGAT, WHO HAS g 28 RESPONSIBILITY FOR CABLE TRAYS AND SUPPORTS. Sp,'",'[,C,',5,C 0 DOIDGE & CARROLL c os,,, g o,,, CERTIFIED SHORTH AND REPORTERS cov%T* ca%*%D 44 's e32 'i 15 is t 5145 t -339e DEPOSITION NOTARIES

^~ e 3 1 ALSO HERE TODAY ARE MEMBERS OF THE CPRT SENIOR REVIEW k[ 2 TEAM. IN ATTENDANCE, YOU MIGHT INDICATE BY RAISING YOUR HAND, 3 JOHN GJIBERT, TONY BUHL, JOHN FRENCH, AND JOHN BECK. 4 WE ALSO HAVE VARIOUS CONSULTANTS THAT WILL BE 5 ASSISTING US IN THIS REVIEW WHO ARE NOT HERE TODAY, BUT WILL 6 PARTICIPATE IN DEVELOPMENT OF THE PROGRAM AND HAVE ACCESS TO 7 THE RECORD THAT'S CREATED TODAY. THESE GENTLEMEN INCLUDE 8 EVERETT BOW, BILL HALL, AND BOB KLAW. 9 THIS MEETING IS A SECOND IN A SERIES WE PLAN TO HOLD 10 WITH PARTIES WHO REVIEWED ISSUES APPLICABLE TO THE DESIGN 11 ADEQUACY QUESTION, THE FIRST MEETING BEING ON FEBRUARY 26 WITH 12 THE NRC STAFF. WE INTEND TO HOLD FUTURE MEETINGS WITH CASE AND 13 INTERVENORS. 14 THE OBJECTIVES OF THE SERIES OF THE MEETINGS, NUMBER T 15 ONE, TO ENSURE THAT WE CAPTURE IMPORTANT ISSUES TO FULLY 16 UNDERSTAND THE CONCERNS EXPRESSED BY THE SOURCE, AND IN THAT 17 PROCESS, NOTE THE SOURCE'S ASSESSMENT OF ENGINEERING 18 SIGNIFICANCE OF THESE ISSUES AND ANY KNOWLEDGE THEY MAY HAVE OF 19 THE EXTENT OR GENERIC IMPLICATIONS. 20 WE'RE IN THE PROCESS OF DEVELOPING A SCREEN CRITERIA 21 OR PROCESS FOR IDENTIFYING ISSUES REQUIRING SPECIAL ATTENTION. 22 THE CPRT RECOGNIZES THAT SELECTED ISSUES MAY BE SIGNIFICANT, 23 BUT AT THE SAME TIME IT'S LIKELY THAT OTHERS MAY BE VALID 24 DEVIATIONS, YET INSIGNIFICANT TO SAFETY. 25 WE'RE LOOKING FOR CYGNA TO HELP US FOCUS AND 26 CATEGORIZE THESE APPROPRIATELY. THIS ULTIMATELY WILL LEAD US 27 TO DEVELOPMENT AND EXECUTION OF ACTION PLANS FOR A RESOLUTION. 3 28 THROUGH OUR ONGOING REVIEW OF THE RECORD, WE HAVE Sy,'",'jC,',5,C o DOIDGE & C ARROLL cos,,,go,,, CERTIFIED SHORTH AND REPORTERS coa ** cana%o 5'53 " ea ssa ssi-aaos DEPOSITION NOTARIES

4 1 NOTED MANY KEY ISSUES, IN PARTICULAR SOME OF THE PAST 2 DIFFICULTIES IN RESOLVING THESE ISSUES. IT'S APPARENT TO US 3 THAT OUR ACTION PLANS FOR RESOLUTION SHOULD INCLUDE DIRECT 4 APPROACHES SUCH AS MODIFICATIONS AS CALLED FOR, AS OPPOSED TO 5 PROJECTED ANALYTICAL OR EXPERIMENTAL INVESTIGATIONS. 6 THIS APPROACH MAY OR MAY NOT BE OPTIMAL OR EXPEDIENT 7 IN ALL CASES. HOWEVER, IT'S INDICATIVE OF THE GENERAL APPROACH 8 FOR ME AND OUR MANDATE, THE MANDATE BEING THAT WE FEEL IT'S OUR 9 CHARGE TO PROVIDE CONFIDENCE THAT ANY SIGNIFICANT DESIGN 10 DEFICIENCIES ARE DETECTED AND RESOLVED. 11 IN MEETING THIS OBJECTIVE, OUR EFFORTS WILL BE 12 FOCUSED LARGELY ON THE QUALITY OF THE END PRODUCT. REVIEW OF 13 PROGRAMS IS, IN OUR VIEW, IS NOT AN END UNTO ITSELF AND, 14 THEREFORE, THESE REVIEWS WILL BE USED TO HELP DETERMINE T 15 IMPLICATIONS OF PROGRAMMATIC WEAKNESSES IN AN EFFORT TO BOUND 16 TECHNICAL ISSUES AFFECTING END PRODUCTS. 17 FURTHERMORE AND IMPORTANTLY, IS THE FACT THAT THESE 18 LESSONS WILL BE FACTORED INTO UNIT 2 AND THE OPERATIONS PHASE 19 OF THE COMANCHE PEAK PLAN. 20 FOR TODAY'S AGENDA, I WOULD FIRST LIKE TO HAVE A 21 BRIEF DISCUSSION ON THE PART OF NANCY AND HER STAFF DESCRIBING 22 SOME OF THE OVERALL OBJECTIVES AND METHODOLOGY, SCOPE AND 23 STATUS OF THE INDEPENDENT ASSESSMENT PROGRAM. I THINK THIS 24 WILL BENEFIT MANY OF THE PARTICIPANTS AND OBSERVERS TODAY. 25 FOLLOWING THAT, I WOULD LIKE TO GET INTO THE 26 SUBSTANCE OF THE DISCUSSION TO DISCUSS SPECIFIC TECHNICAL 27 ISSUES, AND WE'LL START OFF WHERE OUR PEOPLE TAKE THE LEAD IN s 28 ASKING CERTAIN QUESTIONS, FIRST IN THE AREA OF PIPING AND 5,'7,",',]Cy*,Cf DOnDGE & CARROLL ,og,, 3,,, CE RTIFIED SHORTHAND REPORTERS couve o.%aw 'd ' ' ' ' 3 ' ' ' ' 5 ietsi esi asos DEPOSITION NOTARIES l

I 5 1 SUPPORT CABLE TRAYS AND SUPPORTS, AND THEN LASTLY, ANY ISSUES ( 2 PERTINENT TO PROGRAMMATIC OR GENERIC IMPLICATIONS. THAT'S AN 3 AGENDA, AS WE SEE IT, AND THERE IS ANYTHING YOU WOULD LIKE TO 4 ADD. 5 MS. WILLIAMS: NO, THAT'S FINE. 6 LET ME INTRODUCE A COUPLE OF THE PEOPLE THAT I HAVE 7 WITH ME TODAY. TO MY RIGHT IS GORDON BdORKMAN, WHO IS ONE OF 8 OUR SENIOR CONSULTANTS ON THE JOB. NEXT TO HIM, JOHN 9 MINICHIELLO, PROJECT ENGINEER. MOST OF THE REVIEWERS ARE 10 SCATTERED AROUND THE ROOM HERE, AND AS NECESSARY THEY WILL BE 11 . PARTICIPATING IN THE CONVERSATION. 12 WE ALSO HAVE WITH US OUR SENIOR REVIEW TEAM. THERE 13 IS SPENCE BUSH. AGAINST THE WALL THERE IS BOB NICHOL DOWN 14 THERE. AND THERE IS MIKE SHULMAN AT THE END OF THE TABLE. AND T s 15 THAT'S THE HIGHLIGHTS OF OUR PARTICIPATING MEMBERS IN THIS ROOM. 16 I WILL ATTEMPT TO GO THROUGH AN OVERVIEW OF WHAT EACH 17 OF THE FOUR PHASES WERE, THE SCOPE, THE OBJECTIVES AND A LITTLE 18 BIT ABOUT WHERE WE ARE IN TIME. I'M NOT SURE HOW MUCH DETAIL 19 YOU WANT ME TO GO INTO ON THIS. SINCE WE JUST TALKED ABOUT 20 DOING IT LAST NIGHT, I HAVEN'T PREPARED ANYTHING TO HAND OUT. 21 SO I'LL JUST HAVE TO WALK YOU THROUGH THE PROCESS. 22 TO BEGIN WITH, PHASE 1 STARTED IN THE SPRING OF '83, 23 AND IT WAS INTENDED ONLY TO PROVIDE ADDED ASSURANCE. IT DID 24 NOT INCLUDE ANY KIND OF DESIGN REVIEW FROM A TECHNICAL 25 STANDPOINT. 26 IT WASN'T TOO LONG INTO PHASE 1 WHERE IT WAS DECIDED 27 THAT IT WAS REQUIRED TO DO A TECHNICAL DESIGN REVIEW, AND PHASE 3 28 2 WAS ADDED SO, THEREFORE, WE'LL TALK ABOUT PHASE 1 AND 2 AS sawsmascmco DOIDGE & CARROLL ''3'C cos,. cost. CERTIFIED SHORTHAND REPORTERS cov%" .4i sU4Nasse DEPOSITION NOTARIES

o o S 1 ONE REVIEW. 2 THERE IS A FINAL REPORT FOR PHASE 1 AND 2 WHICH HAS 3 BEEN ISSUED, AND WE HAVE REV ZERO ON THE STREET RIGHT NOW. THE 4 SCOPE WAS TO PROVIDE ASSESSMENT OF THE ADEQUACY OF THE DESIGN 5 CONTROL PROGRAM AT COMANCHE PEAK, TO PROVIDE AN ASSESSMENT OF 6 THE DESIGN ADEQUACY OF A SELECTED SYSTEM, TO VERIFY A SELECTED 7 AS-BUILT CONFIGURATION, AND TO EVALUATE THE EXTENT OF 8 IMPLEMENTATION OF SELECTED DESIGN CONTROL PROGRAM ELEMENTS. 9 THIS WAS NOT A FULL IDVP, IT DID NOT INCLUDE A 10 COMPLETE IMPLEMENTATION EVALUATION OF ANSI N45.2.11. BECAUSE 11 0F THE WAY PHASE 1 AND 2 DEVELOPED IN THAT, WE STARTED ON PHASE 12 1, AND PHASE 2 WAS ADDED LATER. TWO SYSTEMS WERE USED TO 13 CONDUCT THI'S REVIEW. 14 WE STARTED THE SCOPE OF PHASE 1 WITH A SPENT FUEL 15 POOL COOLING SYSTEM, THE REASON FOR THAT BEING IT WAS THE ONLY 16 COMPLETED SYSTEM AT THE TIME THAT WE COULD DO A WALK-DOWN ON. 17 WHEN PHASE 2 WAS ADDED TO DO THE DESIGN REVIEW, THE 18 RHR SYSTEM WAS SELECTED BECAUSE IT EXHIBITED MORE DEMANDING 19 JESIGN CHARACTERISTICS THAN DID THE SPENT FUEL POOL COOLING, SO 20 THERE IS NOT A COMPLETE CONTINUITY BETWEEN THE ONE SYSTEM AND 21 DOING THE WALK-DOWNS AND DESIGN REVIEWS AVAILABLE FROM THAT 22 WORK. 21 THE PHASE 3 WORK WAS ADDED EARLY IN 1984. THE 24 OBJECTIVE OF THAT WAS TO PERFORM A TECHNICAL REVIEW OF A 25 SELECTED SYSTEM IN THE AREA OF PIPING AND PIPE SUPPORTS, AND TO 26 ADDRESS CONCERNS THAT THE ASLB HAD WITH CERTAIN PORTIONS OF THE i 27 COMANCHE PEAK DESIGN CONTROL PROGRAM. THE SYSTEM SELECTED FOR 3 28 THAT WERE THE MAIN STEAM AND THE COMPONENT COOLING WATER SYSTEM. ','*]c Sto DOIDGE & CARROLL S' cosy,cos,. CERTIFIED SHORTHAND REPORTERS cow' o,,,, e sensiasi ases DEPOSITION NOTARIES

I i } 7 1 1 WE ASSESSED THE ADEQUACY OF THE PIPING AND PIPE s -4 2 SUPPORT DESIGNS FOR THOSE TWO SYSTEMS, ASSESSED THE ADEQUACY OF 3 TEXAS UTILITIES, GIBBS & HILLS NPS&I, AND ITT COORDINATION AND 4 ACCESS PROGRAMS AS THEY PERTAINED TO DESIGN. 5 WE VERIFIED THE ADEQUACY OF THE IMPLEMENTATION OF THE 6 CRITERION ONE AND 16 ORGANIZATION AND CORRECTIVE ACTION 7 PROGRAMS AS THEY PERTAIN TO DESIGN. THOSE ARE 10 CFR APPENDIX 8 B CRITERIA. THE RESULT 5 OF THAT REVIEW ARE AVAILABLE IN A 9 REPORT. REV ONE HAS BEEN ISSUED TO THIS DATE, AND THAT WAS 10 ISSUED SOMETIME IN THE SUMMER OF 1984. 11 SHORTLY AFTER THE BEGINNINGS OF PHASE 3, PHASE 4 WAS 12 ADDED. THE PURPOSE OF PHASE 4 WAS TO PERFORM AN INDEPENDENT 13 MULTIDISCIPLINE REVIEW OF ONE SYSTEM AND TO ADDRESS ADDITIONAL 14 CONCERNS ALSB HAD WITH A CERTAIN PORTION OF ASCT DESIGN CONTROL 3 15 PROGRAM. 16 IT WAS A COHESIVE REVIEW FROM INSTALLATION ON THROUGH 17 DESIGN WITH ONE SYSTEM. WE PERFORMED A MULTIDISCIPLINED 18 TECHNICAL REVIEW OF SELECTED PORTIONS OF DESIGN OF THE 19 COMPONENT COOLING WATER SYSTEM. 20 WE DID AN AS-BUILT VERIFICATION OF THE SELECTED 21 PORTIONS OF THE COMPONENT COOLING WATER SYSTEM AND MAIN STEAM 22 SYSTEMS, AND WE PERFORMED AN EVALUATION OF THE IMPLEMENTATION 23 OF TWO ADDITIONAL ELEMENTS OF THE DESIGN CONTROL PROGRAM. 24 IN TOTAL, THEN, ACROSS ALL FOUR PHASES, WE HAVE 25 ASSESSED THE COMPLETE DESIGN CONTROL PROGRAM FOR 2-C AND GIBBS 26 & HILL, WE HAVE PERFORMED A MULTIPLE MULTIDISCIPLINE TECHNICAL 27 REVIEW PORTIONS OF ONE TRAIN OF THE COMPONENT COOLING WATER g 28 SYSTEM AND A PORTION OF THE RHR SYSTEM. Sy,' ",*,]C,',5,C,0 DOIDGE & CARROLL coy,,,go,,, CERTIFIED SHORTH AND REPORTERS

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DEPOSITION NOTARIES ' 5 ' ' 3 2 ' ' ' ' '

~ s 8 1 WE PERFORMED AN AS-BUILT VERIFICATION OF ONE PORTION t 2 OF THE COMPONENT COOLING WATER SYSTEM AND THE SPENT FUEL POOL 3 COOLING SYSTEM. 4 WE PERFORMED A REVIEW OF THE PIPING AND PIPE SUPPORTS 5 ON THE MAIN STEAM COMPONENT COOLING WATER SYSTEM AND RHR 6 SYSTEMS. 7 WE HAVE PERFORMED IMPLEMENTATION EVALUATIONS ON THE i 8 DESIGN CONTROL PROGRAM IN TERMS OF FIVE SELECTED DESIGN CONTROL 9 ELEMENTS AS GIVEN IN THE ANSI N45.2.11. 10 AND WE HAVE PERFORMED PROGRAMMATIC REVIEWS OF 11 ORGANIZATION AND CORRECTIVE ACTIONS SYSTEMS AS THEY PERTAIN TO 12 DESIGN AND ASSESS IMPLEMENTATION OF THOSE TWO FACETS OF 10 CFR 13 50, APPENDIX B. 14 THERE IS A GOOD DESCRIPTION AVAILABLE IN THE T 15 TRANSCRIPTS OF A MEETING BETWEEN OURSELVES AND THE NRC STAFF IN 16 DECEMBER OF '84 WHICH WALKS THROUGH THIS IN MUCH MORE DETAIL., 17 PROVIDE YOU WITH SLIDES, DIAGRAMS, FLOW CHARTS, AND MUCH MORE 18 DETAILED ASSESSMENT OF WHAT I HAVE TRIED TO CAPSULIZE HERE IN A 19 VERY BRIEF PERIOD OF TIME. 20 BEFORE I GO INTO METHODOLOGY, PERHAPS, BECAUSE I 21 THINK THAT THIS IS A VERY CONFUSING DEVELOPMENT OF THIS PROGRAM 22 WITH TIME, AND AS YOU CAN SEE THE SCOPE JUMPS AROUND QUITE A 23 BIT, PERHAPS IF YOU HAVEN'T HAD THE BENEFIT OF REVIEWING THAT 24 TRANSCRIPT, WHAT I HAVE SAID HERE HAS NOT BEEN TOO HELPFUL TO 25 YOU. 26 IS THERE ANYTHING THAT I COULD ANSWER FOR THE 27 PURPOSES OF TODAY THAT WOULD HELP TO CLARIFY ANYTHING ALONG THE g i 28 LINES OF SCOPE BEFORE I DO METHODOLOGY? 5 [ * *]C,',5,C,0 DOIDGE & CARROLL coNTaa costa CERTIFIED SHORTHAND REPORTERS cosw?, oa%ase taisi asi asse DEPOSITION NOTARIES d'S'538~5

o s 9 1 MR. DOUGHERTY: I DON'T THINK I HAVE ANY QUESTIONS ON w 2 SCOPE. I MIGHT COME BACK TO THAT AFTER WE GET INTO METHODOLOGY 3 AND HOW METHODOLOGY APPLIED TO VARIOUS SCOPES. 4 MR. GUIBERT: JOHN GUIBERT. DESIGN CONTROL PROCESS, 5 COULD YOU ENUMERATE THOSE? 6 MS. WILLIAMS: INTERFACE CONTROL, DESIGN CHANGE 7 CONTROL, DESIGN ANALYSIS CONTROL, DESIGN INPUT CONTROL, AND 8 DESIGN VERIFICATION. 9 MR. GUIBERT: THANK YOU. 10 MR. LEVIN: ARE THERE ANY OTHER PROGRAMMATIC 11 DOCUMENTS OR THINGS LIKE THAT, WHICH WE SHOULD BE DIRECTED TO? 12 MS. WILLIAMS: YOUR BEST 3OURCE ARE THE FINAL REPORTS ~ 13 FOR EACH OF THE PHASES AND FOR A

SUMMARY

IN TOTAL ACROSS ALL 14 PHASES, THE DECEMBER TRANSCRIPT. T 15 MR. GUIBERT: ONE OTHER QUESTION. YOU INDICATED 16 THERE WERE REPORTS OUT DESCRIBING PHASE I AND 2 AS A GROUP AND 17 PHASE 3. CAN YOU SAY ANYTHING ELSE WITH RESPECT TO WHERE YOU 18 ARE IN TERMS OF THE REPORT ON PHASE 4? 19 MS. WILLIAMS: YOU CATCH ME RIGHT NOW IN THE PROCESS 20 OF DEVELOPING A SCHEDULE. WE ARE WELL ALONG AND HAVE COMPLETED 21 MANY PORTIONS OF PHASE 4 WORK. THERE ARE CERTAIN PORTIONS 22 WHICH WE'RE STILL EVALUATING AND WORKING ON THE RESOLUTION. 23 WE'RE DECIDING AT THIS POINT IN TIME WHETHER TO ISSUE 24 AN INTERIM REPORT OR PARTIAL REPORT, OR JUST HOW WOULD BE BEST 25 TO GET THE INFORMATION TO THE PARTIES WHO NEED THE INFORMATION 26 AS SOON AS POSSIBLE. 3 27 I THINK THAT IN THE NEXT DAY I'M GOING TO HAVE THAT 28 AVAILABLE. AND I WILL BE WALKING YOU THROUGH THE STATUS OF Sy,'",*,]c,',5 c o DOIDGE & CARROLL cos,. cos,, CERTiplED SHORTHAND REPORTERS coss?' o uay '3#' eats asnaies DEPOSITION NOTARIES

10 1 WHAT WE SEE ALL THE ISSUES ARE AND WHAT PHASE THEY COME OUT OF, m 1 2 AND PERHAPS THAT WILL GIVE YOU THE INFORMATION THAT YOU NEED 3 RIGHT NOW TO START YOUR PROGRAM. 4 MR. GUIBERT: THANK YOU. 5 MS. WILLIAMS: REGARDING METHODOLOGY, I THINK A VERY 6 BRIEF DESCRIPTION OF SOME OF OUR TERMINOLOGY WOULD BE HELPFUL. 7 THE DOCUMENTS YOU WILL HEAR US TALKING ABOUT ARE CHECKLISTS 8 WHICH IS OUR TOOL FOR THE REVIEWERS TO USE IN CONDUCTING THE 9 REVIEW AND RECORDING THE RESULTS OF THEIR REVIEW. 10 THE ATTRIBUTES ON THE CHECKLIST FOR EACH OF THE 11 DISCIPLINES ARE CHECKED SATISFACTORY OR UNSATISFACTORY OR NOT 12 APPLICABLE, AS THE CASE MAY BE, BY THE REVIEWERS. ITEMS WHICH 13 ARE MARKED ONSATISFACTORY ON THE CHECKLIST, BUT ARE CONSIDERED 14 VERY MINOR IN NATURE, WE WOULD IDENTIFY AS A DISCREPANCY, T 15 MEANING IT'S A DIFFERENCE BETWEEN THE REQUIREMENTS OF THE 16 REVIEW CRITERIA AND THE PARTICULAR ATTRIBUTE. 17 IF AN UNSATISFACTORY ITEM ON A CHECKLIST IS 18 CONSIDERED TO HAVE POSSIBLE IMPACT ON THE DESIGN ADEOUACY, IT 19 BECOMES AN OBSERVATION. BOTH THE CHECKLIST AND THE 20 OBSERVATIONS ARE CONTAINED IN THE FINAL REPORT. 21 YOUR BEST STARTING POINT IN TRYING TO ASSIMILATE THE 22 INFOP.MATION ON THE CHECKLIST AND OBSERVATIONS IS TO WORK YOUR 23 WAY BACKWARDS STARTING FROM THE OBSERVATIONS AND THEN PURSUING 24 THE DETAILS OF THE CHECKLIST AS NEED BE WHEN YOU ARE EVALUATING 25 A PARTICULAR AREA OF CONCERN. 26 BEYOND THE OBSERVATIONS, WE HAVE WHAT WE REFER TO AS 27 A POTENTIAL FINDING REPORT AS DEFINED AS A VALID OBSERVATION, 3 28 HAVING A POTENTIAL IMPACT ON PLANT SAFETY AS JUDGED BY THE Sy,",',K',5,e DOIDGE & CARROLL cas,.. cos,. CERTIFIED SHORTH AND REPORTERS c oss" omataNo *3# 8 saisiast.330s DEPOSITION NOTARIES ) i

) 11 1 PROJECT REVIEW TEAM. m-j 2 THE PROJECT REVIEW TEAMS CONSISTS OF OUR IN-HOUSE 3 CONSULTANTS AND MEMBERS OF THE VARIOUS REVIEW GROUPS, AS 4 OPPOSED TO THE ' SENIOR REVIEW TEAM WHICH IS COMPOSED OF OUTSIDE ~ 5 PARTIES WHOM I HAVE INTRODUCED HERE EARLIER ON. 6 THE LAST KEY DOCUMENT WE HAVE IS A DEFINITE POTENTIAL 7 FINDING, THAT I S, A POTENTIAL FINDING WHICH IS VERIFIED BY THE 8 SENIOR REVIEW TEAM TO HAVE A POTENTIAL IMPACT ON PLANT SAFETY 9 REPORTABLE FINDING TO BOTH TEXAS -- EXCUSE ME, TO TEXAS UNDER 10 THE REQUIREMENTS OF 10 CFR PART 21. BEYOND THAT, IT'S A FAIRLY 11 ITERATIVE PROCESS. 12 IT'S A PROCESS WHERE WE HAVE MANY MEETINGS BOTH 13 WITHIN THE PROJECT REVIEW TEAM AND THEN THE SENIOR REVIEW TEAM. 14 BEFORE ANYTHING GETS RECORDED AS A POTENTIAL FINDING OR VALID 3 15 OBSERVATION, IT HAS GONE THROUGH MANY CYCLES OF REVIEW 16 INTERNALLY AND MANY DISCUSSIONS TO ASCERTAIN WHETHER ADDITIONAL 17 INFORMATION IS NECESSARY FROM TEXAS UTILITIES. 18 ALL OF THESE DOCUMENTS I TALKED ABOUT ARE AVAILABLE 19 IN THE FINAL REPORTS, AND I THINK THAT'S ABOUT ALL THAT IS 20 NECESSARY FOR THE PURPOSES OF DISCUSSING ANYTHING THAT I HAVE 21 WITH ME TODAY. 22 MR. DOUGHERTY: ON OBSERVATION, AT WHAT POINT DO YOU 23 RELEASE OBSERVATIONS TO TEXAS UTILITIES? 24 MS. WILLIAMS: IN THE FINAL REPORT. 25 MR. DOUGHERTY: IF YOU DON'T GO INTO A PROCESS OF 26 INTERIM REPORTS ON PHASE 4, YOU WON'T HAVE RELEASED ANY g 27 OBSERVATIONS TO OUTSIDE PEOPLE? 28 MS. WILLIAMS: THAT'S CORRECT. S*y",'[NCy5,cf DOIDGE & CARROLL cos,,,cc.,. CERTtFIED SHORTH AND REPORTERS cossvv oa%aso sai si as t 33e6 DEPOSITION NOTARIES '3#'

12 1 MR. GUIBERT: YOU MENTIONED THE REVIEW CRITERIA. I ' *a 2 DON'T KNOW WHETHER YOU ARE GOING TO GET INTO THIS IN MORE 3 DETAIL LATER. COULD YOU GENERALLY CHARACTERIZE THAT? WHAT I 4 AM TRYING TO UNDERSTAND IS WHETHER OR NOT YOU TOOK THE FSAR 5 COMMITMENTS AS YOUR BASE LINE FOR REVIEW OR WHETHER YOU USED 6 SOME OTHER SET OF CRITERIA OR COMBINATION OF BOTH? 7 MS. WILLIAMS: IT'S A COMPILATION OF INDUSTRY 8 ACCEPTED PROCEDURES, STANDARDS AND FSAR LICENSING COMMITMENTS. 9 MR. BUHL: I WOULD ASSUME THOSE CRITERIA ARE 10 SGMEWHERE IN THE DOCUMENTS YOU ARE TALKING ABOUT. 11 MS. WILLIAMS: YES, THEY ARE IN THE FINAL REPORT FOR 12 EACH OF THE DISCIPLINES THAT ARE AVAILABLE. 13 MR. GUIBERT: WE COULD GO BACK TO THE ONE AND TO THE 14 TWO REPORT. T 15 MR. FRENCH: JOHN FRENCH. HOW WOULD YOU CHARACTERIZE 16 YOUR METHODS IN RELATION TO STATE OF THE ART AS IT EXISTS IN 17 THE INDUSTRY SUPPORTED DESIGN? CAN YOU MAKE A COMMENT ON THAT? 18 MS. WILLIAMS: FOR PIPE SUPPORT DESIGN? 19 MR. FRENCH: YES. 20 MS. WILLIAMS: WE DO CHARACTERIZE THE REVIEW WITH THE 21 TIME FRAME OF THE DEVELOPMENT OF THE FSAR. 22 MR. FRENCH: 50 YOU GO BACK TO WHAT WAS THEN THE 23 STATE OF THE ART WHEN IT WAS GOING ON? 24 MS. WILLIAMS: YES. BUT IF THERE IS,ANYTHING WITHIN 25 THE INDUSTRY STATE OF THE ART PARTICULARLY PERTINENT TO THE 26 ISSUE, IT DOES COME UP IN OUR DISCUSSIONS INTERNALLY, WHETHER 27 IT'S APPLICABLE TO THE STATE OF COMANCHE PEAK OR NOT IS s 28 SOMETHING THAT WE HAVE TO WORK OUT INTERNALLY. ',$35 ",','3,'.'.( DOIDGE & CARROLL cog,,co3,, CERTIFIED SHORTHAND REPORTERS co ets om,g 5'esa ivis eatteaso33ee DEPOSITION NOTARIES l l

13 1 MR. FRENCH: OKAY. w -( 2 MR. GUIBERT: ONE OTHER QUESTION, NANCY. FOLLOWING 3 UP ON THE OTHER OUESTION I ASKED, DID YOUR REVIEW CRITERIA GO 4 BEYOND THE FSAR COMMITMENTS WHEN YOU TALK ABOUT INDUSTRY 5 ACCEPTED PRACTICE UTILIZED, FOR THE POINT OF CLARIFICATION, OF 6 THOSE COMMITMENTS? 7 MS. WILLIAMS: MOSTLY CLARIFICATION, NOT AS SPECIFIC 8 AS AWS. IF WE RELY ON SOMETHING MORE SPECIFIC, WE RELY ON THE 9 AWS. 10 MR. DOUGHERTY: IN TERMS OF SCOPE OF REVIEW, TO WHAT 11 EXTENT DID YOU REVIEW WORK DONE BY WESTINGHOUSE AS OPPOSED TO 12 WORK DONE BY GIBBS S HILL AND TUGCO? 13 MS. WILLIAMS: THE WESTINGHOUSE REVIEWS WERE 14 EQUIPMENT QUALIFICATION. WE REVIEWED ONE SEISMIC QUALIFICATION, 1 15 A DOCUMENT FROM WESTINGHOUSE. WE REVIEWED SOME WESTINGHOUSE 16 DESIGN DOCUMENTS FOR THE COMPONENT COOLING WATER SYSTEM, 17 MECHANICAL SYSTEMS REVIEW WHERE WESTINGHOUSE DEFINED THE 18 PARAMETERS FOR THE OPERATION, THE SYSTEM WOULD START AT THAT 19 POINT. AND THAT'S ALL THE WESTINGHOUSE INTERFACES THAT I CAN 20 THINK OF. 21 WE PRIMARILY CONCENTRATED ON GIBBS & HILL, TEXAS 22 UTILITIES, AND PIPE DESIGN ORGANIZATIONS. 23 MR. DOUGHERTY: ARE YOU PLANNING TO TALK ABOUT YOUR 24 JANUARY 25TH LETTER, OR CAN WE GO IN AND ASK A FEW QUESTIONS 25 ABOUT THAT? 26 MS. WILLIAMS: WHY DON'T YOU ASK ME SOME QUESTIONS. 27 MR. DOUGHERTY: I THINK YOU PROBABLY ANSWERED THE ) ^ 28 FIRST QUESTION. THE JANUARY 25TH LETTER, ATTACHMENT "A" TALKS Sj,'",'jC,',5,C,0 DOIDGE & CARROLL costan costa oa uaso CERTIFIED SHORTH AND REPORTERS c o At* aa t si as i-ases DEPOSITION NOTARIES ' ' ' 5 32' ' ' ' 5 .. ~

I 14 1 ABOUT PHASES 2 AND 3, DOESN'T TALK ABOUT PHASE 1, BUT I TAKE IT 2 THAT PHASE 2 REALLY INCLUDED ALL OF PHASE 1 RESULTS IN THAT 3 TABLE? 4 MS. WILLIAMS: THAT'S CORRECT. 5 MR. DOUGHERTY: OKAY. 6 YOU DEFINED VALID OBSERVATIONS A MINUTE AGO, AND AS I 7 LOOK THROUGH THE ATTACHMENT "A," I NOTICE THAT THERE WAS SOME 8 OBSERVATIONS THAT WERE MARKED NOT VALID, BUT YOU HAD MARKED THE 9 PROBABLE CAUSE COLUMN TO BE CHANGED AS YES, AND I AM NOT SURE 10 THAT I UNDERSTAND THE MEANING OR SIGNIFICANCE OF THAT KIND OF 11 SITUATION. LET ME SEE IF I CAN FIND AN EXAMPLE FOR YOU. 12 PI-0204. 13 MR. WITT: WHY DON'T YOU GIVE THE SHEET NUMBER. 14 MR. DOUGHERTY: I DIDN'T WRITE DOWN THE SHEET NUMBER. ) i 15 MR. LEVIN: 5. 16 MR. DOUGHERTY: SHEET 5 PI-0204 SHOWS UP AS NOT BEING 17 VALID, BUT THAT YOU EXPECT TO CHANGE THE PROBABLE CAUSE. I 18 DIDN'T QUITE UNDERSTAND HOW THAT COULD OCCUR. AND I WAS ALSO 19 GOING TO A FOLLOW-UP QUESTION AND ASK YOU, WHAT CRITERIA DID 20 YOU USE IN ASSIGNING THINGS TO THE PROBABLE CAUSE AND 21 RESOLUTION TO BE CHANGED COLUMNS IN THAT ATTACHMENT " A" IN 22 GENERAL, NOT JUST SPECIFICALLY FOR THAT ONE. 23 MS. WILLIAMS: THE PROCESS WE WENT THROUGH IN 24 DEVELOPING INPUT TO THIS LETTER WAS TO LAY DOWN ALL THE 25 OBSERVATIONS WITH A ROOMFUL OF OUR REVIEWERS AND SOME OUTSIDE 26 PERSONNEL FOR A FRESH LOOK. 27 AND WE FOCUSED ONLY ON PROBABLE CAUSE AND RESOLUTION 3 28 WHICH IS GOING TO ACCOUNT FOR THIS DISCREPANCY YOU ARE TALKING Sy,'",',$ C,',5po DOIDGE & CARROLL cos,,,co,y, CERTIFIED SHORTHAND REPORTERS cous'v o, g,s 3 **'33 sa i si as i.a ses DEPOSITION NOTARIES

) 15 1 ABOUT, BECAUSE ALL WE DID WAS LOOKED AT EACH OF THEM, AND m t 2 WITH -- WHERE WE SAT RIGHT NOW, WITH ALL THE INFORMATION FROM 3 ALL FOUR PHASES, AND DID A STUDY AS TO THE CURRENT ACCURACY OF 4 THE PROBABLE CAUSES. 5 SO THAT'S ALL WE WERE LOOKING AT WAS THE PROBABLE 6 CAUSES, AND WE DID THAT WITHOUT REGARD AS TO WHETHER IT'S VALID 7 OR NOT. YOUR POINT IS WELL TAKEN. NO, THERE IS NOT GOING TO 8 BE A MAJOR CHANGE SINCE IT'S AN INVALID OBSERVATION. 9 MR. DOUGHERTY: FOR EACH OBSERVATION YOU IDENTIFY 10 WHAT THE PROBABLE CAUSE WAS, AND THERE WAS A RESOLUTION FOR 11 EACH OBSERVATION THAT IS EITHER, WHAT, SOME ACTION THAT TUGCO 12 HAD TAKEN OR WAS PLANNING TO TAKE? 13 MS. WILLIAMS: THAT'S CORRECT. 14 MR. DOUGHERTY: AND THOSE RESOLUTIONS, WERE THOSE ON 3 15 THE SPECIFIC ITEMS? SOME OF THESE ITEMS ARE FAIRLY -- FAIRLY 16 SPECIFIC AND OTHERS ARE QUITE BROAD. THE RESOLUTION APPLIES TO 17 THE SPECIFIC ITEM AS STATED HERE OR DOES IT INCLUDE ANY FURTHER 18 IMPLICATIONS AS A RESULT OF WHAT MIGHT BE A SINGLE ITEM, BUT 19 MIGHT APPLY TO MULTIPLE SUPPORTS OR MULTIPLE PIPING PROBLEMS, 20 THAT KIND OF THING? 21 MS. WILLIAMS: THE SECOND PART OF WHAT YOU DESCRIBED 22 IS WHAT WE'RE DOING RIGHT NOW, TO LOOK AT ALL SPECIFIC ITEMS 23 ACROSS ALL FOUR PHASES. 24 MR. DOUGHERTY: YOUR INITIAL RESOLUTION WAS SPECIFIC 25 TO THAT ISSUE, BUT DID NOT GO ACROSS AND LOOK AT ALL THE 26 POSSIBILITIES? 27 MS. WILLIAMS: FOR THE MOST PART, THAT'S TRUE, EXCEPT s 28 THE DESCRIPTIONS IS GENERIC ACCRUING AT ACROSS ALL PIPING 'S["3,$'s'.# DOIDGE & CARROLL o coyy,,cogy, j CERTIFIED SHORTHAND REPORTERS cowstv j o %,go aat s: esi aise DEPOSITION NOTARIES 538'8 )

I 16 1 SYSTEMS. IN SOME OBSERVATIONS, SOME ARE VERY SPECIFIC. m 2 CUMULATIVE EFFECT OF EACH OF THE SPECIFIC ITEMS IS CURRENTLY 3 ONGOING. 4 MR. WITT: LET ME ASK A QUESTION SIMPLY RELATED TO 5 THAT. IN THE CASES, THEN, WHERE WE HAVE FROM THIS TABLE, AGAIN 6 THE ISSUE HAS BEEN CLOSED, THAT DOES NOT INDICATE, OB VI OUS LY, 7 THAT IT HAS BEEN CLOSED WITH RESPECT TO THE CUMULATIVE EFFECTS. 8 IS THERE ANY WAY OF KNOWING WHICH, IF ANY OF THESE 9 OBSERVATIONS, ARE -- WILL BE, IN FACT, EXCLUDED FROM THE 10 CUMULATIVE EFFECTS REVIEWED JUST BECAUSE THEY ARE CONSIDERED TO 11 HAVE NO MEANING WITHIN THAT CONTEXT? IS THERE ANY WAY I CAN 12 LOOK AT THIS TABLE? 13 MS. WILLIAMS: NOT AT THIS POINT IN TIME, ONLY 14 BECAUSE THAT'S WHERE WE ARE AT THIS TIME. IT WOULD PROBABLY BE 3 15 SAFE TO SAY THE INVALID ONES YOU CAN EXCLUDE, THAT'S ABOUT ALL 16 I CAN DO TO HELP YOU RIGHT NOW. 17 MR. DOUGHERTY: WHEN YOU EXPECT THE PROBABLE CAUSE TO 18. CHANGE, BUT YOU HAVE A NO MARKED IN THE RESOLUTION, COULD YOU 19 EXPLAIN WHAT YOUR EXPECTATION IS WHEN -- WHEN YOUR CUMULATIVE 20 SIGNIFICANCE REPORT COMES OUT AND YOU STATE THAT ONE OF THESE 21 THINGS, SOME PROBABLE CAUSE HAS CHANGED, BUT YOU DON'T EXPECT 22 THAT THE RESOLUTION HAS CHANGED, WHAT ACTION WOULD YOU EXPECT l 23 TUGCO OR SOMEBODY ELSE TO TAKE AS A RESULT OF THAT7 24 MS. WILLIAMS: THERE MAY BE NO ACTION REQUIRED BY 25 TUGCO. THE REVISION TO THE PROBABLE CAUSE WAS FOR THE PURPOSES 26 0F CONSISTENCY SO WE COULD BETTER TREND THE ROOT CAUSES OF THE g 27 OBSERVATIONS FOR THE CUMULATIVE EFFECTS DESIGN ADEQUACY, 28 OVERVIEW REVIEW THAT WE'RE DOING RIGHT NOW.

• y,'",'jCy,5,C,0 DOIDGE & CARROLL cos,,,co,,,

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17 1 50 WE WENT THROUGH AND TRIED TO COME UP WITH A 7 2 CONSISTENT SET OF ROOT CAUSES THAT COULD BE APPLIED TO EACH 3 OBSERVATION, BUT YET THE TECHNICAL RESOLUTION MAY STILL BE 4 PERFECTLY ADEQUATE AND COMPLETE, BUT WE NEED TO STILL GO 5 THROUGH AND LOOK AT THE ROOT CAUSES FOR ANY TRENDS FROM A 6 PROGRAMMATIC STANDPOINT. 7 MR. DOUGHERTY: BASED WHERE YOU ARE NOW, PHASE 1, 2, 8 3, ARE THERE CLASSES OF ROOT CAUSES OR PROBABLE CAUSES THAT 9 SEEM TO BE MOST SIGNIFICANT IN YOUR MIND? 10 MS. WILLIAMS: I THINK IT'S A LITTLE EARLY TO ANSWER 11 THAT. 12 MR. STUART: DICK STUART. FRANK, I THINK TO TRY TO 13 GET AT YOUR QUESTION, I BELIEVE WITH THE INFORMATION THAT'S 14 PREPARED TODAY AND WHAT WE'RE INTENDING TO PREPARE OVER THE T i 15 NEXT 10 DAYS, I THINK WILL ANSWER BOTH OF YOUR TWO QUESTIONS, 16 WHICH IS, THIS DOCUMENT SITTING IN FRONT OF NANCY ADDRESSES THE 17 SPECIFIC FINDINGS AND ISSUES THAT I THINK WILL GIVE YOU A LOT 18 TO WORK ON. 19 AND, SECONDLY, THE GENERIC GROUPING TOGETHER TO FORM 20 GENERIC ISSUES WE'LL BE DOING OVER THE NEXT WEEK OR SO TO, I 21 THINK, AID YOUR GROUP IN KNOWING EXACTLY WHAT ARE THE TRUE ROOT 22 CAUSES, ISSUES, AS YOU REFERRED TO THEM, TO GIVE YOU A STARTING 23 POINT FOR YOUR PROGRAM. AND WE'LL DISCUSS THAT, BY THE WAY. 24 MR. FRENCH: JOHN FRENCH. CAN I IMPLY THE 10-DAY 25 PERIOD, WILL YOU ALSO HAVE A SCHEDULE OF THE REVISED SCHEDULE? 26 WHEN WILL WE KNOW WHEN THE END POINT IS COMING? 27 MR. STUART: I THINK, AS NANCY INDICATED, WE'RE GOING g 28 TO HAVE OUR SCHEDULE WITHIN THE NEXT FEW DAYS. 50 EARLIER THAN Sy,'",',*,C,',5,Cy D01DGE & CARROLL eoyy,,ee,,, CERTIFIED SHORTH AND REPORTERS cov%n oa%amo eaa s e 15 saisiasosse6 DEPOSITION NOTARIES

18 1 THE 10 DAY'S POINT. AND I THINK BETWEEN THIS DOCUMENT WHICH I m 7 2 CALL THE SPECIFIC ISSUES VERSUS THE DOCUMENT WE'LL PREPARE IN 7 3 TO 10 DAYS, WHICH IS A GROUPING TOGETHER OF THE ROOT CAUSE 4 GENERIC ISSUES, THAT SHOULD LAY OUT ALL THE KNOWN ISSUES TODAY. 5 MR. DOUGHERTY: FOR PHASES 1, 2, AND 3 OR INCLUDES 6 PHASE 4? 7 MS. WILLIAMS: INCLUDES PHASE 4. THIS IS A VERY 8 COMPREHENSIVE LISTING WITH ALL CROSS-REFERENCES FOR YOU. 9 MR. STUART: I THINK NANCY WILL GET INTO MORE DETAIL 10 IN A FEW MINUTES. 11 MR. DOUGHERTY: I'M READY TO GO ON. LET'S HEAR ABOUT 12 THAT. M'. WILLIAMS: OFF THE RECORD. 13 S 14 (OFF THE RECORD.) 3 15 MS. WILLIAMS: BACK ON THE RECORD. 16 WHAT YOU HAVE BEFORE YOU IS A COMPLETE COMPILATION OF 17 ALL THE OUTSTANDING ISSUES THAT WE KNOW ABOUT FROM ALL FOUR 18 PHASES AS OF YESTERDAY. I WOULD ESTIMATE THIS DOCUMENT TO BE 19 AT LEAST 90 PERCENT COMPLETE, IF NOT 99.5 PERCENT COMPLETE. 20 IT LOOKS VERY LENGTHY BUT THE BULK OF IT IS 21 REFERENCES. WE PROVIDED THE REFERENCES FOR THE BENEFIT OF 22 THOSE OF YOU WHO HAVEN'T BEEN INVOLVED IN THE PROGRAM FROM DAY I 23 ONE. SO IF YOU WANT TO DO MORE READING ON IT, WANT TO GET i 24 CLEAR BACKGROUND ON AN ISSUE, THESE ARE THE PLACES THAT YOU CAN 25 TURN TO TO DO A LITTLE HOMEWORK, AND THEN WE CAN GET TOGETHER 26 AND GIVE YOU MORE DEPTH, IF THAT'S NECESSARY. 27 OVER THE NEXT WEEK WE WILL BE PREPARING, AS DICK i 28 INDICATED, A MORE CONCISE EVALUATION OF THE CONTENTS OF THIS saw eaa~cisco DOIDGE & CARROLL co%v=4 costa

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) A e 19 1 DOCUMENT SUCH THAT YOU CAN FOCUS YOUR EFFORTS ON THOSE THINGS s 7 2 WE CONSIDER TO BE MORE GENERIC IN NATURE OR THOSE THINGS THAT 3 REQUIRE ADDITIONAL WORK BY TUGCO, THINGS ALONG THESE LINES. 4 MR. LEVIN: NANCY, IN THAT REGARD, I THINK YOU 5 PROBABLY KEYED ON TWO OF OUR i:AIN OBJECTIVES FOR THE MEETING, 6 SO TO THE EXTENT WE CAN DO THAT, AT LEAST VERBALLY, THAT WILL 7 HELP US WHEN WE G}T THAT DOCUMENT. THAT'S EXACTLY WHAT WE'RE 8 TRYING TO DO RIGHT NOW. 9 MS. WILLIAMS: WE CAN DO AN ELEMENT OF THAT THROUGH 10 THIS MEETING. THAT DOCUMENT I'M PLANNING ON MAKING AVAILABLE 11 SOMEWHERE AROUND MARCH 27TH, 50 IT IS A WEEK AND A HALF A WAY. 12 WE THOUGHT THAT YOU SHOULD HAVE THIS FIRST SO THAT 13 YOU COULD S$E THE TOTALITY OF THE ISSUES, AND THEN THE OTHER 14 DOCUMENT AND A DISCUSSION TODAY WILL HELP TO SCREEN THOSE A ) 15 LITTLE FOR YOU. 16 THERE IS A COUPLE OF TERMS USED HERE THAT I WANT TO 17 CLARIFY. UNDER STATUS FOR EACH OF THESE ITEMS, SOME ARE 18 INDICATED AS CLOSED. THAT MEANS WE DON'T THINK ANY ADDITIONAL 19 WORK IS REQUIRED, EITHER BY OURSELVES OR BY TUGCO, AND THE ONLY 20 THING THAT'S OUTSTANDING IS THIS CUMULATIVE EFFECTS EVALUATION 21 THAT WE JUST DISCUSSED THAT WE WILL BE PERFORMING OVER THE 22 COURSE OF THE NEXT SEVERAL WEEKS. 23 THERE ARE SOME STATUS ITEMS WHICH INDICATE SOME 24 SPECIFIC ACTIONS THAT WE NOTE TODAY WILL BE REQUIRED BY TUGCO 25 OR GIBBS & HILL, OR THE NEED FOR SOME DISCUSSIONS ON A 26 PARTICULAR POINT, OR SOMETHING ALONG THOSE LINES. s 27 THERE ARE A COUPLE OF STATUS ITEMS WHICH ARE MARKED, 28 CYGNA INTERNAL REVIEW. THIS MEANS WE DON'T THINK WE NEED ANY sa% rea%cisco DOIDGE & CARROLL '*3'** coy,.. cos,. CERTIFIED SHORTHAND REPORTERS cou%tv sa i 33ee DEPOSITION NOTARIES '3#

20 1 MORE INFORMATION. WE THINK WE HAVE ALL OF THE DOCUMENTS THAT w T 2 WE NEED, WE REVIEWED.THEM, BUT WE JUST WANT TO DISCUSS THEM IN 3 TERMS OF THE REVIEW TEAM TO MAKE SURE THAT THERE AREN'T ANY 4 IMPLICATIONS OR ASPECTS OF A PROBLEM THAT WE HAVE NOT FULLY 5 EXPLORED. 6 SO WE DO NOT ANTICIPATE ANY FURTHER WORK COMING OUT 7 OF THOSE, BUT YOU SHOULD KNOW THAT WE'RE STILL DISCUSSING THEM 8 INTERNALLY. THIS IS A VERY INTIMIDATING LIST. IT'S SOMEWHERE 9 AROUND 87 PAGES LONG. WHEN YOU FIRST LOOK AT I T, SOME AREAS, 10 SUCH AS CABLE TRAYS, ARE VERY LONG, BUT I JUST CAUTION PEOPLE 11 WHO ARE NOT SO FAMILIAR WITH OUR PROCESS AND HOW THESE GET 12 EVALUATED, AT THE CULMINATION OF THE ENTIRE REVIEW, THAT THESE 13 LISTS TEND TO GET SMALLER WITH TIME AS THE PIECES FIT TOGETHER. 14 BUT THIS IS AN ATTEMPT, AND IT IS A GOOD TOOL FOR US, 15 AS WELL, TO TRY AND GET EVERYTHING WE CAN THINK OF IN ONE PLACE 16 AT THIS POINT IN TIME SO THAT WE CAN WORK WITH IT. 17 THIS IS STAMPED, PRELIMINARY, AND EMPHASIZE 18 PRELIMINARY. IT'S HOT OFF THE PRESSES THIS MORNING. YOU ARE 19 GOING TO FIND TYPOS AND ENGLISH, AND ALL THAT, AND WE'LL GET 20 YOU A NICE CLEANED-UP COPY AS SOON AS POSSIBLE. 21 I THINK ALL THE INFORMATION IS THERE, 50 YOU PEOPLE 22 CAN GET STARTED ON THINGS THAT YOU WANT TO PURSUE. WE'LL GIVE 23 IT TO YOU ON THAT BASIS. JUST DON'T THINK IT'S REFLECTIVE OF 24 OUR ENGLISH ABILITIES AND EDITORIAL COMMENTS. 25 MR. WITT: JUST A COMMENT. WHEN YOU ISSUE THE FINAL, 26 WOULD YOU NOTE ANY SUBSTANTIVE CHANGES POSSIBLY FOR US SO WE 27 CAN FOCUS? I PRESUME THE CHANGE WILL BE MINOR, BUT ANYTHING 28 SUBSTANTIVE, YOU MIGHT CALL IT OUT. sam sma%cisco DOIDGE & CARROLL coyvna costa " ' S' S' 8 "' CERTIFIED SHORTH AND REPORTERS C 09 % sais $ Y3es DEPOSITION NOTARIES

-e ) 21 1 MS. WILLIAMS: ABSOLUTELY. IF THERE ARE REVISIONS, s 3 2 WE'LL INDICATE THE REVISIONS AND INDICATE AT WHAT POINT IN TIME 3 WE THINK IT'S A FINAL AND COMPLETE LIST. 4 MR. GUIBERT: NANCY, CAN YOU COMMENT ABOUT THIS LIST 5 VIS-A-VIS YOUR COMMENT ABOUT THIS LIST ULTIMATELY SHRINKING AND 6 PROJECTING THAT WILL OCCUR? I'M SURE THERE ARE A VARIETY OF 7 REASONS WHY THAT CAN OCCUR. DOES THAT IMPLY AT LEAST ONE OF 8 THOSE IS SAFETY REVIEW HAS NOT BEEN OVERLAID ON THESE ITEMS? 9 MS. WILLIAMS: THE SAFETY SIGNIFICANCE REVIEW HAS NOT 10 BEEN DONE, THAT'S CORRECT. WE MAY NEED MORE INFORMATION TO 11 CLOSE IT OUT. WE MAY NOT COMPLETELY UNDERSTAND ALL ASPECTS OF 12 THE PROBLEM, AND ONCE WE GET OTHER INFORMATION, WE FIND OUT 13 IT'S NOT WHdT WE THOUGHT IT WAS, AND IT MAY OR MAY NOT BE A 14 PROBLEM, OR SOMETHING COME TOGETHER AS ONE ISSUE. AND WHAT 3 15 WE'RE SEEING IS JUST CERTAIN PARTS OF IT RIGHT NOW. 16 MR. BUHL: TONY BUHL. WILL YOU TALK ABOUT HOW YOU 17 ARE GOING TO DO YOUR SAFETY SIGNIFICANCE REVIEW AT SOME POINT 18 OR DOCUMENTED SOME OTHER PLACE? 19 MS. WILLIAMS: THAT'S DOCUMENTED IN THE METHODOLOGY. 20 I CAN ANSWER QUESTIONS YOU HAVE ALONG THOSE LINES. I'M NOT 21 QUITE SURE OF WHAT INFORMATION YOU WOULD LIKE. 22 MR. BUHL: I WANT TO UNDERSTAND WHAT PROCESS YOU ARE 23 GOING TO FOLLOW. IF YOU WILL GIVE ME THE DOCUMENT, I'LL BE 24 HAPPY TO READ IT. 25 MS. WILLIAMS: THE FINAL REPORT IN THE PROCESS WE GO 26 THROUGH IN ASSESSING SAFETY SIGNIFICANCE AND RESULTS OF g 27 PREVIOUS ASSESSMENT ALONG THOSE LINES AND ALL OF THE 28 OBSERVATIONS, SO YOU CAN SEE THE RESOLUTION AND THE BASIS AND

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) 22 1 WHAT WE FELT THE IMPACT, DESIGN IMPACT WAS. k 2~ MR. BLACKWOOD: I'M GOING TO HAVE TO BE ASKING YOU A 3 COUPLE OF QUESTIONS ON THAT LATER ON. 4 MS. WILLIAMS: THE DISCIPLINES COVERED IN HERE ARE 5 PIPE STRESS, PIPE SUPPORTS, CABLE TRAY SUPPORTS, CONDUIT 6 SUPPORTS, DESIGN CONTROL MECHANICAL SYSTEMS. AND ELECTRICAL 7 WALK-DOWN RESULTS ARE SCATTERED THROUGHOUT THE DISCIPLINES. 8 IT'S NOT A SEPARATE LIST. 9 AND I HAVE FURTHER DESIGN CONTROL AT THE END. AND 10 ONE OF THE THINGS YOU WILL NOTICE WHEN YOU LOOK AT IT I S, IT 11 LACKS SOME LEVEL OF DETAIL DESCRIPTION OF JUST WHAT WE THINK 12 SOME OF THE TRENDS MAY BE. 13 BOT I HAVE PUT SOME ITEMS IN THERE, SUCH AS INTERFACE 14 CONTROL, AND TOLD YOU A LITTLE BIT ABOUT OUR NEED TO DO THE T t 15 ROOT CAUSE CUMULATIVE EFFECT REVIEW. 50 WHEN YOU ARE AWARE 16 WE'RE DOING THIS, IT WON'T BE A SURPRISE IF WE COME UP WITH 17. QUESTIONS ALONG THE LINES FOR TUGCO OR GIBBS S HILL. 18 AT THIS POINT IN TIME, WE REALLY DON'T KNOW IF IT'S 19 GOING TO TURN OUT TO BE A PROBLEM OR NOT. THIS WAS AN ATTEMPT 20 TO ERR ON THE COMPLETE SIDE AS OPPOSED TO TRYING TO HOLD THINGS 21 IN THE WINGS UNTIL WE KNEW FOR SURE. 22 MR. DOUGHERTY: ARE THERE ANY DIFFERENCES BETWEEN 23 WHAT YOU HAVE GOT HERE AND ATTACHMENT B OF THE JANUARY 25TH 24 LETTER, AND IN PARTICULAR, I'M THINKING ABOUT EQ AND ELECTRICAL 25 WHICH IN THE JANUARY 25TH LETTER, YOU BASICALLY SAID, I THINK, 26 THEY WERE CLOSED OUT, YOU HADN'T FOUND ANYTHING MORE IN PHASE'4 27 TO REOPEN THEM. IS THAT STILL BASICALLY WHERE YOU ARE? 3 28 MS. WILLIAMS: THIS IS CONSISTENT WITH THAT, YES. 1 saw ema%cisco DOIDGE & CARROLL co%,. cesta "'S'S'"' CERTIFIED SHORTHAND REPORTERS C odNi' sa, Y 33,e OEPOSITION NOTARIES ... ~

23 1 MR. GUIBERT: IF ONE WERE TO LOOK AT THE DESIGN s -1, 2 CONTROL SIDE, YOU WERE LOOKING TO MAKE A COMPLETE LIST, THESE 3 ARE ALL THE QUESTIONS YOU INTEND TO ANSWER OR ARE THERE OTHER 4 QUESTIONS YOU INTEND TO ANSWER? 5 MS. WILLIAMS: I WOULD PUT THIS AS 90 PERCENT 6 COMPLETE RIGHT NOW. I CAN'T THINK OF ANY. IF I COULD HAVE, I 7 WOULD HAVE PUT THEM THERE. WE ARE STILL DOING A LITTLE 8 PLANNING AROUND WHAT ALL THOSE QUESTIONS ARE. 9 WE WANT TO MAKE SURE WE HAVE ANSWERED, AND WE NEED TO 10 TAKE ONE MORE RUN THROUGH TO MAKE SURE THAT THIS IS COMPLETE. 11 I DON'T ANTICIPATE ANYTHING OF ANY MAGNITUDE. I THINK THIS IS 12 PRETTY COMPLETE, BUT THERE IS THAT POSSIBILITY. 13 MR. GUIBERT: AT ANY RATE, IT'S YOUR INTENT TO FILE A 14 REPORT TO HAVE AN ANSWER TO AT LEAST EACH OF THE ITEMS? 3 15 MS. WILLIAMS: YES, AS WE VIEW THINGS BASED ON OUR 16 SCOPE. 17 MR. GUIBERT: OKAY. 18 MS. WILLIAMS: I THINK l'M GOING TO TURN THIS BACK TO 19 YOU, HOWARD, AND YOU TELL ME HOW YOU WANT TO PROCEED THROUGH 20 THIS. 21 MR. LEVIN: FIRST, I'LL ASK ANY MEMBERS OF THE TEAM 22 IF THEY HAVE QUESTIONS ON SCOPE OR METHODOLOGY. IF NOT, I 23 PROPOSE WE JUST GET DIRECTLY INTO THE PIPING AND PIPE SUPPORTS 24 AREA. 25 MR. BLACKWOOD: I DON'T HAVE ANYTHING MORE AT lHIS e 26 TIME. 27 MR. LEVIN: WITH THAT, I WOULD LIKE TO TURN OVER THE ) I 28 DISCUSSION TO DOUG WITT. T,'",',K',5,C O DOIDGE & CARROLL coy,,ce,,, CERTIFIED SHORTH AND REPORTE RS cow. onntaso ' S ' 8 32 ' ' ' ' S edisi est 3394 DEPOSITION NOTARIES

s. s 24 1 1 MR. WITT: BY WAY OF INTRODUCTION, I THINK THAT THIS m j 2 IS GOING TO BE VERY HELPFUL IN GIVING US A ROAD MAP TO LOOK AT 3 THE DETAILS OF THE ACYIVITIES YOU PERFORMED. AS SUCH, I THINK 4 IT WOULD PROBABLY BE NOT PARTICULARLY EFFECTIVE FOR US TO GET 5 INTO THOSE KIND OF DETAILS AT THIS POINT, 50 I'LL TRY TO DIRECT 6 MY QUESTIONS MORE TOWARDS AN UNDERSTANDING OF THE GENERAL 7 ISSUES IN THE PARTICULAR WAY YOU VIEWED THEM. 8 AT TIMES, I WILL BE GETTING INTO ISSUES WHICH I 9 RECOGNIZE WERE NOT ORIGINATED BY QUESTIONS YOU WERE ASKED TO 10 LOOK AT. I WOULD PARTICULARLY LIKE TO FOCUS ON THE WAY YOU 11 LOOKED AT THOSE TYPE OF THINGS. 12 IN OUR EFFORTS TO EXAMINE THE ISSUES, IT'S NOT IN 13 GENERAL OUR INTENT TO REPEAT REVIEW ACTIVITIES, BUT WE ARE 14 IDENTIFYING PROGRAMS TO LOOK AT ROOT CAUSE GENERIC IMPLICATIONS. T 15 AND ALL OF MY QUESTIONS TODAY ARE WITH THE IDEA OF TRYING TO 16 UNDERSTAND WHERE YOU WERE COMING FROM. 17 SO WE CAN MOST EFFECTIVELY GET TO THAT POINT, I'M 18 GOING TO START IN ONE OF THE AREAS THAT I THINK IS 19 REPRESENTATIVE OF SOMETHING SOMEWHAT UNIQUE TO THIS TYPE OF 20 REVIEW. IT'S THE AREA 0F SUPPORT STABILITY. 21 AND I HAVE LOOKED THROUGH YOUR LETTER OF FEBRUARY 22 19TH OF '85, AND MY QUESTIONS ARE REALLY PRIMARILY GASED ON 23 THAT LETTER. 24 I THINK THE STABILITY ISSUE IS SOMEWH,AT 25 REPRESENTATIVE OF AN AREA WHERE WHAT WE'RE REALLY EXAMINING IS 26 THE VALIDITY OF THE SIMPLIFIED MODELING TECHNIQUES USED IN 27 PIPING. THAT COMES UP IN VARIOUS AREAS THROUGHOUT THE ISSUES ) 28 IDENTIFIED, AND I PARTICULARLY WANT TO FOCUS ON HOW WE DEAL s,*7,s a a e sc,o DOIDGE & CARROLL coy,, go,,, CERTIFIED SHORTHAND REPORTERS couv= oanaso sa t s, as i-ases DEPOSITION NOTARIES ' S ' ' 3 2 ' ' ' ' 5

i 25 i 1 WITH THAT ASPECT OF IT AS OPPOSED TO WHAT WE VIEWED TO BE THE w -i, 2 TECHNICAL OR ENGINEERING SIGNIFICANCE OF THE ISSUE AND HOW YOU 3 HAVE LOOKED AT-THAT ASPECT. 4 IT RELATES A LITTLE BIT TO JOHN FRENCH'S QUESTION IN 5 TERMS OF THE STATE OF THE ART. THE SUPPORT STABILITY ISSUE 6 GIVES US A GOOD STARTING POINT TO LOOK AT THAT ASPECT. WHO 7 SHOULD I BE ADDRESSING MY QUESTIONS TO, NANCY, TO YOU? 8 MS. WILLIAMS: TO START WITH. j 9 MR. WITT: FOR STARTERS, THERE IS A DEFINITION IN 10 YOUR '85 LETTER OF STABILITY ITSELF. THIS IS ONE OF BASICALLY 11 THREE DEFINITIONS. OTHER THAN THE CLASSICAL DEFINITION, THREE 12 PRACTICAL ENGINEERING DEFINITIONS OF STABILITY, ONE RAISED BY 13 CASE, NRC HAS A DEFINITION, AND I BELIEVE CYGNA'S ANSWER IS A i 14 THIRD. I WOULD LIKE TO HAVE A COMMENT ON HOW THE DEFINITION i } ( 15 WAS ARRIVED AT IN TERMS OF WHAT'S VIEWED TO BE TECHNICALLY 16 SIGNIFICANT IN ANY AREAS. IT MIGHT DISAGREE WITH THE OTHER 17 DEFINITIONS. HOW YOU ADDRESS THAT? 18 MS. WILLIAMS: LET ME START WITH THE LAST PART. 19 FIRST, WE DON'T KNOW THE OTHER PARTIES' DEFINITIONS OF 20 STABILITY. WE HAVE NOT SEEN THE NRC'S DEFINITION WITH THE 21 EXCEPTION OF CROSS-EXAMINATION ON THE WITNESS STAND IN LAST 22 APRIL AND MAY OF DAVE TERRELL AND THE STAFF, OF THE STAFF., WE _ g 23 HAVE NOT SEEN CASE'S DEFINITION OTHER THAN DISCUSSIONS WITH MR. 24 D0YLE, ALSO DURING THE HEARINGS. 25 WE'RE NOT ON THE DISTRIBUTION LIST FOR THE 26 CORRESPONDENCE BETWEEN THOSE PARTIES, 50 WE CAN COMMENT ON THE 27 DEVELOPMENT OF OUR CRITERIA, WE CAN COMMENT ON THE TUGC0 3 I 28 AFFIDAVIT BECAUSE WE DID HAVE THAT, BUT WE CAN'T COMMENT ON THE Sy,'",^]c,isc o DOIDGE & CARROLL ,,.,,,, co,,,, CERTIFIED $ NORTH AND REPORTERS towv o,%.w 'd2 satsi est ases DEPOSITION NOTARIES .-,-..--..-._.-__._-.,._m,,,,4_. __m. . _ _,,....,, ~ -.., ._.s __.,v.-,9g. 7 .-,,yn._,,-yi.,.,-.m ,,_e., ,..w

>~, ) 26 1 DIFFERENCES. I'M GOING TO LET GORDO AlK TO THE SPECIFIC ~< -l 2 DETAILS, IF YOU WANT TO GET INTO THEM. WE HAVE DEVELOPED WHAT 3 WE TH{NK IS A CLASSICAL DEFINITION OF STABILITY. IF YOU WOULD 4 LIKE TO WALK THROUGH THAT, hE CAN DO THAT. I DON'T KNOW IF YOU' s 5 WANT TO DO THAT IN THIS MEETING, THAT MUCH DETAIL.

6.

MR. WITT: I THINK STABILITY IS IMPORTANT ENOUGH. AS 7 A STARTING POINT, I WOULD LIKE TO GET INTO SOME APOUNT OF 8 DETAIL WITH RESPECT TO THE DEFINITION. LET ME COMMENT ON WHAT ~ 9 YOU JUST SAID. 10 YOU DID HAVE I PRESUME WHAT YOU ARE SAYING IS YOU 1 11 HAVE. NEVER BEEN FORMALLY. INTRODUCED TO THOSE OTHER DEFINITIONS 12 IN WRITING THROUGH CORRESPONDENCE, BUT I THINK YOUR INTERACTION = 13 WITH BOTH THE NRC AND CASE,' ONE FORM OR ANOTHER, WOULD LEAD YOU r 14. TO BELIEVE THAT YOUR DEFINITION F.ITHER ENCOMPASSES OR IS 3 15 CONSISTENT WITH -- 16 MR. LEVIN: EXCUSE ME, NANCY, I F. YOU WILL, I BELIEVE 17 THE IMPORTANT THING FOR THIS MEETING IS CYGNA'S INTERPRETATION 18 OF THE SAC (TY SIGSIFICANCE IN THEIR VIEW, THE SAFETY '\\ 19 SIGNIFICANT ASPECTS OF STABILITY AND HOW 17'AFFECTS PIPING 20 SYSTEMS IN COMANC.M3 PEAK FROM YOUR PERSPECTIVE. AND WE CAN 21 ADDRESS THOSE THINGS WITH OTHER PA RT'l E S, I THINK. WHEN YOU '22 \\ WERE TALKING / BOUT CLA'SSICAL DEFINITIONS OF STABIITY, YOU WERE I3 T.iLKING ABOUT FROM A EULER SENSE ~ AND SOME OF THE STABILITY 24' DEFINITIONS DEFINED HERE ON FEBRUARY 19TH, 50 WITH THAT, I 25 THINK'WE CAN GET ON WITH IT. MR.,BJORKMAN: THE CLASSIC DEFINITION OF STABILITY 26 -r 27 ACTUALLY COULD BE APPLIED TO PIPING SYSTEMS, AND IN HERE WHEN 3 T i '. '28 WE TALK ABOUT STABILITY, WE ARE N05-REALLY TALKING ABOUT COLUMN = t w w%cisco DOiDGE & CARROLL ' ' S' 5 ' 3' "' co%vaa cesta CEPTtFiZD SHORTHAND REPORTERS covN?v sais a es DEPOSITICN NOTARIES .h

O, 0 27 1 BUCKLING IN THAT SENSE, BUT WHAT WE ARE TALKING ABOUT IS A 2 RIGID BODY TYPE OF STABILITY, WHAT'S CALLED LEOPONOV STABILITY 3 WHICH BASICALLY IS A STABILITY WHERE ONE JUDGES THE STABILITY 4 OF A SYSTEM BY LOOKING AT THE SYSTEM UNDER LOAD. 5 ONE THEN CAN DEFORM THAT SYSTEM SLIGHTLY FROM ITS 6 EQUILIBRIUM POSITION AND JUDGE WHETHER THAT SYSTEM RETURNS TO 7 ITS ORIGINAL EQUILIBRIUM POSITION OR WHETHER OR NOT IT 8 BASICALLY WANTS TO DIVERGE FROM THAT POSITION. THIS IS MORE OR 9 LESS THE CLASSIC DEFINITION OF STABILITY, AS I SEE THE CLASSIC 10 DEFINITION OF S T AB'I L I T Y. 11 AND IN THAT SENSE YOU COULD APPLY THIS CLASSIC 12 DEFINITION OF STABILITY, IF YOU REALLY WANTED TO, TO THE PIPING 13 SYSTEM, BECAUSE YOU CAN MOVE A PIPING SYSTEM FROM THE 14 EQUILIBRIUM POSITION AND DETERMINE WHETHER OR NOT IT WILL T ( 15 RETURN TO THE f-QUILIBRIUM POSITION UNDER THE FORCES IN THE 16 SYSTEM AT THE TIME. 17 SO WHILE WE HAVEN'T GONE INTO DEPTH OF APPLYING THE 18 CLASSIC DEFINITION, WHAT WE'RE TRYING TO DO, BASICALLY, IS TO 19 DETERMINE WHAT THE CRITERIA SHOULD BE FOR AN INDIVIDUAL SUPPORT 20 TO BE STABLE. THAT I S, CAN IT RESIST APPLIED LOADS, THE LOADS 21 THAT IT WAS INTENDED TO RESIST WITH SOME FACTOR OF SAFETY, AND 22 CAN IT MAINTAIN ITS POSITION ON THE PIPE OR RELATIVE TO THE 23 PIPE WITH TIME. l. 24 BECAUSE IF IT CAN'T MAINTAIN ITS POSITION WITH TIME, 25 WE CAN ALTER SOME OF THE ECCENTRICITIES, ANGLE OF THE SUPPORT, 26 SUPPORT MAKES WITH THE PIPE, THE DIRECTION OF THE LINE OF 27 ACTION OF THE COMPRESSIVE FORCE WHICH TENDS TO DESTABILIZE. g 28 THE FORCE MAY BE CHANGED WITH THE CENTER OF ROTATION OF THE Sf',$ ","j C,',5,C 0 DOIDGE & CARROLL e egy,,en,,, oanta%o CERTIFIED SMORTH AND REPORTERS

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28 1 SUPPORT, 50, THEREFORE, WE WANT TO MAINTAIN THE POSITION OF THE 2 SUPPORT WITH TIME, WE DON'T WANT THESE SUPPORTS MOVING ARE J 3 RELATIVE TO THE PIPE WITH TIME TO POSITIONS THEY HAVE BEEN 4 CLASSIFIED AS STABLE BY DESIGN. 5 MR. WITT: DID YOU PUT ANY -- DO YOU, IN YOUR OWN 6 MIND, PUT ANY PRACTICAL BOUNDS ON THE TOLERANCES OF SUCH? 7 MR. BJORKMAN: NO, NOT IN THE BASIC DEFINITION. 8 MR. WITT: AND I PRESUME, THEN, ALSO IN APPLYING THAT 9 DEFINITION IN REVIEWING SUPPORTS, IT'S A SIMILAR SITUATION, 10 THAT IT EITHER MEETS OR DOES NOT MEET THE DEFINITION OF 11 STABILITY? 12 MR. BdORKMAN: YES. WE HAVE DEFINED SUPPORTS AS 13 POTENTIALLY UNSTABLE BECAUSE THERE HAVE BEEN NO OUANTIFICATION 14 ON THE FACT THAT IT IS STABLE. BASICALLY, THAT'S WHY. D. 15 MR. LEVIN: GORDON, HAVE YOU TAKEN IT A STEP FURTHER 16 AND TAKEN A LOOK AT, NOW GOING FROM SUPPORTS INTO SYSTEMS AND 17 DEFINED SYSTEMS AND ABILITY AND RELATIVE TO THE SAFETY 18 OBJECTIVES WE HAVE FOR THE SYSTEMS WHICH, YOU KNOW, WE'RE 19 REALLY AFTER MEETING CODE AND INSURING THAT STRESSES IN THE 20 SYSTEMS ARE WITHIN THE APPROPRIATE ALLOWABLES? JUST CURIOUS IF 21 YOU HAVE TAKEN IT TO THAT. 22 MR. BdORKMAN: WE HAVE DESIGNED WHAT WE BELIEVE TO BE 23 SYSTEM STABILITY. IF YOU LOOK AT A PIPING SYSTEM AS A 24 STRUCTURE AND BASIC DEFINITION OF STRUCTURAL STEEL APPLYING TO 25 PIPING SYSTEMS AS WELL, AND WE KNOW THAT IF WE, AS I MENTION l 26 CVEN AS LONG AGO AS THE HEARINGS, IF WE DO A PIPING ANALYSIS 27 AND FINITE ELEMENT ANALYSIS DOES GIVE US AN ANSWER, WE KNOW ) 28 THAT WE BASICALLY HAVE A GEOMETRICALLY STABLE STRUCTURE. saw eaa%cisco DOIDGE & CARROLL co%vaa costa CERTIFIED SHORTHAND REPORTERS CCWM' .ai$Y[3ea DEPOstTION NOTARIES

29 1 THAT, HOWEVER, IS BASED UPON THE ASSUMPTIONS THAT ONE 2 'PUT INTO THE PIPING ANALYSIS AT THE TIME. IF WE HAVE A STRUT 3 CONNECTED, ATTACHED TO A CLAMP ATTACHED TO A PIPE, IF WE HAVE A 4 STRUT ATTACHED TO A CLAMP WHICH IS ATTACHED TO THE PIPE, THAT l 5 MEMBER WOULD THEN GO INTO THE ANALYSIS AS AN AXI AL RESTRAINT. 6 AND IT IS ASSUMED IN THE ANALYSIS THAT THAT CAN 7 DEVELOP THE FORCES IN THE DIRECTION OF THE STRUT. THE ANALYSIS 8 DOESN'T KNOW THAT. POTENTIALLY, IF THE CLAMP CANNOT DEVELOP 9 SUFFICIENT FRICTIONAL FORCES, THAT THE CLAMP MAY ROTATE AROUND 10 THE PIPE. THAT'S NOT PART OF THE OVERALL FINITE ELEMENT 11 EVALUATIONS. 12 SO FROM A STANDPOINT OF GEOMETRIC STABILITY, THE 13 SUCCESSFUL COMPLETION OF A PIPE STRESS ANALYSIS INDICATES THAT 14 YOU HAVE A GEOMETRICALLY STABLE SYSTEM OR GEOMETRICALLY l i 15 SATISFACTORY ARRANGEMENT OF SUPPORTS. 16 SO FROM THE SYSTEM STABILITY POINT OF VIEW, THERE IS 17 NOT A PROBLEM, EXCEPT IF AN INDIVIDUAL PIPE SUPPORT BY ITSELF 18 COULD BECOME UNSTABLE AND NOT PERFORM ITS FUNCTION. IF IT 19 DOESN'T PERFORM ITS FUNCTION, IT DOES NOT RESIST THE INTENDED 20 LOAD, THEN AT THAT POINT YOU REALLY DON'T KNOW WHETHER WE HAVE 21 A SYSTEM STABILITY PROBLEM. 22 IT'S RATHER A LONG SHOT, BUT IF YOU LOSE ONE SUPPORT, 23 YOU COULD BE IN A GEOMETRICALLY UNSTABLE CONFIGURATION, VERY 24 DOUBTFUL, HOWEVER. YOU CERTAINLY WOULD DEVELOP HIGHER LOADS IN 25 ADdACENT SUPPORTS FOR WHICH THEY WERE NEVER INTENDED TO RESIST, 26 SO YOU HAVE THE POTENTIAL FOR SYSTEM INSTABILITY, BUT REALLY 27 ONLY AFTER YOU WOULD HAVE AN INDIVIDUAL SUPPORT INTENTIONALLY. ) I 28 MR. LEVIN: DO YOU BELIEVE WE HAVE THE TOOLS TO sa% en.%cisco DOIDGE & CARROLL

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.e 30 1 REALLY JUDGE THAT? -i 2 MS. WILLIAMS: WHETHER AN INDIVIDUAL SUPPORT IS 3 UNSTABLE? 4 MR. LEVIN: GIVEN AN INDIVIDUAL SUPPORT IS EXHIBITING 5 UNSTABLE BEHAVIOR, AND TAKING A LOOK AT THE IMPACT OF THAT INTO 6 THE REST OF THE SYSTEM, IT SEEMS TO ME THAT IT'S SOMETHING THAT 7 WE CAN DEAL WITH, IT WOULD CREATE ANOTHER ITERATION IN OUR 8 NORMAL PROCESS. JUST CURIOUS IF YOU GOT TO THE POINT WHERE YOU 9 HAVE IDENTIFIED CONFIGURATIONS THAT ARE POTENTIALLY UNSTABLE, 10 YOU HAVE CARRIED IT THE NEXT STEP YOURSELF. 11 MR. SHULMAN: MIKE SHULMAN. I DON'T THINK WE'RE 12 RAISING THE ISSUE ON PIPING SYSTEM STABILITY. I THINK THE WORD 13 STABILITY T$NDS TO CARRY US OVER. WE'RE RAISING THE ISSUE OF A 14 SUPPORT THAT IS NOT PERFORMING ITS FUNCTION. IF IT BECOMES 3 ( 15 UNSTABLE, YOU WOULD ASK THE SAME QUESTION. IF THE SUPPORT 16 EXCEEDED ALLOWABLES FOR SOME REASON, UNABLE TO ISSUE -- THE 17 STABILITY ISSUE, RAISING THE ISSUE OF WHETHER A SUPPORT CANNOT 18 PERFORM ITS FUNCTION. IS THAT A FAIR STATEMENT FOR YOU? 19 MS. WILLIAMS: I THINK I WANT TO ADD SOMETHING. I 20 WANT TO MAKE SURE THAT YOU ARE NOT THINKING THAT WE'RE 21 ADVOCATING PERFORMING ANALYSES THAT WOULD CHECK THE STABLE 22 CONDITION OF THE SYSTEM BEYOND THE TOOLS YOU HAVE AVAILABLE IN 23 A NORMAL STRESS ANALYSIS TODAY. 24 BUT WHAT WE ARE SAYING I S, BASED ON YOUR 25 CLASSIFICATION AT THE END OF THE LETTER HERE OF THE SUPPORTS 26 THAT WE HAVE IN OUR REVIEW SCOPE, THERE IS ENOUGH OF THEM WHERE 27 THIS POTENTIAL EXISTS THAT WE THINK TUGC0 SHOULD GO THROUGH A ) 28 SYSTEMATIC REVIEW, WHICH IS NOT NECESSARILY ANYTHING EXTREMELY

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i 31 1 ESOTERIC, BUT SOMETHING METHODICAL TO EVALUATE THE EFFECT FROM 2 A SYSTEM STANDPOINT, OR WHICHEVER OF THE THREE ALTERNATIVES YOU 3 CHOOSE, THAT WE HAVE AT THE END OF THE LETTER. i 4 BUT WE'RE NOT VERY SPECIFIC ON THAT, BUT WE'RE NOT 5 TALKING ABOUT HIGHLY SOPHISTICATED TOOLS OR DIFFERENT 6 APPROACHES IN THAT MANNER OF SPEAKING, WE DON'T HAVE ALL THE 7 INFORMATION TO DO THAT. SO WE HAVEN'T GONE AND DONE AN 8 INDIVIDUAL SYSTEM, THAT YOU JUST ASKED, AND FOUND AN UNSTABLE 9 GEOMETRY. AS A WHOLE, WE'RE SAYING THAT WE THINK IT NEEDS TO 10 BE DONE, BUT WE'RE NOT THE PEOPLE TO DO IT. 11 MR. LEVIN: ADD TOWARDS WHETHER YOU -- YOU EITHER 12 COMPLETED OR CONTEMPLATED SUCH AN EFFORT FOR THE SYSTEMS IN THE 13 SCOPE, COUL6 YOU MAKE A STATEMENT ON THE OVERALL SYSTEM'S 14 STABILITY ON THE SYSTEMS COLLECTED? \\ 15 MS. WILLIAMS: NO, WE HAVEN'T ATTEMPTED TO DO IT. 16 MR. WITT: AS I INTERPRETED THE LETTER, IN YOUR 17 DISCUSSIONS, SPECIFICALLY ON SYSTEM STABILITY WITH RESPECT TO 18 THIS TYPE OF STABILITY, IT WOULD -- I THINK IT SAYS THAT IF YOU 19 DON'T HAVE THE SUPPORT STABILITY BASED ON THE SUPPORT ITSELF 20 WITHOUT TAKING CREDIT FOR THF. ADdACENT SUPPORTS, THEN YOU HAVE 21 A STABILITY PROBLEM AT THAT POINT IN TIME. 22 MR. BdORKMAN: YOU HAVE A POTENTIAL FOR A PROBLEM. 23 MS. WILLIAMS: YOU HAVE TO CHECK NEIGHBORING SUPPORTS. 24 MR. BdORKMAN: YOU HAVE TO CHECK NEIGHBORING SUPPORTS. 25 MR. WITT: WOULD BE TO DELETE FROM THE MODEL THE 26 SUPPORT THAT WAS VIEWED TO BE UNSTABLE, I THINK I READ IN HERE, 27 YOU WOULD THEN RECOMMEND REMOVAL OF THE SUPF&tT? ) I 28 MR. BdORKMAN: M-HM, THAT'S CORRECT. 5 p,",jcy,5,C 0 D01DGE & CARROLL

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e s 32 1 MR. WITT: BUT THE CONCEPT OF LEAVING THE UNSTABLE 2 SUPPORT AND TAKING CREDIT FOR ADdACENT SUPPORTS TO DEMONSTRATE 3 OVERALL SYSTEM STABILITY, YOU HAVE DETERMINED TO BE REALLY NOT 4 A CORRECT WAY TO VIEW THE SITUATION? 5 MR. BdORKMAN: NO, IT'S PROBABLY VERY SUBTLE, THE 6 DIFFERENCE. LET ME CLARIFY. 7 MR. DOUGHERTY: I THINK THERE ARE SUBTLE ASPECTS. 8 THAT'S WHY I'M PURSUING IT. I THINK A SOLID UNDERSTANDING OF 9 THE ISSUE HAS TO, I THINK YOU HAVE LOOKED AT IT, 50 I HAVE TO 10 BENEFIT. 11 MR. BdORKMAN: IF YOU JUDGE YOU HAVE A SUPPORT WHICH 12 IS POTENTIALLY UNSTABLE, AND YOU WOULD -- AND YOU WOULD LIKE TO 13 ADDRESS THE~ PROBLEM OF THAT SUPPORT STABILITY BY JUST REMOVING 14 IT AND SAYING, I THINK OUR SYSTEM IS OKAY WITHOUT THE SUPPORT, T 15 AND YOU REANALYZE THE SYSTEM WITHOUT THAT SUPPORT IN THE PIPING i 16 SYSTEM, ONE WOULD NORMALLY THEN GO BACK AND LOOK AT STRESSES IN 17 THE PIPING LOADS IN THE SUPPORT AND MAKE A REEVALUATION BASED 18 ON THOSE. 19 WHAT WE'RE SAYING IS, THAT THAT IS NOT SUFFICIENT. 20 WHAT WE'RE SAYING IS THAT ONE MUST NOW ALSO LOOK AT THE 21 DISPLACEMENTS WHICH HAVE NOW BEEN GENERATED BY THE REMOVAL OF 22 THAT SUPPORT AND LOOK AT THE DISPLACEMENTS THAT REMOVAL OF THAT 23 SUPPORT HAS HAD ON OTHER NEIGHBORING SUPPORTS, WHICH ALSO MAY 24 HAVE A PROBLEM OF INSTABILITY, IF THEIR DISPLACEMENTS EXCEED A 25 CERTAIN MARGIN OR CERTAIN LIMIT. 26 SO THERE IS MORE THAN JUST CHECKING SUPPORT LOADS AND 27 PIPE STRESSES. THE RESULTS OF THE PROBLEM, YOU MAY HAVE g 28 ANOTHER SUPPORT OF THE SAME TYPE POTENTIALLY UNSTABLE, IF IT'S saw ena=cesco DOIDGE & CARROLL 4' S' '*60 cosy.. cost. CERTIFIED SHORTH AND REPORTERS Co^t' saiN [ 33s. DEPOSITION NOTARIES "#^

2 33 1 DEFORMATION EXCEEDED A CERTAIN VALUE. 2 MR. SHULMAN: MIKE SHULMAN. IT WOULD STILL BE A 3 SUPPORT OF THE SAME TYPE THAT HAD CONCERN FOR SUPPORTED 4 STABILITY. 5 MR. BdORKMAN: CORRECT. 6 MR. LEVIN: I THINK WHAT WE'RE SHOOTING FOR IS SOME 7 RECONCILIATION IN OUR MIND THAT WE WILL BE ABLE -- I THINK 8 THERE IS GROUPS OF STABILITY ISSUES. I THINK THERE ARE 9 PROBABLY CONFIGURATIONS WHERE IT'S MORE DIFFICULT TO TRY TO 10 DEAL WITH IT IN AN, ANALYTICAL WAY, FOR EXAMPLE, AND AS I 11 SUGGESTED IN MY OPENING COMMENTS, MORE EXPEDIENT APPROACH OF 12 DEALING WITH I T, SIMPLY BECAUSE WE DON'T KNOW HOW THAT WOULD 13 IMPACT SYST M STABILITY, MIGHT BE TO DO SOMETHING ABOUT THAT 14 SUPPORT, INCLUDING REMOVAL OR MODIFICATION. T 4 15 BUT THERE IS ALSO A CLASS THAT MIGHT FIT INTO THE 16 DEFINITION OF STABILITY, IT MIGHT BE NOTED WHERE, WITHIN THE 17 BOUNDS OF WHAT WE CAN DO. WE CAN INTEGRATE, WE CAN MODEL, SO 18 TO SPEAK, IN RECONCILING HOW WE WOULD EXPECT IT TO BEHAVE INTO 19 A MORE COMMON ANALYSIS AND INTEGRATE THAT WITH A LOT OF OTHER 20 EFFECTS WE'RE GOING TO BE TALKING ABOUT TODAY. 21 WE HAVE A LOT OF ISSUES ON THE TABLE THAT HAVE TO BE 22 INTEGRATED INTO A SYSTEM MODEL WHERE WE HAVE TO LOOK AT THESE 23 THINGS TOGETHER. I THINK CERTAIN TYPES OF SUPPORT 24 CONFIGURATIONS CAN FIT INTO THAT CATEGORY AS WELL. WE'RE 25 TRYING TO SEEK A GROUNDS, SO TO SPEAK, WHERE IT IS 26 APPROPRIATE -- I DON'T PERSONALLY WANT TO SEE A SITUATION WHERE 27 ANYTHING FALLING INTO THIS CATEGORY HAS TO BE DEALT WITH ) 28 ENTIRELY BY REMOVAL OR MODIFICATION. I DON'T REALLY BELIEVE i 1 5

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O s 34 4 1 THAT85 APPROPRIATE. Rb. WILLIAMS: IF YOU ARE INDICATING A POTENTIAL FOR 2 y ~ 3 A GENERIC STUD'f 6b THIS, I THINK THAT OUR FEELING IS THAT WON'T 4 ANSWER THE. QUESTION, THAT YOU DO HAVE TO DO A SYSTEMATIC REVIEW 5 SYSTEM BY SYSTEM. 6 MR. LEVIN: NANCY, I AGREE. I THINK THAT ONE.NEEDS 7 TO GO LOOK AT THE HARDWARE, ASSESS HOW WE EXPECT IT TO BEHAVE 8 AND RECONCILE THAT. AND OUR PROGRAM WILL ADDRESS THE DEGREE TO 9 WHICH ONE NEEDS TO DO THAT TO GET THE LEVEL OF CONFIDENCE WE 10 NEED, BUT IT CERTAINLY WILL INCLUDE AN ELEMENT OF RECONCILING 11 WHAT EXISTS IN THE FIELD AND BEHAVIOR THAT WE EXPECT WITH 12 RESPECT TO THE STABILITY. GOING BACK INTO THE ANALYSIS, IN 13 SOME CASES,'THE ASSUMPTIONS MAY BE APPROPRI ATE. THAT'S THE 14 GROUNDS I'M TALKING ABOUT. IN OTHER CASES, NOT. 3 15 WE MAY FIND IT'S OUTSIDE OUR ABILITY TO DEAL WITH, 16 AND WE WILL HAVE TO SEEK SOME OTHER SOLUTION. 17 MR. SHULMAN: I THINK YOU CAN GO THROUGH A OUICK 18 SCREENING PROCESS AND DETERMINE WHICH SYSTEMS HAVE TO BE LOOKED - 19 AT. FOR INSTANCE, IF THERE IS ONE SUPPORT IN THE SYSTEM THAT 20 EXHIBITS THE POTENTIAL TO BE UNSTABLE, OB VI OUS LY, ONCE YOU PULL 21 THAT ONE OUT, YOU DON'T HAVE TO LOOK AT SYSTEM STABILITY. 22 THERE ARE NO OTHER SUPPORTS THAT HAVE THAT POTENTIAL. I DON'T 23 KNOW HOW MANY THERE ARE, ONE OR TW O, IN A GIVEN SYSTEM. THAT'S i 24 A OVERVIEW WE HAVE TO DO TO DETERMINE WHETHER OR NOT THERE IS A i 1 25 POTENTIAL THROUGH OTHER SUPPORTS BECOMING UNSTABLE. I KEEP J 26 RESTATING THE ISSUE THAT GORDON IS TALKING ABOUT ULTIMATELY 27 GOES BACK TO SUPPORT STABILITY. 3 I 28 MR. MORTGAT: I HAVE A QUESTION REGARDING THE EXAMPLE. S*N *=asc sco DOlD & CARROLL coyvnacosta ''3"'C CERTIFIED SHORTH AND REPORTE RS Cov*T' sa,N [ asse DEPOSITION NOTARIES

o 35 1 DO YOU DEFINE A STABILITY PROBLEM AS A FUNCTION OF THE GEOMETRY s -i 2 OF THE SUPPORT ONLY OR THE WAY IT BEHAVES IN THE ANALYSIS OR 3 FUNCTION OF DISPLACEMENT? 4 FOR EXAMPLE, YOU GAVE'THE EXAMPLE OF ONE SUPPORT 5 THAT'S POTENTIALLY UNSTABLE YOU REMOVE FROM THE ANALYSIS AND 6 SAID YOU HAVE TO CHECK THE OTHER ONES TO SEE IF THEY ARE NOT 7 UNSTABLE. IF IT'S A FUNCTION OF GEOMETRY, YOU KNOW IT AHEAD OF 8 TIME. 9 MR. BdORKMAN: LET'S TAKE THE CASE WHERE YOU HAVE THE 10 POTENTIAL FOR UNSTABLE SUPPORT, AND YOU REMOVE IT FROM THE 11 SYSTEM. AND TO TAKE A -- AN EXAMPLE WHICH ACTUALLY EXISTS OF A 12 U-BOLT CINCHED AROUND THE PIPE, OKAY? -- WITH A CLEVIS AT THE 13 BOTTOM OF THE CROSSPIECE AND STRUT ANGLED AT SOME ANGLE THREE 14 DEGREES OFFSET THE LINE OF ACTION OF THE STRUT FORCE, DOES NOT 3 i 15 GO THROUGH THE CENTER OF THE PIPE, WHICH IS A TENDENCY FOR THAT 16 TO ROTATE. 17 THIS SUPPORT COULD HAVE BEEN CHECKED AND FOUND TO BE 18 STABLE BASED UPON THE LEVEL OF PRE-LOAD THAT WAS IN IT AND WILL 19 BE MAINTAINED DURING THE LIFE OF THE SUPPORT. HOWEVER, WHEN 20 THE SUPPORT DOWNSTREAM IS REMOVED, THE THERMAL MOVEMENT MAY 21 MOVE THAT SUPPORT TO A NEW POSITION, AND SEISMIC AND OTHER 22 FORCES MOVE IT TO STILL ANOTHER POSITION WHERE THE ECCENTRICITY 23 IS INCREASED GREATLY, THEN YOU HAVE TO GO BACK AND REEVALUATE 24 THE SUPPORT. THAT'S THE KIND OF SITUATION I'M TALKING ABOUT. 25 MR. WITT: THAT KIND OF EVALUATION IS LIMITED TO THE 2G SUPPORTS THAT INITIALLY ARE OF THE CATEGORY THAT MIGHT HAVE 27 INSTABILITY? 5 28 MR. BJORKMAN: CORRECT. S AN FRANCISCO DotDGE & CARROLL sa a esso comy. costa CERTIFIED SHORTH AND REPORTERS C ouNT ' .4, 33ee DEPOSITION NOTARIES

36 1 MR. WITT: YOU MADE THE POINT, MIKE, I THINK IT'S 2 IMPORTANT. THERE HAS BEEN INTRODUCED THE CONCEPT OF SYSTEM 3 STABILITY, SUPPORT STABILITY, NOT IN THE SENSE OF BEING A 4 CONCERN FOR SYSTEM STABILITY, BUT THAT MIGHT BE A WAY OF 5 LOOKING AT A SUPPORT AND SHOWING THAT IN FACT, THAT ALTHOUGH 6 THE SUPPORT IS INDIVIDUALLY UNSTABLE, THAT IT CAN PERFORM ITS 7 INTENDED FUNCTION BECAUSE IT IS A PART OF A SYSTEM, THAT IT'S 8 BEEN A CONCEPT RAISED IN TERMS OF ADDRESSING THIS. WHAT I AM 9 HEARING HERE, YOU HAVE LOOKED AT THAT, AND YOU DON'T KNOW THAT 10 THAT'S REALLY VALID, TRUE. 11 MR. BJORKMAN: I THINK WHAT I AM HEARING IS THAT A 12 SUPPORT WHICH HAS THE POTENTIAL FOR BEING UNSTABLE, BUT AS A 13 SYSTEM -- 14 MR. WITT: AS PART. ) 15 MR. BJORKMAN: -- THAT IT WILL STILL PERFORM ITS 16 INTENDED FUNCTION, SOMEHOW, WITHIN THE OVERALL SYSTEM CONCEPT. 17 I CAN'T SEPARATE THAT OUT. IF IT DOES NOT PERFORM ITS INTENDED 18 FUNCTION, THEN THE SYSTEM SHOULD BE EVALUATED WITHOUT THAT 19 SUPPORT. 20 MR. WITT: WITHOUT IT, OKAY. 21 MR. SHULMAN: I THINK THE POSITION YOU MENTIONED THAT 22 WOULD BE CONSERVATIVE TO SAY THE SUPPORT HAS A POTENTIAL TO BE 23 UNSTABLE, PULL IT OUT. I THINK GORDON IS SAYING YOU EVALUATE 24 IT BASED ON THE DEFLECTIONS AND ROTATIONS GIVER THE UNSTABLE 25 SUPPORT. 26 MR. MORTGAT: THEN YOU ANALYZE IT WITHIN THE SYSTEM, s 27 PART OF THE SYSTEM, IS HOW YOU EVALUATE IT. I 28 MR. SHULMAN: YOU SAY ANALYSIS. I THINK THAT CAN BE saw ena=cisco DOIDGE & CARROLL S3*** cos,=. cos,a CERTIFIED SHORTHAND REPORTERS C 0 sNT ' is t asse DEPOSITION NOTARIES

I 37 1 TO SOME EXTENT THE SCREENING PROCESS. I DON'T SEE THAT BEING a% l -( 2 THE MAJOR ANALYTICAL. IT MAY BE YOU CAN DISMISS THAT BASED ON 3 KNOWN DEFLECTIONS-AND WHAT OCCURS. 4 MR. STUART: DICK STUART. IF I CAN MAKE A COMMENT 5 HERE, I THINK THAT THERE IS TWO ISSUES, REALLY, THAT WE'RE 6 ADDRESSING AT THE TABLE. I THINK ONE OF THE TWO ISSUES, THERE l 7 ARE MORE EXAMPLES OTHER THAN THE ONE WE CITED HERE OF 8 INDIVIDUAL SUPPORT POSSIBLE INSTABILITIES, AND I THINK I 9 SEPARATED THE TWO CLASSES DETERMINING, NUMBER ONE, WHETHER AN 10 INDIVIDUAL SUPPORT HAS THE POTENTIAL FOR INSTABILITIES, AND 11 THERE IS SEVERAL WAYS THAT ONE COULD GO ABOUT DOING THAT. I 12 THINK GORDON MENTIONED ONE OR TWO WAYS, BUT ALSO THERE IS THIS 13 RATHER SIMPLE KL OVER R WHERE THERE IS SOME EXAMPLES OF THE 14 SLENDERNESS RATIO CRITERIA KL OVER R, WHICH BASICALLY HAS BEEN T 15 VIOLATED OR NOT CHECKED AS A PART OF THE SUPPORTS. 16 50 I THINK THERE IS SEVERAL CLASSES OF I NDI VIDUAL 17 SUPPORT INSTABILITIES, POSSIBLY, THAT NEED TO BE ADDRESSED ONE 18 BY ONE TO DETERMINE WHETHER, IN FACT, THIS IS JUST ANALYTICAL 19 INSTABILITY OR TRUE INSTABILITY IF THEY WERE TO ACHIEVE THOSE 4 20 LOADS. 21 AND THEN I THINK, SECONDLY, ONE NEEDS TO LOOK AT THE 22 EFFECT OF AN INDIVIDUAL SUPPORT INSTABILITY UPON THE OVERALL 23 SYSTEM. AND I THINK THERE IS SEVERAL WAYS THAT ONE COULD DO 1 24 THAT. THE LEAST ACCEI' TABLE FROM MY POINT OF VIEW, WOULD BE 25 GOING BACK AND ANALYZING ALL THE SYSTEMS AGAIN SEVERAL WAYS. 26 ONE COULD LOOK AT THE EFFECTS ON ADJACENT SUPPORTS 27 OF -- NARROW THEM DOWN TO CLASSIFYING WHERE THOSE SITUATIONS g I 28 EXIST AND WHAT, IF ANY, ARE THE CORRECTIVE ACTIONS TO DEAL WITH i Sy,'",",]Cy,5,ef DOIDGE & CARROLL costaa costa CERTIFIED SHORTHAND REPORTERS cov%n oa%ase "isi 932-31s seits est saps. OEPOSITION NOTARIES .,--n--- ,.- -- - ~.---- -.,..,,.

o 38 1 THAT. 2 IF, IN FACT, ALL OF THE INDIVIDUAL SUPPORT POTENTIAL 3 INSTABILITIES COULD BE RESOLVED, THEN IT'S POSSIBLE THAT ONE ] 4 DOESN'T HAVE TO GO BACK AND LOOK AT THE OVERALL SYSTEM AS A a 5 SOLUTION. I THINK PART OF WHAT WE'RE GOING TO TRY TO DO, AS I 6 SAID, OVER THE NEXT 10 DAYS OR 50, IS TO REALLY TRY TO CLASSIFY 7 WHERE THOSE ISSUES CAN BE GROUPED INTO THOSE OF INDIVIDUAL 8 SUPPORT INSTABILITY AS WELL AS THE OVERALL SYSTEM EFFECTS AND 9 TRY TO PRESENT THEM, A

SUMMARY

, INTO THOSE TWO CATEGORIES FOR 10 YOU. 11 MR. WITT: ANOTHER TOPIC ON STABILITY, BUT I THINK WE 12 HAVE A PRETTY GOOD UNDERSTANDING OF YOUR REVIEW IN THAT AREA, 13 THIS DEALS WITH THE DYNAMIC TESTING AND ANALYSIS COMMON, AS I 14 UNDERSTAND, THAT YOU LOOK AT IT AND DON'T SEE THAT THIS IS A ) 15 PARTICULARLY EFFECTIVE WAY OF LOOKING AT THE ISSUE. 16 IN OTHER WORDS, IF YC'J DON'T HAVE STATIC STABILITY, 17 THE CONCEPT OF USING DYNAMIC TESTING TO SHOW IT'S DYNAMICALLY 18 STABLE, COULD YOU COMMENT ON WHAT YOU WENT THROUGH TO ARRIVE AT 19 THAT POSITION, IF THERE WAS ANY -- ANYTHING IN TERMS OF TESTING, 20 THAT YOU DID LOOK AT OR PROPOSE TESTS OR WHATEVER BACKGROUND TO 21 REACH THAT CONCLUSION? 22 MR. BdORKMAN: BASICALLY, SUPPORT STABILITY, THE 23 LOADS THAT ARE GENERATED ON SUPPORT NOT ONLY -- THE LOADS THAT 24 ARE GENERATED ON THE SUPPORT NOT ONLY ARE DYNAMIC, THEY ARE 25 ALSO STATIC. CERTAINLY, THE CASE OF DEAD LOAD AND THERMAL 26 LOADS, THE SUPPORT MUST MAINTAIN ITSELF STATICALLY IN A STABLE 27 CONDITION. ) 28 AS FAR AS THE -- RESOLVING THE ISSUE OF A POTENTIALLY sa% ema%cisco DOIDGE & CARROLL cos,=. cost. s43 esso CERTIFIED SHORTH AND REPORTERS CowNT' e4,74[33es OEPOSITION NOTARIES

39 1 UNSTABLE SUPPORT WHICH IS -- COULD BE SHOWN FROM A SIMPLE 2 CALCULATION TO BE STATICALLY UNSTABLE TO TRY AND OUALIFY IT 3 THROUGH A DYNAMIC TEST, I THINK FOR ANY TEST TO REALLY BE VALID, 4 IT WOULD HAVE TO BE EXTREMELY COMPLEX AND EXTENSIVE. 5 BECAUSE THE DYNAMICS, UNFORTUNATELY, WORKS IN BOTH 6 WAYS. IT CAN WORK FOR YOU, IT CAN WORK AGAINST YOU. THE TEST 7 WOULD HAVE TO BE REPRESENTATIVE OF PIPING SYSTEM FUNDAMENTAL 8 FREQUENCIES, THE SYSTEM WOULD HAVE TO BE DRIVEN IN THOSE 9 FUNDAMENTAL FREQUENCIES, AND THIS MEANS THAT GENERALLY YOU 10 WOULD HAVE FAIRLY LARGE DISPLACEMENT DYNAMIC TESTS TO BE TRULY 11 A GOOD DYNAMICS TEST. 12 THE INPUT SHOULD BE SOMEWHAT RANDOM AND NOT 13 NECESSARILY THE SAME WHEN ALL OF THESE THINGS COMBINED, THE 14 RANDOM MOTION, POTENTIAL FOR RELATIVELY LARGE DISPLACEMENT, ) 15 DYNAMIC INPUT TO SYSTEMS WHICH HAVE FREQUENCY IN THE 16 NEIGHBORHOOD OF WHAT THE PIPING SYSTEM FREQUENCY WOULD BE, I 17 THINK THEN YOU ARE BEGINNING TO GET A DYNAMIC TEST WHICH BETTER 18 REPRESENTS THE IDEA. TO DO SUCH A TEST WOULD BE VERY DIFFICULT, 19 IN MY OPINION, BECAUSE I THINK THAT TO INPUT THE MAGNITUDE OF 20 THE FORCES THAT WE'RE TALKING ABOUT AND THE MAGNITUDE OF THE 21 DISPLACEMENTS THAT WE'RE TALKING ABOUT, I THINK PUTS A REAL 22 STRAIN ON ANY TEST FACILITY. 23 MR. WIT'i' LET ME EXPLAIN THE REASON FOR MY QUESTION. 24 IN TERMS OF WHAT WE HAVE SEEN PROPOSED BY COMANCHE PEAK FOR ) 25 RESOLUTION ON SOME OF THESE STABILITY PROBLEMS, THEIR PROPOSED ) 26 FIXES INVOLVE UNTYPICAL USE OF HARDWARE. AND IT MAY BE 27 NECESSARY, IF THEY WANT TO PURSUE THAT, TO PERFORM TESTING, TO ) ( 28 VALIDATE THOSE ASSUMPTIONS. THAT'S WHERE I WAS, YOU KNOW, san *aasc'sco DOIDGE & CARROLL coc., cas,, "'3*** CERTIFIED SHORTH AND REPORTERS covNTv S3' sa i aise DEPOSITION NOTARIES

40 4 1 CONCERNED ABOUT THE FACT THAT IT APPEARED THAT DYNAMIC TESTING m -i 2 WAS REJECTED AS A MEANS OF LOOKING AT THIS ISSUE. 3 AND IN SOME CASES THAT WOULD GO ALONG WITH IT, SOME 4 OF THE PROPOSED FIXES JUST WITHOUT ANY FURTHER EXAMINATION. 5 AND IT APPEARED TO ME THAT IT MIGHT -- IT SHOULD BE A COURSE 6 WHICH IS LEFT OPEN, IF IT'S VALID. AND I WAS CONCERNED ABOUT 7 WHETHER YOU FELT IT WAS NOT VALID TO DO THIS OR WHETHER YOU 8 FELT IT WAS. 9 MR. WITT: I THINK YOU CAN 00 DYNAMIC TESTING, I 10 THINK THE EXTENT OF ANY DYNAMIC -- THE S IZE OF THE DYNAMIC 11 TESTING PROGRAM WOULD BE VERY EXTENSIVE AND IT WOULD HAVE TO 12 COVER WORSE CASES AND UP TO MAKE SURE THAT ALL THE PARAMETERS 13 THAT COULD BE -- OR THAT THE TEST ENVELOPE WORSE CASE 14 PARAMETERS CERTAINLY IF THERE IS A LIMIT TESTING. 3 e 15 MS. WILLIAMS: IT SOUNDS LIKE THE TESTING YOU ARE 16 TALKING A'r)UT, DOUG, IS FOR HARDWARE ACCEPTABILITY IN A 17 PARTICULAR CONFIGURATION AS OPPOSED TO TESTING -- 18 MR. WITT: ALMOST PROTOTYPE. ~ 19 MS. WILLIAMS: NOT TALKING ABOUT TESTING A SYSTEM. 20 MR. WITT: THAT'S AN INTERESTING POINT. SINCE WE ARE 21 LOOKING PRIMARILY AT SUPPORT STABILITY, I PRESUME THE TEST 22 COULD BE LIMITED TO INDIVIDUAL SUPPORT CONFIGURATIONS AND YOU 23 AGREE WITH THAT. 24 MR. BUSH: SPENCE BUSH. JUST ONE THING THAT MIGHT 25 INTEREST THE GROUP, AND I DON'T THINK THERE IS ANYBODY IN THE 26 ROOM THAT'S AWARE OF IT. LIVERMORE HAS COMPLETED RECENTLY A 27 TWO-YEAR EXTENSIVE STUDY OF THE BUSINESS OF, NOT SO MUCH 3 I 28 INSTABILITY AS THE BUSINESS OF REMOVAL OF SUPPORTS, AND THE S^N 'a*%C'Sc o DOIDGE & CARROLL cos,. cos,. CE RTIFIED SHORTH AND REPORTERS cow' 3#~" .a t 33ee DEPOSITION NOTARIES

41 1 IMPLICATIONS INSOFAR AS PIPING SYSTEM RESPONSE IS CONCERNED. 2 THAT DOCUMENT EITHER IS ON THE STREET NOW OR IT'S VERY CLOSE TO 3 BEING THERE. 4 I HAVE VIEWED IT A COUPLE OF TIMES IN THE CONTEXT OF 5 PRESSURE VESSEL RESEARCH STEERING COMMITTEE ON PIPING, AND I 6 THINK, WHEREAS IT DOESN'T ADDRESS THE INSTABILITY ISSUE 7 DIRECTLY, THAT THE INPUT AND THE IMPLICATIONS MIGHT BE OF VALUE 8 TO SOME OF THE REVIEW TEAM MEMBERS. YOU.MIGHT WANT TO TRY TO i 9 GET AHOLD OF THAT REPORT. IT DOES REPRESENT A LARGE NUMBER OF 10 CASE HISTORIES AND REMOVAL OF ONE OR MORE SUPPORTS IN DIFFERENT 11 LOCATIONS AND HOW THE SYSTEM RESPONDS. IT SHOULD BE A NEW REG 12 DOCUMENT. I DON'T HAVE THE NUMBER. IF THERE WAS AN INTEREST, 13 THE BEST CONTACT WOULD BE JOHN O'BRIEN AT THE NRC RESEARCH. 14 MR. WITT: I JUST HAVE I THINK ONE MORE QUESTION T -15 THAT'S FAIRLY SIMPLE. I THINK IN THE LETTER YOU MENTIONED i 16 THERE HAD SEEN 226 SUPPORTS SELECTED AND YOU GAVE STATISTICS AS 17 TO YOUR FINDING, WAS THAT 226 SELECTED, WAS THAT FOCUSED ON THE 18 -INSTABILITY OR WAS THAT A RANDOM 226? 19 MS. WILLIAMS: THAT WAS OUR REVIEW SCOPE. 20 MR. WITT: THAT WAS YOUR REVIEW SCOPE. I WANT TO 21 COME BACK TO THE ISSUE OF TESTING, GORDON. CORRECT ME IF I'M 22 WRONG. GIVEN THAT VIRTUALLY EVERY COMPONENT OF A NUCLEAR POWER \\. 23 PLANT HAS BEEN TESTED IN ONE FASHION OR ANOTHER, I FIND IT 24 DIFFICULT TO BELIEVE THAT YOUR GROUP COULDN'T DEVELOP A TEST 25 THAT COULD BE ACCEPTABLE TO THE CYGNA REVIEWERS. 26 MR. STUART: IF IT WAS CAREFULLY THOUGHT OUT TO 27 ENVELOPE THE CASES, AS GORDON SAID, I THINK THAT'S JUST A -- ) 28 ONE P0 TINT I WOULD LIKE TO EMPHASIZE. I THINK IT'S BECAUSE WE Sy,* ",^,','C,',S,c,o D01DGE & CARROLL eos,,,go,,, CiiRTIFIED SHORTH AND REPORTERS c onte oanamo se a ts es b3394 DEPOSITION NOTARIES '* ' S ' '3 2 ' ' ' S

42 1 HAVE BEEN LOOKING AT IT FOR A LONG TIME. I'M SURE GORDON AND -{ 2 NANCY AND OTHER REVIEWERS HAVE THOUGHT ABOUT THE POSSIBLE 3 THINGS THAT COULD GO WRONG OR THINGS THAT NEED TO BE CONSIDERED 4 IN A TEST,.AND I THINK A WELL DESIGNED TEST, I'M SURE, WILL 5 SATISFY OUR REVIEWERS, AND IF THEY HAVE A CHANCE TO TAKE A LOOK 6 AT IT BEFORE THEY START. 7 MR. WITT: THAT'S ALL THE QUESTIONS I HAD IN THE AREA 8 OF STABILITY, 9 THE NEXT ISSUE I WANT TO LOOK AT, AT MASS 10 PARTICIPATION AND MASS POfNT SPACING AND NOT AT ALL FROM THE 11 DETAILED ASPECT OF THOSE BECAUSE I THINK THOSE ARE FAIRLY WELL 12 COVERED IN THE RECORD, BUT WITH RESPECT TO THE -- WITH RESPECT 13 TO WHAT TYPd OF -- WHAT CYGNA MIGHT EXPECT TO FIND IN THE CLOSE 14 OF THAT ISSUE BY TUGCO WITH RESPECT TO THE LAST COMMENT YOU T ( 15 MADE IN THE LETTER, SAYING THIS IS A REMINDER, ESSENTIALLY, 16 THAT THOSE ISSUES SHOULD BE PART OF THE ANALYSIS OF RECORD. 17 WHAT I WOULD LIKE TO COMMENT ON IS WHETHER YOU EXPECT 18 WHETHER A PARAMETRIC TYPE PROGRAM CAREFULLY THOUGHT OUT WOULD 19 BE SOMETHING THAT WOULD SATISFY THAT NEED OR WHETHER YOU WERE 20 LOOKING TOWARDS A 100 PERCENT VERIFICATION THROUGH ANALYSIS? 21 MS. WILLIAMS: I THINK THERE IS A COUPLE OF ASPECTS 22 TO THE PROBLEM. THE FIRST IS THE FSAR, WHATEVER YOU DO, HAS TO 23 BRING THE ANALYSIS INTO COMPLIANCE WITH THE FSAR OR I THINK YOU 24 WOULD HAVE TO FILE FOR A REVISION TO THE FSAR, WHICH IS TUGCO'S 25 CHOICE. WE'RE NOT TELLING THEM WHICH WAY TO GO WITH THAT. WE 26 ALWAYS HAVE THAT ULTIMATE CRITERIA WHAT'S BEEN DONE DOES NOT 27 COMPLY WITH THE FSAR AND HAVE NOT SEEN ANY INITIATIVE TO CHANGE ) i 28 THE FSAR TO DATE. THAT'S THE ULTIMATE QUESTION. saw sma=c'sco DOIDGE & CARROLL ***3"' co= van costa CERTIFIED SHORTHAND REPORTERS CouN'T i4 U [ asse DEPOSITION NOTARIES ~_ _

.~ 43 1 MR. LEVIN: NANCY, ON THAT STATEMENT, WHEN YOU SAY m -i 2 WHAT'S BEEN DONE TO DATE, YOU MEAN, IN THE ORIGINAL DESIGN 3 BASIS ANALYSIS OR THE RECENT WORK BY GIBBS S HILL? 4 MS. WILLIAMS: THE RECENT WORK BY GIBBS S HILL. 5 MR. LEVIN: DOES THAT REFER ALSO TO -- MY 6 UNDERSTANDING OF THEIR WORK OF APPROXIMATELY 270 LARGE BORE 7 PIPING PROBLEMS IN THEIR SCOPE THEY REANALYZED IN THE AREA 0F 8 200. DO YOU TALK TO THE PROBLEMS OF THAT OR REMAINDER? 9 MS. WILLIAMS: I THINK IT WAS 207 0F THE STRESS 10 PROBLEMS THEY DID THAT BROUGHT THEM UP TO THE POINT OF HAVING 11 ANALYZED ALL SYSTEMS UP TO 40 PERCENT PARTICIPATION. WHAT THAT 12 MEANS I S, A THIRD OF THE SYSTEMS OUT THERE HAVE PARTICIPATION 13 FACTORS BETWEEN'40 AND 100 PERCENT AND THE FSAR REQUIRES 14 SOMETHING ON THE ORDER OF 90 PERCENT. T i 15 MR. LEVIN: WHAT I AM GETTING AT, YOU ARE FAIRLY WELL 16 SATISFIED THE WAY IT WAS ADDRESSED FOR THE 200, YOU ARE SAYING 17 GIVEN THAT THE REMAINING PROBLEMS HAVE MASS PARTICIPATION, IT'S 18 STILL RELATIVELY LOW, I TAKE I T, THAT THE -- THEY NEED TO GO 19 FURTHER? 20 MS. WILLIAMS: THAT'S CORRECT. AND WE DID NOT HAVE 21 ANY PROBLEM WITH THEIR USE OF VERSION D OF ADL PIPE. THE 22 MANNER THEY DID IT IS VERY STRAIGHTFORWARD. OUR PROBLEM IN 23 TERMS OF REANALYSIS GOES, TO A LARGE EXTENT, TO THE PIPE 24 SUPPORTS THEMSELVES AND THE WORK THAT WAS DONE TO ASSESS THE 25 EFFECT OF THE REVISED LOADS ON PIPE SUPPORTS. 26 AND THEN THERE WERE SOME ASPECTS OF PIPING ANALYSIS 27 WHICH, IF YOU WERE TO MAKE IT THE ANALYSIS OF RECORD, WHICH IS 3 28 OUR RECOMMENDATION, YOU WOULD HAVE TO GO BACK AND CHECK, FOR 5,y ",'j c,',5,c o DOIDGE & CARROLL cos,,,e,,,, CERTIFIED SHORTH AND REPORTERS cossn oawa%o edisi ess ases DEPOSITION NOTARIES 532'8

44 1 EXAMPLE, THE NOZZLE LOADS, AND DO A COMPLETE REVIEW THAT YOU 2 WOULD 00 TO MAKE THIS AN ANALYSIS OF RECORD, AND MAKE SURE THAT 3 WHEN THE ANALYSIS IS DONE, THAT YOU HAVE ACCOUNTED FOR ALL THE 4 FINDINGS IN THE PIPE STRESS AREA. AND YOU WILL HAVE ONE GOOD 5 COMPLETE PACKAGE ONCE THAT'S DONE. 6 MR. STUART: I THINK THE FUNDAMENTAL ISSUE THERE IS 7 THE MAGNITUDE OF THE MASS THAT WAS INCLUDED IN THOSE ANALYSES. 8 MR. LEVIN: I THINK WE CAN ALL AGREE THERE IS A POINT 9 AT WHICH THE MASS FRACTION INCLUDED AS EMPIRICALLY APPROACHES A 10 VALUE WHERE WE HAVE CAPTURED -- I THINK WE HAVE THE FSAR 11 COMMITMENT WHERE WE HAVE CAPTURED 90 PERCENT OF THE RESPONSE. 12 I TAKE IT FROM YOUR COMMENTS THAT YOU DON'T BELIEVE 13 THAT AS FAR'AS THE PROJECT HAS GONE -- IN OTHER WORDS, THE MASS 14 FRACTION THAT INCLUDED AT THE CUTOFF OF THEIR 200 PROBLEMS IS 15 HIGH ENOUGH TO HAVE MET THAT COMMITMENT? 16 MS. WILLIAMS: THAT'S CORRECT. 17 MR. WITT: JUST A MINOR POINT ON SOMETHING YOU SAID, 18 NANCY, YOU SAID THAT THE FSAR COMMITMENT IS TO RUN THE ANALYSIS 19 UP TO THE POINT WHERE THEY CONSIDERED 90 PERCENT MASS 20 PARTICIPATION. ACTUALLY, THE COMMITMENT IS THE SAME. 21 MS. WILLIAMS: AS THE STANDARD REVIEW PLAN. 22 MR. WITT: THAT MAY OR MAY NOT CORRESPOND DIRECTLY TO 23 THE POINT. 24 MS. WILLIAMS: I USED THAT AS A GUIDELINE. I THINK 25 THE WORDS ARE MORE YOU ARE INSURE THE ADDITIONAL MODES WON'T 26 DISTRIBUTE MORE THAN 10 PERCENT ADDITIONAL RESPONSE TO THE 27 SYSTEM. ) I 28 MR. LEVIN: YOU JUST DON'T KNOW OR SIMPLY A FAILURE sa~ ena~cesco DOIDGE & CARROLL cos,.. cost. 5'5'3 88'0 CERTiriED SHORTHAND REPORTERS c ouN'y Ia3ee DEPOSITION NOTARIES ''#^

) 45 1 TO MEET A COMMITMENT, OKAY? BECAUSE I BELIEVE THAT THE 2 PROJECT'S POSITION, AS I UNDERSTOOD I T, WAS THAT WE STARTED OFF 3 WITH THOSE PIPING PROBLEMS HAVING LOWER MASS FRACTION MARCHING 4 TO HIGHER FRACTIONS, AND TO DO CERTAIN CONCLUSIONS IN TERMS OF 5 IMPACT ON HARDWARE, AND GOT TO A POINT WHERE THEY ARE ABLE TO 6 DEAL WITH IT. 7 AND THE ASSUMPTION BEING, IF WE GO TO HIGHER FASS 8 FRACTIONS, THE SITUATION CAN ONLY GET BETTER FROM A HARDWARE 9 POINT OF VIEW. SO THAT'S WHY I'M CURIOUS AS TO WHETHER OR 10 NOT -- YOUR CONCERN IS SIMPLY THERE IS A NEED TO DEAL WITH THE 11 COMMITME'NT THING OR YOU BELIEVE IT IS A PHYSICAL PROBLEM. 12 MS. WILLIAMS: THERE IS A NEED TO DEAL WITH THE 13 COMMITMENT,'BUT TO ANSWER WHAT APPEARS TO BE, WHAT DO YOU THINK 14 THE IMPACT OF IT REALLY I S, CYGNA. WE DON'T THINK THERE IS 3 15 GOING TO BE MUCH OF AN IMPACT ON THE PIPE STRESS AREA AND THE 16 RESULTS TO DATE HAVE BORNE THAT OUT. 17 OUR DIFFICULTY RISES IN THE SUPPORT MARGIN AREA, AND 18 WITH OUR KNOWLEDGE OF THE SUPPORT DESIGNS FROM NOW, FOUR PHASES 19 0F REVIEW AND THE TYPES OF MARGINS THAT WE HAVE SEEN, AND THE 20 WELL DESIGNED VARIOUS ASPECTS OF WHAT YOU MIGHT FOCUS AS BEING 21 THE WEAK LINK PART OF THE SUPPORT DESIGN THAT YOU MIGHT WANT TO 22 CHECK IN ORDER TO ASSESS ADEQUACY, THAT WE COULD NOT ASSURE 23 OURSELVES, AND FJUND EXAMPLES WHERE ALL THE INFORMATION WASN'T 24 EVEN AVAILABLE ON SITE TO MAKE THE ASSESSMENT ON, SAY, A GANG 25 HANGER, OR SOMETHING LIKE THIS. 26 AND THE MARGIN THERE WAS AT ONE POINT IN TIME, TO BE 27 A CRITERIA DEVELOPED WHICH WOULD IN SOME WAY CORRELATE, PERHAPS, ) 28 OR TRY TO IDENTIFY A TREND WHERE YOU COULD JUSTIFY NOT GOING Sg'",'jty,5,C 0 DOIDGE & CARROLL cas,,,go,,, CERTIFIED SHORTHAND REPORTERS CowNS o, %,.,e ' S ' ' 3 0 ' ' ' ' aaise asi 2396 DEPOSITION NOTARIES

4 I 46 1 ANY FURTHER ON THE BASIS OF ADEQUATE DESIGN MARGIN IN THE PIPE 2 SUPPORTS VERSUS THE MASS FRACTIONS. 3 AND THAT CRITERIA NEVER CAME TO BEAR, AT LEAST IN THE 4 DOCUMENTS THAT WE SAW, SO WE'RE REALLY MINUS THE INFORMATION ON 5 THE PIPE SUPPORT DESIGN MARGINS, AND WE COULDN'T ASSURE 6 OURSELVES IN ANY WAY WHEN WE WENT DOWN TO AUDIT THAT WORK ON 7 SITE, THAT THERE WERE SUFFICIENT MARGINS THAT YOU COULD 8 EXTRAPOLATE THE RESULTS IN A MANNER THAT WAS BEING ATTEMPTED. 9 MR. WITT: 50 THAT, ESSENTIALLY, IN AN ATTEMPT TO 10 AUDIT WHAT THEY DID, YOU REACHED AN INDETERMINATE CCNCLUSION, 11 YOU COULDN'T BE SURE THEY DID OR DID NOT, IN FACT, HA\\E THE 12 MARGINS WHICH WOULD HAVE BEEN NECESSARY TO CLOSE THE ISSUE 7 13 MS. WILLIAMS: YES. AND THE PIPE SUPPORTS WOULD BE 14 THE MAJOR ROADBLOCK. ) 15 MR. LEVIN: THIS WHOLE PROBLEM IS VERY MUCH 16 GEOMETRICALLY RELATED. FOR EXAMPLE, STIFFER PORTIONS OF 17 SYSTEMS WHICH MAY OVERALL HAVE EVEN HIGH MASS FRACTIONS COULD 18 BE MORE PRONE TO, YOU KNOW, LOWER MARGINS DUE TO THE FACT -- 19 DID YOU EXPLORE IN ANY WAY WAYS OF IDENTIFYING THAT EVEN IN 20 SYSTEMS OF HIGHER MASS FRACTIONS? 21 MS. WILLIAMS: THE PROBLEM YOU RUN INTO, YOU COULD 22 APPROACH THE PROBLEM IN THAT REGARD AS FAR AS TRYING TO FOCUS 23 ON THOSE AREAS WHERE YOU WOULD GET THE LARGEST INCREASE IN 24 SUPPORT LOADS. HOWEVER, TO CORRELATE THAT WITH SUPPORT MARGINS, 25 YOU DON'T HAVE ANY WAY OF CORRELATING. 26 MR. LEVIN: NOT CORRELATING IT TO MARGINS, BUT TO 27 IDENTIFY, IS THERE A QUICK WAY OF IDENTIFYING THOSE WHICH YOU ) I 28 MIGHT HAVE TO LOOK AT TO DETERMINE THAT MARGIN? sa% ena%cesco DOIDGE & CARROLL "'S'S'3'*** co%rna costa CERTIFIED SHORTMAND REPORTERS co AT' u,$'Y33,e OEPOSITION NOTARIES

47 1 MS. WILLIAMS: IT'S TOUGH. I DON'T KNOW THAT THERE 2 IS AN EASY WAY IN THE PIPE SUPPORT AREAS BECAUSE THERE IS NO 3 CHARACTERISTICS OF THE SUPPORTS. YOU COULD SAY, ALL RIGHT, ALL 4 SUPPORTS OF THIS TYPE WOULD TEND TO HAVE LOWER MARGINS IN THEIR 5 ORIGINAL DESIGNS, SAY, ALL RIGHT, I WANT TO MATCH THAT AGAINST 6 THOSE AREAS WHERE I GET THE MAXIMUM LOAD CENTER AND DEVELOP AN 7 ARGUMENT THERE IS NO DESIGN IMPACT IS TOUGH. 8 MR. LEVIN: I GUESS ON YOUR COMMENTS NOT RELATIVE TO 9 THE TYPES OF SUPPORTS, BUT SUPPORTS THAT MAY BE IN STIFFER 10 REGIONS OF THE PIPE, PROB ABLY AXI AL STRENGTH, THAT COULD HAVE 11 BEEN, LET'S SAY, MORE IMPACTED BY THE PREVIOUS CUTOFF THAT THAT 12 COULD BE IDENTIFIED? 13 M$. WILLIAMS: YOU CAN DO THAT FROM THE PIPE STRESS 14 ANALYSIS. THE PROBLEM IS BEING ABLE TO ASSURE YOURSELF YOU T 15 HAVE ADEQUATE MARGINS FOR THE SUPPORTS. THERE IS NO EASY WAY 16 TO COME UP WITH THE WORST CASE ON A SUPPORT DESIGN. 17 MR. WITT: THANK YOU. THE NEXT ISSUE I WANT TO LOOK 18 INTO, THERE IS TWO ASPECTS OF RICHMOND INSERTS WHICH HAVE BEEN 15 LOOKED AT. I WOULD JUST LIKE TO COMMENT ON YOUR PROSPECTIVE 20 WITH RESPECT TO THESE TWO ISSUES. 21 ONE IS THE FACT THAT THE CODES DON'T DEAL WITH 22 BENDING IN BOLTS, AND THE PROJECT HAS PROPOSED AN INTERACTION 23 EQUATION TO DEAL WITH THAT. I WOULD LIKE TO GET YOUR OPINIONS 24 ON THAT, AND IN PARTICULAR, COMMENT TO ANYTHING YOU HAVE 25 REVIEWED WITH RESPECT TO IT. AND THE OTHER IS THE FIXED VERSUS 26 PINNED ASSUMPTION FOR THOSE TYPE CONNECTIONS. 27 MS. WILLIAMS: I THINK IN THOSE AREAS WE'RE MISSING 3 28 SOME INFORMATION, IS OUR PROBLEM, AND WE SENT OUT A REQUEST TO l 5,' * ' ",^ %c,is c DOIDGE & CARROLL co,,,,,,,,, CERTIFIED SHORTH AND REPORTERS c ov%'. o, %,% 3 832'8 satSiastasse DEPOstTION NOTARIES

48 1 GET FURTHER CLARIFICATION AND DEFINITION ON WHAT YOU ARE 2 TALKING ABOUT. AND WE WERE JUST REVIEWING THIS HERE. IT'S IN 3 OUR LETTER DATED JANUARY 31ST, '85, AND WE HAVE NOT RECEIVED A 4 RESPONSE. I'M NOT SURE WE'RE READY TO ANSWER THAT FOR YOU 5 WITHOUT ADDITIONAL INFORMATION. 6 MR. WITT: 50 I GUESS THE STATUS I S, YOU NEED MORE 7 INFORMATION? 8 MS. WILLIAMS: CORRECT. ALSO, WE UNDERSTAND THERE IS 9 AN ADDITION TO THE AFFIDAVIT. WE HAVE NOT RECEIVED THAT. 10 MR. WITT: THE NEXT ASPECT I WANTED TO TALK ABOUT WAS 11 SUPPORT STIFFNESS. I THINK THAT RELATES BACK TO OTHER ISSUES 12 WHICH WOULD REQUIRE REVISING PIPING ANALYSIS. 13 IN PARTICULAR, I THINK IT'S KNOWN THAT THE WAY THAT 14 SUPPORT STIFFNESS HAS BEEN HANDLED THROUGH TIME ON VARIOUS T l 15 PROJECTS HAS VARIED, AND I THINK IT'S A MATTER OF RECORD THAT 16 THE WAY IT WAS ADDRESSED ON THIS PROJECT HAS BEEN QUESTIONED, 17 BECAUSE IN CE"TAIN CIRCUMSTANCES THE LOADS DEFINITELY SHOW 18 CHANGES WHICH ARE SIGNIFICANT AS A RESULT OF MODELING ACTUAL 19 STIFFNESSES. 20 WHAT I WOULD LIKE TO POSSIBLY GET COMMENTARY ON IS IF 21 IT WOULD APPEAR VALID THAT THAT -- THE DIFF ICULTY WITH SUPPORT 22 STIFFNESSES IS PERVASIVE THROUGHOUT OR WHETHER THERE ARE 23 PARTICULAR AREAS THAT MIGHT BE LOCALIZED, AND THAT THE BASIC 24 APPROACH OF USING SOME GENERIC STIFFNESS IS WITHIN SOME 25 CATEGORY, SUPPORTS WOULD MAKE ANY SENSE. HAVE YOU LOOKED AT 26 THAT AT ALL? 27 MS. WILLIAMS: NO. THE REASON WE DIDN'T, WE ) 28 IDENTIFIED THE STIFFNESS ISSUE IN PHASE 2, AND I BELIEVE AT '[,$ ",'yC,',',C o DOIDGE & CARROLL e,y,,,go,,, o CERTIFIED SHOffTH AND REPORTERS coeTv ,, %,%e saisi es osses DEPOSITION NOTARIES

• • '38

- - ~,, -,. -. - - - - -.---,

49 1 THAT TIME ONE OF THE STAFF REVIEWS HAD IDENTIFIED, IT MIGHT m i 2 HAVE BEEN -- ONE OF THOSE, SO WE HAVE PRETTY MUCH DEFERRED 3 ANYTHING WITH THAT ISSUE BETWEEN THE STAFF AND TUGCO RATHER 4 THAN GETTING ANOTHER PARTY INVOLVED. WE IDENTIFIED I T, IT WAS 5 ON OUR CHECKLIST AND STATUSED IT. AS WE'RE NOT LOOKING AT IT, 6 WE IDENTIFIED IT AS PHASE 2 AS A PROBLEL. 7 MR. WITT: WHEN YOU IDENTIFIED IT, WHAT LED TO THE 8 IDENTIFICATION AND CONCERN FOR SIGNIFICANCE? 9 MR. MINICHIELLO: JOHN MINICHIELLO. BASICALLY, THERE 10 WAS A CERTAIN SET OF STIFFNESSES THAT GIBBS & HILL WAS 11 INPUTTING TO THE PIPE STRESS ANALYSIS. AND PART OF OUR 12 CRITERIA WAS THAT THERE WERE PIPE STRESS ANALYSES, CHECK TO 13 MAKE SURE THEY ARE INPUTTING IT, WENT TO THE SUPPORT SIDE AND 14 SAID, ARE YOU GUARANTEEING THAT THE SUPPORTS MEET THE STIFFNESS. T 15 AND WE BASICALLY FOUND, NO, THEY ARE NOT. THEY USED A 16 DIFFERENT CRITERIA, BROUGHT THE QUESTION UP, FOUND THAT THE NRC 17 WAS ALREADY PURSUING IT, SAID FINE. 18 MR. WITT: 50 THAT AT YOUR LEVEL OF REVIEW, IT WAS 19 NOT A DETERMINATION OF TECHNICAL SIGNIFICANCE, BUT IN A SENSE A 20 METHOD OR COMMITMENT WAS NOT BEING SATISFIED? 21 MS. WILLIAMS: WE DIDN'T EXPLORE THE IMPACT, NO. 22 MR. GUIBERT: IS IT SAFE TO ASSUME, THEN, THAT YOU 23 DCN'T INTEND TO ADDRESS THAT FROM A CUMULATIVE EFFECT POINT OF 24 VIEW OR IF YOU DO INTEND TO ADDRESS IT? 25 MS. WILLIAMS: YOU WON'T SEE US ADDRESSING OR MAKING 26 COMMENTARY. WE HAVE NO TOOLS OR WAY TO ASSESS THE IMPACT. YOU 27 WILL SEE IT NOTED AS AN ITEM THAT WE HAVE SEEN, BUT PASSED ON g I 28 TO OTHERS. s Sy

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o 50 1 MR. WITT: HAVE YOU HAD ACCESS TO THE WORK THAT'S 2 BEEN DONE ON THIS AT ALL? 3 MS. WILLIAMS: NO. 4 MR. WITT: THE REASON I'M PURSUING THIS IS THE FACT, 5 FROM WHAT I HAVE SEEN, THERE IS AN OPINION THAT IT CAN'T BE 6 SEPARATED FROM THE OTHER ASPECTS, AND I WONDER AT HOW, WITH 7 THAT ON THE RECORD, YOU CAN REACH A CUMULATIVE SIGNIFICANCE 8 EVALUATION. IF YOUR FINAL REPORT SAYS THIS IS OUR OPINION, BUT 9 IT DOESN'T INCLUDE SOMETHING WHICH IS, AS A MATTER OF RECORD, 10 IS IMPORTANT TO THAT CONCLUSION, I'M NOT SURE HOW WE DEAL WITH 11 THAT. 12 MS. WILLIAMS: WE THINK IT NEEDS TO BE ADDRESSED AND 13 RECONCILED AND ADDRESSED IN ANY KIND OF PROGRAM SUCH AS THE ONE 14 THAT YOU ARE PUTTING TOGETHER. AND THE QUANTIFICATION OF THE l T 15 EFFECTS AND THESE SORTS OF THINGS ARE SOMETHING THAT'S NOT OUR l 16 RESPONSIBILITY. AND WE BASICALLY SAY IT'S AN ISSUE. WE'RE 17 GOING TO ISSUE THE REPORT AND EVERYONE THAT READS THE REPORT IS 18 GOING TO SEE IT WAS AN ISSUE THAT SHOULD BE ADDRESSED IN 1 19 CONJUNCTION WITH EVERYTHING ELSE. AND THEN AS FAR AS THE 20 EXECUTION OF IT, THEY HAVE TO TURN TO TUGCO. 21 MR. WITT: OKAY. SATISFIED. 22 THERE ARE VARIOUS PLACES WHERE THERE ARE STATISTICS l 23 PRESENTED WITH RESPECT TO RESULTS. THE ONE I MENTIONED, THE 24 FIRST WAS THE 226. YOU INDICATED THAT WAS YOUR -- THAT WAS 25 DUST THE SAMPLE YOU HAD CHOSEN IN TERMS OF SYSTEMS YOU WERE 26 LOOKING AT. 27 IN GENERAL, IS THAT THE APPROACH THAT WAS USED OR ARE g I 28 THERE AREAS WHERE YOU STATISTICALLY SAMPLED OR HOW -- IT ISN'T 4

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~ l 51 1 OBVIOUS TO ME IN ALL CASES WHICH METHODS WERE USED. IF I HAD 2 ACCESS TO THE INFORMATION PUT. TOGETHER FOR YOUR FINAL REPORT, 3 WILL THAT BECOME CLEAR? 4 MS. WILLIAMS: IT MIGHT. BUT I CAN GIVE YOU A 5 GUIDELINE. THE ORIGINAL REVIEW SCOPE BASED ON SELECTED SYSTEMS 6 THAT EVERYONE AGREES EXHIBITS THE CHARACTERISTICS AND 7 PARAMETERS THAT WE'RE RUNNING A CHECK ON. 8 BEYOND THAT, ONCE WE FIND SOMETHING THAT IS OCCURRING 9 IN MAYBE A COUPLE OF PIPE SUPPORTS AND MADE THE DETERMINATION 10 AS TO WHETHER YOU,HAVE TO GO AND SAMPLE ADDITIONAL PIPE 11 SUPPORTS TO ASSESS THE EXTENT AND DESIGN IMPACT OF I T, THEN WE 12 WILL TURN TO A MORE STANDARD STATISTICAL TECHNIQUE SUCH AS MILL 13 STANDARD 105 D IN THE CASE OF, FOR EXAMPLE, THE DOCUMENT 14 CONTROL CENTER WHERE WE FOUND WHAT WE THOUGHT WAS A SIGNIFICANT 3 4 15 NUMBER OF ERRORS BASED ON OUR REVIEW SCOPE. WE THEN SELECTED 16 AN INDIGENOUS SAMPLE USING STATISTICAL TECHNIQUES TO PURSUE IT. 17 YOU WILL SEE THE STANDARD STATISTICS BEING APPLIED FOR 18 FOLLOW-UP WORK OUTSIDE THE ORIGINAL REVIEW SCOPE TO DETERMINE 19 EXTENT. 20 MR. WITT: OKAY. CNE OF THE ISSUES WHICH WAS RAISED 21 WAS PI-00-07 WITH AN ATTACHMENT OF A SNUBBER TO A VALVE 22 ACTUATOR. 23 COULD YOU DESCRIBE TO WHAT EXTENT THAT REVIEW WAS 24 PERFORMED? WAS THAT SIMILAR TO THE SITUATION, WAS THE SUPPORT 25 STIFFNESS JUST A DETERMINATION THAT THE CRITERIA HADN'T BEEN 26 SATISFIED AT THE FIRST LEVEL OR DID YOU LOOK AT THE TECHNICAL 27 SIGNIFICANCE OF THE ATTACHMENT? 3 28 MS. WILLIAMS: WE -- I GUESS YOU ASKED TWO QUESTIONS. "$s'"g4* 'enf D010GE & CARROLL e cos,..co,,, CERTIFIED SHORTHAND REPORTERS cows" oa%a%o 'diu osa-v i ts setD6asi aate DEPOSITION NOTARIES

O 52 1 ONE, EXTENT, WHAT DID WE PURSUE. 2 MR. WITT: I BASICALLY WANT TO FIND OUT WHETHER OR 3 NOT YOU LOOKED AT -- WHETHER THE ATTACHMENT WAS SOME REAL 4 ENGINEERING OR PHYSICAL PROBLEM OR WHETHER OR NOT YOU JUST 5 DETERMINED THAT THEY HADN'T HANDLED AN INTERFACE CORRECTLY? 6 MS. WILLIAMS: OKAY.. WE DID NOT LOOK AT THE VALVE 7 SEISMIC QUALIFICATION. WE WERE LOOKING AT IT BECAUSE WE WERE 8 DOING A PIPE STRESS REVIEW. WE LOOKED AT IT FROM AN INTERFACE 9 STANDPOINT AND PURSUED IT FOR OTHER LIKE VALVES TO MAKE SURE IT 10 WASN'T A PERVASIVE PROBLEM OUTSIDE OF THE REVIEW SCOPE. 11 MR. WITT: FURSUED IT FROM THE STANDPOINT OF 12 INTERFACES? 13 MS. WILLIAMS: THAT ALL OF THE FOLLOW-UP WAS 00NE IN 14 CONJUNCTION WITH THE MANUFACTURER, CORRECT, DID NOT VIEW THE 15 SCOPE TO REVIEW THE SEISMIC QUALIFICATION. 16 MR. WITT: DON LANDERS, A COUPLE OF WEEKS AGO, AND IN 17 HIS PRELIMINARY REPORT, INDICATED THAT HE DIDN'T FEEL THAT -- I i 18 HAVE GOT TO PARAPHRASE THIS CORRECTLY. HIS MAJOR CONCERN WAS 19 NOT SEISMIC ON THIS PLANT WITH RESPECT TO PIPING, BUT THAT HE 20 HAD A -- IF THERE WERE A CONCERN, HE FELT IT WOULD OCCUR IN THE 21 AREA 0F STEAM HAMMER AND WATER HAMMER LOADS. 22 THERE WAS AT LEAST ONE PLACE WHERE I NOTED THAT YOU 23 HAD IDENTIFIED AN ISSUE OR OBSERVATIONS SO ASSOCIATED WITH THE 24 HANDLING OF STEAM HAMMER. WHAT I WOULD LIKE TO DO IS GET A 25 KIND OF

SUMMARY

OF WHAT YOUR BASIC REVIEW WAS OF THAT ENTIRE 26 AREA, NOT FOR THAT SPECIFIC ISSUE. 27 MS. WILLIAMS: WE DID REVIEW THE RELAP AND ANSYS 3 28 ANALYSIS FOR MAIN STEAM LINES FOR STEAM HAMMER, JUST AS WE DID y",'.]cisc DOIDGE & CARROLL cos,..cas,. CERTiptED SHORTHAND REPORTERS C os%t

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o s ) 53 1 REVIEW THE STRESS ANALYSIS. AND WE CHECKED TO MAKE SURE THAT 2 THOSE LOADS WERE, PROPERLY CONSIDERED IN THE DESIGN OF THIS ON 3 THE MAIN STEAM SYSTEM ONLY. I THINK THAT OUR OBSERVATION ON 4 STEAM HAMMER WAS ON TRACEABILITY, BUT MAYBE NOT. LET ME SEE IF 5 I CAN FIND IT. DO YOU HAVE AN OBSERVATION NUMBER? 6 MR. WITT: NO, I DON'T, I APOLOGIZE FOR THAT. I'M 7 NOT REALLY SO CONCERNED ABOUT THAT ONE OBSERVATION. I JUST 8 WANT TO FIND OUT IF YOU HAD ACTUALLY GONE INTO THE FLUID 9 MECHANICS ANALYSIS, HYDRAULIC ANALYSIS OF THE RELAP OR WHETHER 10 YOU JUST LOOKED AT THE LOADS AND THE DYNAMIC MODELING AT THAT 11 POINT FROM YOUR SAYING YOU ACTUALLY WENT IN AND VERIFIED THE 12 ANALYSIS ITSELF. 13 MR. BdORKMAN: LEE WEINGART. 14 MR. WEINGART: WE TREATED THE RELAP ANALYSIS SIMILAR 3 15 TO THE SEISMIC RESPONSE VECTOR, WHERL WE ASSUMED THAT WAS A 16 GIVEN. WE DID CHECK WAS THE INPUT FROM THE RELAP, THE PROPER 17 INPUT WENT TO THE PROPER STEAM HAMMER ANALYSIS, BUT THAT WAS 18 THE EXTENT OF CHECKING THE RELAP. 19 MR. WITT: 50, THEN, I WAS WRONG IN THE WAY I l 20 INTERPRETED IT. THE THERMAL HYDRAULIC ANALYSIS WAS NOT l 21 REVI EWED IN TERMS OF STARTING IT AND TAKING IT THROUGH THE 22 RELAP ANALYSIS AND VERIFYING THE VALIDITY OF THE OUTPUT OF THAT l 23 ANALYSIS, IT WAS JUST THAT THE ANALYSIS, ONCE YOU HAD THE 24 RESULTS, TIME HISTORIES, I PRESUME THAT THOSE WERE PROPERLY 25 INPUT INTO A DYNAMIC ANALYSIS. DID YOU CHECK THROUGH THE 26 DYNAMIC ANALYSIS? 27 MR. WEINGART: ABSOLUTELY. ) 28 MR. WITT: THIS IS MAYBE MORE DETAILED THAN I WOULD S a y a']C,',S,c o DOIDGE & CARROLL cos,,,cas,, CERTIFIED SHORTH AND REPORTERS covN" oanaND saisiestasse DEPOSITION NOTARIES '38'S

} e 54 1 LIKE TO GET INTO IN MOST ISSUES, BUT I'M SERIOUS AS TO WHETHER s -j 2 THEY HAD ONE BOUNDING ANALYSIS OR WHETHER YOU -- WHETHER THERE 3 WERE SEVERAL LOAD CASES THAT YOU LOOKED AT, SEVERAL EVENTS? 4 MR. WEINGART: FOR THE STEAM HAMMER ANALYSIS? 5 MR. WITT: YES. 6 MR. WEINGART: THERE WAS A SINGLE STEAM HAMMER 7 ANALYSIS FOR EACH LINE. 8 MR. WITT: AND DO YOU RECALL WHAT THE EVENT WAS THAT 9 IT WAS BASED ON, WHAT ABNORMAL TRANSIENTS OR WHAT ACCIDENT 10 CONDITION? 11 MR. WEINGART: NO, WE TOOK -- AS I SAID, THE RELAP 12 ANALYSIS AS A GIVEN SIMILAR TO LOOK AT WHAT WAS THE INPUT TO 13 THE SEISMIC ~ RESPONSE VECTOR, TOOK THE OB SPECTER AND SEC 14 SPECTER MAKING SURE THEY USE THE RIGHT SPECTER. T ( 15 MS. WILLIAMS: ART TARTER WAS TO LOOK AT THE PIPE 16 STRESS ANALYSIS. EVERYTHING THAT GOES INTO THAT IS A GIVEN 17 WHERE YOU WOULDN'T PURSUE THE BUILDING ANALYSIS TO MAKE SURE 18 THE SPECTER WAS CORRECT. WE ALSO DON'T DO THE SAME THING. 19 MR. WITT: THE REASON I RAISED IT, IT WAS 20 EMPHATICALLY POINTED OUT THAT THAT WAS -- IF THERE WERE AN AREA 21 WHERE WE HAD A TRULY TECHNICALLY SIGNIFICANT ISSUE WITH RESPECT 22 TO PIPING, THAT IT WOULD LIKELY BE IN THAT AREA. SO IT'S ONE 23 THAT WE'RE CONSIDERING LOOKING AT. 24 MR. DOUGHERTY: LET ME ASK, WHO DID THE RELAP 25 ANALYSIS? 26 MR. WEINGART: GIBBS & HILL. 27 MR. WITT: DO YOU REMEMBER WHAT VERSION? ) 28 MR. WEINGART: NO, I DON'T. Sy,'",*,*,Cy,5,c D01DGE & CARROLL c eoy,,,eo,,, CERTIFIED SHORTHAND REPC r as cousiv oanamo isiosasiis idise ass.sses DEPOSITION NOTARIES

I 3 55 1 MS. WILLIAMS: I THINK IT MIGHT BE IN THE -d 2 OBSERVATIONS. 3 MR. WEINGART: NOTED IN THE QA BINDERS. 4 MS. WILLIAMS: YOU MIGHT LOOK IN THERE. 5 MR. WITT: THIS IS PROGRAMMATIC. IF WE WANTED TO GET 6 ADDITIONAL INFORMATION OF THAT LEVEL OF DETAIL, IS THERE SOME 7 CONVENIENT DOCUMENTATION LIKE YOUR CHECKLIST, FOR EXAMPLE? ARE b THOSE THINGS WE CAN WITH SOME EASE, FIGURE OUT WHAT WAS DONE? 9 MS. WILLIAMS: CERTAINLY. YOU MIGHT WANT US TO HELP 10 YOU WALK THROUGH A COUPLE OF CASES SO YOU ARE NOT SPENDING A 11 LOT OF TIME LOOKING AT DOCUMENTATION. MOST OF THE GREAT DEAL 12 OF REFERENCES THAT ARE ON THOSE CHECKLISTS WE HAVE IN-HOUSE SO 13 WE CAN ANSW$R IMMEDIATE QUESTIONS ON THOSE. AND THEN IN SOME 14 CASES WE WOULD HAVE TO GO TO GIBBS & HILL TO GET SOME REVIEW 3 15 DOCUMENTS DEPENDING ON WHAT YOU WANT TO SEE. 1 16 MR. WITT: OKAY. THANKS. 17 MR. GUIBERT: WHILE DOUG IS THINKING OF HIS NEXT 18 QUESTION, HE ASKED A COUPLE OF QUESTIONS REGARDING STATISTICS. 19 ONE OF THE THINGS WE HAVE DONE IN THE CPRT IS TRY TO BE CAREFUL 20 WHERE WE DEVELOPED SAMPLES BASED ON RANDOM TECHNIQUES OR 21 ENGINEERING TECHNIQUES. WILL IT BE SELF-EVIDENT IN YOUR 22 REPORTS AS TO WHERE YOU HAVE USED BIASED TECHNIQUES AND 23 RATIONALE FOR IT, IF YOU HAVE USED ANY? 24 MS. WILLIAMS: NOT IN THE REPORT. THAT IS SOMETHING 25 THAT WE KEEP INTERNALLY, BUT IT'S SOMETHING WE CAN EXPLAIN OR 26 ANSWER ANY QUESTIONS ON THE PARTICULAR EXAMPLE FOR YOU. 27 MR. GUIBERT: THEN I GATHER YOU HAVE USED SOME BIASED ) I 28 TECHNIQUES? Sy,'",'j C,',5,C,0 DOIDGE & CARROLL c oy,, c o,,, CERTIFIED SHORTHAND REPORTERS co e o,%o saisiasi.33e* DEPOSITION NOTARIES "'5'538'S

56 1 MS. WILLIAMS: MOST OF THE EXAMPLES THAT WE HAVE HAD 2 TO USE THOSE TECHNIQUES HAVE BEEN RANDOM SAMPLES OF A GIVEN 3 ATTRIBUTE OR GIVEN CHARACTERISTIC OR NOT A SKEWED SAMPLE IN A 4 PARTICULAR. DIRECTION, BUT RATHER, ALL OF ONE TYPE THAT WE'RE 5 TRYING TO EXPLORE A PROBLEM WITH AND DO A RANDOM SAMPLE, 50 6 IT'S A MORE A MATTER OF DEFINING THE POPULATION THAT WE SAMPLE 7 FROM THEN USING TECHNIQUES ON THAT OPERATION. 8 MR. BUSH: SPENCE BUSH. I DON'T KNOW IF YOU WOULD BE 9 CONCERNED OR NOT. CERTAINLY THE ISSUE RAISED ON THE WATER 10 STEAM HANDLER SPECIFIC CASE, PARTICULARLY WITH THE SNUBBERS, IS. 11 I DON'T KNOW WHETHER THIS WILL COME UP AT THE OL HEARINGS OR 12 NOT, BUT THE TRACK RECORD HAS BEEN VERY BAD, PARTICULARLY OVER 13 THE LAST 12'TO 18 MONTHS, A DOD DOCUMENT ON THIS, ALSO ARE TWO 14 INE INFORMATION LETTERS ON THIS ITEM, WHERE SUCH AN EVENT IS ) g 15 ESSENTIALLY WIPED OUT ALL OF THE SNUBBERS, THE MECHANICAL 16 SNUBBERS IN THE SYSTEM, AND WIPED THEM OUT IN THE CONTEXT THAT 17 THEY LOCK UP. 50 YOU NOW HAVE THE WORST POSSIBLE CONDITION. 18 AND I THINK THAT WOULD BE A VERY EMBARRASSING QUESTION IF 19 SOMEBODY RAISED IT. SOMEHOW IT WOULD HAVE TO BE CONSIDERED. 20 MR. WITT: I THINK YOU JUST DID RAISE IT. 21 MR. BUSH: ALL I'M SAYING IS, IT'S BETTER TO RAISE IT 22 NOW THEN HAVE SOMEBODY RAISE IT LATER IT. COULD WELL HAVE BEEN 23 RAISED EARLIER. IT'S A VERY REAL ISSUE. IT'S HAPPENED IN AT 24 LEAST THREE OPERATING PLANTS IN THE LAST 18 MONTHS. j 25 MR. WITT: I THINK WE'RE ALL INTERESTED IN LOOKING AT l 26 THE REAL ISSUES AND WE HAVE TO MEET COMMITMENTS, I THINK OUR I 27 FIRST PRIORITY. ) l 1 28 MR. BUSH: I ALSO RECOGNIZE THAT THIS QUESTION IS

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) 57 1 RAISED. WE HAVE TO GO BACK AND RESEARCH IT. YOU DO NOT MEET w -( 2 YOUR COMMITMENTS. 3 MR. WITT: NANCY, MAYBE WE'RE AT A POINT WHERE WE CAN 4 GIVE OUR REPORTER A BREAK AS WELL AS EVERYBODY ELSE AND MAYBE 5 RECONVENE IN 10 OR 15 MINUTES. 6 (RECESS.) 7 MR. LEVIN: CAN WE GET STARTED NOW? I BELIEVE MOST 8 PEOPLE HAVE RETURNED. THE TERMS OF LOGISTICS FOR THE REMAINDER 9 OF THE MEETING. I THINK THERE IS A CONSENSUS THAT WE WILL 10 CONTINUE UP UNTIL A LATE LUNCH. I BELIEVE THAT WILL PROBABLY 11 BE SOMETIME BETWEEN THE ORDER OF 1:00, 2:00 0' CLOCK. I'M NOT i 12 CERTAIN. IF THAT'S ACCEPTABLE TO EVERYBODY ELSE. 13 MR. BUHL: THAT'S A NORMAL DINNER. 14 MR. LEVIN: WITH THAT, WE WILL CONTINUE IN THE PIPING T g 15 AREA. I 16 MR. WITT: THE NEXT THING I WANT TO LOOK AT WERE TWO l l 17 THINGS, COMBINED CONCEPT OF SUPPORT MASS MODELING IN THE PIPING 18 ANALYSIS AND SELF-WEIGHT EXCITATION OF THE PIPE SUPPORT ITSELF. ( 19 MY QUESTION THERE IS VERY GENERAL. 20 IN LOOKING AT THIS AS AN ISSUE, ARE THERE SOME -- IS 21 THIS AN ISSUE IS THIS VIEWED TO BE AN ISSUE WITH RESPECT TO 22 SPECIFIC CONFIGURATIONS OR SOMETHING THAT NEEDS TO BE CONFIRMED 23 FOR EACH AND EVERY SUPPORT IN THE SYSTEM? ARE THERE -- DO YOU 24 SEE A NEED -- LET US -- ARE THERE STANDARD CONFIGURATIONS YOU 25 CAN JUST SAY THIS IS COMMON PRACTICE TELLS US THIS IS NOT AN 26 ISSUE AND OTHERd THAT NEED TO BE SINGLED OUT OR IS THIS 3 27 SOMETHING THAT NEEDS TO BE REVIEWED ACROSS THE BOARD. i 28 MS. WILLIAMS: IN THE CASE OF SELF-WEIGHT EXCITATION, l saw *aawc'sco DOIDGE 8 CARROLL ****3'** co%,.. cas,. CERTIFIED SHORTHAND REPORTERS couNYv i i4 : asse DEPOSITION NOTARIES 44:s'saa i e is

58 1 THAT IS SOMETHING WE IDENTIFIED IN PHASE 2, AND IT, LIKE THE s ~ -l 2 STIFFNESS, WAS DEFERRED TO RESOLUTION BETWEEN THE STAFF AND 3 TUGCO. WE HAVE NOT BEEN INVOLVED IN ANY OF THE -- IN ANY GREAT 4 DETAIL IN THE STUDIES THAT TRANSPIRED, IF THERE WERE ANY. 5 THERE WAS A STUDY DONE SOME TIME TWO YEARS AGO OR 6 SOMETHING LIKE THAT, THAT WE READ THROUGH, BUT THAT'S IT. SO 7 WE ARE NOT REVIEWING THE RESOLUTION OF THAT ISSUE AT THIS POINT 8 IN TIME. 9 WITH REGARDS TO THE SUPPORT MASS AND STRESS ANALYSIS, 10 THAT IS SOMETHING THAT WE LEFT HEARINGS WITH THE UNDERSTANDING 11 THAT IT NEEDED TO BE EVALUATED. WE THINK YOU COULD SET UP 12 CRITERI A FOR EVALUATING IT. TO DO A PARAMETRIC STUDY ON IT 13 WOULD BE DIFFICULT. IN THIS PARTICULAR CASE, WE WERE TOLD NOT 14 TO DO I T, 50 WE HAVE LEFT IT. YOU WILL SEE IT ON OUR LIST HERE, ) 15 BUT WE WERE TOLD NOT TO PURSUE IT. 16 MR. WITT: AND I TAKE IT THAT ITS IDENTIFICATION WAS l 17 SIMILAR WHERE YOU DIDN'T DEVELOP INTO THE SIGNIFICANCE WHICH IS 18 WHAT YOU IDENTIFIED SOME SPECIFIC CASES WHERE YOU THOUGHT IT l 19 WAS NOT TREATED CORRECTLY, AND THAT WAS THE BASIS FOR 20 IDENTIFYING THE ISSUE? 21 MS. WILLIAMS: THAT'S CORRECT. YOU COVERED ALL THREE 22 ISSUES, ACTUALLY, WHERE THIS HAS HAPPENED, THE STIFFNESS, 23 SELF-WEIGHT EXCITATION, AND SUPPORT MASS STRESS ANALYSIS. I 24 THINK OFF THE TOP, THOSE ARE THE ONLY THREE YOU TALKED ABOUT 25 IDENTIFIED, BUT NOT PURSUED. 26 MR. WITT: I GUESS THE NEXT ISSUE IS THE U-BOLT 27 CINCHING ISSUE. AND THERE, AGAIN, I WOULD LIKE TO GET GENERAL ) ^ 28 COMMENTARY, BUT I WOULD LIKE THAT MAYBE TO BE SEGMENTED ALONG l i ',7,7 ","jC,',5,#,0 DOIDGE & CARROLL e o%,. e o,,. o.%.go CERTIFIED SHORTHAND REPORTERS cov%" emiss asi ases DEPOSITION NOTARIES '8#' l

i I 59 1 THE LINES OF THESE U-BOLTS ARE USED FOR VARIOUS PURPOSES. ONE w -i 2 IS THE PRIMARY LOAD PATH INTENDED. AND THERE ARE VARIOUS OTHER 3 LEVELS OF USE RANGING ANYTHING FROM JUST ASSURING THAT THE 4 POSITION DOESN'T CHANGE WITH RESPECT TO ALONG THE ACCESS TO THE 5 PIPE TO PROVIDING ROTATIONAL OR TORSIONAL RESTRAINT TO VALIDATE 6 THE STABILITY OF THE SUPPORT. 7 WITHOUT REVISITING THE SUPPORT STABILITY ISSUE, I 8 WOULD LIKE TO GET SOME COMMENTARY ON WHAT YOU HAVE LOOKED AT 9 AND WHETHER OR NOT YOU SEE THAT THERE IS A PATH HERE THAT MAY 10 LEAD TO A RESOLUTION OR NOT. 11 MS. WILLIAMS: FROM AT LEAST OUR REVIEW SCOPE, A 12 LARGE PORTION OF UNSTABLE SUPPORTS ARE AFFECTED IN THE 13 ACCEPTABILITY OF U-BOLT TESTING AND ANALYSIS PROGRAM. IF THAT 14 PROGRAM IS DEEMED ACCEPTABLE, THEN THAT WILL TAKE CARE OF A 15 GREAT NUMBER OF SUPPORTS. 16 NOW, WE HAVE BEEN SINCE, I THINK SEPTEMBER OF '84 OR 17 THEREABOUTS, LOOKING AT THE WESTINGHOUSE REPORTS AND THE 18 AFFIDAVITS. WE HAVE HAD SEVERAL MEETINGS AND TRYING TO TRACE 19 OUR WAY THROUGH THE ANALYSIS AND TESTING PROGRAM TO ASSURE 20 OURSELVES THAT WE AGREE WITH THE RESULTS AND CONCLUSIONS. 21 AS OF TODAY, THERE IS A DRAFT LETTER ON MY DESK WHICH 22 IS VERY LENGTHY, AND IT CONTAINS A LOT OF QUESTIONS AND A LOT 23 0F DIFFICULTY WE'RE HAVING CDMING UP WITH THE SAME NUMBERS, AND 24 WE NEED TO EITHER HAVE A MEETING TO GO THROUGH THESE THINGS 25 AGAIN OR WAIT A RESPONSE FOR THIS LETTER AND FOR PREVIOUS 26 LETTERS WHICH WE HAVE SENT. 27 SO WE ARE REALLY -- IT DOESN'T APPEAR VERY CLOSE AT ) I 28 THIS POINT IN TIME TO BEING ABLE TO OFFER AN OPINION ON THE

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60 1 ACCEPTABILITY OF THAT PROGRAM UNLESS WE CET SOME ANSWERS THAT m 2 ARE GOING TO HELP US THROUGH THE REPORTS, AND THEN WE'LL BE 3 READY TO DRAW OUR CONCLUSION. 4 MR. LEVIN: THIS INFORMATION YOU ARE SEEKING, NANCY, 5 CAN YOU CATEGORIZE IT? JUST CLARIFICATION YOU NEED IN 6 UNDERSTANDING THE WORK THAT WAS DONE OR IF THERE ARE PARTICULAR 7 ' ISSUES, I THINK WE WOULD LIKE TO HEAR A

SUMMARY

OF THAT HERE 8 TODAY. IT'S ACROSS-THE-BOARD. AND, YES, WE CAN GO INTO SOME 9 OF IT. IT MIGHT BE A LITTLE PREMATURE AND LENGTHY AND I WOULD 10 SUGGEST THAT YOU READ A COUPLE OF THE LETTERS THAT WERE 11 REFERENCED HERE FIRST. 12 BUT WE HAVE HAD PROBLEMS WITH TESTING METHODOLOGY 13 CONFIGURATIONS. WE HAVE HAD PROBLEMS WITH THE COMPARISON OF 14 TEST TO ANALYSIS. SOME OF THE ANALYSES, 11 'S PRETTY MUCH 15 ACROSS-THE-BOARD. WE HAVE TRIED TO REPRODUCE SOME OF THE 16 NUMBERS AND WE HAVE HAD DIFFICULTY. I CAN'T THINK OF ANY 17 PARTICULAR ASPECT OF THE PROGRAM AT THIS POINT IN TIME, WE HAVE 18 ALL THE ANSWERS WE NEED. 19 MR. WITT AT THIS POINT, IT'S STILL DUE -- IT'S DOWN 20 TO THE POINT OF REACHING AGREEMENT ON THE SPECIFIC OF THE 21 TESTING AND THE ANALYSIS THAT WAS ASSOCIATED, IT'S NOT A 22 CONCEPTUAL DISAGREEMENT WITH THE CONCEPT OF'THE ISSUE IN 23 GENERAL? 24 MS. WILLIAMS: TO BE HONEST WITH YOU, WE HAVE SO MANY k5 QUESTIONS ON THE TESTING ANALYSIS PROGRAM THAT IT COULD VERY 26 WELL BE THE CONCEPT THAT'S A PROBLEM AS A BOTTOM LINE IF WE 27 . DON'T GET ANSWERS TO THESE. WE CAN'T EVEN HAVE AN INTERNAL ) I 28 FUEL FOR WHETHER THE PROGRAM IS GOING TO BE ACCEPTABLE IN OUR Sy ' ",^,,*(',S,C,0 DOIDGE & C ARROLL m,,,co,,, o,,,,9 CERTIFIED SHORTHAND REPORTERS cow' saisi alt ases DEPOSITION NOTARIES 488'

~ ] 61 1 MIND BECAUSE THERE IS SO MANY QUESTIONS, AND THIS IS PROBABLY s 2 THE ONLY ISSUE THAT WE'RE SO FAR AWAY FROM REACHING RESOLUTION 3 IF WE DON'T -- IF WE'RE UNABLE TO RESOLVE THEM. 4 MR. VAN METER: NANCY, BILL VAN METER REPRESENTING 5 CASE. SINCE YOU STATE THAT THERE MAY BE PROBLEMS WITH THE ITEM s 6 CINCH IN THE U-BOLTS AND THE TEST RESULTS -- 7 MR. REDDING: JACK REDDING WITH TUGCO. THIS MEETING 8 IS BETWEEN CPRT AND CYGNA, YOU ARE WELCOME TO MAKE COMMENTS AT 9 THE END OF THE MEETING, BUT NOT PARTICIPATE DURING THE COURSE. 10 MS. WILLIAMS: I WANT TO MAKE CLEAR BY WHAT I HAVE 11 SAID RIGHT NOW, DON'T TAKE THIS AS A CYGNA OPINION ON THE 12 PROGRAM. RIGHT NOW WE NEED TO HAVE SOME MEANINGFUL DISCUSSION 13 TO GET OUR QUESTIONS ANSWERED AND THEN WE WILL BE POSITIONED 14 SUCH THAT WE CAN GIVE AN OPINION ON THE PROGRAM. DON'T ) 15 CONSTRUE OPEN QUESTIONS TO MEAN NEGATIVE RESPONSE FROM CYGNA. 16 WE'RE JUST NOT THERE YET. 17 MR. WITT: MY QUESTION WAS MORE DIRECTED AS 18 DISCUSSING IT NOW THAN LATER. IT APPEARS WE COULD BENEFIT FROM 19 REVIEWING WHAT'S ON THE RECORD IN DETAIL BEFORE WE GET INTO ANY 20 KIND OF DETAILED DISCUSSION. 21 MS. WILLIAMS: IF YOU CAN REVIEW THE LETTERS HERE AND 22 KNOW THAT I HAVE ONE OTHER LETTER OUT THERE, I'M TALKING RIGHT .23 NOW OF REVIEWING TWO OF OUR LETTERS AND KNOW THAT I HAVE GOT 24 THIS OTHER LETTER THAT WE'RE GOING TO ISSUE ON MONDAY, THAT 25 WILL GIVE YOU THE PREPARATION TO, I THINK, HAVE A MEANINGFUL 26 DISCUSSION ON I T, IF THAT'S ACCEPTABLE TO YOUR SCHEDULE. 27 MR. WITT: ONE OF THE OTHER AREAS I WANT TO LOOK AT, ) 28 I'M GETTING DOWN TOWARDS THE BOTTOM OF THE LIST, WAS THE ISSUE sa% *aa%cesco DOIDGE & CARROLL cos,.. co,,, CERTIFIED SHORTHAND REPORTERS Cov%f t is,sf.Nasee DEPOSITION NOTARIES '8#'"'

62 1 OF DIFFERENCE BETWEEN AWS AND ASME CODE REQUIREMENTS IN THE 7L 2 AREA OF WELDING AND OTHER ISSUES. 3 THERE WERE, AS EkAMPLES, THE ANGULARITY REQUIREMENT 4 AND SKEWED WELDS, PUNISHING SHEAR TYPE CRITERIA THAT EXISTS 5 BETWEEN AWS AND DON'T EXIST WITHIN ASME. AND THAT EXPLICIT 6 FORM, THE BASIC QUESTION, NOT THE DETAILS OF THE TECHNICAL 7 DISCUSSIONS, IS THIS AN ISSUE RAISED BECAUSE OF -- THERE IS 8 ROOM FOR INTERPRETATION AS TO WHAT THE COMMITMENT SHOULD BE ON j 9 THE PART OF THE APPLICANT OR IS IT A TECHNICAL ISSUE THAT YOU 10 FEEL THAT, WHETHER IT'S IN ASME CODE OR NOT, THIS LEVEL SHOULD 11 BE ADDRESSED? 12 MS. WILLIAMS: LET ME ANSWER YOUR QUESTION BY GIVING i 13 YOU A LITTLE BACKGROUND SO YOU KNOW WHERE WE'RE AT ON THIS, 14 WON'T FIRST APPEAR TO BE A DIRECT RESPONSE TO YOUR QUESTION. T 15 OUR EXPOSURE TO ANSWERING QUESTIONS LIKE THE ONE YOU HAVE JUST 16 BROUGHT UP IS ONLY THROUGH EXAMPLE IN OUR REVIEW SCOPE. SO 17 DURING PHASE 3, WHAT WE WOULD DO IS GO THROUGH AND REVIEW ALL 18 THE PIPE SUPPORTS. AND IF WE FOUND EXAMPLES, SAYS PUNCHING 19 SHEAR WAS NOT PROPERLY ACCOUNTED FOR, WE WOULD PURSUE THAT 20 ASPECT, WHICH COULD BE A DIFFERENCE BETWEEN THE CODES AND AN 21 EVALUATION HOW TUGCO PERFORMED THEIR REVIEW OF I T, AND THIS 22 SORT OF THING. 23 WE NEVER TOOK THE ISSUE OF THE DIFFERENCE BETWEEN THE 24 CODES, WHICH WE UNDERSTAND TO BE ONE OF THE HEARING ISSUES, 25 THAT AFFIDAVITS HAVE BEEN WRITTEN ON THIS SORT OF THING, AND 26 WENT THROUGH AN EVALUATION SOLELY FOR THE PURPOSES OF 27 RECONCILING THE DIFFERENCE IN JUDGING HOW TEXAS DID THEIR WORK 3 28 RELATIVE TO THE DIFFERENCE. Sg *,'*c;,S,c o DotDGE & CARROLL cos...ce,,, CERTIFIED SMORTHAND REPORTERS cowNtv oaa6a%o saiseasi asse DEPOSITION NOTARIES H" ,m

63 1 WE HAVE LOOKED AT PUNCHING SHEAR, WE HAVE LOOKED AT 2 SKEWED WELDS, WE HAVE LOOKED AT HOW THEY EVALUATED ON THE 3 COMANCHE PEAK PROJECT, AND WE CAN GIVE YOU ANSWERS ON EACH OF 4 THESE SPECIFIC THINGS, BUT WE CAN'T GIVE YOU MUCH MEANINGFUL 5 DISCUSSION ON THE ALLEGATIONS OF THE DIFFERENCES BETWEEN THE 6 CODES IN GENERAL. 7 MR. WITT: WITH RESPECT TO THESE KIND OF THINGS, THEN, 8 YOU ARE FOCUSING ON THE TECHNICAL ASPECT AS OPPOSED TO A 9 JURISDICTIONAL ASPECT? 10 MS. WILLIAMS: THAT'S CORRECT. AS WE SEE AS EXAMPLES 11 IN OUR SCOPE. 12 MR. WITT: OKAY. THAT'S EXACTLY WHAT I MEANT. I 13 THINK THIS WILL BE THE LAST AREA THAT I WANT TO ASK QUESTIONS 14 IN, AND IT'S SOMEWHAT REDUNDANT WITH SOME OF THE THINGS WE HAVE 15 GONE THROUGH BEFORE, BUT THERE ARE A NUMBER OF AREAS WHERE THE 16 SPECIFIC-MODELING OF SUPPORT BCHAVIOR VERSUS THE DETAILS OF 17 PHYSICAL CONFIGURATION ARE SOMEWHAT AT ODDS. 18 AN EXAMPLE OF THIS, THE QUESTION, HOW MANY LUGS 19 CONTACT ON AN AXI AL SUPPORT, FOR EXAMPLE. I'D LIKE TO GET SOME 20 SENSE IN REALITY. THESE KIND OF DIFFERENCES ALWAYS EXIST WHEN 21 SYSTEMS ARE IDEALIZED. I WOULD LIKE TO GET SOME SENSE OF WHEN 22 IT IS THAT THESE ARE RAISED AS ISSUES AS OPPOSED TO MAKING A 23 PRESUMPTION THAT THE MODELING TECHNIQUE IS ACCEPTABLE. IT'S 24 NOT ALWAYS AN ANALYTICAL JUSTIFICATION, AT LEAST -- THERE ISN'T 25 AN ANALYTICAL JUSTIFICATION FOR EVERY DIFFERENCE THAT EXISTS 26 BETWEEN MODELING AND THE DETAILS OF PHYSICAL CONFIGURATION. 27 WHEN IS IT THAT YOU LOOKED AT WHAT TRIGGERED A CLOSER ) I 28 EXAMINATION INTO SOME OF THESE TYPE OF AREAS?

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) 64 1 MS. WILLIAMS: WE DEVELOPED A CHECKLIST WHICH HAD w 2 ATTRIBUTES WHICH WERE BASED ON PRACTICE. FOR EXAMPLE, ON THE - 1 f 3 LUGS, WE WOULD CHECK THAT FOR OUR UNDERSTANDING OF INDUSTRY 4 PRACTICE IN THAT AREA. 5 NOW, THERE IS A COUPLE OF ISSUES THAT HAVE COME UP 6 THROUGH THE HEARINGS WHERE INDUSTRY PRACTICE IS BEING 7 QUESTIONED, AND WE HAVE GONE THROUGH AND SORTED OUT OUR ISSUES 8 AS TO WHICH ONES WE RELIED ON PRACTICE TO RESOLVE AND THOSE 9 WHERE WE HAVE PURSUED THE BASIS FOR THE PRACTICE OR ACTUALLY 10 DID SOME STUDIES TO JUSTIFY OR NOT JUSTIFY, AS THE CASE MAY BE, 11 THE PRACTICE. AND THOSE ARE ALL AVAILABLE. IN THE DECEMBER 12 MEETING AT THE NRC I SUMMARIZED AND CLASSIFIED THE ALLEGATIONS 13 AND PRACTICES AND JUDGMENTS THAT WE MADE. WAS THAT RESPONSIVE 14 TO YOUR QUESTION? 3 15 MR. WITT: RIGHT ON THE NOSE. THAT'S EXACTLY WHAT I 16 WANTED TO KNOW. THAT PRETTY MUCH ENDS THE ISSUES THAT I WANT 17 TO DISCUSS AT THIS POINT. ANYTHING ELSE? 18 MR. LEVIN: APPARENTLY NOT. I'LL ASK THE SRT IF 19 THERE ARE ANY OTHER QUESTIONS IN THE PIPING AREA. IF NOT, 20 WE'LL MOVE ON TO CABLE TRAYS AND SUPPORTS. I WOULD LIKE TO 21 INTRODUCE CHRIS MORTGAT. HE WILL BE LEADING OUR DISCUSSION 22 TODAY IN THIS AREA. 23 MR. MORTGAT: NANCY, AS I SAID, THERE ARE QUITE A FEW 24 IN THE CABLE AREA. WE FEEL SOME ARE GENERALLY CONSIDERED 25 SAFETY SIGNIFICANT AND OTHERS MAY BE MUCH LESS IMPORTANT. WHAT 26 I WOULD LIKE TO 00 HERE IS MAYBE GET A FEEL FOR WHAT YOUR TRUE 3 27 CONCERN IS, HOW WE MIGHT BE ABLE TO SORT THOSE DIFFERENT ISSUES 28 AND PUT THEM INTO DIFFERENT HOPPERS AS TO WHAT THEIR REAL f,'.'3,','.o DOIDGE 8 CARROLL t * ,. s m,,,,,p, oa ns aa.o CERilFIED SHORTHAND REPORTERS coWe s.eosase. asea DEPO 5ttiON NOTARIES '4 8 8' ess o ne

65 1 IMPLICATION IS. I ALSO WOULD LIKE TO GET SOME KIND OF AN IDEA 2 HOW YOU MADE YOUR ASSESSMENT OF WHAT THE IMPACT OF THOSE ISSUES 3 WERE. 4 I WILL GO THROUGH THEM WITHOUT GOING INTO THE DETAIL 5 OF ALL OF THEM. I'LL JUST PICK UP A FEW OF THEM WHICH I WOULD 6 LIKE TO GET MORE INFORMATION ABOUT. 7 IN THE DESIGN OF THE SUPPORTS, THE DEAD LOAD WAS SRSS 8 SEISMIC LOADS. I WOULD LIKE TO KNOW HOW YOU CAME UP WITH THE 9 ASSESSMENT OF WHAT THE IMPACT WAS, YOU GAVE A NUMBER, WHAT THE 10 IMPLICATION MIGHT HAVE BEEN? 11 MS. WILLIAMS: IN THAT PARTICULAR CASE, I BELIEVE 12 GIBBS & HILL DID DO SOME CALCULATIONS TO QUANTIFY THE IMPACT, 13 BUT I WANT TO MAKE A GENERAL STATEMENT BECAUSE IT MIGHT 14 GUIDE YOUR QUESTIONS A LITTLE BIT. T 15 FOR EACH ONE OF THE CABLE TRAY ISSUES, WHERE WE ARE 16 TODAY IN TIME, WE HAVE NOT GONE THROUGH WITH THIS LIST. WE DID 17 WITH THE PHASE 2 LIST. WE HAVEN'T WITH THE PHASE 4 LIST. WE 18 DID CABLE TRAY REVIEWS IN 2, NOWHERE IN DETAIL AS TO WHAT WE 19 HAVE DONE IN PHASE 4, AND TRIED TO DO THE CUMULATIVE EFFECT 20 ASSESSMENT. 21 IN FACT, WE REALLY CAN'T WITHOUT SOME FURTHER 22 INTERACTION WITH GIBBS & HILL, DISCUSSION OF THE ISSUES, 23 SORTING THEM OUT AS YOU ARE STARTING TO DECIDE HOW TO GO ABOUT 24 DOING IT. WE'RE ABOUT THERE IN TIME, TOO, GOING THROUGH AND 25 CREATING THIS LIST. TODAY WAS PROBABLY THE MOST COHESIVE 26 EXERCISE WE HAVE GONE THROUGH TO DATE TO TRY AND SORT THEM ALL 27 OUT. ) 28 NOW, THAT WE HAVE GOT THEM ALL BEFORE US, WE HAVE TO 'y,'.",*,].%ll,3 DOIDGE & CARROLL cow'ma costa o., CEMilkiED SHOMtHAND REPORTERS C OW ' idio asi.asee DEPOSITION NotAMitS

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I 66 1 DO THE ASSESSMENT OF WHAT'S CRITICAL, WHAT'S NOT, WHAT MIGHT A 2 DYNAMIC ANALYSIS ANSWER, WHAT MIGHT IT NOT ANSWER, WHAT ARE WE 3 LEFT WITH AFTER WE EVALUATE 10 0F THESE EFFECTS. THESE OTHER 4 FOUR EFFECTS, ARE THEY MEANINGFUL, RELATIVE. I'M NOT GOING TO 5 HAVE ALL THE ANSWERS ON THAT FOR YOU TODAY, BUT WE'RE RIGHT 6 THERE IN TIME, AND THE NEXT STEP FOR US IS GOING TO BE, WITH 7 THIS LIST IN MIND, WHICH IS CABLE TRAYS AND DESIGN, ARE THE 8 LEAST COMPLETE LIST IN THE WHOLE PACKAGE. 9 OTHER THAN THAT, IT'S PRETTY SOLID. WE'RE STILL 10 COMPLETING THE DOCUMENTATION ON THE CHECKLIST. WE'RE GOING TO 11 NEW YORK TO LOOK AT THE DYNAMIC ANALYSIS AND HAVING SOME 12 DISCUSSIONS ON WHAT, IF ANYTHING, THAT ANSWERS, AND HOW TO 13 QUANTIFY THs EFFECTS AND WHAT FURTHER WORK IS REQUIRED OF IT. 14 MR. LEVIN: NANCY, IN PARTICULAR WITH REGARD TO 15 CHRIS'S QUESTION, WHICH RELATES TO THE METHODS OF COMBINATION 16 0F SEISMIC RESPONSES, I THINK THIS IS ONE AREA WHERE YOU 17 PROBABLY HAVE GOTTEN TO A POINT WHERE YOU HAVE SOME 18 QUANTIFICATION OF ITS IMPACT TO SUPPORTS IN GENERAL. AND IT'S 19 KIND OF TEMPORARILY ON THE SHELF WAITING FOR AREAS, OTHER AREAS 20 YOU HAVEN'T GOTTEN SO FAR. 21 1 THINK AS WE GO THROUGH THE QUESTIONS, DIFFERENTIATE 22 BETWEEN THOSE, AND ALSO SHARE WITH US YOUR FEELINGS 23 PARTICULARLY IN 1HIS CASE IF YOU ARE ABLE TO WRAP YOUR ARMS 24 AROUND ANL TELL US WHERE YOU THINK IT IS. 25 MS. WILLIAMS: THIS ONE YOU KNOW WE HAVE DONE SOME 26 QUANT IF ICAT ION. WHETHER WE'RE GOING TO RELY ON THAT 27 ) QUANTIFICATION AS A BASIS FOR RESOLUTION OR NOT, I DON'T KNOW 28 YET, BECAUSE THERE ARE -- AND WITH THIS LIST THERE ARE SO MANY 1

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o a ) 67 1 THINGS THAT INTERACT TOGETHER THAT WE HAVE TO THINK ABOUT IT AS m H 2 A WHOLE TO GO ABOUT TO APPROACH THE RESOLUTION. 3 MR. LEVIN: I THINK WHAT YOU ARE SAYING, THESE ISSUES 4 THAT ARE ON THE SHELF, ALL OF THEM IN GENERAL ARE NOT TO BE 5 CONSIDERED ALGEBRAICALLY. 6 MS. WILLIAMS: THAT'S RIGHT, ABSOLUTELY. 7 MR. LEVIN: ONE OF THE THINGS WE MIGHT WANT TO GET 8 INTO IS THE EXTENT SOME OF THE ONGOING ACTIVITY CAN DEAL WITH 9 THAT PROBLEM. 10 MS. WILLIAMS: I CAN TELL YOU WHAT WE'RE DOING, I 11 CAN'T TELL YOU THE ANSWER YET. 12 MR. LEVIN: INTERESTED IN THE ASSESSMENT OF WHAT IS 13 ONGOING ON THE PART OF THE PROJECT. 14 MS. WI'.L I AMS : LET ME TELL YOU WHAT WE HAVE NOT DONE T 15 YET. MAYBE THAT WOULD BE A GOOD WAY TO APPROACH IT. WE HAVE 16 CREATED THIS LIST AND GIVEN YOU SOME REFERENCES AND SUCH. WE 17 HAVE TRIED TO PROVIDE A BRIEF

SUMMARY

, BUT NOWHERE IS NEAR A 18 GOOD ENOUGH AND THOROUGH ENOUGH

SUMMARY

FOR, I THINK, YOU 19 PEOPLE TO UTILIZE IN COMING UP WITH A MASTER PLAN. 20 1 THINK WE NEED TO HAVE A SERIES OF DISCUSSIONS ON 21 CONTENTS OF THIS DOCUMENT. WE HAVE NOT HAD A SET OF 22 DISCUS $10NS TO DEAL WITH THESE TECHNICAL MATTERS IN A COHESIVE ,/ 23 FASHION TO DATE BECAUSE THEY HAVEN'T ALL BEEN ONE PLACE. WE 24 HAVE HAD REVIEWERS, ON-SITE REVIEWERS IN NEW YORK, INTERACTIONS 25 WITH TUGC0 AND GIBBS & MILL TO GIVF SPECIFIC ANSWERS, BUT WE 26 HAVEN'T HAD A DISCUSSION TO PUT TH2 STLFF'IN ONE BIN. ) 27 MR. MORTGAT: INTERNAL DISCUS $10N. 28 MS. WILLIAMS: WE'RE DOING IT INTERNALLY RIGHT NOW, s**

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i 5 1 68 1 NOT READY TO HAVE EXTERNAL DISCUSSION YET. THIS LISTING HERE _s 7; 2 IS FIRST SHOT, PUTTING IT ALL IN ONE PLACE LAST NIGHT. 3 WE NEED TO DO THE FOLLOWING. WE NEED TO TAKE THIS 4 LIST AND START TO SORT OUT THOSE THINGS WHICH ARE CUMULATIVE IN 5 NATURE, AND THOSE THINGS WHICH ARE NOT. THEY ARE NOT 6 ALGEBRAICALLY RELATED TO EACH OTHER IN THE SENSE OF CUMULATIVE 7 EFFECT. WE NEED TO SORT OUT THE LIST OF THINGS THAT ARE 8 GENERIC IN NATURE VERSUS ISOLATED INSTANCES AND WHY WE NEED TO 9 SORT OUT ROOT CAUSE SO WE CAN LOOK FOR TRENDS IN THE CONTROL OF 10 THE ANALYSIS. 11 AND THEN WITH THAT INFORMATION, WE NEED TO SIT DOWN 12 AND HAVE SOME DISCUSSIONS WITH GIBBS S HILL AND TUGC0 ON GIVEN 13 THE LIST OF' THINGS THAT ARE CUMULATIVE IN NATURE OR GENERIC IN 14 NATURE, WHAT KIND OF WORK IS NECESSARY TO QUANTIFY THE EFFECTS 15 IN A PLANT-WIDE BASIS. 16 SC YOU SEE, WE'RE JUST STARTING THAT PART OF THE 17 REVIEW RIGHT NOW, AND THIS IS A GOOD TOOL FOR US, TO O, 50 IT 18 HELPED (!S TO GO THROUGH DOING IT AS WELL. THIS LIST ON CABLE 19 TRAYS HAS EXISTED, AS YOU SEE, THIS IS A REV 8, BUT THIS IS THE 20 MOST COMPREHENSIVE. 21 MR. MORTGAT: DO YOU HAVE AN IDEA WHAT TYPE OF 22 SCHEDULE YOU ARE AIMING AT THE SORTING OF ISSUES OR VERY LAST 23 ONE, WHAT TYPE OF ACTIONS ARE NECESSARY TO RESOLVE THEM7 24 MS. WILLIAMS: THAT'S ALL PART OF THE NEXT TAKE, AND 25 MY REDOING ALL THE SCHEDULES AT THIS POINT IN TIME, BECAUSE 26 THERE HAS BEEN SHIFTS IN TUGCO'S APPROACH TO RESOLVING ISSUES, 27 AND SUCH. WE ALSO HAVE TO DO A NEW SCHEDULE AND, YES, THAT ) 28 WOULD BE AVAILABLE.

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a O o 69 1 MR. MORTGAT: THAT LINE MENTIONED 10 DAYS FROM NOW. 2 WOULD THAT BE INCLUDED BY THAT TIME? 3 MS. WILLIAMS: I CAN INCLUDE THAT INFORMATION FOR YOU 4 IN THAT SAME SUBMITTAL WHICH SUMMARIZE THE ISSUES, YES, IN THE 5 CASE OF CABLE TRAYS FOR THE ASSESSMENT OF WHAT I HAVE JUST 6 DESCRIBED. THE DOCUMENT THAT WE'RE TALKING ABOUT IN 10 DAYS 7 ISN'T GOING TO DO ALL THAT, BUT I CAN INCLUDE A SCHEDULE THAT 8 WILL TELL YOU WHEN WE'RE DOING WHAT AND HOW WE'RE PROCEEDING. 9 WE ARE GOING TO HAVE REVIEWERS IN NEW YORK IN THE VERY NEAR 10 FUTURE. IN FACT, I WOULD LIKE TO FLY OUT MONDAY AND START TO 11 LOOK AT THE KlNDS OF TOOLS THAT ARE AVAILABLE AND WHAT'S BEEN 12 DONE BEFORE WE START TO DRAW SOME OF THE CUMULATIVE EFFECTS 13 THINGS TO A' POINT WHERE WE CAN DISCUSS THEM. 14 MR. STUART: SEEMS TO ME I THINK WE HAVE FOUR TO SIX l i 15 WEEKS, ROUGHLY, OF TECHNICAL EVALUATION TO COMPLETE THE WORKING 16 WITH TUGC0 AND GIBBS & HILL TO RESOLVE THESE ISSUES. 17 THE DOCUMENT THAT WE'RE INTENDING TO TRY TO PREPARE, 18 WHICH IS A CONSOLIDATION OF THE MAJOR ISSUES WE SEE AS BEING A 19 POSSIBLE ROAD MAP THAT WOULD ALLOW YOU TO DECIDE WHAT CAN BE 20 DONE, ARE THOSE ISSUES THAT CAN'T BE RESOLVED SPECIFICALLY 21 THROUGH THE EXISTING MATERIAL THAT'S AVAILABLE. 22 I THINK IN THE AREA 0F CABLE TRAYS, IT'S POSSIBLE 23 THAT THAT WILL BE MORE THE INTERACTION OF THE VARIOUS POTENTIAL 24 PIECE PARTS MIGHT BE GREATER THAN IT WOULD BE IN THE PIPING 25 SYSTEM WHICH CAN BE SUBDIVIDED AND ANALYZED AND LOOKED AT IN 26 THE INDIVIDUAL AREA. I THINK THAT'S PART OF NANCY'S DILEMMA 27 AND REVIEW TEAM'S DILEMMA IN THE LEVEL OF THAT INTERACTION ON ) 28 THE CABLE TRAY SUPPORT SYSTEM. saw eaa%cisco DOIDGE & C ARROLL **8" co%,..cas,. CERTIFIED SHORTMAND REPORTERS C osN e4,74[s$,e DEPOSITION NOTARIES '8#"

o ( 5 70 1 SO WE hAVE TO WRESTLE WITH THAT OVER THE NEXT WEEK TO m 2 10 DAYS, AND WE'RE GOING TO TRY TO ARTICULATE OUR BEST 3 ASSESSMENT TO YOU OF WHAT WE THINK WOULD BE REALLY THE 4 UNDERLYING.!SSUES WITH CABLE TRAYS. 5 AND IF IT'S POSSIBLE TO SUBDIVIDE THEM INTO PIECE 6 PARTS, WE'LL DO THAT. AND THAT LIST WOULD LOOK SIMILAR TO THIS. 7 IF WE FEEL IT HAS TO HAVE A UNIFIED -- IT'S A UNIFIED PROBLEM 8 OR IT MIGHT BE A UNIFIED APPROACH TO SOLVING THE PROBLEM, WE'LL 9 ALSO TRY TO GIVE THAT TO YOU. 10 MR. MORTGAT: I GUESS QUITE A FEW OF THE QUESTIONS 11 THAT I HAD HAVE BEEN ANSWERED RIGHT NOW. THERE 13 NO ANSWER AT 12 THIS TIME. HOWEVER, I WOULD LIKE TO BRING UP A FEW OF THE 13 ISSUES TO SGE IF WE KIND OF SHARE THE SAME TYPE OF CONCERN 14 REGARDING THE LEVEL OF SIGNIFICANCE OF THOSE ISSUES. ONE OF T 15 THEM IS FOR LONGITUDINAL SUPPORTS. THERE WAS NO DESIGN FOR 16 TRANSVERSE OR VERTICAL LOADS. WHAT IS YOUR OPINION RELATED TO 17 SIGNIFICANCE OF SUCH AN ISSUE AND HOW IT CAN BE HANDLED? 18 MS. WILLIAMS: THERE IS TWO SIDES TO THAT, I GUESS. 19 ONE OF THE APPROACHES TO THE DESIGN, WHICH WE'RE STILL 20 DISCUSSING IN-HOUSE, IS THE APPROACH TO DESIGNING A CABLE TRAY 21 SYSTEM WHERE YOU SEPARATE OUT THE SUPPORT MECHANISMS, I.E., 22 LATERAL FROM TRANSVERSE, AND WHAT LOADS DO YOU DESIGN EACH OF 23 THOSE FOUR TYPES FOR, AND WE'RE THINKING A900T THAT STILL. 24 NOW, WE KNOW WE'RE DEALING WITH A CERTAIN TYPE CLAMP 25 ON THOSE SUPPORTS, AND WE DON'T THINK THAT IF WE DON'T GO WITH 26 THE FIRST APPROACH, THEN THE PROBLEM BECOMES GREATER BECAUSE 27 YOU HAVE GOT SUPPORTS WHERE CERTAIN LOADS AREN'T BEING ) 28 CURRENTLY EVALUATED FOR. AND, OBVIOUSLY, YOU CAN JUDGE THE

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) 71 1 RAMIFICATIONS OF SOMETHING LIKE THAT. BUT HOW REAL IS IT AND w 2 .HOW DOES THE SYSTEM BEHAVE. AND SOME OF THESE TYPES OF ASPECTS 3 OF THE CABLING TRAYS AS A WHOLE, I HAVE GOT SOME PEOPLE WORKING 4 ON IN-HOUSE. AND IT IS ON OUR LIST BECAUSE IT'S NOT RESOLVED 5 IN OUR MIND. 6 WE HAVEN'T DECIDED WHICH DIRECTION WE ARE GOING TO GO 7 WITH I T, AND WE WANT YOU TO KNOW EVERYTHING THAT WE'RE THINKING 8 OF AT THE TIME. AS I SAY, WE HAVE GOT A LITTLE MORE WORK TO DO 1 9 ON THAT ONE. AND IF YOU BUY THE SECOND ONE THAT, YES, YOU 10 REALLY GOT TO DESIGN THEM FOR THE VERTICAL LOADS, THEN WE DON'T 11 AGREE YOU CAN DO IT JUST ON THE TYPE OF STIFFNESS ANALYSIS THAT 12 GIBBS & HILL HAS PROVIDED TO DATE WHICH IS A VERY CURSORY 13 ANALYSIS. THE SOLUTION WOULD NOT BE QUITE THAT SIMPLE. 14 MR. MORTGAT: ARE YOU PLANNING ON LOOKING AT THOSE 3 t 15 FROM A SYSTEMS POINT OF VIEW 7 16 MS. WILLIAMS: A COUPLE OF THESE ARE REALLY 17 INTERTWINED INTO DISCUSSIONS OF HOW THE SYSTEM BEHAVES, AND I 18 NEED TO GO THROUGH THIS LIST AND DECIDE JUST WHICH ONES OF 19 THOSE ISSUES ARE AFFECTED BY THESE CONCEPTS, AND THEN WE NEED 20 TO AGREE ON THE CONCEPTS. SO I'M NOT READY TO SORT THEM YET, 21 BUT THAT IS CERTAINLY SOMETHING WE'RE DOING RIGHT NOW. 22 MR. MORTGAT: THE NEXT ONE WOULD BE THE WORKING POINT 23 ISSUE TO GET AN IDEA OF HOW YOU MADE UP YOUR -- HOW YOU CAME UP 24 WITH AN ASSESSMENT OF WHAT THE IMPACT WOULD BE ON THE STRESSES 25 OF THE SUPPORT. 26 MS. WILLIAMS: ON THAT ONE, WE HAVE NOT, BECAUSE WE 27 LOOKED AT THE STUDY THAT WAS DONE, I DON'T KNOW, MAYBE IT IS A 3 I 28 YEAR OLD OR IT'S BEEN AN ONGOING STUDY OR SOMETHING WE FOUND 'E,* *,'N#,',',( DOIDGE & CARROLL g ,,,g,,,, CERTlirlED SHORTH AND REPORTERS cov%t, oa % A%o easti asi saos DEPOSITION NOTARIES s.es:-ttis

e 72 1 SOME PROBLEMS WITH IT IN TERMS OF CONFLICT WITH WHAT EXISTED IN t 2 THE FIELD, AND CONSIDERATIONS IN THE NATURE OF DESIGN CHANGES 3 AND CERTAIN ASPECTS OF ANALYSIS OF HOW IT WAS PERFORMED. AND 4 SOME OF THOSE THINGS HAVE BEEN CORRECTED ON-AN ENGINEER BASIS, 5 SUCH AS CLOSELY SPACED MULLETS, SOMETHING THEY WENT BACK AND 6 DID A STUDY ON FOR ALL THOSE THINGS, AND ANALYSIS THAT WERE 7 AFFECTED. 8 WE'RE STILL FACED WITH FAIRLY LENGTHY DISCREPANCIES 9 ON THE ANALYSIS, AND THE LAST PIECES OF INFORMATION THAT WE HAD 10 ON THAT WAS THERE WAS AN AS-BUILT PROGRAM GOING ON THAT WAS 11 GOING TO MAYBE AFFECT SOME OF THE ASSUMPTIONS IN THE WORKING 12 POINT ANALYSIS IN THE TERMS OF THE EXTENT OF THE WORKING POINT 13 DEVIATIONS. 50 IT DIDN'T MAKE A LOT OF SENSE TO CONTINUE TO 14 PURSUE ANY KIND OF QUANTIFICATION OF THE EFFECTS OF AN ANALYSIS T 15 THAT COULD POSSIBLY CHANGE. IT'S NOTED AS KIND OF ON HOLD 16 UNTIL WE GET FEEDBACK FROM TEXAS ON THE STATUS. 17 MR. LEVIN: WORKING POINTS ECCENTRICITIES OCCUR FROM 18 TWO SOURCES, ONE, PER THE DESIGN DRAWING THERE IS AN 19 ECCENTRICITY, TWO, THERE IS A POSSIBILITY OUT IN THE FIELD 20 THERE IS CONSTRUCTION DEVIATION FROM THE DRAWING. DID THE 21 STUDY THE WORKING POINTS, QUOTE, STUDY ADDRESS THE FORMER OR 22 TRY TO INCLUDE -- 23 MS. WILLIAMS: IT STARTED BECAUSE OF THE LATTER. IT 24 STARTED BECAUSE THERE WERE -- SOME IN QC, I THINK IT WAS, 25 DISCOVERED DEVIATIONS, AND THE WORKING POINTS IN THE INSTALLED 26 SUPPORTS, AND THEN THEY WENT BACK TO THE ANALYSIS, FOUND OUT 27 THAT THAT, IN FACT, HAD NOT BEEN ACCOUNTED FOR AND THEY DID A g 28 GENERIC STUDY TO ASSESS THE IMPACT GIVEN MAXIMUM DEVI ATIONS IN ',$,$ ",','*[.'.# o DOIDGE & CARROLL ees...ce,,, ca%a%o CERTIFIED SHORTMAND REPORTERS coss

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{ t ) 73 1 THE FIELD. 2 MR. LEVIN: IS THAT THE ESSENCE OF YOUR -- I GUESS 3 YOUR ONGOING REVIEW, THAT CONSIDERATION OF WHETHER OR NOT THAT 4 WAS DONE IN THE BOUNDARY WAY OR IS IT FUNDAMENTAL TO THE WAY, 5 THE APPROACH OF A SESSION, THESE ECCENTRICITIES. 6 MS. WILLIAMS: THIS PROBLEM UNFOLDS IN THAT WAY. THE 7 ENGINEERING STUDIES AS A WHOLE THAT HAVE BEEN DONE, WORKING 8 POINT IS ONE OF THEM. WE HAVE SOME DIFFICULTY, POSSIBLY, WITH 9 THE BOUNDS. WHICH GETS BACK TO THE ORIGINAL APPROACH, AND 1 10 THERE IS SOME REASONS FOR THAT WHICH WE HAVE WRITTEN UP SOME 11 SUMMARIES ON. 12 MR. LEVIN: THE BOUNDS, BECAUSE WE DON'T KNOW OR 13 BECAUSE WE DON'T HAVE AN UNDERSTANDING WHAT THE POPULATION 14 REALLY LOOKS LIKE OR -- 3 15 MS. WILLIAMS: WHEN THE STUDIES WERE DONE, THEY 16 DIDN'T. NOW, THERE IS SOME PROGRAMS GOING ON NOW THAT MAY SHED 17 LIGHT ON THAT. WE DON'T KNOW EXACTLY HOW THAT'S GOING TO FIT 18 INTO THE WHOLE PICTURE, YET. 19 MR. LEVIN: I THINK WHAT I HEAR YOU SAYING, THE l 20 RESULTS OF THE CABLE TRAY AS-BUILT PROGRAM NEED TO BE 21 RECONCILED WITH THE STUDY, THE STUDY WOULD NEED TO BE UPDATED 22 TO DEAL WITH THE DISTRIBUTION OF WORKING POINT TO MEASURE IN 23 THE FIELD. 24 MS. WILLIAMS: THAT'S ONE ASPECT OF IT. THE THING 25 THAT COMPLICATES THE ISSUE A LITTLE BIT IS THE ORIGINAL 26 APPROACH THAT WAS TAKEN TO THE ANALYSIS IN THE SENSE OF DOING 27 GENERIC DESIGNS, AND THEN SPECIFIC DESIGNS. AND WHEN YOU DO A ) I 28 STUDY, YOU HAVE TO MAKE SURE THAT YOU'RE ACCOUNTING FOR ALL OF

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74 1 THE DEVIATIONS THAT ARE ALLOWED FOR EACH OF THE GENERIC SUPPORT ~j 2 TYPINGS FOR EACH OF THE LOCATIONS IN THE BUILDING, AND ALL THE 3 CHANGE PAPER WAS ACCOUNTED FOR IN A COUPLE OF STUDIES. 4 THEY HAVE TAKEN THE ORIGINAL ANALYSIS AS THE BASIS 5 FOR, AS A STARTING POINT FOR THE STUDIES, BUT THE ORIGINAL 6 ANALYSIS WAS NOT A GOOD STARTING POINT BECAUSE OF THE NUMBER OF 7 CHANGES. YOU REALLY MIGHT WANT TO START WITH A CLEAN SLATE, 8 BUT WE'RE NOT MAKING THAT RECOMMENDATION. WE WANT TO TALK TO 9 PEOPLE A LITTLE MORE ABOUT THAT. 10 MR. MORTGAT: ANOTHER ISSUE I WOULD LIKE TO GET YOUR 11 INPUT ON IS THE SLENDERNESS RATIO IN COMPRESSION MEMBERS WHEN 12 YOU HAVE THE TRAPEZE SUPPORTS. WHAT IS YOUR THEORY REGARDING 13 THE SAFETY SIGNIFICANCE OF THAT TYPE OF SUPPORT BEING NEEDED OR 14 HAVING A SLENDERNESS RATIO TOO LARGE? 3 i 15 MS. WILLIAMS: THAT PROBLEM COMES UP IN A COUPLE OF 16 DIFFERENT WAYS. AND BY THAT, I MEAN, WHAT LENGTH DO YOU USE 17 AND HOW ARE YOU ASSUMING THAT THAT MEMBER IS SUPPORTED? ARE 18 YOU TAKING CREDIT FOR SUPPORT FROM THE TRAY SYSTEM, AND IT 19 GROWS INTO A MUCH LARGER ISSUE? WE HAVEN'T QUANTIFIED IT, BUT 20 WE'RE ALSO MEETING TO GO BACK TO THE BEHAVIOR TO DECIDE WHICH 21 ASPECTS OF THE SLENDERNESS RATIO QUESTION ARE A PROBLEM. ONCE 22 YOU UNDERSTAND THE BEHAVIOR OF THE SYSTEM AND FROM THERE YOU 23 HAVE TO QUANTIFY. WE HAVEN'T TAKEN THAT STEP YET. 24 MR. MORTGAT: WOULD YOU LOOK AT THE STABILITY OF THE 25 SYSTEM OR WHETHER THE RATIO SY ITSELF IS LARGER IN YOUR 26 ASSESSMENT, WOULD YOU LOOK AT WHAT THE SAFETY IMPLICATION IS OR 3 27 JUST WHETHER THE CRITERIA HAVE BEEN MET? 4 28 MS. WILLIAMS: BOTH. AND I SAY THAT BECAUSE CABLE

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s 75 1 TRAYS ARE A UNIQUE ANIMAL IN MANY WAYS, AND THEY ARE NOT A s M, 2 PIPING SYSTEM THAT'S CARRYING FLUID AND -- THAT'S WHY I SAY 3 SAFETY SIGNIFICANCE, BECAUSE, YES, YOU HAVE GOT CRITERIA THAT 4 YOU ARE DESIGNING TO, YOU NEED TO MEET. WHEN YOU STEP OUTSIDE 5 THE BOUNDS OF THAT CRITERIA, THEN YOU HAVE TO ASSESS IMPACT. 6 THAT'S WHY I SAY BOTH. 4 7 MR. LEVIN: NANCY, IT STRIKES ME THERE ARE A FEW 8 THINGS WITH REGARD TO THIS THAT SHOULD BE QUITE SIMPLE. NUMBER 9 ONE, THE MAGNITUDE OF THE COMPRESSIVE LOAD.ON THIS PARTICULAR 10 MEMBER, I ASSUME, IS NOT REALLY AN ISSUE, BUT IT SEEMS TO ME, 11 THEN, WHAT WE GET DOWN TO IS COMING TO A CONSENSUS AS TO WHAT 12 BOUNDARY CONDITIONS ARE CONSIDERED APPROPRIATE, AND HOW THOSE 13 BOUNDARY CONDITIONS WOULD AFFECT, ESSENTIALLY, YOUR K VALUES. 14 IS THAT THE ESSENCE OF WHAT'S AT ISSUE, LIKE, HOW TO 3 15 DEAL WITH THINGS LIKE THAT CONNECTION INTO THE CEILING OR THE 16 CONNECTIONS INTO OTHER TRAYS AND HOW THAT AFFECTS K? 17 MS. WILLIAMS: THAT'S WHERE WE ARE STARTING WITH, 18 EXACTLY. 19 MR. LEVIN: I GUESS -- 20 MS. WILLIAMS: SOME OF THAT WE HAVE DONE. 21 MR. LEVIN: YOU HAVE. 1 22 MS. WILLIAMS: THAT'S WHY I WANT TO LOOK AT THE 25 DYNAMIC ANALYSIS IN NEW YORK. WE HAVE DONE BASE STUDIES. 24 THERE IS A DYNAMICS ANALYSIS WE WANT TO TAKE A LOOK AT FOR THE 25 ASSUMED BOUNDARY CONDITIONS THERE AND THE RESULTING BEHAVIOR. a 26 AND THEN WE'RE ALSO DRAWING ON SOME OF OUR PEOPLE WHO 27 HAVE HAD A LOT OF EXPERIENCE IN THE VARIOUS METHODS OF g I 28 DESIGNING CABLE TRAYS, AND THE DIFFERENCES BETWEEN THOSE saw saa%cisco DOIDGE & CARROLL S*8" coena costa CERTIFIED SHORTHAND REPORTERS C o ^ 4,sfahasee DEPOslTION NOTARIES

} 76 1 APPROACHES AND SOMEONE WHO IS NOT IN THIS ROOM TODAY IS LOOKING 2 AT THAT. 3 BUT I THINK YOU HAVE HIT THE NAIL ON THE HEAD IN 4 TERMS OF WHAT YOU GOT TO AGREE ON BEFORE YOU CAN SAY YES OR NO. 5 IT'S A PROBLEM AND THEN QUANTIFY THE EFFECT. YOU ARE ON TRACK 6 THERE. 7 MR. MORTGAT: ANOTHER PROBLEM OF A SIMILAR NATURE, 8 THE ECCENTRICITY WAS NOT INCLUDED IN THE SINGLE ANGLE BRACES. 9 AGAIN, I WOULD LIKE TO GET AN IDEA 0F HOW YOU COME UP WITH 10 IMPACT SIGNIFICANCE FOR THAT ISSUE, AND WHICH IS SOMEWHAT 11 SIMILAR TO THE PREVIOUS ONE? EVENTUALLY MY FOLLOWING QUESTION 12 WAS HOW YOU COME BACK WITH A COMBINED EFFORT? 13 MS. WILLIAMS: YOU ARE ASKING ALL THE QUESTIONS THAT 14 WE'RE WORKING ON RIGHT NOW. y BUT YOU ARE ASKING THE RIGHT i 15 QUESTIONS. 16 MR. MORTGAT: THOSE ARE THE ONES THAT COME UP. ONCE 17 I GO THROUGH THE LIST, SORT WHAT THE ISSUES ARE AND GLOBAL z 18 EFFECT AND WHAT THE IMPACT IS. 19 MS. WILLIAMS: IT SEEMS TO ME LIKE YOU ARE GOING 20 THROUGH THE SAME THOUGHT PROCESS THAT WE GO THROUGH. IT'S JUST 21 WHERE WE ARE IN TIME AND THAT'S EXACTLY HOW WE APPROACH IT. 22 MR. MORTGAT: DO YOU FEEL THAT EVENTUALLY THROUGH 23 YOUR SORTING PROCESS, SOME OF THOSE ISSUES ARE GOING TO 24 COLLAPSE INTO A SINGLE ONE OF ONES THAT CAN BE HANDLED TOGETHER? 25 FOR EXAMPLE, THERE ARE A NUMBER OF ISSUES DEALING 26 WITH BOLTS OR WELDS OR PRYING ACTION, AS YOU GO THROUGH YOUR 3 27 SORTING PROCESS AND YOUR -- THE WORK YOU ARE GOING TO DO IN THE ~ 28 NEXT FEW WEEKS, YOU WILL BE ABLE TO MAKE THOSE ISSUES TO ",*]c 5,0 0 DOIDGE & CARROLL co y,,eg,,, CERTIF ED SHORTHAND REPORTERS coves I cana%o .aise asi.ases DEPOSITION NOTARIES s' e sa t t i s

77 .~ 1 CONVERGE TOWARD A SINGLE ISSUE? ? 2 MS. WILLIAMS: YES. 3 MR. MORTGAT: IS THAT ONE OF YOUR GOALS? 4 MS. WILLIAMS: THAT'S ONE OF OMR GOALS. 5 MR. WITT: IS ANY OF IT COMING TOGETHER YET OR 6 RESEARCH STAGE? 7 MS. WILLIAMS: THIS IS OUR FIRST REAL THOROUGH. I 8 HAVE MY IDEAS. OTHER REVIEWERS HAVE THEIR IDEAS. WE HAVE HAD 9 SOME DISCUSSIONS. WE HAVE TO GO THROUGH THE FORMAL EXERCISE OF 10 SORTING THAT OUT SO YOU CAN SEE HOW WE HAVE DONE THAT 11 CONDENSATION. 12 MR. MORTGAT: HOW IS YOUR FEELING ABOUT TESTING IN 13 THIS AREA? YOU MENTIONED SOME IDEAS YOU HAD ABOUT TESTING IN 14 THE PIPING AREA. IN THIS AREA, ONE ISSUE THAT HAS COME UP A T 15 LOT IS THE SINGLE BOLT CONNECTION AND RELATED TO I T, STIFFNESS 16 RELATED TO IT. HOW IS YOUR FEELING REGARDING TESTING IN THAT 17 AREA? 18 MS. WILLIAMS: I THINK IT HAS ITS PLACE. MY ONLY 19 CONCERN WITH DOING TESTING, IT MIGHT BE A GOOD SOLUTION TO SOME 20 OF THESE. I DON'T KNOW IF YOU NEED TO GO TO THAT EXTENT OR IF 21 THAT IS THE EASIEST AVENUE UNTIL WE FLUSH OUT THE ISSUES, BUT 22 THE ONLY CAUTION I WOULD SAY ON TESTING IS THAT IT'S GOT TO BE 23 VERY WELL THOUGHT OUT. AND YOU GOT TO MAKE VERY SURE YOU ARE 24 UNDERSTANDING WHAT WE'RE SAYING OR HAVE A LITTLE MORE 25 INTERACTION THAN WE HAVE IN THE PAST IN GETTING OUR PROBLEMS 26 ACROSS BEFORE THE TESTING STARTS SO THAT YOU ARE NOT GOING UP A 27 BLIND ALLEY. ) 28 MR. LEVIN: I THINK THAT'S IMPORTANT, CHRIS. THERE Sy '",']Cy,5,C,0 DOIDGE & CARROLL cog,,,,,, oanta%o CERTIFIED SHORTHAND REPORTERS cou%t, seiss ast asse OEPOSITION NOTARIES 'd ' ' 8 2 ' ' ' '

y e 78 1 ARE SEVERAL REASONS YOU MAY NOT WANT TO EMBARK UPON THAT THING, m -f 2 ONE BEING THE STRENGTH OF CONNECTION, ONE BEING ITS BEHAVIOR 3 THAT MAY AFFECT A LOT OF THINGS, INCLUDING STABILITY. 4 MR. WITT: A METHODOLOGY QUESTION AT THIS POINT. IN 5 YOUR PAST DEALINGS WITH THE PROJECT, HAVE THEY INVOLVED YOU AT 6 ALL IN THE EARLY STAGES OF PROGRAMS, EITHER ANALYTICAL OR TESTS, l 7 WHERE THERE ISN'T A CLEAR ROAD MAP BASED ON PRECEDENTS FOR 8 RESOLVING AN ISSUE? HAVE THEY INVOLVED YOU IN REACHING, IF NOT 9 AGREEMENT, AT LEAST GETTING INPUT ON THE EARLY STAGES OR HAVE 10 YOU JUST.2EN GETTING THE RESULTS AT THE END? WHAT HAS THAT 11 PROCESS BEEN? 12 MS. WILLIAMS: THERE HAS BEEN ATTEMPTS TO INTERACT, 13 BUT NEVER Td THE POINT THAT I FELT THAT OUR AUDIENCE UNDERSTOOD 14 BEFORE THEY EMBARKED ON A PROGRAM. AND WHAT HAPPENS IS, I CAN 3 15 GIVE YOU A SPECIFIC EXAMPLE, PERHAPS THAT WOULD BE THE BEST WAY 16 TO WALK THROUGH, BECAUSE IT'S ONE THAT WE'RE DEALING WITH, 17 SADLY ENOUGH, RIGHT NOW. 18 THAT'S THE CONDUIT TESTING. WHAT HAPPENED THERE IS, 19 WE WROTE A LETTER BECAUSE WE HAD DONE SOME ANALYSIS, AND IN THE 20 LETTER, ALTHOUGH IT WAS A DISCUSSION OF ANALYTICAL ASPECTS OF A 21 PROBLEM, WE IDENTIFIED A CONCERN WITH WHAT WOULD BE THE WEAK 22 LINK IN THE DESIGN, AND SOMETHING FOR WHICH THE INTERSTRUCTURE 23 HAD NOT BEEN -- THERE WAS NO CAPACITY VALUES AVAILABLE FOR A 24 PARTICULAR DIRECTION OF GOING TOWARDS. 25 THEN THERE WAS A TESTING PROGRAM WHICH STARTED. WE 26 GOT THE PROCEDURE FOR THE PROGRAM WHEN THEY WERE ONE WEEK AWAY 27 FROM COMPLETING SIX WEEKS, OR WHAT HAVE YOU, OF TESTS. AT THAT 3 28 POINT IN TIME, IF WE HAD COMMENTS ON THE PROCEDURE AND WHETHER sa% ema%cesco DOIDGE & CARROLL cow,.cos,. CERTIFIED SHORTHAND REPORTERS C ov% sa i anos DEPOSITION NOTARIES ' ' 3 # d ' ' '

4 79 1 IT ADDRESSES OUR CONCERNS IN THE ORIGINAL ANALYSIS, IT'S A w -1 2 LITTLE LATE. 3 IT ENDED UP WE WENT DOWN TO THE TESTING LAB AND, IN 4 FACT, THE WEAK LINK IN THE DESIGN WASN'T BEING TESTED. IT 5 REALLY PUTS TUGC0 BACK WHERE THEY STARTED, UNFORTUNATELY, AND 6 WOULD BE MUCH BETTER IF THERE WAS DISCUSSION BEFORE STARTING 7 THE' TEST. 8 MR. WITT: THERE IS NO OBSTROLTION IN REGARDS TO 9 COMMUNICATION IN TERMS OF PROTOCOL? 10 MS. WILLIAMS:, NO, JUST HAVE TO DOCUMENT IT,. MAKING 11 SURE THERE IS PICUGH INTERFACING GOING ON, BECAUSE SOME OF THE 12 TECHNICAL ASPECTS, ALMOST GOT TO GO OVER THEM FIVE TIMES UNTIL 13 YOU ARE SUR$ YOU HAVE FIVE ENGINEERS THINKING THE SAME THING. 14 THEY GET A LITTLE STICKY. 3 15 MR. MORTGAT: IN TERMS OF TESTING, I SEE TWO TYPES OF 16 TESTING. ONE WOULD BE A STUDY TESTING WHICH CAN.BE FAIRLY 17 SIMPLE AND STILL GIVE YOU A LOT OF INFORMATION, PARTICULARLY 18 REGARDING THESE CONNECTIONS. ANOTHER ONE WOULD BE DYNAMICS 19 TESTING WHERE YOU WOULD LOOK AT PART OF THE SYSTEM AND TRY TO 20 UNDERSTAND MORE IN TERMS OF THE OVERALL BEHAVIOR. 21 SO THIS MORNING WHEN YOU TALKED ABOUT TESTING, YOU 22 MENTIONED, I BELIEVE, DYNAMIC TESTING. I STILL THINK THERE IS 23 A FAIR AMOUNT OF GAIN TO BE MADE BY SOME STATIC TESTING AS LONG 24 AS THEY WERE DONE. 25 MS. WILLIAMS: I THINK THERE IS A LOT THAT CAN BE 26 GAINED FROM STATIC TESTING, YES. 3 27 MR. MORTGAT: I HAVE A QUESTION OF WHICH I KNOW THE / 28 ANSWER ALREADY. DO YOU HAVE ANY PRELIMINARY COMMENTS REGARDING Sy,7 ",'jC,',5,C[ DOIDGE & CARROLL gas,,,en,,, oanuNo CERTIFIED SHORTHAND REPORTERS cos%Tv satseasi.3386 DEPOSITION NOTARIES '3#'"*

80 1 THE DYNAMICS ANALYSIS OF WHAT'S DONE BY GIBBS & HILL ON THE s i i 2 CABLE TRAYS? 3 MS. WILLIAMS: I DON'T THINK IT'S GOING TO ANSWER ALL 4 THE QUESTIONS. 5 MR. MORTGAT: THAT WAS NOT THE ANSWER I EXPECTED. I 6 THOUGHT YOU WOULD SAY YOU HAD NOT LOOKED AT IT. 50 YOU HAVE 7 HAD A CHANCE TO LOOK AT IT? 8 MS. WILLIAMS: AND THE REPORT MIGHT LACK SOME 9 INFORMATION IN CERTAIN AREAS. THAT'S WHY WE WANT TO GO UP AND 10 TALK TO PEOPLE. 11 MR. LEVIN: OKAY. I WAS JUST CURIOUS IF YOU FELT YOU 12 WERE PREPARED TO ADDRESS THOSE AREAS WHERE IT WON'T ANSWER ALL 13 THE QUESTI0AS. 14 MS. WILLIAMS: NO, THAT'S A LITTLE EARLY. I HAVE GOT 3 15 SOME GENERAL IDEAS, SOME THINGS WE HAVE SPOTTED. SOME PEOPLE 16 HAVE READ IT, SOME PEOPLE MADE COMMENTS, SOME INFORMATION IS 17 NOT THERE. THAT'S ABOUT WHERE WE ARE AT IN TIME. 18 MR. MORTGAT: THAT'S ABOUT IT. 19 MR. LEVIN: DO YOU HAVE A SCHEDULE FOR THAT 20 PARTICULAR REVIEW OF THAT REPORT, WHICH I THINK IS VERY RECENT, 21 ISN'T I T, LAST WEEK OR SOMETHING? 22 MS. WILLIAMS: YES. WE PUT A LOT OF EFFORT INTO 23 DOING THIS. THIS WEEK WE DID LOOK.INTO THE REPORT. I HAVE NOT 24 SET THIS UP. BOB ALLARD IS HEARING THIS FIRST. WE WANT TO FLY 25 OUT MONDAY AND BE IN GIBBS & HILL'S OFFICE TUESDAY AND GO 26 THROUGH AN OVERVIEW, AND SEE IF WE CAN FILL IN THE HOLES THAT' 27 WE CAN'T GET ANSWERED IN THE REPORT, AND GET A GOOD FEEL FOR 3 28 WHAT WAS DONE, AND I WANTED TO SEND FOUR REVIEWERS UP. '$,' ","," *,',',C,0 DOIDGE & CARROLL oasta%o CERTIFIED SHORTHAND REPORTERS coy,..co.,,. cowNT sesseesi sao* DEPOSITION NOTARIE5 'd ' S' ' 8 8 ' ' ' ' '

o ) 81 1 MR. LEVIN: I BELIEVE IN THAT REGARD WE'LL BE DOING w -f 2 MUCH OF THE SAME TYPE OF THING IN PARALLEL. AT SOME POINT IN 3 TIME IT WILL BE APPROPRIATE FOR US TO HAVE ANOTHER DISCUSSION. 4 MS. WILLIAMS: YES. 5 MR. LEVIN: OKAY. 6 MR. MORTGAT: THAT'S ABOUT IT. MOST OF MY QUESTIONS 7 WERE TO BE UNANSWERED, AND I HAVE A FEW MORE, AND THEY ARE OF 8 THE SAME NATURE. THEREFORE, NO REAL RE/ SON TO GO THROUGH THEM. 9 MS. WILLIAMS: SORRY ABOUT THAT. 10 MR. LEVIN: IT SOUNDS AS IF WE'RE GOING TO HAVE TO 11 HAVE ANOTHER MEETING. I WOULD HOPE THAT, PARTICULARLY IN 12 REGARD TO YOUR EARLIER COMMENTS, WE CAN DEVELOP SOME 13 MECHANISM 1 APPEARS TO HAVE BEEN COMMUNICATION IN THE PAST, 14 BUT MAYBE NOT TIMELY COMMUNICATION. THAT'S SOMETHING WE WANT T 15 TO INSURE IN THE FUTURE. I THINK IT'S GOING TO BE NECESSARY 16 MORE IN THIS AREA BECAUSE WE HAVE AT LEAST A FEELING AS TO 17 WHERE THIS ISSUE IS RELATIVE TO SOME OF THE PIPING, LESS OF A 18 RECORD. 19 MS. WILLIAMS: YES. 20 MR. LEVIN: IF THERE ARE ANY OTHER QUESTIONS FROM THE 21 CPRT OR SENIOR REVIEW TEAM. 22 THEN I GUESS I WOULD LIKE TO MOVE FORWARD AND 23 INTRODUCE ED BLACKWOOD HERE, WHO WILL LEAD A DISCUSSION IN THE 24 GENERAL PROGRAMMATIC AREA AS WELL AS GENERIC IMPLICATIONS OF 25 YOUR INDEPENDENT ASSESSMENT PROGRAM. ED. 26 MR. BLACKWOOD: THANK YOU. AS HOWARD MENTIONED 27 EARLIER THIS MORNING, WE BELIEVE THAT AN IMPORTANT PRODUCT OF ) 28 OUR FOCUS WILL BE THE PROGRAMMATIC AND GENERIC IMPLICATIONS OF 1 sa% niase.sco DOIDGE & CARROLL h* [* CERTIFIED SHORTH AND REPORTERS cow i iaisi asi asse OEPOSITION NOTARIES

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) 82 1 THE FINDINGS THAT HAVE COME NOT ONLY FROM CYGNA, BUT ALSO FROM -f 2 MANY OF THE OTHER ORGANIZATIONS THAT HAVE LOOKED AT THE PROJECT. 3 ONE ELEMENT IN OUR CHARTER IS TO EVALUATE THE 4 COLLECTIVE SIGNIFICANCE OF THESE IDENTIFIED DIFFERENCES. IN 5 YOUR JANUARY 25TH LETTER TO MR. NOONAN, I NOTED THAT YOU DID 6 INTEND TO ASSESS THE CUMULATIVE EFFECTS, AND I THINK WE HAVE 7 JUMPED AROUND THAT QUITE A BIT THIS MORNING ALREADY. BUT I 8 THINK IT'S IMPORTANT THAT WE UNDERSTAND THE, OR TRY TO 9 UNDERSTAND YOUR UNDERLYING PHILOSOPHY AND THE APPROACH THAT YOU 10 USED IN OR ARE PLANNING TO USE IN COMING UP WITH CUMULATIVE 11 EFFECTS. COULD YOU -- 12 MS. WILLIAMS: I WAS AFRAID YOU WERE GOING TO STOP 13 THERE. 14 MR. BLACKWOOD: COULD YOU GIVE US ANY INSIGHT ON THE 3 15 PHILOSOPHY? 16 THE WITNESS: ALL RIGHT. LET ME TRY. THIS IS PRETTY 17 IMPROMPTU. 18 MS. WILLIAMS: WE DO CUMULATIVE IN A COUPLE OF AREAS 19 OR WAYS. ONE IS OBVIOUSLY THE QUANTITATIVE ASPECT OF 20 CUMULATIVE EFFECTS WHERE, WITHIN A DISCIPLINE, YOU GO THROUGH 21 AND DETERMINE WHICH OF THE ITEMS ARE CUMULATIVE IN NATURE, 22 WHICH ARE ISOLATED. AND THOSE THINGS THAT ARE RELATED, MAKE AN 23 ATTEMPT AT QUANTIFYING THE EFFECTS SUCH THAT YOU CAN DETERMINE 24 ACROSS-THE-BOARD WHETHER THERE IS ANY IMPLICATION OR ANYTHING 25-ELSE THAT NEEDS TO BE PURSUED AS A RESULT OF THAT ASSESSMENT. 26 MR. BLACKWOOD: IS THAT WITHIN A SINGLE SYSTEM OR 27 COMPONENT OR WITHIN A SINGLE OF THE FUNCTIONAL AREAS THAT YOU 3 28 HAVE ADDRESSED IN YOUR PHASES?

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e L 83 1 MS. WILLIAMS: IT NEEDS TO TAKE PLACE IN A COUPLE OF 2 TIERS. YOU WOULD WANT TO DO IT AND ESTABLISH -- YOU WOULD WANT 3 TO MAKE SURE YOU DON'T HAVE A STRESS INTENSIFICATION FIGURE 4 WITH THE MASS PROBLEM, MASS POINT SPACING PROBLEM. THAT WOULD 5 BE AN EXAMPLE OF SOMETHING WITHIN A SYSTEM. 6 THEN BEYOND THAT, YOU TEND TO LOOK ACROSS THE BOARD 7 FOR IMPLICATIONS OF SOME THINGS THAT MAY NOT BE ADDITIVE IN 8 NATURE. FOR EXAMPLE, IN THE PIPE SUPPORT AREA, A PUNCHING 9 SHEAR CALCULATION OR DISCREPANCY WITH A PUNCHING SHEAR 10 CALCULATIONS WOULD NOT BE CUMULATIVE OF CROSS SUPPORTS. THERE 11 WHAT YOU ARE DOING IS LOOKING FOR TRENDS AND OMISSIONS IN 12 CALCULATIONS OR THE QUALITY LEVEL OF THE WORK OR THE DIRECTION 13 PROVIDED TO'THE ENGINEERS. 14 THERE YOU ARE GETTING A LITTLE MORE INTO THE ROOT T t 15 CAUSE. WE HAVE ASSESSED WHETHER WE GOT ENOUGH EXAMPLES OF I T, 16 THAT IT SHOWS A TREND, THAT MAYBE THERE IS NOT A DIRECTION, AND 17 WE LOOK INTO PROCEDURES AND THERE IS NO DIRECTION, THIS SORT OF 18 THING. SO THAT'S A SECOND WAY THAT WE DO CUMULATIVE EFFECTS. 19 AND THEN A THIRD WAY IS IN USING THE ROOT CAUSE 20 STATEMENTS TO LOOK FOR PROGRAMMATIC TRENDS, AND THEN ANY OTHER 21 INFORMATION WE HAVE FROM THE REVIEWS THAT SEEMS CONNECTED IN 22 ANY WAY TO SUPPORT OR NOT SUPPORT A TREND THAT WE WOULD SEE 23 FROM THE ROOT CAUSES. 24 S O, FOR EXAMPLE, IF IN THE -- AND THIS IS 25 HYPOTHETICAL, SO DON'T TAKE IT LIKE THIS IS SOMETHING TAKING IN 26 MIND. IF WE SAW IN PIPE STRESS EVERY TIME THERE WAS AN ERROR, 27 THERE WAS NO PROCEDURES, WE WOULD SAY THEY PROBABLY NEED TO DO ) I 28 WORK ON THE PROCEDURES BECAUSE PERHAPS IF THEY HAD THAT, IT

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I 84 1 WOULD HAVE PRECLUDED THE ERRORS, THAT SOR,T OF THING. THAT'S m M 2 THE THIRD WAY IN WHICH WE WOULD DO THAT. 3 A FOURTH WAY IN THE END WILL TURN OUT TO BE WITHIN AN 4 ORGANIZATION. IN OTHER WORDS, DO THE PROBLEMS WE SEE ARE 5 ISOLATED TO THE PIPE SUPPORT DESIGN ORGANIZATION, ISOLATED TO 6 GIBBS & HILL, TUGCO, ARE THEY, SAY, A FUNCTION OF THE 7 DISCIPLINE WITHIN THE ORGANIZATION, CROSS-DISCIPLINE. THAT'S 8 WHEN YOU GET THE MORE MANAGEMENT OVERVIEW ASPECTS OF CUMULATIVE 9 EFFECTS. 10 MR. BLACKWOOD: SOUNDS LIKE YOU ARE INHERENTLY 11 IDENTIFYING THE BOUNDS OF THE CUMULATIVE EFFECTS THROUGH EITHER 12 QUALITATIVE OR QUANTITATIVE TYPES OF ATTRIBUTES, IS THAT RIGHT? 13 MS. WILLIAMS: YES, YES. 14 MR. BLACKWOOD: IN THE PHASE 3 REPORT, I READ IT WITH T 15 INTEREST, AND I NOTICE IN THE TERMINOLOGY SECTION THERE WERE 16 SOME -- THERE WERE SOME TERMS THAT I COULDN'T FIND A DEFINITION 17 FOR CUMULATIVE EFFEC TS AND TRENDS, IS ONE THAT I THINK YOU HAVE 18 JUST EXPLAINED RATHER WELL. 19 THE POTENTIAL COLLECTIVE SAFETY IMPACT, I NOTICED, 20 WAS ALSO USED IN A COUPLE OF CASES. AND WHAT I AM TRYING TO DO 21 IS RELATE, AT LEAST IN YOUR PERCEPTION, WHAT THE DIFFERENCE IS 22 BETWEEN THE CUMULATIVE EFFECTS ANALYSIS RESULTS AND THE 23 COLLECTIVE SAFETY IMPACT, AND THE THIRD TERM THAT HAS BEEN 24 KICKED AROUND IS THE GENERIC IMPLICATIONS. COULD YOU TRY TO 25 TIE THOSE THREE THINGS TOGETHER FOR ME, PLEASE? 26 MS. WILLIAMS: I THINK THOSE THREE THINGS PRETTY MUCH g 27 FIT IN WHAT I JUST DESCRIBED. THE TERMS, NUMBER ONE, YOU ARE 1 28 CORRECT, ARE NOT VERY WELL DEFINED IN THE RECORD AND, NUMBER 5* a*]cySc o DOIDGE & C ARROLL ,. g, CERTIFIED SHORTH AND REPORTE RS coa s oantaNo taisi ast asse DEPOSITION NOTARIES ' S' 8 32- ' ' ' 5

85 1 TW O, USED SOMETIMES INTERCHANGEABLY IN DISCUSSIONS. BUT I m i 2 THINK THAT FOR THE MOST PART, THE ACTIVITIES I DESCRIBED TO YOU 3 WOULD TEND TO GIVE YOU THE ANSWERS ON GENERIC IMPLICATIONS, 4 PROGRAMMATIC IMPACT, AND QUANTITATIVE ADDITIVE EFFECTS, AND 5 WHAT WE CALL CUMULATIVE EFFECTS. 6 MR. BLACKWOOD: I ALSO NOTICE AT LEAST ONE CASE THE 7 TERM, PROGRAMMATIC BREAKDOWN, WAS USED. DO YOU HAVE AN 8 OPERATIONAL DEFINITION FOR WHAT A PROGRAMMATIC BREAKDOWN IS? 9 MS. WILLIAMS: THAT WOULD BE A -- I THINK WEAKNESS IS 10 A BETTER -- PROBABLY BETTER WORD THAN PROGRAM, WHERE WE HAVE 11 GONE IN AND LOOKED AT THE QA PROGRAM TO MAKE SURE THAT THEY 12 MEET ALL THEIR COMMITMENTS AS REQUIRED BY ANSI N45.2.11.

YES, 13 THEY HAVE THE PROCEDURES IN PLACE THEY ARE SUPPOSED TO HAVE.

14 THEY HAVE AN FSAR WHICH COVERS THE BASES THAT IT SHOULD, AND T 15 THAT'S THEIR PROGRAM. 16 BUT THEN WE GET INTO THE IMPLEMENTATION EVALUATIONS, 17 OR WE START TO SEE MAYBE A WEAKNESS IN ONE, OF THE PROCEDURES 18 BECAUSE OF AN ERROR THAT KEEPS OCCURRING IN ONE DISCIPLINE, AND 19 THAT MIGHT CAUSE US TO GO BACK AND LOOK AT HOW SOMETHING HAS 20 BEEN COVERED IN THEIR PROCEDURES, AND THAT WOULD BE A WEAKNESS 21 IN THE PROGRAM. 22 MR. BLACKWOOD: OKAY. ALSO IN THE REPORT I THINK 23 SOME OF THE -- SOME OF THE CHECKLISTS, THE TERMS SAFETY IMPACT 24 AND SIGNIFICANT SAFETY IMPACT WERE USED. DOES THIS INFER A 25 TWO-TIERED SYSTEM OF WHAT HAS AN IMPACT AND WHAT HAS A BIG 26 IMPACT, OR HOW DO YOU DIFFERENTIATE BETWEEN A SAFETY IMPACT AND 27 A SIGNIFICANT SAFETY IMPACT? ) I 28 MS. WILLIAMS: WHEN WE FIND A DISCREPANCY, ONE OF THE ",*]C,',5,C O DOIDGE & CARROLL m,,, m,, CERTIFIED SHORTHAND RE PORTERS cow o g,g esise ase ases DEPOSITION NOTARIES d'5'532'5

] 1 FIRST THINGS WE START TO SAY IS, IS THIS PERHAPS INDICATIVE OF s-; 2 SOMETHING LARGER OR IS THE OMISSION, IF IT WAS AN OMISSION IN 3 THE ANALYSIS, DOES IT HAVE A POTENTIALLY SIGNIFICANT EFFECT ON 4 THE OUTCOME OF THE ANALYSIS SUCH THAT IT MAY HA'/E A SAFETY 5 IMPACT. 6 THEN WE GO THROUGH A PROCESS OF DELVING INTO THE 7 ISSUE MUCH DEEPER AND TRYING TO QUANTIFY I T, AND THEN TRYING TO 8 ASK OURSELVES WHETHER IT'S SOMETHING THAT COULD OCCUR ANYWHERE. 9 AND THE PROBABILITY OF IT AFFECTING SOMETHING OVER IN ANOTHER 10 PART OF THE PLANT COULD BE OF WORSE IMPACT THAN MAYBE THE 11 SPECIFIC EXAMPLE THAT WE'RE LOOKING AT, AND THIS SORT OF THING. 12 WE BASICALLY CONTINUE TO PURSUE A PROBLEM UNTIL WE 13 CAN BOX IT I N, ISOLATE I T, OR GIVE OURSELVES SOME ASSURANCE 14 THAT THERE IS NO OTHER REASON TO PURSUE IT FURTHER BECAUSE WE 3 i 15 DON'T THINK IT'S GOING TO RESULT IN ANY SIGNIFICANT IMPACT. 16 THERE ARE ALL KIND OF GRAY TERMS WHICH DESCRIBE A 17 PROCESS THAT'S VERY ITERATIVE FOR US, AND IT'S A MATTER OF 18 PURSUING SOMETHING UNTIL WE FEEL COMFORTABLE TO THE EXTENT 19 WHICH WE HAVE QUANTIFIED IT AND THE EXTENT TO WHICH IT WILL BE 20 A PROBLEM IN THE PLANT. 21 MR. BLACKWOOD: IS WHAT YOU HAVE JUST DESCRIBED 22 SYNONYMOUS WITH A DESIGN IMPACT AND SIGNIFICANT DESIGN IMPACT? 23 MS. WILLIAMS: M-HM, YES. 24 MR. LEVIN: NANCY, I THINK IN YOUR EARLIER 25 DISCUSSIONS YOU ALLUDED TO INSTANCES WHERE YOU EXPANDED YOUR 26 SAMPLE BEYOND THE BOUNDARY OF THE SYSTEMS IN THE PROGRAM. 27 THERE ARE MORE FOCUS SAMPLES LOOKING AT PARTICULAR ATTRIBUTES ) 28 IN POPULATIONS IN OTHER SYSTEMS. FOR THE MOST PART THOSE

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o 87 1 EXPANSIONS ARE STILL WITHIN THE SAME DISCIPLINES. ESSENTIALLY, 2 YOU MIGHT BE LOOKING AT A -- FOR EXAMPLE, THE SNUBBER ON THE 3 VALVE ACTUATOR, I BELIEVE YOU LOOKED ELSEWHERE OUTSIDE OF YOUR 4 SCOPE? 5 MS. WILLIAMS: YES. 6 MR. LEVIN: TO VERIFY WHETHER OR NOT THE SAME 7 SITUATION EXISTED. PRESUMABLY THAT'S SOMETHING THAT'S STILL 8 INTERNAL TO WITHIN A PARTICULAR DESIGN ORGANIZATION. WERE 9 THERE INSTANCES WHERE YOU SAW SOMETHING PR0 GRAMMATICALLY WHERE 10 YOU WENT ELSEWHERE TO OTHER DISCIPLINES OR ANYTHING LIKE THAT? 11 MS. WILLIAMS: OKAY, THAT IS WHEN YOU LOOK AT OUR 12 LISTING FOR DESIGN CONTROL YOU ARE GOING TO SEE, FOR EXAMPLE, 13 INTERFACE CONTROL LISTED. AND ALTHOUGH WE HAVE DONE A QA TYPE 14 REVIEW OF THE INTERFACES AND PROCEDURES AND IMPLEMENTATION AND T 15 HOW WELL THEY FOLLOW THE PROCEDURES, WE'RE RIGHT NOW LOOKING 16 FOR ANY IMPLICATIONS THROUGH OUR TECHNICAL RESULTS AND THROUGH 17 THE TOTALITY OF ALL OF OUR QA DESIGN CONTROL RESULTS TO 18 ESTABLISH WHETHER THERE IS ANY WEAKNESSES. WE'RE NOT THERE YET. 19 IT'S ON THE LIST. HYPOTHETICALLY, IF THERE WAS A WEAKNESS IN 20 THE INTERFACE CONTROL SYSTEM, THEN WE HAVE TO ASK OURSELVES THE 21 QUESTION, BUT WE'RE NOT OUITE THERE YET. 22 MR. LEVIN: YOU HAVEN'T IDENTIFIED ONE TO THE POINT 23 WHERE YOU HAD TO GO OUT AND TEST ANOTHER AREA OR LOOK AT 24 ANOTHER AREA? 25 MS. WILLIAMS: NOT YET. YOU REALLY -- MY FEELING IS 26 THAT YOU GOT TO LOOK AT ALL THE INFORMATION BEFORE, AND YOU 27 JUDGE THAT IN TOTAL, AND THAT'S WHERE -- WHAT WE'RE DOING RIGHT ) I 28 NOW. $3 3E#,'."C DOIDGE & CARROLL c as,,, g o 3,, oanamo CERTIFIED SHORTH AND REPORTERS cov%Tv saisi asi assa DEPOSITION NOTARIES e s> e32 t i t s

88 1 MR. LEVIN: WOULDN'T, FOR EXAMPLE, THE WORK YOU DID 2 IN THE ELECTRICAL AREA GIVE YOU SOME INSIGHT INTO THAT QUESTION? 3 MS. WILLIAMS: BECAUSE OF THE NUMBER OF INTERFACES 4 THAT EXISTED THERE OR 5 MR. LEVIN: LET'S ASSUME YOU MAY HAVE IDENTIFIED AN 6 OPPORTUNITY FOR IMPROVEMENT OF A CERTAIN PROGRAM THAT WAS IN 7 YOUR REVIEW SCOPE, MAY HAVE APPLIED TO THE MECHANICAL AREA. 8 AND, HOWEVER, YOU HAD KNOWLEDGE THAT THIS MAY BE A GENERAL 9 !NTERFACE. IF THAT WOULD BE THE AREA OF INTERFACE CONTROL 10 MECHANISMS EXIST ELSEWHERE, FOR EXAMPLE, ELECTRICAL AREA, ONE 11 MIGHT, COULD USE THAT INFORMATION THROUGH YOUR REVIEW IN THE 12 ELECTRICAL AREA IF YOU EITHER NOTED AND/OR DIDN'T NOTE THAT 13 SAME KIND OF THING IN RECOMMENDING YOU DRAW THAT CONCLUSION. 14 MS, WILLIAMS: I THINK, IF I AM UNDERSTANDING WHAT T ( 15 YOU ARE SAYING, THAT'S REALLY WHAT WE'RE DOING NOW IS LOOKING 16 AT THE INTERFACE IN THE ELECTRICAL MECHANICAL CABLE TRAY AREA, 17 ALL THAT, PUT THAT TOGETHER, TO SAY, IS THERE A PROBLEM 18 RELATIVE TO A GIVEN ORGANIZATION, GIVEN DISCIPLINE 19 ACROSS-THE-BOARD. 20 MR. LEVIN: MAYBE I'M ASKING SOMETHING TOO PREMATURE. 21 I'M TRYING TO ELICIT A FEELING FOR WHETHER OR NOT THESE THINGS 22 ARE, IN FACT, IN YOUR OPINION, ISOLATED TO THIS ONE PARTICULAR 23 DISCIPLINE, WHETHER IT BE MECHANICAL OR HOWEVER YOU WOULD LIKE 24 TO CHARACTERIZE IT. 25 MS. WILLIAMS: IT'S JUST SLIGHTLY PREMATURE. YOU 26 WILL.SEE THAT IN THE DESIGN CONTROL LISTING THAT THERE IS 4 27 THINGS WE'RE LOOKING AT, AND THOSE QUESTIONS NEED TO BE 28 ANSWERED BY US. Sy,'",'jCylll DOIDGE & CARROLL ,3, o g,,, CERTIFIED SHORTH AND REPORTERS Cow %" oa%a%o witiasi3396 DEPO 5tTION NOTARIES disi e32 i t is

89 1 MR. LEVIN: THE PROBLEM WE'RE HAVING WITH YOUR m -i 2 LISTINGS, THEY ARE OF SUCH A GENERAL NATURE, IT DOESN'T GIVE US 3 ENOUGH INSIGHT TO HOW THAT GOT ON THE PUNCH LIST. 4 MS. WILLIAMS: I UNDERSTAND YOUR SITUATION. AND WE 5 WILL TRY TO DO WHAT WE CAN TO EXPEDITE THOSE ASPECTS OF REVIEW 6 THAT WILL BEST AID YOUR WORK. THE KINDS OF THINGS YOU ARE 7 ASKING RIGHT NOW ARE THE PROGRAMMATIC TYPE THINGS YOU PEOPLE DO 8 WANT TO KNOW BECAUSE YOU ARE TRYING TO SET OUT TO DO A PLAN TO 9 ADDRESS THESE THINGS, YET WE CAN'T DO THEM UNTIL WE HAVE ALL 10 THE FACTS IN. AND IT'S BECOME NECESSARY TO DO IT CROSS-PHASE, 11 WHICH WAS NOT ORIGINALLY INTENDED. 50 THAT'S WHY WE'RE NOT 12 QUITE ON TOP OF THAT YET. 13 MR. LEVIN: I'M INTERESTED IN UNDERSTANDING THE 14 DEGREE OF, QUOTE, TESTING YOU HAVE DONE TO VERIFY CERTAIN 3 1 15 HYPOTHESES SO WE KNOW AND GET A FEELING FOR HOW MUCH, IF ANY, 16 ADDITIONAL TESTING -- YOU WANT TO SEE IF THE SAME SITUATION 17 EXISTS ELSEWHERE. 18 MS. WILLIAMS: THE LIKELIHOOD THAT WE WOULD BE 19 GOING -- 20 MR. LEVIN: WE WANT TO TAKE AS MUCH ADVANTAGE OF YOUR 21 INDEPENDENT WORK AS WE CAN TO TRY TO HELP FOCUS WHAT WE HAVE TO 22 DO IN THAT REGARD. KNOWLEDGE OF HOW -- 0F HOW YOU'RE TESTING 23 TO VERIFY EXTENT OF ANYTHING IS VERY IMPORTANT TO US. 24 MR. STUART: ONE, I THINK THERE IS A LOT MORE 25 INFORMATION IN THE DOCUMENT YOU RECEIVED TODAY WHICH WILL AT 26 LEAST ALLOW YOU TO REVIEW THE FOUR OR FIVE REFERENCES THAT ) 27 MIGHT HAVE FORMED THE BASIS OF A THREE-SENTENCE ISSUE THAT YOU l 28 HAVE SEEN IN THE PAST. san amaNc'sto DOIDGE & CARROLL ''3'"O cos,..cos,. CERTIFIED SHORTHAND REPORTERS CowN" sa i s saes DEPOSITION NOTARIES iaisi os2 i ns

e 90 1 AND I SUGGEST THAT THE STARTING POINT, YOU TAKE A m 5 2 LOOK AT THOSE DOCUMENTS. I THINK IN MANY CASES NANCY AND 3 REVIEWERS HAVE GONE THROUGH QUITE A BIT OF DETAIL AS TO WHY 4 THEY BELIEVE THAT THERE'S A CERTAIN ISSUE. I THINK THAT'S 5 POINT ONE. 6 SECONDLY, I BELIEVE THAT WE HAVE HAD AN ONGOING 7 PROCESS, AND THE BASIS OF FORMING A SENIOR REVIEW TEAM TO LOOK 8 AT THE POSSIBLE GENERIC IMPLICATIONS OF A SPECIFIC ISSUE, 9 WHETHER IT BE ACROSS THE PLANT OR WHETHER IT BE ACROSS OTHER 10 DISCIPLINES, COULD SOMETHING THAT WAS FOUND IN THE STRUCTURAL 11 AREA HAVE IMPLICATIONS IN THE CABLE TRAY AREA, AS AN EXAMPLE. 12 I THINK THE SENIOR REVIEW TEAM WAS FOUNDED PARTLY TO 13 TAKE ADVANT4GE OF THEIR YEARS OF EXPERIENCE, REALLY, TO TAKE A 14 LOOK AT THAT QUESTION. AND, SECONDLY, I BELIEVE THAT THE T I 15 SENIOR REVIEW TEAM'S ROLE IN THAT RESPECT IS CERTAINLY NOT 16 COMPLETE. 17 THERE ARE STILL -- THEY WILL STILL BE TAKING A LOOK 18 AT EACH OF THESE ISSUES TO DETERMINE WHETHER THERE ARE GENERIC 19 IMPLICATIONS THAT HAVE NOT BEEN SPECIFIED. 20 AND I THINK A THIRD ASPECT OF THIS IS THAT WE'RE 21 INTENDING IN THE DOCUMENT THAT WE'RE TRYING TO PRODUCE IN THE 22 NE XT 10 DAYS OR SO, TO TRY TO REALLY CONDENSE DOWN ISSUES TO 23 WHAT WE PERCEIVE AS BEING THE CORE ISSUE, AND DEALING WITH THAT 24 CORE ISSUE FROM YOUR PEOPLE'S POINT OF VIEW, I THINK WOULD 25 ALLOW US TO BE'ABLE TO SATISFY SOME OF THE CONCERNS THAT MIGHT 26 BE FOUR OR FIVE DIFFERENT FACETS, REALLY, OF THAT GENERIC OR 27 CORE ISSUE. ) 28 I THINK THE LAST ASPECT IS THE ONE THAT ED BLACKWOOD 5'* *",'jC ',s,e o DOIDGE & CARROLL cas,,,eo,,, oa%a%o CERTIFIED SHORTHAND REPORTERS cou%tv 44isi asi ases DEPOSITION NOTARIES ' O ' 8 8 ~ ' ' ' S

91 1 AND NANCY WERE DISCUSSING, WHICH IS THAT WE HAVE A MAJOR REVIEW s -i 2 EFFORT IN THE -- I THINK WHAT WE'RE REFERRING TO, THE DESIGN 3 CONTROL AREA WHICH HAS SOMETHING LIKE A FOUR TO SIX-WEEK 4 SCHEDULE, AND WE'RE JUST IN THE INFANCY STAGES OF REALLY TAKING 5 A LOOK AT THAT. 6 ALL THOSE THINGS RE GOING ON. AS WE GET DATA, WE'LL 7 TRY TO GIVE THAT TO YOU, BECAUSE I THINK THE MOST FAR SWEEPING 8 CONCLUSIONS OF THIS WHOLE THING COULD BE IN THAT PARTICULAR 9 AREA. WE RECOGNIZE WE WANT TO GET THAT INFORMATION TO YOU AS 10 EARLY AS POSSIBLE. i 11 MR. BLACKWOOD: DICK, WILL THE REPORT OR AP.( OTHER 12 INFORMATION THAT WE'LL RECEIVE, IDENTIFY WHETHER THE SENIOR 13 REVIEW TEAM" LOOKED AT THE ENTIRE PLANT WITH RESPECT TO A 14 PARTICULAR ISSUE OR LIMIT THEIR REVIEW TO SOMETHING SMALLER 3 15 THAN THAT, LIKE A SYSTEM OR A COMPONENT OR A PARTICULAR 16 ANALYSIS? 17 MR. STUART: I THINK NANCY MIGHT WANT TO COMMENT. 18 MS. WILLIAMS: IN A COUPLE OF CASES WE SAID WE LOOKED 19 AT IT IN ONLY A CERTAIN CONTEXT. YOU WILL SEE EXAMPLES, AS FAR 20 AS THE REVIEW TEAMS GOES, THEY GO THROUGH AND WILL BE GOING 21 THROUGH THE SAME PROCESS WHERE WE WILL LAY OUT OUR ENTIRE 22 RESULTS OF THIS CUMULATIVE EFFECTS PROGRAMMATIC IMPLICATIONS, -23 HOW WE GOT THERE, WHAT ALL THE FACTS WERE. WE WILL BE WALKING 24 THROUGH THAT WITH THE SENIOR REVIEW TEAM. 25 MR. SHULMAN: IT'S NOT AS IF THE SENIOR REVIEW TEAM 26 WILL GO THROUGH EVERY PROBLEM IN DETAIL LIKE NANCY AND HER 27 PEOPLE WILL. IT WILL BE NANCY COMING TO US, HERE'S WHAT WE ) 28 LOOKED AT, HERE'S THE RESULT, DO YOU BUY THAT FROM THE POINT OF ',Us s'43 sI o DOIDGE & CARROLL cas,,,c,,,, oana%o CERTIFIED SHORTHAND REPORTERS cov=T, ea t s: 4s13388 DEPOSITION NOTARIES 5' ess i ns

92 1 VIEW OF GENERIC IMPLICATION, WHAT'S YOUR THOUGHTS. IT'S THAT s 2 ROLE THAT THE SENIOR REVIEW TEAM PLAYS AS OPPOSED TO DETAIL. 3 MR. BLACKWOOD: BUT A VERY IMPORTANT DETERMINATION IS 4 THE EXTENT.T'O WHICH THE SENIOR REVIEW TEAM AND NANCY AND THE 5 PROJECT TEAM HAVE LOOKED, AND THAT'S IMPORTANT TO US BECAUSE IT 6 TELLS US THAT, YOU KNOW, IT GIVES US SOME POTENTIAL BOUNDARIES 7 AS TO WHAT HAS BEEN CONSIDERED IN THE PAST WHICH WE COULD RELY 8 ON. 9 MR. SHULMAN: I THINK YOU SAID THE SENIOR REVIEW TEAM, 10 NANCY, AND HER PEOPLE. IT IS A COMBINATION, BOTH. 11 MR. GUIBERT: LET ME MAKE A COMMENT. I THINK YOU 12 APPRECIATE THE SITUATION WE'LL BE IN. A NUMBER OF ISSUES 13 BEFORE THE ARC INCLUDE ISSUES REVIEWED BY YOU TODAY AS WELL AS 14 THE SPECTRUM OF OTHERS BY THE NRC. INDEED, WE ARE FACED WITH T 15 THE TASK OF ASSESSING EACH AND EVERY ONE OF THOSE FROM POINT OF 16 VIEW OF ROOT CAUSES, GENERIC IMPLICATIONS, THE GENERAL TERM 17 COLLECTIVE SIGNIFICANCE, WHICH NANCY POINTS OUT HAS MANY 18 INTERCHANGEABLE DEFINITIONS. IT'S REALLY IMPORTANT FOR US TO 19 KNOW TO WHAT EXTENT YOU CONSIDERED THAT AS WELL AS HOW YOU WENT 20 ABOUT DOING THAT. 50 WE UNDERSTAND TO WHAT EXTENT THAT'S

• 21 CONSISTENT WITH HOW WE'RE DOING IT OR THAT WE'RE INTERPRETING 22 IT CORRECTLY S0.

23 MS. WILLIAMS: YOU WILL SEE THIS IS OUR FIRST STEP 24 FOR US, TO TRY AND HELP YOU PUT IT IN ONE PLACE, AT LEAST, OUR 25 PART. I ALSO RECOGNIZE THIS IS STILL A LARGE VOLUME OF PA PE R 26 TO DEAL WITH AND RESEARCH. 27 AND WHAT YOU WILL FIND THAT WE CAN MAYBE MAKE 3 28 YOUR LIFE A LITTLE EASIER BY KNOWING THAT YOU NEdDED CERTAIN s % sanc.sco DOIDGE & CARROLL '*3" cos,.. cost. CERTIFIED SHORTMAND REPORTERS c ov%T' .ainf4Naase DEPOSITION NOTARIES '3#'

e e ) 93 1 PIECES OF INFORMATION MORE THAN OTHERS, AND THAT'S GOOD FOR US s -( 2 TO KNOW, HOW DEEP DID YOU LOOK, WHERE DID YOU LOOK, HOW MANY 3 SYSTEMS. A LOT OF THAT IS IN THE RESOLUTIONS SECTION OF 4 OBSERVATIONS. WE'LL SAY, SAMPLE TOTAL PROBLEMS, 50 PERCENT 5 HERE'S THE RESULTS. ON THIS BASIS WE CLOSE IT OUT. 6 SO SOME OF THAT I S, FOR THE MOST PART, IN THE 7 RESOLUTION AND OBSERVATIONS, AND THE EXCEPTION OF PHASE 4, MOST 8 0F THE ITEMS THAT ARE IN HERE ARE OBSERVATIONS AND YOU WILL BE 9 ABLE TO GET THAT FROM THE REPORTS, BUT YOU WILL BE AT A LOSS ON 10 PHASE 4. I KNOW THAT'S A PIECE OF INFORMATION YOU NEED, AND WE 11 CAN TRY AND FACTOR THAT IN. 12 MR. GUIBERT: I WANT TO REITERATE THE POINT, NANCY, 13 THAT CERTAIOLY KNOWING WHAT YOUR CONCLUSIONS ARE IN THAT REGARD 14 IS OF PARAMOUNT IMPORTANCE, BUT THE MEANINGFULNESS OF THAT TO 3 15 US MAY NOT BE AS GOOD IF WE DON'T UNDERSTAND HOW YOU WENT ABOUT 16 DOING I T, HOW YOU ARRIVED AT THAT. 17 MS. WILLIAMS: THAT'S IN THE RESOLUTION, WHETHER HE 18 WENT AND LOOKED AT THAT, CHECKED EVERY ONE OF THE STRESS 19 INTENSIFICATION FACTORS OR NOT, THAT KIND OF INFORMATION IS FOR 20 THE MOST PART IN THE RESOLUTION. 21 MR. GUIBERT: LOOKING AT INDIVIDUAL ISSUES AS 22 COMPOSITES OF ISSUES. 23 MS. WILLIAMS: THAT'S NOT AVAILABLE YET. 24 MR. GUIBERT: IT WOULD BE HELPFUL, NOT ONLY THE 25 RESULTS, BUT HAVE SOME UNDERSTANDING HOW ONE WENT ABOUT DOING 26 THAT SO WE WILL BE ABLE TO TRULY BE ABLE TO UNDERSTAND WHAT IT 27 MEANS TO US. ) I 28 MR. FRENCH: ALONG WITH JOHN GUIBERT'S QUESTION, I aa]c s,co DOIDGE & C ARROLL sa co y,,,go,,, CERTIFIED SHORTHAND REPORTERS cou%Tv o g.,, sa i si a s i.ssee DEPOSITION NOTARIES eaiseesa.iiis

'a 94 1 HAVE ONE. I THINK IT'S BEEN ANSWERED. I WANT TO BE SURE I .m -4 2 UNDERSTAND IT. IF I DON'T, MAYBE YOU CAN DESCRIBE IT IN YOUR 3 REPORT. 4 MY ORIGINAL QUESTION WAS TO ASK YOU WHAT WAS A CYGNA 5 MANAGEMENT REVIEW PROCESS THAT YOU WERE GOING TO SUPPLY TO COME 6 UP WITH THE ROOT CAUSES AND CONCLUSIONS. I THINK I HAVE HEARD 7 THAT'S THE SENIOR REVIEW TEAM. I WOULD SURE LIKE TO SEE 8 SOMEPLACE A DESCRIPTION OF HOW THEY ARE GOING TO DO THAT. 9 DID YOU CONSIDER IN MAKING UP THAT SENIOR REVIEW TEAM 10 PEOPLE WITH INDUSTRYWIDE MANAGEMENT AND EXPERIENCE AND 11-MANAGEMENT SYSTEMS OF THE TYPE YOU ARE REVIEWING? 12 MS. WILLIAMS: I WANT TO CORRECT ONE THING.

FIRST, 13 THE SENIOR REVIEW TEAM WON'T ACTUALLY DO I T, THEY WILL REVIEW 14 THE RESULTS OF THAT REVIEW AND THE BASIS.

T 15 MR. GUIBERT: OVERVIEW, RIGHT. 16 MS. WILLIAMS: DO YOU WANT TO ADDRESS THE SENIOR 17 REVIEW TEAM AND WHO IS ON IT AS FAR AS THE SECOND PART OF THE 18 QUESTION? 19 MR. STUART: I WILL TRY. THERE WAS A CURVE BALL. 20 MR. FRENCH: YOU CAN ADDRESS IT NOW OR LATER, 50 WE'LL 21 UNDERSTAND THE PROCESS, 50 IT WILL BE MEANINGFUL. 22 MR. STUART: THERE ARE SEVERAL DOCUMENTS SPELLING 23 THAT OUT, WHO THE ORIGINAL MEMBERS WERE, WHEN IT WAS FORMED, 24 AND WHAT THEIR CHARTER WAS. AND THERE HAS BEEN REALLY ONE 25 CHANGE IN THE SENIOR REVIEW TEAM MEMBER TODAY. BOB KENNEDY WAS 26 ON THE ORIGINAL TEAM, MIKE SHULMAN WAS THE CHAIRMAN OF THE 27 COMMITTEE, AND SPENCE BUSH WAS ON THE ORIGINAL SENIOR REVIEW ) 28 TEAM.

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o o 95 1 FOR THE SAKE OF SOME OF THE PEOPLE HERE WHO AREN'T 2 QUITE FAMILIAR WITH THE BUSINESSES OF EACH OF THE INDIVIDUALS, 3 SPENCE BUSH WAS A PREVIOUS ACRS MEMBER FOR 12 YEARS, AND IF HE 4 HASN'T SEEN EVERY SYSTEM IN THE BUSINESS IN EXCRUCIATING DETAIL, 5 I DON'T KNOW WHO HAS. 6 WE LOOK TO SPENCE, REALLY, TO PROVIDE THE LARGEST 7 OVERVIEW OF WHAT THE IMPLICATIONS OR GENERIC IMPLICATIONS MIGHT 8 HAVE BEEN FOR ALL THESE SYSTEMS. 9 BOB KENNEDY, WHO WAS ON THE ORIGINAL, IS PROBABLY ONE 10 OF THE FOREMOST ENGINEERING MECHANICS EXPERTS IN THE UNITED 11 STATES TODAY, AND ACTUALLY HIS SPECIALTY IS SEISMIC ANALYSES. 12 HE WAS ON THE SENIOR -- HE WAS ON THE NRC'S SENIOR 13 SYSTEMATIC VALUATION PROGRAM REVIEW TEAM, PLAYED A MAJOR ROLE 14 IN THAT EFFORT. AND CERTAINLY IS VERY, VERY FAMILIAR WITH ALL T 15 0F THE ENGINEER MECHANICS' ASPECT OF THIS ENTIRE REVIEW AND, IN 16 FACT, I THINK HIS AREA OF EXPERTISE IS RATHER BROAD, BROADER 17 PROBABLY THAN OUR SCOPE. 18 AND MIKE SHULMAN HAS BEEN A MANAGER IN THE INDUSTRY 19 FOR WESTINGHOUSE. I BELIEVE THAT'S THE SAME TYPE OF SYSTEM AT 20 IMPEL FOR SIX YEARS AS A MANAGER IN THIS ENTIRE ENGINEERING 21 MECHANICS, AS WELL AS A MANAGER AT CYGNA. 22 BOB KENNEDY, FOR VARIOUS REASONS, COULDN'T CONTINUE 23 HIS ROLE, AND WE REPLACED BOB KENNEDY WITH BOB NICHOL. SORRY 24 FOR LEAVING OFF THE DOCTORS, BY THE WAY, OF THESE GENTLEMAN. 25 THEY ALL HAVE THEM, ALL EXCEPT MIKE. BOB NICHOL HAS A LONG 26 ASME BACKGROUND AND RECORD, MOST RECENTLY, I BELIEVE, WITH EPRI, 27 HAS WORKED ON VARIOUS REVIEW TEAMS, SENIOR REVIEW TEAMS IN THE g I 28 PAST, ONE OF WHICH HE AND I WORKED ON TOGETHER. AND I THINK saw saa%cisco DOIDGE & CARROLL *5'8" cos,. cos,. CERTIFIED SHORTHAND REPORTERS CD #%T' .4,sM.'a3,e DEPOSITION NOTARIES '**'3#'

a 96 1 REPLACES BOB KENNEDY IN TERMS OF HIS -- THE AREA 0F EXPERTISE 2 PROBABLY WITH A SLIGHTLY MORE PIPING, PIPE SUPPORT ASME 3 BACKGROUND, A LITTLE BIT LESS SEISMIC ANALYSIS AND EARTHQUAKE 4 ENGINEERING. 5 OUR GOAL WITH THE SENIOR REVIEW TEAM WAS TO SELECT 6 THREE OF THE MOST PROMINENT I NDI VIDUALS IN THE INDUSTRY WHO 7 COULD DO A SANITY CHECK ON THE REVIEW THAT SOMETIMES THE 8 INDIVIDUAL REVIEWERS MIGHT HAVE GOTTEN TOO CLOSE TO THOSE 9 ISSUES. 10 MR. FRENCH: THAT'S GOOD. THAT'S WHAT I WAS LOOKING 11 FOR, WHO WILL APPROVE THE FINAL REPORT, WHERE IS THE STAMP OF 12 APPROVAL, AT THE PROJECT LEVEL, OR NANCY. 13 MR. STUART: FOUR PHASES WITH A SLIGHTLY DIFFERENT 14 SCOPE. I THINK THE ANSWER HAS ALSO BEEN A MOVING TARGET FROM T 15 CYGNA'S POINT OF VIEW, THE FINAL REPORT WILL BE APPROVED BY 16 MYSELF. 17 MR. BLACKWOOD: THAT'S ALL I HAVE, NANCY, THANK YOU. 18 MR. LEVIN: NANCY, I BELIEVE WE HAVE GOTTEN TO THE 19 END OF WHAT I THINK WE CAN ACCOMPLISH, AT LEAST AT THIS STAGE. 20 I HOPE THERE WILL BE FUTURE INTERACTIONS TO GET INTO MORE 21 DETAIL TYPES OF DISCUSSIONS. I WOULD LIKE TO ASK IF THERE ARE 22 ANY OTHER COMMENTS ON THE PART OF THE CPRT TEAM. 23 MR. GUIBERT: SOMETHING OCCURS TO ME. I DON'T KNOW 24 IF YOU WORKED THIS OUT. LOOKS LIKE THERE IS MASSIVE REFERENCES 25 HERE, PRESUMABLY ALL THESE DOCUMENTS EXIST HERE. I HOPE YOU 26 WILL MAKE THE ARRANGEMENTS FORTHWITH TO GET YOUR HANDS ON THEM, 27 EITHER THROUGH HERE OR TUGCO. ) I 28 MR. LEVIN: I DON'T SEE THAT AS A MAJOR PROBLEM. l saw sma%c+:p DOIDGE S CARROLL 5'3*"' cos,,,cos,. CERTsSIED SHORTHAND REPORTERS cou%tv ,,,U,"[3$n DEPOSITION NOTARIES ' S ' ' 33 ' ' ' ' 8

97 1 WITH THAT. IF THERE ARE ANY COMMENTS THAT ANYONE WISHES TO 2 MAKE, OBSERVATION. 3 MR. NOONAN: I'LL IDENTIFY MYSELF, VINCE NOONAN, 4 WE'RE HERE AS OBSERVERS TODAY SO WE'RE NOT HERE TO COMMENT, 5 TECHNICALLY, JUST SIT HERE AND LISTEN. 6 A COUPLE OF THINGS I WOULD LIKE TO CLARIFY, THIS 7 RECORD WILL BE GOING TO THE BOARD, 50 ANY ALL HANDOUTS SHOULD 8 BE INCLUDED IN THE TRANSCRIPT WITH THE TRANSCRIPTS, AND I 9 ASSUME, JOHN, YOU ARE GOING TO MAKE THE BOARD NOTIFICATION. 10 A LITTLE BIT IN LINE WITH WHAT DICK STUART WAS 11 TALKING ABOUT HERE. DR. BUSH EARLIER RAISED AN ISSUE TALKING 12 ABOUT THE STEAM HAMMER, WATER HAMMER, AND THE SNUBBER ISSUES. 13 I THINK I REMEMBER BACK IN 1975 WE TALKING TO DR. BUSH WITH HIS 14 MEMBERS ON THE ACR AND I WAS UP THERE SWEATING UNDER THE LIGHTS, T g 15 50 TO SPEAK, TALKING. THE ISSUE IS NOT NEW TO THE INDUSTRY. 16 THE AEOD REPORTS ARE RECENT, THEY HAVE BEEN GOING BACK AND 17 GATHERING DATA ON THEM. 18 DR. BUSH, MAYBE YOU CAN CLARIFY A LITTLE BIT. I KNOW 19 YOU HAVE BEEN INVOLVED MORE THAN I HAVE. 20 MR. BUSH: PERHAPS I SHOULD. FOR THE RECORD, I HAVE 21 BEEN WORKING FOR THE LAST YEAR AND A HALF ON A PROJECT FOR THE 22 NRC RELATED TO AGING ON SNUBBERS. AND IN THE PROCESS I, 23 BECAUSE OF YOU MIGHT SAY, A LONG-STANDING INTEREST THAT VINCE 24 MENTIONED THAT GOES BACK ROUGHLY 20 YEARS IN THIS AREA, I HAVE 25 RATHER STRONG OPINIONS, NOT NECESSARILY CORRECT, I RECOGNIZE, 26 BUT STRONG OPINIONS. 27 THE ISSUE THAT WE'RE TALKING ABOUT IS A DIRECT g I 28 FUNCTION OF THE FACT THAT BECAUSE OF THE PROBLEMS THAT HAVE Sy,'"^] C ',5,C O DOIDGE & CARROLL cos,,,co,,, CERTIFIED SHORTH AND REPORTERS cov%Tv o g,go sense ass saes DEPOSITION NOTARIES ' S ' 5 3 2 ' ' ' ' S . m.

98 1 OCCURRED WITH HYDRAULIC SNUBBERS, THE INDUSTRY HAS MOVED TO m -i 2 MECHANICAL SNUBBERS. THE MECHANICAL SNUBBERS ARE FINE, EXCEPT 3 THEY HAVE CERTAIN CHARACTERISTICS THAT ARE UNDULY UNDESIRABLE, 4 NAMELY, UNDER SEVERE LOADS THEY LOCK UP INSTEAD OF SIMPLY NOT 5 ACTING AT ALL. 6 AND THIS, UNFORTUNATELY, HAS BEEN A PHENOMENON THAT 7 HAS BEEN OBSERVED REPEATEDLY WITHIN THE LAST 18 MONTHS OR SO. 8 I HAVE DOCUMENTED THESE GOING BACK FOR ABOUT 20 YEARS IN A 9 REPORT THAT YOU CAN'T HAVE YET, BUT SHOULD BE OUT SOMETIME IN 10 THE NEXT THREE TO SIX MONTHS. 11 BUT THE BOTTOM LINE, FUNDAMENTALLY, IS THAT UNDER -- 12 THEY MAY HANDLE SEISMIC LOADS ADEQUATELY, BUT THEY DO NOT 13 HANDLE SEVERE DYNAMIC LOADS. AND PARTICULARLY IN AREAS WHERE 14 THEY ARE WAY UP IN THE AREA SUCH AS THEY ARE, OR SOMETHING OF i 15 THAT NATURE, IN THE PROCESS OF LOCKING UP, YOU HAVE A NUMBER OF 16 OPTIONS. 17 WHEN YOU HEAT UP, THE COOL DOWN, THAT IS, .l TEARS 18 OUT OF THE WALL. THAT HAPPENED A NUMBER OF TIMES. THE OTHER 19 IS, SOMETHING ELSE GIVES. THE THIRD ONE, THEY REINFORCE 20 EVERYTHING AND THEN YOU OVERSTRAIN A COMPONENT AND, OBVIOUSLY, 21 IN SOMETHING LIKE A VALVE OPERATOR THAT'S SITTING WAY UP IN THE 22 AREA, YOU GET A BENDING MOMENT, AND YOU ASK YOURSELF, DOES THE 23 VALVE OPERATE BECAUSE WE ESSENTIALLY DEFORMED THE SHACK, OR 24 SOMETHING OF THAT NATURE, SO ONE HAS TO LOOK AT THESE DETAILS. 25 I ADMIT THAT THIS IS A VERY GLOOMY VIEW, IN FACT, IT 26 MAY NOT BE THAT BAD. AS I INDICATED, I'M AWARE OF SEVERAL 27 SYSTEMS WHERE ONE WATER HAMMER HAS LOCKED UP EVERY MECHANICAL 3 28 SNUBBER FROM ONE END OF THE SYSTEM TO THE OTHER. SO IT IS A san '=ascisco DOIDGE & CARROLL .'((" CERTIFIED SHORTH AND REPORTERS co iaisi asi asos DEPOSITION NOTARIES

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99 1 REAL PROBLEM. 2 AND I THINK THERE ARE A VARIETY OF ANSWERS. ONE OF 3 THE THINGS I THINK DON LANDERS COMMENTS THAT SOME OF YOU HAVE 4 SEEN RELATE TO, DON AND I HAVE BEEN WORKING CLOSELY IN THIS 5 AREA, IS WHAT WE'RE TRYING -- IS TO GET -- COME UP WITH A 6 TECHNIQUE THAT WILL COME UP TO GET RID OF 9U PERCENT OF THE 7 SNUBBERS IN THE PLANT, WHICH I THINK HAS ADVANTAGES. W E, IN 8 FACT -- WRC BULLETIN 300 IN THIS RESPECT AS A SPECIFIC ONE. 9 THIS IS A PART OF THIS OVERALL PICTURE I THINK ONE HAS TO LOOK 10 AT IN ORDER TO MINIMIZE THE IMPACT. 11 I THINK THAT 'S 'JHAT VINCE WAS THINKING ABOUT. IT'S A 12 PROBLEM THAT'S BEEN WITH US A LONG TIME. IT SIMPLY HAS GOTTEN 13 MORE VISIBILITY LATELY, ONE REASON BEING THE SHIFT OF 14 MECHANICAL SNUBBERS, WHICH WAS NOT THE CASE IN '75 OR '76. T i 15 MR. LEVIN: DR. BUSH, IN THE WAY OF CLARIFICATION, SO 16 WE CAN UNDERSTAND THE SIGNIFICANCE OF YOUR FINDINGS AND WORK, 17 IT STRIKES ME A SNUBBER COULD LOCK UP, THERE'S A COUPLE OF 18 REASONS WHY IT COULD, MAYBE INADVERTENTLY BECAUSE OF SOME 19 PROBLEM WITH ITS DESIGN THAT MIGHT OCCUR OVER TIME. 20 I KNOW THERE WAS SOME EXPERIENCE WITH MECHANICAL 21 SNUBBERS WHERE THEY WOULD, QUOTE, FREEZE, UNDER NORMAL 22 OPERATIONS, CORROSION PROBABLY WAS OCCURRING, THAT WOULD CAUSE 23 THAT. THAT'S ONE CATEGORY. 24 ANOTHER CATEGORY THAT, DUE TO SOME DYNAMIC INPUT, IT 25 LOCKS UP TO SOME DEGREE. IT'S DESIGNED TO DO THAT. I'M 26 CURIOUS WITH RESPECT TO THE LATTER, AND YOUR STATEMENT A SERIES 3 27 OF THESE THINGS LOCKED, YOU KNOW -- YOU KNOW, AS A RESULT OF 1 28 WATER OR STEAM HAMMER, THEN WAS IT SOMETHING THAT SHOULD NOT (47,,*]c,',5,c,o DOIDGE & CARROLL cos,,,cos,, o4% Asp CERTIFIED SHORTHAND REPORTERS cousT* iaise asi asse DEPOSITION NOTARIES " *3*S

100 1 HAVE HAPPENED OR WAS IT JUST WASN'T ANALYZED? WERE THEY m -j 2 DESIGNED TO LOCK UP AND DIDN'T PERFORM ADEQUATELY? 3 MR. BUSH: MAYBE I SHOULD INDICATE WHAT ACTUALLY 4 HAPPENS. IF THE ACCELERATION FROM THE LOAD EXCEED A CERTAIN 5 VALUE, WHAT YOU LITERALLY DO IS YOU DAMAGE INTERNALLY INTERNAL 6 COMPONENTS TO THE POINT THAT THE SNUBBER N'O LONGER FUNCTIONS IN 7 ANY MODE, EITHER IN COMPRESSIONS OR TENSION. THAT'S WHAT CAN 8 HAPPEN IN SEVERAL INSTANCES. 9 MR. LEVIN: THAT SITUATION IS ONE WHERE IT MIGHT NOT 10 BE A PROBLEM WITH THE SNUBBER ITSELF, BUT MAY BE IN OUR 11 ESTIMATION OF THE LOAD. 12 MR. BUSH: IT COULD BE. 11'S HAPPENED A NUMBER OF 13 TIMES. YOU COULD CHANGE THE TYPE OF SNUBBER, THAT'S AN OPTION, 14 YOU COULD CHANGE THE SIZE OF THE SNUBBER, THAT MIGHT SOLVE THE T 15 PROBLEM, IT MIGHT NOT. THERE ARE SEVERAL OPTIONS OPEN TO YOU 16 UNDER THESE CIRCUMSTANCES. YOU COULD GET RID OF THE SNUBBER 17 ENTIRELY, WHICH IS WHAT I THINK A LOT OF UTILITIES SHOULD BE 18 DOING, AND YOU COULD GO TO THE SPRING LOAD SUPPORTS, THINGS OF 19 THIS NATURE, THAT PROVIDE A SIMILAR FUNCTION WITHOUT HAVING A 20 PROBLEM. 21 MR. LEVIN: DID WE HAVE ANY KNOWLEDGE ON THESE EVENTS 22 AS TO WHETHER OR NOT THOSE SNUBBERS THAT DIDN'T PERFORM 23 ADEQUATELY, HAD EXPERIENCED LOADS HIGHER THAN THEIR RATING 7 24 MR. BUSH: ONE OF THE PROBLEMS IS THE IDENTIFICATION 25 OF THAT AND, IN FACT, THE AEOD REPORT USES AN INFERENTIAL 26 APPROACH ON IT. THERE ARE OTHERS WHERE I THINK DAMAGE INSIDE 27 THE SNUBBER CLEARLY INDICATES, THERE ARE AT LEAST TWO DOCUMENTS ) 28 THAT DEAL WITH SNUBBERS TAKEN OUT OF THI, TOO, THAT PRETTY ',,'7, ",',)',',8{0 D01DGE & CARROLL ces,..eos,, CERTIFIED SHORTH AND REPORTERS cousYi oan6aso sais*4si 33ee DEPOSITION NOTARIES esa tits ~ _ _ _ __

n i o. ) 101 1 CLEARLY SHOW EXTENSIVE DAMAGE WITHIN. THESE ARE NOT ISOLATED 2 CASES. THERE ARE OTHERS OF THE SAME NATURE. 3 MR. LEVIN: DID PEOPLE INFER THAT THOSE PIECES OF 4 HARDWARE HAD EXPERIENCED LOADS HIGHER THAN DESIGNED? 5 MR. BUSH: IN SOME INSTANCES, THEY HAVE, SOME 6 INSTANCES THEY DON'T HAVE ENOUGH INFORMATION, DIFFICULTY 7 INFERRED. 8 MR. NICKELL: DIFFICULTY INFERRED. 9 MR. BUSH: CAN'T PROVE THAT IT HAPPENED, BUT 10 EVERYTHING INDICATES IT HAPPENED. 11 MR. LEVIN: THE REASON FOR THE QUESTION, SO WE CAN 12 UNDERSTAND THE PROBLEM THAT MIGHT NEED TO BE ATTACKED IN 13 RESPONSE TO DON LANDERS' CONCERNS AND GENERAL ISSUE. 14 MR. GUIBERT: ALONG THAT LINE SO -- SORRY, I THOUGHT T 15 YOU WERE FINISHED. 16 MR. LEVIN: AS TO WHETHER OR NOT OUR PROBLEM SIMPLY 17 IS ARE THESE THINGS BEING USED IN APPLICATIONS THAT ARE 18 INAPPROPRIATE, OR IS IT OUR KNOWLEDGE OF THE ENVIRONMENT TO 19 WHICH WE ARE SUBJECTING THEM TO AND THE UNCERTAINTY OF THAT? 20 IT SEEMS TO ME THERE IS A COUPLE OF POSSIBLE ISSUES 21 HERE. 22 MR. BUSH: LET ME ANSWER IN PART. IN THIS RESPECT, I 23 HAVE BEEN RATHER ACTIVELY PARTICIPATING IN AN NRC SENIOR REVIEW 24 TEAM THAT WAS ESTABLISHED BY THE EXECUTIVE DIRECTOR FOR 25 OPERATIONS TO LOOK AT ALL OF THE PIPING PROBLEMS AT ONCE. WE 26 DID, INDEED, LOOK AT THIS ASPECT. 27 IN FACT, IT IS CITED AS A SPECIFIC ONE IN THE ) 28 DOCUMENT THAT'S NOW IN THE OPEN LITERATURE, THE VOLUME IV ON sa% ema%cesco DOIDGE & CARROLL "'S'S'3C cos,..c3s,. CERTIFIED SHORTHAND REPORTERS C ovN" .4,sfah33eo DEPOSITION NOTARIES

s r t } 102 1 DYNAMICS EFFECTS, AS AN EXAMPLE OF THE TYPE OF SITUATION THAT 9 2 ONE CAN GET INTO. 50 IT'S A RECOGNIZED PROBLEM. AND, IN FACT, 3 THE NRC IS NOW ON RECORD AS TO MOVING AWAY FROM THIS, DEPENDS 4 ON A DEGREE WHICH REGION YOU ARE I N, BUT CERTAINLY THE 5 RECOMMENDED POLICIES ARE TO RETREAT FROM WHERE WE ARE NOW, 6 BECAUSE I THINK THE FEELING IS THAT BUBBLING AND COLLAPSE IS A 7 LOT LESS PROBABLE THAN RATCHETING. A FLEXIBLE SYSTEM IS BETTER, 8 WHICH SAYS YOU GET RID OF A LOT OF SUPPORTS. 9 THEN YOU GET INTO N0ZZLE, WHICH YOU HAVE TO CONSIDER, 10 BUT IN MANY RESPECTS THAT'S THE SIMPLER. I MIGHT INDICATE IN 11 THIS RESPECT JOHN STEVENSON ON ONE DOCUMENT HAS DONE AN 12 EXTENSIVE SURVEY TO PIPING DAMAGE IN EARTHQUAKES, PARTICULARLY 13 OVER THE LAST TWO DECADES, AND THE ONE THING THAT SURVIVES VERY 14 WELL IS PIPING, IS FLEXIBLE PIPING. T i 15 MR. GUIBERT: ON ANOTHER BENT, SINCE YOU OBVIOUSLY 16 HAD THE ADVANTAGE OF LOOKING AT THE REPORT, AS YOU ALLUDED TO, 17 THIS IS NOT A NEW PROBLEM AND IT I S, INDEED, A GENERIC PROBLEM, l 18 PERHAPS THERE HAVE BEEN SOME MORE RECENT EVIDENCES OF ITS 19 MANIFESTATIONS DUE TO SWITCHOVER FROM HYDRAULIC SNUBBERS TO 20 MECHANICALS RECENTLY. DID THE AEOD REPORT RESULT IN ANY 21 RECOMMENDATIONS THAT ARE CURRENTLY BEFORE THE STAFF WITH 22 RESPECT TO RESPECT TO -- HOW TO DEAL WITH THIS ISSUE IN THE 23 LICENSING PROCESS AS WELL AS THE OPERATING VERNACULAR ARENA. 24 MR. BUSH: THEY MADE RECOMMENDATIONS, BUT WHETHER 25 THEY ARE BEFORE THE STAFF, I CAN'T SAY. I DO KNOW THE PIPING 26 REVIEW COMMITTEE CONSIDERED THIS, AMONG OTHER THINGS, AND 27 CERTAINLY IN THAT RESPECT, NO. VINCE MIGHT BE SETTER UP TO ) I 28 DATE ON THAT. CERTAINLY IT IS A CONTINUING ISSUE THAT THE san ena%c'sco DOIDGE & CARROLL ba s see costaa costa CERTIFIED SHORTHAND REPORTERS c ow%" saiN stee DEPOSITION NOTARIES *3#' ...T-.

o ) 103 1 STAFF HAS LOOKED AT, AND AT LEAST ON THE PART OF THE SENIOR m 2 REVIEW COMMITTEE, THEY GAVE IT CONSIDERABLE ATTENTION. 3 MR. NOONAN: JOHN, I WILL GO BACK AND CHECK BOB ~ 4 SOSNICK, FROM THE MECHANICAL ENGINEER, MIGHT HAVE A BETTER 5 PERSPECTIVE, BUT I'LL FIND OUT FOR YOU. 6 MR. GUIBERT: CLEARLY, THIS IS AN ISSUE THAT 'EEDS N 7 TO BE CONSIDERED. I'M NOT SURE AS TO WHAT STANDARD OF 8 EXCELLENCE WE'RE SHOOTING FOR, GIVEN THAT PERHAPS THERE ARE 9 SOME CHANGING -- POTENTIALLY CHANGING REGULATORY POSTURE 10 REQUIREMENTS IN THIS ARENA. 11 MR. NOONAN: I THINK BASED ON THE NORMAL REVIEW DONE 12 BY THE MECHANICAL ENGINEERING BRANCH, THEY ARE LOOKING FROM THE 13 LATEST STAT 5 OF THE ART, 50 TO SPEAK, FOR THAT PARTICULAR 14 REVIEW PROCESS. I KNOW THAT'S GOING TO APPLY TO THIS PLANT T ( 15 HERE. WHAT'S HAPPENED SINCE THE AEOD REPORTS, I'M NOT SURE. 16 I'LL GO BACK AND DOUBLE CHECK. 17 MR. BUSH: BOSNICK HAS INTERFACED EXTENSIVELY, HE'S A 18 MEMBER OF THE PVRC STEERING COMMITTEE, 50 WHAT IS HAPPENING 19 THERE IS BEING MIRRORED IN SUGGESTED CHANGES WITHIN THE 20 MECHANICAL ENGINEERING BRANCH I THINK IS A PARTIAL ANSWER. 21 MR. STUART: OFFERING ONE MORE THOUGHT. THE QUESTION 22 STARTED OUT STEAM HAMMER AND ENDED UP FLEXIBLE PIPING. I 23 WANTED TO POINT THAT OUT TO EVERYONE, WE HERE AT CYGNA ARE 24 EVALUATING IT AGAINST THE LICENSING BASIS. I WANT TO MAKE THAT 25 POINT VERY CLEAR. THE ENTIRE ISSUES THAT ARE BEING DISCUSSED 26 HERE ARE RELAXATION, POTENTIAL FUTURE RELAXATION OF THOSE 27 REQUIREMENTS, AND WE, IN FACT, USE SOME OF THOSE RELAXATION ON ) I 28 A LICENSING BASIS, SPEC IFICALLY TO THE PVRC CRITERI A. THAT'S saw raa%cisco DOIDGE & CARROLL ''3'**0 c osta, cost. CERTiklED SHORTH AND REPORTERS C 0 d% .. i 33ee DEPOSITION NOTARIES

a 104 1 NOW BECOMING RATHER COMMON PRACTICE IN OPERATING PLANTS GOING t 2 BACK FOR RETROFIT ANALYSIS. 3 MR. SHULMAN: EVEN ON SOME FAIRLY NEW PLANTS. 4 4 MR. STUART: THAT'S NOT BEEN THE STANDARD OF OUR 5 REVIEW, THEREFORE, CERTAINLY THAT'S A FERTILE AREA FOR FUTURE 6 DISCUSSION WITH THE NRC IN TERMS OF TUGCO WISHING TO POSSIBLY 7 DISCUSS GETTING TREATMENT SIMILAR TO WHAT SOME OF THE NTOL'S OR 8 OPERATING PLANTS ARE RECEIVING. 9 I WANTED TO OFFER ONE OTHER POINT, AND I THINK IT'S 10 IMPORTANT IN THIS REGARD. THAT I S, THAT THE -- BACK TO THE 11 QUESTION OF THE STEAM HAMMER, WHICH I THINK STARTED THE 12 DISCUSSION. 13 I'THINK IN THAT PARTICULAR AREA, AS INDICATED EARLIER, 14 WE HAVE LOOKED RATHER EXTENSIVELY AT THE RESULTS OF RELAP h 15 ANALYSIS CARRIED FURTHER ON DOWNSTREAM, BUT HAVE NOT REALLY 16 LOOKED AT EITHER THE INPUT TO OR THE ANALYSIS ITSELF, WHICH 17 MIGHT BE. THENCE, IF THIS QUESTION NEEDS TO BE ADDRESSED, DON 18 LANDERS MIGHT BE A PLACE WHERE SOMEONE NEEDS TO TAKE A FURTHER 19 LOOK. 20 MR. BUSH: THE LATTER PART, I WAS REALLY ADDRESSING 21 THE SPECIFIC ISSUE OF A MECHANICAL SNUBBER AT A GIVEN LOCATION 22 WHERE YOU HAD A STEAM HAMMER, WHICH THEN GETS YOU INTO ONE. 23 ANY ACTIONS THAT ARE TAKEN THEREAFTER, ARE ANOTHER MATTER, BUT 24 THAT PROBLEM IN ITSELF HAS BEEN ADDRESSED AND HAS GIVEN 25 CONSIDERABLE SIGNIFICANCE. 26 MR. STUART: I FOLLOW YOU. 27 MR. LEVIN: ANYTHING ELSE ON YOUR PART, VINCE? 3 8 28 MR. NOONAN: NO. I'M FINISHED. THANK YOU. s ,,je,sco DOIDGE & CARROLL ena mtma costa CERTIFIED SHORTHAND REPORTERS COAT

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4 105 1 MR. LEVIN: ANY OTHER OBSERVERS THAT WOULD LIKE TO m -f. 2 MAKE A COMMENT AT THIS TIME? 3 MR. NOONAN: REPRESENTATIVE OF CASE, DO YOU WISH TO 4 TAKE A MINUTE? 5 MR. VAN METER: ME, NO, BUT I WOULD LIKE TO COMMENT 6 ON SOMETHING BEFORE. I PRESUME THAT THAT WAS TO THE END OF THE 7 MEETING. 8 COULD I COMMENT ON THAT? 9 MR. LEVIN: I BELIEVE WE'RE AT THE END OF MEETING NOW. 10 NOW' S THE TIME TO MAKE THE COMMENT. 11 MR. VAN METER: CONCERNING THE REPORT ON THE CINCH 12 DOWN OF THE U-BOLTS, MY QUESTION WILL BE ADDRESSED TO NANCY TO 13 TALK ABOUT I T, AND I WOULD JUST LIKE TO KNOW, HAS ANY OTHER 14 ALTERNATE DESIGN OF U-BOLT AND CLAMP BEEN CONSIDERED? 3 ( 15 MS. WILLIAMS: I DON'T THINK THAT CYGNA COULD ANSWER 16 THAT. I THINK TUGCO SHOULD RESPOND. 17 MR. VAN METER: I HAVE 'NO FURTHER QUESTIONS. 18 MR. LEVIN: WITH THAT, I, PERSONALLY, AND MY 19 COLLEAGUES, WOULD LIKE TO THANK NANCY AND YOU PEOPLE FOR THIS 20 OPPORTUNITY. I HOPE WE HAVE OTHER ONES FOR THE PROGRESS OF OUR 21 PROGRAM. 22 23 24 25 26 27 3 I 28 Sy,",'^,K',sc o DOIDGE & CARROLL e,v o ec,3. o % go CERTIFIED SHORTHAND REPORTERS C OW-iaisi ass ases DEPOSITION NOTARIES '# *38 ~

s o ) 105-A 1 I, LAVERNE VIAT, a Certified Shorthand Reporter, duly 2 M qualified and licensed by the State of California, do hereby 3 certify that the foregoing transcript is a complete and accurate 4 transcription of my Touch Shorthand notes taken at the time and 5 place herein set forth. 6 7 8 10 ( f_LA1 O LAVERNE VIAT 11 Certified Shorthand Reporter C.S.R. No. 4463 12 13 14 3 15 t 16 17 18 e 19 20 21 22 23 24 25 26 27 28 i S AN FRANC'SCO DOIDGE & CARriOLL eaisi S43-s660 CERTIFIED SHORTH AND REPORTERS n,xt no DE POSITION NOT ARIE S sats 4513396

.~. = -. A p TEXAS UTILITIES CPRT MEETING ' Held at Cygna Energy Services San Francisco Office Phrch 14, 1985 Attendance List Name Company Howard Levin Tera Corp. Edward Blackwood Tera Corp. i' F. A. Dougherty Tera Corp. Douglas M. Witt Tera Corp. Chris Mortgat Tera Corp. John Guibert Tera Corp. Tony Buhl Energex Jack Redding TUGC0 Dick Stuart Cygna William Van Meter CASE John C. Minichiello Cygna Gordon Bjorkman Cygna Nancy Williams Cygna John French Delian Corp. Spottswood B. Burwell NRC/NRR/DL Annette L. Vietti NRC/NRR/DL Vincent S. Noonan NRC/ Project Director David L. Smedley Cygna James J. Oszewski Cygna Robert E. Nickell Cygna Consultant Robert W. Hess Cygna Craig Killough Cygna Terry G. Tyler Energex Spencer H. Bush Review and Synthesis Associates Robert A. Wooldridge Worsham, Forsythe, Sampel & Wooldridge Robert C. lotti EBASCO (TUGC0 Consultant) Robert E. Ballard Gibbs & Hill, Inc. Richard M. Kissinger TUGC0 William R. Horstman Cygna Darlene K. Leong Cygna l David R. Pigott Orrick, Herrington, & Sutcliffe John P..Russ Cygna l Lee J. Weingart Cygna l Arlene G. Morris Citizen f L

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[ ' d.. 4 p ;' *.O h,'- . V Revision 0 E h. c :.l f'! h '* M{y !.) H c * ' i. *- E. -.., L. : 0 i ': f. L 4

t. b h vi Page 1 PIPE STRESS Open Items and Generic Issues 1.

Mass Particioation/ Mass Point Spacing

References:

1. R.E. Ballard (G&H) letter to J.B. George (TUGCO), " Mass Participation," GTN-69454, September 14, 1984 2. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Phase 3 Open Items - Mass Partici-pation," 84042.017, September 21, 1984 3. N.H. Williams (Cygna) letter to J.B. George (TUGCO), "Pnase 3 Open Items - Mass Participa-tion," 84042.019, October 2, 1984 lewell (TUGCO) letter to N.H. Williams 4. L.M. Popp'Cygna Potential Finding Report Mass (Cygna ) Participation and the Mass Points Spacing Error in Problem AB-1-61A." December 7, 1984 5. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Phase 3 Open Items - Mass Participation and Mass Point Spacing," 84042.021, February 8, 1985 6. Cygna Pnase 3 Final Report, TR-84042-01, Revision 0, Ooservation PI-00-05, and PFR-01 Sununary: Pipe stress seismic analyses did not include sufficient modes to comply with FSAR requirements. Mass point spacing for dynamic analyses did r.ot always meet project criteria. Status: Cygna has issued Reference 5 which documents Cygna's eva-luation of the Gibbs & Hill piping reanalysis report and lists recommended actions. Awaiting response from TUGC0/Gibbs & Hill. 2. Incorrect Pipe Schedule Used for Calculation of Nozzle Allowables i

Reference:

1. Cygna Phase 1 and 2 Final Report, TR-83090-01, Revision O, Observation PI-02-05 Sussnary: Cygna noted one instance in which nozzle allowables were calculated using an incorrect wall thickness. 1 _-Q Texas Utilities Generating Company Comanche Pesk Steam Electric Station r b p 5[Aj O JL Independent Assessment Program - All Phases lilllllillllillllllllllillllll Job No. 84056 l

- -. - ~ ~ = 1 E 3/13/85 g ; r:: $a {'P. [g { 5 S h($ zh Revision 0 r,,.U.r O._.EIQ e 4 U.P k: 4 Page 2 M db4Gtua J L i PIPE STRESS Open Iteus and Generic Issues Status: Closed out based on expanded review to include pumps on diesel generator system. 3. Finite Element Model Error in Flued Head Analysis

Reference:

1. Cygna Phase 1 and 2 Final Report, TR-83090-01, Revision 0, Observation PI-03-01 Summary: The flued head finite element model was found to contain a geometry error in which some elements were improperly generated. Status: Closed based on review of 15 of the remaining 18 flued head analyses 4. Inclusion of Fluid and Insulation Weight at Valves and/or Flanges

Reference:

1. Cygna Phase 3 Final Report, TR-84042-01, Revision 0, Observation PI-00-04 and Section 5.1., Page 5-6 Summary: Cygna found that it was Gibbs & Hill's standard practice not to include fluid and insulation weight at valves and flanges. Status: Closed based on Gibbs & Hill's reanalysis showing that the effect is minor. 5. Discrepancies in Pipe Support Loads Between Analyses and Sucoort Design

Reference:

1. Cygna Phase 3 Final Report, TR-84042.01, Revision 0, Ooservation PI-00-06 2. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated August 29, 1984. Summary: Cygna found that in some instances the latest support loads were not used in the pipe support design calculations. Status: Closed. ELT E Texas Utilities Generating Company r g'{g2 i[ t Comanche Peak Steam Electric Station e Independent Assessmer,t Program - All Phases t illfililllililllllll!!!! Job No. 84056 e

.a ) I l 3/13/85 o -r -e o-(el l R h g ;.e,. d;i t :k s !!.ij t - iU: } o~ h Revision 0 Page 3 Ps.i er dML E PIPE STRESS Open Items and Generic Issues 6. Snubbers on Fisher Valves

References:

1. Cygna Phase 3 Final Report, TR-84042-01, Observation Pl-00-07 and PFR-02 2. L.M. Popplewell (TUGCO) letter to N.H. Williams (Cygna) dated July 9,1984 3. L.M. Popplewell (TUGCO) letter to N.H. Williams (Cygna) dated August 29, 1984. Sumary: The snubbers on the Fisher valve operators not qualified for the as-built loads. This issue led to questioning whether the valve itself was capable of transmitting these loads and still naintaining operability. Status: Closed based on requalification of valves and snubbers. 7. Snubbers Close to Eouionent Nozzles

Reference:

1. Cygna Phase 4 Pipe Stress Walkdown Checklists (not issued) Sumary: Cygna noted several snubbers on the CCW system which were located close to equipment nozzles. Due to tneir proximity to a rigid attachment point, the dynamic displacements at these locations will be very small such that the snubbers may not perform their intended function. Status: Closed with Cygna's recommendation that these snubbers be candidates for a snubber elimination program. 8. Lack of Traceability for ANSYS/Relao Runs

Reference:

1. Communication Report between S. Lim (Gibbs & Hill) and L. Weingart (Cygna) dated 3/8/84, 8:45 a.m. 2. Communication Report between H. Mentel (Gibbs & Hill) and J. Minichiello (Cygna) dated 3/13/84, 3:00 p.m., Revision 1 h: === Texas Utilities Generating Company = 3g5 Fj Comanche Peak Steam Electric Station Independent Assessment Program - All Phases 111111111111111ltllIIl111111 Job No. 84056

~ QN,7 E E M E".I f E Di f L'/Jeggsi;:0 [d j?. s 3/13/85 b kNs-c 'iIf EE f U1!g y ensi n 0 lg Page 4 PIPE STRESS Open Items and Generic Issues 3. Communications Reports between S. Lim (Gibbs & Hill) and L.Weingart (Cygna) dated 3/15/84, 8:15 a.m. Summary: Per reference 1, ... the original RELAP analyses for the Hain Steam were run circa 1981-1982. These files were subsequently lost and then re-generated well after the ANSYS analyses which rrede use of the RELAP data." Per reference 3 There are four programs involved in the Steam Hammer analysis: (1) RELAP (2) GHFORCE - provides imbalance loads (3) Program to convert to ANSYS format (4) ANSYS Steve has no concrete documentation linking the four for a particular loop. He will attempt to provide a tape / file list from the day files for these runs. The list provided by Gibbs & Hill did not provide the needed cross reference when compared to the ANSYS and RELAP analyses. Gibbs & Hill did provide ANSYS plots of loads at axial restraints for comparison to RELAPs plots of forcing functions. This provided sufficient assurance for Cygna to close the issue technically. Per reference 1, "The binder which is labeled "RELAP Results" for Loop 2 contains only ANSYS output." This was further evidence of improper documentation and filing for special analyses at Gibbs & Hill. FWhM Texac Utilities Generating Company Counche Peak Steam Electric Station r((p 1[ } Independent Assessment Program - All Phases lll111111111111111111ll 111 Job No. 84056

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I '.,},.L a u f, b r H di bl Page 5 PIPE STRESS Open Items and Generic issues Status: Closed technically. Open from a QA standpoint. This issue will be addressed as part of Cygna's Pnase 4 design input control review. 9. Inclusion of Sucoort Mass In Pipe Stress Analy~ sis

References:

1. Communications Report between G. Krishnan (Gibbs & Hill SSAG) and J. Minichiello (Cygna) dated 3/19/84, 8:30 a.m. 2. Gibbs & Hill letter GTN-68852 dated April 25, 1984 3. Comunications Report between H. Mentel (Gjbbs & Hill), G. Grace (EBASCO), N. Williams and L. Weingart (Cygna) dated 5/24/84,10:00 a.m. 4. ASLB Hearings, Doyle Questions #4 5. Cygna Phase 1 and 2 Final Report, TR-83090-01, Revision 0, Pipe Stress Checklist General Note 1 6. Comunications Report between D. Wade (TUGCO) and N. Williams (Cygna) dated 10/11/84, 4:00 p.m. 7. N.H. Williams (Cygna) letter to V. Noonan (USNRC), 84042.022, dated January 18, 1985 "Open Items Associated with Walsh/Doyle Allegations." Sunmary: The weight of the pipe supports was included in the stress analyses for the Main Steam Inside Containment only. In Reference 1, Cygna requested justification for this prac-tice. Gibbs & Hill responded in Reference 2, basically by pointing out the relatively massive supports associated with the nein steam lines. However, per Reference 4, the effect of this omission on support loads was shown to be as high as 24%. Status: Open. Per Ref. 7. Item 13, further Cygna review is not authorized. \\ hW""" Texas Utilities Generating Company 'g' g ' f'j Comanche Peak Steam Electric Station T T Independent Assessment Program - All Phases 1141111lll11ll1lllll111lll1111 Job No. 84056

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10. Stress Intensification Factors (SIFs)

References:

1. Cygna Phase 1 and 2 Report, TR-83090-01, Revision 0, Observation PI-00-01 2. Cygna Phase 3 Report, TR-84042-01, Revision 0, Ooservation PI-00-01 Sunmary: Cygna found numerous instances where G&H either neglected to input the required SIF (Reference 1 & 2) or miscalculated the SIF (Reference 2). Status: Closed based on expanded reviews.

11. Welded Attachments

References:

1. Cygna Phase 1 & 2 Report, TR-83090-01, Revision 0, Observation PI-00-02, PI-02-03, and PI-02-04. 2. Cygna Phase 3 Report, TR-84042-01, Revision 0, Observations PI-00-02 and PI-06-01 Sunmery: Cygna found several problems with G&H's treatment of welded attachments: l Use of an increased allowable in the evaluation of local stresses for upset and emergency combinations (Reference 1). Use of thermal expansion loads rather than load ranges for evaluation of local stresses (Reference 1). e Failure to consider local stresses in break exclusion zones (Reference 2). Failure to consider combined effects of two supports at a single welded attachment (Reference 2). e. Use of incorrect attachment size in evaluation of local stresses (Reference 1). Status: Closed based on use of rationale from later codes, recalcu-lations, and expanded reviews. l N iE 9 7:e Texas Utilities Generating Company Mej l f,j Comanche Peak Steam Electric Station 111111111111!!1111111!!!Ill111Independent Assessment Program - All Phases Job No. 84056

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12. Use of Incorrect Pioe Wall Thickness

References:

1. Cygna Phase 1 & 2 Report, TR-83090-01, Revision 0, Observation PI-01-01 Summary: Cygna found two piping segments were input to the stress analysis with the incorrect wall thickness. Status: Isolated; closed based on Cygna recalculation of stresses. 13. Inclusion of Acoropriate Responses Spectra

References:

1. Cygna Phase 1 & 2 Report, TR-83090-01, Revision 0, Observation PI-02-01 Sunmary: - Cygna noted that stress analysis AB-1-70 did not consider all the appropriate response spectra from all buildings. Status: Closed based on evaluation of the omitted spectra and expanded review. 14. Succort Location Discreoancy

References:

1. Cygna Phase 1 & 2 Report, TR-83090-01, Revision 0, Observation PI-02-02 2. Cygna Phase 3 Report, TR-84042-01, Revision 0, Checklist PI-09, Item 14 Surmary: Supports were modeled at locations outside of tolerance. Reference 1 was closed based on evaluation of stresses and states that this is isolated. Status: Closed. E1Piff2 Texas Utilities Generating Company kg l53[g Comanche Peak Steam Electric Station Independent Assessment Program - All Phases lilllillllllllillllllllllll!! Job No. 84056

= w_ . -.. ~. u.. - - 3/13/85 Revision 0 Page 8 PIPE STRESS Open Items and Generic Issues

15. Use of Incorrect dampino in Seismic Analyses

Reference:

1. Cygna Pnase 3 Report, TR-84042-01, Revision 0, Observation PI-00-03 Sunnary: Cygna noted that G&H did not consider the lower damping response spectra in some systems with mixed sized piping. Status: Closed based on expanded review. gs :n n r r. r p t:. t a E*t : E !*Ibb bhdek g {as,i t u t e.: u.t N \\ '\\ \\\\ \\ EZMM-Texas Utilities Generating Company b j 's 7,I Comanche Peak Steam Electric Station l r J A Independent Assessment Program - All Phases lillilililllllitillilillllllli Job No. 84056

) Ih,, a n rq r, Y)I r ej. ' yLb;i,i<$ e 3/13/85 .g 5 ,g-gQ ) Revision 0 k I w k%. Pa ge 1 PIPE SUPPORTS Open Items and Generic Issues 1. Box Frames With 0" Gap

References:

1. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Box Frames with 0" Gap", 84042.023, dated January 28, 1985 2. Communication Report between Rencher (TUGCO) and Minichiello (Cygna) dated 3/19/84, Item 2 3. L. M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated April 19, 1984 4. L. M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna), Attachment B, dated June 8,1984 5. " Affidavit of John C. Finneran, Jr. Regarding Consideration of Local Displacement and Stress" Original support calculations did not consider the ef-Sumary: feet of the box frame and pipe interaction (Reference 2). Later TUGC0 calculations (References 4 and 5) used unconservative temperature and frame stif fness assump-tions. Later calculations did not include effects of Cygna comments. Status: On hold pending TUGC0 response to Reference 1. 2. Desion of Welded / Bolted Connections

References:

1. N.H. Williams (Cygna) letter to J.B. George l (TUGCO), " Design of Welded / Bolted Connections," l 84042.024, dated January 28, 1985 2. Communication Report between Rencher (TUGCO) and Mtnichiello (Cygna) dated 3/21/84, item 1.c. 3. L. M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated April 19, 1984 @5$sid Texas Utilities Generating Company Mej l f,j Comanche Peak Steam Electric Station Independent Assessment Program - All Phases lll11111111111111111111111lll1Job No. 84056

.2. ,m,- .1 i. l . fi? E N!.k U1! f., k 5, hkk a ev s n0 Pa ge 2 PIPE SUPPORTS Open Itants and Generic Issues 4. Cygna Phase 3 Final Report TR-84042-01, Revision 0, Observation PS-06 3 Summary: Cygna found no evidence that welded / bolted connections are designed in accordance with paragraph XVII-2442 of Section III of tne ASME B&PV Code. Status: On hold pending TUGC0 response to Reference 1. 1 3. Richmond Insert Allowables

References:

1. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Richmond Insert Allowables and Bending Stresses," 84042.025, dated January 31, 1985 2. Communication Report between Rencher (TUGCO) and Minichiello (Cygna) dated 3/16/84, Item 2 3. Communication Report between Rencher (TUGCO) and Minichiello (Cygna) dated 3/30/84, Item 1 4. L. M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated May 2,1984 5. L. M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated May 8,1984 6. Communication Report between Bezkor (Gibbs & Hill) and Minichiello (Cygna) dated 6/12/84, Iten 4 1 7. " Affidavit of John C. Finneran, Jr., Robert C. j l Iotti, and R. Peter Deubler Regarding Design of Richmond Inserts and their Application to Support l Design" Susuary: Cygna has concerns with the following issues: Justification for single insert allowables based on test e concrete strength. Justification for bolt loads due to " axial torsion" of the tube steel. t l EEM Texas Utilities Generating Company [$ltjg'(( Corunche Peak Steam Electric Station Independent Assessment Program - All Phases lililllililllitillllllllllilli Job No. 84056

1 =;p ri y n O 9I { $\\? \\\\ f!N$gg,j f, {$.ht',,$,3 d i ! @ .Y. $. \\ i 3/13/85 .J Revision 0 Page 3 PIPE SUPPORTS Open items and Generic Issues Interaction results from Strudl analyses. Bending stresses in bolts. Status: On nold pending TUGC0 response to Reference 1. 4. Punching Shear (U-Bolt - Tube Steel Design)

References:

1. N. H. Williams (Cygna) letter to J. B. George (TUGCO), "Pnase 4 Open items - Punching Shear," 84056.053, dated January 31, 1985 2. Communication Report between Finneran (TUGCO) and Minichiello (Cygna) dated 10/4/84 3. TUGC0 Calculations dated 10/11/84, received by Cygna 10/18/84 4 Communication Report between Finneran (TUGCO) and Minicniello (Cygna) dated 10/30/84 5. J.B. George (TUGCO) letter to N.H. Williams (Cygna) dated November 8,1984 6. N.H. Williams (Cygna) letter to J.B. George (TUGCO), "Pnase 4 Open Items - Punching Shear" 84056.058, dated March 12, 1985. Surmary: Cygna has not found evidence of an evaluation of the stresses in the tube steel or coverplate in support MS-1-002-005-572R near the U-bolt hole. This lack of calculation is typical of this design. Status: On hold pending TUGC0 response to Reference 1. 5. Mass Participation /ftass Point Spacing

References:

1. N. H. Williams (Cygna) letter to J. B. George (TUGCO), " Pass Participation /Hass Point Spacing," 84042.021, dated February 8,1985 hYlS Texas Utilities Generating Company A Lej Comanche Peak Steam Electric Station lillittililllllilllitilllitill Independent Assessment Program - All Phases Job No. 84056 r-r= + W

c PM? b 5 3 M[f[. E O i,M i O$f s# h-I$5j~u; i. h E R W itiff w)f.'N $ U'N 3/13/85 ~ Revision 0 Page 4 PIPE SUPPORTS Open Items and Generic Issues 2. R. E. Ballard (G&H) letter to J. B. George (TUGCO), " Mass Participation," GTN-69454, dated September 14, 1984 3. N. H. Williams (Cygna) letter to J. B. George (TUGCO), " Phase 3 Open Items - Mass Participation," 84042.017, dated September 21, 1984 4. N. H. Williams (Cygna) letter to J. B. George (TUGCO), "Pnase 3 Open Items - Mass Participa-tion," 84042.019, dated October 2,1984 5. L.M. Poppelwell (TUGCO) letter to N. Williams (Cygna), "Cygna Potential Finding Report Mass Participation and the Mass Point Spacing Error in Problem AB-1-61A," dated December 7,1984 Sunmary: Due to the detailed nature of this subject, please see Reference 1. Status: On hold pending TUGC0 response to Reference 1. 6. Stability of Pioe Suocorts

References:

1. N. H. Williams (Cygna) letter to J. B. Geor e (TUGCO), " Stability of Pipe Supports," 8404.035, dated February 19, 1985 2. Communication Report between Rencher (TUGCO) and Minichiello (Cygna) dated 3/20/84, Item 3 3. L. M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated April 19, 1984 4. Communication Report between Rencher/ Grace (TUGCO) and Minichiello/Wong (Cygna) dated 5/24/84, Item 15 5. L. M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated July 12, 1984 W E Texa's Utilities Generating Company 3N l fd Comanche Peak Steam Electric Station ll111111111llll111111111111111Independent Assessment Program - All Phases Job No. 84056

~. 5, 3/13/85 i kwlbbu n 1 "'g55 " PIPE SUPPORTS Open Items and Generic Issues 6. Affidavit of John C. Finneran Jr. regarding Sta-bility of Pipe Supports and Piping Systems, cated June 17, 1984 7. Cygna Phase 3 Final Report TR-84042-1, Rev. O, Appendix J. General Note 12, and Appendix G, Observation PS-02. Sunsary: The issue of support stability is quite detailed. Please see Reference 1 for a discussion of Cygna's concerns. 7. Cinching of U-Bolts

References:

1. N.H. Williams (Cygna) letter to J.B. George (TUGCC, " Cinching of U-Bolts," 84042.036, (to be issue 1 March 18, 1985). 2. Comn. nica cion Report between Rencher (TUGCO) and Minichiello (Cygna) dated 3/19/84, Item 5 3. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated April 19, 1984 4. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna), Attachment C, dated June 8,1984 5. Affidavit of Cobert C. Iotti and John C. Finneran, Jr., regarding Cinching Down of U-Bolts (received July 12, 1984) l 6. Westinghouse Electric Corp. Report EQ&T-EQT-860, Revision 0, " Comanche Peak Steam Electric Station U-Bolt Support / Pipe Test Program" (received July l' 12,1984) 7. Westinghouse Electric Corp. Report entitled " Comanche Peak Steam Electric Station U-Bolt Finite Element Analysis", dated June 12, 1984 (receivedJuly 12,1984) h [bl f d Comanche Peak Steam Electric Station Texas Utilities Generating Company d j 1111!!!11111111111111llll!!!!! Independent Assessment Program - All Phases Job No. 84056 j

....:.... ~ 3 hDE! 5)i((flM h 3/13/85 I'* A f f? O h 's W U. b H Revision 0 W EIEn'.bi b' *iI E 5 ' U f E l I e Page 6 PIPE SUPPORTS Open Items and Generic Issues 8. N.H. Williams (Cygna) letter to J.B. George (TUGCO), "U-Bolt Cinching Test / Analysis Program - Phase 3 Open Item," 84042.015, dated August 23, 1984 9. Transcript of Meeting between Cygna Energy Ser-vices and Texas Utilities Generating Company and Ebasco Services, Inc. dated September 13, 1984 10. R.C. Iotti (Ebasco) letter to N.H. Williams (Cygna), "Additionel Information as Follow-Up to Meeting of 9/13/84 " 3-Z-17 (6.2), ETCY-1, dated September 18, 1984 11. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Status of Cinched U-Bolt Testing and Analysis Program," 84042.018, dated October 1, 1984 12. J.B. George (TUGCO) letter to N.H. Williams (Cygna), " Cinched U-Bolt Testing and Analysis Program - Additional Information," dated November 1, 1984 13. J.B. George (TUGCO) letter to N.H. Williams (Cy gna ), Cinched U-Bolt Testing and Analysis Program - Additional Information," dated Novemoer 16, 1984 Sunmary: Please see Reference 1. Status: On nold pending TUGC0 response to Reference 1. 8. Richmond Insert Allowable Spacing

References:

1. Communication Report between Rencher (TUGCO) and Minichiello (Cygna) dated 3/10/84, Item 1 2. Comunication Report between Rencher (TUGCO) and Minichiello (Cygna) dated 3/12/84 WW22'3l? Texas Utilities Generating Company 5=

= = = + =

dLd l fd Comanche Peak Steam Electric Station 11111111111111lll1111111111111 Independent Assessment Program - All Phases Job No. 84056

i k b.! 3/13/85 il ' {*,~ [ $k" r Revision 0 l f Li! Et'lkd di Page 7 PIPE SUPPORTS Open Items and Generic Issues Sunme ry: Cygna had asked TUGC0 how the designers ensured the allowables they used were for tne correct spacing. TUGC0 had stated that their designers used minimums, unless a walkdown was done. There was no written procedure for this. While Cygna could not find evidence that this unwritten procedure was not followed, Cygna has no assurance tnat conservative allowables were always used. Status: See cable tray generic item 3. ' 9. Embedment Attachment Spacing

References:

1. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Pipe Support Review Questions," item 5, 84056.13, dated July 31, 1984 2. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated August 24, 1984 3. Communication Report between Purdy (Brown & Root) and Pinichiello (Cygna) dated 3/4/85 4. Brown & Root Procedure CCP-45, Revision 1, dated 8/18/80 5. Brown & Root Procedure QI-QAP-11.1-28, Revision 24, dated April 18, 1984 6. Brown & Root Procedure Ql-QAP-11.1-28, Revision 29, dated January 25, 1985 l 7. Communication report between Warner (TUGCO) and Williams /itinichiello/Russ (Cygna) dated 2/27/85. 8. CPSES procedure QI-QP-19.5-1 " Separation Inspection for Unit 1 and Common Buildings." Sunmary: Cygna has found two pipe support base plates welded to embedded plates with less than 12" required spacing between r l the edges of the support base plates (per Reference 4). This was not an inspection item at the time of the Cygna review (Reference 5) but is now (Reference 6). Since this Texas Utilities Generating Company riL ji d Comanche Peak Steam Electric Station d L j l Hilliltlillillitilillfilillli Independent Assessment Program - All Phases l Job No. 84056 l r

3/13/85 I[k E l n.h.f f.'. t g I j f Revisior. 0 Page 8 -'Qy t i bu s .m PIPE SUPPORTS Open Items and Generic Issues affects all hardware attached to embedded plates (HVAC, raceway, and pipe supports), not just a single discipline, and since it was not an inspection item in other disciplines (per References 7 and 8), this item has generic implication. Status: Open. Cygna will issue a letter describing this issue and requesting assurance that the spacing requirement has been and will be checked throughout CPSES.

10. Thru-Bolts and Concrete Acceptability

References:

1. Communication Report between Rencher (TUGCO) and Minichiello (Cygna) dated 3/30/84, Item 2 2. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated May 2,1984 3. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated June 8,1984, Item 9 and Attachment D Sursnary: In thru-bolt designs, Cygna is concerned that the loads on the walls or' floors ney not be acceptable. Per Reference 3, there is no written procedure documenting transmittal of l loads on concrete structures, although Gibbs & Hill had walked down several hignly loaded areas. Tnis does not provide assurance that each area, particularly near free i edges, would be acceptable. Cygna lacks assurance that the designs across the plant are acceptable, since no procedures regarding load transfer exist. Status: Open for internal Cygna discussion.

11. Bolt Spacing

References:

1. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Pipe Support Review Questions," item 3, i 84056.14, dated August 6, 1984 l 2. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated August 11, 1984 EF*z%YlE Texas Utilities Generating Company F{ yJ6'!} Comanche Peak Steam Electric Station i L Independent Assessment Program - All Phases i Niilllillilillilllitillililli Job No. 84056

.i ~ hh : ev s n0 V "l f [. un; Page 9 sL.bg H,. $ gj n '!'IE On R E. a R a d li. PIPE SUPPORTS Open Items and Generic Issues Susuary: In certain base plate designs in Pnase 4 (CC-2-019-715 A43K, for example), the bolt hole is located from the edge of the plate with "1-1/2 MIN TYP." In some cases, this could re-sult in a dimension from 1-1/2 to 3-1/2 inches. While this may have little etfect on the bolt load, it does effect the maximum plate stresses by as much as 15% for a strut, spring, or snubbe-5* offset. Status: Open for internal Cygna discussion; Cygna does not require further TUGC0 response at this time. ^

12. Support Self Weight Excitation During a Dynamic Event

References:

1. Comunication Report between Rencher/Finneran (TUGCO) and Minichiello (Cygna) dated 3/10/84 2. TUGC0 memo CPP-9977 3. Cygna Phase 3 Final Report, TR-84042-01, Revision 0, Appendix J, Note 7 4 N.H. Williams (Cygna) letter to V. Noonan (USNRC), "Open Items Associates with Walsh/Doyle A11ega-tions," 84042.022, cated January 18, 1985 Sunmary: TUGC0 has not considered the loads due to the support dynamic excitation in the design of the support. Status: Cygna has deferred this issue to the USNRC review, as noted in Reference 4, item 14.

13. Support Stiffness

References:

1. Cygna Pnase 3 Final Report, TR-84042-01, Revision 0, Appendix J. Note 8 2. N.H. Williams (Cygna) letter to V. Noonan (USNRC), "Open Items Associated with Walsh/Doyle Allega-tions," 84042.022, dated January 18, 1985 EMxmfAg Texas Utilities Generating Company PT) Comanche Peak Steam Electric Station r Jkf Li LP 1111111111!!!!ll11111ll1111111Independent Assessment Program - All Phases Job No. 84056

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PIPE SUPPORTS Open Items and Generic Issues Sunnary: In designing Class 2 and 3 supports, TUGC0 has used a de-flection criteria. At low load, this can result in very flexible supports, which would affect the stress analysis results and redistribute support loads. Status: Cygna has deferred this issue to the USNRC per Reference 2, item 15.

14. Hydrotest Support / Stress Design

References:

1. Communication Report between Rencher (TUGCO) and Minichiello (Cygna) dated 3/20/84, Item 1 2. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated April 19, 1984 with TUGC0 Instruc-tions CP-El-4.0-30, Revision 1, attached 3. D.G. Eisenhut (USNRC) letter to M.D. Spence (TUGCO), Item V.E., dated November 29, 1984 Sunnary: Cygna did not find any evidence in either the support design calculations or the pipe stress analyses that hydrostatic loads had been considered. TUGC0 responded with a copy of their procedure. Status: Open for internal Cygna discussion.

15. Dynamic Pipe Movements in Support Design

References:

1. Communication report between Wade (TUGCO) and Williams (Cygna) dated 9/28/83, pipe support item 3 Williams (Cygna) port between Wade (TUGCO) and Communication re 1. dated 10/4/83, pipe suppcrt item 3 2. Cygna Phase 2 Report TR-83090-01, Revision 1, Observation PS-09-01 3. Communication Report between Rencher (TUGCO) and Minichiello (Cygna) oated 3/20/84, Item 2 UMd Texas Utilities Generating Company My l[ j Comanche Peak Steam Electric Station Independent Assessment Program - All Phases l11111111111ll111!!!ll11111111Job No. 84056

.l . = )D57 fI.N E N h f~[d v n0 hf F U NEx$:.IEti28b:;*t.tlI Page 11 PIPE SUPPORTS Open items and Generic Issues 4. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated April 19, 1984 Sumery: TUGC0 does not include dynamic pipe movements in support design when checking frame gaps, swing angles, or spring travel. Cygna was concerned this could affect design, but had considered only the seismic effects. Status: Open for internal Cygna discussion.

16. Dual Strut / Snubber Design

References:

1. Communication Report between Rencher (TUGCO) and Minichiello (Cygna) dated 3/22/84, Item 2.b 2. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna ) dated June 8,1984 3. Cygna Phase 3 Final Report, TR-84042-01, Revision 0, Observation PS-03 4. Cygna Phase 3 Final Report TR-84042-01, Revision 0 Page 5-5. 5. " Affidavit of Robert C. Iotti and John C. Finneran, Jr., Regarding Consideration of Force Distribution in Axial Restraints" 6. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Force Distribution in Axial Restraints - Phase 3 Open Item" 84042.014, dated August 10, 1984 Sumary: While most of the discussion on this subject has been about axial restraints, Cygna wishes to make clear that our con-cern is about all types of dual restraint designs (trapezes, double trunnions, riser clamps with shear lugs). TUGC0 has designed each restraint in these cases to take only 1/2 the total load. Also, Gibbs & Hill stated standard practice in local stress analysis assumes the trunnions share the l oa d. Cygna finds this inconsistent with other design organizations, which usually assume one side takes more than ENN5 Texas Utilities Generating Company [*Qe} g' fj Comanche Peak Steam Electric Station Independent Assessment Program - All Phases 1111!!!11!!!!!!!!!!!!I11111111 Job No. 84056

7 . =:. -.... = - - 3/13/85 P D N. I Revision 0 N D C' ! l f. F E I- {[f Si"/ W.I.l a/' t. $ [. : { E " I h i.$ jE E 5.5 I i Page 12 E PIPE SUPPORTS Open Items and Generic issues 1/2 of the overall support load. TUGC0 is currently performing an assessment in response to Reference 6. Status: Open pending TUGC0 response to Reference 6.

17. Hilti Bolt Embedment length References Williams (Cygna) port between Wade (TUGCO) and Comunication Re

References:

1. dated 9/28/83, pipe support item 1 Williams (Cygna) port between Wade (TUGCO) anddated 10/4/ Communication Re 2. 1 3. Comunication Report between Rencher (TUGCO) and Minichiello (CYGNA) dated 10/6/83, item 1 4. Cygna Phase 2 Report TR-83090-01, Revision 1, ODservation PS-02-01 Surmary: Embedment lengths shown on the support drawing do not tretch those in the support calculation. Tnis is due to the support designer calculating a minimum possible embedment from the bolt length. Status: Closed. 18. Incorrect Data Transmittal

References:

1. Cygna Phase 2 Report TR-83090-01, Revision 1, Observation PS-10-01 Surmary: The displacement transmitted for support RH-1-064-001-522R had an incorrect sign. Status: Closed. ETAIA Texas Utilities Generating Company F 4@ g' fy Comanche Peak Steam Electric Station I Independent Assessment Program - All Phases Illlitilllillilllitilllllilli Job No. 84056

-. ~ _ .. ~ c. ~ ]Ek : [5 l I: Q#j 3/13/85 5 ! M M... 4 Revision 0

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Gd Yh!$5IENi. I Page 13 PIPE SUPPORTS Open Items and Generic Issues 19. Incorrect Standard Component A110wables

References:

1. Communication Report between Wade (TUGCO) and Williams (Cygna) dated 9/28/83, pipe support item 4 2. Communication Report Between Wade (TUGCO) and Williams (Cygna) dated 10/4/83, pipe support item 4 1 3. Cygna Phase 2 Report TR-83090-01, Revision 1, ODservation PS-12-01 Sunmary: The incorrect U-bolt allowables were used in the design of support RH-1-064-011-S22R (formerly RH-1-062-002-522R). J Status: Closed. 20. Inout Errors in the desion of Sueoort M5-1-001-006-C72K

References:

1. Communication Report between Grace (TUGCO) and Minichiello (Cygna) dated 5/22/84, item 10 letter to N.H. Williams L.M. Poppelwell (TUGCO)984, item (41) 2. (Cygna) dated June 8,1 3. Cygna Phase 3 Report TR-84042-01, Revision 0, ODservation PS-01 Susunry: Errors in section properties and boundary conditions will affect STRUDL results. STRUDL input was neitner enecked nor approved. Status: Closed technically. Open for QA significance.

21. Undersized Fillet Welds

References:

1. Communication Report between Rencher (TUGCO) and Minichiello (Cygna) dated 5/16/84, item 5. 2. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated June 8,1984, item (31). MEM Texas utilities Generating Company My l y Comanche Peak Steam Electric Station Independent Assessment Program - All Phases-11lll11111111ll11111111111111!Job No. 84056 r ._...-._,n,

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Cygna Phase 3 Report TR-84042-01, Revision 0, Observation PS-04. Susuary: Two fillet welds were designed under the mir.imum required by the ASME B&pV code, Table XVII-2452.1-1. Status: Closed. 22. Imorocer Weld Calculations for 3 Sided Welds Communication Report between Grace (TUGCO Minichiello (Cygna) dated 5/22/84, item 1) and

References:

1. 2. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated June 8,1984, item (32) 3. Cygna Phase 3 Report TR-84042-01, Revision 0, Ooservation PS-05 4. N.H. Williams (Cygna) letter to J.B. Georoe (TUGCO) " Box Frames with 0" Gap," 84042.023 dated January 28,1985, item 3 of the Attachment 5. N.H. Williams (Cygna) letter to J.B. George (TUGCO) " Mass Participation and Mass Point Spacing," 84042.021 dated February 8, 1985. Pipe Support Review item 5 Sunmary: TUGC0 does not always consider the eccentricity between the member center of gravity and the weld center of rigidity when determining weld loads. Status: Closed for the supports reviewed in Phase 3 and 4 (that revision only). Open for any revision to the pipe stress analysis wnich increases loads (such as noted in References 4 and 5). 23. Improper Weld Calculation for Composite Sections

References:

1. Communication Report between Finneran (TUGCO) and Williams /Minichiello (Cygna) dated 7/11/84, item 1 N _ Texas Utilities Generating Company A[ Comanche Peak Steam Electric Station g, 16ll11111111111111111111111111 Independent Assessment Program.- All Phases Job No. 84056

3/13/85 [ci?!t2(ljy[ys tir t,ly:. p # g ~ Revision 0 JNsE[p,' Md

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is,.a (j.l n.g Page 15 -N Au-6E s o., PIPE SUPPORTS Open Items and Generic Issues 2. Communication Report between Finneran (TUGCO) and Minieniello (Cygna) cated 7/11/84 3. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated 7/12/84 4. Cygna Phase 3 Report TR-84042-01, Revision 0, Observation PS-07 Susuary: Wnen welding cover plates to tubesteel or widefianges to form composite sections, the design method for the weld is not always correct and all the loads are not always considered. Status: Closed as far as the Phase 3 review is concerned, but the errors must be corrected if loads increase in later revisions to the stress analysis. Texas Utilities Generating Company y [ta Corenche Peak Steam Electric Station litilllitillllllIlfilll1111 Independent Assessment Program - All Phases Job No. 84056

It hh! 3/13/85 [NA rIe

S E Revision.8 i Q W st1ES[atagi2vn g Page 1 CABLE TRAY Open Items and Generic Issues 1.

Contolling Load Case for Design

References:

1. Gibbs & Hill Calculation Binder SCS-101C Set 5, Sheets 16-20. Revision 5 2. Comunication Report between P. Huang, S. Chang (Gibbs & Hill) and J. Russ and W. Horstman (Cygna) dated 11/13/84 3. Gibbs & Hill Calculation Binder SCS-101C Set 5, Sheets 1-7, Revision 1 4. CPSES FSAR, Sections 3.8.3 and 3.8.4 Sumary: Gibbs & Hill design calculations, Reference 3, assumed that the design of cable tray supports was governed by the 1/2 SSE seismic event. This was based on a comparison between a 50% increase in seismic accelerations from the 1/2 SSE event at 4% damping the SSE event at 5% damping, and an allowed increase in design stresses of 60% for the.SSE event, per Reference 4 For the design of structural steel members, the 60% increase cannot be applied to certain allowable stresses. For exam-ple, using a 33% increase, allowable stresses for weak axis bending of wide flange beams and bending in base plates, will equal the yield stress. In addition, the allowable loads for concrete anchors (see Generic issue 3) cannot be increased by 60% for the SSE event. Neither of the above limitations were considered in the selection of the govern-ing load case for design. In order to reduce the loads for SSE, Gibbs & Hill elected to use 7% damping for the cable trays at SSE, as allowed for bolted structures. Status: Gibbs & Hill provided tables of peak spectral accelerations for 1/2 SSE at 4% damping and SSE at 7% damping (Reference 1). The reduced SSE accelerations appear to demonstrate that 1/2 SSE governs for support designs on a generic basis. However, for supports designed based on the accelerations for a specific building elevation, e.g., elevations 773', 785' and 790' in the Safeguards Building, the ratio of SSE to 1/2 SSE exceeds 1.33, tne increase allowed for Hilti h Texas Utilities Generating Company A( Comanche Peak Steam Electric Station 3 16:11111lllItIl111111111111111 Independent Assessment Program - All Phases Job No. 84056

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References:

1. Gibbs & Hill Calculation Binder SCS-101C, Set 2 2. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Cable Tray Support Review Questions," 84056.025, dated August 21, 1984, questions 3 and 4 3. R.E. Ballard (Gibbs & Hill) letter to N.H. Williams (Cygna), GTN-69437, dated September 10, 1984, with attached calculations 4. Gibbs & Hill Calculation Binder SCS-101C, Set 5 ? Sunvery: In the design of longitudinal trapeze type supports, e.g., L-A, L-A,ly of,the transverse supports (see Reference 1 4 L-C4 etc., these supports were assumed to act $ndependent 4). Calculations for these supports (Reference 1) consider only longitudinal loads in the design of frame members and anchor bolts. Since these supports are rigidly connected to the' cable trays with " heavy duty clamps", a tributary tray mass will be associated with these supports. It is Cygna's belief that they must be designed for vertical and trans-verse seismic loads just as the transverse supports are (see Refe'rences 2 and 3). Cygna does not accept the simplified reasoning which considers only relative stiffness of support l types as provided in Reference 3. Status: Gibbs & Hill is to consider these effects in the dynamic models being run in response to generic issues. In addition to the Gibbs & Hill analysis of selected systems, performed in responie to Cygna generic issues, further consideration must be given to isolate the above effects to ensure accept-ability on a generic basis. C2= ~~~ Texas Utilities Generating Company gM l fj Comanche Peak Steam Electric Station Independent Assessment Program - All Phases 11111111!!!!111111111111111111 Job No. 84056 l

3 ( Rvs n8 f fhilM' iimn i ">9e 8 CABLE TRAY Open Items and Generic Issues 6. Differences Between the Installation and the Design / Construction Drawings witnout ADDroorlate Docunentation

References:

1. Gibbs & Hill, Inc., support layout drawing 2323-El-0713-01-S 2. Brown & Root, Inc., fabrication drawing FSE-00159 3. American Institute of Steel Construction, Inc., Manual of Steel Construction, 7th Eclition 4. Gibbs & Hill support layout drawing 2323-El-0601-01-S 5. Gibbs & Hill support layout drawing 2323-El-0700-01-S 6. Gibbs & Hill cable tray support design drawings 2323-5-0900 series Sumery: Cygna performed walkdown inspections on 49 of the 92 sup-ports within the review scope. Certain discrepancies be-tween the as-built support configurations and the design requirements were as noted below. A. Support No. 481, Longitudinal Type A4 Single angles were installed as braces in the longitudinal direc-tion, not pairs which are required by the design drawing. No change documentation was located. B. Support No. 408, Type B4 The lower corner of the frame is modified by CMC 9916, Revision 1, to avoid interference with the CCW heat ex* changer. This change shows that 4" channel sections are to be used for the prescribed modification. A 6" channel section is actually installed. C. Support No. 649, Type A3 This installation uses concrete anchorage " Alternate Detail 1" (G&H design drawing 2323-S-0903) which requires the use of an L6x6x3/4. Cygna's field inspection discovered that an L5x5x3/4 was installed. No existing documentation accounted for this discrepancy. 55E Texas Utilities Generating Company fgd l[j Comanche Peak Steam Electric Station lililllill!!Illlllllllllllilli Independent Assessment Program - All Phases Job No. 84056

. -.. ~. -.. - i !. ' bh .f ALLMin;h.,.h.h{li y on 8 n "*9c ' CABLE TRAY Open Items and Generic Issues D. Support Nos. 722 and 2606, Detail "N", Drawing 2323-El-0601-01-S Cygna's field inspection found a working point violation on the brace attachment to the wall. Design drawing 2323-S-0929 Connec-gion Detail "F" was used (2323-5-0903) which has a tolerance of t 0.3b where 12"<b(3g". Cygna 's field inspection results show fhe tolerance used was 7 - 0.5b .(i.e., the brace was located in line with one bolt). E. Support Nos. 2992, 2994, 3005, 3017, 3021, 6654, Type A 2 Reference 1 identified the above six supports as follows: "Ap (ex-cept all members shall be MC6x12)," where L = 8'-3" (f rame wicth), h = 4'-2" (frame height). The Cygna walkdown results show the installed hanger member sizes are as noted in Table 1, below. Due to the presence of Tnermolag coating, Cygna was unable to determine the installed beam member size. No documentation existed to reconcile the differences be-tween the design requirements and the installation. TABLE 1 Cable Tray Support Member Sizes Dimensions (See Note 1) Member Size F la nge Support Depth Width Existing l No. (In) (In) (Note 1) 2992 6 1-7/8 C6 x 8.2 2994 6 1-7/8 C6 x 8.2 3005 6 1-7/8 C6 x 8.2 3017 6 1-7/8 C6 x 8.2 3021 6 1-7/8 C6 x 8.2 6654 6 2-1/8 C6 x 13 Note: 1. Dimensions of the vertical channels are based on mea-surements by Cygna. Member sizes are determined by selecting the channel type from Reference 3 which most closely natches the measured depth and flange width, waa _ GN ly 3 y A I Texas Utilities Generating Company i L Comanche Peak Steam Electric Station 11lllll11111!!!!I11111ll111111 Independent Assessment Program - All Phases Job No. 84056

i ? r} p hbi f) .f Re@ vision 8 85 E r.cau. r: i l *Wi p ;;f ili i,; g g,; [ Page 10 CABLE TRAY Open Items and Generic Issues F. Support No. 455, Type SP-8 Cygna's field inspection indicated that the brace connected to the wall on one side of the support is located outside of the bolt pat-tern on the base angle. ThegypeDetail"B"(2323-S-0903)connec-tion requires a tolerance of t 0.2b. TUGC0 issued CMC 99307, Revision 0, to document this iscrepancy in response to Cygna's question. G. Support Nos. 2998 and 13080, Special Type Supports These supports were installed in floor slabs with 2" topping. The topping depth was apparently not considered in selecting the length of the anchor bolt. Therefore, the required embedment length was not achieved. Status: A. TUGC0 provided CMC 2635, Revision 1, to document the installation discrepancy for support number 481. B. TUGC0 provided CMC 9916, Revision 2 to document the installation discrepancy for support number 408. C. TUGC0 provided CMC 99308, Revision 0, to document the installation of the incorrect size base angle for sup-port number 649. D. TUGC0 provided CMC 99309, Revision 0, to document the anchor bolt installation discrepancy for these two supports. E. TUGC0 provided the CMC's listed below to document the installation of the incorrect member sizes. Support Number CMC No. Revision 2992 44519 2 2994 99326 0 3005 96079 1 3017 99327 0 3021 30452 2 6654 90714 6 E- ~== Texas Utilities Generating Company I [eQtj l M Comanche Peak Steam Electric Station 111111111111111111111111111111 Independent Assessment Program - All Phases Job No. 84056 .__---,u

i.. - - ... a. .-.~.....w.-__. f!!ht.hfbuil!N!m['si;i,f Yb k$b!Ik v n8 ">9e 22 CABLE TRAY Open Items and Generic Issues F. TUGC0 provided CMC 99307, Revision 0, to document the installation discrepancy for support number 455. G. TUGC0 is to evaluate the effect of reduced embedment length for supports 2998 and 13080. Cygna is evaluating the action required by SDAR 80-05 for supports installed after its issuance. 7. Sucoort Frame Out-of-Plane Inertial Loads

References:

None Sunnary: Cygna has not seen any consideration of out-of-plane iner-tial loads for two-way cable tray supports. Such loads must be considered in the design of any base connections or anchorages as well as the design of longitudinal supports, assuming that a positive connection exists between the tray and the support. Status: Gibbs & Hill rust provide technical justification for ignor-ing out-of-plane inertial support loads. 8. Design of Angle Sections Neglecting Loading Eccentricity

References:

1. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Cable Tray Support Review QJestions," 84056.025, dated August 21, 1984, questions 3 and 4 2. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Cable Tray Support Review Questions," 84056.027, dated August 27, 1984, question 2 3. AISC Specification, 7th Edition, Sections 1.15.2 and 1.18.2.4 4. Gibbs & Hill calculation " Cable tray support type SP-7 with bra ce. Brace eccentricity calcula-tions." Cygna Technical File 84056.11-1.228 E Texas Utilities Generating Company

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[ej l[] Comanche Peak Steam Electric Station Independent Assessment Program - All Phases Hillllililllillllllilillilill Job No. 84056

l 3/13/85 n' u,.., g @[.:.p. n %d t 'd "I >, c h,, jL -(- r i Revision 8 E hlh 5 0 iLL 6 sit 'H lH l Page 12 l CABLE TRAY Open Items and Generic Issues 5. Gibbs & Hill calculation " Verify the adequacy of brace L3x3x3/8 of tne governing support Case C." Binder SCS-101C, Set 1, Revision 1, dated 3 11/16/84 6. Gibbs & Hill calculation " Justify the use of two L3-1/2x3-1/2x3/8 angles to take the appropriate load and moment individually in the longitudinal tray supports at the lower brace." Binder SCS-101C, Set 2, Revision 6, dated 9/15/84 Sume ry: A. Longitudinal cable tray supports typically use angle sections as bracing to resist the longitudinal loads, e.g., SP-7 with brace, L-A, L-A4 etc. For the member design, loads were assumed to 1 produce only axial stresses. The induced bending stress due to the eccentric end connection was not considered. Neglecting these flexural stresses can result in members which are under designed. For certain longitudinal supports, double angles are required. Tne design assumes that the angles behave as a composite member. How-ever, no intermittent filler plates are provided as required by AISC specification Section 1.18.2.4. Thus the double angles must l be considered to act independently. l B. Transverse and longitudinal cable tray supports typically use angle sections as in-plane braces to resist transverse loads and provide 3 4 3 L-A, bracing points on the vertical menbers, e.g., A, A, B, B4,ly 4 etc. For the member design, loads were assumed to produce on axial stresses. The induced bending stress due to the eccentric end conditions was not considered. Though it is not explicitly I stated in the AISC Specification, standard practice (Reference 3, l Sheet 3-59) considers the bending stresses due to end connection eccentricity and checks the interaction ratio considering the principal axis sectin modulii. C. Single longitudinal braces are typically connected to the frame by welding along the legs of the angle. However, the connections are ( such that at one end of the angle, only one leg is welded. At the angle's other end, the other leg is welded. Such end conditions may lead to failure by twist buckling. DEN Texas Utilities Generating Company Mtj l M Comanche Peak Steam Electric Station 111ll1111111111111ll111lll!!!1 Independent Assessment Program - All Phases Job No. 84056 l

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Revision 8 I d*3[1'fd[r2 gd 5 Page 13 4 '- g 5 I lii L La n 6 CABLE TRAY Open Iteurs and Generic Issues Status: A. Gibbs & Hill provided calculations considering end ec-centricity and independent action of each angle in double angle braces (Reference 6) Case L-B4 was assumed to provide enveloping brace loads. Calculations (Refer-ente 4) were also provided for SP-7 with brace, which has a single angle brace. Cygna believes that the approach is acceptable, but further verification may be needed to determine enveloping cases. B. Gibbs & Hill provided a calculation (Reference 5) which considered eccentric load application for in-plane bra ces. The brace loads for Case C, from the working 3 point deviation study, were assumed enveloping. See Generic Issue 14 for a discussion of the working point deviation study. C. Cygna is presently evaluating the possibility of twist-buckling on single angle braces. 9. Dynanic Amoiification Factors

References:

1. Later Sunrnary: 1.14 has been established as an appropriate factor. Tne support dynamic amplification factor (DAF) study was based i on continuous, uniformly supported spans. Current CPSES cable tray support design methodology calculates static loads based on tributary length. Any future use of the 1.14 l support DAF nust account for the difference between the l tributary support reactions and the support reactions based l upon continuous cable tray spans. Further, it FBy not be i appropriate to use a DAF of 1.14 if supports are designed in the future using non-uniform tributary span length loads. Status: No further work required. i i i N - Texas Utilities Generating Company [e g l Q Comanche Peak Steam Electric Station g lilitillitilllillililittlill!! Independent Assessment Program - All Phases Job No. 84056

) 3/13/85 n [w, a= :Q J L E f Q: p 3 M7 p. [,j t) Revision 8 )f Ib kIh5!!Nkh l

1. 9" CABLE TRAY Open Items and Generic Issues

10. Reduction in Channel Section Prooerties Due to Clamo Bolt Holes

References:

1. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Cable Tray and Conduit Support Review Questions," 84056.015, dated August 6, 1984, Attachment B, question 2 2. Gibbs & Hill letter GTN-69371, dated 8/23/84, Calculation SCS-111C, Set 8, Sheets 34-39 Sunmary: Cygna asked about the reduction in channel section proper-ties due to clamp bolt holes in Reference 1. Gibbs & Hill provided a response in Reference 2. The response fails to consider the following items: a. Cable trays may be placed anywhere in the beam span (for example, see CMC 2646). b. The resolution did not consider cantilevered supports wnere one tray is close to the wall and other trays are further out. c. The effect of DCA 17838, which provides bolt hole gage tolerances, is not considered. d. All unused flange holes are not required to be plug-welded and may be present in high moment regions. (See Note 15 on Gibbs & Hill drawing 2323-5-0901, Revision 4.) Status: Gibbs & Hill is to provide technical justification for the solutions. i = -. Texas Utilities Generating Company kN l[j Comanche Peak Steam Electric Station l11111111111111111111111111111 Independent Assessment Program - All Phases Job No. 84056

~ 7$E.".UI'iQ[WI2 3/13/85 Edw[t t in E 2 ? fl[Y Y fY E fij{k9.9 Revision 8 i,k Page 15 CABLE TRAY Open Items and Generic Issues

11. System Concept of Design Affecting the Following Areas:

References:

1. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Cable Tray Support Review Ouestions," 84056.031, dated August 31, 1984, Attacnment A, question 2 2. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna), dated September 28, 1984 with attached calculations Surmary: The following items must be addressed with regard to the use of the systems concept: A. Eccentricities between support members and load placement which induces additioinal bending and torsion stresses (References 1 and 2). B. Lateral support for buckling consideration (reference Generic Issue 4). C. Effective tributary spans for longitudinal supports (reference Generic Issue 5). D. Rotation of base connection angles about bolt pattern axis and the assunption of semi-fixity for weak axis buckling calculations (reference Generic Issue 3). t 1 E. Transfer of out-of-plane seismic inertial loads from two-way sup-port frames to longitudinal supports, (reference Generic Issue 7). Status: Item A was evaluated as part of the dynamic analysis by Gibbs & Hill. The status of Items B through E are found under the referenced generic issues. @AM Texas Utilities Generating Company l p,l[j Comanche Peak Steam Electric Station Il!!1111111111$1111111111111 Independent Assessment Program - All Phases Job No. 84056

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12. Desian Control

References:

1. Gibbs & Hill drawings 2323-El-0601-01-5, 2323-El-0700-01-S, 2323-El-0713-01-S 2. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Cable Tray Support Design Review Ques-tions," 84056.022, dated August 17, 1984, ques-tions 1, 2, and 6 3. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Cable Tray Support Design Review Ques-tions," 84056.025, dated August 21, 1984, question 1 4. Gibbs & Hill cable tray support design drawings 2323-5-0900 series 5. Gibbs & Hill calculations for support numbers 3025, 3028, 2861, Cygna Technical File 84056.11.1.225 6. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna), " Responses to Cygna Review Questions," dated September 4,1984, with attached calcula-tions 7. Gibbs & Hill Calculation Binder SCS-101C, Set 3, Sheets 206, Revision 6 8. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna ), " Response to Cygna Design Review Ques-tions," dated September 11, 1984, with attached calculations 9. Gibbs & Hill Calculation Binder SCS-101C, Set 5

10. Gibbs & Hill Drawing 2323-5-0901, Revision 4 11.

N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Cable Tray Support and Electrical Review Questions," 84056.019, dated August 10, 1984, questiens 2.1 and 2.2 E 95 Texas Utilities Generating Company d@j t fi} Comanche Peak Steam Electric Station l11111ll111!111!!1111111111111 Independent Assessment Program - All Phases Job No. 84056

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Revision 8 h khc ((f (( l Page 17 CABLE TRAY Open Items and Generic Issues

12. Gibbs & Hill Drawings 2323-El-0601-01-5, 2323-El-0700-01-S, and 2323-El-0713-01-5 Sumery:

A. Lack of consideration of the effects of generic CMC's and DCA's on original designs. 1. Support type SP-7 with brace is affected by CMC 6187. The CVC was approved and design reviewed by Gibbs & Hill, New York, but its effects were not considered in the SP-7 with brace general calculations or any generic reviews. 2. The effect of CMC 1970, which specifies the allowable edge distance of anchor bolt holes in base angles, was not con-sidered in the design of the anchor bolts. B. Criteria violations in individual support specifications on support plans. In the generic design of cable tray supports, limitations on the support dimensior. and loading are determined for each support type. These limitations are typically stated in the design calcu-lations, but are not shown on the generic support design drawings, (Reference 4). On the support plans (Reference 1) the dimensions for each support are specified in a descriptive block, and the loading is indicated by the supported tray width shown. The tray supports listed below were identified as having loadings or support geometries which exceeded the design limitations. No justifying documentaion existed for these individual support de-signs prior to the Cygna review. 1. Support Nos. 3025, 3028, 2861, Type D. Drawing 2323-El-1 0713-01-5 calls out these supports as "D1 (except bam to be MC6 x 16.3) L = 11'-9", b = 4 -2", and snows a tray width of 78". The FSE-00159 fabrication drawing sheets reflect these dimensions. However, the Gibbs & Hill design calcualtions supports (2323-5-0901) limits L c 8'-0" and tray for Type D3 width to 48". s [U.jg._j Texas Utilities Generating Company

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.i 5.Iif Revision 8 t u$.g Wij .t Hgg 5 s... g t y Page 18 ) i =. CABLE TRAY Open Items and Generic Issues 2. Support No. 2607, Type A. Drawing 2323-El-0601-01-S spe-1 cifies dime.nsion of L = 2'-9" and n = 4'-6" for this sup-port. The design calculations for this support type (S-0901) limits h < 2'-4". 3. Support No. 657, Type A. Drawing 2323-El-0601-01 calls out 1 this support as Type A, L = 7'-0, h = 2'-0". The design i calculations for this support type limits L < 6'-0". 4. Support No. 734 Detail li, drawing 2323-El-0601-01-5 spe-cifies that one beam is to be on MC6x15.1, rotated 90* from normal orientation. The design for this support requires the use of C6x8.2 sections for beams. CMC 00164 requires the use of " heavy duty clamps" for this support, thus intro-ducing longitudinal loads. The design for this support requires the addition of a longitudinal brace if longitu-dinal loads are to be resisted. 5. Support No. 3011, Type SP-6, drawing 2323-El-0713-01-5 specifies dimensions of L = 8'-9" and h = 4'-6". The design calculations for this support type limits L < 6'-0". 6. Support Nos. 2992, 2994,.3005, 3017, 3021, 3111, 6654, Type A, drawing 2323-El-0713-01-5 specifies dimensions of L = g8 -3" and h = 4'-2", and shows a tray width of 78". The i j design calculations for this support type limits L < 6'-0" and the tray width to 48". l C. Consideration of as-built support conditions in generic reviews I which require a case-by-case review. l 1. The SP-7 weld underrun analysis considered 5/16" fillet l welds which were specified on the design drawings. However, the FSE-00159 fabrication drawings specify smaller weld sizes. In addition, the underrun alaysis did not consider the effects of any changes to the supports which were re-ported in CMC's and DCA's. 2. Working point studies (reference Generic issue 14). i __ Texas Utilities Generating Company [ek (rj i M Comanche Peak Steam Electric Station limiiiiiiii....;;mimill Independent Assessment Program - All Phases Job No. 84056 . - _..,,. ~ _, _. ..n. .,,.,..,,_n,,.

a (,- ) us r,.n. c 5. t,% a i' 3/13/85 jdbh Ytf${d M;l',i] r 7s f vi W Revision 8 [ d L P!!i 1 Page 19 CABLE TRAY Open items and Generic Issues D. Inconsistent application of as-built and design information in the evaluation of cable tray supports for Thermolag application. 1. The weight of tray covers is not included in the allowable span length table (Procedure CP-El-4.0-49). 2. Longitudinal supports are not evaluated for the added weight of fire protection. The fire protection review did not note the lack of any longitudinal supports in the tray run with Detail N. 3. Fire protection evaluations are performed on tray-by-tray ba si s. The cumulative effect of multiple trays with fire protection on one support my not be considered. E. Tray span between supports used in original support layout. 1. Reference 9 indicates that cable tray supports are to be designed for 8'-0" spans. Reference 10, Note 13, allows a location tolerance for supports of

• 1/2 Richmond insert spacing parallel to the tray, and that the maximum spacing between supports shall not exceed 9'-0".

Gibbs & Hill design calculations for cable tray supports assume a maximum tributary span of 8'-6", to account for support layout of 8'-0" on center and an erection tolerance of i 6". Cy gna 's review of Reference 12 noted 14 locations where the as-designed tray spans exceeded 8'-0". Cygna 's walkdown of these tray segments discovered five locations where the as-built tray spans exceeded 9'-0" (see Reference 11). This indicates that the design and installation limitations for support spacings were not followed. 2. The design of longitudinal supports indicates that the maximum longitudinal tray span is 40'-0". For several supports within Cygna's review, the support plan drawings (Reference 12) provided supports with tributary spans greater than 40'-0" (see Reference 11). In addition, several horizontal tray segments had no longitudinal sup-ports provided (see Reference 11). This indicates that the . design limitations were not followed for the location of longitudinal supports. W-Fi Texas Utilities Generating Company' Mtj l[] Comanche Peak Steam Electric Station Independent Assessment Program - All Phases lilll!!!!Illiiltlillilitilllll l Job No. 84056 ---,w, --w s

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3/13/85 i f* k Er.E EYk i b TfiO y Page 20 CABLE TRAY Open Itests and Generic Issues F. Use of "For Reference Only" Calculations Cygna has noted several desgin reviews of change notices where the CVC was parked to indicate that new or revised calculations were not required. Attached to the CHC, hovever, are calculations that are narked "For Reference Only". G. Cygna is concerned about support design calculation retrievability and comple'?eness. H. Lack of Controlled Design r-1teria 1. Cygna has noted instances where the field design review group is not utilizing the proper criteria to evaluate support adequacies. The evaluations for fire protection compare the actual load to a design load which is based upon a 9'-0" tributary tray span. The maximum tributary span assumed in the current design is 8'-6". ~ 2. Cygna has asked what supplements to the 7th Edition of AISC Specifications were committed to in the FSAR. No evidence was found to indicate that proper direction was given to design engineers to utilize the requirements of any supple-ments that were committed to. Status: A. No further discussion required. B. Gibbs & Hill has indicated that the engineer preparing a support layout drawing would be familiar with the design limitations. Based upon judgement he/she could violate these limitations without preparing supporting calcula-tions since the support nap drawings would be subject to design review. For the individual support listed above: (1) Gibbs & Hill provided calculations (Reference 5) evaluating these supports. Support numbers 3025 and 3028 were found acceptable, support number 2861 shows 30% overload of anchor belts. (2) TUGC0 provided calculations (Ref erence 6) demon-strating the acceptability of support number 2607. E#~d Texas Utilities Generating Company Mej l fj Comanche Peak Steam Electric Station Hilllllllllillllillllllllll!! Independent Assessment Program - All Phases Job No. 84056

~ 1 ~ _.. F"id E-3 Ii'gli y'-J P, f,j ll.f ' * " ' ' ' ' ' ~ " ' ~~~ ' Revision 8 4 s L au.$ 5 g L. e 7,p,3-( r Page 21 lae Q e E e t,. u e3 l CABLE TRAY Open Items and Generic Issues (3) TUGC0 provided calculations (Reference 6) demon-strating the acceptability of support number 657. (4) Gibbs & Hill /TUGC0 have not provided a response. (5) Gibbs & Hill provided calculation (Reference 7) demonstrating the acceptability of support number 3011. (6) TUGC0 provided calculations (Reference 8) demon-strating the acceptability of these supports. C. No further discussion required. D. Cygna is continuing internal evaluation. E. Gibbs & Hill has indicated that the engineer preparing a support map drawing would be familiar with the span liriitations for transverse and longitudinal supports. Based upon engineering judgement, he/she could violate these limitations without preparing supporting calcula-tions since the support map drawings would be subject to design review. For the individual span violations noted above, 1. Gibbs & Hill /TUGC0 provided calculations qualifying trays and supports for the transverse span viola-tions. 2. Gibbs & Hill /TUGC0 provided calcualtions qualifying l trays and supports for the longitudinal span viola-tions. For tray segments lacking longitudinal sup-ports, the load was applied as additional trans-verse loads on transverse type supports located around a 90' bend from the unsupported tray seg-ment. For one tray run without any existing mecha-nism to resist longitudinal loads, segments T120SBC25 and T130SCA45, the addition of a new longitudinal support was required. F. Cygna is continuing internal evaluation. l G. Cygna is continuing internal evaluation. l H. Ovnn= ie enn+ i noi n n int oena l ova l um + 4 ma. RESi555 Texas Utilities Generating Company ri lj 3 7 3 Comanche Peak Steam Electric Station L JL A Hillitilllittlitillllilllllli Independent Assessment Program - All Phases Job No. 84056

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7) p., y 3/13/85 b 2h Revision 8

~yg"= Page 22 ge M i CABLE TRAY Open Items and Generic Issues

13. Validty of NASTRAN Models

References:

1. Gibbs & Hill Calculation Binder SCS-215C, Sets 2-6 2. Gibbs & Hill Calculation Binder SCS-101C, Set 3, Sheets 234-243, Revision 9 3. Gibbs & Hill Calculation Binder DMI-13C, Set 1 Sumery: Cygna has questioned the validity of the NASTRAN models used in the Gibbs & Hill generic studies, e.g., working point deviation study (Reference 1) and the qualification of Detail D1 (References 2 and 3). The models assume a row of supports of one type. all having identical configuration and spans. This will influence the system frequencies and seismic response. Such models may not be representative of actual installation where a mixture of support types and spans are used. Status: Further discussion is required as part of the model selec-tion for TUGCO's proposed generic study.

14. Workina Point Analysis Study

References:

1. Gibbs & Hill Calculation Binder SCS-215C, Sets 2-6 2. Gibbs & Hill Calculation Binder SCS-216C, Sets 1-5 Sumery: A. Gibbs & Hill's working point study (References 1 and 2) lacks consiceration of the effects of change documentation and previously approved design deviations. The cut-off elevations were esta-blished using assumed 8'-6" spans, enveloping frame dimensions and maximum permissible working point deviations. Frames above the cut-off elevation were analyzed on a case-by-case basis but did not consider the effects of change notices. Since any one of the above assumed parameters may effect the acceptability of the study, the use of QC's check of working point deviations alone to determine field compatability with the scope of the study will be inadequate. =g g[N]r== ass: M Texas Utilities Generating Company J L fAi Comanche Peak Steam Electric Station L. 111111111111111111!!!!!!!!!!!1 Independent Assessment Program - All Phases Job No. 84056

... L :-.. ~. -. _ ~ _u_ 4' 3/13/85 i '. f \\ Revision 8 h t.i r. e g r.,.t "$ ;6. r E !. l. iq i,: 3 Page 23 I e s t u b a s t-CABLE TRAY Open Items and Generic Issues B. The effects of vertical and transverse loads on longitudinal sup-port frames were not considered in the study (reference Generic Issue 5). C. The longitudinal support portion of the study only checked member interaction. No evaluation was made to ensure that this component governed. D. Modeling Assumptions 1. Instead of modeling a longitudinal support, the tray run ends were assumed as fixed. The effects of such a tray boundary fixity on system response was not justified. 2. The analysis assumed a single two-foot tray per beam and did not assess the impact of more realistic multiple tray load-ings. 3. Eccentricities (reference Generic Issue 11).

4..The assumption of tray attachment fixity was not justified.

5. Selection of run configuration (reference Generic Issue 13). 6. The base angle modeling assumed a simply supported beam for i two bolt base connections. l l 7. Excitation in the longitudinal tray direction was not con-l sidered. Status: Gibbs & Hill /TUGC0 must justify the use of the modeling assumptions and the use of the analyses results for QC inspections. The concerns discussed above should be con-sidered in Gibbs & Hill dynamic analysis of the five selected cable tray systems, i L 5 :- N E E i Texas Utilities Generating Company [(M l fj Comanche Peak Steam Electric Station lll11!!!111111111111ll11111111 Independent Assessment Program - All Phases Job No. 84056 l

._.__m u 3/13/85 %I d. ;3 h e i,3 , m j r[ 5 B. L [ s a. - s a;.I.> if l 5-M4iUIf Y Revision 8 Page 24 x t E $ $ M C'. i E CABLE TRAY Open Items and Generic Issues

15. Reduced Spectral Accelerations

References:

1. Gibbs & Hill calculations, " Analysis of Alternate Detail 1" 2. Gibbs & Hill Calculation Binder SCS-101C, Set 3, Sheet 247, Revision 9 3. Gibbs & Hill Calculation Binder SCS-215C, Set 4 Sunnry: Gibbs & Hill used reduced spectral accelerations based on a calculated support / tray system frequency for the qualifica-tion of the supports discussed below. A. For transverse supports, such as type A4 which was used in analysis of Alternate Detail 1 (Reference 1) a reduced acceleration is used based on a calculated frequency which is beyond the spectral peak. The study assumes a tray weight of 35 psf and tray spans of 8'-6". Use of the results of this study will not be valid in installations where either of the above parameters have been exceeded without considering the effect on frequency. B. Similarly, for longitudinal supports, e.g., type SP-7 with brace (Reference 3) L-Al (Reference 2), etc., the frequency will decrease due to tray weights exceeding 35 psf or longitudinal spans exceed-ing 40'-0". In addition, the frequency calculations for support types L-A, L-B, etc., did not include the effect of the axial 4 4 frequency of the tray. Status: Additional discussion between Cygna and Gibbs & Hill.

16. Non-Conformance with AISC Specifications

References:

1. AISC Specifications for the Design, Fabrication and Erection of Structural Steel for Buildings, 7th Edition Summery: Gibbs & Hill failed to properly consider the requirements of Reference 1 as discussed below. l l

=======w =5 =' R; Texas Utilities Generating Company gg W t M Comanche Peak Steam Electric Station 1111111111111111111111111ll111 Independent Assessment Program - All Phases - Job No. 84056 l

._ ~.~_. -... _ _.. _._....s. _ o._. P n.i t ', c ' 3/13/85 mg R ya N? i j.3 h ).T V., .J./ Revision 8 yp3 kIik I 't [.., hb! CABLE TRAY Open Items and Generic Issues A. Unbraced length for axial buckling. 1. Section 1.8.4 regt. ires that kl/r ( 200. 2. Examples where k1/r limitations were exceeded. a. See Generic Item 4. b. SP-7 and associated supports are checked for buckling assuming that the tray provides a roller restraint at the tray attachment point, therefore k = 1.0.

However, since no restraint can be assumed, k = 2 and kl/r > 257 for a 12" tray.

B. Unbraced length for lateral torsinal buckling. 1. Section 1.5.1.4.6a requires that Equation 1.5-7 be used to calculate the allowable bending stress for channels. In the denominator, "1" is the unbraced length of the compression flange. 2. Examples where the specifications were ignored or improperly applied. a. The working point analyses use 22 ksi without checking Equation 1.5-7. The frame heights are on the order of 144" which yield an allowable flexural stress of 15 ksi. b. Detail SP-7 and similar supports consider "1" to be the distance to the tray centerline and not to the outside rail where the load is applied. Use of the larger dis-tance will result in lower allowable bending stresses. C. Reduction in section due to bolt holes in flange per Section 1.10.1 (see Generic Issue 10). D. Lacing of double angle braces (see Generic Issue 4). E. Eccentric connections - Specification Section 1.15.2. 1. This section requires that any axial members not meeting at a point be designed for the eccentricities. E - - - Texas Utilities Generating Company Mej l M Comanche Peak Steam Electric Station Independent Assessment Program - All Phases ll111111ll11111111111111111111 Job No. 84056

~ a..-. ~ j 3/13/85 p Revision 8 Pbpg55.'F,aceniLL!idiltr}ut.:.$aON5U Page 26 GABLL IKAT Open Items and Generic Issues 2. Examples of designs where this specification section applies are the gusset plates used for single angle braces, espe-cially type SP-7 with brace. Status: Further discussion with Gibbs & Hill /TUGC0 required for technical justification.

17. Member Substitution

References:

1. Conference Reports dated 1/17/85, 8:15 a.m. and 3:45 p.m., "Walkdown Response Verification," Kissinger and Russ participating Sucinary: A. Note 9 on Gibbs & Hill drawing 2323-5-0901, Revision 4, states: " Structural members shown on drawing numbers 2323-5-900 series ney be substituted by one step heavier shape of the same size." Cygna interprets this note as allowing craft to interchange struc-tural shapes, e.g., an MC for a' C or vice versa, as long as the substantial shape is heavier than, but of the same depth as the original members. This would allow the use of substitute sections ~ which have lower section modulii. TUGC0 has stated that they interpret this note as requiring the craft to stay with the same shape, i.e., a C section can only be substituted by a C section (Reference 1). B. Within Cygna's walkdown scope, support number 6654 (see Generic Issue 6) was reviewed and reflected Cygna's concern as discussed above.

• The design required an MC6x12 and the installed member was a C6x13 which has a smaller section modulus (S = 5.80 in3 for a C6x13 compared to a 5 = 6.?4 in3 for an MC6x12). For the other supports listed in Generic Issue 6, the required MC6x12's were substituted with C6x8.2's a substitution not permitted by this note.

C. Cygna could not locate any documetnation which requires QC or craf t to note where such substitutions were made. !$ ANN Texas Utilities Generating Company Mej l M Comanche Peak Steam Electric Station 18111111111!!11ll!!111111111!! Independent Assessment Program - All Phases Job No. 84056

p p""h i h; f ?.} I. fd' hT';)l 3/13/85 5 s i' f.T graNh ': f b Revision 8 t i'iL.kf;ki L E E MIQ g Page 27 l CABLE TRAY Open Items and Generic Issues Status: TUGC0/Gibbs & Hill to provide justification of such substi-tutions and the requirements for documentation.

18. Weld Size Rouirements

References:

1. N.H. Williams (Cygna) letter to V. Noonan (USNRC), " Response to NRC Questions," 83090.023, dated March 8, 1985 2. Conference Report dated 10/27/84, " Cable Tray Conduit Review Scope," Change, Huang et al. parti-cipating 3. Conference Reporet dated 11/13/84, " Cable Tray Conduit Review Questions," Chang, Huang et al. participating 4. Conference Report dated 11/17/84, " Cable Tray Support Design Review - Weld Sizes," Chang, Huang et al. participating 5. Conference Report dated 11/30/84, " Cable Tray Weld Details," Kissinger and Russ participating 6. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Cable Tray Support Review Questions," 84056.041, dated February 12, 1985 Suninary: Cygna has discovered the following problems with the weld desigrs of cable tray supports. A. The design drawings are missing the weld details as described in Reference 1. Attachment C. B. Per discussions with Gibbs & Hill /TUGC0 (References 2, 3, 4 and 5) Cygna has noted that the weld sizes shown on the fabrication draw-ings differ from those shown on the design drawings and those that were assumed in Gibbs & Hill calculations. $NW Texas Utilities Generating Company [*)d l[j Comanche Peak Steam Electric Station Independent Assessment Program - All Phases ll1111111111111111111111111111 Job No. 84056

1Tr"3&EF,'bE".(t9[ 3/13/85 .# U h h [MF.t !d fj '[af k.bl.,L,lif(E$ir.i1E Page 28 Revision 8 CABLE TRAY Open Items and Generic Issues C. Eccentricities were not considered in weld connections. 1. SP-7 with brace and similar connections requires a partial penetration groove weld at the gusset plate / beam connec-tion..The design calculations did not consider the eccen-tric load application from the brace member. The eccentri-city of the brace loads results in a weld stress in excess of 400 ksi. 2. Weld designs for base angle connections never considered the eccentricities of the applied loads from the connecting mem-bers. D. The weld designs did not consider the thicknesses of the connected pa rts. Gibbs & Hill's weld designs assumed the development of full weld throat without considering the thickness of the connected member. E. Gibbs & Hill assumed an incorrect minimum weld length for the beam / hanger base angle connection. 1. Gibbs & Hill assumed a distance of 1-k, where 1 = angle leg width and k = distance from back of angle leg to end of fillet. 2. Because of the radius of the curve at the angle toe, r (approximately equal to one-half the leg thickness), the actual weld length is 1-k-r. c I i Status: Open pending response to request per Reference 6. 19. Embedded Plates Design

References:

1. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Cable Tray Support Review Questions," l 84056.041, dated February 12, 1985, Attachment A, question 1 2. L.M. Poppelwell (TUGCO) letter to N.H. Williams l (Cygna) dated April 19,1984, page 11 3. Conference Report dated 9/15/84 " Response to Cygna Cable Tray and Conduit Ouestions," Williams, Russ. Horstman et al. oseticin=tino gysiR2M T-" rIWJ L Texas Utilities Generating Company i a. Comanche Peak Steam Electric Station milllllililittilllllitillll! Independent Assessment Program - All Phases Job No. 84056 l l

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"Fxe Revision 8 k Ni$! [I. l Page 29 CABLE TRAY Open Items and Generic Issues 4. Conference Report dated 2/27/85, " Quality Control (QC) Inspections," Warner, Williams, et al. parti-cipating Sunnary: Cygna's review of cable tray attachments to embedded plates indicated that the allowables for the embedded plates ney not have included the effects of prying action (Reference 1). Additionally, questions from Cygna's pipe support reviewers and cable tray reviewers on the stiffening re-quirements for embedded plate moment connections elicited conflicting responses from TUGC0 personnel. One response indicated that attachments to embedded plates act as stiffeners, for moment connections (Reference 2) while another indicated that any moment attachment must be stiffened or sufficiently analyzed (Reference 3). Cygna has also noted that cable tray embedded plate designs were not within the tolerances of Gibbs & Hill Specification 2323-55-30 " Structural Embedments" (Reference 1). Cygna is also evaluating the lack of attributes for embedded plate inspections on the QC Inspection Report forms as well as the verification procedures for attachment proximity criteria (Reference 4). Status: TUGC0/Gibbs & Hill to provide justification for the above items.

20. Tray Clamos

References:

None Sunnary: The cable trays have been assumed to provide bracing to the tray supports for the following modes of behavior: Buckling of the hanger members. Lateral torsional buckling of the beam members Bracing of the support frame to prevent frame rotation which would result in anchor bolt over-l oa d. 3((lej g' y Comanche Peak Steam Electric Station b A Texas Utilities Generating Company 1 0 111111111111111111111111111 Independent Assessment Program - All Phases Job No. 84056

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3/13/85 I Revision 8 J - j ge rI" U e .. L.; hj { { Ql Page 30 CABLE TRAY Open Items and Generic Issues Such bracing may occur only if the tray clamps provide suitable compatability conditions. Status: Cygna is currently evaluating the various clamp designs to establish their capability to provide sufficient load trans-fer.

21. Other Loads in the FSAR Combinations

References:

1. CPSES FSAR, Section 3.8.4.3.3 2. Gibbs & Hill Calculation Binder SCS-103C, Set 1 Sheets 14-19 3. Gibbs & Hill Calculation Binder SCS-103C, Set 2 Sheet 32 Sunrnary: Cygna is concerned that all applicable loadings, as defined in Reference 1, are considered in the design of cable tray supports. Among these concerns are LOCA loads. Reference 2 provides the calculations for Detail "A" (Gibbs & Hill drawing 2323-El-0500-01-5) which was originally designed for use in containment. Only dead and seismic loads were con-sidered in this design. Similarly, Reference 3 is the design calculation for Detail "C" (Gibbs & Hill drawing 2323-El-0500-04-5). This support was only evaluated for dead and seismic loads. Status: Discussion with Gibbs & Hill /TUGC0 is required to establish the exact criteria for ignoring other possible support loa dings. Ei?" EM Texas Utilities Generating Company 1 bg l ] Comanche Peak Steam Electric Station 1111111111111lll!Ill1111111111 Independent Assessment Program - All Phases Job No. 84056

1 t r' f ' ' ' ~ c 3/13/85 r 'h {Id d $ [.') $ '$'j k] c Revision 0 = h[,.suhkU$kh*kE'{ Page 1 i CONDUIT SUPPORTS Open Items and Generic Issues 1. Contro111no Load Case for Desian

References:

1. Cygna discussion with TUGC0 and Gibbs & Hill on 10/1/84 regarding anchor bolts and controlling load cases Summary: A. Anchor bolts control the design for most supports. A factor of safety of 4.0 was used for the OBE loading. SSE loads will reduce the factor of safety. B. Catalog components are designed for OBE loads. The catalog does not allow an increase in allowables for SSE. Status: Discussion with Gibbs & Hill is required. Also see Cable Tray Generic Item 1. E. Amolification Factor of 1.0 Used fo-Desian of Supports

References:

1. Cygna discussion with Gibbs & Hill on 2/5/85 regarding reference calculations for amplification fa ctor 2. Cygna discussion with Gibbs & Hill on 2/6/85 confirming discussion on 2/5/85 3. Gibbs & Hill Calculation 2323-SCS-100C, Set 4 Sheets 1-11 l Summary: Gibbs & Hill has submitted a calculation for justification t of the 1.0 amplification factor. Tnat calculation was based on a Class 5 piping damage study. Status: Reevaluation of the 1.0 amplification factor is required based on results of the cable tray amplification evaluation (see Cable Tray Generic Item 9). EANS Texas Utilities Generating Company [@ l f] Comanche Peak Steam Electric Station Independent Assessment Program - All Phases 111111111111111111111111111111 Job No. 84056

-3 I 'y 3/13/85 gr)k( k. g t; P.:y P, )I ;' ;R fg g f ~.

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3 ?y Revision 0 g$ i,, nil!Is Page 2 CONDUIT SUPPORTS Open Items and Generic Issues 3. Conbination of Deadweight and Earthouake in SRSS of Loads / Stress

References:

1. Gibbs & Hill Calculation 2323-SCS-1090, Set 1, Sneets 154-163 Summary: Deadweight is added to the vertical acceleration, then SRSSed with the horizontal acceleration components. Status: Gibbs & Hill has submitted calculations for the consideration of vector megnitudes of acceleration for the standard combination method and the SRSS method used in their designs. The unconservatism is snell and is conditionally acceptable based on cumulative effects (see item 24). Also see Cable Tray Generic Item 2. 4. Measurement of Embedment from Too of Tocoing

References:

None 1 Summa ry: Note 5a on Gibbs & Hill Drawing 2323-5-0910, Sneet G-4a allows reduced emoedment for certain supports at lower elevations. Support types in Cygna scope affected: CSM-18 Series, CST-17. Such a reduction is not acceptable for 1/4" and 3/8" Hilti bolts with 2" embedment requirement (these bolts are embedded in topping only). Such a reduction nay not be acceptable for other sizes l depending on the actual acceleration versus the design acceleration. Status: Technical justification is required for instances allowed by the note. l l 55-32=5 Texas Utilities Generating Company ey]j Comanche Peak Steam Electric Station Independent Assessment Program - All Phases llt!!11111!!!111111111111111Job No. 84056 i

w 3/13/85 W ?g f [ F- ? > 8 E t'. 00 5 Revision 0 j u.,! - N p .7 F [,E n.@O :!,h.; #....m..U.n.6 Page 3 C0fdiUli SUPPURTS Open Items and Generic Issues 5. Bolt Hole Tolerance and Edge Distance Violation (GiDDs & Hill Drawing 2325-5-0910, Sneet G-lo, Note 15)

References:

1. AISC Specifications, 7th Edition, Section 1.16.5, Minimum Edge Distance 2. AISC Specifications, 7th Edition, Section 1.23.4, Riveted and Bolted Construction - Holes Sunmary: A. The AISC Code does not provide for bolt hole tolerances. AISC bolt holes are 1/16" larger than the bolt size. Gibbs & Hill allows a tolerance varying with bolt size. B. For oversize holes, the AISC code requires that a minimun clear distance be naintained. Gibbs & Hill designs do not provide the minimum edge distances as specified in the AISC code. Supports in Cygna scope affected: CA-5a : Required edge distance = 25/32"; edge distance provided = 3/4" CSM-42: Required edge distance = 25/32"; edge distance provided = 3/4" Status: Discussion with Gibbs & Hill is required. 6. Other Loads in the FSAR Combinations

References:

1. CPSES FSAR, Section 3.8.4.3.3 l Sunmary: Cygna is concerned that all applicable loads were not considered in the conduit support designs. Among tnose concerns are: Applicable LOCA loads in containment. Design accelerations do not envelop Containment Building and Internal Structure spectra. E$1M Texas Utilities Generating Company 3p ' y Comanche Peak Steam Electric Station Independent Assessment Program - All Phases 111111111111111ll1111111111Job No. 84056

~ .u_.. <...s_.. \\ e* 3/13/85 p): e se g. r 5. !3 b, p. 2.*. b t.18 k!!'s [' E3 Y F ll'!. i Revision 0 te hay Page 4 k MC., CONDUIT SUPPORTS Open Items and Generic Issues Status: Discussion with Gibbs & Hill is required to determine if any justification exists. Also see Cable Tray Generic Item 21. 7. Support Self Weight

References:

1. Cygna Generic Conduit Support Review Sunenary: Cygna's review has noted that support self weights were not uniformly considered as discussed below: A. Only partial support weight was considered. Tube ends are neglected (only length to conduit centerline considered). Brace weight for CSM-6b was not considered. B. Support self weight was neglected. CST-3, CST-17 Unistrut supports. Status: Discussion with Gibbs & Hill is required. This item affects the design of anchor bolts. See cumulative effects, item

24. Also see Cable Tray Generic Item 7.

8. Torsion of Unistrut Members

References:

1. N.H. Williams (Cygna) letter to J.B. George (TUGCO), "Cygna Study of Unistrut Torsional Capacity " 84056.040, dated January 18, 1985 i 2. Cygna discussion with TUGC0 on 1/8/85 regarding l analysis of P1001C3 members under torsional loads 3. Cygna discussion with Gibbs & Hill on 2/21/85 regarding conduit support testing. 4. Cygna visit to CCL test labs on 2/25/85 to witness Unistrut support tests i l M= ~ Texas Utilities Generating Company [ey l[] Comanche Peak Steam Electric Station Independent Assessment Progcam - All Phases l ll1111111111111ll11111111i!I11Job No. 84056

a - - ~.. [tCIkb.;i-Djis(,$[5h/ t T3 W F. ? ;; e r. *** y 3/13/85 y Revision 0 I((.g(gjgg Page 5 = CONDUIT SUPPORTS Open Items and Generic Issues Sunary: Torsion of Unistrut members is not considered in support designs. Unistrut does not support the use of members for torsional loading. Status: TUGC0 and Gibbs & Hill are evaluating the effects of torsion in the Unistrut test program. Cygna personnel visited tne CCL test labs on 2/25/85 and provided comments on the test scope and procedures: (1) Worst case support configuration Member lengths and load agnitudes chosen my not be e the critical case, Member lengths chosen my not adequately address e torsional behavior of the generic support design. Documentation is not readily available to evaluate the criteria used in choosing the test configurations. Choice of larger diameter conduits for some supports e precludes testing of P2558 clamps, since C708-S clamps are required for large conduits. (2) Direction of loading to test weak link Loading of clamps should induce tensile force in e bolts. Many tests load the members in bearing instead of eximizing clamp load. i l For composite Unistrut sections, loading should e l provide tensile load on spot welds to test the l integrity of the section. l TUGC0 is also reanalyzing some supports per AISI methods. l More information is required for evaluation of those analyses. l l - E=-

l Texas Utilities Generating Company l

f g'y l Q Comanche Peak Steam Electric Station 1Il1lll1111111111111111111111 Independent Assessment Progratn - All Phases Job No. 84056

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References:

1. Cygna discussion with TUGC0 and Gibbs & Hill on 9/20/84 regarding AISI versus AISC usage 2. Cygna discussion with TUGC0 on 10/11/84 regarding AISI versus AISC usage 3. Cygna discussion with Unistrut on 1/21/85 regarding P1941 connector plates 4. Cygna discussion with Unistrut on 2/4/85 regarding Unistrut allowbles and use of P1001C3 members 5. Gibbs & Hill Calculation 2323-SCS-153C, Sheet 1/37 6. Cygna Generic Conduit Support Review Checklists Sumary: A. Implicit increase in allowables for SSE (see Item 1). B. AISC derived allowables are used in the design process. These values are generally conservative for bending, but are mostly unconservative for axial allowables, as catalog allowables are based on the AISI code and consider buckling of thin, open sections. Examples: CSM-6b: 20 ksi was used for Fa, which is.6 Fy, wnere Fy = 33 ksi (for all lengtr.2). Catalog values range from 5.77 ksi for a 5' brace to 13.9 ksi for a 2' brace. CST-3: AISC tables were used for Fa, where Fy = 36 l l ksi. See additional coments for CSM-6b l above. i l CST-17: AISC tables were used for Fa, with Fy = 36 ksi; then Fa was reduced by 33/36. See l additional coments for CSli-6b above. EE=E Texas Utilities Generating Company [eg l((j Comanche Peak Steam Electric Station i Independent Assessment Program - All Phases 11llll!!!!1111ll11111111ll1!!! Job No. 84056

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I Page 7 CONDUIT SUPPORTS Open Items and Generic Issues C.

Use of components in ways not intended by the vendors. 1. No allowables are given for P1001C3 sections. Member pro-perties are given for X-Y axes instead of principal axes. Discussion with Unistrut indicates that use of P1001C3 is unique with respect to load application and restraint of the member, such that no generic allowables could be given. Unistrut places the burden on the designer to properly consider the capacity of the section for its intended use. 2. The Unistrut catalog shows use of P1325, P1331, P1332 brackets on single members (pinned connection). Gibbs & Hill uses two brackets on double members (moment connection, but Gibbs & Hill considers them pinned connections for some brackets in CSM-6b, CST-3, and CST-17). Unistrut does not give allowables for this configuration. 3. Gibbs & Hill references a test C-49 to obtain allowables for the double bracket connection in CST-3. The test only provided tensile loading on the bracket; therefore, only tensile load was compared to the allowable, ignoring shear. 4. P1941 plate connectors are used to connect headers to outriggers in CA-la and CA-2a supports. Tightening of Unistrut bolts to specified torque overstresses the plate (by analysis), causing excessive bowing. Discussion with Unistrut indicates that these connectors are used to construct frames, such that restraint is provided at the other end of the connected member. On CA-la and CA-2a supports, clarification of this problem is required, as there is conflicting information regarding behavior of the P1941 plates: a. In Revision 1 of Gibbs & Hill Drawing 2323-5-0910, Sheet CA-la, Note 7 was added to provide P1064 plates if bend-ing of the P1941 plates occurs. b. In Gibbs & Hill Calculation 2323-SCS-153C, Sheet 1/37, a discussion of field installation documents that the P1064 plates do not reduce the bowing of the outriggers. c. Unistrut tests showed no bowing of the outriggers when the P1064 plates were used. Verification of bolt torques for the test is required. 1 E-L= Texas Utilities Generating Company r g. eJ L [A} Comanche Peak Steam Electric Station ai L Independent Assessment Program - All Phases 11tl11111111111lll1111ll1l1111Job No. 84056

.c ~ l 3/13/85 ^ M P { s[-;c,5( E l h $f Revision 0 F t r= I, a w ri d L{i b, # E.3 "c 'n Page 8 i nL, 1 ~ CONDUIT SUPPORTS Open Items and Generic Issues 5. C708-S clamps are not designed for three-directional load-ing. Allowables for tensile loading only are given in the Superstrut Catalog. Sussury: Discussion with TUGC0 and Gibbs & Hill is required.

10. Anchor Bolts

References:

1. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Cable Tray and Conduit Support Review Questions," 84056.015, dated August 6,1984, Question A2b regarding CSD-la Sumery: A. A prying factor of 1.5 was used in most cases without justifica-tion. The Teledyne method predicts higher factors for CSft-18d and CSM-18f (rectangular plates). B. The AISC 8th Edition method was used to omit a prying factor for i l CSD-2, Detail 8 (U-clips). C. No prying factor was used for CST-17. Type 17 (box bracket). [ D. No prying factor was used for CSD-1, Detail 2 (Z-clips). This detail is addressed in the Unistrut test program. Status: Discussion with TUGC0 and Gibbs & Hill is required. Also see Cable Tray Generic Item 3. I

11. Lonoitudinal Loads on Transverse Supports

References:

1. Cygna Generic Conduit Support Review Checklists Susunry: Clamps provide restraint in three-directions. j e Some transverse supports rey be on the same order of stiffness as long cantilever multi-directional supports. Torsion of transverse supports due to transverse loads may induce some longitudinal loads. I E=CC Texas litilities Generating Company Mej l ] Comanche Peak Steam Electric Station 111111111111111111!!!!!!!11111 Independent Assessment Program - All Phases Job No. 84056

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12. Substitution of Hilti Bolts

References:

None Sunnery: Note 4 on Gibbs & Hill Drawing 2323-5-0910, Sheet G-4a, allows substitution of all Hilti Kwik and Super Kwik bolts with those of larger size. A reduction in the allowables for larger bolts ney be necessary due to spacing require-ments, such that the replacement bolts have lower capacity than the original bolts in the design. Examples: e CSM-18c: 1/2" Hilti Kwik bolts at 5" spacing were used in the original design. If all 1/2" bolts are substituted with 3/4" or 1" bolts, the tensile allowable for the replacement bolts will be less than the design tensile allowable (2750 4 lbs for 3/4" bolts versus 3012 lbs used in the design). CSH-42: 1" Hilti Super Kwik bolts at 7.5" spacing were Type III used in the original design (allowable tension = 12452 lbs, allowable shear = 6884 lbs). If all 1" bolts are replaced by 1-1/4" bolts of equal embedment, bolt capacity is signifi-c cantly reduced (allowbie tension = 6405 lbs, allowable shear = 6221 lbs). Status: Technical justification by Gibbs & Hill is required for supports affected by this note. E i Texas Utilities Generating Company rgg4 5 f 3 Comanche Peak Steam Electric Station Independent Assessment Program - All Phases fililllilillit lillfililli Job No. 84056

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13. Substitutior c' Smiler conduits on CA-Tvoe Supports

References:

1. Cygna discussion with TUGC0 on 3/7/85 regarding conduit support allowables for fire-protected supports Summary: CA-type supports are designed using ZPA for-large conduits and peak acceleration for small (<2") conduits. For CA-type supports with capacities tabulated on the drawings, substi-tution of smaller conduits is allowed unless specifically prohibited on the drawings. Although the deadweight load of the snell conduits must be less than the capacity, the accelerated load of the small conduits may exceed the accelerated load of the large conduits used for design. Example: CA-15 was designed for 2 - 3" conduits with deadweight capacity of 156 lbs. Five 1-1/2" conduits can be installed. on a CA-15 support, giving higher accelerated loads than designed for: Rigid span loads (2 - 3"); 343 lbs,109 lbs e i l Flexible span loads (5 1/2"); 504 lbs, 450 lbs This item possibly affects CA-6, CA-7, CA-12, CA-14 Series, and CA-16a. Status: Discussion with TUGC0 and Gibbs & Hill is required. TUGC0 is investigating this item with respect to fire-protected l supports. l k rzzen - Texas Utilities Generating Company r4g ' y Comanche Peak Steam Electric Station killittlilllilili tilliltlil Independent Assessment Program - All Phases 1 Job No. 84056 l

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14. Use of CA-Tyoe Supports in LS Spans

References:

1. Cygna discussion with TUGC0 on 2/20/85 regarding i QC practices 2. Cygna discussion with TUGC0 on 3/7/85 regarding conduit support allowables for fire-protected + supports Sunnary: CA-type supports are used to support LA spans, which are l limited to 6' length. CST-type and CSti-type supports are used to support LS spans, which can be up to 12' for r transverse spans and 24' for longitudinal spans. In field installations, when conduits run from walls to equipment in the middle of a room, transition is made between LA spans and LS spans. Thus, CA type supports may support LS spa ns. The concerns are discussed below. For large diameter conduits (>2"), ZPA was used to calculate ~ 'the accelerated design load. For the CA-type support with 1 an adjacent suspended support (CST-or CSM-type), the peak acceleration should be used to check support capacity, since rigidity of the transitional span can no longer be guaran-teed. There is evidence tnat decreased support capacity is considered for the fire-protected supports (see CP-El-4.0-49), since support capacities are given for both LA spans and LS spans. For unprotected lines, there is no indication that this was considered. f Status: TUGC0 is investigating the practice for fire protected supports. i Stress in Cable Trays for Attached Conduit Suoports 15.

References:

1. Cygna Generic Conduit Support Review Checklists 2. Gibbs & Hill Calculation 2323-SCS-156C, Set 1, 4 Sheets 101-104 Sunnary: This item applies to CSD-16 in the Cygna review scope and to any similar details. Tray spans are ostensibly designed to the capacity of the tray. Addition of conduit supports to the tray rails adds load above that capacity. Therefore, a .i f E=C Texas Utilities Generating Company } Comanche Peak Steam Electric Station r ge ' itil l lilitillittlilllIlllill Independent Assessment Program - All Phases Job No. 84056

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Revision 0 ~ t h L.L..M U K li;n i Page 12 CONDUIT SUPPORTS Open Items and Generic issues 9eneric stress check for the trays is not possible, and all tray spans with these conduit supports should be indivi-dually checked. Since the design drawing does not preclude the use of this detail on fire protected trays, and since the conduit support designer is responsible for showing adequacy of the tray for the attached detail, a proper check must be nade for all uses of this detail. Status: Cygna has reviewed the Gibbs & Hill calculation for CSD-

16. Cygna's comments require discussion with Gibbs & Hill.

16. Allowable Span length Increase from Old S-0910 Package

References:

1. Cygna discussion with Gibbs & Hill on 12/27/84 regarding span increase 2. Gibbs & Hill Calculation 2323-SCS-189C, Set 1 Sheets 15-24 Sunmary: In the revised S-0910 package, LA span lengths were in-creased by a ratio of the refined to the unrefined spectra. Status: Gibbs & Hill provided a calcuation to show that the above changes are correct and that rigid spans remain rigid (large diameter conduit). This is adequate for support design, since support loads are proportional to span lengths. Evaluation of conduit stress is required, since conduit bending stress is proportional to the square of the span length. l

17. Substitution of Next Heavier Structural Member

References:

None Sununary: This item refers to Note 5 on Gibbs & Hill Drawing 2323 0910, Sheet G-la. Since supports are designed to the limit l of the Hilti bolts, and in light of the discussion in Item [ 7.A., generic designs using structural steel are affected but are not checked. l l Status: Discussion with Gibbs & Hill is required. See cumulative l effects, Item 24. I 5 Texas utilities Generating Company Mg l ] Comanche Peak Steam Electric Station Independent Assessment Program - All Phases Nilitilllilllllilillllillllli Job No. 84056

I 3/13/85 en ;ipg.n-tr Revision 0 3 0.Q 3 6 il & J 'y;t S!.-

L ' ' ': 17 Il t i Page 13 6b5 3,tts3: ta trb E h-CONDUIT SUPPORTS Open Items and Generic Issues

18. Clamo Usage

References:

1. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Cable Tray and Conduit Support Review Questions" 84056.015, dated August 6,1984, Question A4 regarding reaming of P2558 clamps 2. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Conduit Support Walkdown Questions," 84056.020, dated August 13, 1984, Question 3 regarding deformed clamps 3. Cygna discussion with Unistrut on 7/25/84 regarding reaming of P2558 clamps 4. Cygna discussion with TUGC0 and Gibbs & Hill on 10/9/84 regarding reaming of P2558 clamps 5. Cygna Walkdown Checklists Sumnery: A. For small diameter conduits (<2"), clamps ney be reamed to accommodate 3/8" Hilti bolts. 1. The minimum edge distance is violated. l l [ 2. Hilti washer for 3/8" bolts will not fit on clamps for smil diameter conduits (<2"). The washer is an integral part of the bolt, and justification for its omission is required. B. In the Cygna walkdown, distortion of clamps for the following supports was noted. l Support ID Support Tyoe C12G93528-8 CSM-18f l C12002935-3 CA-Sa C12G03126-18 CSM-42 C12G02851-6 CA-Sa E5??55 Texas Utilities Generating Company l r 4gJ ' [ A3 Comanche Peak Steam Electric Station Independent Assessment Program - All Phases 1111111111!!I11111111111111111 Job No. 84056 l

3/13/85 F'c t?L E'" % h f? " :.. ! t v n i fgfr E ** **gjstt2\\t Revision 0 ~ b b$ 8 9' " t a CONDUIT SUPPORTS Open Items and Generic Issues Status: A.I. Gibbs & Hill has provided calculations; Cygna is reviewing the calculations. A.2. Discussion with Gibbs & Hill is required. B. Discussion with TUGC0 is required. 19. Documentation /0A Deviations Between IR/ CMC /IN-FP

References:

1. Cygna discussion with Gibbs & Hill on 2/18/85 regarding discrepancies between IR and.IN-fps for C12004695 Summary: For each line, inspection is performed as documented on the IR. All CMCs, supporting calculations, and IN-FP materials should reflect the IR. Examples: Line C11003395, IRME-18120F, Support -1: On the IR, the o i support is listed as CSM-18f, Revision 4. On CMC 62903, the support is listed as CSM-18b, Revision 14. From the CMC information, the IR is in error. Line C12G-05087, IRME-16817F, Support -4: On the IR, e the support is listed as CSM-18C, Revision 13. On CMC 62905, Revision 0, the support is listed as Revision 9. On CMC 62905, Revision 1, the support is listed as Revision 12. Line C12004695, IRME-16089F, IN-FP-216, and IN-FP-226: There are discrepancies between the IR and both IN-FP l drawings for support types CA-la and CA-2a. There is no structural difference in supports, but documentation should be consistent. 1 Status: This item is still in the evolutionary stage. Additional issues will be noted as the review progresses. I i If? 5 Texas Utilities Generating Company l [eg'[tj l }} Comanche Peak Steam Electric Station Independent Assessment Program - All Phases 11111!I11111111111111111111!!!Job No. 84056 . - -.. - -, _ - - - - _.,. -. -. - _ - - - - - -. -,. _. - ~. - _ -

i i 3/13/85 = m. m. g - U.-.. 5 j's Revision 0 .:,3 " " $ i ; fi r. ]dy [:l g,:; ;i ( ~- -17 6 P Page 15 I ml.,3 H o D b d ir li a CONDUIT SUPPORTS Open items and Generic Issues

20. Nelson Studs

References:

1. Cygna discussion with Gibbs & Hill on 8/7/84 regarding Nelson stud and conduit clamp issues 2. Gibbs & Hill Calculation 2323-SCS-156C, Set 1, Sheets 131-160 3. Gibbs & Hill Calculation 2323-SCS-109C, Set 1 Sheets 164-184 Sunmery: A. Allowables. Allowables used by Gibbs & Hill do not conform to allowables given by TRW/ Nelson. B. Pretension of Nelson studs. Gibbs & Hill calculations use pretension force in the Nelson studs to resist applied loads. The pretension force should consider the flexibility of the shim plate and clamp, as distortion and/or re-laxation in these components will decrease the stud preload. C. Bending of Nelson studs. Filler plates with oversized or slotted holes allow the studs to be loaded at the clamp, applying a shear load eccentric to the weld. l Transfer of side-load on the clamp is provided througn sheer and bending of the Nelson stud rather than pure shear considered in the l design. D. Stress in shim plates due to stud welds. Gibbs & Hill provided a calculation to address stress in shim plates. Status: A. Justification of allowables used far the Nelson studs is required. B. Evaluation of the actual preload and its effect on the stud capacity is required. !M=5 E Texas Utilities Generating Company rgel '[A I Comanche Peak Steam Electric Station U 2k Independent Assessment Program - All Phases !!Il11111111111tllI1ll11111111Job No. 84056

i O]" g [d[f f b p E P. !;jy 3/13/85 dt-w[ } d M. !-/ g Revision 0 fi l i 4 3 '. i 'i s ?, g Page 16 l CONDUIT SUPPORTS Open Items and Generic Issues C. Evaluation of the Nelson studs for the above situation is required. D. Cygna has reviewed the calculation and requires technical justification of the following issues regarding the yield line analysis: Underrun was not included in consideration of the weld. The assumed stress distribution in the fillet weld around the plate is not realistic, as it assumes an infinite stress on the bottom of the plate. A more realistic stress distribution shows that the weld can not provide full fixity of the plate. This should be considered in a revised yield line analysis.

21. Configuration of Fire Protection on Conduits

References:

1. Cygna discussion with TUGC0 on 10/16/84 regarding configuration of Tnermolag fire-protection on conduits Surmary: Gibbs & Hill fire-protection calculations consider a round configuration of Thermolag material around conduits. Weight of Thermolag on the spans was calculated based on this con-figuration. Cygna walkdown shows that a square configura-tion was also used in field installation. Status: Evaluation by Gibbs & Hill of the as-built configuration with respect to the design configuration is required to insure that the design adequately envelops the field condition. Preliminary evaluation by Cygna indicates small unconservatisms in some cases. See Item 24 for. cumulative effects. E- - -i Texas titilities Generating Company r(@ T Q Comanche Peak Steam Electric Station lIllll11111111111111111111111 Independent Assessment Program - All Phases Job No. 84056

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22. Span Increase for Fire-Protected Spans

References:

1. Cygna discussion with TUGC0 on 10/16/84 regarding fire-protection on conduits 2. Cygna discussion with TUGC0 on 10/27/84 regarding fire-protection evaluations 3. TUGC0 Instruction CP-EI-4.0-49 4. Gibbs & Hill Drawing 2323-S-0910, LA Series 5. Gibbs & Hill Drawing 2323-5-0910 LS Series 6. Gibbs & Hill Calculation 2323-SCS-1017, Set 1 Sumery: Many allowable spans for fire-protected conduit runs are longer than allowable spans for unprotected runs. Status: Cygna has reviewed calculations provided by TUGCO. Addi-tional discussion with TUGC0 and Gibbs & Hill is required. 23. Loads on Grouted Penetrations

References:

1. None Sumery: For straight conduit runs embedded in walls and floors,- no longitudinal conduit supports are required if there are no bends in the run. For very long conduit runs, the loads on the grouted penetrations nay be large. Status: Technical justification for omission of longitudinal sup-ports on embedded runs with respect to performance of the grouted penetrations is required: Capability of the grout to resist applied loads should e be insured. Proper documentation and inspection of grouting should be performed to validate analysis of the penetrations for applied loads. MhiM Texas Utilities Generating Conpany 3g l ] Comanche Peak Steam Electric Station independent Assessment Program - All Phases fililllllllliflilllllililllfil Job No. 84056 7 _..,y.--

1 1 Of5Ei'f#139hjif 3/13/85 l^t f, (NIj.lf;i.O bc 7 Revision 0 iMa t $ fi t.1 E Vil!) ti Page 18 CONDUIT SUPPORTS Open Items and Generic Issues 24 Cumulative Effect of Generic Items

References:

None i Summary: Small unconservatisms can usually be neglected in design. Since most of the conduit supports are designed to neximun capacity, the cumulative effect of many unconservatisms may be significant. The following items ney have cumulative effects on the conduit designs: a. Combination of dead weight and earthquake loads (Item 3) b. Support self weight (Item 7) c. Substitution of heavier structural members (Item 17) d. Variance in Thermolag cross-section (Item 21) Status: Discussion with Gibbs & Hill is required. i I E W " Texas utilities Generating Company r g psfj Comanche Peak Steam Electric Station helillilillilillIllilllill! Independent Assessment Program - All Phases Job No. 84056 -v ,-,__m- ,,_.~-m. , _ ~ - - - m._.,., -. - - - - - - -, _..-. _. _,,-_%~--_

~~ ~ ~ - - ' - 3/13/85 . T [$ I '$ h ? I PQf Revision 0 'P [ ' < d f t-Page 1 EB I!$!!'thh h ~ MECHANICAL SYSTEMS Open Items and Generic Issues 1. Component Cooling Water System Maximum Temoerature

References:

1. Cygna Pnase 4 Final Report TR-84056-01, Revision 0, Observation MS-01-01 (not issued) 2. N.H. Williams (Cygna) letter to J.B. George (TUGCO), 84056.010, dated July 30, 1984 3. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna), dated August 11, 1984 4. N.H. Williams (Cygna) letter to J.B. George (TUGCO), 84056.023, dated August 21, 1984 5. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna), dated April 11, 1984 6. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna), dated October 1,1984 Sunmary: Cygna noted discrepancies between the Westinghouse stated maximum Component Cooling Water (CCW) system temperature of 120*F, the CPSES FSAR, Gibbs & Hill calculation 233-16 and Gibbs & Hill calculation 229-14 which indicated neximuns of 121.8'F,135'F and 129.7'F, respectively. TUGC0 provided documentation that showed the acceptability of the 135'F maximum temperature. Some of this documentation is dated as late as 9/28/84 indicating that TUGC0 was not aware of the i problem prior to the Cygna questions. Status: Cygna Observation MS-01-01 was closed based on documentation provided. However, when design and operating data is revised, all existing system components should be reviewed to ensure that they meet the new operating conditions. 2. CCW Surge Tank Isolation on High Radiation Signal

References:

1. Cygna Phase 4 Final Report, TR-84056-01, Revision 0, Observation MS-06-01 (not issued) 2. N.H. Williams (Cycna) letter to J.B. George (TUGCO),84056.028, dated August 27, 1984 %%sg Texas utilities Generating Company 3 Comanche Peak Steam Electric Station k.i ( ) L IAl Independent Assessment Program - All Phases Hilllillililillifilllililill! Job No. 84056

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~ j Revision 0 Page 2 s. m am1 MECHANICAL SYSTEMS Open Items and Generic Issues 3. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated September 20, 1984 Sumnary: The Westinghouse functional design requirements document for the CCW system required that the surge tank be isolated by closing the vent valve on receipt of a high radiation sig-nal. TUGC0/Gibbs & Hill removej this control function from the system radiation monitors to prevent spurious actuation caused by rising system temperature during accidents. Since the chang,e did not address the radiation release effects of the vent remaining open, Cygna requested verification that the release would be acceptable. TUGC0 performed a calculation which verified that the release was within the limits of 10 CFR 100. No generic review was conducted of other radiation monitor control function changes at CPSES. Status: Cygna Observation MS-06-01 was closed based on the results of TUGC0 calculation TNE-CA-094 dated September 19, 1984. 3. Class 5 Piping

References:

1. Cygna Phase 4 Final Report, TR-84056-01, Revision 0, Observation MS-02-01 (not issued) 2. N.H. Williams (Cygna) letter to J.B. George ~ (TUGCO),84056.010, dated July 30, 1984 3. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated August 11, 1984 4. N.H. Williams (Cygna) letter to J.B. George l (TUGCO),84056.023, dated August 21, 1984 5. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated September 11, 1984 6. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated September ?1.1984 7. L.M. Poppelwell (TUGCO) lettu to N.H. Williams (Cygna) dated September B. Im l EMElMi Texas Utilities Generating Company Li d k"T T*b Independent Assessment Program - All Phases Comanche Peak Steam Electric Station A l1111111111111ll1ll1111111111! Job No. 84056

a 3/13/85 m: -~ we a e < re r. . r 5.). :. I Y ',, l ( i[f,4 ! b b M l.: i! Eij T h! Revision 0 I r L 3 Page 3 b =learLEsteEt: 5 1 MECHANICAL SYSTDRS Open Items and Generic Issues 8. N.H. Williams (Cygna) letter to V. Noonan (USNRC) "Open Items Associated with Walsh/Doyle Allegations," 84042.022, dated January 18, 1985. Summary: The definition of Class 5 piping design and analysis re-quirements are not clearly presented by TUGCO. Per Gibbs & Hill, Class 5 piping is not seismically designed; it is only seismically supported to prevent it from falling on safety i related equipment. TUGC0 did provide documentation showing that the specific Class 5 CCW piping that was in Cygna's review scope was seismically analyzed and therefore, would remain functional as required. However, Cygna could not determine whether any similar circumstances exist in otner piping systems where Class 5 piping may be required to remain functional during a seismic event. Status: Observation MS-02-01 was closed for the CCW system based on the documentation and analyses provided. Cygna has not been authorized to investigate the generic implications of this issue for other piping systems. 4. Fire Doors

References:

1. N.H. Williams (Cygna) letter to J.B. George (TUGCO),84056.010, dated July 30, 1984 2. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated August 11, 1984 3. N.H. Williars (Cygna) letter to J.B. George (TUGCO),84056.023, dated August 21, 1984 4. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated August 31, 1984 Summa ry: Cygna noted that the double doors between the train A & B nuclear chillers did not have a U.L. fire rating label. TUGC0 stated that this had been previously noted by them and that the proper door was being installed. TUGC0 could not provide documentation of how the error was noted but did supply copies of a purchase order for the correct door. Reinspection by Cygna verified the proper door was in-l stalled. TUGC0 stated that no NCR or other paper work was Is h Texas Utilities Ge.nerating Company f*k (*$ L 7 l Independent Assessment Program - All Phases Comanche Peak Steam Electric Station l 3 t A Hi!Illlllllilllllilllilillfil Job No. 84056

I 3/13/85 As F 1* 7 ';'(f Revision 0 8 E G C 'i f, "[ 3 f:j y ; N !? 'pg 's Page 4 f hLs.u diU Ms! B MECHANICKl sTsIEA5 Open Items and Generic Issues s initiated since the door is not safety related. The door is required to meet Appendix R requirements and as such should be considered important to safety. Documentation and in-spection trail is in question. Status: Open for internal Cygna discussion. 5. Single Failure - Reactor Coolant Pump Thermal Barrier

References:

1. Cygna Phase 4 Final Report, TR-84056-01, Revision 0, Ooservation MS-02-02 (not issued) 2. Cygna Phase 4 Final Report, TR-84056-01, Revision

0. Potential Finding PFR-01 (not issued) 3.

N.H. Williams (Cygna) letter to J.B. George (TUGCO),84056.010, dated July 30, 1984 4. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated August 24, 1984 5. D.H. Wade (TUGCO) letter to N.H. Williams (Cygna), CPPA-40961, dated September 18, 1984 l 6. D.H. Wade (TUGCO) letter to N.H. Williams (Cygna), CPPA 41237, dated October 3,1984 7. N.H. Williams (Cygna) letter to S. Burwell-(USNRC),84056.032, dated October 9,1984 j 8. N.H. Williams (Cygna) letter to S. Burwell (USNRC),84056.035, dated October 22, 1984 9. E.P. Rahe, Jr., (Westinghouse) letter to R.C. DeYoung (USNRC) NS-EPR-2938, dated July 13, 1984 10. T.R. Puryear (Westinghouse) letter to J.T. Merritt, Jr. (TUGCO), WPT-7436, dated July 23, 1984 Sunnary: Cygna expressed a concern that if the single temperature controlled isolation valve on the outlet of the reactor coolant pump thermal barrier should fail to close subsequent Texas Utilities Generating Company was==:e P Comanche Peak Steam Electric Station NN L f A i Independent Assessment Program - All Phases s 1811:111111111111111111ll111I Job No. 84056

3/13/85 E4 Revision 0 N bll;lIFSFk!?.'+?}! [;!3 L Rj p {.. Page 5 / r i I.bE.EIN!;It!"i!k li MECHARitAE"5hi em Open Items and Generic Issues to a rupture of the thermal barrier, then low pressure portions of the CCW system would be over pressurized and reactor coolant could be released outside containment. Westinghouse also notified the NRC and TUGC0 of'a similar problem with CCW systems they designed. TUGC0 informed Cygna that they were filing a 50.55E report with the NRC on this issue and that they would investigate the generic implications of this finding. Cygna submitted two letters on this subject to the NRC and TUGC0 in accordance with our review procedures for a Definite Potential Finding. Cygna has not received any of the TUGC0 documents used to evaluate this issue nor has Cygna performed any additional investigs-tion or review on this issue. s Status: Observation MS-02-02 was upgraded to Potential Finding PFR-01 and closed via the TUGC0 commitment and Cygna's NRC notification. l l m_c_, Texas Utilities Generating Company Comanche Peak Steam Electric Station

== Li(P (=f d Independent Assessment Program - All Phases J6 11111lll1111111111111111111111 Job No. 84056

-. = i 4 7(r [D [IM p$ D 5 5 D[if f N$ n0 J) fd,I [ '" Page 1 E k.m e.15 v E E E U n ([ k l ELECTRICAL SYSTEMS Open Items and Generic Issues 1. Instrumentation Pressure / Temperature Ratings

References:

1. N.H. Williams (Cygna) letter to J.B. George (TUGCO),84056.010, dated July 30, 1984 2. L.M. Poppelwell (TUGCO) letter to N.H. Williams (Cygna) dated August 11, 1984 Susuary: Two instances were noted by Cygna where the pressure tem-perature ratings for instruments installed in the CCW system were lower than the maximum pressure or temperature of system as indicated in Gibbs & Hill analyses. The instru-ments in question were later shown to be qualified for tne higher design conditions or protected by interlocks. The i generic implications of these oversights were not investi-gated. Status: When design and operating data is revised, all existing system components should be reviewed to ensure that they meet the new operating conditions. t 2. Cable Trav Thermo Lag Fire Protection

References:

1. N.H. Williams (Cygna) letter to J.B. George (TUGCO),84056.010, dated July 30, 1984 f 2. L.M. Popplewell (TUGCO) letter to N.H. Williams (Cygna) dated August 11, 1984 3. N.H. Williams (Cygna) letter to J.B. George (TUGCO),84056.024 dated August 21, 1984 4. L.M. Popplewell (TUGCO) letter to N.H. Williams (Cygna) dated September 4,1984 Summary: During the Cygna walkdown of July 16-20, 1984, it was noted that cable tray section T130ACA43 was not covered with thermo lag fire protection material. Cygna reinspected the area in August / September and the proper material was installed. However, the documentation supplied by TUGC0 for the removal and reinstallation of the fire lag insulation indicates that the work was completed and signed off on 7/14/84. This is prior to the Cygna walkdown. While the Texas Utilities Generating Company Comanche Peak Steam Electric Station L% FJ 6 a Independent Assessment Program - All Phases NE Ji!!!!ii Job No. 84056

Vi 7.E E i'. f-l'.? ' ? .a I f 3/13/85 iA fl s= [ E ! Gi c '7. si j.3 Revision 0 i DN.I..$bh!f $fl!.i Page 2 I ELECTRICAL SYSTEMS Open Items and Generic Issues reinspection showed the tray to be properly covered, the documentation is not consistent with the noted sequence of events. Status: Open for internal Cygna discussion only. s-- uc,g Texas Utilities Generating Company Comanche Peak Steam Electric Station [$ [d; 6' 'd Independent Assessment Program - All Phases 111111111111ll1111I!!I11111111 Job No. 84056

....._u.._ ~ f0.[![EE4.y j 9 $1 [.~5j )> 3/13/85 u.E f.iive.. U L.. JgJ Revision 0 g e. Page 1 DESIGN CONTROL Open Items and Generic Issues j 1. Review and Analysis of Cumulative Effects

References:

1. Cygna Phase 1 and 2 Final Report, TR-83090-01, Revision 0, all Sections 2. Cygna Phase 3 Final Report, TR-84042-01, Revision 1, all Sections 3. N. H. Williams (Cygna). letter to V. Noonan (USNRC), "Open items Associated with Walsh/Doyle Allega tions," 84042.022, dated January 18, 1985 l 4. N. H. Williams (Cygna) letter to V. Noonan (USNRC), " Status of IAP Conclusions," 84056.050, dated January 25, 1985 5. All Communication Reports and correspondence written on all Phases of the Independent Assess-ment Program Summary: Given the data available from all four phases of the Cygna technical and design control reviews, a cumulative effects evaluation of all observations and potential finding reports is being performed. This review will also focus on the cumulative effects of individually insignificant discre-pancies. Any trends identified which indicate either strengths or weaknesses in the CPSES design / design control program will be evaluated. Status: Cygna is in the process of extracting raw data from all phases of the IAP performed to date. The results of this review will be included in the Phase 4 Final Report. l 2. Adeauacy of the Design Process used on CPSES

References:

1. Memorandum and Order (Quality Assurance for Design) Texas Utilities Generating Company, et al., Comanche Peak Steam Electric Station Units 1 and 2, dated December 28, 1983 E-$AIG5iB Texas Utilities Generating Company by g' y Comanche Peak Steam Electric Station 1 Independent Assessment Program - All Phases l 1111111111ll111111111111111!! Job No. 84056

st-"'; g i ei d C Uj ' Revision 0 tm.- 3/13/85 h [Ni.,$1.L.d [ E f Ch$h { g Page 2 I DESIGN CONTROL Open Items and Generic Issues 2. CASE's Motion for Sumary Disposition, " Allegations Concerning Quality Assurance Progran for Design of Piping and Pipe Supports," dated July 3, 1984 3. Cygna Phase 1 and 2 Final Report, TR-83090-01, Revision 0, all Sections 4. Cygna Phase 3 Final Report, TR-84042-01, Revision 4 1, all Sections 5. N.H. Williams (Cygna) letter to V. Noonan (USNRC), " Status of IAP Conclusions," 84056.050, dated January 25, 1985 6. All Communication Reports and correspondence written on all Phases of the Independent Assessment Program Sumary: Based on the Phase 1 through 4 review scopes, Cygna is evaluating the adequacy of the process employed in the design of Comanche Peak Steam Electric Station. Tnis review will also include an assessment of the resulting quality of the final design. Status: This evaluation is ongoing in conjunction with the cumula-tive effects review. The results of this review will be included in the Phase 4 Final Report. 3. Qualification and Training of Design Engineers

References:

1. Cygna Phase 1 and 2 Final Report, TR-83090-01, Revision 0, all Sections 2. Cygna Phase 3 Final Report, TR-84042-01, Revision 1, all Sections 3. N. H. Williams (Cygna) letter to V. Noonan (USNRC), " Status of IAP Conclusions," 84056.050, dated January 25, 1985 EEh"" Texas Utilities Generating Company gM l M Comanche Peak Steam Electric Station 181lll111llll11lll11lllllll111 Independent Assessment Program - All Phases Job No. 84056

3/13/85 l Revision 0 )#[% E '[ ! !? HI IIG.t, M,!j p[,]1; Ihf }L ! M V Page 3 41 w ! LW ttn [ ~ u m st'tDNTROL Open Items and Generic Issues 4. All Communication Reports and correspondence written on all Phases of tne Independent Assessment Program Sunnary: Assess the root cause of all discrepancies and observations to determine whether or not a trend exists which indicates any weakness in the training / qualifications of the design engineers. Status: This issue is being addressed in conjunction with the cumulative eff ects evaluation. Results will be provided in the Phase 4 Final Report. 4. Control of Desion Interfaces

References:

1. Cygna Phase 1 and 2 Final Report TR-83090-01, Revision 0, all Sections 2. Cygna Phase 3 Final Report,.TR-84042-01, Revision 1, all Sections 3. N. H. Williams (Cygna) letter to V. Noonan (USNRC), " Status of IAP Conclusions " 84056.050, dated January 25, 1985 r 4. All Communication Reports and correspondence written on all Phases of the Independent Assessment Program Susuary: Assess the adequacy of the interfaces as a result of trending which was performed on Phase 1 through 4 l observations. The results of this review will be provided j in the Phase 4 Final Report. Status: This issue is being addressed in conjunction with the cumulative effects evaluation. 5. Adecuacy of Procedures l

References:

1. Cygna Pnase 1 and 2 Final Report TR-83090-01, Revision 0, all Sections l Texas Utilities Generating Company '4 ' y Comanche Peak Steam Electric Station r 5 Independent Assessment Program - All Phases l HIlitillillllilllillilillliti Job No. 84056 t

.--a.~..-. e i g r an r 3 n 3/13/85 Et)Pl.d. 5 f S E tn.wl t t. ;';*1 f.a."'/y y I-f 4 hr 3 g if Revision 0 S $ e s L e c E s. 0, i Page 4 7. r; DESIGN CONTROL Open Items and Generic Issues 2. Cygna Phase 3 Final Report, TR-84042-01, Revision 1, all Sections 3. N. H. Williams (Cygna) letter to V. Noonan (USNRC), " Status of IAP Conclusions," 84056.050, dated January 25, 1985 4. All Communication Reports and correspondence written on all Phases of the Independent Assessment Program Sunmary: The adequacy of and compliance with procedures for the CPSES project is being reviewed as a result of the initial trending of observations in Phases 1 through 4. The results of this review will be provided in the Pnase 4 Final Report. Status: This issue is being addressed in conjunction with the cumulative effects evaluation. 6. Adequa cy of Desian Documentation

References:

1. Cygna Phase 1 and 2 Final Report, TR-83090-01, Revision 0, all Sections 2. Cygna Phase 3 Final Report, TR-84042-01, Revision 1, all Sections 3. N. H. Williams (Cygna) letter to V. Noonan (USNRC), " Status of IAP Conclusions," 84056.050, dated January 25, 1985 4. All Communication Reports and correspondence written on all Phases of the Independent Assessment Program Summary: The adequacy of design documentation is being evaluated as a result of the usage of undocumented assumptions and inadequate references which were identified during the IAP technical reviews. The results of this review Will be provided in the Phase 4 Final Report. Status: This issue is being addressed in conjunction with the cumulative effects evaluation. = Texas Utilities Generating Company Comanche Peak Steam Electric Station i bJ6 ' Independent Assessment Program - All Phases 116!!"""""'!!Illlll111111 Job No. 84056 i

t Yd]y liIU.l.' h !I [N.0 E 6 h!, f,5

• • I 3/13/85 T

Revision 0 \\[ taf h6in b;(5 I ~ Page 5 v.... DESIGN CONTROL Open Items and Generic Issues 7. Corrective Action as it Pertains to Design Related Issues Identified to Date

Reference:

1. Cygna Phase 1 and 2 Final Report, TR-83090-01, Revision 0, all Sections i 2. Cygna Phase 3 Final Report, TR-84042-01, Revision 1, all Sections N. H. Williams (Cygna)P Conclusions " letter to V. Noonan 3. (USNRC), " Status of IA 84056.050, dated January 25, 1985 4. All Communication Reports and correspondence written on all Phases of the Independent Assessment Program Summary: An evaluation of whether or not the issues identified by Cygna on all phases of the IAP should have been detected by TUGC0 through the corrective action system. The results of this review will be provided in the Pnase 4 Final Report. Status: This issue is being addressed in conjunction with the cumulative effects evaluation. 8. Document Control

References:

1. Cygna Phase 1 and 2 Final Report TR-83090-01, Revision 0, Observations DC-01-01, DC-01-02 and DC-01-03. 2. N.H. Williams (Cygna) letter to S. Burwell (USNRC) "DCC Satellite Review Results " 83090.013, dated June 30, 1984 N. H. Williams (Cygna)P Conclusions," letter to V. Noonan 3. (USNRC), " Status of IA 84056.050, dated January 25, 1985 EON Texas Utilities Generating Company Qel' M Comanche Peak Steam Electric Station IllilillllittillllfililllilliIndependent Assessment Program - All Phases Job No. 84056

L Ik' {,,jN t.t h c c t; l si !h y" j' [ f;E j g 27 l l h** 3/13/85 "} Ih Ii E.I y.) 'T Revision 0 Page 6 DESIGN CONTROL Open Items and Generic Issues Susunry: Observations concerning the Document Control Center (OCC) and control of design documents were written in Phase 1 and 2. Reference 2 was issued to document the adequacy of current DCC practices. Assessment is still required to evaluate the effects of technical and design control deficiencies which could be attributed to inadequate controls in the DCC. The results of this review will be provided in the Phase 4 Final Report. Status: This issue is being addressed in conjunction with the cumulative effects evaluation. 9. Design Change Tracking Group

References:

1. Cygna Phase 1 and 2 Final Report, TR-83090-01, Revision 0, Observation DC-01-04. 2. N.H. Williams (Cygna) letter to S. Burwell (USNRC) "DCTG Data Base Review Results," 83090.017, dated November 6, 1984 Summary: The Field Design Change and Review Status Log was reviewed and Observation DC-01-04 was initiated during Pnases 1 and 2. The effects of inadequate controls on design changes are being reevaluated to determine any possible effects on the design. Status: This issue is closed except for input to the cumulative ef fects review.

10. GAH Design Input References

References:

1. Cygna Phase 1 and 2 Final Report, TR-83090-01, Revision 0, Ooservation DC-02-01 2. N. H. Williams (Cygna) letter to V. Noonan (USNRC), " Status of IAP Conclusions " 84056.050, dated January 25, 1985 Sunnery: A Gibbs & Hill design specification required a different edition of ASME Section 111 than a computer code (ADLPIPE i Version 2c) used for piping calculations. UNOJB Texas Utilities Generating Company rQF T y Comanche Peak Steam Electric Station klulintulili tifillinlill Independent Assessment Program - All Phases Job ho. 84056

3 1 F@ O i f

• 3/13/85 Mhf.f*

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• l Revision 0 bylu 75

$ 75 n,, Page 7 t DESIGN CONTROL Open Items and Generic Issues Status: This Ooservation is considered closed except for review during the cumulative effects review. 11. Inspection Reports

References:

1. Cygna Phase 3 Final Report, TR-84042-01, Revision 1, Observation DC-01-01, 2. N.H. Williams (Cygna) letter to V. Noonan (USNRC), " Status of IAP Conclusions," 84056.050, dated January 25, 1985 Sumary: Three inspection reports had been filed in the permnent plant records vault prior to closure. Status: This Observation is closed except for input to the cumulative effects review.

12. TUGC0 Audits

References:

1. Cygna Phase 3 Final Report, TR-84042-01, Revision 1, Observations DC-01-02 and DC-01-03 2. N.H. Williams (Cygna) letter to V. Noonan (USNRC), " Status of IAP Conclusions," 84056.050, dated January 25, 1985 Sumery: TUGC0 Audit files did not contain corrective action responses for selected audit findings. Status: These Observations are closed except for input to the cumulative effects review.

13. Gibbs & Hill Internal Surveillances

References:

1. Cygna Phase 3 Final Report, TR-84042-01, Revision 1, Observation DC-02-01 UN+~ Texas Utilities Generating Company ge4 ' f } Counche Peak Steam Electric Station kilillillilllililIllill it!Independent Assessment Program - All Phases Job No. 84056

I $ DIE EE ~ t.t g $ ;g f l3,$.. f. A Pi' c I' 3/13/85 I}w. p 'f p } e s p y c g., :., E. d.. Revision 0 c. u Page 8 DESIGN CONTROL Open items and Generic Issues 2. N.H. Williams (Cygna) letter to V. Noonan (USNRC), " Status of IAP Conclusions," 84056.050, dated January 25, 1985 Summary: Documentation which verified surveillance activities had been performed for 1973 through 1977 was not imediately obtained. Status: This Observation is closed except for input to the cumulative effects review. 14 Gibbs & Hill Manacement Reviews

References:

1. Cygna Phase 3 Final Report, TR-84042-01, Revision 1, Observation DC-02-02 j 2. N.H. Williams (Cygna) letter to V. Noonan (USNRC), " Status of I AP Conclusions," 84056.050, dated January 25, 1985 Suninary: Gibbs & Hill nenagement Review Evaluation Reports were ~ not available for 1974 through 1976. Status: Tnis Ooservation is closed except for input to the cumulative ef fects review. ( 1 i

15. Gibbs & Hill Audit Corrective Actions

References:

1. Cygna Phase 3 Final Report, TR-84042-01, Revision 1, Observation DC-02-03 2. N.H. Williams (Cygna) letter to V. Noonan (USNRC), " Status of I AP Conclusions," 84056.050, dated January 25, 1985 Summary: Gibbs & Hill had renumbered an audit finding and not closed the original finding. Status: This is closed. l E*M Texas Utilities Generating Company [gg,' y Comanche Peak Steam Electric Station. Independent Assessment Program - All Phases lilllillllllllililllilllillll! Job No. 84056

-:1... 9 n I E E f T k ' fi F'? l [fif F{ h N[fI[k. j(I h7 r fi *W 3/13/85 Ekaa=($$;;.. 1 j '.g Revision 0 a Page 9 DESIGN CONTROL l Open Items and Generic Issues 16. Evaluation of Gibbs & Hill Desian Reviewers

References:

1. Cygna Phase 3 Final Report, TR-84042-01, Revision 1, Observation DC-02-04 2. N.H. Williams (Cygna) letter to V. Noonan (USNRC), " Status of IAP Conclusions," 84056.050, dated January 25, 1985 Summary: Gibbs & Hill deisgn reviewers were not evaluated on an annual basis as required. Status: This Observation is closed except for input to the cumulative effects review. E 4 Texas Utilities Generating Company ri [pJ L I A i Comanche Peak. Steam Electric Station 5-1 L Independent Assessment Program - All Phases 11111111111111111lll11111!!!!! Job No. 84056 .-}}