ML20129A608
| ML20129A608 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/13/1985 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20128G622 | List: |
| References | |
| NUDOCS 8507150351 | |
| Download: ML20129A608 (132) | |
Text
{{#Wiki_filter:_ - t OR G \'A _ I i - i NRC/TUGC0 MEETING 1 i i i i i l I r i l VOLUME I MORNING SESSION GODFREY a AMES COURT REPORTING CERTIFIED SHORTHAND REPORTERS
, 1106 W. PtONEER PARKWAY. SillTE 400 l ARLINGTON. TX 76013 ) (817) 460 2048. METRO 469 6100 COMPUTER A10E0 TRANSCRIPTION i v10E0 TAPE SPECIALIST June 13, 1985
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4 APPEARANCES: 5 NRC: TUGCO: 6 Vince Noonan William Counsil Robert Martin John W. Beck 7 Darrell Eisenhut John Marshal Don Landers Spot Burwell 8 Robe'rt Bosnak Larry Shao 9 Jose Calvo Angelos Marinos 10 R. Keimig TENERA CORPORATION: Jim Milhoan John Guilbert 11 J. Youngblood S. Black 12 Jane Axelrod J. Treby (] 13 Charlie Trammell Herb Livermore STONE AND WEBSTER: 14 Jim Gagliardo John Hansel P. Check Vick Hoffman 15 R. Denise John Christianson Ed Jordan 16 Richard Vollmer. TELADYNE: Larry Chandler Jim Hollonson 17 Al Patterson gg * * ****************.************** 19 MEETING HELD before Jayne Ames, a CSR, and Notary Public, in 20 Tarrant County for the State of. Texas, on the 13th of June, 1985, 21 beginning at 8: 4 5 a.m. , at the Sheraton Hotel, 1500 Stadium Drive 22 East, Arlington, Texas.' 23 J' 2 24 b 25 GODFREY & AMES COURT REPORTING
A 3 t 1 P R0C E E D I- N G S 2 MR. EISENHUT: Why don't we go ahead and get , 3 started? Maybe I ought to stand nere to start. I don;t 'l l 4 like the logistics already. 5 Le.t me go ahead and get started. Let me talk here 6 for a second so everyone can hear me. I'm Darrell 7 Eisenhut, the Deputy Director for the Nuclear Reactor 8 Regulations at the NRC. And this is a meeting between 9 the NRC and Texas Utilities concerning the Comanche Peak 10 project. ' 11 The meeting today was requested by the NRC as a 12 vehicle for bringing together all of the relevant 1 i 13 information on the Comanche Peak project, so to speak. L._J 14 What are all the issu,es that need to -be addressed , how 15 are they going to be put together by TUGC0 into an i 16 overall game plan for the resolution permitted decision, 17 into what was called by a lot of people something like 18 an action plan. 19 We asked Texas Utilities to get together'at this 20 point in time to go through an overview of that. We 21 asked for it to'be as much as we could today and 22 tomo,rrow aimed towards a management overview, 23 recognizing there are many, Lany details that, 24 obviously, we're not going to be able to discuss here LJ 25 today. GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
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4 1 .The -- recognizing it's a management meeting from _ _ 2 the standpoint of trying to have an overview, there's 3 quite a number of NRC participants here. I'll introduce 4 just a couple, since we are keeping a transcript. 5 As we go through the meeting, I would ask everyone 6 to identify themselves. 7 Vince Noonan is the director of the NRC's overall 8 project in Comanche Peak. He is assigned to integrate 9 all the pieces together and come up with an overall plan 10 of action leading to a decision by the NRC. 11 Bob Martin, who you all know, I'm sure, is the' 12 Regional Administrator here for t,his area. Some other
! 13 key participants who are here today: Dick Vollmer is LJ 14 the Deputy Dir,ector of the Office of Inspection and
- 15 Enforcement; Jane Axelrad, Director of Enforcement,-if I 16 did these right. Ed Jordan, one of the Division 17 Directors in the office of IE. Quite a bit of 18 management here today from throughout and across the NRC 19 to hear this presentation.
20 Over the last few weeks, the NRC issued its last 21 .SER that was contemplated, originally at least, as a
, 22 result of the technical review team, went out. That is 23 the QA SER, SSER number 11, I believe it was, which 24 identified a lot of the QA/QC-deficiencies, and various 25 items.
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5 l 1 The question that is now, we put to the utility is, _ _ 2 as I said earlier, "What does all this mean? How do you 3 put it together?" There has been some good things 4 found. There's been some bad things found. We looked a 5 lot harder at this plan, a lot greater depth in some 6 areas than we have, typically. 7 How do you factor all these together, leading you 8 to developing an overall feeling about the construction, 9 the design, the operational adequacy, all the relevant 10 aspects on the project. 11 What we asked TUGC0 to do, really, was put together 12 in one place, in a program, all of the issues, all of 13 the decision's, all of the items that have to be decided L._ 14 , on the project. We asked TUGC0 to do that. We -- and 15 this meeting is to some' degree, perhaps a status 16 meeting, because it's recognized all of the answers 17 don't exist at this time. It's also recognized the 18 action plan, the overall game plan, has not been
'19 submitted to the NRC.
20 Basically, it's an interacting meeting between the 21 staff and the Texas Utility. It is not a decision 22 making meeting. Make that right up front. 23 At the end of some appropriate time, I'll ask any 24 other interested parties if they have any comments to be L_m 25 made in the meeting. GODFREY & AMES COURT REPORTING Metro 469-6100, (617) 460-2048
6 i 1 We're going to try to run it, and then, Mr. _ _ 2 Counsil, I may be stealing your thunder, we're going to 3 try it, starting off with -- start with a higher plan ! l 4 management overview, working over a lower plan, working 4 5 - t h r o u g'h , eventually, over the coming weeks, I'm sure, a 6 rather intense effort for working out a lot of details. 7 From a general philosophical standpoint, it would 8 be our intention that Texas Utilities would develop a 4 9 detailed program plan on how they're going to proceed 10 to resolve all of the deficiencies that have been 11 identified in the past, how they all integrate 12 together. The NRC will review that plan, and try to , 77 13 pass judgment on -- if the plan is implemented. It L J-14 could lead to a -- an adequate decision down the road. 7 15 So our thrust will be to -- be looking at the 16 program plan on its adequacy. We will try to give a 17 d ec i~s ie n , something on the order of 30 days from receipt 18 of the final program plan. We're going to try to give 19 you an opinion. That is, an opinion can vary from -- 20 it's a great program plan on one extreme, with no 21 comments, to the other extreme, it's a totally 22 inadequate program plan, and it's so bad we can't given 23 you any specifics. , 24 Those are the two easiest. I doubt it's gotng to ! L_j 25 be either one of those. It will probably fall somewhere GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
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7 1 in between. But we are going to try to reach that _. _ 2 judgment on a time frame. 3 With that as a general introduction, I'm going to 4 ask Vince Noonan and Bob Martin if you have any 5 introductory comments. If not, I'm going to turn it 6 over to the Texas Utility to go ahead and start the 7 meeting. I apologize for the logistics. I don't like a 8 podium. I prefer tables. But we can proceed through 9 there. Vince, do you have any comments? 10 MR. NOONAN: I don't really haye any comments at 11 all. Go ahead. 12 MR. EISENHUT: Bill, I assume you are going to be i 13 sharing the meeting with Texas Utilities. We're going L_ 14 to turn it over. I ask all the NRC, feel free to 15 interrupt and ask any questions you need to. This is 16 really a meeting for anyone to understand any concern, 17 any question that you have. I want to make sure that, 18 even though Bill is going to probably say, "I'd like to 19 finish and reserve your questions," I'd like to make 20 sure we can answer any question that you have. Thank 21 you. 22 MR. COUNSIL: Thank you, Darrell. Good morning 23 ladies and gentlemen. My name,is Bill Counsil. This 24 morning, my portion of this program, what I hope to L' accomplish, I want to state once and for all my 25 GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048 e - -- - ,-.-,-ee , - -
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8 1 qualifications on the record, since I haven't had an !_ 2 opportunity to do that yet. I also want to give you an 3 overview of how I view safety, and that will be very 4 short. 5 I'm going to cover this morning what we nope to 6 accomplish in the next two days. And then as the NRC 7 has requested, I'm going to show you what my 8 organization is to accomplish it. 9 Now as to a quick summary of my background. I'm 10 a graduate of the U.S. Naval Academy in 1960, with a 11 B.S. in engineering. After graduation, I served seven 12 years as a commissioned officer in the navy, five of {] 13 which was in nuclear power. 14 I resigned, joined Northeast Utilities in May of 15 1967 as a shift supervisor on their then most known one 16 project. I quickly became the operations supervisor 17 responsible for the startup testing, preoperational 18 testing, all training of that unit, and its inservice 19 operations. 20 I am or have been SRO licensed, both on a boiling 21 water reactor, two pressurized navy reactors. I have 22 completed all training, and have been senior certified 23 on a combustion, engineering reactor. 24 And I have also been senior certified by I_ _,i L) 25 Westinghouse on a 4 loop pressurized water reactor of GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
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, 2 My manage' ment experience stands from operation 3 supervisor to assistant plant superindendent, as of both 4 a BWR and a PWR units under construction, and all'the 5 way to station superintendent, nine years of operations 6 experience.
7 Then moving into the corporate management chain, 8 first, as a project manager of the Millstone 3 Project, 9 followed by the vice president of a complete nuclear 10 organization. That's engineering and operations, to a 11 senior vice president of Northeast Utilities, where I 12 had 2250 people reporting to me, approximately half L l - 13 professionals, and the other half operations type. kJ 14 As far as industry type experience, I'll only 15 highlight just a couple things of recent vintage. I am
- 16 a member of the AIF policy' committee. I was chairman of 17 a group called the Nuclear Utility Group, on 18 enforcement, one of my favorite subjects.
19 I'm co-chairman presently of the Nuclear Utility 20 Fire Protection Group. I'm also chairman of the Nuclear 21 Utility back pit and regulatory reform group. And I'm a 4 22 past chairman on -- of impulse and analysis engineering 23 division industry review group for three years while 24 input was being formulated. t
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25 I think all of you presently know I'm TUGCO's i GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048 w- ._-g7-ys- w=ye , -e.--,y7g- - ,wy- ,--w,.--,p -4,___,-
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10 1 executive vice president in charge of nuclear _. . 2 activities. 3 This represents approximately 25 years, 23 of which 4 are involved in strictly nuclear power, and 18 of which 5 are commercial nuclear power, at many levels of 6 management, and also in-many disciplines. 7 As the person in charge of TUGCO's nuclear 8 organization,.I am responsible for all nuclear 9 activities of this company. My management style, so you 10 can get used to me, is one of total involvement, in 11 these activities where I hope I may apply my experience 12 .and judgment to implement a safety first attitude. i 13 More specifically, let me give you my management L_J 14 overview of safety. Now for those of you who are NRC in 15 the room, I'm not trying to lecture. I'm going to give 16 you a little brief summary only. And then give you my. 17 view. 18 Obviously one can say is a plant or an 19 organization, is safe if they meet the 10 CFR codes. If 20 they have an understanding and implement all applicable 21 codes and criteria. 22 Number one talks about ASME or any other of the , 23 applicable codes in reference to 10 CFR or any NRC __q 24 documents. And also if the organization has procedures L.J 25 to implement those above. GODFREY & AMES COURT REPORTING l Metro 469-6100, (817) 460-2048
11 1 Obviously, to also have a safe organization and 1 __ 2 safe operation, you must have training in those 3 procedures which you have developed. You must have 4 construction in operation, strictly follow those 5 procedures. And finally you must have inspection 6 processes to insure that they have been properly 7 implemented. 8 But I would submit, ladies and gentlemen, it goes 9 far beyond that. Those are minimum requirements, as I 10 think the NRC is well aware. 11 To have a good organization, well respected, and 12 also one that goes beyond those minimum requirements, t 13 requires a safety ethic. What do I mean by a. safety L_ 14 ethic? Well, when you get right down to it, a safety 15 ethic is really a management state of mind. It goes 16 well beyond codes and criteria. It attempts to instill 17 that same safety ethic in all of its employees. And it 18 is conservative, extremely conservative. It always asks 19 the question, what will happen if. And that is not a 10 20 CFR 5059 question. It goes beyond that. It always 21 questions what your actions are, what you are doing. If 22 you're an operator, what will happen if you don't start 23 the pump, or you incorrectly stop a pump. ___, 24 It also encompasses, especially in construction,
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25 doing it right the first time. It encompasses a strict GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
12 1 adherence to all codes, criteria, and procedures which i_ 2 have been developed. It encourages among its employees 3 an attitude to adopt strictly safety first. 4 And it also requires management to be totally 5 involved. And what do I mean by that? Why should 6 management be totally involved? Well, management must 7 lead; management must train; and management must develop 8 this organizational safety ethic. When safety 9 significant deficiencies are found, it requires that 10 they are correctly -- that we correctly engineer the 11 fix. 12 It also requires follow-up to ensure that the g i 13 proper implementation and corrective-actions remove the uJ 14 root cause of the problem, and ensure that that problem 15 or similar problems will never reoccur. 16 Now that is a short brief on my attitude towards 17 safety. I'd like to turn now to our management meeting, 18 this June 13th and 14th, and the program plans and what 19 we hope to accomplish. 20 I believe our program plans are a comprehensive 21 overview. We will deal with the implementation plans, 22 which are going to be available to you on site. 23 Is that better? 24 And I believe that we are going to deal with all L_ : 25 concerns regardless of their origin. I believe our
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13 1 pro'g ram goes well beyond those concerns that have been _' _ 2 expressed to date. It's designed to provide TUGC0 3 management with assurance that-the plant is properly 4 constructed and can be operated safely. 5 I will assure you that TUGC0 management will not 6 ask-thn URC for an operating license until we are-7 satisfied that those objectives have been met. 8 And in all steps of the way, as we implement this 9 program, I would like to see the NRC closely involved 10 with our technical staff. 11 The program overall is designed to provide 12 reasonable assurance that the health and safety of the e 13 public will be protected. L-14 And now, if I may, I will turn to the organization 15 that I'have in place. Darrell, do you want to ask a 16 question? 17 MR. EISENHUT: Let me ask a generic. question before 18 you pass by the front end safety ethic, do it right the 19 first time philosophy, which I certainly agree with much 20 of it. I think that's certainly the way to go. 21 Can you characterize -- let's see. You have been 22 with TUGC0 now a month and a half roughly. 23 MR. COUNSIL: Roughly. 24 MR. EISENHUT: Can you characterize how you see (- 25 it? You see -- you obviously felt the need to go GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
14 1 through that safety ethic to make sure that that's where _ , 2 you're going. You also said on the last slide that 3 you're not going to ask for an NRC license until you get 4 there. 5 Would you care to characterize where you think you 6 have been as an organization? Where do you think you -- 7 obviously -- I mean it doesn't take a genius sitting 8 here to figure out in some areas it wasn't done right 9 the first time. 10 But can you characterize where you think you have 11 been, and where you think you're going, and give me a 12 feeling for a number of the areas you talked about as -- i 13 how big a step you think it's going to be. Is it a L.J 14 major change? Can you characterize it? 15 MR. COUNSIL: I will attempt to do so. In my six 16 weeks that I -- since I have come here, and the various 17 levels of management that I have talked to .I have been 18 in meetings with, the personnel that I have met in the 19 field, including the operations personnel, the attitude 20 is one of trying to do it right the first time. 21 What I found is, on occasion, some personnel don't 22 know exactly how do to do it the first time, and do it 23 correctly. And that's in retrospective now. _q 24 Where we are today is putting together an J 25 organization where, if I don't have the technical 4 GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048 7 ..
15 1 expertise, I have drawn in that technical expertise from
._ 2 outside to help me to accomplish what I hope to 3 accomplish. And you will meet some of tnose people over 4 the next couple of days.
5 The intent is, over the next few years, is to find 6 the personnel that I need from within the industry, such 7 that I don't have to have technical consultants. And 8 that I can become self contained. That's the way.I like 9 to be. 10 So we're not fully there yet with staff, 11 obviously. The attitude is there, and it has been 12 there. c 13 MR. EISENHUT: But to some degree, don't you really L 14 have to have the qualified staff, at least managers, in 15 place, and ensure they have the right attitude or 16 approach or philosophy, then develop the plan for 17 implementing that philosophy, and then going forth and 18 doing it? Really, how are you going to. address the 19 chicken and the egg argument? Which one do you have 20 first? 21 MR. COUNSIL: Well, right now, Darrell, in answer 22 to your question, I have most of what I need with me 23 today. You're going to see some blanks on my chart when 24 I put it up. That was my next step. What you're going 25 to find where I have a blank, either I or some other GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048 . . . . . , . . . . . .. - . _ . . . . . . ... _...y....
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.16 1 manager or vice president within my organization are
[_ 2 filling that blank on a temporary basis. 3 I have the framework of an organization to carry 4 out exactly what I said. There are certain activities 5 that we're doing today that will not be required in the 6 future. Consequently, those activities are being filled 7 by outside consultants working directly for TUGC0 8 management. 9 There are some activities that I would like to, in 10 the future, in an operating mode, not in the mode we're 11 in today, expand that organization. And that's one of 12 my goals. And I will in fact to do that. i 13 But I don't want you to get the idea that I am not s..J 14 prepared to go forth with what I have presently today 15 and what I have before me. I can easy accomplish that. 16 MR. EISENHUT: And recognizing, to following up on 17 what you said, some places when you go through the 18 organization, you will be showing then yourself filling 19 in a function until you make those transitions. 20 MR. COUNSIL: That's correct. 21 MR. EISENHUT: And could you also when you go 22 through, make it clear again, who is really a TUGC0 23 employee full-time, and who is an outside consultant or 24 temporary assignment or whatever, so we can get a L.. 1 25 feeling of where you really stand from a TUGC0 GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
17 1 organization? I'd appreciate it.
.. 2 MR. COUNSIL: I will. But I took my organization 3 only down to one level. So generally you won't find 4 outsiders filling in any positions inside the 5 organization at that level.
HR. EISENHUT: 6 Okay. 7 MR. COUNSIL: Now John, when I turn it over to John 8 Beck, his organization will go a little deeper than 9 that. And also his explanation of some things that will 10 follow me. And he in fact will show you who is outside, 11 and the qualifications of people who appear on his 12 chart. Am I ready to go on now to the chart? I 13 (Indicating) *
]
14 Obviously I report to Mike Spence, president of 15 TUGCO. Reporting to me are Mr. Warner, who is the 16 manager of SAFE teem. The senior review team, who I 17 will go into a little more detail in a moment, first 18 slot that I'm now filling, that you see my name twice on 19 that chart, is I'm acting as the vice president of 20 nuclear operations at this point. 21 Mr. George is the vice president of Comanche Peak 22 Steam Electric Project, general manager. And obviously 23 at the table with me is John Beck, who is vice ___ 24 president. And I think you know that he has planned 25 licensing, fuels, and quality assurance at this point. GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048 y . . .
18 1 In the nuclear operations area, direct reports to i _ 2 me are Mr. Kahler, supervisor, engineering and 3 . administrative services. And he's located in Dallas. 4 Mr. Kuykendall, who is the manager of nuclear 5 operations. And he's located at the plant site. And 6 Mr. Edwards, also in Dallas, is the supervisor of health 7 physics, t 8 Mr. George's organization, he has Mr. Merritt, who 9 is the assistant project manager for unit number 2 10 construction. He has Mr. Camp, who is outside our 11 organization. He has been on our project now for l 12 several years. And he's the assistant project general l i 13 manager on unit number 1, who~is doing much of the
- l. }u J 14 implementation of the Comanche Peak action plans.
15 And obviously now this is a newly created position, 16 the next one on the right, and that's Mr. George, is. 17 filling as manager of engineering. I 18 In Mr. Beck's organization, again on the far left 19 of the chart, he is filling in as manager of nuclear 1 20 licensing. He has Mr. Janne, manager of nuclear full i 21 and safety analysis. And Mr. Wells, who is director of i 22 quality assurance. And I think most of you know that ! 23 Mr. Wells is a DUKE employee. i ,. 24 When you go to the senior review team, other than Li the chairman of the senior review team, John Beck, all 25
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19 1 are outside our organization. The members are Tony Buhl [ __ 2 of Energyx; John French of Delian; John Guibert of 3 Tenera; and we have Terry Tyler of Energyx, who is the 4 CPRT program director. Mr. Shao? 5 MR. SHAO: Is there any member in the senior review 6 team, expert in the m'echanic or design and structure, 7 where most of the problems are? 8 MR. COUNSIL: No, as you will learn tomorrow, we 9 have Stone and' Webster Engineering Corporation carrying 10 on that effort for us. And they are reporting on the 11 project, as opposed to in the senior. review team. 12 There is -- senior review team has an overview. f~1 13 Now on the CPRT however, which is reporting to the s._J 14 senior review team, there is Howard Levin. And John 15 will get into that organization chart. I just wanted to 16 show the senior review team members themselves. 17 MR. EISENHUT: Okay. I think the question Larry 18 had, John, and you can be thinking about it, is how can 19 the senior review team exercise its function of 20 oversight of the CPRT if there is no one on the 21 CPRT with the expertise in the principal area that is -- 22 or a major area that is being evaluated. And I think 23 that's a question we want to come back to. 24 MR. BECK: Sure. 25 MR. COUNSIL: That concludes my portion of it, GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
i 20 1 unless you have additional questions. L. . 2 MR. EISENHUT: Are you going to go through the next 3 slide on SAFE team? 4 MR. COUNSIL: No, I was not. 5 MR. EISE.NHUT: Is John going to? 6 FI R . COUNSIL: No. 7 'MR. EISENHUT: Then I would like you to go through 8 that. 9 MR. COUNSIL: Fine. 10 HR. EISENHUT: Can you characterize the SAFE team? 11 How long you have had.it in effect? And really, can you 12 describe it a little bit better?
-i 13 HR. COUNSIL: Fine. The SAFE team has been in b
14 effect since about the beginning of this year, as a 15 fully qualified type organization on site. The manager 16 of the SAFE team has been involved on the Comanche Peak 17 project for a number of years in the licensing arena. 18 The SAFE team has two arms, bne is an interview 4 19 arm, as it shows on the chart. And the second is an 20 investigation arm. Those two arms do not meet, except 21 the interview arm turns over, quote, any allegations 22 that it in fact receives, and protects yhe -- the 23 confidentiality of the individuals. __, 24 The investigators then take'that, and they do the, a
~ J 25 quote, interviews and investigation in the field as to GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
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21 1 the allegation. The investigators also draft the final i._ 2 report back to the individual who made the charge. That 3 is reviewed by several layers of management prior to 4 forwarding the letters directly.back to the personnel 5 who made, quote, the allegations. 6 If there is any follow-up required, it so indicates 7 gnat letter that they have the option of coming back 8 through the SAFE team once again, if they feel that they 9 did not get the answers to all the questions they had 10 put forth.
. 11 MR. EISENHUT: All right. Can you -- let me ask a 12 couple of basic questions about it. You have one arm 13 that is an investigative arm. Is that a technical
{ 14 investigative, or does it include people qualified in 15 what I'll loosely call the wrongdoing investigative arm? 16 MR. COUNSIL: It's both. 17 MR. EISENHUT: And they have personnel in the group 18 then, or at their access, knowledge, capability, 19 qualifications in, doing investigative, into the 20 wrongdoing type aspects. 21 MR. COUNSIL: They have people who are qualified, 22 knowledgeable, to look into-the wrongdoings. For 23 instance, many of the -- if there is an allegation of 24 wrongdoing, typically it's an allegation to management,
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25 or a management, quote, wrongdoing. And fully about l-GODFREY & AMES COURT REPORTING j Metro 469-6100, (817) 460-2048 .i _ . . . <
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22 1 one-third of things brought to SAFE team to date are in __ 2 that category. 3 If in fact they do not have the technical 4 expertise, but -- get off the wrongdoing portion of it 5 for a minute, to investigate a technical allegation, 6 they do go to the Comanche Peak project team, and draw 7 in that technical expertise to help in that 8 investigation and in the final report. 9 MR. EISENHUT: Let's see. May be mixing apples and 10 oranges here. Let me take that wrongdoing first. 11 If a third of the issues generally fall or include 12 wrongdoing aspects, does this group, the investigative i 13 group itself, do the investigation, or do they farm it _ _1 14 out to another group? Do they ship it to the general 15 counsel's office? Do they ship it? How do they do it? 16 MR. COUNSIL: Well, basically, if it's a management i 17 allegation, let's put it that way, that flows to the 18 vice president on site. They in turn work with that 19 .vice president to not only investigate, but draft that 20 final report. . 21 If in fact it involves a technical concern, it 22 could be pulling in quality control management. It i 23 could be pulling in weld engineers. Whatever, in order 24 to assist them in completing the investigation and L__J 25 developing a technical response. GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
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23 1 MR. EISENHUT: Okay. Let me make sure I
- _ 2 understand. I don't want to belabor the point, except 3 the way you said it, I want to make sure we don't 4 mislead the record here.
5 Does the reviewer -- let me back it off. 6 If you have an allegation about wrongdoing, does 7 the evaluation get performed by the.same people that the 8 wrongdoing charge is about? Or does it go to a third 9 party or someone else? 10 MR. COUNSIL: No, it does not go to the same person 11 that the allegation is about. No. It might go to, 12 quote, a same discipline in a different area. But e I 13 certainly not about the same -- or by the same group. L_l 14 MR. EISENHUT: Okay. 15 MR. COUNSIL: Now there are disciplines. For 16 instance, if you talk about weld engineering, the 17 capability exists in the ABASCO organization on site; 18 Brown & Root, Comanche organization, so forth. I mean 19 allegations against one of those organizations, it would 20 be drawn -- the technical review would be drawn from 21 another. 22 MR. EISENHUT: Can I ask then a couple of quick 23 questions? How Csny files do you have open today in the 24 SAFE team concept in terms of how many allegations the 25 SAFE team is reviewing? 'How many? Tens, hundreds? GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
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24 1 MR. COUNSIL: Darrell, I can find for the record [. 2 how many there are. But I can give you just a rough -- 3 MR. EISENHUT: Rough numbers is all I'm looking 4 for. 5 MR. COUNSIL: Rough numbers, I believe we have had 6 on the order, just under 600 brought, of which 7 approximately 100 have been responded to. There are 8 a p p ro:t ima t ely 350 in review-and/or investigation at this 9 time. 10 MR. EISENHUT: Now I can appreciate, just to make 11 sure I ask the number, now that I ask for the number, to 12 make sure that to keep it in prospective. I'm sure they [7 13 vary all up the map, in terms of the very insignificant t_ J 14 to potentially more significant. 15 What do you do, and how do you feel -- or what do 16 you feel TUGCO's responsibility is, to reporting an item 17 to the NRC that comes up under the SAFE team concept? 18 Do you feel you have any obligation to report any of
, 19 those matters to the NRC?
20 MR. COUNSIL: If in fact it's a technical concern 21 that has been brought to SAFE team, and we confirm that 22 the allegation is in fact correct, generally that type 23 of item would fall under 5055-E, and definitely would be _ 24 reported to the NRC.
"J 25 Most items, however, would not be, primarily GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048 s,
t 25 i 1 because we are attempting to protect the confidentiality b.. 2 of the people who made the report in the first place. 3 Now in general terms, I believe your people on site 4 from Region 4 have talked to Mr. 'da r n e r . They know what 5 the allegations are. The lists are there available for 6 review. And in addition to that, our response is there, 7 with the persons' names stricken. 8 MR. EISENHUT: I appreciate that, and we have 9 looked at it, and we'll continue to look at it. The 10 question I was really looking to, was what your 11 philosophy, so to, speak, and approach to the problem 12 was. Also the individuals of course can always come to 13 the NRC independently, if they feel the SAFE team isn't {~ 14 satisfied. 15 MR. COUNSIL: Absolutely. 16 MR. EISENHUT: So I feel quite confident in that 17 sense. I was really looking -- 18 MR. COUNSIL: In fact, we encourage them, if they 19 feel they didn't get an answer from the SAFE team to 20 talk to the NRC if they don't feel we're going to follow 21 up. Question? 22 MR. GAGLIARDO: Yes. My name is Jim Gagliardo. 23 You indicated that about 600 issues had been brought to 24 the SAFE team since its inception. To what extent does
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25 that 600 include prior issues that management was aware GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
.,..s..
l 26 \ 1 of, or had been brought to management, before the SAFE
- i. 2 team was formed at the end of this year? Or are all of 3 these 600 issues, been issues that have been brought to 4 the SAFE team since their inception in January?
5 MR. COUNSIL: That's a difficult question for me to 6 answer. I can't honestly answer that question, because 7 of my short history on the project. I do know in the 8 management area, though, that some of these have 9 brought -- been brought up to management in the past. 10 For instance, they -- one of the recurring 11 complaints is that we have not had a pay increase on 12 site, or Brown & Root has not, in approximately three-F7 ~13 years. No general increase. L.J 14 Now that one, although the answer was in fact 15 given, we are still working on hopefully resolving the' 16 issue. Now management has known about that one. But I 17 can't honestly go back and off my memory of 600, either 18 in the safety category, concern category, or management 19 category, so forth, tell you how many we knew about 20 before or how many are new. , 21 John? 22 MR. BECK: Thank you, Bill. I should probably 23 start this morning, although I have been with the 24 organization a slight bit time longer than Mr. Counsil, o 25 with reminding some of you, perhaps who don't know me GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048 7 . , . _ . . _ _ ._ .. . ...- , . -- -
27 1 and don't know what my background is, and where I come l b_ 2 from, and what I have done in the nuclear business over 3 the last 20 years. 4 I ccoe froci Oklahoma originally, and went to school 5 at the University of Tulsa, and moved to New England 6 after graduation. Counsil migrated from the Midwe'st in 7 the upper part, what I call Yankee country, I guess. 8 At any rate, my experience was there was initiated 9 at Betastomic Power Laboratory, Westinghouse 10 Corporation, and reactor physics area. 11 I went from there to Yankee Atomic in Boston. 12 Right at the inception, actually, of a significant Ir 13 expansion of nuclear power in New England in 1967, an L 14 adequate Yankee, one of Bill's old plants, was just 15 coming.on line. I participated in the early phases of 16 that facility, particularly in the physics, 17 thermohydraulics, and safety analysis area, for about 18 five years. And also with Yankee Row in western 19 Massachusetts. 20 The same time the Yankee organization was providing 21 the engineering support for the utility sponsors in New 22 England for Vermont Yankee and Maine Yankee, which were 23 under construction. 24 I served as licensing engineer in Maine Yankee's 25 case for approximately a year. That facility was GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
.m,.., , . - . .. - - -
]
28 1 licensed in 1972. And shortly thereafter, Vermont _ _ _ 2 Yankee also received a license. And I was more involved 3 there with that BWR on the technical side of it, and in 4 the licensing Proceeding as well. 5 I proceeded over the next five years with the 6 Yankee organization on the engineering side of the 7 fence, and left that company in 1976 as director of 8 engineering, where I had responsibility for not only the 9 more esoteric technical disciplines, physics, 10 thermohydraulics,.laga analyses. 11 In that process, by the way, we developed -- I 12 think we were the first utility to provide and have
~1 13 benchmarked and accepted by'the NRC an analytical U
14 methods for doing relow analyses for those plants. 15 We started with Yankee row and did Connecticut 16 Yankee, prior to the transition of responsibility for 17 that plant to Northeast Utilities. And proceeded with 18 Maine Yankee and Vermont Yankee later on, to a lesser 19 extent, in the case of the BWR. 20 At any rate, after the ten years I spent with 21 Yankee Atomic in those various technical and managerial 22 positions, I went to Vermont Yankee as vice president, 23 and was subsequently elected six months after my arrival 24 as executive vice president and chief operating officer
'O 25 for that corporation.
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_ . . _ . ., . , . - - . . , . . . . ...s.. _ . . . . . 7 . -1 _m, _ . - . ,
29 1 I had responsibility in that capacity'for all the _ _ 2 corporate activities reporting directly to the chairman 3 of the board and the CEO for that single unit generating 4 company. And in that position, I dealt extensively in J 5 all respects with that unit, and its interrelationship 6 with not only the s' tate and local officials. 7 'But practicing safety first, as Bill said, I'd like 8 to go back to his comment. I endorse that 110 percent. 9 I have known Bill Counsil personally for about 15 10 years. And his philosophy is 110 percent endorsed by 11 me, as I said. . 12 We practiced very similarly in doing it, albeit e , 13 different parts of that state over the course of the L2 14 last 15 years or so. John, if you could give me the 15 first slide. . 16 The principal areas I'm going to cover this morning 17 have to do with the TUGC0 organization for which I'm 18 responsible, what our activities are, and the 19 non-CPRT licensing issues, if I may. And by that I mean 20 those issues that are not covered directly by the 21 Comanche Peak response team activities, but which are 22 vitally important to the licensing of the facility. 23 I'll go into some detail and give you a status of 24 where we are with regard to the obligations we have to 25 the regulatory, and where the regulators are with regard 1 GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
30 1 to some obligations they have to us, with regard to
- i. 2 responding to pieces that we have submitted.
3 I hope that will be a comprehensive picture. It's 4 not the complete picture. We have provided to staff a
$ comprehensive action list, which is a book about yeah 6 thick that covers in detail all of these areas. But 7 I'll get into substantive issues.
8 I'm going to turn, then, to the CPRT organization 9 as a whole, and give an overview of the issues as we see 10 it in the Comanche Peak response team. And then I'll 11 address overall schedule and the resource loading that 12 we anticipate will be required to execute the program. t i 13 As Bill 1..d i c a t ed , and this is a repeat slide, the L 14 organization.within TUGC0 for which I'm directly 15 responsible includes these areas of licensing where I'm 16 continuing to serve as manager of licensing. 17 Reporting to me is Dr. Randy Janne, who is manager 18 of fuel and safety analysis. And Jim Wells from DUKE 19 Power, as Bill indicated, serving in the capa'ity c of 20 director of our quality assurance and quality control 21 organization. 22 I might add that reporting directly to Mr. Wells is 23 Phillip Halstead, a Daniels contract employee, who is on
, 24 site in charge of the. quality control organization. And i
25 Mr. Dave McAfee, who is also a Daniels employee on GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
4 31 I
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1 contract to us, who is in the Dallas office, and in __ 2 charge of the Dallas QA organization, reporting directly 3 to Mr. Wells. 4 MR. NOONAN: John, I want to interrupt you for a 5 second. 6 HR. BECK: Sure. Any time. 7 MR. NOONAN: Mr. Wells, is he located in the 8 corporate office, or is he at the site? 9 MR. BECK: He's officed in Dallas. He spends 10 probably three days out of five at the site. But his 11 office is in -- he's got one in both places, like the 12 rest of us do. F"- 13 MR. NOONAN: Okay. L. 14 MR. BECK: I should have added, please interrupt if 15 anybody has a question. 16 MR. NOONAN: One other thing. Maybe,'too, when you 17 talk about these gentlemen, Mr. Wells particularly, his 18 qualifications. 19 MR. BECK:~ Jim has been in quality assurance longer 20 that I have been alive, I think. He was a principal in 21 the DUKE Power organization and the quality assurance 22 area. Specifically the sequence I don't recall exactly, 2.2 but many years, 15 or 20 in that regard, and had 24 principal responsibility with the DUKE organization. So I-{
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25 he comes with unparallel qualifications to join us in
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32 i 1 the capacity he's filling right now. ' L._ 2 MR. NOONAN: And the other two gentlemen that you 3 mentioned from the Daniel Construction Company, their -- 4 is it my understanding they were off the Callaway 5 project? 6 MR. BECK: Mr. Halstead did. Right off I don't 7 recall where Dave McAfee'came -- was last. 8 MR. NOONAN: Their backgrounds? 9 MR. B'ECK: Similarly, they're very highly 10 qualified, with many years of experience. 11 MR. COUNSIL: We can get them a resume. 12 MR. BECK: Yeah. We can provide that to you. In i 13 fact, I suspect we already have. 14 Jack Redding I don't want to miss. . Jack is our 15 resident, if you will, in best these days serving as a 16 primary contact. All of you know him. He is of great 17 help to me, and we communicate multiple times daily, 18 making sure that we keep on top of any issues. 19 Next slide, please. This is a further breakdown in 20 the licensing organization. It shows John Marshall, who 21 is helping me with the_ slides this morning, in the 22 generic licensing area and special considerations. 23 That's a recent move to give John a more defined 24 role within the licensing organization. He continues to O 25 serve, however, in those areas where he has had specific GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
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33 1 cognizance over issues having to do with the operating _ 2 plants. 3 But we want to begin to focus more on a longer 4 range look. In particular, to consider how and 5 specifically when we're going to begin to incorporate 6 PRA techniques internally to assist us in a decision 7 making process, particularly with regard to back fit 8 activities. John is going to be a principal in that 9 organization. 10 Don Woodlan, who is not here today, is going to 11 focus primarily on the operating plant licensing
-12 considerations in~the future.
13 I'd like to turn now more to specifics on the { 14 non-CPRT licensing issue area. I'm going to cover --
~
15 please interrupt if you have-got questions. There is a 16 lot of data'here, but I think it's important to 17, recognize that, from my view, we have got our arms 18 around all the issues. We have got them documented. We 19 understand what they are. We know what we need to do, 20 and we think we have got a good feel for when we're 21 going to do it. 22 So I have got a lot of dates in here. These are 23 commitments that we're taking very seriously, and we 24 intend to satisfy them. 25 The first chart indicates what I will be covering.
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l Metro 469-6100, (817) 460-2048 .g .., .
34 1 SER outstanding issues that have been previously __ 2 published. Confirmatory issues; licensing conditions; 3 open correspondence; significant engineering and 4 construction items; deficiency analysis reports; NRC 5 inspection reports; the pre-op tests category; our 6 technical specifications; and a few miscellaneous 7 items. 8 They will not be briefed as part of the Comanche 9 Peak responsibility team effort. We're purposefully 10 keeping that in, if I may characterize it, a licensing 11 usual bin. And we'll treat it as such. 12 MR. EISENHUT: Let me test you on that first item i 13 there. I 14 MR. BECK: Sure. 15 MR. EISENHUT: About SER open issues. You really 16 mean SER issues that really don't interract with the 17 CPRT, because there are a number of items under the 18 SER's, or open issues or follow-up items, which could 19 have an impact or an effect back on CPRT as sort of a 20 secondary matter. 21 MR. BECK: That's right. 22 MR. EISENHUT: Leak before break. Those kinds of 23 items. _ 24 MR. BECK: There are some items, for example, that 25 have come out of Region 4 inspection reports that we GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
._ . ..n.. -- -. ..
35 1 have chosen to treat within the CPRT program because of 2 the close relationship activities that are already 3 ongoing, and we have so indicated our responses to
.4 Region 4. And there may be a few others as we get 5 through here, but basically most of this is 6 non-CPRT activity.
7 MR. EISENHUT: Okay. I'm really looking for the 8 interface. Any item that could potentially interact at 9 CPRT goes with the CPRT . 10 MR. BECK: Yes, sir. That's the preferential - 11 treatment, to keep this one cleanly separate. Under the 12 SER outstanding issues, where we feel that we have done F i 13 what is required, and I would put into the category of L_J 14 its NRC action next, are those principal five issues. 15 An inspection program for pumps and valves. We have 16 submitted -- provided our submittal a number of years 17 ago. There is no emergency requirement for response 18 from the NRC, but I included it for completeness. That 19 documentation has been provided, and we anticipate that 20 the NRC will be covering it in their next SSER , 21 Remote safe shutdown, we provided a submittal in 22 July of 1984, last year. We expect closures of that 23 issue in the next SSER . All of these cases we have had 24 continuing dialogue with reviewers, and we feel that the
~~
25 issues are well in hand. They're included here for l GODFREY & AMES COURT REPORTING l Metro 469-6100, (817) 460-2048
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_' ?.
' ' ^
._ _ .' l
36 1 completeness. _ _. 2 MR. EISENHUT: Let me just ask the detail on one. 3 The recote safe shutdown, is that the fire protection 4 shutdown, or is that just the remote -- the other remote 5 panel from the controller? 6 MR. BECK: It's the safe shutdown, not fire 7 protection aspect. And in particular in this case, 8 we're talking about IEC2 and source range indication 9 being provided on a back pit basis within that cr.tegory. 10 MR. EISENHUT: Let me make sure. Are you saying 11 that you think putting TECO on the panel at the back 12 pit, or is that a correction? I think you used a i 13 management word to trip me off. Is it correcting -- the Q 14 requirement is for instruments to be able to go to TECO 15 in the remote shutdown panel, and you're saying you just 16 have to put the instruments on the panel. 17 MR. BECK: That's correct. It is back pit. It's 18 not part of the original plan design. How can I say 19 that? 20 MR. COUNSIL: You said it right. 21 MR. BECK: Mr. Counsil tells me I said it right. 22 The integrated leak rate test, we submitted a propcsed 23 change -- this touches on a CPRT issue, as a matter of 24 fact, or TRT rather. It was one of those items that was 25 identified as a deficiency with respect to the fact that GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
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1
37 1 we had changed our. requirements. We had not -- or r [_ 2 changed the test requirements. We had not modified the 3 FSAR , 4 This indicates that was done. And we're waiting 5 approval and acceptance by the staff formally. And the 6 safety parameter display package submitted las't month. 7 Next slide, please. These are SER outstanding 8 issues where TUGC0 action is required, and we have not 9 satisfied it yet. Containment isolation dependability, 10 we're going to be submitting the end of September this 11 year. What that is principally directed toward, is a 12 requirement that we provide more complete. documentation 13 with respect to the ability of the containment purge { 14 isolation valve to close in five seconds against the 15 required pressure differential of 50 PSI. That is 16 likely going to require a modification to that 17 particular valve. 18 A containment, some performance. As you know, as 19 you certainly know, you issued the SSER, we must now 20 modify our FSAR to reflect our commitments and 21 requirements with regard -- or in accordance with 22 SSER number 9. That documentation is being prepared, 23 and will be submitted along with other FSAR amendments 24 August 1 of this year. L_ 25 on the control room design review, we have some GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
38 1 final noise measurements to make. Those noise 2 measurements cannot be taken until all construction 3 activity associated with modifications to the control 4 room have been completed. We have reached 5 aGreementttha, deferral of those measurements prior to 6 five percent power is an acceptable resolution. 7 MR. LANDERS: John, all you're deferring is the 8 noise level lest? 9 MR. BECK: There are some other tests having to do 10 with HBAC that will also -- have yet to be 11 accomplished. But in particular that's all I'm talking 12 about here. [_j -13 MR. BECK: Mr. Lan'ders, a'11 of these are -- if you 14 haven't seen the comprehensive action list, are included 15 with a lot more detail as to precisely what the issues 16 are in that document. 17 Preservice and inservice inspection program, I'm 18 including it her? because it's an item that we must 19 satisfy. The satisfaction date must be six months prior 20 to the first refueling' outage when inservice inspection 21 activities take place. 22 Next slide, please. On confirmatory issues, where l 23 we have submitted materials and we're awaiting NRC p. 24 action. On the turbin driven auxiliary feed pump, those a j 25 are hot tests under hot conditions with clean steam. l GODFREY & AMES COURT REPORTING j Metro 469-6100, (817) 460-2048
39 1 They were performed in '83 and again in '84 We're-2 awaitin6 verification of those tests. Essentially an 3 examination by the resident inspector of the 4 documentation, which acccmpanied them. We expect 5 cicsure on that issue in the next SSER. It's basically 6 a records check. 7 Relief and safety valve testing provided a 8 submittal in '83. There will be a additional -- this 9 basically was -- rather was additional information on 10 industry safety and relief valve test programs. It was 11 supplied. Then we anticipate closure in the next SSER . 12 Environmental qualification, primarily directed in { 13 this instance to the mechanical equipment program, which 14 we have completed. We provided our last submittal on 15 that February 15th, and anticipate closure once again in 16 the next SSER , Natural circ testing, we provided a 17 commitment in January, and expect closure in the next 18 SSER on that issue. 19 Next slide. SER license conditions. For 20 completeness, the ultrasonic testing of the LP turbin, 21 we will be providing to staff in -- July 1, in a couple 22 of weeks. That is additional information in the way of 23 clarification to prior meetings that we have had to pr 24 discuss this particular issue.
- w. a 25 Environmental qualification appears again, and GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
40 1 primarily on this issue because action is required by 2 us. And this is directed in the electrical area. It's 3 a generic program tnat Westinghouse is performing, and 4 primarily involves pressure transmitters, the 5 pressurizer safety valve, and position indication. That. 6 ' program will be completed in November, and we'll meet 7 'our commitment on supplying the information to staff. 8 Pre-op testing. We will be providing to staff 9 prior to fuel load adequate documentation for any pre-op 10 test for which we will either seek wavers or deferrals 11 to after fuel load. I don't know precisely what that 12 list will consist of now. [j 13 The security plan, an item obviously of
, 14 importance. We have implemented it, and have in fact 15 modified it recently to provide more easy access for
~
16 construction activity in unit 1 as opposed to having the 17 full fledged implementation, and have been in 18 communication with Region 4 on that issue. 19 The next one. 20 MR. VOLLMER: John, before you leave that. Dick 21 Vollmer,.NRC. In the environmental qualifications, 22 since your category 1 plan, I assume these are tests 23 which will demonstrate a higher qualification for this 24 particular set of instruments, and some of the operating b 25 plans. Do you foresee any difficulty in this area or
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41 1 any other area in meeting environmental qualification , 2 requirements for Comanche Peak? 3 MR. BECK: I'm not aware of any. I'd like John 4 Marshall to say no also, which he just did. 5 MR. MARSHALL: No, we don't anticipate any problems 6 in this qualification program. The date shown there is 7 obviously the rule date. We expect to have the last 8 program finished mid-month, November. That's the'last 9 Westinghouse last testing program issue. And so the 10 outcome would depend on the results of those tests. 11 MR. MARSHALL: Y.es. By the way, it's the '74 12 program that we're qualifying these to, so it's -- [ 13 MR. EISENHUT: Yeah, in fact it's the higher level 14 standard here on their post operative plant. Just my 15 reaction would be -- well, having the test completion 15 16 days before the date to be in conformance is a pretty 17 tight squeeze, particularly. 18 MR. MARSHALL: It's approved by us. 19 MR. EISENHUT: Particularly if the test results are 20 not -- don't turn out as good as you would expect one. 21 When are the tests in itself going to be finished? 22 MR. MARSHALL: I don't know precisely. 23 MR. EISENHUT: Thank you. p 24 MR. SHAO: You have what are the -- no open issue V 25 on that? It's all done? GODFREY & AMES COURT REPORTING _. Metro 469.6100, (817) 460-2048
42 l 1 MR. MARSHALL: Yes. The team has been on site and 2 done the review. 3 MR. BECK: (To the Reporter) Did you catch that? 4 SER license conditions. With regard to the diesel 5 generators, as you well know, we have been participants, 6 and in fact a leader, in the diesel generator owners 7 group. I believe in fact there is a meeting taking 8 place in Bethesda today in that regard. We will 9 continue to follow all recommendations of that owner's 10 group, and we're.to the schedules that have been 11 provided by.the owners group to NRC. 12 Reg guide 1.97, we provided a submittal January (} j 13 28th of this year, with com'mitments for a back pit of 14 several post accident monitoring instruments before the 15 start of the second cycle. We're awaiting NRC action in 16 that respect. Next slide. 17 There are three areas where TUGC0 action is 18 required, and I include these for completeness. The 19 first, the licensed operator requirements at Comanche 20 Peak. As you know, we have committed to proceeding 21 experienced SRO 's in the control room for the first 22 cycle of operation. For the first year, excuse me, past 23 operations. That commitment is included here for g-- 24 completeness. 25 Mineral exploration control, there are some gas and GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
43 1 oil well activities. We have specific requirements with 2 regard to control of those insofar as the site is 3 concerned, and their~ site and instrumentation for 4 inadequate or cooling .s a licensed condition. We will 5 be satisfying.that during the first refueling outage. 6 SER open correspondence issues, TUGC0 action 7 required on purge and vent valve operability for 8 containment. That submittal will be coming September 9 30th. It is the same issue that has been classified as 10 an SER outstanding issue on containment purge valve, as 11 we indicated earlier. 12 Breaker news coordination study. We're due to { 13 provide you'a report July 1 as part of the safe shutdown i 14 issue. This will be more detailed documentation of the 15 electrical protection scheme in Comanche Peak. 16 Next slide. 17 MR. VOLLMER: This is a fire protection issue,
- 18 however, as opposed to the other, isn't it? Section --
19 MR. BECK: Yes, it is. 20 MR. NOONAN: John, you still have a number of fire 21 protection issues, don't you, besides this one? , 22 MR. BECK: I think right now our list is probably 23 shorter than yours, but we're in continue am -- r-] 24 continued dialogue on a couple of issues that I don't LJ 25 anticipate we'll have extreme difficulty satisfying. t GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
44 1 One of them has to do with NFPA-13 and sprinkler l t 2 placement in strict compliance or adherence, as opposed l 3 to the provision for_ alternate complete meeting. The 4 intent of and the discussion is the debate, is really 5 around that particular question. 6 We feel-that we have installed the sprinkler heads 7 in the area in question as an alternate to a strict 8 prescription of where they should be located with 9 respect to the ceiling, and used Btu content or 10 potential Stu generation as a guiding factor in where 11 these sprinkler heads are located. And there is some . 12 more reiteration required with a review in that respect [,j l'3 to satisfy it. I anticipate it will be satisfactorily 14 resolved. But the discussion is continuing. 15 Open correspondence issues. The SDPS optical 16 isolation. We have provided a submittal in January. 17 We're still discussing the contents of that, and it 18 falls under the same SER outstanding issues that I 19 indicated earlier. 20 Safe and alternate shutdown, May 21. We provided 21 additional requested information, and are looking for 22 resolution in a future SSER. Do not think there is an 23 issue outstanding. Simply a matter of completion. 24 The Salem /Atwas event, we provided a committal 25 only last week in that case. Once again, it's GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
45 1 clarification of previous discussions. 2 Turn now to engineering and construction items. 3 This is really a condensation, and I have used t h e -l a s t 4 commitment date on our part to cover a number of items 5 which may in fact be submitted earlier. You mentioned 6 appendix R. And in that particular case we have got 7 nine specific items. The latest date for any back pit 8 aspects are providing information to the staff by the 9 end of September. 10 In the EQ, area 7 items. Last submittal date is 11 one I alluded to earlier, November 15th, having to do 12 with the Westinghouse program. Ventilation system f{j 13 completion looking at October. That includes the 14 modification and retest, or retest of some modifications . 15 in the plant ventilation system. 16 We're providing further modification to the diesel 17 generator ereitation system that will be provided to 18 you later this month. We're modifying the MSIV bypass 19 valves, and that submittal will be provided to you. It
-20 says on Saturday. I doubt it. But tomorrow or Monday.
21 Hot shutdown can go on. All of these are covered, 22 as I said, in the CAL. If you see anything of specific 23 interest, please ask. 24 MR. VOLLMER: That's hot shutdown panel bolts and
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25 -- about the 386 fire protection panels. What are the GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
46 1 extents of those?. 2 MR. MARSHALL: John Marshall, Texas Utilities. Hot 3 shutdown panel bolts are interpanel connections that 4 have apparently some missing bolts. Whether they're 5 missing by design or missing because they weren't 6 installed by the vendor, we need to check that out and 7 determine the fact whether we need a modification or an 8 analysis. So it's a structural issue rather than 9 anything else. 10 MR. BECK: Yes. In the case of fire protection 11 . panels, this is an agreed upon date with staff to 12 provide factory mutual label for those panels. That [j] 13 certification process, if you will, by factory mutual, 14 is in progress. It will simply take that time to get 15 the stakers. 16 Significant deficiency analysis reports that we 17 have yet to submit are included on this next slide. 18 These have been identified as SDAR's to the NRC. Some 19 are part 21 and some are 5055-E's. These dates reflect 20 when we will be providing our response to starr. 21 MR. SHAO: Can you tell me something about the 22 active valves? What are the active valves? 23 MR. BECK: There are some valves where there's a 24 question in our -- there's a question on the table with L. 1 25 regard to the stress limits for those valves exceeding l GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048 .
47 1 normal limits in emergency conditions. It's a question 2 about specification and actual conditions. John, you 3 want to amplify it all? 4 HR. EISENHUT: I was going to ask the question -- 5 really is the question about the specification at this 6 point in time? I mean there's disconnect, as I 7 understand it. 8 MR. BECK: Yes, there is a disconnect between what 9 was specified and what was provided by the vendor. 1 10 MR. EISENHUT: No question about the specification 11 being correct?. 12 MR. BECK: That question is also on the table. uP 13 Both. [_ 14 MR. EISENHUT: So it's a two step process. 15 MR. SHAO: What does FSAR say? What does the -- 16 MR. BECK: The commitment in the FSAR -- the 17 disconnect occurs between the specification and the 18 FSAR commitment, in one or two cases. And there's also 19 a discorrect between what was provided by the vendor and 20 what was in the specification, in another case. Am I 21 correct there, John? 22 MR. MARSHALL: The specification and the FSAR are 23 essentially the same with respect to this particular rq 24 question. Disconnect appears to be between (_ J 25 specification and what was in fact delivered. The valve GODFREY & AMES COURT REPORTING Metro 469._6100, (817) 460-2048r..
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k s 48 1 -- in all cases are code valvss, to meet those 2 requirements. 3 MR. EISENHUT: How many' v'a1ves are we talking? Can l 4 you give me an index? 5 MR. MARSHALL: This is very new. I can't tell you 6 how cany valves. , 7 MR. SHAO: How many vendors involved? 8 MR. 30SNAK: John, this is Bob Bosnak, NRC. Our 9 bottom line here is operability, not necessarily stress So keep that in mind when'you go through this.
~
10 limit. t 11 MR. BECK: Yes, sir. 12 MR. EISENHUT: Yeah. Why is this not tied to a [] 13 CPRT issue? And as a matter of fact, this happened to
'14 be one of the issues I had.in mind when I'a$ked the 15 question a little earlier. I had two issues','I haven't 16 seen the other one come up, but this is one of them.
f 17 And if you don't know whether the question was,a
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18 ~ disconnect between the FSAR commitment and t'he ( ! 19 specification delivery that was provided t,o a' vendor, or 20 a problem between the specification and wdether or not 21 the vendor provided it. And the extent or duration of 22 the problem, I really don't see how yod can a^ddress the 23 issue withoutIpotentially tying it to CPRT. 24 MR. BECK: This is a case, Darrell, wh'ere I think
' 25 clearly, as John said, it's r4).atively new, c1'early this r
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49 1 is going have to be included in the bend for 2 consideration of generic implications by CPRT. 3 MR. SHAO: Do you know how many vendors involved in 4 this area? 5 MR. MARSHALL: No, I don't. 6 MR. SHAO: But so'far -- 7 MR. MARSHALL: It's more than one. 8 MR. SHAO: More than one? 9 MR. MARSHALL: Yes, sir. 10 MR. BECK: More than one and less than five, I 11 believe Larry, but that's preliminary. Fewer than 12 five. Your point's well taken, Darrell, and that -- one [_ 13 of the advantages I have got sitting in both chairs, is 14 that I can make darn certain that happens and the 15 attention is given. 16 MR. EISENHUT: Okay. Yeah, I think that's an area 17 we would want to be disc,ussing very early as you develop 18 the information on how many valves are involved, how 19 many vendors are involved, et cetera, because it has a 20 potential generic implication even beyond Comanche 21 Peak. If in fact you delivered a specification to the 22 vendor and the vendor delivers a product that is 23 different than specification. So we would like to look p 24 into that one very promptly. (.J 25 MR. BECK: At the same time I want to keep Mr. GODFREY & AMES COURT REPORTING
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50 1 Bosnak's thought in mind too, as far as operability, 2 there's no question in that respect. 3 John, the next slide on inspection reports. This 4 provides a -- touched on, on those issues where we need 5 to provide information back. There are socie procedural 6 deficiencies that are being cleaned up and we will have 7 that done by August 1. Fire protection items that 8 resulted from region -- resulting from the Region 4 9 walkdown will be provided by October first. 10 A security communications system, we have upgraded 11 that system. One of the items required was an FCC 12 license for a more powerful transmiter that we (j 13 anticipate receiving the end of July, 14 Permanent security locks, we'll have in place prior 15 to fuel load. Solid cad waste system, we're going to
, 16 have skid mounted systems at the site. They will be 17 arriving after fuel load. The system we have installed 18 right now is inadequate o- judged to be such, by us.
19 Fire alarm panels fir t i rvroeling. 20 Pre-op tests on che next slide. Touches on l 21 ventilation system tests, I believe that Mr. Landers I 22 referred to. We're looking to have those completed by 23 October 1 this year. y 24 Diesel generator load test is yet to be scheduled, L. _ 25 and I'm talking about a load test at the higher output GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
51 1 rating for which we have a request in front of the 2 staff. The other items are self explanatory, if you 3 have no questions. 4 MR. EISENHUT: The question that is before the 5 staff is to go to a higher load rating on the diesel? 6 MR. BECK: From 5800 approximately to 7,000 which 7 is the rated capacity of the units. 8 MR. EISENHUT: All right. 9 MR. BECK: Yes. 10 MR. MARINOS: Angelos Marinos, NRC. Do you 10 to a 11 7 test load level on the diesel? 12 MR. BECK: No. And it's not a requirement as I (_j 13 understand it of the program. 14 MR. EISENHUT: Angelos, you know a lot about this 15 TDR unit than I do, however this type or class of 16 diesel, this model had been tested to the 10 to the 7, 17 already? 18 MR. BECK: I can't speak directly to that, Darrell. 19 The first one is the vintage. 20 MR. MARINOS: I am not certain if the load capacity 21 is the same. That's why I have to checked that out. 22 MR. BECK: We can clarify that. 23 MR. EISENHUT: I think the requirement, the first 24 of a kind model had a spec rating, back multiple J 25 rating. I think was the test. GODFREY & AMES COURT REPORTING
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52 1 MR. MARINOS: 16 cylinder diesels? 2 MR. BECK: Yes. 3 MR. MARINOS: Okay. I think the model had them, 4 HR. EISENHUT: Good. 5 MR. BECK: Technical specifications, we provided 6 our final draft response to staff in November. The 7 staff has issued the final draft specs. There are some 8 questions that have been asked by the reactor systems 9 branch, some additional questions, we responded as 10 indicated in April, and we'll propose some additional 11 changes in the near future. Obviously, we'll have to 12 certify those tech specs as a final step required by [_j 13 staff, our responsibility. 14 Miscellaneous activities on the next slide, I have 15 got environmental protection plan, which the NRC is to 16 issue. I'm not aware of any outstanding issues in that 17 regard. The draft plan has been agreed on. Our 18 emergency plan implementation has been approved. We 19 have exercised it twice. It can be implemented 20 immediately, when necessary. 21 If there are no questions further in the -- 22 MR. EISENHUT: There's one. On the last item, do 23 you have a full FEMA signoff. p 24 MR. BECK: Yes. k_ 25 MR. EISENHUT: Okay. . i GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
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53 1 MR. BECK: I'd like to go now to the CPRT 2 organization. This first slide is -- I'm putting up for 3 historical prospective, and I'd like to speak to the 4 evolution of our response, which as you know was 5 originally structured to respond to TRT issues in 6 accordance with the initial letter in September of 7 1984. This is really a second set. 8 Our initial response included, as review team 9 leaders, and I'll go into more detail as to who these 10 gentlemen are and what we're expecting of them, but the 11 initial response included, as review team leaders those 12 people in our organization who are most familiar with (_ 13 the issues involved. 14 We fell short, quite frankly, in retrospect of an 15 objectivity goal in that regard. And that's why we made 16 the change we did and went to outside, previously 17 uninvolved, third party people to serve as the review 18 team leaders. And we also modified at that time the 19 SRT membership to include outside, previously 20 uninvolved, experts. 21 And, Larry, right now, I'd like to touch on your t 22 previous question about the absence in that august body 23 of someone with experience in mechanical systems area. i i 24 We have not tried to populate the SRT with experts , k..J 25 in all the disciplines that are involved in a nuclear GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
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54 1 power facility. It would end up being a rather large 2 body of people, should we do so. 3 At the same time I'm sensitive to the concentration 4 that we have, as far as issues and concerns, in the 5 mechanical systems area. And there are two ways we have 6 dealt with that. 7 The first is to have consultants to the SRT wh'o 8 have expertise specifically in the area you're talking 9 about. And Mr. Rodevall, for example. And the 10 second, is to have actively involved in the process, 11 other people with expertise in that regard. 12 And then, specifically, I'm talking about Dr. Bob (} 13 Cloud, right now. Doctcr Cloud is working, if I may, on 14 the project side of the house, but within our concept of 15 CPRT, he's available to *is any time we need to consult 16 with him, or talk to him, or any time he wants to come 17 to the SRT. 18 So the fact that he's not included as a previously 19 uninvolved third party, although he essentially is, his 20 efforts are focused more on the project side, but in no 21 way, is he's isolated or unavailable, or his advice l 22 stifled, or whatever. I 23 So we have got that input. And as you will be p-- 24 hearing a lot more tomorrow, we have also, recently, k_ 25 contracted with Stone and Webster Engineering GODFREY & AMES COURT REPORTING Metro 469-6100, (817_) 460.2048
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55 i 1 Corporation, once again on the projects side. But 2 there's an eminent working relationship between the 3 SRT as far as the Cocanche Peak response team effort and 4 these experts that are available to us. 5 So I don't think we're missing the input or the i
- 6. Judgmental factors, or the ability to do an overview 7 because of the fact that there isn't somebody actually 8 on the body as an expert in that particular area.
I 9 MR. SHAO: This is just a comment. If you have a 10 lot of problem in that area, and you have a special team 11 to oversite all the problems, always a good idea to 12 expert team in that particular area, otherwise, might be ({, 13 oversight,'other people's work. 14 MR. EISENHUT: Yeah, I think Larry's question was 15 not aimed towards the group that we thought ought to be 16 populated with people from all the disciplines. It was 17 really though, the senior review team, wi'11 make the 18 management review calls, so to speak. 19 At least, perhaps the principal area of issues 20 probably should be represented on the SRT. And granted, 21 it's in retrospect, because we have all evolved. You 22 did structure the SRT to respond to the September, 1974 23 letter, and I think things have evolved since then, ii 24 So I think this is a comment we're giving you as we (J
~25 see things evolving. That's certainly an area which GODFREY & AMES COURT REPORTING Metro 469 .6100, (817) 460-2048
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56 1 will want to continue to explore with you. 2 Granted you have Mr. Rodevall, Mr. Cloud, both have 3 do a very high capability and credentials, and we have 4 no other reservations other than they are are a 5 consultant available on call.to the SRT. They're not 6 the principal, responsible person, who is going to have 7 to make that decisio'n later on down the road. 8 MR. BECK: I think another -- I appreciate the 9 comment and input. . s.nother consideration from a 10 practical viewpoint. SRT, while we're recommending and 11 providing guidance to review team leaders, serving in 12 that capacity, developing the programs, all of which [j 13 you're going to hear much more about this afternoon, the 14 QA/QC area and design adequacy tomorrow, serves as an 15 advisor in the end to Mr. Counsil. Mr. Counsil's 16 receptivity to that counsel and advice has been 17 uniform. In fact he has had a few suggestions of his 18 own, surprisingly enough as time has gone by. But I'm 19 sensitive to it. I understand your concern. We'll keep 20 visiting that issue. 21 MR. NOONAN: John, I'm not going to try to belabor 22 it. But I do want to point out to you that as the
'23 program plan is being developed here, the details will 24 be developed, we will probably be talking to these 25 people from the CPRT .
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57 1 At that time, for example, if I was going to be 2 talking to Mr. Jones, I'm. going to ask you provide 3 somebody from the SRT to be involved in those particular 4 meetings. And I think that's what Larry is looking at. 5 In-the civil structural area, we don't see anybody 6 up there to call in, so to speak, to sit with Howard 7 when'we're talking to him. 8 MR. BECK: I'm sure when we get to civil structural 9 area in that regard, I'll be there, number one. I would 10 like to participate in a lot of those meetings. Bill 11 Counsil I'm sure would be.lookin'g forward to' sitting in 12 as well, specifically in that area. [] 13 Back to the historical evolution, if I may, for a 14 few minutes. As our responses evolved over the last few 15 months,.we found a number'of shifts in direction as we 16 have learned more, as the SSER 's have come out, as we 17 have conti'nued to dialogue on occasion with NRC staff 18 reviewers, it has obviously caused us to exhibit the 19 living nature of this process. 20 It is not a static one. There.~are not -- there's 21 no one on this -- on the face of this earth who can sit 22 and look with a cressient clear vision down the 23 stream, and identify all the issues that need to be p-- 24 addressed clearly. (_ ; 25 We have in place, however, an organization that has GODFREY & AMES COURT REPORTING
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58 1 the capacity technically, and has the objectivity to 2 deal with those isspes. And they are doing so. 3 There are two aspects to our response, however, I 4 want to emphasize. One, are the issues specific plans 5 that have been covered in subsequent -- previous detail, 6 ir. detail in previous meetings. 7 Those issues are not, however, the principal source 8 of what we want to talk about this afternoon and 9 tomorrow. .May I have the next slide? 10 The issues that are of prime importance that we 11 want to cover today and tomorrow are in what I would 12 call the self-initiated category. And by l- 13 self-initiated, I mean it's a response in our part in an 14 overview context to what we might characterize as 15 prelimina'y r root cause evaluations. What we might 16 characterize as an extension of generic implications. 17 And it clearly has led us to two areas. The.first 18 is design adequacy. Is the design at Comanche Peak 19 adequate? And the second is quality of construction and 20 the.QA/QC adequacy question. I'll be introducing Mr. 21 John Hansel a little later, and he will be covering 22 today the quality of construction and QA/QC adequacy 23 self-initiated action plan. Mr. Levin and some of his
- p. 24 colleagues tomorrow will cover design adequacy.
L.- 25 Next slide. With regard to specific CPRT issues, GODFREY & AMES COURT REPORTING
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59 1 I'd like to go to the next slide on the charter. Our
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2 charter is to develop and implement a comprehensive 3 review program which will address potential safety 4 concerns related to the design and construction of 5 Comanche Peak. units 1 and 2. It's straightforward. And 6 I emphasize the comprehensive aspect. 7 There are a number of issues and there are a number 8 of sources. I'd like to cover some of those right now. 9 The NRC technical review team obviously was the initial 10 driving force to develop this response. But it 11 certainly was not the only one that is serving as a 12 source-or issues for consideration. () 13 The CYGNA Independent assessment program has turned 14 up a number of questions that fall within the
' 15 CPRT category. The atomic safety.and licensing board 16 proceedings, and issues that have been raised by the 17 inter'venors will be covered in entirety with a 18 CPRT effort.
19 Other-NRC activities are serving as sources of 20 input such as SIT, CAT, Region 4 reports, and last and 21 certainly not least, the self-initiated actions that you 22 will be hearing more about today, providing that 23 comprehensive overview. 1 prq 24 MR. EISENHUT: Let me ask you a question, if I I (_J 25 could. I'm not sure I can make it an intelligent GODFREY & AMES COURT REPORTING
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60 1 question, but-let me try. These are sources of issues 2 in that the TRT and CYGNA, et cetera down the line, 3 right through fourth bullet, concluding with Region 4, 4 found some good things and some bad things. They found 5 some places there were not problems. They- found places 6 there were problems. And from that you can develop a 7 spectrum of goodness or feeling of confidence or lack of 8 confidence. 9 The overall program you develop.must be able to 10 say that we have confidence in the construction. We 11 have confidence in the design, et cetera. 12 To what degree.are you therefore taking credit or
'( ] 13 consideration for previous work where the NRC found a 14 good thing or a bad thing? To what degree are you 15 factoring that in? That is, are you looking at the 16 profile from these documents which are by and large not real'y, 1 as you said, TUGC0 originated documents?
17 They 18 came from an external source, external stimulus, so to 19 speak. 20 To what degree are you relying upon those to index > 21 your program and develop what kind of program you're 22 going to develop, versus saying that those are clearly 23 indicators of spot checks and spot areas? And that what 24 you're going to do is take a broad look and say, "I must 25 develop a program that gives me overall confidence. GODFREY & AMES COURT REPORTING
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61 1 And, oh, by the way, while I'm going along, it also must 2 include those kinds of issues." 3 Which philosophical approach are you going to try 4 to address it? 5 MR. BECK- Our philosophical approach is very 6 clear. And that is to get our arms around Comanche 7 Peak, from a design and construction standpoint. Any 8 one of these sources is insufficient. All of these 9 sources by themselves, in our view, are insufficient to 10 that task. 11 And that's why we have taken the next step, to go 12 must have further than that, and to -- to make sure that (g 13 the conclusions that we're going to draw, namely that 14 reasonable assurance with regard to Comanche Peak, are 15 indeed conclusions that we can extrapolate to the entire 16 facility. 17 You're going to hear a lot more today and tomorrow 18 about why we feel as confident as we do that that 19 program is all encompassing. And that we in fact do 20 have our arms around the issues and the problems. We 21 cannot ignore the good or the bad that's included in any 22 of these sources, and we're not. We're going to be 23 relying on both sides of the fence in that respect. 24 MR. EISENHUT: Yeah. My question wasn't so much 25 ignoring as much as how you factor it in. And let me , GODFREY & AMES COUF.T REPORTING i-Metro 469-6100, (8*7) 460-2048
62 1 give you a specific. Let me give you a hypothetical. 2 Sup* pose the TRT found -- reviewed an area, did an audit 3 review, and found generally no problems. 4 Similarly, Region 4 could have done an inspection 5 in an area'and found no problems, or the CAT team. How 6 would you approach an area where we, based on our 7 limited audit, found no problems? 8 HR. BECK: Let me pick one that pops into my mind. 9 And you will be hear.ing more about it tomorrow. And I 10 think it will be illustrated in more detail than I'm 11 able to give you right now. 12 And that's electrical area. It's one where there's ( 13 been what I characterize as perhaps a light touch by a 14 number of people. I'm not aware, other than some 15 initial TRT findings in butt splice area, for example. 16 And in some termination questions of any serious design 17 questions, as far as electrical is concerned. But 18 there's enough there, for example, to raise an issue. 19 Number two, there has not been an intensive look 20 that I'm aware of. 21 So, number three, we're going to cover that 22 comprehensively so that there's not any question
- 23 outstanding with regard to that particular design 24 discipline.
Cv-J 25 So that's a case where there's not an awful lot of GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-.2048
1 1 63 l 1 smoke. But we want to be darned certain there are no ' 2 remaining issues. And tomorrow we'll hear a lot more. 3 MR. CARV0: Jose Carvo, for the NRC. You're 4 right. Our focus was more in trying to embrace the 5 allegation, the concerns about the allegation. 6 But keep in mind that the QA/QC SER also raised 7 some questions that is touching all the disciplines, 8 including the electrical. 9 So whatever limited look we had at the time, now 10 the QA/QC is covering, you have to take another look, 11 because they have got some problems that are in here 12 that not only affect the electrical, mechanical, and so [J 13 forth. 14 So that kind of a look, you have got to be 15 factoring to your program, so, again, you can put your 16 arms around it. Otherwise it will do no fair to the 17 electrical -- in terms of the mechanical. 18 MR. EISENHUT: Yeah. Let me follow that. The 19 electrical happens to be an area where we have some 20 concern, because we did only perform a limited look. So 21 within the limited look, we did find some problems. We 22 want to be sure that when you develop this program, you 23 don't go off principally addressing the narrow specific p-- 24 issue that we found in that review. (;- 25 MR. MARINOS: Which are mainly constructed related, GODFREY & AMES COURT REPORTING Met , . . _ 469..
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L j 64 1 if I may add. > - -- 2 MR. BECK: That's correct. 3 MR. EISENHUT: That's correct. Which were ; 4 principally construction related. And we want to be f5 sure that you.put enough qualified people, enough heart 6 to heart power, with a broad enough program, i 7 programmatic look, to be able to say that, 8 notwithstanding the fact that the NRC didn't turn up big . 9 problems, or CYGNA didn't turn up big problems, or that l 10 other activities didn't turn up big problems, I don't 11 want to take too much confidence in that. Because we'
- 12 didn't really look that hard in those areas.
1 (] 13 We war.t to make sure, at least not as hard, but 14 there weren't as many concerns that we followed up on in 15 some degree. We want to make sure that you develop a
- 16 broad enough program to come back and say that you have 17 high confidence. Things are all right in the area,
)' 18 electrical and construction and design. So that when we ; 19 audit you, I want to put these guys out of work. I want ! 20 to make it a low likelihood of finding any significant ! 21 issues. 22 MR. BECK: Point very well taken. And I hope at 23 the end of this two days, you will agree with me that we 7- 24 .have anticipated that question in developing our
- I u-25 program. We have -- that's the crux of the issue, as a i
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65 1 matter of fact, Darrell. 2 MR. EISENHUT: Two other thoughts that I had. 3 number one, when you started, you have -- you had an 4 ororganizational chart. You said you laid out the 5 organization and the program principally around the 6 September '84 letter. 7 MR. BECK: Yes. 8 MR. EISENHUT: Do you see any major changes that 9 you're going along now, looking at the detailed SER 's, 10 which, as Jose Calvo pointed out, the QA/QC SSER in fact 11 includes quite a number of electrical areas or 12 complications or concerns? Are you going back and [ 13 relooking at your program, factoring those in? 14 MR. BECK: There are two parts,. Darrell. We're 15 going to respond to every single issues that was raised 16 by TRT. That's one set. 17 The other set, and quite frankly, the bigger 18 program clearly is going to be the self-initiated 19 activities in construction adequacy, QA/QC, and the 20 design adequacy question. 21 And we're not ignoring the specific questions. All 22 of those have to be addressed and put to bed. We're j 23 going to do that. But that's far from enough to satisfy l ! 24 us that we have answered that question, and be able to l 25 have that reasonable assurance required in our minds, as t GODFREY & AMES COURT REPORTING p .. . . . . . . -.._.-.;...... . , . Metro 469..6100.. (817) 460.2048
re r,- 66 1 well as'yours. 2 MR. EISENHUT: Is this the time for you to also say 3 something about how.you're going to factor the CYGNA 4 effort into your program? Or are you -- are you going 5 to factor it in? Or how you're goins to consider it? 6 MR. BECK: Yes. Howard will be talking further to 7 unat tomorrow. .I can say right now that the CYGNA 8 effort is serving on the one hand as a source of input 9 for issues. 10 On the other hand, in that context, our program is 11 going to be responsive to every issue that's been raised 12 by CYGNA. I anticipate when we have issued our program (([ 13 plan,;and the issues specific actions plans, that we're 14 also going to be providing -- I don't anticipate it. 15 We're going to do it. Provide CYGNA'with a' road map
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16 that shows them where w1 thin this overall program the 17 combination of issues specific action plans, all the 18 issues that they have raised have been covered. 19 I anticipate meetings with CYGNA to discuss our 20 review of where we think it's covered to make sure that 21 there's resolution.
*22 MR. EISENHUT: Let me --
23 MR. BECK: Staff, I'm sure, will be present at that y,- 24 session.
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67 1 I'm trying to explore how you see the CYGNA effort 2 continuing. CYGNA presently has phases one through 3 four. Do you see it then, from a conceptual standpoint, 4 that at the end of the phase four, the work trunkates? 5 And that any generic implication, any follow-up, any 6 issues, are already addressed in your overall program? 7 So that at the end of phase 4, it's in essence drawing 8 to a close? 9 MR. SECK: That's our anticipation, that we will 10 cover any outstanding issues that CYGNA has on the 11 table, at the end of their fourth phase, within the* 12 CPRT umbrella. And that they will agree with us if that [_ 13 happens. 14 .M R . EISENHUT: And plus any generic expansion 15 follow up activities'will have already been included in 16 your broader program. 17 MR. BECK: That's correct. 18 MR. SHAO: Is CYGNA going to give you all the root 19 causes of these problems, and you can follow later? 20 MR. BECK: Their phase four report I'm sure will 21 include some observations in that regard. Specifically 22 whether or not they will within the scope that's 23 assigned to them, be able to make a comprehensive
--- 24 resolution, I frankly doubt.
_] 25 CPRT will certainly do that. These -- any of the GODFREY & AMES COURT REPORTING Metro 469-6100, (8,17) 460-2048
68 1 issues that they have raised with our root cause 2 evaluation and generic implication program, which you're 3 going to hear a lot more about today and tomorrow. So > 4 the issue clearly is going to be covered. 5 MR. NOONAN: Are you going to discuss that 6 tomorrow? The CYGNA work tomorrow. 7 MR.. BECK: Yes. Not in detail,.Vince. But we will 8 be covering that particular aspects, that input, that 9 source. And how we're going to handle it. 10 MR. NOONAN: For example, like CYGNA found a number 11 of problems in the piping support area. You're going to 12 say how you plan to treat that in -- to overall
' _j 13 piping -- piping and pipe supports at the plint?
. 14 HR. BECK: We'll tell you tomorrow the 15 metho'dologies the details of how we treated our subject 16 for detailed meters later on.
17 MR. SHAO: What I would like to hear is, normally 18 how do you fix a piping problem, how do you fix the 19 bolt? How do you implement the whole plan? 20 MR. BECK: What does it mean in totality? 21 I have been to1d that there are those anxious -- 22 THE REPORTER: Excuse me. 23 MR. BECK: This is a good time. We'll take a - l 24 break. - F-- i L-l 25 (Whereupon there was a recess.) i GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048 ,,, ,,, _ _ ,,
r 69 1 MR. BECK: I'd like to get restarted again, and 2 focus on CPRT objectives. This is a summary slide that 3 really covers the essence of what appeared in the draft 4 program plan, and what will be covered in more detail in ! 5 our submittal.later this month, of the entire program 6 plan, complete with all the issues, specific action 7 plans. 8 But I think this is the essence of the effort. And 9 that's first to identify the root cause, and evaluate j 10 any generic implication of confirmed deficiencies. i 11 MR. LANDERS: Excuse me, John. Don Landers. Could
- 12 I go back'to sources of issues, and'the point that
( 13 Darrell brought up earlier, that I'm still concerned 14 about, and still having difficulty seeing the interface,
; 15 and that is the comprehensive action list and some 16 issues on that some people feel may be CPRT issues. And 17 wondering how your organization has a control interface
- 18 there, to make sure that comprehensive action list items
- 19 are in fact moved over to CPRT if they demonstrate they 20 have the some kind of root cause or generic concerns.
i 21 MR. SECK: Don, that primary responsibility lies l 22 with me as manager of licensing and as chairman of the 23 SRT. And that's been the exercise, or the way it's been 24 accomplished. I'm aware of all the issues on both sides 25 of the fence. ^ GODFREY & AMES COURT REPORTING Metro 469-6100, (8.17..) . ., s 4 6 0 .2 0_4,8.. , , ,. .. g ..,,.. ..... ..
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70 1 Formerly, as I indicated, we have had some Region 4 2 inspection reports that have been responded to partially. 3 by indicating that CPRT would be covering those issues. 4 So that has really come through the licensing arm, but 5 has been transferred over partially to CPRT, and that is 6 documented. 7 In other cases, it's been simply a fact that we 8 have periodically discussed issues that have gone on in 9 the non-CPRT area in SRT meetings to make sure that we 10 have got a cross tie. And that it's a well lubricated 11 one. And that we're not missing anything, and nothing's 12 dropping through the crack. r u- 13 It's par 6icularly important, I'm sure you recognize 14 in those areas, where we're doing root cause evaluation, 15 and the generic implication of all activities that we're 16 coming to focus on, that it be done. 17 The heavy load in that regard, if I can use the 18 term, is going to occur later in the program, when we 19 have finished a lot of these issues specific action 20 plans, and actually get to the generic implications of 21 these. 22 MR. LANDERS: But your program plan will show that
- 23 link? -
i 24 MR. BECK: It certainly will. l 25 MS. BLACK: John, I have a question regarding these ! GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
p j, 71 1 issues also. It seems to me'that want to take into 2 consideration of your findings to SAFE team to review
. allegations into your program. And I don't see that one l-4 of the sources of issues in here.
5 MR. BECK: As an issue, specific item, it isn't 6 there. But I assure you that anything that comes out of 7 the SAFE team activitiy in the way of findings will be 8 looked at by CPRT, as far as its applicability is 9 concerned. It's a good point. I didn't include it as a 10 source, but it is. That was an oversight. 11 MR. COUNSIL: That is an oversight. Because the 12 corporate general council does in fact review. L
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[_ _ 13 MR. BECK: Yes. Right. 14 MR. COUNSIL: For the record. 15 MR. BECK: I appreciate that. We'll clarify that 16 in any future pieces. 17 MR. BECK: Back to the objectives list. The second 18 bullet is to define actions to preclude similar 19 occurrences in the future. We're interested just as 20 much in the future as we are in a careful and thorough 21 examination of the past. In fact, even more so. Those l 22 past efforts must form part of the basis for our future 23 activities.
.; 24 We want to evaluate collective significance of
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72 1 assure that they have -- these concerns have been 2 sufficiently addressed. 3 Collective significance is a very carefully chosen-4 word, because there may well be in many instances 5 interactions between findings. And the significance of 6 individual issues could be in fact dwarfed by the 7 collective aspect of that. And we want to be sure we 8 don't miss the boat in that regard. 9 And finally we want to provide reasonable 10 assurance that Comanche Peak can be operated without 11 undue re'st to the public health and safety. That's the 12 bottom line of the entire program. [ 13 MR. MILHOAN: Jim Milhoan, NRC staff. Your first 14 three bullets seem to -- they all previously -- on 15 previously identified issues, is receive CPRT objectives 16 also concerning additional reviews. For example, in the 17 design adequacy area? 18 MR. SECK: That is part and parcel of the entire 19 process. Collective significance, for example, cannot 20 be evaluated until the entire program has been 21 exercised. And I didn't mean in any way to isolate past 22 occurrences with our future activities, and what those 23 findings may be. It's part and parcel of the whole. 24 All of it will be considered. 25 MR. MILHOAN: Later in the day and tomorrow we'll GODFREY & AMES COURT REPORTING M*tyo 469 f1,00, (817) 460-2048
I I 'l 73 1 hear about the design adequacy program? l - 2 MR. BECK: You will hear a lot more. And you will l ; 3 hear specifically about methodology and how we're going , 4 to assure that those things happen, not only design 5 adequacy, but.in the quality assurance and in the 1 l 6 construction adequacy areas with Mr. Hansel later 7 today. 8 I think it's important to touch briefly on the i
~9 objectives of our effort. When we set up the 10 CPRT program, consisting of the senior review team and 11 the review team leaders, we set some very high standards 12 with regard to the knowledge and ex'perience of the
[_ 13 personnel who were going to be involved. 14 And I think we have met those standards in every 15 respect with regard to not only personnel, but the 16 organizational integrity of various groups that are , 17 associated with the effort. And one of the key , i 18 touchstones in that regard was a requirement that there 19 be no previous involvement in Comanche Peak activities t l , 20 in question by those who are in the process of -- or in 21 the review process. 22 We have in fact required people involved in the 23 program to sign and go through an objectivity analysis, ; 24 if you will, to make sure that that's the case. And we [ l ~ l 25 have accomplished that. There's more in the program l l GODFREY & AMES COURT REPORTING
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74 1 plan in that regard. Jose? -- 2 MR. CALV0: I'm still having trouble.with the 3 senior review team and the -- it looks to me like if you 4 see a review team doesn't have that expertise and 5 knowledge of what 'is going down at the team level, I 6 think it -- we're going to be doing a lot of work. 7 And the flRC is going to become the senior review 8 team, kind of finding out where that -- whether that 9 kind of logic goes back to the senior review team. It 10 looks to me like you need somebody there that has an 11 understanding of what is going on in those disciplines 12 to appreciate how those -- and specifically as plans are [ 13 set down, and also how the work is being accomplished. 14 I'm having that kind of a trouble. I don't see 15 that kind of -- that kind of direction coming down. I 16 can see from a standpoint of preparation and guidance. 17 But I want to get the specific plans of trying to 18 resolve these issues. I don't see-how the senior review 19 team can in any way look like you're doing a good job, 20 or look like you're on the wrong kind of direction. 21 So I'm having some kind of a problem in the 22 structure that you have today to portray that kind of 23 device to the team leaders. 24 HR. BECK: Let me characterize. This really is 25 kind of a philosophical question. I think there is a GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048 . . . . . . . , . .
r 75 1 specific content in your question that is very 2 important. 3 And that is, do we have the expertise directed l 4 toward the problem in the program? Clearly we're l 5 looking at the review team *1eader for that first level l 6 of experience and expertise in that discipline they're 7 responsible for. 8 In some cases, we have got that reflected on SRT 9 by review of specific individuals' experience or 10 . combination of experiences at the Board of Directors, if 11 I will. But not in all cases, as I said earlier. 12 We're sensitive to that fact, and we have drawn
'13 people in from the outside in a consulting role where we 14 feel that we're missing, in fact at the senior review 15 team level, a required degree of specific disciplinary 16 expertise and experience.
17 Our entire program -- let me finish, is a living 18 program. One that has purposefully been structured in a 19 flexible fashion, because we don't know for sure whether 20 we're going to have to have further emphasis in the 21 future. 22 MR. BOSNAK: John, if I can interrupt for a 23 minute. When you saw you're going to draw in your l l 24 consultants, and I heard you mention Bob Cloud and l ~ l 25 others in the area that we're most concerned about. And GODFREY & AMES COURT REPORTING
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76 1 that's the pipe and pipe supoort area. 2 How are they going to function? Since they are not 3 in the line, how are you going to accept theihadviceor 4 reject their advice, and how wi.ll'we in the NRC know 5 what's going on? - 6 MR. BECK: What's go[nB on with regard to what the 7 SRT discussed or considered?' ' 8 HR..BOSNAK: The interaction between your 9 consultants and your SRT , just how deeply. involved they 10 get. They are, if you will, they're letters of 11 author 12ation, what they can do and whdt they can't do. 12 MR. BECK: Sure. Okay. Two things. One, all of l~ 13 our records are opsn for audit and inspection. All the t__ 14 minutes of meetings that we have held, all contractual
' 15 relationships, it's,available for staff to look at. So
/
16 the working relationchip is defined in those documents.
)
17 And they're availabic, too., 18 Secondly, Irthink most~1hportantly, thd specific 19 action plans that reflect what people's responsibilities 20 are or going to be -- will be and are, that you haven't 21 seen yet, very clear who has what responp4.bility. 22 And let me illustrate what's going on in the piping 23 system and pipe support area. I'll steal a little bit y--] ' 24 / of the thunder from tomorr,ow to do this, but I think LJ ' 25 it's important to illustrate or focus on your concern. J GODFREY & AMES COURT REPORTING Hetro
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77 1 We have made a decision to bring Stone and Webster 2 Engineering Corporation in to do a substantial 3 reanalysis in the piping system and support area. 4 They're going to have this responsibility in 5 conjunction with our architect engineer of record, Gibbs 6 & Hill. They will be redoing 100 percent of all large 7 bore piping and supports. That reanalysis effort is
. 8 going to be done with the constant attention and focus 9 of Doctor Cloud and his organization, as a double check.
10 The SRT will be hearing directly and frequently as 11 to how that program, one, is going to be fully flushed 12 out. And Mr. Siskin from Stone and Webster will speak (, 13 tomorrow as to the details of that, or some of that, an 14 overview. 15 Mr. Counsil, for example, will be briefed on a 16 bi-weekly basis as to how that program is proceeding, 17 and what the results are. 18 MR. EISENHUT: Let me ask you a question. 19 MR. BECK: Mr. Siskin in that capacity with Stone 20 and Webster will report directly to Mr. Counsil. 21 MR. EISENHUT: That's the question I was going to 22 ask. Because I didn't understand -- when you laid out 23 that organization, you got a Comanche Peak response 24 team. You got a program laid out wd.th the different Lr-. 25 disciplines and areas. GODFREY & AMES COURT REPORTING
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78 1 And now, somewhat external of the senior review 2 team, external of this program that's looking at this 3 response, you have got another entity, reanalyzing all 4 lower bores piping supports. 5 How does.it interact? And I guess we just -- it's 6 a piece we just haven't seen how it interacts with 7 what's being done on the response team, and how do you 8 insure that not just the findings, so to speak, but the 9 real feelings, understanding, knowledge, that would be 10 done by this Stone and Webster review team, gets 11 factored together in-this team coming up with its 12 overall conclusions, root causes, follow-up, et cetera. x'_. 13 MR. BECK: Mr. Levin will cover in detail that 14 specific relationship tomorrow. I'll touch on it for a 15 brier minute here. But you will hear a lot more from 16 him on that subject. 17 He is charged with the responsibility on the third 18 party side of the fence, to be intimately involved and 19 satisfied that, A , all concerns that have been raised, 20 whatever their source, whether they will SALB or TRT or 21 whatever, in this specific area, are resolved and put to [ 22 bed, number one. I' 23 Number two, and perhaps more importantly from the 24 CPRT side of the fence, he is going to be looking at all 25 generic implications to assure ourselves that once we GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460 ,2048
79 1 resolve all issues in that specific disciplinary area, 2 that there isn't any transfer beyond that specific 3 discipline. 4 Or if there is, we understand it, we recognize it, 5 and we pursue it to whatever end conclusion it has to be 6 pursued. Now that's a general explanation of how that 7 interface is going to work. But it's a very important
~8 one that I agree we need to understand. And we'll spend 9 hours tomorrow, I'm sure, making sure that we do.
10 MR. EISENHUT: Let me ask a question then on a 11 little bit more conceptual level. When you approach 't 12 this kind of problem, and in effect you're saying that, (}, 13 as a management decision, you have decided that the 14 senior review team and its arms underneath it, really, 15 when a problem gets as big as -- look at it that way. 16 MR. BECK: Reanalyzing. l L 17 MR. EISENHUT: Or maybe not a problem gets so big, 18 as much as the solution to bound the problem, or the 19 response to the problem, or the approach taken by 20 management, gets so big that it becomes a very large 21 effort, let's say. 22 You have, from a management standpoint, two 23 choices. You could put that entire effort under the cq 24 arms of the SRT or the -- under the Levins of the world, b 25 or whoever they would be in the various areas, and make GODFREY & AMES COURT-REPORTING
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80 1 them a -- the line function, so to speak, carrying out 2 the redesign or re-evaluation, or whatever it is. 3 Or you could put them, when it's a larg'. separate 4 major entity on the side, and put the SRT and its arms 5 in a mode of overseeing to insure that all of those 6 pieces get factored and integrated together, so they 7 sort of have a dotted line, so to speak, on an 8 organizational chart of monitoring all the pieces. And 9 if it's -- what I understand you're saying, you have 10 chosen this kind of option? 11 MR. BECK: In this specific case, yes. 12 MR. EISENHUT: Good. Because now my next case was 13 going to be, suppose, for example, as you go through the- [ 14 electrical area, we -- issues start coming up bigger and 15 bigger in the electrical area. I would take it then. 16 that if you decided on a major effort, had to be 17 undertaken to oversee audit reject, a lot of electrical 18 work splices, loadings, a number of different things. 19 And you set up an over the -- a large effort, let's 20 say. The same kind of logic would say that you want to 21 keep the SRT in on overseeing role than a line functions 22 role. 23 MR. SECK: Exactly. 24 MR. EISENHUT: I think I understand the logic. 25 MR. BECK: In that specific case, it hasn't come to GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
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81 1 the point where a decision has been made to how large i
'- - 2 the magnitude of the effort has been made. You will 3 hear more from Martin Jones tomorrow wnat we're 4 proposing to do, and what we think at this stage is 5 going to be satisfactory if we come to the conclusion in 6 midstream in that particular regard, that an effort of 7 the magnitude associated with the pipe reanalysis was in 8 order, clearly, in my mind, that would be the 9 responsibility of a much larger organ zation than we 10 have focused on them right now.
11 So it's flexible in that sense, Darrell. And we 12 intend to keep it that way. The key is make darn 13 certain that we have got the resources necessary to the 14 task directed toward it. And we'll do whatever's 15 necessary to see that that happens. 16 MR. EISENHUT: Right. So let's see if you -- the 17 obvious extension, if I followed up on Bob Bosnak's 18 extent, that a large area of concern is, to him, is if 19 you made a decision to look at pipe supports on a 20 broader scale. Or if you made a decision to look at 21 valve design on a broader scale, you could go to a Stone 22 and Webster type entity, or some other entity, and 23 follow in the same regard. 24 MR. BECK: Yes, sir. 25 MR. EISENHUT: I should say, Bob made the comment. GODFREY & AMES COURT REPORTING y .. . ., . , . . . . . ... ._..-._,..._ m_._9.6100, Metro 46 (8,1 7_) 460-2048
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I l 82 l 1 A principal area of concern, or the biggest area, is 2 what he actually said, concern to us, is piping, pipe 3 supports, things like that. 4 At least in my mind, I'm not sure I agree with 5 that. That one of the biggest areas that we know about, 6 is piping and pipe supports. And knowing about it in 7 fact gives me some comfort, because I don't mind saying, 8 I'm very pleased to hear that you are responding to 9 those kinds of issues by putting together a large 10 compliment of people with lots of experience to go 11 review and resolve them. 12 My' concern actually goes larger in the other [, 13 direction, what don't I.know yet. And that's why I was 14 asking questions about, how are you designing up the 15 entire umbrella, rather than the known issue, so that 16 will be the focus, I think, of where I'm headed. 17 MR. BECK: Good. And I assure you that by the end 18 of the day tomorrow, you will have a much, much stronger 19 feeling of satisfaction. I hope that the effort I do, 20 certainly that we're undertaking, is one that will 21 answer that question. 22 MR. SHAO: I have a question here. You have 23 different groups doing different things, like you have 24
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83 1 What happened to interface? How do you make sure 2 the interface is transferred from one group to the other 3 group, is done right? Who has that responsibility? 4 MR. BECK: In the specific case that you have 5 cited, Larry,.the only interface is Stone and Webster 6 within their own organization. 7 MR. SHAO: Yeah. But if you get someone off to the 8 wrong lead, the final rules -- someone has to give him 9 the right loads. So the structure people, the 10 different -- and support the low -- 11 MR. BECK: That's also within the Stone and Webster 12 scope. i 13 MR. CHANDLER: How can Stone and Webster know that L.- 14 the structure work is right? 15 MR. BECK: They're going to look at it. Siskin 16 will talk to you about this tomorrow. I don't want to 17 -get into his business. I'm not qualified to 18 specifically. But that interface is one that'we have 19 discussed, and he'll illustrate it tomorrow. I'll make 20 sure he gets that message. 21 MR. SHAO: Yeah. But interface _can be in many 22 areas. Specifications, the loads. 23 MR. BECK: Sure. I think it will be more 24 appropriate to have him follow up on that question, than 25 me try to do it. 1 GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048 , , ,
84 f 1 MR. BOSNAK: John, are there any other areas that 2 you have already decided are large enough to bring.in 3 separate groups? Or is this tne only area at this 4 point? 4 5 MR. BECK: There is another area. It has to to do
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6 cable tray supports and conduit supports, and we have 7 Abasco involved in that respect. 8 MR. CALV0: That's what bothers me, John. 9 MR. BECK: Clearly a separate discipline. 10 MR. CALV0: Everything up to now has been triggered 11 by issues. We got an issue. We set up a team. We set 12 up a task force to do it. You're still -- you said the [)) 13 overall objective is determine the reasonable 14 assurance. 15 So therefore you,must look at each discipline,'and 16 do whatever you have to do to ascertain the reasonable 17 assurance. So that means whatever effort that needs to 18 be done in the electrical instrumentation or mechanical 19 systems. 20 So what you have today set up with the senior 21 review team is totally inadequate to come up with that 22 reasonable assurance. You see,-the emphasis ~ is 23 different now. Those are little data points. How you p 24 must embrace all the data points to come up with
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85 1 So whatever method you selected, you have got to be 2 comprehensive enough so you can properly correlate it, 3 and say, based on what I'm seeing, the rest is okay. 4 So you need this kind of expertise at all levels of 5 the senior review team. So you understand that the team 6 leaders are doing what be they're supposed to be doin6 7 That's the part that bothers me.. 8 MR. BECK: I appreciate your input, Jose. And I 9 can assure you that the collective significance 10 evaluation process is one that we're looking to very 11 strongly to resolve an answer to that question in our 12 own mind. [ '13 But we're having'a disconnect as to whether or not 14 there's enough expertise at the senior review team level 15 to make that evaluation today. I assure you, by the 16 time that's made, that won't be a disconnect. That's a 17 commitment. 18 MR. CALV0: Okay. 19 MR. BECK: No further questions? I'll go on to the 20 next slide on principles we're using to exercise the 21 CPRT program. The first one is a very clear one. The 22 CPRT has full and completes access to any records, any 23 persons, any history, anyone. There is no restriction 24 whatsoever on -this activity. t;. 25 The review team leaders, subject to SRT guidance, GODFREY & AMES COURT REPORTING
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86 1 and I emphasize the guidance aspect. We are relying, 2 and have to this point, on the expertise of these 3 individuals in their specific areas, have responsibility 4 for it, for developing and implementing the action plans 5 as they may be appropriate. 6 Any analyses and calculations, and, Darrell, this 7 touches on a point you raised earlier, are either to be 8 performed by those previously uninvolved, or reviewed by 9 a third party, or both. 10 And in the case of the -- clearly, in the case of 11 the piping system analyses that's the case. It will be 12 done by someone previously uninvolved, and reviewed by [;j 13 third' parties. Namely the CPRT , 14 MR. SOSNAK: John, does the charter of the third 15 party permit them just to recommend, or does it give 16 them the authority that they can reject something if 17 they believe that's-the proper course of action? 18 MR. BECK: Clearly it can be rejected. Their 19 charge is to be completely satisfied in their 20 independence, in their objectivity, that what is being
-21 done resolves the issue, number one, and that the 22 resolution is properly incorporated into the entire --
23 the generic collective significance issue. i 24 And the calls are hard sometimes. We have had LJ 25 some pretty stiff discussions as to the course events GODFREY & AMES COURT REPORTING ,, .- . _ - .. _.. Metro 469-6100, (817) 460-20g , ,_ , _.
i 87
.1 we.should take in order to be able to satisfy ourselves 2 that we're headed down the complete path. So they're --
1 3 it's a call, and it's a governing call. f 4 MR. NOONAN: John, you're using the word sampling 5 basis on here..- I guess sometime between today and
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6 toaccrow we're going to understand what that means? 7 MR. BECK: Yes. I'll touch on it in more detail
.8 here in a second. And John Hansel will touch on it a 9 lot more this afternoon, as well as to remember in the 10 case of Howard.
11 Any inspections that are done in the course of 12 executing these programs will be done by previously [_ 13 uninvolved or third party validation on a sampling 14 basis. And this specific case, if we're talking about 15 an inspection performed in the QA/QC area, for example, 16 Mr. Hansel has been involved in validating, on a 17 sampling basis, some inspection activities that has 18 taken place through the part of the project. And he can 19 speak to that in detail, if you would like, a little 20 later. 21 Record reviews will be done by a third party or 22 validated once again on a sampling basis by third 23 party. John has had some experience in this effort, or pr- 24 in that specific regard. (.- 25 Testing and NDE activities, other than the pre-op GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
88 1 program itself, will be conducted and certified by a 2 third party. Case in point is the concrete sampling 3 effort fits into that category of testing. Mostly 4 non-destructive. 5 The CPRT.itself will not perform any inspections, 6 calculations, or designs or record. That's a typo. It 7 should say of record. Where appropriate, however, the
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8 third party will overview inspections calculations or 9 redesigns of record. 10 This is an excerpt from the program plan, and it's 11 more definitive and complete with regard to these 12 particular issues. And I encourage you to review that. [L ' 13 And we can touch on it later. 14 Next slide. An issue -- 15 MR. MARTIN: John, Bob Martin. All records of 16 inspections performed under the CPRT , will they be ' 17 retained through more than your normal recordkeeping 18 systems? Not project overall, segregated and kept 19 separate, or in a CPRT record system, as opposed to the 20 project record system for the time being? 21 MR. BECK: All CPRT activities and records that 22 result' therefrom are kept in the CPRT project files, and 23 they're separate. - 24 There may be cases where some investigati've efforts C 25 are done by the project and overviewed by CPRT . In
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I 89 1 that case, those records will be in the project file. 2 MR. MARTIN: Okay. And all -- 3 MR. SECK: Where they belong. 4 MR. MARTIN: And all corrective actions that are 5 triggered as a consequence of these reviews and third 6 party inspections, are fed.back into your normal -- 7 turn ~ed back into the project corrective action system? 8 MR. BECK: Yes, sir. 9 MR. MARTIN: It is not a separate corrective action 10 system? 11 MR. BECK: There may be. Let me be clear. And 12 John will be talking furth'r e to this, and you will hear (]L 13 more tomorrow.
-14 If in the course of reinspection effort, for 15 example, a deficiency is noted, that deficiency goes to 16 TUGCO for resolution. It doesn't have Enything to do 17 with CPRT as far as resolving a deficiency on a TUGC0 18 side of the -- project side of the house, if you will.
19 It also go'es to the CPRT for an evaluation with 20 regard to safety significance. Two different 21 processes. And that -- in fact at the safety 22 significance slide is coming up next. I think I will 23 use to illustrate further that particular point. 24 MR. MARTIN: Okay. '
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i l 90 1 evaluated for reportability on the project side of the 2 house, safety significance on -- and safety significance 3 on the project side. But in particular, CPRT, we're . 4 interested in safety significant findings. 5 These evaluations will be performed in accordance 6 with our guidelines. Our being CPRT in this case. And 7 those are clearly defined. 8 MR. LANDERS: John, Don Landers. Throughout 9 CPRT review effort, you do continually note safety 10 significance? Is the CPRT going to be at all concerned 11 with licensing compliance? 12 MR. BECK: The CPRT does not have any functional [_j 13 responsibility for licensing compliance. That's TUGCO's 14 responsibility. CPRT will, however, in the course of 15 executing their -- our responsibilities, note in every 16 instance, and look as part of our charter, if you will, 17 at compliance with licensing commitments clearly. And 18 that will be noted and identified and dealt with 19 appropriately, either -- 20 MR. LANDERS: Let me take it a step further. If in 21 reviewing an item, the CPRT determines it does not have 22 safety significance, would they then hesitate to chase 23 the generic root or the root cause and generic p- 24 significance? L_ 25 MR. BECK: Absolutely no hesitation in pursuing GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
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1 that. And that's a very fundamentally important part of 2 the program to trend any non-safety significant findings 3 to be certain that there's nothing, even though it, in 4 and of itself, may not have safety significance, needs 5 to be pursued further. And that will be done. 6 That's going to be the subject of more conversation 7 chis afternoon and tomorrow. It's an integral part of 8 the effort. And on the -- 9 MR. ORGLEN:- George Orrien participating. What 10 may be going on, in addition, is that any particular 11 definition of safety significance you're using? 12 MR. . BECK: Those criteria will be very carefully { 13 and defined, and available for discussion, I'm sure, at 14 a -- at the next series of meetings. 15 MR. EISENHUT: Yeah. Let me follow-up on that if I 16 could. Larry sort ~of came to the same place I did. 17 While clearly ~the most important thing is the safety 18 significance of the evaluation, and you want-to make 19 sure the plant is SAFE in all aspects. 20 On the other hand, is the general approach going to 21 be that you're going through reviewing all the issues, 22 trying to make sure that the plant now conforms with the *: 23 overall licensing envelope. 1 -- - 24 Or have you -- to what degree are you now going 25 back and relooking at what was previously in the FSAR, GODFREY & AMES COURT REPORTING .. Metro 469..6100, (817) .4 6 0 - 2 0 4 8 ....
92 1 with the thought that you might want to amend licensing 7 2 requirements, et cetera? How are -- have you got a goal 3 as you're going in? 4 HR. SECK: That evaluation, Darrell, is part and 5 parcel of the whole effort. We will clearly identify 6 any areas where we're not in compliance with 7 FSAR. commitments or other commitments that we have made, 8 and either get in compliance or justify a deviation from 9 that commitment, one or the other. And that's true for 10 any_ findings that we make. 11 MR. EISENHUT: Let me ask the question a little 12 different. Do you have a goal going-in of saying that 13 your goal is to show that the. plant is in conformance [] 14 with the FSAR previously reviewed, and approved 15 licensing commitment approved through at least ESI, 16 and that as you do the review, any time you find a 17 deviation, you obviously flag that by whatever vehicle 18 you'need to.
-19 MR. BECK: NCR 's.
20 MR. EISENHUT: Is that really the objective of 21 trying to stay within the previously approved 22 FSAR designed envelope? - 23 MR. BECK: It's a mechanism. We're almost back to 24 a chicken and egg. argument. I think in a way a L-. 25 deviation, for example, is defined by the, fact that we GODFREY & AMES COURT REPORTING , Metro 469._,6100, .(8~.17 )-- 460-2048 _ __ .7
93 1 have violated an FSAR commitment. We have violated a 2 criteria or a specification or whatever, that's what. 3 MR. EISENHUT: I don't really mean it in that 4 sense. Let me be specific. Let me give you an 5 example. We have gone through some projects at great , 6 length where the utilities approach was that rather than 7 argue about the FSAR commitments again, since you laid 8 out a design. envelope, you'will just, whatever it 9 takes. Re-evaluate, redesign, rework to meet that 10 FSAR requirement. 11 We have had ot'her situations where utility comes 12 back and argues that, well, let me modify my [ 13 FSAR commitments and modify FSAR my commitments, which 14 may be acceptable. Come back within a new chapter of a 15 FSAR or portion of a FSAR, and reopen the review process 16 on that. 17 And I was wondering if you had some going in, 18 goal. And I give you, for example, the one on response 19 spectrum. You could start from relooking at response 20 spectra, and reopen a major issue that's already been 21 reviewed once. 22 And I'm trying to get a' feeling for it from a 23 management prospective of, do you have an objective
. 24 going in, or goal. And what might I expect in terms of 25 anything else. What kind of work load am I going to be GODFREY & AMES COURT REPORTING Metro 469-61_00, (817)_ 460_-20,48 ,,_ _ .
i 94 1 foreseeing from the NRC standpoint? Am I going to go 2 back and re-evaluate, starting from literally ground up, 3 wnich is certainly an option. 4 MR. BECK: No. I certainly don't want to do that. 5 MR. EISENHUT: I don't want to do that either. 6 MR. BECK: I think I understand the drift of your 7 question. There is one area, and you raised it, a 8 response spectra where we are -- would be going to -- 9 coming to the staff with a suggested revision, and how 10 we treat that particular issue, and in fact a -- to 11 petition the staff for a changed basis. 12 And we will be meeting with staff next week on that [j 13 subject. My goal is to meet commitments that we have 14 got on the table insofar as it's physically and 15 reasonably feasible to do so. That's going to be the 16 test, basically. 17 Now I'm not committing that there may not be other 18 areas where we won't seek a change. But in general, we 19 want to meet the commitments that are on the table right 20 now. And I think in most instances we have and will 21 continue to do.so. 22 MR. EISENHUT: The one you talked about. Can you 23 just summarize, you know, a couple more sentences worth, p 24 how widespread or how, to what extent, you would be (__ 25 foreseeing making that kind of a request to the staff, GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048 - - _ . - . , . , - - - .
95 1 to go back and look at some. aspects, and how widespread 2 you would at this point? 3 MR. BECK: At this p o i r. t , the only one I'm aware of 4 is the response spectra question.
.5 MR. EISENHUT: Is it complete rework of the 6 response spectra?
7 MR. BECK: Yes, it is. We have got a very 8 conservative, old, if I may. Old in the context of 9 time, and we'll be talking to you. 10 MR. EISENHUT: I thought ~you were going to apply 11 for a amendment on sample values and response. 12 MR. BECK: That has been done. That's to use [ 13 criteria or values that have been ac'cepted at other 14 facilities by staff. And I don't see any othe? reason 15 why it's.a significant issue here. I understand there 16 are conditions-associated with our request, and we have 17 those under consideration. 18 MR. SHAO: I hope these should be minimized. 4 19 MR. BECK: I do, too. It will make the process 20 much simple for both of us. Yes, sir? 21 MR. BURWELL: Spot Burwell, NRC. 2& THE REPORTER: I can't hear yo.u. 23 MR. BECK: Spot Burwell. p 24 MR. BURWELL: My name's Spot Burwell, NRC. Along
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96 1 a moment ago, I noted that in a recent letter, you have 2 asked for some changes to the technical specifications 3 that was delayed through a design change on a isolation 4 valve bypass. 5 MR. BECK: Yes, sir. 6 MR. BURWELL: Basically, to my view, that falls 7 into a design change. Do other design changes which 8 staff review, will need to be conformed? Do you 9 anticipate others that come to your mind? 10 MR. BECK: Right now I don't, Spot. But I don't 11 know of a nuclear plant in the United States that 12 doesn't have design changes from time to time. So I'm [}] 13 sure I can commit that we're going to have more for 14 . you. . 15 Offhand, I can't think of any, that you haven't 16 seen or you're not aware of. 17 MR. BURWELL: I recognize that. 18 MR. TRAMMELL: Charlie Trammell, NRC. I just have 19 a question on this design -- floor response spectra, 20 that what we're going to be discussing, I want to make 21 sure that I can sort of understand when the process is 22 going to end. 23 We were going to meet on floor response spectra, t 24 and we have, as already mentioned, a request to use the L. 25 TOW Case 411, which we're approving today. And also GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460;2048 . _,..
97 1 Code Case 397, I believe it is. And using the latest 2 1984 edition of Section NF of the Section 3. And this 3 all seems to be part of a package that -- is that'the 4 end of it or -- 5 MR. SECK: In our discussion, we're scheduled for 6 the 18th. You will have it. 7 MR. TRAMMELL: We will have the whole thing? 8 MR. SHAO: The 397 is on damoening area, and 411 9 is on the EE response shifting. 10 MR. BECK: Yes. The 18th. 11 MR. SHAO: Are you going to talk about the ' 12 . dampening values, too? 18th is just the response L, 13 s p e c t'r a , or -- ' . . 14 MR. BECK: The other has already been submitted. Yes. 15 16 MR. VOLLMER: The applicability of these changes to 17 a somewhat more fundamental design input would be 18 applied to piping, piping systems, supports, cable 19 trays. The whole gamut? Is that including structures? 20 How far does this thing go? 21 MR., BECK: The answer is yes, and Bill I think 22 would like to add to that. 23 MR. COUNSIL: I think some of the discussion we're r- 24 hearing right now is a little more premature, because ' 25 we're going to discuss this with you on the 18th, in GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048 a
98 1 another public noticed meeting. 2 However, in answer to your question directly, Dick, 3 in the Stone and ' deb s te r e f fo rt , we are starting.now on 4 making initial runs, so forth, using the response 5 spectra today as in the FSAR, and enveloping, quote, 1 6 that design. 7 An'd Ed Siskin can get into more details with you 8 tomorrow on that subject. And if possible, I'd like to 9 get off response spectra, because I think we're off the 10 purpose of this meeting. And that is the purpose of the 11 meeting on Tuesday. And be happy at that time to answer 12 any of_your questions on response spe'etra. We're not
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{_j ' 13 prepared to do that today. 14 HR. VOLLMER: Yeah. I think the drift of it is ' 15 really not off line for this meeting, because I think 16 what we're looking for is the principals under which , 17 this process is to be guided in taking place. 18 And, you know, broadly you can look at it, as I , 19 think we have already discussed, as meeting regulatory 20 requirements one by one, as you come to it. Or making a 21 fundamental change'to design criteria, may put the plant 22 in its -- pertinences into a completely new design 23 light. And that is a rather fundamental management
- g. ; 24 approach.
u 25 MR. COUNSIL: I see. Dick, if in fact we convince GODFREY & AMES COURT REPORTING Metro 469-610,0,,J817) 460-2048
99 l 1 you that today's response spectra and codes, so forth, 2 are the better_way because they are far more 3 sophisticated techniques today than existed in 1972 and 4 1974, as you're well aware, that what that will impact 5 is quite clearly the civil structural, which quite 6 clearly. impacts piping. 7 And it also, when you get into the small bore pipe 8 and in cable tray and in conduit supports, wi11 clearly 9 impact that as part of our effort. 10 Today, however, right now we are going forth with 11 the existing response spectra in all of our redesign 12 views. We are not going away from that program. L- 13 MR. EISENHUT: Okay. I understand that. Follow-up 14 on Dick's comment a little bit. I think what we're
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15 really looking for, and the reason we brought it up here 16 is, we're looking for areas that might interact with 17 what you're doing here, because in essence it's sort of 18 a computerized "do loop". You go back, if in fact you 19 change things at some point, you go back and re-analyze 20 what you have been doing. 21 Certainly some of the things we're talking about by 22 new modeling and new approaches today, I agree with you, 23 are much more sophisticated than they were ten years 24 ago. And in many cases there may actually be better 25 ways to model things. GODFREY & AMES COURT REPORTING , , . . . . - , , . ~ . . Metro 469..6100,,.z. .. . . (8 _ , - . . , . , . __ _1,7 ) 4 6 0 .,2 0, 4 8.r - .
100 1 But this whole area we look at as a package. I 2 think that's a key. le try not to look at damping, 3 trunkation and spectra, modifying spectra. So when we 4 look at it, the reason you see our questions, we look at 5 it as a package to make sure the whole thing fits 6 together in the response spectra. 7 And certainly, if the base of the plant starts -- 8 responses differently to an earthquake motion, 9 everything that sits on the base of the plant is open to 10 questions. It goes without saying. 11 So I think we're just trying to explore today. And 12 the reason for the questions is, to what degree ether 13 'o n g o in g efforts could interact with CPRT work. And [] 14 that's the thrust of where we're headed. 15 MR. COUNSIL: I think as John has answered, that I 16 personally know of no other area, than trying to look at 17 at the more sophisticated techniques of response spectra 18 today. Any of the ongoing trork, however, is not being 19 done to, quote, a new response spectra. t 20 MR. EISENHUT: At this time. 21 MR. COUNSIL: It is not. At this time. And it 22 will not proceed until we have convinced staff that it 23 should.- i 24 MR. EISENHUT: Okay. Let me -- there's one other 25 one. My earlier question, I had two things in mind. GODFREY & AMES COURT REPORTING Metro 469.6100, (817) 460-2048 _.m- -
101 1 One was'for response spectra, and the other was the
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f " - 2 plastic versus elastic modes on valves. So there was a 3 message behind my question. 4 Do you foresee, to be perfectly straightforward and 5 tell.you that those are the two areas I was much earlier 6 in the meeting exploring, do you see the valve design 7 criteria, elastic versus plastic, as another area where 8 it might interact at this time, or is this too early to 9 tell? 10 MR. COUNSIL: Well, it's too early for me to tell. 11 Let's put it that way. 12 MR. EISENHUT: I'll reserve usual a -- '] t 13 MR. COUNSIL: If you would like to hold that 14 question tomorrow, and Ed Siskin's standing up here, I 15 sure he will be happy to answer it for you. 16 MR. SHAO: One c'omment I would like to make, is you 17 made a comment that you're going to start your piping 18 analysis right now, okay. 19 But usually, if you want to look at a whole plant, 20 usually the sequence is, you look at the structures 21 first, and then you look at the piping. You don't want 22 to do a piping now, and do the structure later. And you 23 find out something is wrong with the structure, you have p j '24 to redo the piping again. ' m..) 25 MR. COUNSIL: You're entirely correct. We are GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048 . - ..
102 1 looking at the structures first. I con't know where you 2 got the idea we weren't. 3 MR. EISENHUT: I think it was because earlier it 4 was said in the meeting, that you established a Stone 5 and Webster to look at large bore piping and supports. , 6 You didn't say a group to look at structures and 7 the associated piping and supports. And so we came 8 across, at least I did, too, with the same feeling that 9 was said in the meeting here, that the Stone and Webster 4 10 group was largely looking at reanalyzing piping and i 11 supports. 12 I think, if in fact it's expanded to say it's Ej 13 looking at the overall area, the interaction and the 14 overall subject as it would naturally extend to, I think
; 15 that --
16 MR. COUNSIL: Well, that's entirely correct. Your i
! 17 concern in the first case was directed to piping and 5
18 piping supports. 19 MR. EISENHUT: Right. ]; 20 MR. COUNSIL: I did not -- I would steal Ed 21 Siskin's thunder of tomorrow, but his first charge was 22 not only to learn what has been done what was the basic 23 modeling, so forth was, to go back and look at the stick 24 models on a structure, so forth. Get a full 25 understanding of that, looking at the enveloping of the GODFREY & AMES COURT REPORTING . Metro 469-6100, (817) 460-2048
103 1 loads on, quote, the structure, before he ever got
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2 started on reanalysis. 3 MR. EISENHUT: Okay. Is he tied in, or is he doin6 4 the floor response spectra issue then, or -- 5 MR. SHAO: Who is the structure group? Who is 6 doing the source structure acting analysis? 7 MR. COUNSIL: Right now, if in fact we go forward 8 with a new response spectra, sole interactions and floor 9 response, that is being doing by Gibbs &' Hill with the 10 assistance of Doctor Rizzo and several others. Mr. 11 Siskin is also involved with that review. 12 MR. SHAO: Okay. I have one question on this. I { 13 thought, why don't you kill two birds with one stone? 14 If you want to look at a structure in the problem, you 15 want an independent group, are you using the same 16 group? You answered no before. Or will you use a new 17 independent group? 18 MR. COUNSIL: If I understand your question 19 correctly, Larry, it is the Gibbs & Hill group that is 20 looking at, quote, today's techniques along with the 21 systems from Doctor Rizzo, and I believe about three 22 others, involving Stone and Webster. Looking at what is 23 there today, today's spectrum, so forth, that is 24 Siskin's group in New York. 25 MR. EISENHUT: Okay. Good. GODFREY & AMES COURT REPORTING Metro 469-6100, ( 817, ) 460-2048
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. s i , 104 1 M R '. SHAO: If I understand you, you are not really - - 2 changing dhe standard of your plant. Mainly it's just 3 using a different. technology to de the structure et f 4 analysis? >
MR. COUNSIL:
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5 That's my underscanding. 6 MR. EISENHUT: Later acceptable models and later 7 accepted approaches. , t , 8 MR. SHA0h They don't have to change L 9 MR. EISENHUT- R i g h t' . ,In fact it depends -- you 10 have to take a hard look at it. Bill, I might suggest 11 that this is an area the staff has a' lot of interest 12 in. And one way to car ainly hear Ed' iskin tomorrow, [ 13 and I might"suggest that th'ere is the meeting on the 14 floor response spectra nexti. week.
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15 And I might suggest, and already'even before the
, ;16 meeting, asked Larry and Vince to look' int'o this, we 17 might have a meeting on the interaction between the 18 action between your technical staff and yourtechf.ical 19 staff, as soon as you would be ready to say, this i's' h o w 20 you might go about insuring those details work. I think' 21 I agree, we don't want to go too much depth here. But 22 at the same time, we.think this.is potentially ---is a 23 significant issue. ; 24 MR. COUNSIL: We'll be happy to t'alk at any time.
L_ _ 25 But if my calendar is correct, we have only got Monday,. GODFREY & AMES COURT REPORTING e Metro 469...6100,
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105 1 MR. EISENHUT: Only got Monday before -- 2 MR. COUNSIL: The Tuesday meeting. 3 MR. EISENHUT: No. I didn't mean Tuesday meeting 4 as a response to floor spectra. Mine was more, unless 5 you were planning to include in that the interaction of e 6 how Ed Siskin's work is going to proceed, and I didn't 7 think you were. 8 MR. COUNSIL: No, we are not. 9 MR. EISENHUT: And I was really more looking at it 10 as the overall question of the interaction of floor 11 response spectra, the piping and pipe support, whether 12 or not this would be done under -- without an [_ 13 FSAR amendment. Those kinds of questions at a later 14 meeting. 15 MR. COUNSIL: That's fine with me. We can set that 16 up with Vince after the Tuesday meeting at any time at 17 your convenience. 18 MR. BECK: Let's go to the next one. 19 You're going to be hearing a lot more and more 20 detail by people more expert than I in the area of 21 sampling. But I did want to touch on the issue, because 22 it's one that's important to our program. 23 And ue have look at very, very carefully, and touch 24 on in the sense that we are going to use sampling (~. ] 25 techniques, and many of the CPRT issue specific action GODFREY & AMES COURT REPORTING _ Metro 469-6100, (817) 460-2048
106 1 plans, and in the overall design and construction - - 2 adequacy aspect. 3 We have established guidelines with regard to the 4 CPRT activities, as far as sampling goes. And they will 5 be included as Appendix D to our program plan, which you 6 will have within a couple of weeks. 7 These guidelines require that any issued specific 8 action plan sampling programs adhere in general and
'9 there~will be more, as I said, in the program document, 10 to these criteria, that we utilize random selection 11 methods for samples of defying populations, and I mean 12 that in the rigorous sense.
{J 13 That these sample sizes meet a 9595 statistical 14 standard. That we utilize predefined accept and reject 15 criteria, which touches really on the issue that came up 16 with regard to safety significance, for example, that we 17 define these criteria ahead of time, and that we adhere 18 to them. That we identify decision criteria for sample 19 results, acceptance, or sample expansion. And this will 20 be very clear in every instance as to how we plan to 21 proceed. As I said, we will have more discussion on 22 that point. 23 MR. MARTIN: John, you said you -- when you said in 24 the rigorous sense with regard to random selection for L.. 25 defined populations. In your appendix, you will define GODFREY & AMES COURT REPORTING Metre 469-6100, (817) 460-2048
107 1 the bounding or the manner in which you approach a 2 definition of a defined population? 3 MR. SECK: Yes. 4 MR. MARTIN: What I concern myself is that will we 5 be able to elicit from Appendix D to the program plan, 6 that if you're going to go out and sample pipe nangers 7 that how you define populations of pipe hangers in some 8 fashion, that at least we can understand when we go out 9 and see what you're doing. 10 MR. BECK: There will be two pieces. One, the 11 methodology will be described in appendix D. 12 Two, in every specification where we use sampling i , 13 as part of that issue, specific sampling plan, and the 14 back up documentation, it will be very clear to anyone 15 who wants to look at it how we arrived at populations, 16 how we describe them, and-how the sampling will proceed, 17 and what the criteria are. 18 So appendix D methodology to be applied in general 19 issues specific actions plans, if sampling is used as 20 part of them, will describe precisely how it was done in 21 that case, in accordance with a previous -- the 22 established methodology. 23 MR. MARTIN: And your predefined reject criteria _ 24 will define what constitutes a failure within that 25 population? GODFREY & AMES COURT REPORTING Metro (81 ;.__.460.:2048 469..-6100,_.-.-.7) , .. . . . , - - . , _ . . .
108 1 MR. BECK: Yes, sir. 2 MR. MARTIN: Whether the sampling plan or the 3 inspection plan, which goes out to d these things, 4 particularly if you want to approach the pattern of 5 9595. 6 MR. BECK: Yes. It will be specific in each case. 7 MR. MARTIN: Size of samples, numbers required, 8 and then presumably the response to if a reject rate 9 ' exceeds a certain number, the size of a population 10 growth that's required for that class within the 11 population. 12 MR. BECK: Exactly. [] 13 MR. MARTIN: One of the things that has gone on for 14 about the last six months or so is, because of-the 15 formulation of the CPRT , we have, in terms of 16 inspection findings and enforcement, offered the option 17 of the company to either respond directly to the 18 particular issue, or to sweep it into the Comanche Peak 19 response team. 20 Do you perceive a point at which the -- I think of 21 that more as a planning document and an overall response 22 document. At some point you will then be much further 23 into implementation, and no longer developing the
- 24 program plan for responding, than at that particular
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109 1 enforcement ~ issues as they arise? ' 2 MR. BECK: We're still going to use all information 3 available to CPRT , including project response to 4 enforcement actions or Region 4 inspection reports, for 5 example. That process will continue until we have 6 reached the end of the CPRT program. 7 MR. MARTIN: Okay. In terms of another continuing 8 input into their ac'tivity? 9 MR. BECK: Yes, sir. Whether or not CPRT has 10 specified responsibilities in response to an inspection 11 report, we still are looking at those results. 12 MR. MARTIN: Okay. [_ 13 MR. DENISE: John, Dick Denise, NRC. Regarding 14 your sampling, I don't see any mention of what previous 15 samples have to do with this sampling. Is there a clean 16 slate approach or -- 17 MR. BECK: I don't understand your question. 18 MR. DENISE: Well, there have been lot of 19 inspections you have done. And some have been a hundred 20 percent, and some have been samples, and they have had 21 certain results. Do they have anything to do with the 22 selected sampling protocol of the CPRT ? 23 MR. BECK: If it's a CPRT activity, in day 1, if we F-- 24 have used sampling in that respect, we have done it in
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110 1 We have had Fred Webster, Dr. F' red Webster on our
- - 2 team,- from the very beginnin6, to serve in tnat 3 capacity. He is tne author of Appendix D. And any 4 sampling that's been done to date, has been done in 5 accordance with those principles.
6 MR. DEMISE: Perhaps you didn't understand my 7 question, and I didn't understand your answer. 8 MR. SECK: Maybe I didn't. 9 MR. DENISE: What I'm asking you is, does the 10 previous inspection program -- 11 MR. BECK: CPRT? 12 MR. DENISE: No. The program conducted over a j 13 period of years, inspecting the construction'of.the 14 plant, some of which involved overcheck and sampling 15 when there were NCR 's and corrective-actions written. 16 Do any of those results, in any of those samplings 17 results, have anything to do with the selection of the 18 samples by CPRT ? 19 MR. BECK: No. 20 MR. DENISE: It's a clean slate, is what you're 21 saying? 22 MR. BECK: Yes. 23 MR. DENISE: I want to understand. 24 MR. BECK: I understand your question, and I hope 25 my answer was clear. l GODFREY & AMES COURT REPORTING M e t r ..,..._..; o 4 6 9_.. ,6 1 0 0..., . ( 817.).: 4 6 0 . ,2 0 4 8. ... _._ , l
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111 1 MR. DENISE: Let me say it was concise. 2 MR. SECK: No, there is no connection whatsoever. 3 MR. MARTIU: Okay. 4 MR. MILHOAN: Excuse me. Jim Milhoan. As the 5 design area, are you saying that you're going to do a 6 random sampling of pumps of components for the desigri 7 adequacy review? Are you saying you're going to go to a 8 sample system basis? 9 MR. BECK: I think you should wait to tomorrow and 10 ask your question when Mr. Levin is here, and it will be 11 very clear what that design adequacy review is going to 12 entail. [, 13 MR. CALV0: I think ever'ybody is under the 14 impression that we're doing it separately of different-15 areas the plant, is whatever'it needs you to supplement, 16 like you said before, you had done before. So whatever.
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17 areas you -- 18 MR. BECK: No. He said that. 19 MR. CALV0: But I think the impression that this is 20 creating is that, starting from scratch, and you're 21 going to sample all these areas to give the reasonable 22 assurance, I think what it's in your mind, if I 23 understand you correctly today, whatever you have done 24 before, you assess with it. You need to do anything in 25 that area. But the area that you decide to look for, GODFREY & AMES COURT REPORTING
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112 1 thats the one you're going to apply the sampling, if 2 you decide to. 3 MR. SECE: If -- I think the confusion, Jose, at 4 least in my mind, is coming with non-CPRT activities 5 that may have.taken place before it was even a twinkle 6 in somebody's eye. And that I can't speak to. 7 I can speak to any experiences that we might have 8 had in that regard, are not going to serve as the basis 9 or a precedent, or anything else. We're blind to that. 10 But to your specific point, we have used sampling
-11 on issued specific actions plans within CPRT. And those 12 sampling efforts has been done in accordance with the
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I'l 13 methodology. LJ 14 MR. CALV0: For instance, the CYGNA phase 1, 2, 3, 15 4, did some sampling on your own, and you want to take 16 credit for that effort, if you want to take credit, you 17 have got to go back now, and the CPRT is going to. sample 18 those things in there, after they have been fixed and 19 everything corrected. , 20 MR. BECK: No. We're not going to take credit.for 21 anything CYGNA did. 22 MR. CALV0: But you have to concentrate your effort 23 in those areas, be'cause everything has been done and
.p 24 corrected. Because you're not going to find anything k._
- 25 wrong with them. That's what I'm saying.
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113 MR. BECK: 1 I'm not going to make any judgment. 2 'd e ' r e n o t going to use it. 3 MR. CALV0: That's what I'm saying. So therefore, 4 this is whatever you elected to, this -- the area of 5 planning and fueling, you want to concentrate on, then 6 'you sample that area. All right. 7 MR. BECK: That's correct. When I say we're not 8 going to use. We are using CYGNA. Output as input. So 9 we're not going to use it. So we're not going to use 10 what they'did as part and parcel of our program. 11 MR. CALVO- So you're -- to the bounds that you 12 have specified? (_ 13 MR. BECK: Yes, sir. 14 MR. SHAO: In the design area, you mentioned Stone 15 and Webster were going to pipe support. Gibbs & Hill 16 working on the spectra. And Abasco working on the cable 17 tray support. Any other groups? You already mentioned 18 three groups. 19 MR. COUNSIL: They're all together. 20 MR. BECK: There are other groups involved, but not 2.1 ~in the kind of analytical revision that you're talking 22 about. 23 MR. EISENHUT: Here's what I think, and Larry's p- 24 question is very pointed in civil structure, mechanical t_ J 25 and piping. He's biased over there where he's looking GOD? REY & AMES COURT REPORTING = . .... ... Metro -469-6100, (817) 460-2048
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114 1 at. 2 MR. BECK: I can appreciate that. 3 MR. EISENHUT: You have got these tnree other 4 groups. And I guess what the staff's real question is, 5 how they interact. Because they obviously are 6 interacting as more of an unknown to us of how well 7 they're glued together, and how that interaction is 8 going to be taking place. 9 MR. BECK: I think it's obviously a question of 10 real interest. And that's going to be very crystal 11 . clear in the issued specific actions plans that are 12 going to be coming in, and in the meetings we're going ~ [] 13 to have. And I suggest that that's prime subject for 14 subsequent get-togethers. 15 MR. VOLLMER: John, one area that's peripheral to 16 that, a question of Darrell's, is, again, a management 17 issue. Do you have responsibility for QA/QC broadly 18 under you, and the TUGCO organization, not SRT , with 19 the consultants that.you have, the number of groups you 20 have, some of which I'm aware have QA topic reports in 21 the NRC, and have approved QA programs, some of which 22 you don't how are you going to broadly handle the 23 quality aspects of all of these activities? 24 The organizational viewpoint from the viewpoint of s__ 25 auditing and demonstration. And perhaps in some cases GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460 2048
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115 1 where vendors are part of the program. We may wish to 2 get vendor inspection involved. Can you -- could you 3 give me an overview of that? 4 HR. BECK- Sure. This was a subject of a very. 5 careful look in the CPRT program, of how precisely we 6 were going to deal with QA witn regard to our
? CPRT effort. Let me characterize CPRT for purposes of 8 this brief discussion as a consulting activity, per se.
9 It's not for design of record. We on the project 10 side of the house are not relying on anything. And this 11 is one of the reasons, by the way, for having Stone and 12 Webster placed where they are, reporting to Bill Counsil () 13 on the project side of the house, if in fact the results 14 of some of their analyses are used for the record, or to 15 verify the record as it exists. 16 If that's the case, they will obviously be subject 17 to their QA program, which they are, and that program 18 will obviously be subject to our audit, if it's set up 19 that way. 20 But back to CPRT as a whole. We are not 21 considering CPRT activity in that consulting capacity as 22 subject to our QA program. They're providing advice. . 23 They're providing direction for programs. 24 If any parts of those programs, however, fall into 25 the category of being subject to the QA program, it will GODFREY & AMES COURT REPORTING
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-- 2 it's a rather clean definition, I think, that these 3' consulting activities are not part of the design or 4 record. They do not have a direct impact .n that 5 capacity on the plant as it physically exists.
6 MR. TRAMMELL: John? Charlie Trammell again. The < 7 nature of some of the questions I'm hearing, together 8 with parts of this program, which we don't know where 9 it's going to lead yet, going to go out. And some of 10 these self-initiated things we'll learn about later.
/ 11 And you're going to find things and you're going to f
12 maybe hire special groups to look into this and that. [)) 13 An important element at least from a regulator's 14 standpoint, is-reporting on what is happening, and where 4 15 is it leading you. And maybe a look ahead at what i 16 you're going to do, and maybe your sampling results; 1 17 out of 83, you decide you're going to look at all of 18 them, and this type of thing. 19 And I think NRC would be interested in knowing what 20 your reporting methods will be. And perhaps we would 21 like to look closely at certain areas, and maybe we 22 would like to not look closely at other activities, 23 depending on circumstances. r- 24 So I would like at some point to hear some k-25 discussion on what your thoughts are on reporting, so GODFREY & AMES COURT REPORTING
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117 1 that we could comment on that. ( 2 MR. BECK: Okay. Let me respond in a couple of 3 different ways. You will hear today and tocorrow about 4 what role wrap-up reports play in the program itself. 5 Number one, just internal to CPRT in ilr. Hansel and Mr. 6 Levin. 7 We also, aside from the self-initiated actions, 8 have all of our TRT response activities underway. Some 9 of them are nearing completion. A couple of them 10 physically, the physical work associated with them, has 11 been completed. There will be a results. reports as a 12 result of all these activities. These results reports t~- (___ 13 will be made available, provided to staff and all 14 interested parties. 15 Staff is, I hope I'm viewed as being responsive, 16 when Mr. Noonan rings my chime and wants to have a 17 meeting on any subject. So that door is always open as 18 staff need -- have the contact. And it will continue to 19 be. 20 At what stage staff chooses to be involved at a 21 detailed sense in any area.Where there may be interim 22 results made available, that's obviously a subject for 23 discussion and meeting.
-g -24 So we're here to cooperate. We encourage staff J
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118 E 1 that it's going to lead to a.better understanding of , 2 unat we're doing, and why we're doing it, and what that 3 end result is going to mean. 4 1: R . TRAMMELL: I wouldn't want to have to 5 orchestrate something like this every month to find out 6 what's going on. 7 MR. SECK: Neither would I. 8 11 R . TRAMMELL:' I had in mind a monthly report, 9 bi-weekly report, how it's going, what's your finding, 10 what new groups. Stone and Webster is down at the site 11 now, and I just learned that by telephone and this 12 morning really. And I learned about Abasco doing Fr (_j 13 something for you. And this is all unknown. This is 14 all news to me. And maybe a periodic report would be 15 maybe not so hard to put together. 16 MR. BECK: I'd like to think about the best way for 17 us to be responsive to the need you have just expressed, 18 and get back to Vince on that one, or to you. There are 19 a number of ways we can approach it. Let's talk about l 20 it. 21 MR. EISENHUT: Yeah. I'm not hooked into, you 22 know, a very frequent report, because you end up 23 spending all your time writing reports. But at the same
- c. 24 time there is a need to have communication, something we k_J 25 we need to talk about.
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1 l 119 , 1 1 MR. SECK: Yes. Can I have the next one? l 2 This slide is intended to address the issue of 3 where we have been responsive to specific issues. And 4 what that process will do is lead to a conclusion that 5 there is reasonable assurance that no safety significant 6 issues, be they design or construction that are related 7 to issues that have been raised by others, exist at 8 CPSES . 9 That's not the whole story, however. And the next 10 slide talks about our self-initiated efforts. And what 11 those efforts will do is permit the conclusion with 12 regard to the issue responsive efforts to be extended to y- 13 the balance of a safety significant plant. - 14 That is the key in my mind to the entire program, 15 to simply address those issues, whatever the source, is 16 not enough. And that's why we're going to this 17 substantial additional effort. It will provide the 18 necessary enhancement of confidence and the conclusions 19 we're going to reach at the end of the program. 20 MR. LANDERS: John, I want to make sure I'm reading 21 this wrong, and what you said is really right. The 22 self-initiated efforts again address issues or issue 23 responsive efforts. pr- 24 And that's the same terminology that is used in the C 25 previous slide, and would lead,one to believe that the GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
120 j 1 self-initiated efforts are going to take the issues that 2 are currently on the table, and extend them throughout 3 the plant. =And that is not what I heard you say 4 earlier. 5 MR. BECK: I apologize for the language. The 6 self-initiated will allow us to take the issue, 7 responsive results, supplement them in a fashion such 8 that the totality can b'e extended to the entire plant. 9 MR. LANDERS: Thank you. 10 MR. BECK: And -- 11 MR. SHAO: Can you tell me which of the 12 organization are going to address that issue? Which
-[j 13 group is going to work on this issue?
14 MR. BECK: The final conclusion? 15 MR. SHAO: No. Which group? Like you have Stone 16 and Webster working on this part, and Gibbs & Hill f 17 working on this. And Abasco working on that. Who is 18 working on self-initiated effort? 19 MR. BECK: Yes, Mr. Hansel will talk about the I 20 QA/QC today. And Mr. Levin tomorrow will tell you the 21 number of different entities that are in the -- 22 MR. SHAO: So that therefore would be under the 23 Howard Levin, and -- 24 MR. BECK: He will speak to the issue. He's 25 certainly not doing it by his lonesome. But, yes, GODFREY & AMES COURT REPORTING (, . - . . .- ,...ro 469.6100, Met
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121 1 tomorrow you will understand precisely who is involved 2 at this stage. 3 MR. SHAO: But you do have an crganization working 4 on.the issue? 5 MR. SECK: Yes, absolutely. 6 MR. CALV0: It goes back what I said before. You 7 have got Stone and Webster; you have Gibbs & Hill. You 8 have got Abasco. And now you have got somebody else. 9 We want to know how many somebody else before all that 10 things is -- 11 MR. BECK: Yes. 12 MR. CALV0: -- all the things are -- [ 13 MR. BECK: The -- if you're talking about getting 14 our arms around the whole thing, I'm going to be 15 involved. The SRT is going to be involved. Mr. Counsil 16 has never been bashful about being involved in 17 anything. 18 So it's going to be the totality of the project and 19 the CPRT efforts. The focus is going to be with the 20 SRT, if that answers your question. 21 MR. NOONAN: John, the comments I'm hearing from 22 the staff. You may have talked to Bill. The 23 organization chart is complex. People involved, who , ' ,j 24 they report to, is a very complex system. It depends on J 25 the one and other. And they don't see how it all comes GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
r 122 1 together. 2 MR. EISENHUT: I don't think it seems so much that 3 it seems to be confusing. He don't knou. b'e ' r e trying 4 to understand what it is. And assume, when you settle 5 down in your final program plan, that you suomit -- you 6 have heard the questions today, and you can factor those 7 in and try to expan'd and explain the interworkings and 8 the mechanisms of how this is going to function. 9 I appreciate that it's complex. It's been 10 expanding. It's been evolving. Different people have 11 been coming into different play. But I think this is an 12 area that the staff does really want to look at, is the [] 13 organizations and how they're going to interact. 14 So I think at this point it probably suffices to 15 say -- well, in fact not only that question, but all the 16 other' questions we discuss, are for your benefit, to 17 feed back into your plan. So when it comes in, a lot of 18 them will be addressed. But clearly, there is the key. 19 MR. BECK: I appreciate that, Darrell. I i 20 MR. MARTIN: John, in the CPRT objectives, two of. 21 the objectives include evaluation of generic , 22 implications, and then evaluation of collective L 23 significance. I presume in nonissue areas, areas for 24 which issues have not been identified, the thing that i 25 the -- it is this generic implications and collective i j GODFREY & AMES COURT REPORTING l Metro 469-6100,.. (817) 460-2048
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123 1 significance that would lead the CPRT to go into areas, 2 pottntially go into areas, which -- for which there are 3 no specific issues on the table relative to the Coc.anche 4 Peck project. 5 MR. BECK: It could. The generic implication is 6 set up specifically to address that concern and -- 7 MR. MARTIN: So tnere are. It might lead you in. 8 It would not necessarily. 9 MR. BECK: That's correct. 10 MR. MARTIN: I guess conceptually, just as a 11 concept, do you either believe it is possible that there 12 could be hardware or activity areas relative to Comanche { 13 Peak, for which an additional overview would not be 14 conducted? 15 Because either, A, there have been no issues 16 identified. Or, B, the collective significance -- 17 collective -- yeah, collective significance or generic 18 implications could potentially not lead you into an 19 area. 20 And have you made any overt decisions that, should 21 that be the case, that area will be looked at anyway? 22 So that you can still come to that bottom line that 23 everything has been looked at at some level to your pr 24 current status of confidence in the plant, s.- 25 MR. BECK: Bob, I think when Mr. Hansel's finished GODFREY & AMES COURT REPORTING
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124 1 -this afternoon, you will have a better appreciation for 2 tne totality of our construction adequacy program. Tnat 3 there is not going to be any area of tne plant, from a 4 construction end point prospective, that won't be 5 touched upon in our sampling effort, number one. 6 In the design area that Howard will be talking to 7 tomorrow, and others, I think it will also be clear tha~t 8 there, if it's not covered specifically and directly by 9 CPRT , it clearly has been by others, number one. 10 or if there is any generic implication, for 11 example, a oiekinc area,-large bore pipes analysis, - 12 there will be findings in that area. f~J
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l 13 'de already know of areas where there are 14 deficiencies that are going to be corrected. What's the 15 generic implication of the design process, for example 16 there, that would lead you to look somewhere else? 17 That's the question on the table. 18
~
I don't know for sure today where it is going to 19 lead, but it's certainly on the table. It could go into 20 an area that, I can't think of where right now, but we 21 haven't drawn any conclusions yet, that would touch on 22 ~ something. Doesn't have anything to do with pipe 23 supports or piping system analysis.
,. 24 I think the answer to your question is best, the b
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125 1 days, and if there's still a question on the table, we
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2 necd to revisit it. 3 MR. MARTIU: Okay. 4 MR. VOLLMER: I would like to get back again to a 5 ' question.that.I asked before, oecause I gave you 6 . thinking time to think about your answer. 7 And that is, we have talked about,.for example,~I 8 think an instance Howard is doing on civil, structural, 9 mechanical, and so on. What you're suggesting, I guess, 10 from your previous answer, is that all of his activities 11 will not come under any-sort of a quality assurance 12 program because they don't become a part of a design of [] 13 record. 14 MR. BECK: Some do, Dick. The concrete 15 inspection -- reinspection efforts for hardness clearly 16 falls under our QA/QC " program, and has been executed 17 .that way. Southwest Research did the NDE testing, but 18 they did it under our QA/QC program for. project. 19 MR. VOLLMER: So some parts of the CPRT -- 20 CPRT work will come under what? The -- 21 MR. BECK: Under the project QA/QC program. 22 MR. VOLLMER: Normal project QA QC program. And 23 how is this going to be defined? Is this going to be 24 structured in the next couple days? L.- 25 MR. BECK: Yes. You will understand better how GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
126 1 that falls out. I don't want to go into the -- I'm not 2 sure I can go into all the detail that woule lead you to 3 that understanding you're seeking, I think, 4 specifically, where it does and didn't apply. 5 HR. VOLLMER:- Okay. So some of this work will 6 clearly become part of design decisions'and perhaps be 7 input designs. So it should be, although it won't be 8 design of record in the sense that they will be 9 necessary final calculations, final design drawings, 10 they will have some principal ingredients, perhaps 11 criteria direction and so on. 12 In other words, I'm wondering how anybody will ever [] 13 be able to look back and decide 'n i retr'ospect to how 14 some of the decisions are made. 15 MR. BECK: Okay. The track record will be very 16 clear. And, Bill, I think you wanted to add something. 17 MS. GARDE: One thing that perhaps, Dick, isn't 18 very clear to you yet, because Mr. Hansel hasn't been up 19 or Mr. Levin. 20 Any deviations they find, design and/or 21 construction, are going to result in a nonconformance 22 report. That nonconformance report then flows to the 23 project. We are then under the QA program of TUGCO. We 24 p-] L.a will resolve, and that record will be available to you 25 on how we dispositioned a nonconformance. GODFREY & AMES COURT REPORTING Hetro 469-6100,,. (817) , 460-2048
127 1 It could be, as you're well aware, use as is. We 2 may change it. Change out the thing, whatever. That . 3 will be available. 4 When you get into Mr. Levin's area, where he is a 5 third-party. .We are not applying our program to the 6 third party because it w'ould give unduc in flu en c e to the 7 third party. 8 They will in fact come up with recomt.tendations to 9 us, and that will be documented such that if in fact we 10 do fully go with the recommendations, whatever we come 11 up.with as a program to change it, will.be fully 12 documented in accordance with the QA program of TUGCO. ((_ 13 I think some of th's questions you have got, are we 14 applying their QA program to what they are doing in the 15 areas in which it has to be applied. 16 For instance, if Mr. Levin doesn't do design 17 calculation or check a design cale in accordance with 18 their program, one part of it would require a second 19 engineer to determine the cales. But that's as far as 20 it would go. 21 And then it would come to us as a recommendation to 22 take action. And under our QA program, I hope that 23 gives you just a little bit overview. 24 HR. VOLLMER: To the extent they use the 25 terminology independent design review as part of this
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-1 ' program, there should be some control lights of that, of 2 that process, same degree of confidence and final oesign 3 process.
4 MR. COUf;SIL: It's part of -- that is totally part 5 of the CPRT procedures, the review of those procedures, 6 ano.the approval of the procedures, and how this work 7 would be conducted. 8 MR. BECK: But it's not -- appreciate the 9 difference with me. It is not subject to project coming 10 in and looking over the reviewers shoulder as far as 11 QA/QC is concerned. That just gets untenable. 12 MR. MILHOAN: Jim M11hoan. Without reliance on [] 13 o'ther wdrk and in the third party, I think the term was 14 used, third party design review program,' design adequacy 15 program. 16 Do you expect that program, without reliance on 17 other work, to reach conclusions with respect to the 18 adequacy of the cont.rol of the design process in each, 19 let's say the five major design discipline areas? 20 Mechanical systems, mechanical components, civil, 21 structural, electrical, and instrumentation and 22 controls? 23 MR. BECK: That program will rely very heavily on
'24 work that other people have done. Much of it is a L.;;
25 review of work that other people have done, and the 4 GODFREY & AMES COURT REPORTING Metro. 469.6100, (81.7) 460-2048
129 1 methodology they nave used to' output the results. 2 So in tnat context, it does reiy on.what otner 3 people have done. I'm not sure I follow the gist of 4 your question. 5 MR. MILHOAN: Well, you mentioned you have the 6 CYGHA work. 7 MR. EECK: In that specific case, CYGNA has done an 8 independent capital-I protocol controlled effort. CYGNA
-9 will have results from that effort. Those results will 10 in socie instances be, in their mind, unresolved issues.
11 That will serve as an input to the design adequacy 12 program, and will have responses to them. We will make {_ 13 sure they understand what our response is and how we got 14 here. 15 But we are not going to look at the CYGNA 16 independent assessment program, other than the results 17 that come out of it. 18 MR. MILHOAN: Let me ask another question. With 19 respect to the scope of the third party design review, 20 does the previous design review efforts affect the scope 21 of what you're going to look at with respect to the 22 breadth and depth of review? 23 MR. BECK: No. 24 MR. MILHOAN: And each of the five design 25 discipline areas, are we going to hear about that later? GODFREY & AMES COURT REPORTING
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130 1 MR. BECKi You will hear about it tomorrow at 2 length. But the answer is no, the previous design 3 reviews are not impacting our scope. In many instances, 4 CPRT has not looked at what was done in previous design 5 reviews. We couldn't even know, or don't knou yet. 6 I'm not sure whether there's another question 7 brewing back there. 8 MR. MILHOAN: It was an internal discussion between 9 Dick and I. 10 MR. BECK: The last subject I'd like to touch on is 11 overall schedule and resource leading. You will be 12 hearing later today from John Hansel, and tomorrow from [j 13 Howard Levin regarding their schedules specifically for 14 the construction adequacy, QA/QC program adequacy, and 15 the design adequacy tomorrow, self-initiated efforts. 16 Absent significant scope expansion, you understand. 17 It's a living program with an expension potential built 18 in, or hardware modifications. 19 These and all other CPRT efforts should be complied 20 by this coming winter. Implementation completed. 21 With regard to resources that are dedicated to the l 22 CPRT effort on behalf of TUGC0 and all other parties 23 involved, the manpower estimates to date, and projected 1 24 into the completion of the program, is an effort
- 25 approximately 15 to 20 times the size of the TRT effort, GODFREY & AMES COURT REPORTING
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l' t 13! I for example. We're looking at somewhere between 750 ar 2 a 1000 man years for this CPRT effort. 3 If there are no other questions,.we'll resume at-4 1:45. 5 li R . EISZbHUT: Tnere are, yes, sir. 6 MR. BECK: I'm sure there will be. 7 MR. EISENHUT: I'm -- I was going to -- there 8 questions that I was wanting to -- I want toexplo{ 9 this schedule thing and the resource thing, obviou!
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10 a later time. I don't think I need to here. 11 But when we do, I would like to talk about 12 resources in terms of, howmuchdoyouenvision{ [,, 13 mainline program? And how much do you en. vision 1 N' %., 14 overseeing program of your independent groups, et ,q 15 cetera? I would like to have the feeling of how much, 16 what the breakdown of that is. 17 As I said, I don't think I need to now. And as far 18 as the schedule is concerned, I appreciate it's 19 sufficiently flexible, that we're all going to have to 20 evolve and develop before it's going to pin down any 21 more. 22 MR. BECK: Yes. That's why I can't be any more 23 specific than I was, but the program as structured falls 24 into that time frame. 25 MR. EISENHUT: I'm surprised you were as specific GODFREY & AMES COURT REPORTING ,
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x \ 132 1 as you were. 2 HR. N00NAH: John, maybe I have just one 3 question. 4 MS. AXELRAD: I have a suggestion. The senedule, I
, e 5 assume you were talking about licensing sometime after 6 the pro, gram is c'o;plete. I think one thing you should.
7 keep in mind -- 8 HR. BECK: I didn't hear your assumption. 9 MS. AXELRAD:. Licensing of the plant would probably 10 occur sometime after this winter, after the program is
. .1 1 comp eted, and everything goes as'such.
i 12 But I think'one thing you should keep in' mind is (] 13 that certain things were approved by instrumentation for 14 fueling your justification, for not putting the 15 instrumentation into the first refueling, might have 16 been an assumption that the staff approved back in 17 1983. WNen they assumed your first refueling, would be 18 in 1985. 19 And so you ought to consider whether we'would need 20 a license condition, or wh' ether yo should get[that kind 21 of instrumentation installed prior to licensing. 22 HR. YOUNGBLOOD: You have several items that are 23 that way in here, John. 24 HR. BECK: I understand. s. 25 MR. YOUNGBLOOD: And you should give us a date 1 , 1 (
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133 1 specific, if not prior to five percent, prior to five 2 percent if we're going to be licensed next month -- 3 prior to five percent. 4 MR. BECK: I understand. 5 MR. NOONAN: John, just a little on the program 6 plan. When do you visualize we'll start seeing this 7 thing in some detail? 8 MR. BECK: Before July. 9 MR. NOONAN: Do you see a need for us to sit and 10 talk about these details? 11 MR. BECK: I think the advantage we're getting from 12 the input here today and in previous meetings and - (] , 13 discussions is going to be sufficient for us to publ'ish 14 a document that's going to be very close to the mark. I 15 don't anticipate that it's going to be perfect. 16 And as I said, it's an open program. But we want 17 to get it out, complete, and on the street. And we're 18 shooting for the 28th of June, as a matter of fact. 19 MR. NOONAN: Okay. 20 MR. BECK: All of it. Any other questions, 21 please? Mr. Hansel, enjoy your lunch. You're on at 22 1:45. 23 (Whereupon there was a recess.) 24 fq s.g 25 GODFREY & AMES COURT REPORTING Metro 469-61,00, (817) 460-2048 _ _ , _ _ _}}