Text

Transcript of 800402 Hearing Before PA Public Util Commission in Harrisburg,Pa.Pp 141-224
	ML20126D398
Person / Time
Site:	Beaver Valley
Issue date:	04/02/1980
From:	; PENNSYLVANIA, COMMONWEALTH OF
To:	;
Shared Package
ML20126D389	List: ML20126D385; ML20126D394; ML20126D398;
References
	NUDOCS 8004290101
	Download: ML20126D398 (84)
	v • d • e

{{#Wiki_filter:. 0l' 8004290/ ........ ~. 1 Eefora i TiiE PENNF.,x"CIANIA PUBIll.C U11L1'." cant Usca>tio M 10 n y liEC EIVE D ~.oCo - SECRETAT!'S OFFICE ) i, In m : A l, d I 79070318 CommiJuion Invettirpi. ion intc th" d &ctencied Outages oC the Ec?."cr Vaj ley 1 Uuclear l lj Generating Sna. tion (Pennuylve'11a Power Corapany., 4 Ha?, ring. 1 J ). P-79040173 - Coumj union Trial StnCf Peti';$ on bo l inodify hhe net enecSy claur.e of Duquesne LJrhh / Company. Ho,.rint;. l

i r

] .,, y P-79040174 - City of Pittaburgh c.nd Bia;}or :'iolmr<.i j "t' S. Oc.liguiri Petiti.cn to rictlify the nct c:.ur e:.7 j . l: c19une of Du.quecno Lir;ht Ccwpany. Henrine,. i l r ... - c.no.. 6 j . 3 l l Jarrieburr. Peque '.m ido t. i i .. coo -. - ,. t) 6 d 97..g;oa li'l %c W.' j l 4 4 ., )I, e l[,[}'jI'$ b 8 ,e i? Nurch 6 .'i.'.'0:.' A4cuun n.1P;. i f; r w Parn:,;,- S r 5 *" i .,~ .~. .-..,.,o_..,m, ,,.,y-,-..

4 141 _.. -............_.,...-----.-..~.... - -- ~.-..... -. ~... - q..-...... a .: p fUTF f C UN.LT1Y CO*G ' S' hoi h, p "f COD 210NUM MT' OF ??Du!CYLi"M LT & t it ....oca-- 3' ) I-790't03 G Comissi ca Innstigr.tton into the E,: tended Ontne.as ',i cf the Beaver Valley 1 Hucles.r' Genere. ting Sta t.ico (Duqu.nne i Light Com.pany,) Henring g I-79070318 conualesion Invec tige.tico into the Exten< cd C.atages "4 cf the Enver Valley 1 Huel.mr Generr. ting Ste. tion (Pennsylvanic Fouer Company.) Heari ng 't i of P-790401'3 Commission Trici Ste.fr Petition to raccity the net '[energv c'.ause of Ducincatic Light Conicany. Mearing

,9f P 'f t)0401i 4 City of P9 ttaourgh and MPyor.!1(chcrd S. Caligeirl g". lctition to modily W" het energy cl: me of Duquec& Light jj C ornos.n.u.

Hon.rirg P. I - n V" p;l --ooc-- i ,..s. ' ^ tj Sheticg aphic report of hee. ring held g in See i og Roca No. 2. Norith Offier. 3 Un il61og;, Me.rric hure;, Fe rnwyl ic.nie, .^. ] Hodnesday

. J Ap.il 2, 1980 f

' y at 10:00 o' clock e..m.

s

a s

.occ - g I i grj l n HA3RY G. DAK30FF, AU41NTSTRATIV1: Lo i JU CGn' .q' il --c0c-- m)j I l '~ 1. ' FPGA PANW8 : .. c" e U THOMA3.': TROLIAS ,,,. f ?. O. Ber. 999, Norricburg, Pennsylvanic. lY108 h*l. ~. a. CUARL~ds E. %IOMAS, SR > ESQ.UIRF. /,; FATUICI A L. MMSTE0?!G, CSqlfR f. ,,3 '?c r : Drcimam Light Corm n" ' d Fatu:,y?_vania Feuer Cr,x 'uy l .s p a, j J .......,.....,.,..,,3.. ..,n.-.-. -~ .. ~. _ ,.m._ m.m g m7 ,.,,_ 7 y

l I!w .g~~ [ APPMRIdiCES : (Continued) ^ GREGO C. EM'.RE. ESO,UIRE ,, I JOIIN f.. LTT U. ESQUIPC /- North Orf'ien Buildi ng, Hnrric hu g, P enar.y1' ania For: Cc.mnission Trini Sterf n' IRUIN POFOWUKY, FSQUIRE 4' 1425 Stratrberry Souare, Harrichitrg, Pennsylvania Vor: Office of Consumer f.dvocate U_. IMRVIN A. FUIN, ESQUIRE 313 City-county Building Pittsburgh, Pennsylvanin.15219 7 For: City of P1btoburgh Mayor Bichard S. Calicuiri i n.r 1 1 n.. -} i '.i.G [ 1..y ! ,g 1.7 O v.. 4 I-: E}h k wl, 7/i!I I:. 1.79h ,. Ii x 1.. 15 a 7.0!! n . iI I t

s. l 4t

~. i; 4 / l1 l ..s i O .N n.,cn m ;l; 4 f . o! i ,.,...,.2,. -.-_.__._._.._._..__c..

43 ll C

. !j IH.0EX TO HITH1?SSES I' '

n lj l i i ,?. li

l

?' DUQUESNE DIRECT CROSS i 4l Clifford N. Dunn. 144 (' .r: i li- .. i '/ t il e i INDEX TO EXHIBITS i r. s !- o .T,.RIA.L_ STAFF I..D__S_.UTI__F.I.F..D AD. M...,I.TTE__D, ,u I 10 !. Ho. 1 - DrawipG. 204 204 ... P.1

u. ((

l ~ 1 D_UQ.U. ESNE r-tj Statement and Fr.hibita, previously ,,. O. described 205 .4 ae g i

c. L s.<

t i

j

.g-,.C0b3. UZIit AD.V_OCATE_ I to:. No. 1 - Previouoly deucribed 206 1.7. ',1 .r,

f f t. '

.u.. - i.

l. e.. I) i q

'1 e.d. 'j , ;i 3 l' 3 i .i.. ;j s 3 8 i I e, e i i 3 O I 1 4 .7.. a. I a 4 j i . ~.. = :

.v.: -, ~. -. r -. w : :.:.
,,77.m

.y.,,.-~.m.m.g,- -

o } h lt o i s c r..iEliOHD M. DONM. cel' : a o. . 00 - h a'.* in;;, f '.lI

7. i-baan pc"lo'mly duly n'.1orn accordin7. t o le;* 'm a:. 7..il ued and s

S 7:lI testifi ed as follous : 1. 4 MR. THOMAS: If.rour Honor cleaacs, T;e as'; that) f there be marked for identification at Duqreone Enbihit L o /I l commtmica. tion address: <3 to J. M. Arthur, C'1 iro'2n oc the i ? I Ecard and Chief Executive Officer, Duquesne Light Company, CI!, let'.cr dated May 25, 1979, by J. U. Landis, Senior V!ce .b '.f)Freridnan, Stone & UcLoter Ergineering Cornorn. tion, r.nd the k. 101 cnc?.onur" referred to in that letter., v hich ir. " '.etter ,b, 'i.liinddrwac<1 to Mr. Harold Denton, Director, Office of Nuc.'.c't.c 3.' 3 Faaetor RcCuletion, U.S. Nuclear R gulatory Conmicsion, r d'i.,:.te J 9..' 8 4 o arid signed by W. J. L. Konuedy, Vice h esident t . h't - p, F uco.: I': '%..i ter Endineering Corpor:c. tion. 't 7.'f Thic in the letter ethich te used t.y l 2C[ ?' r. 7'or.ot.0:.y i n c ros s examinati_.on yen terov.,,'. S th)nt the 7 l'T i icttee at:cald bo in the record h May it be r,o i dentift ad'i I \\, 9 v 'ifi,} THE AGIINISTRATIVE LAN JUWE: G r. a ntod. I b %D w p, t .i ? !! (Duqueene E thibit L, abohococ.y of le tt.er Tldl e ted llay 25, 1970 to Mr. J. M. Arthur i frca J. U. Landis with enclosure,?ar 0 produced and n:arhed.for identificction.) ?.. ) ,.., i 1 I l .; i n f f. m,..,) a t i l 4 i w ~s.-9 sg.p sa si w w.epg.m.s e e.ma.no.e'p*** ' '"*acome'=v***- -w 7.mw y - -e u ae M y -tr -e

- _, _. =. 1M . - - - - _.. ~.. - . -.. ~ - -. - - ,1 1 y t p

== : /

7. !

Br MR, Ti!0MnS: 3' Q Mr. Dunn, I shou you what has been marked for 6 identification en Duquesno Exhibit L and csk you if the.t 5 exhibit is two letters, one addressed to Mr Arthur by 0j Mr. J. U, Landis, Senior Vice President,. dated May 25, 1979, f f 7 in which there was enclosed a copy'of a letter frcra a O[ Mr. Kennedy, e Vice President of Ston? & Webster Engineering. E*[ 8enior Engin?ering Manager, to Harold Dantcu of the Nucinar. j t ] 10j Tiagula' ory Comissient c U.l A Yes, it is. l ,.e 12-Q Is this the letter to Nhich you refelred-D .i

3 if yestaroat; in your tentiracuy and which Mr. Popowsky t. sed ut

.i Mf evous '.mraining you?

- c'. '-j A Yec, it is. As you recall yesterde.y, I j 10f indi(:ated the Stcne S: Webster letter to Mr. Danton was undatsdj l'l at least the copy I had, e.nd the date rhich now appure on i M N..iat 1.ettor an per the exhibit is ray be.nclwriting., 7S] h MR. THO?MS : Thank you very rauch. Tus witners 1 i 7h! is availa' ale for crose, i f ?,1.'.. re i 7M'l CROS_S..E_.X._AM..INATION., g ~,a e-MR. SAYRE: Mr. Dunn, I c.ra Orr@J 3cyra. I l O 4 7S w torcent the Ocmaission Trial Stc.f f. ifith Wur He na r ' c i 2 ' parmiraien I wi.'.1-ack c. f au quentiem e.nd theo Mr. [.evin 1 l l i L._. ' ....--.. e,.,.n.:.c....y. m. m. .f.i.,.c m.r. m... m _. i I (f* '[ r M *'* %- v, ,4} ,,,p.' ' '.

~.. i P f Dans-crou.s 11!6' 4 ft l ,h, y F t:ill take over for the Staf f. l l C I

7. [ M ti9 SA.YRE:

4 ?s ~ Your responsibilities for the st'pervision of Q 4 the operr. tion and maintenanc'e of the company's generaticu 5 stations, would these responsibilities involve technical 6 decisiono like whether a plant is being operated properly t 7

11 thin. its design 11mitationsY C

A It would in'rolve responsibility ?.scocie.ted 9

1Lth the uansuring of the performance of p?.cuta. yee.

!Of Q But ape.rt from moneurind thuu do you uc.uc u! techplen? decisions as to exactly hon the plcnt is to be.run? Ud A No. There are gcuerel guidsliuca es to 'ecu O t i - ij i o t tbc p.' aria et a to be rttu. I do not m ie tecascary day b.? day : ) M[ dacintout. Trota r. technico.1 standpMn'- I t i 71 .t lot er the technical decisions n lot cf SI:e i 16[ t achoica' work, althorgh it would be under or generc.1 1? d responnihility. 'fould really be delegated i.o th? Ge ne rn.1 I 18[ Sqportotade nt uf Potter Stations,'or furbho e do*m ti:e lina, 19 { b o th.P specific Station Superintendent ned even rurther d:xn j t 20;i-t'aa line to the ?.echnteal group which ::noporto the stetion i g vi o xrations. A r ] ] ?l. So depending. upco uhat -you ro te.1kisg chou % i i 'l R..i a.9d the ecopc' of the responsibility 4.t cott.M 04 an.W:m ' - lu l i j ? M nc.cr:en.1:ation. i, J. 25'. O, ' But all of thosa deeDtetu n'renhually comeno 1 l -... : :::.:vm, :::.r.=v., :=:. ~ r: r. :xn:-ms:: - :r. - c-n.x,v~r: ~ -a-. r a.

., 7.g.gy.,

7 7 n.,,- ._.33 g, _ggg - g. es4

'Dunn~crosa lh7-7~ .s 2 to you, at lenst as far at the citain of ecamand? C Z' A ' What decisions? I i' fa ; Q The technical decisions 'on how a plant is to l l 1 1 4 be run. Or do some oi' them have their ultimate responsi-I bilitico elacuhere in the corporation? 1 0' A. If you mean do I approve ovary operating 7 procedure which is a form of technical decision which governs 6, the tray a plant is operated, the arisuer is no. l t CI If ycur question is, do I 0;oorove every I l 16 { iriaintenance proceduro as to hou a plent iu maintained, the 1 .U[ answer lu no. That is done at lower levels in the i i 17. organiz? tion. O ?. ' ]l 1 9 But ell of those Jotter levele report throegh l 16j you ou du they report up to anyone'else 1 IS A They report ultimately to me along tile lines i i } 1 of com.med I ljust indicated, and, of course, -I report to the I 1? '.5 roc idant, the President reports to thn Chairrnn of the Board,[ ( l l: 38 so I Guou the ultir. tate responsibility icy! with the 1 k EF$ Chairwan from an organizchional standpoint, e I ?E[ On pegs 2 of.ycur testitriony you refer to your e 4 7.1: cunc biomJ in your lq$h codition. In suosectien (d) thert. you I q e j 'i7 I V3fer to DachDlc01 Dreble!!il. What hind cf teciHlical brGhl@2SI< 'M e A . Problems khich come no at cue tinu ou unW' p. P C. hh u mer abation lovel. For instance, syh y um W l '~ ar tlhcfh3r or nob ve.'oyarhaul n un,,t 2g - p e,p y p,* 1,39 -g pg, 5 !!"._.. c. - _ : :;-, c.. n. r r r, '..- - r,-..e -- . -. f,; c e.,- -. _. _ 4 *V 6 9Fy7 ^ ,7 ,.8** pr'ur

g

. ---.4g, . Y8 e ] { T' hN* t t-i M E . Q. ' mrt - i iy **

M '

4 ; (~

f 7..- ._ll!B.. Dunn croso q J. (b uhon ve nahe the outccc. I *sould norti tith other people in P E the org2312ction nnd deterrdne when was tha best tiue for Ts tha.t outage. In como casos I would actually approve or 6 recommend the outage be taken at that time. 5 There may be problet1s on c.ir preheators,.thore 6 may be chemical prob 1 cms, especially in the ch?mistry area, I 7' Mbich would come to me. I Of That is generally it, it is a very broad fiel.d. I ( F Q, Ilave you been trained as a cheminti-10 A Ye a, I have. l 11I Q You mentioned today in your testimouy that one ' 17-of th9 early probicos with this unit was resonnnen in the r g#[nipin3 system,inthatcorrect? e I 1 ! A

Yes, i

i i 4 75l Q Do you know whether it is no.rmal prone. dure in i W5 design Mark to consider the possibility of-that.kinej of e i. ? ) U[ i.'auonauca and to design a system in such c tmy cs to cvoid it?: I .1 2A A I atil not C d0 Sign engiDacr, as I testifie c j y3Hte.?da"., So I rOnlly CS.n't anS?Ier DDO qu?Ghion Uith ai;y 4 r ml-fl3GrCO c:? GEpOrtiSc. I e Q You don't know whether that in a facter that J P 4 i ?S.4 ",oes into planning the desirr,n? arAl a I cannot tastify from perscaal Ir.ncule6ge en 9c F ?.7 :how the ulsota are designed. I can only esotene thc2 cuch j 8 1 Ei things ya ttkan into consideretion. i f ..-.-...,-............z....2...m..:...,.,,:. . - - w. ,,...n 1 - P'"J

- 'Fr fF"l*;*'""*yM..

@ g.., -. : .;qq ;. ; 7 vggysyTh*yrz:-Trrg*rp_,,

. -~ De.nu.cr oss 3)tg. d -t I. It is nY Ganarcl iscrun.i oti in. retrospect in Z reviewin,7, the problem, what tras dono, it m.c one which o h probably could not be anticipated because not only did it involve the pipe configurations, it also involved the trim on i !!1 a valve, and nico involved the number of impellera and the 6 speed of the water feed pumps, 'I So there were a number of combinations of 't i 0[' eronts which crocted tills re.ther unique problem and ib only l l y occurred at approxim.tely 20 percent of retod cepacity ond ".t t 7.0 (. did not occur ovary time. 11 1 Q Would you agree that the licensee is crimari.ly l U. responsiMn for c.csering that a nuclen.r p19.nt is safe? l U{ A The prine responsibility does rest uith tim M{ licenseo. I testified to that yesterde.y. However, you do as, If the licer.see retain consultants, shall I s?.y, who hc.ve certain 16i o ryertise in 'mriore, technicci fields, froa pipe de. sign to } I t M t. cr.uids flow to electrical systems, coabrolled instrumente. tion,'! IN n'.lat beve you, who holp you in the design end conctruction d j ) Ff Md initial stagen of operation of. any facility. be it nuclaarj i l ?M oc be it fossil. I ) SI 9. Eut if there is a safety problem uihb tha ERO,. s f ?2.[! the bock stops Uith the licenseo.. is tuc'; right? l M[ A The.t ie~the NRC's positica, rec. No, mao ning; 1 p { i ?,f! the uM.lihy th'.t has the license,10 the era tha MEd he.rne to j M. f ar : any rancivbion c::' technica? c' roh.' rau, 4 4 ...-. ~. .. n e...:, a...,..:..., :u w:. ,c . -...~:. u: , -.., r m. _ j l r. yg._ y _., ,,,.,,,,.,,,.w,,,w,.a,,,..cm_.

1 4 Liutu. cross 150 j - - - - ~ ~ - - - - - - - - - - - - r-- f 2 Q If a plant in not snfo no riesigned

then, 7

vould,yca scy tbc.t it is the licanuse*s reopensiblity? l} A It would have to come out of some sort of /t investigation as to in what way the plant was unsafe and how fi unsafe end in whose judgment unco.fc. 6 Safety is e relo.tivo question. How safe is 7 unfe? Not even the NDO to this date has c.nswered that r O question. Q If it is uncare in the opinion of tha URO, then i D 10. .imiting; the questico in that uny would yc'.'. ogree that it is 1.1 the liconsee 'n responsibility? t U. A It clopando en the fc.ct situation. -l O D ;[l. Q Under, hat circumetences would it not be thw ] l 7A .i. ice ns es 2 s rocponsi'ility? o U A Where there is on honest difference of opinion 1 a 14 betweco hhc NDO and the licensec, including the technical i 1.7 ! r epport the liceasco ro2y call upon as to ahtt the fact i U 0 ai e, iter. tion is, and -whab judgmenbu are tecdr 1 don't holietre l 0 c 7,d '.he l'.'RC is the ultinc.bc cuthority, the court of.last reco?t, I. 7.0 j-e,s to +hother a plant is ccfe or unsafe. i l i .t. t Again,-I uill repeat $1 hat I scid b0 fore. Ev en

l

) 6 1

10 She NRC today canno'c define bo'; safo is unic.

Safoty is c t 7f! fcletive torn. I-f ci[t, ~., s whnn the licensea na the Mac can tap the- :.Da s Il T'Gr0c. th?.t. for GO.fety' E S22e CCrtain thiU'f S m'1S '2', ' cc dODS tC 1 'il t --. ~. n-- ?e 7 t _ r.c:.1,; ;m:. - m a w;: w. - -:.., :w - ~e -, e... --e ee 1 _,,g.. my y y~ p.g y-wwwmm ; wem -

.k _g Dunn-cross 191 i E i the plant, then that '.s the licensce 's re,;pensibility, isn't

2. -

it? l 5 g. A Once tre a6ree that certain modifications must f be made to the plant, then it becomes the-responsibility of 5 the licensee to soo that that connaitment is fulfilled. 6 The licensco mndo tbc corsitment. Tho ? licensoc should fulfill it. A l Q You just mantioned that in the course of }. f T' builditrg a plcnt the licensee has h01p from contractors. To. 10 .your knouledge, did your architects and ongineers, Stone & k 11 ' Webster, get c.ny outside opinions on their design proceduren f l .ChinthecourseofdesigningEcaverValleyI?? j -l 'r n j D A I do not knor. 9 $*'h! Q In it correct that in the course of the seismici u X5fstress prob 1cm Stone & Webster wa.s revietiing tiin stress 1 1.6 c2lculations beccuse of notification from-Hestinghouse that 17 i thm'o uc.a au crror in their specifice.tions. as to the -valve 1, i 1C[ tietghts? Is the.t tchat started it off? l i l i IQ A. The who2.e thing started aa the i.'eault of e. I EGIdesign change we made at Doaver Ve.lloy trhich I tactified to r, 11 earlier lastardcy. In the course'o1' this design ebenso it-i 7J. nme to +.be attention of Stone A Webctar that. there Mas n - I i 22" differcuta in the eclglit of a valvo 'between what shoued ou the : j} p ,j .% drawing rnd thich Stone a: Febster userl in their scica.in i 25j am. lysis. ?nd tbch which they h2.1 availabic to them.frc~ I

n. ex. m =..... = :.. -

.x. e :.,... n ~ %~ 3:. m.'.~~+ ?

. ~-

c.* ?*7 y

C*f *

*lG7p*i"Wls*T**r***** %WM f ??[ *Ty*K*u ft;j (g

(

DODn=crOB3 -159 y L 0 R[ other sources. O e 2 According to Stone a Febster's sciamic I Si analysis and according to the.information they had available 4 to them at the time they did it, the valv'e we16hed 250-pounds, i 3 Tboy Icarned later th-).t the valvo actuo.lly.weigbcd 450 pounds. 0 Q And that was an error by UWctihghouse in I upecifying hott heavy the valves were? n '3[ A No. I don't kno'i whose error if indeed it t/cs j h an error. 7.0 Q Well, the specifica.tlons you say said 250 and' '1 11l the valvos are really 450 n A', A No, I didn't say the cpecificabious un.id that.' r 1^" l I said the drcwing indicated the valve weighed 250 yoveds. 10 The drawin6 would not necescarily be a specification. The-Crawing 1.s one which the engineer doing the seiseio I]I design tnuld use in hin input to his ce.lcule.tica, 17,j T'oare is a valvo there. According to my' print- ?li it weigha 250 pounds, therefore I input tbat into tha i y ,. I 6l progre.a. I ZN 9 Do you kno 1 what parscn or antity re.a F d T.O recponnible for labeling the valve on the draring at 250 I I i 23 insteed.of 4507 t 1 1 n A . No 3 I do not. l

4. qj r

.l' i 2'!1 .4 If tha vs.lves hr.d auteclly zeigtad 90 noundy i n l 3.E d0 yet 'lL O'I '1hath0F Or-not thO '1 hole 7 M r>S Sp hor 0 rould hCVO a %.--.n ~. ~.< :, v* ~c~;,, t.:..< :; t, ;. :r - ;;y.~?: ~n - : ~~;~ ~m, -.i, :n :.6 - =. 1 l L ] j .- e.- g,, .y ~. . 7..,

a 4 I 153 .,..,...._.. D u n n.. c r o c e i C

. !tcon e.de Juo.te uaing the NU?IPE computer progrcrg?

I- '7, h A I do not knou. i S' Q Do you know whether Stone & Webster or anybody ) i /!.l: et Duquesne made that kind of analysis? l ) 51 A I do not kno;r offhand. Perhaps that analyaic M was medo. You said NUPIPE, which is. not the code used in the 7 6esign of the pinnt by Stonc & Webster. II bn. TrIOMAS: Read that ensucr back, pleaue. 'l 9-1 .o,l (Ansvar read.') e i 7.0 [ 1..t BY I4R. SSYRE: 1.?. 4 Ubat chout the PSTRESS Shock III program that D ..>3 changcd the method of edding the force factors, trould th he.ve

7. '

been cecaptable using that program' if.the.valvec actuel?.y 70 weighed 250 pounds? t Idonotknowiithoutgoin.gbachandlochingatle ...&p A e .?? y!) the recorda. The de.tr. pcasibly e::ists scacple.ca but I es.nnet t-t Mf rocc11 it offband at this point in timo, f I6[ Q Yota have tectified that no lose or safet.r r 2,0 function would ha.ve occurred with excessiva stress in one of L ?.I the si:: flow pahba, in th'.t. correct? t ??.I A-fact wr.s the information which was provided in ? f;l

the various reports which wera stat to the' NRC and it in th

.i p

.Vilbcsisfo"pytestimony. My techimony is based uuon the l-R 1 4 !Td >ccorda. not upon my personal invo2.vocerit. 1 1 t =.-.n c w m. =...c:.=..~--.c...........c.=.,,.-.n.. ~.._ y.

.W5 y Dunn'crous 1% = q s! Q But somebody at: Duquocnc c Ae to that F I p, conclusion and. reported it. to the NRO, is.that riy,bt? ,c) l A Stone C: Webster came to that conclusion. Thcir fi /g conclusion was reviewed by at least the on si'te safety n ri committen and came to the same conclusions, yen. S j Q - I presume that.with too much'of a stress in one s i 7 fcf the flow paths then the reason the safety function would i G Inct have been lost is that the.other five-would be availabla i 9.in s. vedunde.ucy kind of situation, is thc.t right? liO ' A Ecdundancy is the answer to the question. 11 ] Q But is it correct the.t all six flow paths. B,tnder thn later eniculations that did not use algebraic. i O yhedditica; all sl:: were strccscd beyond the all'o'emble obress D L l'ij,3tler'etasfarastheNRCdetermincdit,isthatr16ht? 7 d r 13 A I don't believe so. no. 1.j p Q Uhnt is the difference betroen alleve.ble strest? 0 Nnd yield strosa? is 11 ,Q A I can only give you re-intercroh'; ion. E ain 6 s P cI m not an export in the c.rea of seinic analysis, I will 10 ::aswcr the question on tbc basis of my qu?.1.ifications in the !f 7.1.ftastimon:. I'. 7.?, g'l Allowable' me.y be a stende.rd estab1'i. sher 1 by sono fi %1i;crganise. tion, not necessarily the NRC,it.s to what.iti n q O I4 7.hjr.cascuab. a level from the stc.ndpoint of drecign. - i E! Tield ntrass.is that peint.nhee the. pipe; i, ,. -. =t s.. m. - c ::. w.:m. m.m. s ~::.m:-. :. - m.. -...- f I ,.m.--.-,.--.;.,_9,,.,,,.,, ++ r x. .a.

' ' " ' ' ' ' ' ~ ~ ' ' ' ' ' ' ~.' ~ ~ ~ ' ~ ' ' ' ' ' ' ' ~ ~ ~ ' ' " ' ' ~ ~ ~ " ' ~ ~ ~ " ' ~ " ' ' ~ ~ ~ ~ ~ ~ ' 155 I Denn..crosn .h. ~ yi o sy band or tui.st but not necessarily brerk. i r i' i l i 7 Tharc is another value, and 7. bnve forgotton ] i e n T; that it is called, in nhich there is 'a high probability the I pipe Mill break if it' exceeded that number. 3l So you have a'dosign number., you havo n' yield 4 d0 number, 2nd you have a fnilure number. l 7i I'may not use the exact connotation from the in t N etandpoint of the technical peopic, but that is the way 'I put. li O I it iu Dy NordC. U i Nj 9 11 hen the csiculations rero-rorun were any i e ?.1! of tiia pi. pes nbove the yield number't .-l 3 A I belicyc the answer to thW; question you can l

'p j

F .., '1 i 'p' find ego 3 in my direch testimony in accuac 'T in the ' inst i 1 .d'I ec atence. The recalculated stress, levels ucceded nllouabic '- i 2 ISl; etrouses. l 1 Honcver, they did not onceed yield stresses, that i 9.i u, Grfo. mntion uith or without breching, a.xacp b it onc cas o I i .., r a de cut of the six flow natha. ^ J f 3)!! Q After revie'erintf that tortion of you.r testiwouy_ 20!.it in at?.11 your recollechion tha.t Icos then sik of the flor I I E i p. bha Mu: e stresced bayond the c.llotmble stress. is tint l i q i 7.I r1*}*0 W! 6i i h i i U,C A My testimony sparks for itsol.f. 'I don!t kns I; i n

i. -

e 1 2Si 1 o >r J. c i add euyhhi.nl; more 1to it, 'beth in ry direet ?d ste.tcrnu; ' u t'a!.1 c.s the variota ehbib' tu atte.cbod 'to it. i ,l ' S h k.ch .0 reI .[ .e 10 .s' or shO .O l-) h jdbIt.Y. ' .nh PCYIor s -YO. I i.._... _... * <. m.,,... o..,r.:. ....,..._..,. s :.,......, _ ,._r. _. _ -i i '****f-e f.e '/ 7.r g

q..e

,s .m, ,,,,,,,wwq ,y, ..g ,,9 p., i i e t e .r

'.. - - -.~- 1 - Dwulcross 156 i . _.. _ ~.... _ _. _ _.. _ - - ~ - -. - - ~ - - - - - - - E i s', ii 2 F nado to the DRC can be found in. cither hhibit A, B or C. 2 Q-That does not culto specifically anster my 3 question. I am interested in how mr.ny of those flow paths 4 under the now calculations -- in how acny-of those paths 5 c.11onable strecs was exceeded. d A I do not know the ansucr to your qitestion. 7 q Would you turn to hhibit D, the NRC show r'< cause order. On page 2 of the show cause-order aboub half 9 way down, the HM refern to a General Desi6n Critorien 2. "A

In the.t r, difforcut document from Ecsulatory Guide 1927 O

1 13. A I do not Imou. U .Q Do you kncer when Gcueral Desi6n Criterien 2-s i O .,vd i y m'.a issued by the NRC7 4 lh A No, I cm not a desilin engincor? i i n Uji Q Une Duquesno the first compnuy to uncover this I d a :j ru:ticule.r deal:m yiroblom? y 4 3 3p ? j S That is my unGorstanding, 1 i bp 181[' Q Mac-it Duqttocne rather then Stone & 'feuster or ! t i am p }

~[any chbar colapany thet actually mado' the.. first report 'to the

) 2C[LIRC7 _[ ^^} A As fe.r as I know, the prob?.cm burfaced cs'the i s 1 'E[' rest 0.h of a design change which was initiated at.Banver J 1< s[ 7 alley. The design chzuga, among other thingu, resulted in O ,.. ij 4 v ;. the comutation cf s ;rasses in certe.in cipes twinr te:: i li 1 D. df..Cterent ectputer codes. 'The results from the tuc- [ I . "- ;- a.<;*;. t*. -* 3* % ' ;;. ;- ;t h 7 *;.t '. c:f f *.. 7-a "; : rf,--'r. .a. y ;, ; ~ ;... w u. i p-r pre yve,* m q1 a s?m

* *. ]

. U r~-*** y?f3 7+r "$y' *"*^ T T - ' ' *__'t i

O Dann-crosc 197 7 Y .' i calcuk.tions shoe'ad significant differencen by n factoc of, r

j 2f I hava heard three to sist, andasaresultofthc.tcifferenceb l

t 3l the whole questicit was raised. 4 Q But, my question, though, was whether Duquesne 5' was the first entity to report to the NRC. And that is l 1 4[ correct? ? A Ac for as I know, yes. .F Q Uere the other plants that t'are shut dcun at d' cr cbout the saac timn by the NEC for those scismic 10 calculction reaserts cll designed by Stono G Ucbster? s ?.E [ A I am not c hundred percent uure. It is my U unde.vetc.tding thah at 1 cast sorae of theta, if not all of them, O 3 ;, A- ' tere, boccuse the comacnality which the NRO saened to be i 'B,P lochim. et 'rac the Stone & Webstericalculntica tachtt:Un. l' Dl Dut I em not n. hundred percent curo. t I l} ( MI It is easy to verify by looking in the Gray .l U! Books. I 1 l !.C., 9 Alco en Exhibit D goir.g b2ch t: th ,/irst i F 4 page of tile order to shou cnusc, I am interce :ed " cry much in k the whole recital of facts that the NBC mr.%cu in the.t .J.ljraragraphIIcftheorderthatrunsfrem:thefirstpage M throug,h, I guess, the Acct fe.1.1 pa.rcrpraph on the third pr.ge, .,.I NJ I toold liho you to ano.lyce., in light of the 1 i O ,.,.) Pacts thr.> ycv cre nt;c,r3 Cy of now, Cach of Dhc39 Tort.G"Tohs Of 1 I '.{ ?s -- ;p the crder to shou eens :: an9 tell un in uhr.t rtnnc%.- l " ' ] .. -...... r : t r~.m c - - ~r:n :.. -~:... r c. *,. a rf n n .r~

-,4

-~ m_

ISO Dunn; -- us c r.o.. -. 9 i

t. l.

p 1 ? ; he recital of f:v.te by the NRC is incorrect, t-Perbs.ps we could just do it on a pr.rngraph by I t o.- [ larce;raph basis, and if you feel you need acre time than ne

r have nore time to tc.he a look at it,'1e could look at it 5

rgain after l ech. -'? A l'io, I uill do it now. 7 I!fl. THOMAS: Hoff far does your question 607 7 Clear over to pisc 4?

r. '

j l'J1. S A 'I R E :

No, ;)ust pesc.3 I would leavo -3 r. ;- ;. cut bhc fun-over pe.rngraph from 3 to 4. That seems not to be r ^ j( a rF Citation of f act. t- j THE HITNESS: With regard to the f.tre.h O '".' e.regre.ph, and thic is the NRC's show cauc e order, oc i '.I, 1 therefora it is what they wroto reflectir3 thair interpretc.- r. 4 ^l tion, their understondine, in the third Jina bha word [ j 11 ,; i.nadverte ntly, ic used. I don:t imor uhather th-.h i s a troe 1l g e. b k t charactorizaticu or act. I N. I cieply say tho.t what 'fe reportad on g I Occmber 6 in LM: "(8-53 is chcun in Dhihi.; '2 The @ ola r i report iu tharc. j ^' s s j:i Uhether the stress compuhrbious inc.diccrtentl;r i 1 .27. !g ! h ?.d nu t bo m c o'w;.1. ete d T d on ' t.sucy. I cen't v..;ree with tbnt ' 11 - > q D t D }. G 'uOliit ih ti!P 3. g d - 4 O l +', M MD. Sr.UE: .i et S 7, N '*' N O, Or 1CDc To cord,. COUld,CJM dQ f.^

N.i at A'

L -n = n.t - ~ - ~ : t, - :. - :,= ~ < * : - ~ =., * - 2..

~" ~ '~- - -.

.-~~' . 77- - t-y.~. , ~ - -

Dinn-c roa s 59 1 n g -.. -.... ~. l 1 1-A I. ice nact Event Report. D S Q Thank you. T 3 A With regard to the first full paragraph on 4 ); age 2, I do not necessarily agree trith the statement starting 5 in the fourth line, the fact that the piping analysis' code P specified in the application for en operating licence uses an ? olgebraic summation. It is not elect to.me and I don't thinh

E'

- it is clocr to the people who are doing the revi'en 1: bat the 1 9 commitments ticre in our cuerating license. i V] I don't hacessarily say that as a hundred i AQ percent fact. That in something uhich is being revietrod. y"< Again, it is comethi og based upon ini erpreta-O c 4 13 Sion b.y pecule far nole ear.crt in the field than I cm. t 5'd. Q Wouldn't that questi.on be anct:cred if the-4 C( cperating liconac applica;, ion simply said that the code to A e nalg.c this would bc.* STRESS Shoch II? I Aii A The licensing trill spea3 for itualf. I guese 3 ) 1 2 3.0 : the ensucr to the quoetion is if the law ma ttritten as clns.r i /r,, : that rou arc inplying this should bc ?ritten here, then there e WIl*40uld tc no need for latrycrs. It is an interprete. tion of e htt i { ~ i 41. . ti=.s tTr i t t e n. e ?#j Q -Can you tell me,, dooc the c.pplice. tion'fdr an ] $ apercting'liconne specifically strte thr.t the scicmic annly313 O 2i[ 1 "culd usa FSTRESS Shock II? l I a f {' I-4e.dx} A- ~ I don' t be.'.i tva -i ; +.;r hit I he.v not genc 'sc [ ... -== :O*, *,

f. * *

g *,*,, tatc, f * ****/**~~*"

r?. * '?.*N.*; N "a "*. ***M,9...-...... _ p. gry, Q.g ; g.-,. 7.+ - u.~.. -- . ~. e r.wwp p r.yy y ;y.,-~; ~ s.m.,, .y- -. npen. _.,..

~. 1 e i l N htmtycross .Mo s 1, look ct ~ the operating licenso, and tho-conatibnent, really,, I 2 don't Imx if it is in the operating 7.icense or if it 10 in 3 1.hc FSAR, Final Safoty Analysis Report. - 1 Q I gucas I would like to me.ho that request of i 5 rou to tell us at a Inter date o.'hother it in speciPlod in i 4 cither pf those documents that PSTRESS Shock II ur.s used. 7 MR. TIIOMAS: Uc will look e.t it. D THE WITNESS: Again, in that sc.me parcgraph *-- i D end tbla is a matter ubich no discussed yesterday _ -- the J.0 sont:cuco in the middle of the paragro.ph so.ys: this incorrect 17.' trec.troon; of such loads was not recognized at that time.. 12 Escin. I am not convinced it was.nu incorrcet treatment at the, ? O l v'I time tilo plant uns desi.gned. It may h?.ve been an incorrect l l M troo.tment under regulatory requirclacnt;s.in 1.076 or 1977 ki ?.S ~ hon na y;ot our operating license. I .VI 5" idR, S'iYRE: 3 i 1 .i ?.7 - O, Areyoutactifyingth2titMaocor.cectatthat_{' 4 'J.Gi tius or Phat you don't knou whether or not.ii, nas it.co.'rodt .D,CV0r7 ?B A At who.t tiraa? i g 2.1lL Q At. tbc timo the original -calculchion 't?.s rc.ada.. i 'l I i j. i ?." ! Stre you tastifying thc.t that calculation was correct ct thei h pan.g g .:is c ?

i p

2G. A I am tectifying that in the arn nht:n-P.m*cr 4 3 4 C',y-11oy. um beitr dauignedy again cae er., Scll-Ir~, abov 1972,- i ..... ~ - * "7 7,9,q d * =**"***M*, ..tr * * *.

n ' * * * * *" * * ~l *g..

"f*'***,*-i =, a eE ' -r.mer e n s s rvser**sP*-*.*g l r'*.* P r*

fA * * " " ', ' '

f '*W***7 ""'**J' . T '[.'f ;," s.. M, f'~ y

+ .%.s Duuu-cross 161 d( - - = y* 1973, 1914, it to my understanding tint there were no p. 2 cpecific HRC guidelines as to what war. being done, c.td

p. thereforo each architect /cogineer -- and that Soes beyond 3

Stone 8: Webster -- was pretty much left-to his own methods of F mnking these calcule.tions. ti The IsiRC, to the best of tay knowledge, did not 2 0;o into any detail on the codes. 'It is my understanding if If you go back in tho.t period there were about 29 plants which S tore designed using a technique which ubes thia algebraic 10 s uramntion. i 11 The technique may have been used to various 17, clos m a deponding on the plo.nt. Some plants any he.ve used it ' O i 5 on1.y ou. mall cyctems., Other plants, stch as Beaver W iley, i 14 it ems used on all systems for which the computer ca.1.culations 7.S l ere nndo. il. N So in 1972, 1973., 1974 it is my underebending --} ?,.}frnditlaalwayssub;iocttofurtherrevioubypeople1boare I t J.r orperts in the field, cha11

e say

- the.t that uns the state j a FI of the a:?t. )d 29 It was accepte.blo in terms theP. it esc unver 1 ?;j. reif acted. when you had something like 23 planta that wera 1 w 21 oporchin:; at that time which were designed and ccustractad. V ,9 raing tb'.t 3:ipo'of conputer code. 2.; L o. sue. referring to nuat you ident r ies abis. ?.5 Ecruit?,nG DbiMt L cn p'On 5 of nveu, the neend ~ full

. r.: n :-

~ : x::m. *::c,. :-~. -, ~,v nvn* :. rr. '". 7'rnr. ~t-~ ~', ~ ', S t '. -- ----- - --- +pNwgy e- ._ m.,- s,.e ne + w e. gly p, 3.p 7; lem y 33 y ,3

_ _ _ ~ i truun-cross 162 I 1([-parac;raph on paga 5 of seven, the seccad soutence, they p + i 2[ indice.te. do they not, that even Stonc & Ucbsher used n L 3! aquare root of the cum of the squares summation, or,at leasc i k 4, had available to it that type of computer program in 1972 and 1 5f 1973, isn't that correct? d A They may have had it e.va11ah.'ic to them but I j 7[ there wan no requirement that that procedure be used. ) 3' Q But they not only had them o.vailable, they T* used that prog. ram in 1972 and 19737 j 10! A They me.y have used it..They may he.va 'ecen 11, chill in the development ste6e. I do not knoa what was. t X2l goine; on in the Stone tc Webster orGaniz.?. tion in terme of' the O U:I developmont of ths.t computer and what degroo of confidence i /4( they may have had in that model ate that particule.r time. -.. d MR. THOMAS: If.t/our Honor. pleases, I thinir D H M bhis letter from Stone tc Webster to the ERC bc.c to be ha' ten I 1 1 T.i ( in its full context boce.use on engo 1 at the bottom of the t '0 page it.nstys the NRC bcs contended tha.t the use of algebraic A j E summation in this case uns incorrect -

a do not e.",ree.

y 00 l I think you have to te.ke the full context of l

d f tbc letter.

I don't believe you can take one or two t P,[ .;cnte nce a. I think you have to'take the full letter. L i .43 UR. SM'RE: Your Honor, th?.t iu.a mr.tber 'lcr O 2H era ment f. S5 UR 'GOMAS: Well, it tc y be a me.tter for. L . m :-.. : : a - _w._ : n

m. :.a.n.-. - s.,,. _. -. 7.-~.

... r, n.c _.__._ p,,. g.,,n,, 3, ,g.,.., ... ~, ,f.,,.y, m.p., ...7,,,s,. y-

I i .... ~. - _. _.. D..u a..n - c r o n.,a... -..- -..... - -....,-._1.6 3 t 7- ~ n. 5 i EI ergument '6ut T. just don't think that we should -csit questions O 2 which may be out of context beccuse I bhink you get tbc wrong i result. t 4 EY 18. SnYRE: 8 N Q Shall ne continue with pare. graph 2 of j 0 Exhibit D? Have you finished your comments on the first full 7 lps.re. graph of pcco 27 O A You have to read the whole paragraph in I r . contexb er the comaentu I he.vc circady made., For instance, 10 ' the ucnt sentence says: -auch loads should not be algebraically E1[added unicos far more complex time-history analyses are j O'.' performed. That is the NRCfs position.,- I r l Q And you disagree? e A I don't nececcarily' disagree. I am saying O that is c 'cubject which is now being dis :ussed, and again N l i are tolk$ ne, about time differences. Uhat existad and uhat j m. M 'ms acceptable in 1979 was not, in my opinion, based on L 1C information I have availabic to me necesacrily the controlling ? w factors in 1972, 1973, 1974. i 3 orl 'y In that period there ucra e aunber of plaubs, .] 31l23operatingplants,fourunderconstruction.,which~uerousing i 1 ML the algebraic si.imaatica techniqua. ii i So it rac the state of t.he ert. Mes 14 ~ O ,i d Ifoll, it was accepted in that it u.s not rc,Joetc6. - l .,a.' ni:cepted ? j> U Q. !!r. Dunn,.I Mould like you te confine your

t. ' '- - + 6-.---. T *.*T."M.*2 a rM.") *C.V., 0*a e. ;:7 T*. * :'*:"/* ? ti'*/, * ' t. ~ "- "- ? " t* d t **. -
M
F # NN '

"4 y y'f 8 R'j" '[ .flP8W"** ' W# *-[ 0*" Of ,L 'l', T '9g".-. ', s

[ [ - [ ** = '

c w Dwan-crocs 1 6113 ,e v i I II anaucrs, if you can, to my question. All.I whed you at thet O \\ S timo tras do you egree or disagree uith the.t stateraent. ?) I MR. THOMAS: Nou, if your Honor plec.ncs, one 1 4 t.hing that has to be kept in mind -- e.nd I object to 5! Mr. Sayro's remark to my 'vitnocs -- the paragre.phs or pages "<' l to which Mr. Sayro han referred in his question contain nob 7 caly factual statements but they contain judgments and E cpinions by the NRC cud I think that the uitacca has e. right o to corcment to the extent that he says he is qunified to ( 10 comment. 11l I have not objected to questions beccuse I i Uf want it to go if it ce.n. But at the same time, if thcae are D .t "! ;Judgraento cnd opinione. of NRC, then it is t it c factu?1

A' i question, is this right or is thisiurong; thoro can be 3

difforences of opinion and I think it has to be answered in i 1 I MI that context. I 1 Til If the.t in the conte::t in which thrt questionisj l 1A anhed I have no objection. But if it i:: cohad te e. streirSst ' 3 i t 19 aut right or urong, then I would object.to the question .'E'! baccuse 1.G is asking my witness to comment'on opinicus and l j 'Aj judgments of the NRC. 1 V-f.!R..SMBE: Your Honor, I don % think thore is ; 'i _t .-- l c Lthar n.t objection to the question er n.' motion,to abrihe i M j p M-[l 4 ptnding, ao 7 nm not eure whe.t the laat remn.rb rio.c 16 c.id of. ,,]I' MR. TH0!MS: I' will tell yott ubs.t. it : tan in ' ] .~.- .x.-: ~ ww: n. v. -nr :, r,. : r :.- - r u m r-: s e. v-m t ,., ~ . ~,, ,_y m. _ y en., m,-. syp.ye4nny:r c~

~._ ~. t i D 165 urm-c ro s s...--.. - i nid or3 Mr. Snyre. If you are acNinr the avestion in the s y ~ i O ( j 2. context, is this statament right or is this wrong, in that h 3[ context I object. T I ,g ' In the context of asking the witness to I f; comtaent in those instances where they are.not factual /d utatements, they arc Judgments or opinions, than I wouldn't t '/ object. D

You have asked my ' witness an extrenely i

0! difficulh c.nd complex question involving a lot of nosertior.s, t 10, nnd ha is trying to answer the questiom I don't think he l t i I { lI[ is respchsibic for judgments or opinions of the NRC in l .12, respect to decign matters as to which he has said ho io not ^ D 13f a dcaign engineer. He is trying to cooperate, t 14 THE ADMINISTRATIVE 'IAU JUDGE:

Continue, f

13 Mr..Sayra.

h.. ',iDY IR!. SSYRE:

f.7', Q, HaVD you coGpleted your conMOnts Uith r00pect f 10I to the first perngraph on pago 27 ?

t IP[

A Yes, I hava;, and the co m onts I made rou.1d ) r j 7/F e.pply uch only to the upocific parts I have talked about } ,7.7, liut the varagraph an a nhole. 4 i 1 2p, In the third parngraph the trord in the very t ,1 -{ Cg first line, the innppropriate annlyticed treattient, the "cra, j 1 O 2,};i ino.ppropriate3 I think is c. judgment on thc NRC's pn.rt e:hich l 25 .tay or.mr.y not be trua. s m i ,' 'J,' * * ";.* '. C' ? A ** * !* C! *?., *j N.

1" " *, ? /"l7, [*.*!!.*. * *J* ['.**",.. 'J * * ',I"""'7*.*,.*P,*. 1* i "A e.e.e -.

..,7 p

q.

A,_, y-- g;%.-m 97 w my, py.7,mp.,y, .; mg.7,.w w, e

l l

q...,,. -...... _ _....

...... -.....u.n.n.. r a u......, .,,. _.. 1_6_6-D co l

(

1 y, p In the very last soittouco 10 auyn: it is in P [ J. { those runs that the predicted carthqu?.7 c ltnds nr.y dif fer t 9 ( 3 ; signifienntly. Age.iu, that is a judgrnent. They raa,y diff er. t 4 h'hether or not it in significant is comething thich v:culd 9l como out by the cetual. calculationc thetacelvec. What is 3 6 l} nignificrtut is a jud.grsent, t 7 Q Could tre go en to the run-over paregraph 6 from 2 to 3? ? A In hindsight I talte exception to the whole h J0y parce:raph. Again, thin was t7ritten to Merch 19T8 ebero the 'li. g! i HM really didn't knor the anstrcru to the questiona which had Ul haon e.iued. They indicated cn honest conecrn: is there ) O + U fl an me eviewed cafety question? ,I l ' So the whole paragro.ph reflects a forecight t .9 { ' /c) e.nd an assumption on their part the.h there io c. aigniric;nt l 15 ] ornh.1.am. l tl .. d I think in retroepset if you look et tbo f i 10;. immber of desi~n che.nges trhich ucra tr60 in ac:na of thaun ) JM riants as a result of the revien you will find bbeo rather e i 20 insignificant, e.t leert in the case cf Mair$ Yankee whero 7.E lthere were cccentic.lly no modifications required of the ii + ?.7. l-plant. ae I unGorstnud ib, and in Boaver Valley trbare the ?J ! uombsr of modific::hiona 10 rather sm l.t in horms cf the 1 4 t ) ? '[ number c:;' croporhn which were e.nalyned. 4 e i St3 hi Stic0.lly, 33 7 'Oc".'.1 'J orCO figurC 9 UD C.

6 L.-

- u - r : = e.. -~=- m. ~ n, u ;, :. v - = -:. - : - m.. -,. - - w......-,.. I ., m

. ~. _ - 1 Dunn-crons - p/ .r. i = l p .T [ ] read semcplace, there narc very fat: denign modifications 2[' necessary, 1 or 2 percent, something lihe that. l 3 So I would take exception in hindcight to 1.; 4 the implication of that paragraph which was foresight on the h 3l part of the NBC. 4 ed Q Now,in the next paragraph I am not going to 7 csk you to analyze the last portion of it that talkc about I 'E based on this more detailed review the NRC sts.fr hns 4 i P concluded, but do you take any exception to any of the M1 ctatencnts in the proceding' portion of that.first full 11 pare. graph on page 3? U-A The second line, by this error. I don't egrae j t O i d,.-[ that necesso.rily an error was mede. How far in thah parae:raph l i t JN: ' do you wish me to go? i 4 3L Q Stop with a centence thah anys: concurrently I ,ed ; on !! arch 9,1979 the licensco cuspendeo power operation of-I l fi i t the facility. After that I won't ask you to refiew it. 4 Ml . MR. M10 MAS : In other worde, does the tritueen h i 1 M' have cny comment on the first fivo linos, is that the 20 g.ucstion? ) M THE WITNESS:.First seven. 27,[ MR. E M E: The firct scran lines, yea. ~ !j Mj; THE WITNESS: Other than-tha quest $cn of .) O t 20 hotb0r c.r not an error ms me.de, I-thinh that parec:cch, to iH j ~ y the c: tent I have reviewed it, tho first savon liner. La .1 L- - t:.e ..? , r. ie ~. m.. = : :.cwr ::: a? vv. -::n,:::- ) ~,. -,.3,,7. r -, -. ~, -, ,- ~, ; .-,q. .e g,. .,,-,p., . v.- a - wr. a,% g y., - 4 ~-

t Dunn~cro st !]_ 168 1. 1 ractml. - 2 LY MR. SAYRE: I 3 Q Who at Duquesne Light is+most. familiar with ) 4 Stonc 2: Webster's past or present methods of calculating S coismic stress? 0 A It would be someone in our Mcchanical 7 Ensinocring Department. Idon'tNnouwhospecifically. i 8 MR. SAYRE: I would mcke.,the request that that' 9 person be identified, j 10 MR. TtIOMAS: We will have to find out. r Al l MR. SATRE: I would also4 request that you i f 12lidentify the person at Duquesne Light who is mont familiar p i 2 O with past and present NRC standards for scismic designs. E MR, THOMAS: Just n' minute. Let me get the l i i D firsi ona down. The first one is who at Duquosne in most 1 ( l 10 familiar with uhnt? 1 l'! MR, SM'RE: Stonc h Ecbster'a pnut ced precent j .I/3 mothetis of calculating seismic strans. - F MR. TIIOMAS: I woiald think Stone 2: Webster 20 -. should answer that question. 21 MR. SAYRE: Are you objecting to the data ??, requestadi i l 2E tiR. THOMAS: -Hell, it in geing to reauira. -p l M:lccacbodyatDuquesnetoanalyseStoneccUebater, I.would } M' h. jj think Stone *: Wobutor uould be the. onas ubo. itnen that they. 3 } b..._. c rc, -: e :r :te..

a.

,: r, w :m.,- - . ~ - :r.m:,:- c, n. : u I b Pd%9W '.A5=,j.-,-, ThI* sM'.. f '

~' b D.

q W

'd

W.4 46 s P.spes #. .a#,'$44.. a. ge1 wJir Eth,_m.- {u.un-cross 169 7 _-..= f t L ho.ve and have not dona, otherwico ne are,n.;oirs to h?.ve to p. form e judgment. 2 c S I am willing to c:: amine into the problem. I i ,(. uill come back to you if I think we can answer. 3 [ t ' ~ 5 !

12. FEIN:

Itwasmyunderste.ndingthat ) 6 uomebody at Duquesno was.the one who fi.rst cscortained that 1i ) i g. there was an error in those calculations. That would be G. probably the person that would be most familiar with this

I P

problem 10I-THE WIhiESS: No, that is not correct, I?arvin. v 11 " It was not someone at Duquesne who firct indicated there was 'j a ' i '3.7 an error in 'ho calculation. There was comeone in Duquesne c i D 1 El1 1 vbo first obsarved there was a difference as between the 14 s.'onults from.tro calculs.tions; there were dicerepancias. i 1 15 Whether or no'c they were errors in a second question. I 36j

12. FEIH:

All right, it would ta that percon l ' U' 7ho is ruost familiar, I would assumo, because that parcoa ens l 10 looMn3 a.t tho' calcala. tion in Duquecua 's orgcnization. !l1 I 19

18. 130!!AS:

The question, at least an I i i l 4 4 l 20 'indo.str.nd it, is: who at D9auasne is.most familiar with- .l a 7' Stoni n "oNter'r, past and present anthods as to stress 20, analreic? ] ( 7M. Now 'wa can say this gu.r, rhoever ha ia, hnc7c 1 y[ r g 1 9.: [a nora abcit Shane & Webstar o atress calculcP.icus in Duq'.'ocuo i 1 i 'j .h 'Olan snybody elsa, but we are not saying bt is r;;cing te be j It e - ---.--- wemn. :r..=.r.. = -. =.

v. -.. --

.-:- ~=r-r,xe.v..- 'N app 9 q -M sgpympWa_-; q,.W ^ $5 ,4p p e _, n ep e. it we % es we n, pert feedpge_* y,5 eggy.ywp1p p.ye.yg v s a mgWas p sp e ee,w a w

= I . _ _-_.Dunreerosa. L170 d ) i XI the e.nsucrs as to what tha.y crc. ]

2. 'I C

i li But let's So on. I. taill try to find sottothing - 4 3 out. 4-THE WITNESS: What is the second one? 5 IIR. SMRE: Who at Duquesno.is most familiar 4 4-ulth the NRC past and present standarde for seismic design? 7 MR. THO?mS: We are goint; to try' to find cut 0, 1 but the.t is a real lond. 1 h 9 MR. SMRE: I just want the nam? of one pornon., L 10 l:. MR. THOMAS: I underste.nd uha.t you want. 1 ( 11 [ MR. FEIM: Could ue also have the nacie or the l Dn-. person that discovered the discrepancy? D q' I "I MR. THOMAS: You soy you ucut the nari.c7 If} UR. FEIN: Yes. l t i AS. tTR.- THOIMS: We will get-the ntme,, t, @ ET MR. SMRE: I t 7,7 Q Do you knctt who in the compery made the i i 13 decision to report th.ts problem to the Huc1 car Regulatory 1 1 1# 0?mmission? I Mj A Yes. t ?I Q Who was that? i i M j3 A Mr. Worling,. the Station, Superintendeat. He { d I [ ij TI ma' Ice all such reports. } l D

4. t Q-Nhat 4s his'first nime: '

a -, i DI A Juec. He cisned the latter uhich is shcrn in-r.in :.-.., ~ m=. w. - r: =. r.ea::cw :s : - c. nnm=*. - ~ ~ --~~ tl' l' i

M#W

[* i'Y 7 ' Y. 'l 9 6

Dvnu ercim 171 f- <I i lh<. i tu.. ~.t o C \\. L .l 9 D, I thint /- l 3{ A It ic F.lso C. B is an earlier oce, d 0, And he has o.uthority in the corapnut; to send ..D, ;be.t off trithout epproval at highcr loval? i l d< A Ilo had a responsibility to Go it. i 7 0, I gathor from E::hibits Ale.nd H - ord 1'la r3aing nt 'l be es?.; you to correct me if I o.ro urong -.. that originn.lly in t< /**, l l : ho d ecmrcry or hhic probica there vero come cchuel errors 3 ruccenrod in usits the hand-calcule. tion se hhod, is tivlt ' ', e nr:. a".t ? y',* l A I don't have that impreunion no. .T racce,ni m O

.: 1 the

ords which unrc n.; red in thero., th0" uallt chonb

} "I laapni'opriate U. a oi' n hcud caletD.h.t10uy bu' I don 't I rota ..,'. b, j jthahlwr or not therc !!as an error endo, a 6 l ~l d 4 Oculd you turn to pego 1-ot' Rr,hibit l'3 the 27 k ebird peregraph there. startirc tiith tbn senood lino, state: f p XUd bat there wra arrers in the piping streus cualycit i e.mit t.r,g j t E 2 rom a.n error in the haud cclculation raathed, in tha?. cerra :b7; 4 .,g d Th!'.h iS Mll'It it ;30.y5 2 D i.[.13'*. pO..VU.iCIJ..Il'r.O01Hh i e s j ., y. atime out I nu ender the intpreccion tbc 3 Mune Q Uebcte.r ban ..n 0 * - }.. C 'ti ?.t.,j

7.'s

.s)3 f.r 0 0f11 $ 1 0 0 CO.C Od UpO D. 13. j'O.,1.' t i l:2.V OV i N'J, Of.' t[lO c n Il -l proh3c9 Cd !b.uthor or no", thora ' c.:3 m crror Umde ir t y1d ociac rilr: 1.-:,.i. M.e voi co be deterai.ued, t< /tI' il . ' - ~ ~ ~ - -.. n.-- y *,.;, _~ s- =n o y, r,* ~,. - - - - - - - ', y;' ';, =,. _, _ f.) f' a 9

cij *j ;)
Q ';.Jg

(?,1h{ ge.; p h,*'1*,1, h 1O d },f $ l *.*"} *;D 'A 1 P.d d 0 ~> v. ,-,,.y gm,,- - -....--.w..r v. , y,,... y -. m y.- -

.a = - - d' Dtmn.-cr oss l'(2 p._..--.~..--... . - ~ - - - - - - ~ ~ - - - i g-of thilign? On one ha.nd, the use of' tha hnnd calculo. tion C ,q method, and on the cther hand, the difference in ecmputer ,e, ' codes and the way stresses were added up in those computer 4 codes, or are all those part of the same. thing? 5 A You use both hand-calculation acthod as nell 6 na computer codes to do your design wor!c cud hand calculation 1 ? ? methods, as I understand them, arc really charts which a .O design cugineer con une baccuse he has c straight run of p a P l pipo.'.ith a certcin weight and c. certain. pressure, and i in somebody has m '.de the calculation many times before, and here

15. { is c table you can go to and find out what the frecuency is l'i. and wint the usights cre and what serb of hanger would ba i,

j I? f appropciate based upon peut experie'nce or past calcu3etions. ( 14l It is a simplified rhethod. From a pre.ctical I i 15l standpoint you cannot use seismic type dynamic computer codos j i i ) 14' to an,. lyt e every pipe in n nucicar reactor plant. I?, O Icoking at the next to the Inst line of ?.0hthibit l'., page 1, escin it referc to onor: 4.c the c.pplien-4 Fl.nl.on of i.he chart method. What kind of crrorn doec that t 20j refer to? i r i C.7. .A I do nob 1 mon. I have tried to get c.o.neucr l' n -1 pI h the some gycution.- It is my interpretation et thie poin% t .g .%; in time that there me.y not have been an error, but I.do con . j O i .Q; hacu. This ie.eemething which is bein5 stn61:6 by eur outbide 'El consultant. who is an export in tha fl.cid, ':he.is ' 6014'.y to l

m. :- --

e:r ::::*.. ~:: :. r -- ,m . -m -- a-r =: - e, m. a m ------- r --- i .m =.,.. - nn. g ..,y m,y, .g,p;ng.p~.,y- --,,.,~ e n.

?.!uutt-cro s a 17 ; L 1l revic-ub:.i.6 Stono a: Tiebster did. D f s 2I '1"ni s w or d, crror, appen.Ic umny times in 3' Exhibit A ard appears in some of the other exhibits which 4 reflected someone's opinion based upon limited information I a7nilable to him at the timo he wrote the ichter, 0 lb is my impression, bace:1 upon subsequeilt 7 review at a 1cter point in time, whether or not errors of any g m9snitude were made is still subject to revicw, judgroent and e! i ultimate decicion.

b 0,

I still don't understand, thoup;h,.chather him i II crrors referred to in 8xhibits A, B, and C with reapect to hbe-J.7. hand calculat;ictm or the chart method beva enythirig to Go tiith O w:.30 thor er not stress vectors were cdded al;;ebro.ically or 1:1 t i t. some other method. Co.n you answer'that? 15) A Ho, I cannot. Q In Exhibit C on 9050 1 of the 7A consce Il 7.Noni; Korort, hich is the third p y;c o. th'?.4 c:r.hibib, tu.dar r i ind'.)l the paragraph 2*T, cause description cd correnti.vc ectiott, H wl. 0:;ein thc.ro is a stetcmont about the arror, i 70): a I am not trith you. tihare are you ree.61n:.; ,.2 { from? i i. t yt 1 Q About half na.y do 1n tir! png. A Shich page? 1 O l m l Q Tbc first p?6e of the.r.d eaneo, g.ang aer crt w~t d;" '.tich is the third pc.3c of Exhibit % chor.t be.3.f a'..'r de "n the m -. nu.., r .,2 ,:. r.v.r.n.,a..._..,: .__,7..__. m.,.y,.

. - ~. ..m - ~ ~.. ~. - - +.. Dubn crouS. P/h t y, ' pogo, I ;ucas line '10, it refers again to the error and the i C . time p. misapplication of the chart method,- but at the sano/it states 3 " that corrective action was completed. Is that correct? .4 A You. 3; . Q Do you know whether or not the NRC approved f,.i the steps that had bocn taken at the time of that~ Licensee 'l Event Report as closing the matter of the errors as they are D greferred to here in the chart method? I ? A I don't know what the NRC-mey have done with i I 5

to e egn.rd to the question of, whether or not an error ?;r.c made.

1). I do knou that the NRC did review the design change which we i U. made to thic..particule.r cystem and we are satisfied that it D !.S tan edequate. M 9 So uhat you are saying ie. then, then after '!S this Licenace Event Report, the question of the arrors in the I 'i ici chart nothod.was closed, is that righb1-L'j ] A No, I did not say.that. I am nrying I don't ic Jnow unetly whore that questien ultimate.1r anded up 9.nd hoc'

Ff it was resolved.

20 I do know from the standpoint of the physice.1 l l p j

'.1 ' chanson vc mado to the plant, the additiencl supports no put I

p.p in, one enubbor, the NRC was satisfied that the piping enc g, r. n i 2M, adequata in torres of the design changes dia6.e.s i I 1 f J. i 7/.1 Q Although you subseqt'.cntly br,d to shut de : n end 'l il '\\ .W ar.hn tu%hc0 waificationa? ~ g L .:..= w.,.:--.

-. :- ;r.q.n.: q.r. -- : -.-

.w., wm ; 7nn ~ . ~.,,,. ,j y., _ 7, n, qy-7.e ,pp; ay, q$ y,_

a. - -

s.--

as,.=- , s.u .a .r-. a. o. , * ~ +- 4 D 17cj-- _....._... _uin n c r o s a : = A' I don't think we made further modificablon'.'. .I f p g of this particular systora. I 1(R. THOMAS: - If your Honor pleases,-I hc.ve nn. .q, 7*, urgent telephone call to make end I was wondering if we could I r: have three or four minutes, I don't no.nt it to be lonn,, but \\ 6 I would :.ihe to mche the call. l cj TrIE AEMINISTRATIVE iAW JUICE: 'We will.ts.ke a j l tj ten minuto receno,

e. :

(Short recess.-) }.k 4 j y.i CLIFTOP.D N. DUNN, resumed, U. DY UR. SAYRE: I t i j 7..? i 9 Mr. Dunn, does Duqncena have s.vailcb?.e to. it 1 (, l p'. olthe:.' Bl'c 1iUTIFE computer program icy hba ISTJLES Shoch III JSf program? i l i I i. 8 ) 1-A In-house? 1 'l I l

7.,

9 Right. ?

,,h A

To tin bech of ray hwwledge, nn, j i 1c: 9. Stone & Nobster van thosa progrces on tim l ypt occouione tho.t you refer to them in yciur testimony, is that .I y.:;j c '.sh t? l l 4 t 4 4 'i 3y. S YOG+ l 3,t ['I 0, are you cecrs of any: URC iloceraunt th.? b l r .i ) ,4 O ,g c9ecifierily e.pproves. algebraic additi on fev c eicmic otrasu l12! c '.1culo.tient. ? fl , e:.m-.,cr - - = :-: m .~.- n. :., r r. ,.. - -.:-m. re. r ;. l' l ..y- .y. o . g 7., .-.,.3.)

g.. -,

-g, ,. 7.,;;.,7~, .c.q g -.*7 a ; g. - y qq;g- .I ,,,ggy;e e s m.._ +. -~

= j Dunn~ cross - 176 gn 1 A I am not' aware of any that approve it, I am not j 2 aware of any that disapprove it, if you are talking about 3 periods before Dbcember 1974, which is che date the Regul'atory i /) Guide 1.92 was initially issued, and its-effective date which 5 I believe was April 1975 I 6 Q Does Duquesne have any insurance to cover the 7 cost of purchase power during extended outages of nuclear O plants? 9 A You can't buy such insurance at this time. 10 Q Has Duquesne considered buying a transportable 11' transformer? 12 'MR. THOMAS: I want to liear the question, O M plence. Af (Q'uestion read.) v 15 THE WITNESS: Considered at what point in time 16 and what size transformer? As a genera 14 answer to the a 17 question, yes, we always consider it, and yes, we do have 16 portabic transformers. 19 DY 101. SAYRE: 20 Q I mean one of the size that woulck be n' 21 sufficient to replace the o'ne that caused the early outage 22 at Beaver Valley. 23 A This was evaluated at the.tiac the statien was i 24 being dor,igned on the basis of an economic evaluation made. 25[ j At that time. the= decision was made not to have a spare f -- rexc.c. sex e e.mm:n w.-m w. t.oc:rar_:.sw m.- nexc=.rra, n n::.:- ~ 4" ~& r& . w"~ ~ ' R~~ ' =~ '? ?" > '~

~ ] Dunn~c rosc 177 1 itransforuer. p 2' However, with a second unit coming on and the j 3 fact that we do have a spare transformer at this particular 4 point in time, we will maintain at the site, at least of 5 today, one spare transformer which is available to be used at 6 either units in event of a future transformer failure. t 7 BY MR. THOMAS: 0 Q By any units you mean BV-1 or BV-27 9 A-Both units, BV-1 and BV-2, and we would also 10 make that transformer available to any other utility who got 11 into serious problems and wanted to borrow it or even buy it. 1E EY MR. SAYRE: O j 13 q What is the cost of that kind of transformer? 14 A I would be guessing: I don't know offhand. 15 q could you turn to page 12,of your testimony. 16 At the bottom of the page you refer to the purchase power 17 credit on the net energy clause for March through June of 1979 10 of $751,000. Am I correct in understanding from your 19 testimony on cross examination yesterday that that amount 20 , would have been increased by.the $19,880,000 that you referred i 21 to in ant:wer 15 on page 14 if Beaver Valley had been running 22 at 91 percent capacity factor? 23 A No. 24 Q What is incorrect about that statemenb? SU A The time period you"are lookin<; at. The O t.;MODAC*1 WA303M MC. = W N.1.OCZmtCW AVZ. = WI=IRT. N. W 30 - l .,_-,_._m.,,.. ,-7-.,- 3- ~,, .. ~,.. p,

Dunn-cross 178 q. J l' $751,000 is for a purchase power expense for the period 2 March through June 1979 and those are calendar month periods. 3 The figure you refer to later,.,the $19,880,000, 4 involves a calculation which covered 162 days and included 5 not only purchase power but increased production costs on our 0 own generating facilities. So they are not the same. 7 Q Would all of that $19,880,000 have been 0 reflected in the net energy cost? 9 A That is the basis for the calculation, yes, i 10{ Q Is Mr. Werling still Station Superintendo nt at 11 Beaver Valley? 12 A Yes, he is. O 13 Q He would be familiar, would he not, with the 14' errors that he referred to in his report regarding ' he hand-t D . calculation method? 16 A Not necessarily. He, again, is not a seismic 17 design engineer. His reports reflect information supolied to ; 1GL him by Stone & Webster. In the interest of safety he would 19l have to essuma the information is correct and act 'accordingly 20 . until such time as the information is either proven right or ( 21{ wrong.. 22 Q Then I guess I would like..to make another data 23 request of you, the name of a person at Duquesne who could 24 explain that Mr. Werling referred to as errors in the chart 1 25 method or hand calculations in his reports to the NRC. momet e nr.snt. rac. - o w. toc:wne ow ne. -:.xi. r:ot no. ra. mu g,.n,-..- ,, y.; ,7 ..y m.gr. g.- ~--

. ~.. Dunn-cross 179 1 A His report'is based on the information shown 2 in Exhibit A which is a memorandum to Mr. Worling from Stone & 3 Webster personnel. 4 Incidentally, Exhibit A also contains some of 5 the answers to the questions you asked earlier involving the 6 valve weight question, paragraph 2, specifically. 7 Q That is right, Westingh'ouse furnished the .O drawing, is that right? 9 A That is right. 10 Q But is there. anybody at D'uquasne who would 11 understand the problems with the hand-calculation method? 12 A Possibly, yes. I don't know who that O 13 individual would be. 14 Q Could you furnish either that name or inform 15 us that there is not anybody there who understands it? 16 MR.. THOMAS: We will inform you as to whether 17 Werling based the statement on in-house-information or Ston2 & 10 Webster information. 19, MR. SAYRE: My request goes beyond that. I 20 : would like to know if there is anybody at Duquesne who,can 21 explain the natures of the errors that Mr. Worling referred to. 2,( MR. THOMAS: Well, then,-you have changed your i 23 reques ti. 'I thought your request. was who gave Werling the O 24j information uoon which he used the phrase, crror. 3 i l 25 MR. SrlRE: No, I want to know if there is anybody there neannCM te MAMMM IUC. - 2:* F.1.0,cir/E.,0W t/n:. = IUIa:OctRC Pr WT2 - _., 7,. ,3 - w..., ..~ ~ m - -

Dunn-crose 180 g I I' who can explain the situation. p 2 MR. THOMAS: We will try,to find out. I would 3 like to go off the record a moment if I may. 4 THE A31INISTRATIVE LAW JUDGE: All right. 5 (Discussion off the record.) 7 BY MR. SAYRE: 0 Q I just have one last question or pair of 0 : ques tions.. What were the available percentage and the N i capacity factor for Beaver Valley 1 for the full year 19797 11 MR. THOMAS: The availability factor is already 12 in the record in answer to a Staff interrogatory in O l Exhibit 10A which I think is Item No. 9 It.is in there 14*- through July. I don't know about the capacity factor. MR. SAYRE: I am interested in the full' N calendar 1979 figure. I don't think ' loa would have that. 1Y MR. THOMAS: No, I don't think it does. If it 3 is not in the record we will provide it.- 19 MR. SAYRE: I yield to Mr. Levin. 20 MR. LEVIN: Thank you. 21 BY MR. LEVIN: 'j 22 Q Mr. Dunn, your original training was in ( ,i .N 4'4 j chemistry? p 2'l': A I h' ld a Degree in Chemistry from Carnegie o j Mellon' University. s.a, ,n m=. . u.- n - e.-w.w - nun. .-..7 .~ r m..;.7 m n y.. ,., ;,rsm,.. n #,-7.gq ym m g y ,7 ~~

Dunn-cross 181 1 Q Did you specialize in any branch of chamistry } 2 cr was that a general chemistry specialization? I 3 A It was general chemistry but-I did take a 4 graduate course in Nuclear Chemistry. 5 Q What year was that in? 6 A Approximately'1955, 1954 or 1955 7 Q Can you tell me whether all aspects of nuclear 8 chemistry, such as metallurgy, physics, and radiological-9 subjects were covered? 10 A That is a big broad field and you could not 1 11 possibly cover that scope of technical information in the I ]. 12 course of a one year or year and a half program. D 13 It involved both lab courses in terms of 14 dealing with radioactive materials' It involved actual 15 experiment involving radioactive materials such as lodine 131, J 16 Cesium 137, Cobalt 60 perhaps. 17' It involved claceroom discussions on theoretic 18 theoretical physics at least from the standpoint of radiation JS chemistry. 20. It involved concepts such as half life,,, 4 { 21 shielding, decay, nuclear structure, very broad. m j 22{ On top of that, of course, I had specialized 23 training programs in preparation for my nssignment at 24 Shippingport involving the theoretical aspecto of health 2Sj physics, radiation' chemistry, radiation training, as well ac f nm:- mn a marsu, me.- er ru.oe:nm.:.cw.w::. -:rmicaune, p.s. stm c e ,m,, _.m., -, w.,, y p . m, r - e. y 4 g y,qp y 7 ~w

~ Dunn-cross 182 es ) 1 practical applications of such techniques at the Material O t 2 Testing Reactor in Idaho Falls, Idaho. 3 Q What was your assignment at Shippingport? 4 A I had many assignments.. Initially I was' i 5 responsible for the chemistry program, subsequently promoted i 0 to a position which involved responsibility for the training 7 of operating personnel as well as general plant training, and 9 ultimately I held a position where I had tne total 9 responsibility for chemistry, training and plant testing, 10 Q When you say chemistry are you referring to 11' chemistry of primary and secondary coolant loops or general 12-plant chemistry or what? ] O N A Yes, to all of those. Total plant chemistry 1 14 involving both primary and secondary. D Q You would be the individual who would have 4 j 16 general supervision over anything having to do with plant q 17 chemistry and radiological safety? 10 A Plant chemistry, not so much radiological 19 safety. 20 ~ Q Would you say that you spent a few years at 21 Shippingport? l 22 A I was there frou tiarch 1957 through october }'t E 1962. i 2h Q-Was Shippingport a pressurized water reactor? e 2- }. A. ' Ye s, i t i s. mer: men a w,noxu nic.-a n. i.cc:rmu.m w::.- tmm::cu e, n ::::a ~- .-~ - ~~;; -~- y p,,:7 ; :7 " ':Y~

y.~

.. -,.; ~ :

' " ~ ~ '

Dunn-crosn 18'4 1 S% 1 p Q Was that one of the firsb pressurize ( *ater 2 reactors built in the country? 3 A Ye s, i t was. 4 Q 'It was operated, of course, by Duquesne Light? I 5 3 y,,, Q And you were an employee of Duquesne Light at ) I the time? l Q A

Yes, j

Q Would you say that as a Jesult of'having worked at Shippingport for those years that you have a good ' conversational understanding with the hardware of.a nuclear i 12' ' i D . power plant that is a pressurized water reactor? u A Generally, yes. ~ 1A* Q In Beaver Valley Unit 1 a pressurized water i 15 reactor? \\ A Yes, it is. 17 Q Consequently, when you discuss the various 18 i i events and engineering problems in your testimony, that is ) i 19 j partially based on the experience that you obtained from 20 working at Shippingport, is that right? A i 21 A Partially from Shippingport but also partially ) i M from approximately one year experience at Beaver Valley. .I s 4 ' spent full time at Beaver Valley in about'the years 1974 1975r O

D I' don't reca11'specifically, but anyhow, the period just prior 4

1 25 I to the plant beginning its start-up. j raermanen a uncun: rue.- c n. s.ocxwn.t.w em.- rearmaa, en, m ia y.- ,,. y.... m -.g 7 - r - l , mq

g,,,

~ ~ . ~; ~ ~ ~~~ ^^ ^ ~- Dunn-cross 184 1 Q Are there any areas in your statement that are 2 not from personal knowledge but are from basically 3 discucsions with or selected from conclusions of other 4 individuals? j 5 A A lot of the information in my testimony is ) 6 ba. sed upcn what I have read, particularly information 7 involving engineering concepts, design concepts. As I 0 i;estified before, I am not a design engineer, particularly in 9 the area of seismic, nor am I a nuclear engineer, as I 1 10 testified before. j 11, Q Of course, to the extent..that you obtain that i 12 information from other individuals and sources that would O O' be hearse.y? N A No, the information I get from people in t 15 Duquesne Light's organization I consider to be cr, edible in 20' terms thc.t it.is being prepared and submitted to me by 17 tridividue.ls who are technically qualified in their own 13 specialized areas. 19 Q On page 3, question A-7, is your response there 20 . from personal knowledge? 21 A It is primarily based upon the documents which a 22 are available in this record as well as3 again, I would have 23 to go back to that particular time whether or not I got a 24 telephone call frem either Mr. Moore or Mr. Werling on the M subject. I. don't specifically recall.' i vemmex o m,an:w me. rr n, s.ce::wn.t.ow a.-r.- nc maune, n, wm .p,,_- ....,gg,,,,, ,y g - 4, y

- - _. _ ~ - DLuin-cross 18'i 1 c A i 1 i O My knowledge on the basis of this testimony 3j was information which was supplied to Duquesne Light Company j 5 l by Stone & Webster and subsequent reports from Duquesne Light-4 Company to the NRC. I S q The last five lines on page 3, are those your 6 own worda or were those selected from some other report or l l 7 statement? .0 A Those are my words. 9" Q Did you testify earlier that while you used the 10 word, yield stress, that you could not tell what it meant with i i 11' regard to NRC terminology? 12 A I don't believe so. I indicated there were O 13 essentially three or four numbers which-I normally see. l If 4 Number one is a design figure, alldwable figure. Number two !l 15 is a yield figure, yield stress, which.I indicated is a >4 t i 16L figure which indicates the piipe may deform, bend, twist, what I 17 have you, but not racessarily break, and that is why I nut i Ill those words '.<nich appear in the next to the last line in ) 19 a parentheses -- yield. stress (deformation with or without J 1 2 3 20- bre.aking). j 21 Q When you say allowable stress, is that 4 } 22 )allowable stress according to your own calculations or j 23 cllowable stress with regcrd to NRC regulations? O 241 A Allowable stress based upon whatever the design j i l 'M. i criterion is, be it some code or be it an NRC requirement. I 3 -- e. c:nnacri a swat me. .v x. s.ccr.w.m.vu. - rumes=c, en. tvi en i ~ ~ - ,.,y_...,, ,,m.;, y,. meyc p9 py yq ~p , niep s,g mg yrqr n [r7 * [^

Dunn-cross - 186 4. 1 Not all lesign requirements are necessarily NRC documents. i b f 2 Many of them are other codes. I 3 Q Can you tell us what that design criterion 4 is you are referring to there? 5 A It would be whatever the allowable stress-would d' b3 for that particular pipe. I cannot define' it any better J t 7 than that. 8 Q Do you know in whose opinion allowable stress 9-is defined? 14 A The words I used in my testimony are based 11, upon information supplied to me by Mr.Werling via Stone & 12 Webster and you can find these words in the various exhibits. O 1-3 j Q That is my recollection,,too. 14 A I must rely on information supplied to me. E ,Q On page 4 you discuss the difference between 16l the algebraic summation and the. square 4 root of the sum of i 17 the squares. Can you tell us why the square root _of the sun-13 of the scuares is a preferable method for making stress i 39 calculations? j 20 A It is preferable today because it, as a general 21 rule, results in more conservatism in t'he design. 7 Q-The word, conservatism, -is not very 23 illuminating. Can you tell us mathematically why that results 24 in a better calculation of stress? 25 A I don't know if it results in a better er vorce - mmmen a mmmin,. me. - a w. we.:r ra.cri ex. - n.missue, n, er s.: M*MN4b"'9',' NN' 'IH 'N' f IE

f'

_'f I )* 5I k .c .3 r%

Dunn-cross 187 s I calculation of streso. My word, conservatism, is a word which 2 aptly deccribes the difference between the two results. It 3 is a quention of how safe is safe. How. conservative is a 4 design. + 5 e with regar'd' to the algebraic summation, is it 4 possible for the. algebraic' summation to predict no stress in 7 a situation where actual stress or deformation would occur? O A I do not know. Anything is possible. It is 9 a statistical calculation. It depends upon the numbers 10 involved. 11 Again, I have never used the computer program. I 12 My general understanding, based upon the information O 13 j availabin to me, is that you have two computer codes for j 14 making seismic type calculations, iThey can, under different-i U circumstances, yield different results, i 16 When there is one set of circumstances, one 17l computer code may give a more conservat.ive result than the 10 other and vice versa. But the general... opinion seems to be 1 that the technique which uses the square root of the sum of 7A thesquaresgivesamorecbnservativeresultintermsof l 21 design criteria than the algebraic summation. J .!j 22 Q So basically.what you are telling me is that i M the opinions which you have polled indicate that the square O 24, root of the sum of the squares is a preferable method? Uf A It is preferable today, and if ne knew about

. e ::,c: o ::mr3A' : rte - av :2. Lec trntt.v r.a'.-. - :'t.. :ct.mc. Pr.17: rn.

.,.,. r.. y, ,,g

.y y

Dunn-cross 180 ( s g it in 1945 maybe it would have been preferable then. It is D .i 3 a question of what was the state of the art when Beaver Valley 3 was initially designed, what were the computer codes which 4 sy were acceptable -- acceptable meaning that they were not 3 precluded. 6 Q Of course, my question did not raise that 7 issue. 8 A I volunteered that information, p Q That is right. Whose opinions did you poll 10 when you were determining the state of opinion with regard to 11 the state of the art? 12 A I didn' t poll anybody personally. It is based O 13 upon information I have read in letters, opinions I heard ~14 expressed by Stone & Webster, opinions expressed perhans.by 15: some of our own engineers, testimony I have read in other 16 proceedings where thin question was raised. 17 Q You are not tesbifying from your personal. 13 opinion but you are testifying to the opinions of others? I ,19 A I am testifying on the basis of what I have 20 read in terms of opinions of many other people which cecm t: i 21 all come to the same general conclusion, that the state of the gg art today and the methods which are now acceptable to the N:lC, b g]' in terms of seismic design, requires a computer.cedo which in O 3,.; s ubro't. tine -- l 23 .Q Stop right there, plea.;e. 1 ttor.txc:: o t?mrt:n. ve. - e r'. ?.rc. msev ty::,- t tmoruno, P1 :Ut tr. - ,,,,,,,,_v., g ,,,n,,, n. -

Dunn-cross - 189 k 1" A -- usoc the square root of the sum of the 2, squares method. 3 MR, LEVIN: May I have ray question read back, 1 4 please? 5 (The following was read by the reporter: 6 7 Question: You are not testifying 0 from your personal opinion but you 9 are testifying to the opinions of 10' others?) 11l 12 MR.TbOMAS: Read the answer, please. O 1 d4 (The following was read by the reporter:- 14 i i IS Answer: I am testifying on the basis-i l 10 of what I have read its terms of p. 1 ( opinions of many,other people which ) lIl seem to all come to the same general 19 conclusion, that the state of the 20 art today and the methods which are 21 now c.cceptable to the NRC, in terms i 27, of seismic design, requires a i 2I computer code which in subroutine O 2 24 uses the square root of the sum of 23l the squares method.) t I

e. ex:::Ae:: e mr:rx. n:c. - a n. s.ocr.v :.t.u r.v=. - mnumme e in :.t.

m..

y..y g.,_ 7 ;, _

,y g. ,_c,. s.. . g.. m...,

i Dunn-cross 190 1 i 3 MR. LEVIN: Your Honor, if the situation D 3 continues I will ask for a direction from the Bench. But it 3 appears to me that the witness is not focusing in on the - 4 questions. 5 MR. THOMAS: Q,uite the contrary, your Honor, 6 the witn3ss is. 7 THE AD1INISTRATIVE LAW J.UDGE: I see nothing ,8 wrong with his answer to your question. 9 MR. LEVIN: My question was simply -- 10 THE AU4INISTRATIVE LAW JUDGE: Go ahead, 11 simply what? 12 MR. LEVIN: Was simply: Are you relying on O U others' opinions and his answer was, yes, and their opinions 14 are. That last portion was not asked for in the question. 15 THE ADMINISTRATIVE LAW JULGE: I can understand ( -} 16 : why the witness would want to ansuer the question the way he 17 did. la MR. LEVIN: I can understand it, too. 19 MR. THOMAS: If your Honor pleases, this i 2{} witness has a.right, to inform himself, the has a duty to inform 21 himself, he has a right to form opinions. It is no different t l g; than education we had in law school. 23 THE AElINISTRATIVE LAW JUDGE: Conti nue. ) i O 24 MR. LEVIN: Thank you, your Honor, l 25l r 1.- .wwws e anzu: rw.- n u. s.a=ma.ww m - wwmx.c. n. :rna i +.. -,. _.... .,, y m e,, ,y. m., mg.g.,,gwmw,FD-m.'M7ayp5'Me*W:5']" J-1 ~;~

~ Dunn-cr os s,,,_ 191 I lil MR. L!NIN: ) 3 Q On page 6 when you state in the 6th line from 1 3 the bottom, currently acceptable techniques, you are referring i 4 to what currently acceptable techniques? 5 A To anawer your question specifically, the 6 techniques involved in.the application of computer codes such 7 as NUPIPE, or PSTRESS Shock III. Both those computer codes 0 use a subroutine which does not include the portion which n uses an algebraic summation technique. There are other { 10' acceptable codes, I am sure. 11 Q On page 10 you state -- and I will make a 12 direct quote: customers realize the cost benefit of large O 2, ^* units when these large units operate and should realize the II cost penn.lties (or regular business risks) of extended E cutages. l 16 Now, Mr. Dunn, if an extended outage is due 17 to a failure or misfensance or malfee.sence on the part of the 18 contractor, would your statement be the same? 19 MR. TH0!fuiS : If your Honor pleases, I believe XI hr. Popowsky cross examined on the same subject matter and 21 almost same question yesterday, w l j 32 MR. POIW SKY: I think you objected to the j M question at the time and I don't think that specific question O u. was answered. ~ 5 MR. THOMAS: All right, if you think not. rcms.ws a :wwut : :a. - e :a. :.v=vm..w r.r. - w.mv=-m. r.z swa .l 3._., .y.... ~ m;,,,,,,, ,e m y g 7 q,.p. y, y.

= Dunn-crons 192 I s 1 THE ADMINISTRATIVE IAW JUDGE: Answer the 2-question. 3 THE WITNESS: I believe-if it can be 4 established that'a contractor maile some. gross error for which O be is legally liable, then the company has a right to pursue b ~ a 1egal course of action against that contractor to make an 7-honest effort to recover such costs, and to the extent that G th'r' is a cost recovery, then the company through its O t accSJn.ing procedures can give the customers due credit for M whatever moneys are recovered. 11 But until such time as that decision is 17 reached in a court of last resort, shall we say, I think the O is penalty, so to speak, for that particular expense, for that 1 14 i particular point in time, has to b6 borne by the customers. I I They receive the benefits when the unit Nllo pe re.tes. They take the risks of it being down. 17 BT MR. LEVIN: 10-Q That is your opinion, your personal opinion? Ih A That is what you ached for. 2'O f Q Is that personal opinion based upon your. 2-expertise as a chemist? 21 A Hardly. j MR. THOMAS: It is unfair. I move the D 2'bl question be stricken. l1 i r 2N THE ADMINISTRATIVE CAW JUDGE: I didn't hea.r r ~=,te: a news :rc.-a m. i.ee::7.ew m.-:=n=rr, u min .,.,,,..e .., g - -

uc. _2.2 w.: 0-Dunn-cross 193 T 1 the lasb'few words, based upon what? 3 i. 3 MR. LEVIN: His expertise as a chemist. 3 MR. THOMAS: Your Honor'-- .!] 4 MR. LEVIN: Your Honor, otherwise if he is 5 giving opinion evidence I would like to know the basis for 6 the opinion evidence. He is qualified as a chemist,.and I 7 . don't know -- although this is an administrative hearing -- ] , 6 whether we want to have random opinions floating around in ? J 9 testimony. 10' I would think that those would be more j 11 appropriately the subject of argu:nent. 12 THE AI14INISRATIVE LAW JUDGE: You have not p i 13 hesitatad in phrasing your questions to ask for opinions 14 which certainly go far beyond thait of a chemist. 1 13 Th6 WITNESS: My qualifications, as I outlined i 16 in my direct statement, are beyond that of a chenist. 17 THE AD4INISTRATIVE LAW JUDGE: Are considerablyi 18 beyond those of a chemist. 19 THE WITNESS: Yes. 20 BY MR. LEVIN: t 1 21 Q On page -11, the 7th line down, you use the { ',1 22 words, absolute guarantor. Where did you find the nords 23 absolute guarantor? l f i 24 A .I believe those words can also be found 3.n one 1 i 23 of our reply briefs. Now whether I was the author cf the' t ^ L - taon :o w< a nArncnw, enc. - = u. s.oma m.t.cn m - rnm=una, n. :~:w. - .m .. g,4

r. f, g

, s. .,..y y.,,,,.q. .; gg.- q

1 Dunn-cross 194 4 7, words or whether' ccunsel was the author of the words in preparing the brief, I am not sure at this point in time. 1 3 My recollection is -- and the record will 4 speak for itself -- that those words can also be found in 5 one of our reply briefs. 6 Q That is my recollection, too. Can you give me 7 a definition of the words, absolute guarantor,.as you have 8 used them there? 9 A Essentially it-means Duquecne Light guarantees 10 anything and everything under all conditions and 11 circumstances. 12 Q On page 12, question A-13, the 2nd line, you f*% 13 state: the question is now moot as far as the outage which j 14 started in March 1979 since the unit was returned to 15 operation (synchronized). What do you mean when you say, t 16 returned to operation (synchronized)? i 17 A It is a unique point in time when the unit is 18; delivering energy to the customers. Synchronized means it.is 1 19, electr'ically connectod to the company's transmission system. i 20 Q Would that be true even if the unit was 1j 21 providing only 10 percent of its rated capacity? 22 l A It is providing' electricity to the customets 2 1q 13 .regardless of whether it is 10 percent ~or 101 percent. /*\\ i 24 .Q I In fact ' the unit was not providing-101 varcent f 23 of its capacity after. August 17,.1979, is that r~1ght? I - ec:=m a rumm me. - =7 n. r.ocr.ri:u.er.. n. -:mnrrre.w n. m m --- J w- ~ my g ,.,.x, ,,.y,7,y..

Dunn-crosa 195 \\ 1 i i 1, A I would have to go back and review what the J A daily outputs were. I don't think it hit 101 percent. How 3 close it came to its rated capacity of 800 I am not sure. 4 Q What documents would you be reviewing? 5 A Daily reports which show what the peak load 0 was on each day of the year. 7 Q Do you have such daily reports? 1 0 A Absolutely. 9 Q May I ask what kind of reports you keep wit.h 10 regard to the various repairs and modifications being made to i .1 1 Beaver Valley Unit i now? 12 A For every design change which is being raade O 13 there is what is called a design change pachage, and I hwe 14 used that terminology in my diredt statement. A DCP is a 15 design change package. 10 With regard to maintenance work there would 17l be an equipment history card somewhere in the station which 18 would reflect the work done. There may be other documente 19 which I am not familiar with. 00; Q And for modifications? r -i /1 A We have talked about.two things. We talitec j 22 about modifications. All mcdtficati.ons are handled as derign Dl change packages, to the extent it constitutes a des 4.gn che age O 74 as defined in our technical specifications, our license, nI Maintentace work is work which doec not involve l i MS!W'.*.Ctf S ?.f A*tf7! f... ??m. *. " 7 IL L 0;"CVT Lt.Di** ?.T!*, - !!A*M:;7t";Jf 0. F'.i.1*f i10 = 4 x .m ,-..m .-..,.,m

.1_. Dunn-cross 195 . IT l 1 i a design change, it is strictly mainhenance. and they s.re O 2 handled under two separate procedures from the standpoint of 3 how the work is. accomplished. 4 Q What kind of material do you have in the 5 design chan6e package for the low pressur.e turbine spindle 6 problem? 7 A We have a whole new turbine, two spindles. 6 Those are the prime pieces of material and they are 9, physically on the site. I 10 Q You have received them? 11 A Yes. 12 Q Are you familiar generally with the O 1 13 construction and operation and design of turbine spindles? 14 A I have general ' knowledge of operatf.on. I am 15 not thoroughly familiar with design nor construction. 1d Q Have you ever secu a low pressure turbine 17 spindle? 18, A Absolutely. 19 Q You have? j 20 A Oh yes, many times. 21 Q Did you personally inspect the low presourc l A 22 ' turbino spindles the.t were removed? A3 A' Fersonally,'no.. People >cnder my supervision j 1 p. 4 i 24L and direction did. Tne actual inspection was cerformed by a-1 i i J 25' Westinghouse team who had 'been specie.11y tratnad to inahe the - ercirr:nt cn e maw:A* SMc. - c/ !!. Locrwn!.t.ovt /.*.":'. ~ :rAn r:rmi:n :'A t7: M -- f ~},..

Dunn-cross '197 T~ ~ 1 p type of inspection referred to, that is, the inspection to 2 determine whether or not there are cracks on these disks'. 3 .This Westinghouse team is not only at Beaver 4 Valley but it is also at Indian Point and any other spindle a O which may be in trouble. 0 Q. Have you -- 6 7 A I personally did not oversee the inspection but O people in my organization did. N Q Have you seen the cracked turbLne spindles? 10 A No, I have not. .I have.seen sketches indicat-f Il ing where the cracks are and their location. 12 MR. LEVIN: Your Honor, could I have a-moment? l D 13 BYMR.LNVIN: 1.} Q Mr. Dunn, I'm goin,g to hand you a blue marl;er. 15 I will ask you to ti.? best of your ability.to draw a low .i - 16 pressura turbine spindle 1er illuscrative purposes. ) 17 MR. TH0tMS: Can you draw it? 13 THE WI7WESS: Within my capability. I 1E MR. THOMAS: We have not contended that this 20l witness is cualified - as an artist. 21! THE WITNESS:- Within my capabilitics, that' is I i 72 a low pressure spindle -- shaft,. blades.. The steaa.- t 4 comes in here, flows in both directions 'out here. 8-d,, i 1 [ BY MR. LEVIH: 3-t i

- 3 ll Q

Could you label the clace wh*2re the steam: i --. nemes e unn:rt, rue. - w n. i.eer :.t.on n - nin=en, :n. sm a - ...a..... ,.y,...,. y,,. py y

..m. Dutln-c ro s8 '190 1 comes in the inlet? 2 A (Witness marked drawing.) 3 Q , Of course, where steam goes out are the ~ 4 outleta, is that right? i 5 A That is ri ht. G 6 Q Could you label those, too? 7 A (witness marked drawing. ) 8 Q Could you just draw a line indicating the 9 spindle and label that as well? 10 A The whola thing is a spindle. 11 'Q Is the long central ' portion 'you have drawn a 12 shaft? I O j 73 A That is called the shaft. L l., 14 Q. ifould you label that, please? l 15 A-(Witness marked drawing.) } ( 16 Q These vertical lines on either side, are those-17 the rotors? 10 A No, they are blades, blada rings, blade rors.- 19 Q Could you label those appropriateiy? 20' A All of them? 1 21 .Q-Not 'all of than but just

5. imply indicate that i

b 22 those are blade rings. ] .. M A (Witness marked drawing.) O l' 24, ,Q; New what you have given us is ' a. liori::ont.tl 23' cress section of a turbine spindle, in tha't right?- ^~ . nowne s w.nw: mc. - o n. te cwn.tav i.v=. ~ w nwentma n m s n.-- - l ". ~ i _. j ' ;;;:?EI[b l'1/ ', d I E M 5 7 3 k."E* *' Mi$ d N @?fiW .a,

a,- Dunn-cross 3 qq - .1 A Yes. a 'D 2 Q Cou?.d you also draw us a cross section of it 3 looking toward one end of the shaft? 4 A (Witness marked drawing.) 5 Q Now on that section could you label the key- 'c way area and give an approximate indication what it looks ') I 7{11kei 3 A What you have is a shaft. Because of the size 9 of these rotors and because of their rotating speed, because 10 of the mass involved, it is not possible to forge and li manufacture a low pressure spindle of this size in one piece 12 of metal, so what they do is to essentially forge the shaft 1, O 13 and then they shrink onto the shaft what they call disks. N What you do is act'ually heat the dishs on, i .S push it onto the shaft, cool it, and when it cools i t I l M contracts, when it contracts it binds itself, so to speak, to j 17 the shaft itself. 18 In addition to binding, there are also keyways 19 in thera which help key this disk to the shaft itself. 70 Q Is that kind of like a. projection from the [ 21-disk into the shari, to affix it to the shaft? If you like i 22 you could draw the detail you are looking for in a different- '23 area. l O ' M A You have a disk which is shrunk onto a shalt j 25 and as I recall it' there are keyways, ' there is an area right.. - r emuce wAnerx me. - r.r ::. s.ec.r.- e.m m - sm:mmn s a m - - l

- er

,.y r w p=--a i.esswww r 4 ree .p* w y -lw.=, yara= sepy.,4 gwy p ,,y-gs e-e 7gg,,

Dunn-erosg,___ 200 I 1 in here comething like this -- this is very general -- which ?, a pin goes through that helps position this disk in relation 3 to the chaft itself. i 4 Q Could you label that as the keyway? ] 5 A (witness marked drawing.) 6 Q Is it at the keyway that these cracks in the i 7 low pressure turbinas are occurring? 8 A On some, yes, on some, no. 9 Q The actual cracks we are referring to are 10 cracks in the shrunk-on -- what do you call them? 11 A It is.a disk. I 12 Q The shrunk-on disk, are those where the cracks i O i 13 are occ 2rring? 14 A As far as I know, tall the cracks are on che 15 disk either in the keyway or 1'n some other part of the disk 16 itself. 17 "Q It is these disks which are not labeled, I 18 believe -- could you label those -- that actually hold the f 19 blades? 20 A Yes. 71 Q So therefore, if there is a failure in a disk 22 there would also be a failure in the blade and there would be 23{ an accident, is that right? r 24l A Yes. 21. q - What kind of accident would that be?

10tiMacM o r.!.*.fi$ !AL. Urc. = E7 N. LOCXY!!L' CV1 dV:0 - !!AT'ftttpurto, f*A.17f in ~~-.-

.f - 2 n. .., > wp,m,77pvg, .e gy., j y :.. ., gwy,e gy .7 ;w n n. n

Dunn-cross 201 r-h 1 A We have had experience. The Shippingport 2: spindic failed this way and you essentially destroy the 3 spindle. There 'was another reactor which had a similar 4 incident within the last month or so with a turbine failure 5 and the turbine was essentially destroyed.from the standpoint 6 of its repairability or future use. 7 q liow long would it ordinarily take to reolace a .O turbine unit that had been destroyed in that ki nd of an event? 9 A It depends on whether or not there are 10 j any available from some other utility as a spare or there is 11 one available because a given unit is delayed and therefore ..a I 12 can be made available,such as in our case. j O U-If you had to go bach and get one from the 14 beginning, pi obably 18 months. to 'two yeara, assuming you can 15 get the material. .i 10 Q Would that be a dangerous event if one of those i. i 17 cracks caused a fai. lure? 1.0 A Dangerous to whom? 19 Q To anyone standing nearby. 20 A Based upon the two incidents which have 21 happened to date, the answer would be no. No one was hurt 22l when Shippingport failed. There were no missiles which Bot l 23 outside the containment of the turbine itself either at ~ 24 Shippine, port or the one.that failed up here in New Engle.nd

25. uithin i.he last month.

I - . r.sennrcn a w.ncur. n:c. - a n. s.cegw:u.cw r.v. - ca.w:suna, m. m n -- 1 _s, . _,. ~.,, _ .m_ _..,,.,,,.. , 4,y,.

Dunn-cross 209 1 3 Q That is an area of concern to the NRC, isn't 2 it? 4 3 A Yes, it is. It vas an area of concern and an <f area which was considered when these plants were designed, 5 turbine missile protection. 0 Q Do you -- when I s,ay you I am actually 7 referring to the manufacturer which was Westinghouse in this 8 instance -- does Westinghouse shrink on one of.these di sks for every rotor? 10 A For every row of blades. There is one disk for Al' every row of blades. In the case of Beaver Vsliey there are p~ ten disks per spindle and two spindles so we are talking about ['\\ 13 20 disks. 14 Q When you say a row of blades, what do you mean "5 1 by a row of blades? 16 A There are any number of rows of blades on both 17; ! sides oc this turbine. In the case of Beaver Vs11ey there 10 are five rows of blades, therefore five disks here and five 10' disks on this end so there are ten disks, on a spindle and - since we have two spindles, there are 20 disks total at 21 Beaver Valley. 27'[ Q Are there other manuft.cturers that annufacture "'3 ' 9 low pressure turbine spindles? (%

'b A

Yes. Q Does General Electric manufacture such turbine i- . :.se>: n:, es : :.unmt.. inc. - :7 n. t.occm.:.w.wr. - tunr:tr.nuna, n. m in y.-, -e

Dunn-creas 2,03 _ 1 spindles ? 2 A Yes. 3 Q Do they use a different methed of manufacture 'I than Westinghouse? 5 A I don't know if they use a'different one.. I 0 do know they use this technique. 7 Q Do they shrink on their disk's in a different manner than Westinghouse?. 9 A I am not familiar with the oroduction 10 procedures of GE versus Westinghouse. AI-Q Is there an individual in your department who 12 is familiar with the differences? O 13 A I doubt it. 14 Q Could you simply sign that I suppose, since 3 it is your production? Take credit for it. 10 MR. LEVIN: We will have this marked as i.tn U' exhibit, your Honor. IO MR. THOMAS: You can have it marked. That is 19 as far as you are going. I.think it is ridiculous.and 1 20 object to it. It is used for the purpose of describing the i t ~11 9 - spindle. The witness has done an excellent job.. He is not 22 a constructor of spindles. ?'.3 ~ THE ADMINISTRATIVE LAW JUDGE: The object. ion is l' O 24 l.overruled. l - 25 f THE UITNESS: Do I heva to sign this? I l L e:nu-u o r.unr::r.v me. .w n. i.oc:wst.c >< r.ve. - wr.re,na, n. m se r~y~~- - ' m - : ~,~~ q yp r7=~ m y.q q 7:3 3- ~ r-' q qpv ~rv gas-:,;;._: p.yy;jpy sy y w -

Dunn-cross 204 y MR. THOMAS: No, he did not rule that you have 2 to sign it. I assume he is ruling it can be made an exhibit. 4 3 MR. LEVIN: Your Honor, the drawing which 4 Mr. Dunn just completed for us and has not signed, we would 5 like to have it produced and marked as an exhibit as Trial 6 Staff E::hibit 1. 7 MR THOMAS: There is no objection to marking. 8 Objection to introduction. P THE AD4INISTRATIVE LAW JUDGE: It may be so 1 10 , marked. i 11 12 (Commission Trial Staff Exhibit p No. 1, drawing, was produced and ,,,u marked for identification.) 3 14 ?.5 MR. LEVIN: Your Honor, we move its j 16 introduction into evidence, i 17 MR. THOMAS: I think it is premature to move 18 its introduc tion. We have not moved introduction of our 19 l exhibits. 20 MR. LEVIN: May we have a ruling, your Honor?- 21 THE ADMINISTRATIVE LAU JUDGE:. It may be 22 admitted. j 23{ MR. TIIOMAS : Then, your Honor, I offer intc I 24 evidence all of'our exhibits. I should be accorded the sa:ne

25. courtes;r as the Coraission Staff.

If they can offer their = ;!OM 275AOf11 ??f.?:"HAL. IMC. ~ fC' PL LCCXWILLe*? AW. - t-tAnntecUnc, PA.171 ta. ..,n..- .n. 7 3, ---ry m. ,;n n - wr. ~~ r

a+ a.. ,n,~..- Dunn-cross 205 exhibits in evidence, then I am entitled to offer mine. g 2 THE ADMINISTRATIVE LAU JUDGE: Any objection? 3 MR. LEVIN: No objection. 3 MR. FEIN: May I have a moment to look through 3 them? b 6 Your Honor, with respect to objection to 7 particular documents, the only document I would have an ,8 objection to would be Exhibit G which was submitted'in P responsa to the Commission's order of November 29, 1979 and 10 three o aarters of it is a legal brief citing ceveral cases, 11 and obviously was written by Mr. Thomas or somebody in his i 12, firm and not by Mr. Dunn, and therefore I would object to O 13 Exhibit G but no other exhibits. 14 MR. THOMAS: If your Honor pleases, that 15 responso is prepared at the direction of the Commission and i 16' filed in this proceeding pursuant to a Commission order and 17 ue respactfully submit that we are entitled to have in this 13 record 5he response which we made. 19 I will agree that it has mixed enginerring, 20 legal and everything else in it. But it'is signed by l 21 Mr. Dunn and it is submitted in response to a direct order of 7 } 27. the Commission. We are entitled to have it'in the record. i 23 THE AUiINISTRATIVE LAW JUDGE: The objection 2 d, is overruled. The e::hibits e.re admitted. ZS MR. POPOKSKY: Perhaps I should move my one neiaceca 3 :.an:=2: me-u 1. weum:.eme ~ mmcune. re. m tc - l _..._y. ,y-,,_, n. .,.y., ;, ,.m y.m. . 5 7..

Dunn-cross 206 1 exhibit in evidence at this time before forgetting te do it D 2 at the end of the case. I move for the admission of Office 3 of Consumer Advocate Exhibit No. 1. 4 MR. THOMAS: We have no objection. 3 THE ADMINISTRATIVE LAW JUI'GE: Admitted. 6 MR. POPOWSKY: Thank you, your Honor. 7 Mr. Levin? .O BY MR. LEVIN: 9 Q Mr. Dunn, with regard to the fabrication and 10 design of turbiile spindles, who is your resident in-house 11 expert? 12 A To the design of them? 13 Q. Yes, sir. 14 A I don't know if we have anybody who is 15 actually a design specialist, who gets into the design of 16 turbines, because we do not design turbines. We have people 17 who are knowledgeable of turbine design, who are knowledgeable j i 18' of turbine operations and turbine maintenance. 19 But design of a turbine is a very complex, } 20 highly technical field, starting with the material of 21. construction to the forces which are applied to the turbine 12 blade, the length of the turbine blades, the speed, all these !j 23 factors. D t 2s Q However, when you are selecting between 23l turbinca made by different manufacturars, how do you select YOC AC11 Q P? '.itM1At., iffC. a7 IL t.CCXWILt CVt ??/::. - !M3ctrTJnc. Pt., *711,a. --. e.

?'"*~*'*S* I them? i f i i ,2 A On the basis of competitive bids which may or 3 may not be influenced by previous performance of the vendor. 4 Q Did you have or did anyone in your organization 5 that is Duquesna, have previous experience with Westinghouse I 6 low pressure turbine spindles before you purchased the two at 7 Beaver Valley 17 ,8 A Yes. 9 Q Were they of the'same design and rating as il those two spindles? .l.1 A No. 12 Q Were they larger spindles or smaller spindles? D i.3 A Speaking for Duquesne Light Company's system 14; only, they were smaller spindles b,ecause this is a snindle i 15 designed for a nuclear power reactor which has far differcut 'l 16 steam conditions in terms of temperature and pressure and 17 flow than you would find in a modern coal-fired station where 10 ! the steam flows are different, the steam precsure is 19 different, the steam temperature is different. 1 20' For instance, nuclear machines have an i 21 1800 RYM speed where as you will find moat coal fired 22 statione are 3600 RPM machines. i j 23 l Q Would the pressure be higher or lower? O 24 A The pressure, temperature vould be much Mgher, I 25 h Q Why do low pressure turbine spindles for I d n-- . -. *,;r 1;r-Ac;? O F.MT:: IIA

INC.== 0*/ **. ?.CC'**f*it'.7." ?.V**. -. ?'A'tr;t.?Tjuita, !'fs. 2T114

.m..--_

Dunn-cross 208 p '1 nuclear plants rotate at a slower speed than for coal plants? 2 A Because of the physical limitations of the 3 materials involved, the steam you must flow through these 4 turbines in order to get the energy out, the fact that you 5 are decling essentially with saturated steam with very little 6 degree of additional heat, superheat, as opposed to a coal-7 fired station where you are essentially operating with steem 8 at very high temperatures and pressures, therefore a high 9 degree of superheat and therefore more energy per pound of 10 steam flow from a coal-fired station as opposed to the energy 11 per pounds of steam flow for a nuclear facility. 12 Q Are you saying,then,that the construction cf D 13 turbine spindles for nuclear power plants presented a 14 difficult series of engineering p'roblems or a new serie:5 of 15 engineering. problems for the constructors of those spindles? 10 'A No. 17 Q What are you saying? 10 A I au saying the design and construction of 3 spindles for a nuclear plant is different from what you would 20 find in a normal coal-fired station, particularly a mpdern I I 21 stationof.300,600,600 megawatts. i 2% Turbines of this particular design, that 1.3, 4j M 1800 E4, essent'ially little in terms'of supe.rheat from the I O 3'I. team, were a state of the art-back in the 1920's 1930's..It s .5 was a state of the srt which ws.s abandoned and when you - no:e:.wi o u.ar:x. s.. me. - a re. :.x:n un r.n: - nmrrunc, n. m n: -- ,w,,w~ , u; r,,., -. n +., y, ,,,g,, p,z yp.. ., y.. -

Dunn-cross 209 1 I ctarted to go to higher temperatures and pressures of steam, h D 2 they had higher capacities in terms of the size of the units 3 involved. 4 Q Are there new metals or new methods of 5 fabrication employed in the low pressure. turbine spindles for 6 Beaver Valley 17 7 A I am not familiar with the methods of 8 manufacture and fabrication of spindles. 9 Q Let 's assume that Duquesne Light Company is 10 to choose between two manufacturers for these turbine 11 spindles and the cost of one is slightly higher than the 12 other. What further evidence would Duquesne Light Company O U need to obtain before it could make a decision to ourchaso l'I one or the 'other company's turbine spindles? 15 A Obtain from whom? 16 Q From the manufacturer or frou its' own resic ent 17 in-house engineers or from anyone else in the entire worici? 18 A The question was based on the oremise that 19 you are going to buy a turbins spindle, number one. Two, you 70 have two simple prospective suopliers. Three, everything is 21 different other than a small differential in price and we 1 7.2 uon't spend too much time on how small is small, but there is 23 a differential in price. An'd really your question, as I O 24' interpret it was, given that type of information, what 23; decision'would the company make? I. - nowmr.x e runsw.t mc.-::n:. r ouven.s.ow mx,- u.1.ienusa. m m m - t yr..,... _ 7.

Dunn-crosc 210 I 1 Q No, my quection is whnt otner factors bec! des 2 price would the company want to consider? 3 A The reliability of the equipment, past history 4 of the equipment particularly from that vendor is number one. 5 Number two, whether or not the equipment can be supplied in 6 the time schedule ne have established and normally that 7 condition is met. 8 These would be the tuo that come to my mind 9 quickly. 10' Q Do you know if Duquesne uould make any attempt i 11 to independently evaluate the design or construction proposed 12 to be used by the msnufacturer? O I 13 A No, we would not do that as a normal i 14 procedure on a turbine. You are ' essentially dealing with 15 suppliers in this country who have been in the business fc r I 30 many, many years. We do have personal relationships in te rms 17 of knowing the people, having dealt with them on nrobleias in 18 the cast, both GE as well as Westinghouse. 19 We have some degree of confidence in the 70 product based upon past experience, and since there was no 21-previous poor experience record with these turbines at thc I j 22 point we made the decision to buy, at least to the best of my 23. knowledge, there we.s no reason why we did not go with j O s'm Uectinghouse. 75; Q tihat assurances do you attempt to obtain f cm A

t. mnn=n a r.unr:~.n me. - = u. u mew.v.vz - wam=:c: n m w. -- ---- -

.__7

Dunn-cross 211 I i 1 the manufacturer in the form of warranties or guarantees or O 2 specifications with regard to the service life of these 3 turbines? 4 A Normal warranty is a time -- and I can't be i 5 specific as to this particular warranty -- but normally the 6 warranties read such as the unit is warranted against certain 7 conditions for 30 months from the time of delivery or 24 8 months from the time of initial operation, something like 9 this. Usually it is from the time of delivery, 10 But the warranties vary from manufacturer to 11 manufacturer -- somewhat similar to your car warranty which 12 expires in one y. ear or 12,000 miles, whichever comes first. 13 Q What was the expected service life of thLs i 14 type of turbine for Beaver Valley? 15 A I would say 35 years based upon the expected 16 service life of the plant. Now it would not be unusual tc 17 find it may be necessary to replace that turbine in abo'It 20, 18 25 years after normal attrition. This is based uuon 19 experience we have with other units. 20 They, too, develop cracks and you have to go in 21' and uha't we call bottle bore. In other words, that shax't on 22 some of your larger spindles is actually hollow, in crder to 23j keep the mass down, and you sometimes get cracks in there. /*N 24.To the extent you have enough material lef t you can go in and 22 bore, take a small layer of metal evay, increase the diameter I!-- ---- nonw cu a ww n.. ere. -. :e n. s.ec::vm.:.ew r., r. - w neenunc:. ac. m 2: -- _..., 7 _ _.m.._,.._

Dunn-cross 212 I 1 of the bore, so to speak, larger in order to remove the j ('\\ 2 cracks. j 3 3 But it is possible, and we have units like 4 that today where these cracks can no longer be removed by 5 that procedure and we have ordered from Westinghouse a l 6 replacement spindle. 7 Q Do you make any provision with regard to the O cost of replacement power in the event of untimely failure of 9 turbine spindles? i 10 A What do you mean do we make any provisions for l 11 replacement power? 12 Q Did you agree with the manufacturer that some j fm\\ l 13 of the costs of replacenent power would be picked up by the j 14 manufacturer in the event of unthmely failure? 15 A No supplier would give you that type of i { 16 insurance, that type of warranty. 17 Q But the consequences of a turbine failure for 18 Beaver Valley 1, or indeed any plant, uould be quite serious 19 for Duquesne, is that right? j 20 A It depends on the magnitude of the failure. l 21 Q In the ecse of the turbine spindles we are 6 22 discussing now, the failure was great enough to require l '3 ' replacement, is that ri6 t? i. h I'\\ 24 A Replacement was the most economical way ';o 25 effect a change and return the unit to service in bne shortest L . mesmacu n n.new inc. - ev it. tocrewr.t.civ e.v i. -imn:2i once, nn.17 1.. l l .m ._r _, _.. _c.

Dunn-cross -= 213 f 1 period of time. 'Ihere are other alternates available to us 3 and some of'these alternates have been taken by other l 3 companies. } 4 For instance, one of the things you can do is 3 to remove the row of blades with a cracked dish and put a 6 baffle plate in there in order to give you the pressure drop 7 across it and run the unit for some period of time at reduced t '3' capacity while the replacement forging dick is manufacturered 9l and machined and made available for some subsequent outage 10 , where you can then put the disk back on, by sending it to E 11 someplace 'like Charlotte, North Carolina, where they have 12 facilities. to do this. l O 13 Q That gives you a drop in rating? U A Yes, but some util'ities have taken that ontion i 13 because you cannot get a replacement in a short' oeriod.)f 16 time. We were fortunate. I A7 Q The: efore, it is extremely important that the a 18 low pressure turbine spindles live up to their specifications a A9 j and design life, isn't that right? 4 ] 20 A Well, you said design life. I.did not, imp 3y -- 3 21 if I did, 'I will correct it -- that there. is any design life. a 2,7, The thrust of-your earlier question was what is the expect ed q 23 ^ ' life, end there is. a difference between the concept of c. 1 24; ~ design. life and expected life. i 25' j q What is the difference in your mind? -. wmucu e t.xsn.v ma. :., n.1.cean.us:.vi.:. -. :.p...metma, n. tv t: -- +- I i ...,..m ,. g y .7 7

Dunn-cross 214 i 1 'A. I don't know of any design life. The expected 2 life time is basically what the utility would expect in terms 3 of performance out of that unit. In other words, as I 4 indicated before, it may be a reasonabic assumption that the 5 plant is going to operate for 35 years. .In the case of 6 Beaver Valley that is about the length of 'its'operatin6 7 license. During the courue of that 35 years it 'may be 8 necessary to replace one of these spindles at least one time, 9 maybe twice. 10 Q In addition to considering the' operating 11 history of similar turbirie spindles made by the same 32 manufacturer, the cost of the units, and the personal D 13 1 relationship you have had with the manufacturer, would you N not consider it desirable as an eingineer to also consider 15 differences in engineering features between the two spindles l 16 made by two different manufacturers? 17 A I don' t think there is any significant ~ 18 difference between the design in terms of the way the disks 19 are forged, the way the disks are shrunk on the shaft. 4 20 Westinghouse did make some design changes in 21: that technique. It used to be that keyway was a square 22 keyway. A equare keyway design gives you a sharp corne:. t hich j 23fthenbecomesafocalpointfoFthedevelopment.ofcracha, f 8 i 24 stress risers they are called, so they changed the design et 25 semo point in time from a square. type key to a round ty,e key isam::,cu a wnwn wa. - a n.1.ccuvm.:.orr me. - us.nmexr a. n. ssm ---=--.y.,,q.u, ,,4 . _g.;,.g ,- z y,.

- W'**
+94e'
- ause

&Aa Dunn-cross 215 1 in order to preclude the problem. Lo and behold, cracks 2 still developed in the rounded key. 3 1 don't think based upon my knowledge, that' 4 there is any significant difference in terms of the basic 3 concepts involved of building a turbine where you shrink on 6 disks and the disks in turn support blades. I 4 7 BY MR. THOMAS: .O Q Is that between manufacturers? 9 A Between manufacturers. 10 BY MR. LEVIN: 11 Q Are you aware that it is mainly Westinghouse i 12 turbine spindles that are suffering these types of cracks? ~ O 13 A Yes, I am, 1 i I J J 14 Q Are you aware that there is a peculiari ty of 13 Westinghouse design which is responsible for the fact that f 10 these spindics 'are developing these types of cracks? 17 A I am not aware of it and if you have that 18 type of information I am sure there are people in the 1 19 industry who would like to know what it is. i 20 MR. THOMAS:.Yes, I would li ke to have it. ibis .{ 2 21 ofterncon. a 22 THE WITNESS: Westi nghouce attributes the !~ 23 cracks to stress corrosion. I don't think that oninion it !N O 2'r, necessarily f ully necepted by the-industry nor by NDC, but I lg lg'3 can't speak'for the NRC. I know I don't accent it, i 73Qll.T Arfst fe M? Wr"AL, IPOC. - 27 N. 9,ocWnLLc /* Nr; -- E;.: tater tr.te;, r,%

7f 12 -

l 0

4_ Dunn-cro.u 916 ~ ,f 1 personclly. They mcy be right, i 2 BY MR. LEVIN: 1 3 Q Stress corrosion covers a wide range of 4 possibilities, doesn't it? 5 A well, stress corrosion cracking is a unique 6 phenomenon which has been found in other applications. Stress 7 corrosion of nuclear boiler tubes is a well known fact. O Chloride stress in this particular case in terms of boiler 9 tubes. In this particular case they are saying it is 10 caustic stress corresion. 11 Q You were with Duquesne Light Company at th( 12 time the decision to build and in the process of building O 13 Beaver Valley Unit 1, weren't you? 14 A I have been with Duquesne for a little over 15 30 years and yes, I was at Duquesac when that decision na: l 16 made. 17 Q Were you an active participant in that process? 18 A No. 19 Q Was John Arthur an active particicant in that 20 process? 1 21l A I don't know to what degree Mr. Arthur may { 22j have participated. I.am sure he would have carticipated st 23l least to the point of signing ' the. piece tf pacer which 1 r 24 authorized the purchase. Now over and beyond that I have no 1 i 23 i , knowledt;e. 1-ve nt::.en t: u..nn:1.t me. - = n. tcesc:w.ev. xx - n:mewmo; n. :s s s -- - ...-....g 7 3. _ 3 L, ,.w. ,,..,.4. .g . 7., ..g,,.,.. g.

Dunn-croso 217 1 1 Q Who did Mr. Arthur rely upon for engineering

f j

2 judgments with regard to the purchase and construction of ] 3 Beaver Valley 17 4 A He would rely primarily through Mr. Schaffer, t 3 who is the President, on the people in our Engineering 6 Department, and also rely on input to whatever extent 7 required from the operating people, '3 Q Who did he rely on principally? 9 A I don't know what he did, f 10 Q I guess it is safe to say that you were not I 11 that person? 12 A That is safe to say, yes.

i O

j 13 MR. LEVIN: Well, your Honor, thank you. I 14 think that concludes our cross examination at this time. t 15 THE ADMINISTRATIVE LAW JUDGE: Mr. Popowsky? i 10 BY f.iR. POP 0HSKY: d 1 n 17 h Q Could you distinguish for us the phrases, i 18 s bate of the art and industry practice? 19 A .For what? 20 Q Well, I don't think it is necessary but I will' l El give as an example methods of determining seismic stress. 1 I 2.2 A Would you repeat the' question? 23 Q I wanted you to distinguish between the D i \\ ,j I4j concent, state of the art, and the concent, industrial 1 "#'5 . practice, ' if you. find there is a distinction between those-t ! l' l - -.- normoen a nxiew. tr:c. -:n ::. 2.oei:v.r_s.ow ver - w.v.nununo, n. : rue -- -- J - !I i: l l . - + m 3,w.n. u.n. - -7. v i -, -~r.:- -j,-- ~r.. ,,n s,..w.g:gy 7. m 7.

j s Dunn-crouc,_ E18 i !l 1 two concepts. 2 A In my own opinion they-could be very, very 1 3 similar but not identical. i 4 Q They could be similar. Are they necessarily j 5 similar? 6 A I don't know. I think the answer would be 7 different for almost any person y'ou asked. It is an opinion O tyr>e question. l 9 Q Is it possible that the state of the art 10 in a given area might be different from the industrial 11 practice in a given area? 12 A There may be a lag between the state of the D 13 l , art and industry practice, a time lag. I 14 Q What way would that lag run? l 15 A The state of the art may be leading the 16 practices. 17 Q So that, for example, when you say that the:re 18 were numerous nuclear plants that were designed using an 19 algebraic summation method in a given period of time, whi.'.e I 20 you may argue that that is the industric.1 practice, that nay ] 21 not be the state of.the art, is that correct? 'l 22 A That is true-because as one of these exhibits ~ 2.3 shcus, Stone & 'clebster was ' using techniques. involving the f 24. square root of the sum of the squares even in 1972, 1973 L 25 '. But the state of the art, at least in terma.of L = f90'iPDAC110 2 *.nMi/1 ??!!". = 27 II. LCCm/lktO%* NN -!-fAr"t:c*t.fftc. FA. 27122 ' 7 nrKR?? .p ."~T*~~'"N ~"''**Y'":' "T"'"'r*f';y"~*****MV K*r n}T7 6i;) ' fyk ~ WV}:~ s

4 W --er rtus.' wgmi p c-d+-

m-m Lunn-cross 219 9l-practice, and the standards which were used for the design of

(% .j 2 Beaver Valley, was the technique involving the algebraic 3 summation. 4 So again I guess this reflects the typical + 3j 5 example where the industry practice may be laggin6 the state 6 of the art because the state of the art is something which is 7 always in a state of dynamic change. 8 Q Is it correct that you do not know what the 9 i state of the art was at the time the Beaver Valley design was ] 10 made? f,1 A Only in a very, very general context, based i 12 upon information which I have read, and basically the ouinion O 13 I form, based upon what I have read, the state of the art was i I 14 a rather dynamic type motion, thipgs were changing, new 15 techniques were being developed. 16 We had greater computer capability to solve l 17 these problems, so to speak, at least to simulate the 18 problems. So as your computer techniques in terms of i 19 hardware expanded, then your computer. techniques in terms of i 20 the software, that is the orograms, could follow along. ] 'l '} 21 Q Then you don't know that in 1974, which is the i i i 22l 'date on which certain analyses were done using the Shock II 1 23' method,. according to your Exhibit C, you ' don't Know.whether j O that we.s the state'cf the art at the time? 24, 4-s I 25H A. Would you repeat the qesstion? moun.un a nanew :rm. - m:. t.ccum. c r.we - uanne:aun, v.s. :1n -- i . : r..,c.1,,,

y. _,,_ _,.- y

_, 7 y.,.., g._,,. m...

"T L- ~ ^ ~ ~ o.,. ; Dunn-erose 220 (Question reeld.) f 'That was at least the industry i THE WI'INESS: 2

3 practice at the time, based upon the fact of roughly 29 1

plants, four of them under construction, had used the 4 a 5 algebraic technique in some part or nerhaps the entire part -{ i of the design of the nuclear station. [ 7 BY MR. POPOWSKY: 8 Q Do you know whether they were using that in p 1974? 10 'A Using what in 19747 11 .Q What you just described, the algebraic 1 12. numnnbion techni'que. D

1.3 A

There is an exhibit which indicatee Stone 0: 1,4 Webster tras using the square root, of the cun of the eqtures 15 technique in 1972, 1973 But again, I don't knoti whether i 16 Stone & Webster wac merely uping this in terms of developraent, i 17j limited applications, or how they were using, it. It is not i

c' clear.

i .i ,1,o ! Industry practice, based upon informationd i 20-read, tcas for most stations, not necesse.rily all stations, J 3 11 but most stations, to use the coraouter code which in one ray 1 l j .e or another uses the algebrate summation technique. 1 I f 33 I Q. k you know why in' Octobor 1978 when Stone & j ~ O 36l.Hebster was asked to reanalyze the piping system, because of . )l 25i the change in the valve weights,. they used the NUFIPE' method? l 0 I- - - nwr.y t n s:r.nctti.1 suc.~ n n. : ::m'nu.o t.vr ~ nt,nntsounts, tV tvs tn -- ^ s E, ,.9 + r e i.g 5, n .e.+yveW, y(sep ytt e g. t{$* tge.r4rF,4QiW Wde 'y 4k ]T"'"9'" '8-9Tlf] FM{ s 'JW ' dY' -f 7

.j Dunn-cross 221-1 A Because it was one of the programs which 1 I 2 apparently was available to them at that particular point in. 3-time. It was.a program they were using. It was a program 4 which I assume in their opinion was at least as conservative f 5 as other techniques which they may have used. 6 They could have gone back and used the 7 original program.upon which the Beaver Valley plant was 8 designed. Why they made that determination, I don't know. 9 It may have been simply convenience. 10 Q It is at that time that the discrepancies were ~ 11 discovered between the two codes, to your knowledge, is that 12 correct? j i D 13 A That is correct. 1 j I4 Q Do you know whether the algebraic summation i j 15 method produces a result, leaving aside whether or not it is ij 16 [, equally or more less conservative than the other methods -- is i 17 it a result which is an accurate reflection of the sunnation 18 of the lond, to your knowledge? 19 A I don't know. 20 Q Can you tell us approximately when the vicing i 21 of the Beaver Valley plant -- I realize that is a large te rm, 22 piping -- but in general can you give us the dates piping was q 23 installed in the Beaver Valley plantt .i R pag. 1 i 24' A I can give.you a rough' estimate. The nioir.g Y ~ '25; 'was installed 11n Beaver Valley probably starting sometiae- !.iO233MCf1 O f.??.O*Af.. tJC. = C' N. LCC:W.'fLLOV/ t.YL - t?AtttfCCtmC,.*t ? ? !!:',. + % gy g qsgn>,, 4e a ges, g q, .,..q I ' ]" W * *pMap

1 Dunn-crons -222 i .; t early 1972, 1973, and is still being installed today. f g -Q In general would piping be among the latter i 3 projects in construction? A It is more in the mid-term from the standpoint ,y 5 of cons truction of a station. You start with your r 6 foundations, get your foundationc up, your walls 'up, and 7 enclose the building, so to speak', and then you bring in your 8 larger components in terms of size and get those set;-finish 9 off the major parts of your buildin6; and then begin to tie 10 together your components with piping, control, electrical 11 cable, et cetera.- 12 You essentiall;r need the walls of the building j O 13 to support the_ piping.. M Q What about piping hangers and supports, they 15 would be bui3.t after the actual. pipes would be installed, is 16 that correct? i 17 A No, you would do that as the pipe ia being 7.3 installed. You just can't hang a piece of pipe from a sky-19 hook. 20 Q I had asked you yesterday -- I'm not sure if 31 you answered --'do you know when the piping design was a 3g established, when it was actually designed? Y, 33 A _It would have_been designed ever some pericd ) ] O' 34 of. tine. I don't know precisely. 25 MR. TtIOMAS:. This in repeti tion, Mr,' Poocws ty, i -. :amant.cn O nan:w., suc. ~ av n. Lon::::n.ta u r.xs - w.m:nem, vn. :ms ,,.,,g,y,.,. j..,.. _ -.e .,q_,,.3, ,,.7.,

y,T ^ ~ ~ .j u i Dunn-cross 223 1, 1 ,( from yesterday. .I D l 5 2 MR. POPOWSKY: I 'm corry. Can I go off the { 3 record for a minute? i THE ADMINISTRATIVE LAW JUDGE: Yes. a 4 5 (Discussion off the record'. ) 6 7 THE ADMINISTRATIVE' LAW JUEGE: Concerning the ,8 off the record discussion, the contract between Stone & 9 Webster and Duquesne Light which was made available at che 10 last proceeding under a protective order, it is my under-11 standing; that counsel for Duquesne Light has no objections 1 12 to my making that contract available to you, Mr. Popowaky. l O l 13 MR. THOMAS: Subject to the same protective 14

order, 15 14R. POPOWSKY:

Thank you. That is all I heve. 4 ] 16 THE ADMINISTRATIVE IAW JJUIGE: Is there any J,7 further croso examination of this witness n't this time? 1 18 MR. THOMAS: We reserve our right to redirect. l 19 THE ADMINISTRATIVE LAW JULGE: The aitness is j. 20 excuced. Now let's go off the record. 21 lj (Discussion off the record.)

a.,

j 23 THE ADMINISTRATIVE LAW JUDGE: We have-had an-O 24 extensive discussion off the record as te the manner in.which', 25l we chould proceed with'this matter. We have discussed-4 1 C - -- umnmen e, e.wem me. .e n. i. rem.t.ew m... mnwwne. g. sein i

?#.

. Fe 8M*7; , -lf N,%,,pgvw wQWM ,M Qi6aggg h w-

-

it"'.WT
7,7;--~

.gt

. =. 0 _ _ _._22h 1 g ' witness es, we have discusacd issues, wa have discuoced an D 3 apparent upcoming rate case of Duquesne arm how that may 3 affect this proceeding. It has been decided that as the Administrative 4 3 Law Judge I am going to review the various filings of the 6 partiec concerning their concepts as to the issues, and then 7 hold a meeting with counsel to ariive at a decision as to the 8 best way to proceed. 9 In lieu of this, I will not set any further j 10 hearing dates in this matter, havin6 in mind that within the y,[ next week or ten de.ys we will be getting together, and at 12 that point in time we will set hearing dates, f 13 It is my understanding that this is 14 satisfactory to the carties concerned. 15 MR. T3OMAS : That is satisfactory'to me. 16 MR. LEVIN: The Trial Staff as well. 27 l THE ADMINISTRATIVE LAW JUEGE: The hearings gg are recessed until a date that will be set at a later timt. 19 I 20 i I 21 (The hearing was adjourned at 1:05 o' clock p.m ) k' 22 i 23 N i. m.., 1 25 4 i. uam.a manem me. - u. 6em.nw r.,m,- w.amww.,, n. nm -..- - - ~.- ,,.-w.,%.~., gy.7.,,, <m..,y. ,q,m.,,. o.., g_ ,y g g,,,.,,,,,. ,,y,

] - -. - -. ~ ~. -.. -...... - -.. -. e 1 --oOo-- l 2 'l I hereby certify that the proceedine;n and ] 3 evidenco c.re contained fully and accurately in the' notes 4 taken by me on the hearing of' the within cause before the 5 Pennsylvania Public Utility Ccatiiscion, c.nd that this is a 0 ev rect transcript of the same. O MOHRr3ACH & MARSHAL, INC. o By i 10 Offici,/ Reporter E*- Y-Al~f0 l'"' t RE]'OrtTED 'BY: O i 13 2AiT38 P. O'HARA 4 74 (dobrbach & Me.rchal, Inc 27 North Lociatillow ktdnue i I!arrinburg, Penncylvanie.17D2 a 1 16 i 17 i t la i 19 20 'o. ('Ibe foregoinc certification of this transcript i j 2 , dccs net e.pply to any reprcduction cf the sr.me by any treans un' esa under the direct control-and/or supervinion of the 2,4 j j certifying reportar.). h 2.9 i }p 24 g 1. eyr,.: .., r.o.:..r.. c:rn. a r...om. r :,c.:,m*. - : c n mn. rA m s.t - l l v m-~7 pry :..v ~:r ;~ -tr~ +m~ v e ~ n,. w . c.:yr ;, nyq;77g m-~rw7 q,pyyyn.mmy.spyn,y y.y ,}}

ML20126D398

Text

Navigation menu

Search