ML20129A628
| ML20129A628 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/13/1985 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20128G622 | List: |
| References | |
| NUDOCS 8507150354 | |
| Download: ML20129A628 (163) | |
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NRC/TUGC0 MEETING l
VOLUME II AFTERNOON SESSION GODFREY & AMES COURT REPORTING CERTIFIED SHORTHAND REPORTERS 1106 W. PIONEER PARKWAY SUITE 400 -
l ARLINGTON. TX 76013 .
(817) 460 2048, METRO 469 6100 '
COMPUTER AIDED TRANSCRIPTION vt0E0 TAPE SPECIALIST g ,g g 3 3, 3 p. 5 DAILY COPY 8507150354 850703 PDR A ADOCK 05000445 PDR
134 1 AFTERNOON SESSION N
-- 2 JUNE 13, 1985 3 ,
PR0C EED INGS 4 MR. NOONAN: Let's be seated. We'd like the 5 meeting to begin. I guess we're ready to go back on the-6 record.
7 MR. BECK: Vince, thank you very much. John Beck 8 again. I'd like to introduce Mr. John Hansel, who is 9 review team leader for the QA/QC area. And also review 10 team leader for the adequacy of construction and 11 QA/QC adequacy self-initiated action on the part of 12 TUGC0 and the CPRT.
13 Mr. Hansel many of you know. I won't belabor too J
14 long the fact that he is an eminently qualified expert 15 in the area of quality assurance / quality control, 16 currently serving as president of the American Society 17 for Quality Control.
18 John has had over 30 years of experience in the 19 QA/QC area. He has lectured around the world on that 20 subject. China and Europe, as well as the United 21 States. He served as a consultant to Bavtel on the 22 Ford Foundation -- the Ford Amendment Report. Excusc 23 me.
- 24 He also served as a consultant to Co==onwealta 25 Ed'ison Company on the Byron and Braewood plant efforts, GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
135 1 insofar as QA/QC was involved.
2 Without further ado, John, the agenda is yours for 3 the afternoon. .
4 MR. LIVERMORE: Could I ask a question before we 5 get. started there?
6 MR. SECK: Me or John?
7 MR. LEVIN: I want to pose to Bill Counsil.
8 MR. LEVIN: One of the things you went through, you 9 talked about your safety ethic or your top management 10 ethic, where management is a state of mind, and you 11 instill safety ethics in all employees.
12 And you also went on, you talked about the CPRT to 1 13 charter. It mentions safety. And you talked about l 'J .
14 FSAR commitments.
15 And I guess what bothered me, the first -- until 16 about 10: 30, I never heard the word quality. And it l
l 17 just bothers me that I didn't hear that at all.
f 18 We talk about management ethics, safety ethics.
! 19 But the word quality didn't slip in there at all. And 20 that was certainly appropriate, I would say.
21 And I guess what I'd like to do so I don't have any 22 misconceptions, I'd like to get your version on quality 23 and its role in the organization if you wouldn't = ire.
__ 24 MR. COUNSIL: Sill Counsil once again. My vieu: On
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25 quality: Number one, I believe that you cannot inspect GODFREY &~AMES COURT REPORTING Metro 469-6100, (817) 460-2048 r __. . _ _ _ . . ,-
136 1 quality into a project. And I'think I alluoed to this
.- 2 this morning in a very short brief I gave you on my 3 safety ethics.
4 That is, do it right the first time. Have the 5 proper procedure.s, implement those procedures, and 6 inspect to insure compliance with those procedures. Now 7 I think -- I believe it's Herb 7 You are -- come from 8 the inspect portion of it, which is quite often a 9 quality assurance / quality control function.
10 I believe that to insure quality, number one, you 11 have to have a fully qualified'line management, and hold 12 the line management responsible for not only r~~ 13 construction quality, but quality of operations, once e_ .
14 the plant becomes operational.
15 A staff function is quality assurance and quality 16 control. They insurance the compliance of that 17 organization. If they find deviations in their 18 inspection process, they insure that line management not
.19 only corrects it, roots out -- finds the root cause, 20 changes procedures, practices, whatever is required, and 21 then insures after that, that it is being appropriately 22 implemented. Does that answer your question?
23 MR. LEVIN: Somewhat. I was really waitin; to hear
. . _ 24 that management state of mind of quality, trickle dcun 25 effect, starting with you at the' top.
GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048.
137 1 MR. COUNSIL: Well, I'd say it's not a trickle down
_j 2 effect. It's a rush. I don't believe in doing things 3 part way, or letting it trickle or anything else.
4 Any NRC people that's sitting in this room that 5 have attended meetings with me, who have heard me before 6 put on presentations at Northeast Utilities, when I have 7 found things wrong and whatever done to correct them, it 8 certainly isn't a trickle down.
9 And it won't be too long before all employees here 10 at TUGC0 know of my attitude and what I believe is 11 safety first.
12 MR. EISENHUT: In fact, I can speak from 13 experience, hare, Bill. Let me make one comment. I was t -
14 encouraged to hear your first answer that you rea'11y ,
15 don't inspect safety into a plant. And I think 16 that's -- nothing can be farther from the truth. I mean 17 I really strongly believe that myself, and I'm 16 encouraged to hear you say that.
19 I think what Herb is referring to is, any timet you 20 have found an organization that has the right safety 21 ethic, safety approach, it emanates fro.T a few key 22 people in the organization. And I think it's not meant 23 it was trickling down slowly. I don't tninx that aas
_ _ , 24 the point.
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25 MR.-LIVERMORE: No.
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138 1 MR. EISENHUT: It was really, that message
. _ 2 permeates the organization and comes from the key 3 players.
4 And so in that context, I agree with you. Also 5 from knowing you.for a number of years, it's more the 6 sledgehammer intimidating approach.
l 7 MR. COUNSIL: I wish you wouldn't use the word i
8 intimidating approach.
9 MR. EISENHUT: No. But I do, because there is good 10 intimidation. There is bad intimidation. So -- but it 11 really is intimidation by itself, is not necessarily bad 12 unless it, you know, -- bad. intimidation, I guess. But 13 some managers intimidating, I think that is a fact of 14 any basic management.
j 15 But I think what we're really looking for, and only 16 time will tell, how fast that approach permeates the
- 17 entire organization. And I think that's really where l- Herb is coming f' rom.
18 19 MR. COUNSIL: I understand. And I'm doin5 my I
l 20 darned best to make sure that it does that. People have l
21 the attitude -- I do, and I'm sure have a feel for the 22 attitude, I have come that far, Herb.
23 What I haven't been able to do yet is to insure
_ _ _ . 24 through meetings with the= and other t r. i n g s , Onat t r. S y
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25 have, quote, the full safety ethic that I have. Do it GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
139 1 first the right time. Rework costs money. Inspections
_ _ 2 cost money. Meetings like this cost a lot of money.
3 And I firmly believe ensuring that the procedures 4 and the programs are right, and then live to them. And 5 that's the message I would hope that we are getting to 6 you today.
7 MR. LIVERMORE: Thank you.
8 MR. HANSEL: Thank you, Bill. Just another bit of 9 levity before we get started. Bill came over and said, 10 " John, do you mind if I sit at the front table."
11 And I said, "Not at all. Just don't intimidate 12 me." '
13 It's been like a breath of fresh air with Bill L -
14 Counsil hear. We have had nothing but good. response.
15 I'll back up what'he said. We have had excellent 16 relationships.
17 Okay. With that, again, as John Beck indicated, my 18 name is John Hansel. I'm the Q /QC review team leader 19 for the CPRT. These are the subjects that I'm going to 20 talk about this afternoon. And hopefully I have put 21 together a-presentation that will give you a total 22 understanding of the approach that we're going to take 23 that it is integrated.
,_ _ 24 And it is well tied together with the :ner Oc;e0:s
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25 of the CPRT. I'll start out by talking about the GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
140 1 objectives, and then going to talk about the elements of
_ _ 2 the plan. And we have several of those.
3 And I will talk about the interrelationships of the 4 various elements between our effort and the efforts of 5 the remainder of the team, and some other TUGC0 6 activities.
7 I'll talk about our collective evaluation process, 8 root cause generic implication process, trending 9 programs. Talk just a very bit about schedule in our 10 organization. And I'll represent to you what our end 11 products are.
"12 MR. NOONAN: John, I wondered if I could interrupt 13 you just one minute here. In February and March we met L J 14 with the utility, and we talked about some of these 15 plans. Can you kind of pu.t in prospective where you're 16 at today compared to what you were doing in February, so 17 we will know?
18 MR. HANSEL: Kind of bring you up from February to ;
19 now?
20 MR. NOONAN: Just a little bit.
21 MR. HANSEL: Of course we received the letter from 22 ycu folks January the 8th. We did meet in February and 23 talked about the exchange of that.
_ _ 24 We met subsequent to that here in Arlington at the 25 Holiday Inn. We're well on our way toward the GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
141 1 investigation of those specific issues that were
_ _ 2 identified in the January letter. Issues, specific 3 plans have.been written. The implementation has 4 started, and in some cases very close to closure.
5 Likewise, as other SSER 's have come out, we have 6 reviewed those. In fact, to be certain that there were 7 no new issues that were identified in those SSER 's, and 8 where required, we have gone back and issued our 9 modified plans.
10 Unless you really choose to, I would not want to 11 get back into the specifics of each of those plans 12 today. -I can just tell you in general that we're well
- L 13 on the way. We have conducted some inspections. We L .-
14 have conducted a lot of documentation reviews. We have 15 conducted a number of reviews of procedures.
16 I had a number of interviews. We have been in the 17 field and looked at the hardware extensively. And we're 18 well along on the initial set of issues that were 19 provided to us.
20 I'll show you later, Vince, the current list of 21 issues specific action plans that we have, botn in the 22 programmatic area and in the hardware area. If you 23 choose to question of them at that cime, I'll 'ce ; lad ::
,_ _ 24 de so.
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25 MR. NOONAN: Okay. That will be fine.
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142 1 MR. HANSEL: What's our objective? It's our
. . 2 objective to provide reasonable assurance that there are 3 no undetected and uncorreeted safety significant 4 deficiencies at the Comanche Peak station.
5 I'm going t.o approach that first by talking about 6 the specific external issues. John Beck showed you a 7 list this morning of the sources of those external 8 issues. I will repeat that this afternoon.
9 We will also go through a root cause and generic 10 implications evaluation on each of those issues to 11 satisfy ourself that, yeah, verily, they have in fact 12 been resolved satisfactorily, and that there are no
' i j 13 remaining implications that need to be resolved in 14 respect to those.
15 We feel that by review of those initial sources 16 that we will have a good level of confidence. That we 17 do not have any undetected safety significant 18 deficiencies in the p'lant.
19 'de have designed and are well on the way to 20 implementing a self-initiated program of reinspection 21 and documentation reviews that will give us an e r. t r a 22 level of confidence. That will extend to the remainder 23 of the plant.
_- 24 If you would for a moment --
25 MR. CALV0: Jose Calvo for the NRC. About tnis GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
143 1 finished program, will we hear about it in detail later
_ _ _ _ 2 on?
3 MR. HANSEL: Going to talk about it in detail. May 4 want to run me off before the afternoon is over. If you 5 would, for a moment, ignore the cross hatched marks in 6 the first two blocks.
7 The elements of the plan consist of the first two 8 blocks, which deal with issues identified by external 9 sources. As I indicated, I will show you what those are 10 in a second. We have broken those down into 11 pnogrammatic and hardware issue specifics that we will 12 investigate very thoroughly.
I 13 The center block, and let me back up. The first L J 14 two I'm going to be addressing later on as category 1.
15 The third block, the center block, deals with a 16 hardware reinspection and documentation review plan.
17 We're going to refer to that as a category 2 issue, 18 specific plan, and that is the self-initiated program.
19 The fourth block addresses the interface that we i
20 will have to the other review team leaders. 'd e have had 21 extensive interface, and will continue to hate i r. t e r f a c e 22 and dialogue, with the other review team leaders in the 23 investigation of any of their specific external is:ues.
__, 24 kle have conducted inspections for tnem. .le have
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25 conducted documented reviews for them. Anything that GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
144 1 they find in the review of their issue plans that
. . 2 indicates thatJthere may be something we need to look at 3 in the QA/QC area, they provide that to us. We either 4 include it within an existing issue plan, or we will 5 create a new one..
6 By the same token, the information that we gain 7 that may fit into one of their categories, there is a 8 close dialogue. There is an interface established on a 9 case by case basis on each -- each item, be it root 10 cause or generic implication study that we conduct.
11 The block to the far right deals with other 12 programs, not specifically from external sources. The l 13 design adequacy plan is in there. Other inspection L J ,
14 activities that have taken place to date on cable tray 15 hangers, as built, these kinds of things we also gather 16 information from those programs.
17 The two center blocks we'll talk about the 18 collective evaluation process. And we-will gather data 19 for two purposes. One is to address the adequacy of the 20 construction QA/QC program. And we will receive input 21 from all of the five sources identified above that feed 22 into that.
23 The other one that we will address is the adequacy
__ 24 of the installed hardware. And we will again ecllact 25 data from every source identified above to feed into GODFREY & AMES COURT REPORTING Metro 469-6100, (S17) 460-2048
145 I that.
_ _ 2 From those rive sources of data, we will do a 3 collective evaluation, two collective evaluations,.to 4 answer those questions. And then finally there will be 5 a-summary report.put out on our effort.
6 Next chart. In the first two cross hatched blocks 7 that I talked about are the category one issue specific 8 action plans. And they address the issues that have 9 been and may continue to be identified by external 10 sources.
11 We are reviewing external source documents, and 12 identifying any item in there that we feel is a concern i
j 13. or a very specific issue that we should address. We t J .
14 have a matrix that we're preparing and maintaining to 15 assure that we have each of those identified and cross 16 tracked to an issue plan or some form of an 17 investigation, if in fact they have not already been 18 closed to the satisfaction of the staff.
19 MR. SHAO: Are the concerns in SSER number 11, 20 would be in t'his category?
21 MR. HANSEL: Yes. SSER 11 and all other SSER 's.
22 The previous letters that we have received, the CAT 23 report, SIT report, Region 4 reports.
__ 24 In a second, SSER 11 will be included in tna:
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25 review.
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146 1 MR. CALV0: You also will have the Region 4
_ _ 2 inspection report? How far do you go back?
3 MR. HANSEL: Back to anything that is not closed.
4 Open issues.
5 MR. CALV0: Go back to the last ten years?
6 MR. HANSEL: Open issues. Those remain at this 7 time. And any new ones that are received that apply to 8 our effort.
9 MR. CALV0: Maybe you wait long enough, you know, 10 all the causes, and then you won't have to look --
11 MR. HANSEL: We're not waiting. It is an ongoing 12 process,-and has been for us since last November.
13 MR. SHAO: In that process, appendix P is new.
J 14 Have you thought of how to handle this appendix P?
15 MR. HANSEL: I have reviewed SSER 11. I received 16 it. late last Thursday night. I have read it, quite 17 quickly, I might add, because it was preparing for this 18 meeting.
19 We are conducting a detailed raview. And exactly 20 how we will approach appendix P, I'm not certain at unis 21 time. We will, however, have that resolved price to One 22 submission of the program plan and our issue plans that 23 you will soon have, I think John indicated by the end
-, 24 of June.
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25 MR. NOONAN: John, let me ask yo'u a question.
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147 1 Anything that comes out of your safety --
_ _ 2 MR. HANSEL: I'm sorry?
3 MR. NOONAN: Anything that comes out of the SAFE 4 team work, does that fit into the external sources?
5 MR. HANSEL: I think that John Beck and Bill 6 counsil indicated this morning that there may be some 7 spillover into our effort, if in fact it fits into our 8 current scope of work.
9 I am doing two inspections now at the request of 10 SAFE team, where they have given me some area of concern 11 that they felt needed inspection by.an independent 12
- party. And.we're doing those. That system is working.
13 MR. EISENHUT: Let me expand that just a little L -
14 bit. I was thinking of from a little different angle.
15 But that's a different point Vince brought out.
16 There's been a lot of discussion in the hearing 17 process in the general area of intimidation and 18 harrassment. And there are -- there was quite a number 19 of issues that were identified and questions and 20 concerns.
21 Without looking at the merits of them one way er 22 the other, is there.a vehicle for that kind of 23 concern -- that kind of issue, if there would be
__ 24 considerations also being factored into the program here
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25 as another external force, that SAFE team would secedow ,
i l
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-. - _ . ~
148 1 factor in? Is there an avenue to permit --
there is i _ _ 2 evaluations, reports of intimidation and harassment, 3 that turn out indeed to be substantiated.
, 4 How do you factor those into the question of, did l 5 intimidation affect the overall program conducted at 6 all?
7 MR. HANSEL: That's a difficult thing to 8 determine. Again, in most of these cases, and we 9 certainly know that there were allegations in this area, 10 It's very difficult to tell, Darrell, if in fact it did 11 have an impact on the hardware.
12 I have to* approach it from two ways. If I were to 13 know of a specific, I would have to look at that
- c. -
14 specific piece of hardware. And if the hardware were 15 okay, I would draw a conclusion based on that.
16 One of the reasons for our self-intitiated program, 17 certainly is some of the background information in this 18 area and the concern. Our -- we're going to conduct a 19 sampling reinspection program representing all the 20 hardware, safety related hardware, in the facility.
21 And hopefully from that we will be able to draw 22 conclusions. We will be able to draw conclusions as to 23 whether or not anything of that nature did in fact have
,_ -. 24 an effect on the hardware. It's a very difficult item
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25 to investigate, unless you have a specific --
the bes:
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149 l
1 way I know to attack it is to go on a sampling basis, l
__ 2 which was our recommendation.
3 MR. EISENHUT: Yeah. I appreciate it, even though 4 it's -- well, Counsil and I were commenting, 5 intimidation is a very, very difficult subject, because 6 you can have an intimidating atmosphere or intimidating 7 individuals, and I think -- and even I have been accused 8 of being intimidating by my staff. It's perhaps.not 9 necessarily bad, because you're driving to get the job 10 done. You're driving to do it right. You're driving to 11 make sure all safety issues are resolved.
12 But you at the same time have got to come up with
13 i a first where you have specifies you can follow-up to LJ 14 see whether or not there is a -- whether it really 15 materializes.
16 MR. HANSEL: I can test the hardware by looking at 17 it.
18 MR. EISENHUT: It's the second tier of that. That 19 is a little more subtle, where you can't really include 20 intimidation one way or the other per se. And it's T. ore 21 of a vague charge that the overall atmosphere is to 22 intimidate and push things along really faster. There's 23 nothing you can really hang on.
_ 24 And that's why -- I was trying to get a feel fcr
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25 how that information can get back to them, because --
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150 1 MR.-COUNSIL: Could I have that?
_- 2 Bill Counsil again. I did check at the lunch break 3 that very subject to our corporate general ~ counsel, 4 'because I was interested. And I hope I will have some 5 more information.for you on that this evening before the 6 close of the day.
7 But on, specifically, intimidation allegations, to 8 the best of our knowledge, there's been one verified to 9 date, and that has been afforded to the administrative 10 judge. So that that would get into the process. And I 11 understand that there's one other review right now.
'12 MR. EISENHUT: That have the origin in the SAFE 13 team?
14 MR. COUNSIL: That's correct.
15 MR. EISENHUT: Okay. And.then I was only 16 extending the question very slightly beyond that to say 17 that, in addition to the SAFE team, there was quite a 18 bit of discussion dialogue process, a number of other 19 vehicles for that discussion, that really don't have 20 their origin in SAFE. team. And it was the same question 21 I was trying to explore. And I' don't know wnether tnere 22 is an avenue, or how to get that other information 23 factored into the overall umbrella either. But I think
, . - - 24 that's something we're all going to have to continue ;c
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25 look at, is the way~to do that.
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152 1 MR. HANSEL: I wrestle with that one very hard.
, _ 2 It's difficult when you're dealing with allegations or 3 intimidation, as to how to research those. And the only 4 proof -- I know what makes me feel better, is if I find 5 the hardware to be right. Then you have- to say that the
~
6 system must have worked, in spite of the harassment and 7 intimidation.
8 MR. EISENHUT: Yeah. Has the company done anything 9 independent of the CPRT? Bill, I'll direct this to 10 you.
11 Has the company done anything to -- there's been, 12 over the years, there's been charges of intimidation and 13 harassment. Has the company done anything, what I'll L -
14 call systematically, before SAFE team, to go back and 15 interview the people? Bring in whoever it wou.1d be, a 16 group, whose business it is, so to speak, looking into 17 intimidation?
18 If there is such a qualified people to look at the 19 subjects and look at all of the sources of charges of 20 intimidation and harassment, and package it up, so to 21 speak, has the company done anything like that?
22 MR. COUllSIL : Bill Counsil again. I'll take it.
23 As far as that subject is concerned, through the SAFE
_ _ . 24 team effort, we schedule interviews with all emplcyees.
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25 Employees.who are, quote, being laid'off, are also GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
152 1 scheduled in for interview. So, as well as the
_ _ 2 volunteers, have come under the program. There are 3 scheduled interviews each week. And on our bi-weekly 4 reports, the numbers of personnel who have been 5 interviewed are covered.
6 By and large what's been occurring on the 7 scheduled interviews and the interviews of people 8 leaving the site so forth, that is, they fall in the no 9 concerns category.
10 Now as far as how to package all this up, Darrell, 11 I can't answer that right now. I don't honestly know 12 how to package it yet.
13 MR. EISENHUT: Yeah. And my question went actually L -
14 a little -- as I understand the SAFE team concept, went 15 into effect, let's say January of this year.
16 Before.that, there was another program. But many 17 of the concerns go back actually, let's say go back 18 years, in fact, because quite a bit of the construction 19 is done much earlier. Many of the people left the 20 project much earlier.
21 So the best I think you can hope for in those 22 areas, is that there may be identified incidences or 23 charges, ideas, whatever. And I was really more leching
_, 24 pre-SAFE.
25 I think the approach of the SAFE team is an GODFREY & AMES COURT REPORTING Metro 469-6100, (517) 460-2048
153 1 approach which strongly has encouraged; undertaken has a
_ , 2 means of attacking some of those problems. And the 3 overall effectiveness of an effort like that, we're all 4 still hoping to learn from, by and large, in our entire 5 industry, and th.e government.
6 I was~really more focusing on those incidences that 7 go back several years, let's say. Spanned a period of 8 time when much of the plant was built, and the personnel 9 moving on to a different facility, different site, or 10 whatever, or out of this, to try to systematically look 11 at that. And of course you are aware we are looking at 12 all of the documented records, and trying to see what it 13 means. And that's why I was asking you about that.
,." ]
14 HR. COUNSIL: To the best of my knowledge right 15 now, we have not gotten together an entire program.
16 Somebody can correct me, if possible, in the room. But 17 a counter, systematically to go back before the SAFE 18 team and do this resurrection.
~19 Any open areas, however., are being rolled into 20 these QA/QC issues items that we're looking at. And we 21 are going back and reinspecting hardware. That's as far 22 as I think I can go right now.
23 MR. EISENHUT: So it would be fair to say, tnen, in
,_ 24 this effort, really between the lines, you have SAFE i' ~
25 team. As in other matters, you have other open GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
154 1 intimidation questions as inputs to the program, s.
__ 2 MR. COUNSIL: That's correct.
3 MR. HANSEL: Yes. -
4 MR. CHANDLER: If I can follow-up on what Carl was 5 asking. Larry Chandler. Talking to Bill or John.
6 Bill, in response to your last comment, John also 7 mentioned going back to look at the hardware, in 8 association with the allegations of harassment and 9 intimidation. Are you also going back and looking at 10 .the other QA/QC activities, paper flow, and all of that?
11 MR. HANSEL: Yes. We're doing a number of 12 procedure reviews. There will be documentation reviews
, 13 included in the reinspection self-initiated program as 14 well. So, yes, we're looking at it across the board.
15 Just as a point of interest, Darrell. One of our
. 16 actions plans deals with exit interviews. And we have 17 talked to those folks, both prior to January, 1985, in 18 that effort. And currently we understand the process 19 and what's happening there. And if we see any need for 20 recommendations to TUGCO, we'll do that as a result of 21 'that effort.
i 22 MR. CALV0: Quickly, the results for the 23 independent assessment program of CYGNA, do ycu consider
! m, 24 those as external sources or other investigative
! 25 programs?
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}
155 1 MR. HANSEL: Other investigative programs, the far
__ 2 block to the right, other investigative, from my 3 . viewpoint.
l 4 MR. MARTIN: John, Bob Martin, one more. question.
5 Is the -- you described that the open issues remaining 6 in inspection reports, you are factoring in into the 7 program as one of the inputs.
8 MR. HANSEL: Yes.
9 MR. MARTIN: Is that consistent with the logic you 10 have used on other documents that have been provided~ to 11 you?
12 I think perhaps there have been specific issues in i
13 SER 's, SSER 's, in which the safety significance has L_
14- been dispositioned as the NRC has reviewed it. And said 15 there is no safety significance associated with this.
16 And it may have some QA/QC implications.
17 If NRC has judged-that a specific hardware item 18 deficiency has no safety significance, are you still 19 considering that as an input to your program?
20 MR. HANSEL: Let me take it this way, Bob. On that 21 individual case,' I -- probably not. But I would l i!< e ,
22 in the collective basis, and if I think there is enougn 23 implications of more hardware that could be affected,
_, 24 .either in that population of hardware or others, we'll
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25 search that out.
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156 1 The other thing I'll look at is, from the
. _ 2 programmatic standpoint, is even though the hardware is 3 okay, there must have been something that caused concern l
4 there. Then we'll search out that avenue.
5 MR. MARTIN: Okay. Would that not then -- or go a 6 similar approach from NRC inspection programs, would not 7 only be the focus of remaining issues which are 8 remaining open, but-to look at the significance of 9 issues identified in the inspection program -- in the 10 inspection program, but possibly closed in a prior year, 11 but in fact represent an issue that may be under that 12 kind of an umbrella, would deserve a broader look, 13 rather than not treating it in your current program?
u -
14 MR. HANSEL: Let me' answer that from two 15 standpoints. ' Excuse me.
16 We looked at and have reviewed Region 4 reports 17 back, I guess probably close to two and a half, three 18 years, open and closed. I think that the key point, 19 Bob, is that if there were -- let's talk about hardware 20 specific items.
21 That where you had generic' types of problea.: in ne 22 past, that which would also hit a good sizable amount of 23 those in the reinspection effort.
_, 24 Again, I think when I get to the self-initiate:
25 program, you're going to to see that that is broad GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
157 1 enough and all inclusive enough, that we will have
_ _ 2 touched upon a pretty good sized portion of the plant 3 that should later rest any past concerns, whether open 4 or closed, without going back and re-reviewing and 5 addressing each of those past Region 4 reports, or even 6 other reports from the staff.
7 MR. NOONAN: Someplace in here~, John, we have an 8 SER that we sent to you on the coding area. We said 9 basically that was a non-safety -- paints themselves a 10 non-safety issue. But clearly there are some 11 QA/QC implications in that SER. How is that being 12 affected?
t i 13 MR. HANSEL: Yes. Well, a couple of places. One t J 14 is there is a material traceability problem in there.
15 We're going to pick that under the materials 16 traceability issue plan, which we have. Also there is 17 some craft inspection training type of issues. We'll 18 pick -- we're looking at that now.
19 So even though it's declassified, we're still 20 looking at those, for the i=plications events on the 21 program, because there was something at ene tide that 22 caused a problem there, even though it's been 23 declassified.
_, 24 MR. CHANDLER: Larry Chandler again. Ycu also ueed
' ~
25 the term safety significant. Earlier this morning John GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
I 158 1 Beck sort of begged off answering my question on that.
- - 2 Are you using the particular definition of the term?
3 MR. HANSEL: The deficiency that you detect on a 4 piece of hardware will cause that hardware to not 5 perform. It's a safety related function. And that will 6 be looked at on a case by case basis and a collective 7 evaluation.
8 .Okay. Let me move. ahead, because I think a lot of 9 these will get answered later.
10 MR. CALVO: I want to go back to the original 11 report. I don't even guess there is an answer. Are you 12 going to look, going back, are you going to look at the 13 good and the bad, or what the original reports show u -
14 you? Or where the real report maybe shows some 15 constructions and maybe some designs problems? If you 16 feed it back, are you going to look at it, or not? No 17 use saying the overall program is going to consider.
18 But you are not answering the question. Will you please 19 answer?
20 MR. HANSEL: I do not plan to go back currently 21 more than two and a half or three years, which I have 22 already done.
23 MR. CALV0: But tne assessment you ;ct ever the two
_ _ 24 and a nalf, three years, that is going -- it can affect
~
25 your program here, whatever you learn from those.
GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2046
b 159 1 MR. HANSEL: Yes. Certainly open items, and 1
2 something I see in th'ere that may have been reoccurring,
)
3 and -- or something in question, we'll pick that up.
4 MR. CALVO: On the cross items, when you look at 5 the cross items, and you figure out that you may have 6 some generic implications, are they reflected to design 7 or reflected back to some other area? The way you're
! 8 going to look at the PFP SER, you may look at'the things i
i 9 that are crossed out, or find them acceptable? Are you
^
10 going to do the same thing for the inspection reports?
11 MR. HANSEL: Yes, I think I followed everything you 12 were saying there, but I believe -- yes, yes.
1 t
I 13 we.will look -- let me say it again. We will go L J 14 back two and half to three years, which we have done.
. 15 Thers is indication there, that something was wrong.
16 Something didn't work as planned.
17 As we're looking at our total program, if we think 18 that we need to look at that area again, we'll do so.
19 Either through a specific action plan or through our 20 self-initiated program.
21 MR. CALV0: Okay.
22 MR. HANSEL: Okay. Moving right along. Once that 23 review of external documents is completed, then we're
_- 24 going to group these from external sources ir:0 either i'~ 25 a programmatic issue plan or a hardware issue plan.
GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
160 1 And they will prepare action plans for each of those as
.- 2 we go next time.
3 The methodology that we're going to follow, number 4 one, is to make sure that we fully understand the 5 issue. And we may have to call people. We have been on 6 the phone with Herb and his folks a number of times, 7 Herb Livermore, to make sure that we fully understand.
8 "What did you see? What did you observe? What 9 procedures were you looking at," where we understand 10 what the issue is. -
11 We'll then go through and' select an evaluation 12 approach. I'm going to talk about each of these 13 elements briefly in the next couple of slides. We'll u -
14 implement that evaluation approach or approaches, 15 evaluate the results, and then provide the data into the 16 collective evaluation process. Next slide.
17 Cu r r en t ..y , this is the list of external sources.
18 I indicated a moment ago that I had done a preliminary 19 review. It's really more than a preliminary. It's 20 rather a detailed of SSER 11. We'll continue to 21 evaluate that, and make certain that we have etery 22 concern or issue in there covered. And we are 23 maintaining a matrix of those issues versus cert::r
_, 24 issue plans. Next chart.
25 This is a list of the current programmatic issue GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048 J
161 1 plans. They haven't changed much since you saw them
_ _ 2 last time, except that we moved the fuel pool liner over 3 from a hardware issue to a programmatic issue, and 4 retitled it fuel pool liner documentation.
5 We'll add to this list as required. Next chart.
6 MS. AXELRAD: Jane Axelrad, from the office of 7 inspecting and endorsement. Does the intimidation and 8 harassment report fall into the subcategory on any of 9 these issues?
10 MR. HANSEL: I don't have it specifically listed.
11 What I have done is, I was provided through the .
12 attorneys a summary of the harassment and intimidation
' i 13 information. And I have researched myself that list to L.J 14 satisfy myself that each of those items were in fact 15 covered in one of our current issues specific plans. So 16 that's a pretty good summary. I feel that that area has 17 been covered.
18 MR. CALV0: John, I think your slide on the i 19 external sources, there is an error. You indicated he 20 had the CYGNA independent, in spite of external 21 sources. And I believe you indicated that before-as 22 part of the overall investigative programs; is that 23 correct?
,_ 24 MR. HANSEL: I'm sorry. I couldn't -- Jose --
~ ~
25 MR. CALV0: The external sources program, you --
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162 1 CYGNA independent sources program, before that you said
_ _ 2 the CYGNA independent assessment program, you're going 3 to oversee that as part of the overall investigative 4 programs.
5 MR. HANSEL: Yes.
6 MR. CALV0: So this is an error here.
7 MR. HANSEL: No. The primary area that will 8 investigate the CYGNA report is the group, Howard 9 Levin's group, associated with design adequacy. I will
~
10 only get involved-in.that if in fact there are 11 QA/QC implications, and not the design program or the 12 design adequacy.
! 13 But only those implications in there that'might u -
14 deal with the QA/QC side of that issue. So it does 15 appropriately fit in the far right-hand block for me.
16 MR. LIVERMORE: John, question. Herb Livermore.
17 Two things come to mind. Your two reinspections you 18 have going on there, the one on the electrical hanger 19 eclipse, and the other one you mentioned this morning, 20 about the pipe hangers. How would that fit in here?
21 They would certainly be under external sources, cut I 22 don't see them listed here.
23 MR. HANSEL: They're not in tnere spee:rically,
-, 24 Herb. They have -- well, the cable tray P.'ar.ger 30 built
~
25 program came from Region 4 The pipe support program GODFREY & AMES COURT REPORTING Metro 469-6100, (817L 460-2048
-163 1 came_in from where, John? That came to us from?
__ 2 MR. BECK: A number of sources.
3 MR. HANSEL: I beg your pardon?
4 MR. BECK: A number of sources.
5 MR. HANSEL: . A number of different sources. I did 6 not attempt to identify each individual case.
7 MR. LIVERMORE: You are addressing both of those?
8 MR. HANSEL: Yes. We're ~ involved with it.
9 MR. LIVERMORE: They just don't appear here.
10 MR. HANSEL: They just don't appear here as an 11 external source.
12 MR. LEVIN:- Are there any others that you're 13 addressing here?
c._
14 MR. HANSEL: Just the h'its thing that I have just 15 talked about. We have-reviewed that. Nothing else in 16 an external source.
17 MR. HANSEL: There was a question back here.
18 MR. BURWELL: Spot Burwell, NRC. Point of 19 clarification, please. The CYGNA revie- included 20 certain aspects of quality control, particularly with 21 the -- for example, in document control. Am I correct 22 in understanding that you will review the observations 23 in this area as far as your program?
__ 24 MR. H A . S E L : Yes, In fact we already cre. 'l c nave 25 an issue plan on documentation control. Or exists GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
164 1 already, existing or on our way to it.
. . 2 MR. CALV0: When you submit the final program plan 3 for approval, you, also by June 18th, will you also have 4 with you a listing of all the sources with enough of the 5 specific so that,we will understand which external
~6 sources you considered? Is that detailed information 7 -- will become available to us so we can ascertain it 8' together?
9 MR. HANSEL: John, you want to address that?
10 MR. CALV0: I'm going on the basis that we're going 11 to have the program plan by June 18.
12 MR. HANSEL: No, no. End of June.
13 MR. EISENHUT: End of June. June 18 is the meeting u -
14 on response spectra. End of June --
15 MR..CALV0: June 18. That's what I said. 18th.
16 Oh, I'm sorry. I missed it by ten days. I'm sorry.
17 MR. HANSEL: That would be a rough ten days to 18 beat.
19 MR. CALVO: Yeah,'I know.
20 MR.. BECK: Jose, the -- your question, if I 21 understood it. Let me repeat it again, is, will the 22 issue specific action plans indicate which source: of
~ 23 external input are 'ceing used in each instance? I ~ tost
_ _ , 24 it? Or will there be a table that c o v e r s ::e w h o . 2 25 thing?
s GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
165 1 MR. CALVO: Right.
_ 2 MR. BECK: The program plan itself will include in 3 the appendices coverage in general, which specific 4 issues are being addressed as a result of external 5 input. And we have gone over in essence those sources 6 this morning.
7 MR. CALV0: What I'm missing in here is the fact 8 this is incomplete. You indicated there is not quite 9 all of them there. And I would like to know which ones 10 there aren't. The reason for is, your self-initiated 11 thing is going to implement, supplement, or it's going 12 to see all these things. And I'd like to get an overall i
13 idea how all the things --
L }
14 MR. HANSEL: What he's after, John is a-good 15 detailed list of the external sources. And we can 16 provide that.
17 MR. LANDERS: Yes, I asked the question this 18 morning of John. And I thought he told me that you were 19 going to cover it. And that is, the outstan' ding issues 20 that are still in the CAL, and how those are goint to be 21 factored into your plan, and what part of their e:: t e r n al 22 sources or where they fit --
23 MR. HANSEL: You just gave me a new acrcny?. CAL 7
_- 24 MR. LANDERS: Comprehensive action list. For
' ~
25 example, the value that is still there.
GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
166 1 MR. BECK: John, if I could respond. I thought I
__ 2 answered that this morning. Those issues that were in 3 the comprehensive action list that haven't interfaced 4 with CPRT are already directly factored'into the 5 CPRT effort. We have not tried to draw a correlation or 6 put a check mark in the right-hand column of CPL open 7 items that CPRT is considering. There are not very many 8 who fit into that category.
9 MR. LANDERS: We talked this morning, John, about 10 covering an interface between CAL and CPRT. And I'm 11 wondering if the interface is existent in this current 12 program with respect to QA/QC. And'I think I'm going to 13 continue to wonder if it is when we_get into the design J
14 area itself.
15 MR. BECK: Okay. The point's taken.
16 MR. HANSEL: Back in the back.
17 UNIDENTIFIED FEMALE SPEAKER: Are the intimidation 18 and harrassment issues'being dealt with purely from a 19 hardware standpoint, or also from a programmatic and 20 management-standpoint?
21 MR. HANSEL: Both. All of the above.
22 UNIDENTIFIED FEMALE SPEAKER: Pardon me?
23 MR. HANSEL: All of the acove. He're leckin; 3
_- 24 procedures. We're Icoking at hardware. '.i e ' r e 10:1:in;
~
25 at documentation that -- we're covering it all. It's GODFREY & AMES COURT REPORTING Metro 469-6100 (817) 460-2048
167 1 not just hardware.
_j 2 UNIDENTIFIED FEMALE SPEAKER: But'are you looking 3 at the programmatic or management consideration that 4 could affect that? You have haven't --
5 MR. HANSEL: I think I know where you're coming 6 from. Again I -- it's management harassment, 7 intimidation. I don't know how to evaluate that, since 8 I wasn't there, unless I can see an impact on the 9 hardware or in the documentation. That's the only thing 10 I can do. I know of no other way to evaluate that.
11 Unless it had an impact on the hardware or the 12 documentation, I don't know how to do it.
' Okay.
i 13 Next chart, J o h n '. This is a listing of the L J 14 current hardware issue plans. I might indicate that 15 there is a significant amount of interface and 16 interaction between a hardware issue plan and a 17 programmatic issue plan.
18 We may do some investigations of hardware, and find 19 that there are certain programmatic in.plications that 20 need to be researched. If there is a current issue 21 plan in that area, then we'll investigate it through 22 there from a programmatic standpoint.
23 By the same token, when we're reviewing
,_ _ , 24 programmatic issues plans, if we find that On3ra Oculd I
' ~
25 be an impact on the hardware, then we'll approacn in GODFREY & AMES COURT REPORTING Hetro 469-6100, (817) 460-2048
168 1 both from a. hardware and a programmatic standpoint.
_ . 2 Next chart. There are a number of evaluation 3 alternatives that we may use one or more of as we 4 approach each plan. There's certainly that. We can go 5 out and re-inspect hardware. We can also conduct a 6 review of closed out documentation.
7 There will be data gathered in other CPRT issue 8 plans that will provide us with a certain amount of 9 information. We may find ourselves in a position where .
i 10 we want to review and possibly verify some other TUCCO 11 actions that have taken place that could have been 12 corrective action programs, special inspections that t
13 they did or might have completed. Any walkdown L -
14 inspections they might have done. Any testing programs 15 that they have completed. Whatever we can get our hands 16 on.
17 We may also end up in a position where we have to 18 go some engineering analysis and evaluation to determine 19 similarity between operations, craft, inspection, 20 inspection techniques, tooling, specific processes, or 21 whatever.
22 And if we cannot get to some particular piece of 23 hardware that's either inaccessible or just r. 0 t
_ , 24 availaole to us, we may have to go to some otner 2 venue 25 to accept that piece of hardware. And it could include GODFREY & AMES COURT REPORTING 1 Metro 469-6100, (817) 460-2048
169 1 some or all of.these.
_. 2 And we are currently using just about all of these ,
1 3 in one way or another in current issue plans.
4 HR. LANDERS: John?
5 MR. HANSEL: Yes?
6 MR. LANDERS: The data from other CPRT action plans 7 or issue action plans, who is going to make the judgment 8 on a specific issue that in fact there may be some 9 QA significance? Is the team leader and electrical 10 going to make that decision, and call you people in?
11 Are you people going to review all the specific action 12 plans, and make your own determination.
13 MR. HANSEL: We have reviewed -- we're very active 14 in that case, Don. We have reviewed all action plans 15 written to date. We're kept informed through periodic 16 meetings as a result of those. In most cases, we do the 17 inspections and documentations reviews for them.
18 As those results reports are generated by the other 19 review team leaders, we'll be in on the review and 20 exchange of data at that point and pass the baton if in 21 fact there has been an implication in the QA/QC ~ area.
22 We were talking about at lunch a couple of ethers 23 that may be coming down the pipe. So that crecess is
,__ 24 working.
' ~
25 MR. LANDERS: Are any of those others that you nave GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
170 1 just talked about part of the. category 1, programmatic
._ 2 AISP's, either in the programmatic sense or the hardware 3 sense 7 4 MR. HANSEL: That we're currently using today? Oh, 5 we have already done a lot of inspection of hardware 6 already.
7 MR. LANDERS: No. I mean data from other issues.
8 MR. HANSEL: That have fit into us from current --
9 MR. LANDERS: Yes. I think this list is relatively 10 old.
11 MR. HANSEL: Those are just mine. And you're 12 asking me, is there -- have I had input from other 13 review team leaders into any of these?
14 MR. LANDERS: Yeah. One of the evaluation 15 alternatives is data from other -- in fact, one of the 16 sources, external sources of issues, is other groups 17 within CPRT.
18 MR. HANSEL: Yes. Let me talk about it. On the 19 Hilti anchor bolt ins'tallation, we have exchange 20 information there. Not particularly from the CPRT, but 21 through the group that inspected cable tray hangers.
22 Same thing, we're exchanging information r 23 electrical raceway supports. Materials traceability, no
.- 24 exchange of data, but.a lot of discussion on material; 25 traceability issues.
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171 1 Document control, there has been a very active
_ _ 2 interface between ourselves and the guys who are 3 researching the preoperational testing. In fact we're 4 piggybacking on each other's efforts, going through a 5 combined review there.
6 MR. LANDERS: Is there any interface in that one 7 area between you and the design construction people, 8 document control?
9 MR. HANSEL: The project people?
10 MR. L A ND E R'S : Yes.
11 MR. HANSEL: We have certainly had to go to them to
~
12 find out what their files are, how material is filed, i
13 drawing list, recision list, DCA's, CMC's, these kinds u . -
14 of things.
, 15 So, yes, we have had to go to them to find out 16 various computer printouts and access until the -- to 17 those. And we certainly have a daily interface with the 18 people in the document control center for access to 19 information and closed out QA files, QC files.
20 In the back?
21 MR. BURWELL: Spot Surwell again, NRC. In icokin;
, 22 at your list of category one hardware, at these, I 23 remember that one of the items of this nature fcund b '/
_ _ , 24 the CAT team, I believe, was the heating and venti;anin; 25 supports, duct supports. Ycu might want to take a look i
i l
l l GODFREY & AMES COURT REPORTING l Metro 469-6100, (817) 460-2048 L
1 l
172 1 at that and view. Make some decision about whether you
_ _ 2 want to include in that.
l 3 MR. HANSEL: I will be looking at that specifically l i
4 as one population in our self-intitiated plan. But we l
5 will go look at that, yes. :
6 MR. MOLLONSON: Yes. I'm Jim Mollonson, Teladyne.
7 And under your category 1 issues, I don't see any 8 category for piping. Now there were in a few cases in 9 the quality assurance issues that involved piping 10 deficiencies.
11 And I would think if you had a category 1 hardware 12 issues specific action plan, you would have one for 13 piping inspection, because you have specific actions to 14 be done.
15 MR. HANSEL: We're going to hit that under the 16 category 2, self-initiated program.
17 Any others? Okay.
18 MR. LANDERS: Yeah. I guess I would like to ask, 19 John, what is it that lead you to that specific 20 judgment? Because I have the same concern, that tnere 21 are a lot of hardware issues and program issues tnet :
22 don't see on here, that I can go to external sources and 23 find.
_ . , 24 And therefore you have made some jud; ment to taxe
~
25 that out of the external source and.put it in the GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
173 I self-initiated program. And what is it that led to that
_. 2 decision, specifically for piping?
3 MR. HANSEL: Just that we have -- that's an area of 4 investigation. We feel it's probably more easy to get 5 to through a sample reinspection program and will 6 provide us better answers than going after some type of
'7 targeted approach.
8 MR. SHAO: Maybe to answer this question, is this 9 piping program that you're talking about -- I think 10 you're not ready to address. I think that's in the --
11 so I don't think you're quite ready to address appendix 12 P yet.
13 MR. CALV0: No. That piping SER has been going for
, L.]
l 14 quite some time.
15 MR. SHAO: Yeah. But the thing is, that kind of 16 piping, we will say no safety significance. But there 17 is a key breakdown. So what Herb Livermore is saying 18 should be in appendix P. I think you should address 19 appendix P.
20 MR. CALV0: I'm sorry. But I misunderstood 21 something. You say -- you said you went to every 22 SER that the TRT has prepared. And you went there witn 23 the lookin6 at the hardware, and picked up the
,,_ 24 QA/QC implications on that hardware. You didn't have :
~
25 be waiting for the Appendix P if you had done that, if GODFREY-& AMES COURT REPORTING Metro 469-6100, (817) 460-2048
174 1 you had in essence collected all the cards on the
._ 2 QA/QC problems.
3 MR. HANSEL: You're correct. We didn't have to do 4 that, we have had sufficient information in the past.
5 MR. CALVO: So the question, why that particular 6 one is missing from this list?
7 MR. HANSEL: Again, we have chosen to put that into 8 our self-intitiated program.
9 MR. CALV0: What is the judgment of that?
10 MR. HANSEL: That's the easiest way for us to get 11 at researching that issue.
12 MR. SHAO: If you provide that answer, a lot of i '
13 items are missing. A lot of things are missing other 14 than piping. I can cite other ten areas.
15 MR. HANSEL: So -- no, you have to realize these 16 are the on the issue. There are a number of other 17 issues being investigated by the other team review 18 leaders.
19 MR. SHAO: But I'm talking about all QA/QC 20 related. But it's not here right now. But I thou'ht J 21 you were going to address in appendix P in the future.
22 But if you say you took all the issues from the report, 23 in this report here, I can think of ten issues t r. n t '; c u
-- 24 haven't addressed.
^
- 25 MR. HANSEL
- Well, we'll be glad to sit cown anc GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
i l
l 175 1 review on a case by case basis where you think there is
_ _ 2 an issue that you think isn't identified.
3 MR. SHAO: For instance, I don't see anything on 4 concrete.
5 HR. HANSEL: . Concrete is being addressed in another 6 action, under Howard Levin's effort. We have 7 participated with him in that evaluation.
8 MR. CALV0: You're saying there is no QA/QC.
9 complications of concrete; is that right?
10 MR. HANSEL: Not saying that specifically. We may 11 well address them in Howard's action.
12 MR. CALV0: You're not quite there to make that
' 13 judgment.
l t J 14 MR. HANSEL: That's correct. We haven't closed 15 this action plan.
16 MR. CALV0: So this part here is incomplete then.
17 MR. HANSEL: I indicated before that this list may 18 be added to as we go, as we learn new things, as we go 19 through all the various actions plan.
20 HR. SHAO: Howard Levin I think was going to 21 address the design. Is Howard Levin going to addre::
22 QA/QC issues?
23 MR. HANSEL: Howard Levin is also responsicle fer
,__ 24 researching certain issues that prim.arily ended up
' ~
25 being either a design issue or a process related tesue.
GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
176 1 Now if it also has QA/QC implications, there's a
_. 2 lot of dialogue between myself and Howard Levin in_the 3 case of the concrete issue. We worked with them in 4 reviewing and the development of that plan. We went out 5 and helped him to get the vendor that would do the 6 actual testing on that concrete. And we reviewed the 7 results of that concrete evaluation.
8 MR. NOONAN: John, let me interrupt here. It seems 9 to me what this needs right here at this point in time 10 is for you to go back, say, to look at all the SER 's.
11 You have got issues being identified by somebody else, 12 like in the Howard Levin area, something like that. I
' think you have to put that on the chart to show where 13 u -
14 the hell it's being investigated. I think the --
15 MR. HANSEL: We have that detail at the site, 16 Vince. But I don't have it on this particular chart.
17 As I indicated, we're keeping track of all the issues, 18 where they come from. And if we pass some off to 19 somebody else, where they go and they -- how they're 20 cispositioned and the end result.
21 MR. NOONAN: When get your end program, I think I 22 need to see that. We need to see where all the QA/QC 's
- 23 are being addressed. If you're not looking at it
_- 24 specifically, then we're already being addressed.
25 MR. LANDERS: John, is what I'm hearing is tne GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
177 1 issues that face us here are primarily QA/QC issues?
_ _ 2 They may have some other site issues, such as piping.
3 Maybe primarily in your mind the design issue, it has 4 some side QA/QA issues. Is that the dividing line?
5 MR. HANSEL:, Yes, Don. And the senior review team 6 and ours looked at the issues and decided who would be 7 the primary person to work it. And that's been done.
8 MR. LANDERS: Which does not mean that you will 9 not look at the QA/QC aspects of design control.
10 MR. HANSEL: I will look at every one of those 11 others, and search out and seek out any QA/QC 12 implications and research them.
! 13 MR. LANDERS: So in following up what Vince said, a L J 14 Matrix that would indicate primary responsibility for 15 your group, and maybe a secondary responsibility for 16 your group, would be of great benefit to us.
17 MR. HANSEL: Yes. And in each of our action plans, 18 the interphases are identified. I don't know for 19 certain, but I suspect if'you go look at Howard Levin's 20 issue plan on concrete, you'll see me in there as an 21 interface point for the QA QC implicaticns on that.
22 We may have in our action plans where we may have a 23 design issue, or we may nave some other type of a
__ 24 process issue. You will see that I have icentifiec tne
' ~
25 interface there.
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178 1 If you go to the electrical issue plans, you will
_ _ 2 see in places'where they have talked to me, and I'm 3 identified as an interface.
4 And there's a very active exchange of data and 5 information. But I think we see where your concerns 6 are.
7 MR. VOLLMER: -I guess the important point, the 8 action plan. detail is going to address on how you made 9 this cross from all the design plans, how you interface 10 with' it. So I at least can understand.
11 MR. HANSEL: Yes.
12 MR. LIVERMORE: I have a question. Herb 13 Livermore. I guess, bottom line, when we come to review a -
14 the QA/QC plan, I myself will be looking for that type 15 of identification of the -- all the QA/QC issues. And 16 you will address them in your plan?
17 MR. HANSEL: Yes.
18 MR. LIVERMORE: Not just by a reference, "go see 19 another plan"? I can expect some other plan; is that 20 correct?
21 MR. HANSEL: Either that or through a matrix. :
22 can get you to those other plans. I will not have, a
23 Herb, per se, an issue plan on every CA/QC issue, if in i '
. . , 24 fact I'm secondary to somebody else who is working :ns:
25 issue. I will have in my records, though, what I did in GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048 l' __ _ - - - - - , . _ - . _ . _ _ _ . - - .
179 1 research of that, from a QA/QC standpoint.
_ _ 2 MR. LIVERMORE: My bottom line is.that I have got 3 to go see that you did that from a a standpoint.
4 MR. HANSEL: And we can provide that 5 accountability.
6 -M R . LIVERMORE: Address some kind of conclusion 7 somewhere.
8 MR. HANSEL: Yes. We can provide you that road 9 map.
10 MR. LANDERS: And, John, when you are secondary, 11 you are still going.to look at the cumulative effect of 12 different issues?
ii I 13 MR. HANSEL: You bet. In fact, Don, and for that
!_J 14 second chart where I showed the five blocks across the i
15 top, I'm going to draw every piece of data I can get 16 from all those actions plan into our collective 17 evaluation on QA/QC and construction adequacy.
18 MR. CALV0: Maybe I'm getting too early, I guess.
19 You're talking about issues going into the plan, i r. t c 20 this right here. How do you look at these issues if l
l l 21 they come from the electrical discipline, or from the 22 mechanical, and you relate that, because something you 23 found on the electrical also was -- had some
,_ _. 24 complications maybe in the meenanical.
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25 How will you tell the mechanical team, "Now will GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
I 180 l
1 you please worry about this particular part, because the
_J 2 electrical is pointing out a problem in here?"
3 That cuts across to other discipline. -
4 MR. HANSEL: From a QA/QC standpoint you want --
5 MR. CALV0: Are you talking about it now, or are we 6 too early? It can wait.
7 MR. HANSEL: I wasn't going to talk about it. But 8 again, it's back to the interplay between the various 9 issue plans. If, in the research of an electrical 10 concern or issue, and.they found an implication in there 11 that says that there may have been.a problem in the -
12 quality control or QA aspects of mechanical type i installations, we'll take that and we'll work it.
13 L. -
14 If we don't have an action plan where it fits 15 currently, we'll create a new plan, and go work the 16 specifics aspects of that, and feed the information back 17 into that other plan, or close it our -- in that plan.
18 MR. CALV0: Who makes that decision? Ycu as the 19 team leader make that decision, or back to the ser. or 20 review?
21 MR. HANSEL: It's usually done collectively between 22 the two review team leaders. And then we'll go tell the 23 senior review team it needs to be done and we're doing
_ _ , 24 it.
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25 MR. CALV0: Ycur plan, detailed plan, you're going GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
181 1 to submit it? I will see that you can address, how to aj 2 handle that?
3 MR. HANSEL: Okay. What he's talking about is the 4 interplay and transfer back and forth of knowledge of 5 information.
6 MR. BECK: Yes.
7 MR. HANSEL: All right. Evaluation and results.
8 When we are inspecting documentation or reviewing 9 --
inspecting either documentation or hardware, we will 10 have differences from the drawings or the 11 specifications.
12 We're going to classify those as deviations at
- i 13 that point in time. They will then be evaluated on a L. .
.14 case by case basis, first to determine if in fact that 15 deviation has -- it exists on that piece of hardware, is 16 safety significant.
17 At that point in time, if it is, it will be 18 classified as a safety significant deficiency. If we 19 have a programmatic problem, it's either a problem in 20 terms of the procedure or the records or the method of 21 handling paper or traceability of materials, whatever 22 that might be. Ve'll classify that as a programmatic 23 deficiency, and take it f r o r.: there.
_, 24 We may also at that point in time nave ;o crette ,
' ~
25 some new issue plans if in fact the research of enat, to GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
182 1 determine how far spread or how widespread it is. We
_- 2 may have to create some new issues plans for the 3 investigation of that.
4 We'll then go through a root cause analysis and a 5 generic implicat. ions analysis on a case by case basis 6 for each of those that are determined to be safety 7 significant.
8 MR. NOONAN: John, can I interrupt you. Have you 9 done any of that? Have you looked at any root causes 10 yet?
11 MR. HANSEL: Nothing that-we have documented. We 12 have done a-lot of research and investigation. We have 13 done some, for instance, in the area of nonconformance 14 reports that came out of the-January letter. And again, 15 is covered in the SSER 11.
16 And we have done some in the fabrication shop. A 17 lot of preliminary analysis, but no conclusions that I 18 want to draw yet. We're getting close in a couple of 19 areas.
20 MR. CALV0: Excuse me. Let me pose you a 21 hypothetical question.- Let's say you do a review of tne 22 'QA/QC program, and you find sometning was wrong witn tne 23 NCR. The nonconformance report wasn't kept,
_, 24 hypothetically.
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25 What step would you take to convey this message to GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
183 1 all the team leaders? What will you tell them to do?
_ _ 2 MR. HANSEL: First off, I want to identify if it 3 was a single instance or --
4 MR. CALV0: Generic.
5 MR. HANSEL: , Generic kind of a problem, and there 6 are generic implications? Then we'll certainly send a 7 letter, number one, to the senior review team, and to 8 all the other issue plans, and say, " Hey, we found 9 another issue here that could have implications in your 10 area."
11 And then we'll get together to research that to 12 look at the effects. But if we found something that cut 13 across all areas, Jose, it would go to the senior review L -
14 team and to other review team leaders. And they would 15 collectively decide how to go about it and assess the 16 effect.
17 MR. CALV0: Okay. That's all right.
18 MR. MOLLONSON: John, I'm Jim Mo11onson. I look 19 at this evaluation of results. And from a quality 20 assurance effect, I could see a bottom line that snous 21 how I get over into a corrective action mold. Are we 22 going to come to that place after the evaluation of 23 results?
,_ 24 MR. HANSEL: I will in the self-initiated progrs.r.
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25 In this particular case, I apologize. There snoulo GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
184 1 be another one on here that says recommend corrective
_] 2 actions. If in fact they're in order, and I.'m sure 3 - there will be some of those.
4 MR. MOLLONSON: I have one other question. Is 5 that~a corrective active system within the response 6 team, or within the Comanche Peak QA program?
7 MR. HANSEL: We're going to make recommendations 8 only to the project as to what they need to do to fix a 9 specific item or area of concern. We will send them 10 information. In most cases, via an NCR.
11 If it's a programmatic. type of thing, we're going 12 to notify them through the senior review team.
' 13 MR. MOLLONSON: And you have a follow-up grcup in L. -
14 the response team that follows up on corrective actions?
15 MR. HANSEN: Yes.
16 MR. CALV0: Where the trending appear, or the 17 -- come. Where is that?
18 MR. HANSEL: I'm going to talk about trending, 19 Jose, in the self-initiated program. Not so much here, 20 because I'm working a specific issue here. Now I may 21 well find trends in the research there as well. I ' n.
22 going to talk about trending later on in detail.
23 MR. BOSNAK: Jonn, I'd like to follow-up on Jim's
_ - 24 question witn respect to root cause in the piping ana 25 pipe support area. Haven't you yet in fact determined
\
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185 1 a -- the basic root cause there? p
_ _ 2 MR. HANSEL: For QA/QC?
3 MR. BOSNAK: Well, the design process itself, 4 QA/QC.
5 MR. HANSEL: , I have not gotten ' involved in the 6 design process yet on piping or anything else. We're 7 leaving that to the other group. They will call upon 8 me as needed. I -- we have broken that off 9 specifically, rather than trying to have two parties 10 working one area.
11 And that particular piece was given to Hcward Levin 12 and his folks. Works a whole lot better that way than
-1 13 having two people mulling in there trying to search out LJ 14 the same type of issues. Next chart.
15 In our root cause evaluation, we're going to 16 attempt to identify what cause -- what was the root 17 cause or root causes? And we'll be doing that for 18 safety significant hardware deficiencies, any 19 programmatic deficiencies that we identify, and adverse 20 trends. And you will note the reinspection, Jose.
21 Now we may find some in specific action plans, but 22 I doubt it, because we're looking at specifics there.
23 We may not find generic trends that apply elsewhere.
,__ 24 I'll talk in more detail later in terms of the
~
25 -- some of the potential root causes and how we're going GODFREY & AMES COUFT REPORTING Metro 469-6100, (8*.7) 460-2048
186 1 to go about that. We'll identify those root causes,
. - 2 document them and, then look for-the generic implication 3 in, number one, the hardware population.
4 We're looking at other populations, and they may as 5 well as be -- there may well be implications in 6 programmatic areas.
7 MR. CALV0: I'm assuming that you will cross 8 between disciplines and with the same discipline?
9 MR. HANSEL: Yes.
10 MR. CALV0: You should have said that. Otherwise 11 we'll be asking you the same question all the time.
12 MR. HANSEL: Okay. Next chart. When we finish i 13 this program on the category 1's, we think that we will w -
14 have identified any safety significant hardware 15 deficiencies that exist, and any programmatic 16 deficiencies that exist.
17 We will have analyzed them for root cause generic 18 implications, and we will have provided reasonable 19 assurance that there are no undetected and uncorrected 20 safety significant hardware deficiencies related to 21 those external sources. Next chart.
22 I'd like to now talk about the self-initiated 23 program, which is the center block of this chart,
.- 24 labeled hardware reinspection and documentation rev . ew.
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25 And if you will recall, I labeled tnat as category two.
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'187 1 By the initiation of this program, we feel it will
__ 2 add another level of confidence into the results of what 3 we learn in the category 1 issue plans. And that we'll 4 be able to extend the' conclusions that we drew from the 5 category 1 issuecplans to the entire population of 6 safety related hardware. It's quite an extensive 7 program. Next chart.
8 Our methodology'. I'm going to talk about each of 9 these in great detail. We will establish hardware 10 populations. We'll select samples. We'll inspect those 11 samples, and we will : Iso conduct documentation 12 reviews. We'll evaluate the results of those on a E I 13 population by population basis and in the.' entirety.
L J s 14 Next chart.
15 MR. LANDERE: John, before you go on, in 16 establishing populations and selecting samples, how much 17 reliance, if any, will you place on the , category one 18 issues that you have resolved? A'e'you r going to try and 19 turn a blank mind what's going on in t$at area, or what?
20 MR. HANSEL: We're -- ifwehavedhne a rather 21 extensive sampling process already in category 1, ue 22 haven't made a determination yet. If it's -- it was 23 extensive, and we're satisfied witn it, we may
,__, 24 substitute it. I'm not ready to answer it yet.
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25 So far I know of none where we would do any of the GODFREY & AMES COURT' REPORTING '
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l 188 l l
1 modification of the sampling and reinspection program. i l
_ _ 2 MR. CALV0: Will the detail plan provide the 3 criteria that you are supposed to do that? l l
MR. HANSEL: Yes.
4 5 MR. CALV0: Tell us how to do it, whether you know 6 that's correct. Will you please take a look, so we have 7 some plan? I mean your program plan by June 28, we are 8 going to have'that information?
9 MR. HANSEL: Tell me again exactly what you want, 10 Jose. Tell me again exactly ~what you want. How we're 11 going to define the populations and how we're going to -
4 12 select the samples?
13 MR. CALV0: No. How are you going to adjust for L -
14' the fact if the specific issues already give you enough 15 of the sampling, you have got to come up with a --
16 MR. HANSEL: That will be covered, yes, in our 17 issue plans.
18 MR. CALV0: Will the issue plans also how you are 19 going to factor that into selective population?
20 MR. BECK: If it is.
21 MR. CALV0: If we have to approve the plan, we nave 22 got to get that information.
23 MR. HANSEL: Yes. You will, in the composite
,..., 24 between those issue plans, you will know wnich plan t r. e
~
25 nardware is being covered in. You will know if we're GODFREY & AMES COURT REPORTING Metro 469-6100, (617) 460-2048
189 1 combining the efforts of two. You will have to account
__ 2 for it.
3 MR. CALV0: I'm not going to get the issue plan 4 June the 28th. I'm going to have the master plan June 5 the 28th, and that covers the criteria -- covers how the 6 specific issue plan is going to be done? We have got to 7 know it then, or it's going to be an open item.
8 MR. SECK: Jose, you will have all of it on the 9 28th.
10 MR. CALV0: You keep saying yes and he keeps 11 saying no.
12 MR. HANSEL: No. We're saying the same thing.
i 13 It's all going to be in that package that you receive LJ 14 the end of June.
15 MR. BECK: We said he doesn't know of any instance 16 in the generic where there is any duplication. But if 17 there is, it will.be identified.
18 MR. CALV0: That's all right. But it will be 19 identified.
20 MR. SECK: But today there's not.
21 MR. SHAO: But anything that's missing in nis 22 package,.will be in Howard Levin's package? l 23 MR. HANSEL: In'the totality. In the package that
_ _ , 24 you get the end of June, I think you will be satisfied
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25 that all issues have been addressed, in addition to the GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
190 1 self-initiated programs. And where there is some
._ 2 interplay between issue plans, Larry, and the 3 self-initiated programs. You can see that.
4 MR. SHAO: What about tomorrow? You have a list 5 that you are working on right now? You said those 6 issues are working. Tocorrow will I see none of this, 7 of the missing items?
8 MR. BECK: What you will see tomorrow is a list of 9 those items that are going to be covered under the 10 design adequacy plan. We are not going to address, as 11 part of this presentation, those issued specific actions 12 plans that we have already talked ab'out on a number of 13 occasions. It will, however, be included at the end of J
14 the month in the total package. Everything.
15 I will, before the close of the day tomorrow, give 16 you a status on the issue specific action plans.
17 MR. SHAO: I'm a bit confused now. John just say 18 that a lot of QA/QC~ item is not here, but will be 19 addressed by Howard Levin, QA/QC related. I'm not 20 talking about design QA/QC related construction issues.
21 MR. BECK: .I'm not sure I understand your concern 22 right nou.
23 MR. SHAO: Okay.
-- 24 MR. HA!!SEL: Let me take that.
~
25 MR, SHAO: Give an example. I'll just ask the GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
191 1 question again. A lot of QA/QC concrete construction
. _ 2 issues is not listed here. And I think John is saying 3 it will be covered by Howard Levin.
4 MR. HANSEL: Let me take a cut at it, John.
5 M R '. BECK: Please do.
6 MR. HANSEL: In the package that you get at the end 7 of the month, you're going to receive the complete 8 program plan. You're gcing to receive an appendix that 9 covers my construction QA/QC adequacy plan. You're 10 going to receive another appendix addressing Howard 11 Levin's program. And you're going to receive all of the 12 issue specific action plans. Let me go ahead, Jose, if I
13 I may.
14 MR. CALV0: Don't miss --
15 MR, SHAO: Tomorrow you're not going to cover that?
16 MR. CALV0: You miss one more important one.
17 You're going to see all the interactions between all the 18 plans design -- what design review, design adequate 19 review, right across these disciplines, but if you find 20 something's wrong, how the interactions are'geing to 'o e 21 taken care of. That's what we're going to see; r i;', n t ?
22 That was pointed to you, John.
23 MR. HANSEL: We'll have to develop that.
_, 24 MR. SECK: Yes. 'J h a t we have not done is put
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25 together a matrix that draws on each of the issues GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
192 1 specific action plans and involve interfaces between the
_- 2 primary responsibility in a discipline, i.e.,
3 mechanical, and QA/QC. It's in the body of the action 4 plan itself. For convenience of reference, we will 5 develop that matrix, and have it included.
6 MR. CALV0: I'm not only looking for the matrix.
7 For the mechanism.
8 MR. BECK: The mechanism is spelled out in words.
9 MD. CALV0: All right.
10 MR. HANSEL: The mechanism for the transfer is 11 there.
12 MR. BECK: And the name of the people involved on 13 both sides of the issue and the discipline, and the u -
14 QA/QC. It's all in there.
15 MR. CALV0: Okay.
16 MR. HANSEL: Let's talk about the self-initiated 17 program. And bear with me and, please try to hold --
18 not to shut off questions. But try to hold them because 19 I think by the time I finish, I will have answered cost 20 of the questions.
21 We're going to establish populations of harduare.
22 And currently there are approximately 30 of those. I'll 23 show you a list of what those icok like in a second.
i
, . _ 24 There will be a population description on a population
~
l 25 by population basis that says what is in a particular l GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
I l
193 !
I I population, what is not in a population, how it's
_ _ J2 bounded, and what are the interfaces between that 3 population of hardware and another population of 4 hardware.
5 Let's show.them the list, John. This is a 6 preliminary list. This is the approach that we took at 7 Braewood, and it's worked very well there. I want to 8' emphasize it's preliminary, but it will come out very 9 close to being just like this.
10 And I'm sure I could stand up here all afternoon 11 answering questions about the specifics of where a 12 particular item of hardware is at. And I'm not capable 1 13 of answering that at this point in time. I can only L J 14 assure you that when we finish these populations of 15 hardware, will include all types of safety related 16 items.
17 We feel that these populations of hardware will be 18 reasonably homogenous, and that they -- populations will 19 be based on similarity of construction processes and our 20 inspection processes, which is the best way for us to 21 get to the hardware.
22 The adequacy of each population will be, a r,a i n , as 23 I indicated, based upon similarity of the inspection
_ _ , 24 techniques, construction techniques, and hcu we can ber:
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25 get to it.
GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
194 1 Let's go back to the main chart, John. From that
. _ 2 point in time, once those population definitions are 3 completed. And incidentally, we have four of those 4 completed, we then will go about the process of 5 selecting samples.
6 Let's put the next chart up. We'll develop a list 7 of all safety related construction work that's been 8 completed and inspected for both units for each of those 9 populations. I want to emphasize completed and 10 inspected. Basically bought off.
11 We cannot -- will not inspect in-process work.
12 We're going to work on completed work. We then will 13 select a sample randomly from that total list, based on t -
1' 4 the 9595 standard that John talked about this morning.
15 That will be our first sample. That will be a totally 16 random' sample from that population.
17 We then will continue to select items randomly from 18 that population that fall within the category of syste=s 19 required for safe shutdown. So we will have two samples 20 of hardware from the same population.
21 It's currently planned that the first sample u_11 22 be 60 items. The second sample will also consist of 60, 23 but there may be some items in the firs; populatior. t r. 2 :
_- 24 are from safe shutdown systems. So ycu could have 30M
~
25 overlap of items in the population.
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195 1 We have to verify the accessibility of each item.
_ _ 2 Can we get to it and can we inspect it? If we cannot, 3 we will throw that item out of the sample and go to the 4 next item. Let's go back to the master chart, John.
5 MR. HANSEL:. Once we have the samples selected, 6 we'll then parallel. Really we will develop detailed 7 check lists to be used by the inspectors. And those 8 check lists will include the safety significant 9 attributes for each of the populations and the 10 accept / reject criteria. And those will be based upon 11 released drawings and construction specs, the codes, 12 standards, whatever might apply. ,
I want to emphasize i
13 safety significant attributes.
L -
14 In some cases, where it's necessary, we will even 15 provide additional instructions to the inspector on now 16 to conduct the inspection.
17 MR. BOSNAK: John, I hope the FSAR would include 18 the criteria.
19 MR. HANSEL: I had not planned to go that far. And 20 it may be a bad assumption, I don't know. But assuming 21 tnere has been a verification between the released 22 drawings and specifics and the FSAR.
23 MR. BOSNAK: Do we know that?
94 MR. LANDERS: You mean that they were in
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25 compliance?
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196 1 MR. BOSNAK: That's an important step, if we don't
. - 2 know it.
3 MR. VOLLMER: I missed that. Would you repeat that 4 again?
5 MR. HANSEL:. The question was, do we plan to go 6 make a comparison against the FSAR? Again, I'm not 7 trying to verify in my program the adequacy of the 8 design, or the compliance of the design. Its my job to 9 evaluate the adequacy of the construction. So therefore 10 I must start from released drawings and specifications.
11 MR. LANDERS: But in making a determination on -
12 safety significance and reliance on the drawing and 13 specification, then the use of the terms safety
,u _
14 significant, based on your assumption, automatically 15 includes compliance with the FSAR because you have made 16 the assumption up front that the drawing complies with 17 the FSAR. And my concern is how you are going to 18 determine safety significant attributes of a weld, for 19 example.
20 MR. HANSEN: Well, I think we could. You know, in 21 that case, Don, there is some types of defects or 22 attributes that are certainly more. Well spatteren, for 23 instance, in my opinion, is not a safety significant
_ . _ . 24 ceficiency. Certain types of undercut, certain ie/els 25 of porosity.
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197 1 No need to spend a lot of time out there in
_ _ 2 speculating hardware for certain types of defects, if in 3 fact you don't determine or make a determination that 4 they're safety significant.
5 MR. L A ND ERS.: But then you bring up a very, very 6 important issue, because, in fact, the undercut and the 7 kinds of things you're talking about won't show on the 8 design drawing. Will.not be allowed by the 9 construction.
10 MR. HANSEL: But they will be included in codes 11 and standards.
12 MR. LANDERS: Will not be allowed by some codes and i 1 13 standards, depending on what we're talking about, how L J .
14 you're going to make the determination that the weld 15 does not have safety significance, if it's not in 16 compliance with those. I'm just trying to --
17 MR. HANSEL: I think that the only --- I cannot tell 18 you that our review will be complete enough, in the 19 definition of what's safety significant. If we have to 20 go to the FSAR to determine that, we will.
21 'd e ha v e n o t had that experience in tne past, unare 22 we have had to do that, to a great degree. Another 23 point, let me help again. The results of cur e n e :::
_ _ _ 24 lists are going to De provided to the other rr/ leu t e 2.i:
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25 leaders as well. And they will have input into it. In GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
198 1 fact, if they see something that needs to be included in
. . 2 there. So they will bring that piece to the program.
3 MR. TRAMMELL:
John, this is Charlie Trammell. On 4 that same line, I had a question about safety 5 significant. Is. that a yes/no question? You just let 6 it go at that.
7 MR. HANSEL: Not totally, but it's very close to 8 that, I think.
9 MR. TRAMMELL: Well, maybe just as a thought here.
10 There are grades, as you just suggested, of importance.
11 And it would seem to me like you may want to give some j 12 thought of having maybe critical defects or important t 13 defects or unimportant, so that you can --
t .
14 MR. HANSEL: What it is, Charlie? It's basically 15 to screen out the unimportant defects and include 16 everything else.
17 MR. BOSNAK: We have to have an idea what you 18 consider to be important and what you consider not to be 19 important. That gradation is vital.
20 MR. NOONAN: John, I think you have to rethink that 21 . position about not using the FSAR. I really do.
22 MR. BECK: I have taken -- =ade a note of tnat. I 23 think the key is going to be, when we get to the
__ 24 nitty-gritty of the safety significant attricutes,
'25 either they're going to be derived, how tney were GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
199 1 derived, what they are, what the sources were. Clearly
_ _ 2 we're going to have to consider that. I 3 MR. CALVO: I'm sorry. I don't think so, because 4 we are going to approve.the master plan by June 28th, 5 and have the criteria for -- the safety significant.
6 You keep throwing us back to the plan, specific ones.
7 Those are not going to be ready for a long time.
8 We have got to know what you have~in mind when you 9 say what's important and not important by June 28.
10 Otherwise, we are going to have to have to wait for the 11 plan, the specific plan. If that's what you want, we 12 wait for that.
! 13 MR. BECK: I just said that we would have to L J .
14 consider that at the FSAR connection and commitments I
15 visavis safety significant attributes, and we will do 16 that. I think we need to modify the plan.
17 MR. VOLLMER: I'm sorry. I see. -
18 MR. BECK: I recognize the observation as a darned 19 good one.
20 MR. MARTIN: Another question. Scb Martin. 'd h e n 21 will the inspections conducted on those attributes, 22 which are judged to be safety significant, after we 23 establish.what those will constitute.
, _ , 24 Those. attributes whien are safety si;nificant
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25 attributes, is it possible or likely that they will bc GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
200 1 be inspected against more specific criteria than were
. _ 2 contained in the codes or standards that were applicable 3_ at the time of the original inspection?
4 MR. HANSEL: No, I would anticipate them to be 5 equal to or less.than.
6 MR. MARTIN: Equal to or less than?
7 MR. HANSEL: In most cases, equal to.
8 MR. MARTIN: There are certain codes. One I can 9 think of, in which the code or standard itself leaves 10 great flexibility to the individual inspector in terms 11 of judging the adequacy. I think of AWS, the American 12 Welding Society, D-11, industrial welding code, is the 13 most recent example I have in mind. It leaves a number u -
14 of attributes to the skill and training and judgment of i
15 the inspector.
16 Then are we running the risk, absent the CPRT, 17 specifying more objective criteria, ra-ther than 18 judgmental criteria. Are we running the risk of getting 19 into having to resolve differences in judgments? We 20 will be going out in some of those areas and also 21 inspecting, probably, using the same codes ui r 22 different people making the judgments.
23 MR. HANSEL: I don't --
_- 24 MR. MARTIN: Have you 1 coked at tnose ecder to see, 25 and will you be, ag part of your issues, looking at the GODFREY & AMES COURT REPORTING Metro 469-6100, (617) 460-2046
201 1 standards you're applying, to see if they are
_ _ 2 sufficiently objective, that they become objective 3 evaluations, rather than subjective evaluations?
4 MR. HANSEL: That's in the process right now. But, 5 you know, as well as I do, in the code world, we're 6 always going to have a lot of subjectivity and some 7 disagreement. But we are reseaching that right now as 8 we develop the accept / reject criteria and the method of 9 inspection.
10 MR. MARTIN: And again, if I understood you 11 correctly, there is a possibility that you anticipate 12 that the criteria, the inspection criteria, is not i
13 likely to be more demanding than the original. And L -
14 could in some cases be less than demanding than the 15 original criteria.
16 MR. HANSEL: That's correct, sir. We certainly 17 could not go out and inspect that plant today with more 18 stringent criteria than what was applied. That is not 19- a good judgment. We do need to assure ourselves that 20 innerently that these drawing and specs were used for 21 that inspection initially.
22 But we can't certainly go out and apply more rigid 23 standards today, unless they have been included in
_, 24 update standards, and in fact applied to that harcuare.
' ~
25 It's not right to do. It's a very touchy area, and we GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
202 1 need to watch that one very close.
_ . 2 We will also put together a documentation check 3 review list that will be used for the review of 4 _ documentation. We do not plan to do an indepth review 5 of documentation. We will do what is required to assure 6 ourselves that any critical operations took place, and 7 that they were applied. And t a'1k i n g terms traceability, 8 heat treat, whatever it might have been.
9 But we're concentrating on what. impact could have 10 been on the hardware. We're not looking for the 11 crossing of the T's and dotting of the I's, these hinds 12 of things. We'll be looking for those kind of 13 attributes that could have had an impact on the u -
14 hardware. Let's go back to the original, John.
15 Verification packages will be put together for the 16 inspectors that will include the drawings, the 17 specifications, the check lists, and NCR 's that are 18 appropriate for him to do that inspection. They will 19 then go about the process of conducting the inspections 20 and the documentation review. Next chart.
21 MR. SHAO: Excuse me. After you select the s a r.p z e ,
22 you'look at it, everything, locate how can you draw tne 23 conclusion that the rest of the plans are okay?
,__ 24 MR. HANSEL: I can on that populaticn, en a 23 statistical basis.
l l
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l 203 )
i 1 MR. SHAO: You can on a statistical basis? 1 l
_ _ 2 MR. HANSEL: Yes. On a population by population 3 basis.
4 MR. SHAO: Okay.
5 MR. HANSEL: Upon what I find in this sample.
6 MR. MOLLONSON: All right. John, so you --
7 MR. HANSEL: Somebody had a question.
8 MR. MOLLONSON: John, excuse me. The documentation 9 checklist for review of documentation, will that include 10 the existing site procedures?
11 MR. HANSEL: The existing site procedure?
12 ,
MR. MOLLONSON:
Yes.
! i 13 MR. HANSEL: No, it will be related to the item of 14 equipment that I'm looking at. I will look at the 15 hardware on a case by case basis. I'll be looking at l 16 the same piece of closed out inspection paperwork on 17 that piece of -- on that piece of hardware.
18 M R .- MOLLONSON: But out of the system, we're trying 19 to get here, I guess, is flotation of -- get ~ well. If 20 some construction continues out there, and if your 21 review only -finds that the documentation is good to 22 satisfy the issue, and doesn't take into consideration 23 that it can improve the system by improving adequacy cf
- _. 24 the procedure or --
' ~
25 MR. HANSEL: I'm beyond the issue nou. I ' m. looking GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
204 1 at a random sample of hardware representing the total
_ _ 2 plant on a population by population basis.
3 If I find that the haraware is good, and the 4 documentation that's been verified by inspection is in 5 the vault, and it's okay, then I should be able to --
6 MR. MOLLONSON: Then the ones you find are good 7 aren't the items of concern. The ones that you find 8 that aren't good are the items of concern.
9 MR. HANSEL: Then if I find them not to be good, 10 I'll research them for root cause and generic 11 implications, and expand as necessary.
12 MR. MOLLONSON: Thank you.
13 MR. HANSEL: Does that answer it? We're'not going u -
14 to quit just -- no, let me go ahead. We're going to do 15 a root cause and generic implication and adverse trends 16 analysis as well. So that could lead me back into 17 current procedures.
18 MR. CALV0: Go ahead.
19 MR. LANDERS: The adverse trend analysis, and 20 getting back to Bob's point about the code cf 21 construction or something less than that, in a situatien 22 and a sample where you would have 20 items that were --
23 that you have judged the hardware is acceptacle, and you
_, 24 could defend that, based on a criteria that was less 25 than the construction criteria, would that lead you to GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
- - - . - - - = - - .
205 1 do some trend a'nalysis because 20 items did not comply
. j 2 with the construction requirements, even though in your 3 opinion, the hardware did not have safety significance?
4 MR. HANSEL: Let me talk about that a little bit 5 later in detail.. But let me address it now, because I 6 think it's appropriate.
7 If I had 20 deviations, and none of them were 8 safety significant, if they were all different in terms' 9 of the deviation, and if they were all insignificant, I
~
10 probably wouldn't do a thing.
11 You know, there's no science what I can say to 12 you. I can see you're starting to chuckle. However, if F1 13 I had some number in there, and I don't know what that L J 14 number is, there were more significant, it may say, 15 " Hey, I better go research this and" -- or if I zerced 16 in and I had a problem with a particular craft or a 17 particular inspector a particular discipline or a 18 particular procedure, then I'm going to go research it.
19 So I can't answer your question until I get my hands on 20 the data.
21 MR. LANDERS: However, in a general way, uill ycu 22 address tnis in tne plan?
23 MR. HANSEL: Yes. You bet. Jose?
l
,_ _ , 24 MR. CALVO: Are you going --
I guess the tn:ng .
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25 understand what you're talking about the population, are GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048 i
206 1 you going to talk about how you can figure these
. _ 2 populations that you can eventually come out over all 3 reasonable assurance? Are you going to address that 4 point sometime later?
5 And the other question that I had, is why do you 6 pick up random and selected samples'from the system 7 required for safety shutdown? Why did you not pick up 8 the system required to mitigate the consequence o'f the 9 accidents? I'm just asking.
10 To the best of my knowledge, you pick up a 11 significant for required for safe shutdown. That's the 12 system that you normally use every time you shut the I plant down.
13 The one you don't normally use is the 14 system that's required for the the accident. What was 15 the criteria for selecting this one, and not the other?
16 I'm not saying you're wrong. But I wonder why.
17 MR. HANSEL: That's been a subject of many hours of 18 discussion, as to what we would pick our engineered 19 sample from. And we felt it was those systems required 20 for safe shutdown for a number of reasons.
21 Number one, that list is identified thrcu;h the 22 FSAR. It's been accepted. It's easy to implement. In 23 will cut across all those 30 populations, if we er: up
_, 24 with 30 populations.
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25 And beyond that I can't give you any really great GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2043
207 1 reason. There are a' number of approaches to this, as
.. j 2 you know. There are no PRA's on this plan. We have no 3
way to back into that easily. And we felt the. safe 4 shutdown-systems were the most logical way to go on this 5 plant.
6 MR. CALV0: You're right about cutt-ing -- cut off 7 all the'other systems interfaces because remote shutdown 8 plan on all these systems be required, borrowing pieces 9 from all the other systems, is what you're saying. And 10 this is more representative in taking a design basis --
11 MR. HANSEL: About the only thing I might miss is 12 concrete.
t l 13 MR. HANSEL: Okay. There will be --
- t. J .
14 MR. CALV0: Wait a minute. You didn't answer my 15 first question. Are you going to tell us how you put 16 together all those populations? How you figure it all 17 up?
'18 MR. HANSEL: I thought I'd answered that, but let
'19 me go back. We will identify the populations. It will '
20 come soceplace c1cse to that list of 30 that I.showed 21 you.
22 MR. CALV0: What was the basis for that?
23 MR. HANSEL: And there will be a detailed
,__, 24 description at the site for each population, what is ;n 25 the population, now it's bounded, what is not ir. the GCDFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
208 l
1 population, and the ipterfaces between that population
.. 2 and the other populations.
3 MR. CALVO:
You would also explain why not 300 4 instead of 30? There would be a reason for that?
5 MR. HANSEL:. To be real frank, we used a system 6 similar to that at Braewood, and it covered everything, 7 and it was convenient and easy. And I used it.
8 And it does cover everyth'ing, and it's grouped 9 primarily similarly by work processes and inspection.
10 MR. CALV0: You're not answering my question. If 11 you did it in Braewood, you had some basis at Braewood.
12 What was your basis in Braewood?
13 MR. HANSEL: It's based upon similarity of work-J 14 processes and inspection craft people. When I put 15 together the check lists for those populations, I can 16 now define the individual attributes for that. And they 17 come out pretty clean and easy to implement. It's been 18 proven and it's good.
19 It's primarily, though, Jose, it's based upon -- we 20 got to the populations via the route of defining werk 21 processes and the attributes we wanted to gc after.
22 MR. CALV0: Well, you also factor that OC 23 inspections, and you configure tne populaticn. ;f ycu
__ 24 had a problem with certain craft, electrical craft or 25 the piping, do you consider that, or that was an input GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
1 l
209 1 for you to come up with this configuration? l
_ . 2 MR. HANSEL: I used no bias in putting together 3 those lists of populations, because I wanted at this 4 time to be random. I wanted the population to be 5 reasonably homogenous.
6 MR. CALV0: The population itself. But the 7 configuration of the various populations, why you got --
8 I still -- I know what you're saying. You did it based 9 on what you did at Braewood, and that was based on the 10 fact that you come up with 30 -- you got 30 work --
11 MR. HANSEL: Similar work processes and inspection 12 types.
t i 13 MR. CALV0: You say -- okay, all right. That's t J .
14 okay. Okay.
15 MR. HANSEL: Okay. Now once a deviation is 16 documented, it will come back into the same group of 17 engineers that put together, the checklist, and defined 18 the accept / reject criteria.
19 And they're going to verify that that deviation has 20 identified by an inspector is in fact valid. And I'm l
21 not saying that there.is a big population of invaiic 22 deficiencies. But in any situation like tnis, ycu may i
23 have one where the condition as descrioed really is i r.
l ,_ _ . 24 fact in accordance with engineering. _
' ~
25 When it's l'o o k e d at by the engineer, or it's i
GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
210 1 already been documented and accepted on a control
. . . 2 deficiency document, such as an NCR, or you could find
\
3 the point to where there -- the condition was okay at 4 the point in time of the initial construction, and has 5 been some pieces. Subsequent engineering came out, 6 found that item of hardware, accepted it.
7 Or you may in the fourth case, and this gets back 6 to Bob Miller's question. I'm certain we're going to 9 have some where they're highly subjective in nature.
10 And in those cases, we'll use a level 3 as ~a referee.
11 MR. BOSNAK: Just to comment on that, John. If 12 your yardstick that you're measuring your proof design 13 is flawed, then that number A is flawed also. So it u - .
14 goes back to the issue I raised earlier. But it's very 15 important.
16 MR. HANSEL: No. A gets to a potential where an 17 inspector didn't read the checklist or the drawing 18 properly, and called something deficient. And wnen he 19 comes back and actually checks it with the engineerin; 20 and the drawings, it was in fact --
21 MR. BOSNAK: Again, as long as we have an a;rer ert 22 by what you mean by approved design, and that was tae 23 point I raised earlier. And this number 3, I 20n't
_- 24 understand it. If it's a deficiency, then it's a 25 deficiency. Why do you say it's invalid anc --
l GODFREY & AMES COURT REPORTING Metro 469-6100, (617) 460-2048 !
211 1 MR.' HANSEL: I may have in the case of -- I may
_ _ 2 have a condition that was documented sometime in the 3 past, and has been dispositioned by engineering as 4 okay. As is, do not repair. And we in fact agree with 5 that disposition.
6 Now you have somewhat of a diversion, minor 7 diversions from drawing their spec. The inspector-8 picked it up. It has been accepted by engineering and 9 is okay as is. And parallel with that process, the 10 deviations will all go to the project for preparation of 11 an NCR~. So they go a parallel route.
12 At this point in time, we're going to ask that that l 13 hardware not be repaired until such time as we can get
, t 2 14 an engineering group out there to conduct an evaluation 15 for safety significance.
16 Let's go back to the flow chart, John. I nave to 17 apologize.- Sometime during the night one of my charts 18 didn't -- yes, Don?
19 M.. LANDERS: John, I'd like to go back, because 20 I'm trying to figure out what C means. And maybe ycu 21 could help me. Under process deviaticn reporta, '~. nct 22 sure I understand C. And I want to understand.
23 MR. HANSEL: There could be the situation, anc :
_ 24 con't know that it will happen here. I':. nc; :na-
' ~
25 familiar with their system yet. But you could have a GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
W i
1 212 ;
1 1 situation to where you only required rework or s.
. _ 2 modification of certain hangers. A population of 3 hangers or a subset of some hangers by typing, but not 4 on others.
5 And the inspector, when he looked at it, saw a 6 condition. And in fact that particular hanger may have 7 been exempted from a particular modification. You would 8 have to have, in every case, you would have to have 9 evidence of the engineering that covered that.
10 You may have some category 1 hardware that's been 11 modified, versus some category 2 that hadn't, the guy 12 carried it over and looked at it, and the mods on this i
13 particular hanger were not required. And the e _
14 documentation should reflect that by part number, serial 15 number, whatever.
16 MR. LANDERS: Isn't that an A?
17 MR. HANSEL: It is A, but it's almost a -- A. I 18 look at as a -- an inspection accuracy. The guy saw 19 something, and didn't read the drawing right. Whereas 20 compared with C, you do have a released drawing to ecver 21 it. The first one's a call.
22 '
MR. LANDERS: Thank you.
23 MR. HAUSEL: Okay. On the float chart, in tnis
_ , 24 particular bicek right here, wnich I'm golag to es_x 25 about next, that block is correct in saying evaluate GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2046 t-
213 1 results.
_ _ 2 But in that evaluation, we're going to do root 3 cause and generic implications evaluation for safety 4 significant deficiencies. And we will also do trend 5 analysis to identify any adverse trends. So it's bigger 6' than just to evaluate results. It's root cause, generic 7 implications, and adverse trend analysis. And that we 8 will conduct in that area. Going to talk about those in 9 some detail.
10 MR. NOONAN: John, how is that' fed back into the 11 leaders group?
12 MR. HANSEL: Again, if we start to find problems, ,
I t 13 say, in the piping area or cable tray hanger area, we t J .
14 now have some safety significant deficiencies that need 15 to be evaluated. We will be processing that 16 information. They will have access to and get copies of 17 our deviations and our deficiencies.
18 And also they may even be asked to participate in 19 root cause analysis. In fact, it has design 20 implications. There is a tremendous exchange of 21 information between ourselves and them.
- 22 We have in my organization a separate group of i
23 engineers that are assigned the responsit:lity to 24 conduct safety significance evaluation.
,_ _q
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25 MR. BOSNAK: Jonn, are you saying, in that second GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
214 i 1 bullet, that you have the full responsibility for, or is
__ 2 it the other group?
3 MR. HANSEL: Which one are you talking about now?
4 MR. BOSNAK: To perform engineering evaluation.
5 MR. HANSEL: We have the prime responsibility. But 6 we will have a very, very close interface with the otner 7 review team leaders and the design adequacy group.
8 MR. LANDERS: John, I have a concern with the way 9 that's worded, because it is in fact a reflection of a 10 number of issues that have transpired in the past.
11 And that is, performing evaluation or analysis'with 12 respect to safety function. And we get into that 13 situation again with respect to, "What are you going to 14 use? What are you going to comply with? What is the 15 criteria are you going to be using, nonstandard type 16 analys'es and techniques," that kind of situation.
17 MR. HANSEL: In this particular area, this will 18 include again drawings, specifications. And I'm certain 19 in this particular case, considerations of the FSAR.
20 How the evaluation of that goes about, usually 21 figure the worst case. If you have got, for i r. s t a n c e , a 22 welding discrepancy, and a weld is short, they will 1 23 re-evaluate that, based upon wnat remainin; mar;:n is in
_, 24 that particular nanger or support.
25 MR. BOSNAK: I would put a big star in that one.
GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048 j
215 1 MR. HANSEL: What?
, _ 2 MR. BOSNAK: I would put a big red star about that 3 bullet.
4 MR. HANSEL: Why is that?
5 MR. BOSNAK: We're concerned about that particular 6 aspect.
7 MR. HANSEL: Yes. We're bringing in these 8 particular evaluation people from Stone and Webster.
9 People will be working with me and conducting the 10 evaluation. There has to be a very close interface with 11 the other design adequacy group and the other review 12 team leaders.
i 13 MR. LANDERS: Okay. Can I add here, John, that you o J .
14 said consideration to the FSAR requirements?
i 15 MR. HANSEL: Yes.
16 MR. HANSEL: John committed me on the front end.
17 Ve will put it in the back end as well.
18 MR. CALV0: I'd like to go back to the po'pulation.
19 You want to go ahead and finish?
20 MR. HANSEL: Go back to the population for just a 21 second. John Guilbert, did you have a point?
22 MR. GUILBERT: Yes. John Guilbert on the senior 23 review team. Bob, you have raised the question several
__ 24 times with respect to what extent we go back tc tne
' ~
25 FSAR. This quality construction, one of the things we I
i r
GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
o 216 1 need to understand.
. _ 2 First of all, we have two self-initiated programs.
3 The employees, John Hansen is one, is intended to 4 determine whether or not the plant as constructed was 5 properly constructed in accordance with the design that 6 was given to the people to construct it to. And it was 7 sampling that to determine whether or not the people 8 were constructing it right.
9 On the other hand, as you will hear tomorrow, we 10 have a number of activities looking at various aspects 11 of the design processes, which start with the design 12 criteria, and determine whether the designers actually i
.13 met the design criteria and commitments when they 14 designed the' plant.
15 These are two supplementary efforts. But they each 16 have a different purpose. Okay. Now when you get into 17 the safety significance evaluations of deviation and 18 deficiencies from the construction process, certainly 19 then you have to look at the underlying criteria the 20 designer used for the design it was constructed tc. An:
21 that's going to relate back to the FSAR.
22 And nevertheless, it's a comnitment. So come 23 again -- so you have to understand those are two
__ 24 supplementary or complimenta*y programs going here.
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25 They're intended to reach'a conclusion on separate GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
217 1 things.
_ _ 2 MR. BOSNAK: I tnink I understand what you're 3 saying. But I don't know how well the thing is going to 4 be integrated. That's the way --
5 MR. GUILBERT: The way it's being integrated is, is 6 that we're doing enough checking through the number of 7 populations and samplings.
8 We're doing, in both pieces of that program, to 9 individually come a conclusion we can extrapolate. And 10 either one of them-to their end, so that we can make a 11 conclusion based upon the total population, as it were, 12 from the point of view of construction weld and from the i
i 13 total population ove'r here, as it is for design u J .
14 quality. Therefore we dealt with it across the board.
15 MR. LANDERS: John, I have no problem with what you
~
16 have just said, other than when I see the word safety 17 significance and recognize that someone is making 18 judgment on what an inspector will look at it in making 19 that determination.
20 MR. HANSEL: Oh, that will not be an inspector.
21 MR. LANDERS: I understand it won't be. He is 22 going to be provided. procedures. And we need to kncu l
23 the basis for those procedures and the determination of
_ _ , 24 what is safety significant. Tnat's our only concern
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25 with respect to the link between construction and design GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
218 1 and FSAR. That's the first one.
. _ 2 And the second one is, when a deviation occurs, and 3 I'm going to evaluate the safety significance, we are 4 concerned because of what's occurred in the past, that 5 that evaluation will go well beyond the standard 6 evaluation used in designing the plant.
7 MR. GUILBERT: Understood. But I think you know 8 enough about FSAR's to know this -- the kinds of plans 9 are, and the kinds of things you would inspect, are not 10 randomly included in the FSAR. They're in the 11 underlying document, drawing, procedures, 12 specifications.
L 13 John Hansel's offering -- this program, until he u -
14 finds a deviation, that those underlying criteria, 15 commitments, et cetera, have been accurately reflected 16 in the design, that that guy who has asked to go 17 construction.
18 It's only when he finds a deviation, he will.then 19 go back and maybe perhaps question the other issue as 20 well.
21 And Howard's task is to verify that he can make s 22 statement to the extent of what he's looking at, that 23 he's got confidence that the plan was desi;ned in f , _ _. 24 accordance with the design criteria.
~
25 MR. LANDERS: I understana that. But we did get a n' GODFREY & AMES COURT REPORTING 4 Metro 469-6100, (817) 460-2048 l
1
219 1 answer that said, you know, if the weld size doesn't
_ _ 2 agree with the drawing, that might be acceptable. And 3 based on what you just said, it is not acceptable.
4 MR. GUILBERT: It will have to be evaluated.
5 MR. HANSEL:. Don, we're going -- the checklist will 6 be put together primarily concerning safety'significant 7 attributes, inspect document deviations. And those are 8 evaluated by some very senior engineers to determine if 9 in fact that~ defect or deficiency as identified is 10 safety significant.
11 And they will take all the tools that thcy need in 12 terms of calculations, drawing, background information i
l 13 -on that particular hanger, support, whatever it might be t J 14 to make that -- to draw that conclusion.
15 , HR. LANDERS: The more you say, the more concerned 16 I become.
17 MR. CALV0: John, if we are going to approve your 18 so -- we know that plan is sufficiently -- sufficient, 19 and we don't have to wait for the results to approve in 20 for that new choice.
21 MR. HANSEL: You had a question on populations?
22 MR. NOONAN: I think I'd like to take a break nos, 23 for the reporter.
_ _ , 24 (Whereupon tnere was a recess.)
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25 MR. HANSEL: I think for the sake of clarity, I'c GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
220 1 like to take just a couple of minutes.
.. 2 MR. NOONAN: John, let me interrupt you a second.
3 During the break, the staff was talking to me about the 4 safety significance. And it's not clear to us of 5 defining whether.it's -- it appears to be judgmental, I 6 know. It's know it's not. It's just not clear.
7 I think in your program, you're going to have to be 8 very explicit what you mean by safety significance. I 9 got that from a number of staff people. I want to make 10 that request from this podium, how you stand, very, very 11 clearly on it.
'12 MR. EISENHUT: I wanted to ask more of a logistic 13 question also. We were talking about, before we 14 started. Can you give me a rough idea when at the rate 15 we're now going, when you think you would finish the 16 agenda which you had in mind for_today?
17 MR. HANSEL: Without, and I don't mean this 18 facetiously, without a whole lot of questions, 15 to 20 19 minutes. 30 minutes at the most.
20 MR. EISENHUT: I want to make the assumption tnat 21 if the pace continues the way it's been over the east 22 few pages. I had the pleasure of going over the project 23 with a number of people, and last night we finisned a
,, 24 couple, three nours late. .So I was just tryir.s to :; e t
~
25 an idea.
l GODFREY & AMES COURT REPORTIMG Metro 469-6100, (817) 460-2048
221 1 MR. COUNSIL: Based on what Ive seen thus far this
.. _ 2 afternoon, I would say approximately two hours.
3 .
MR. EISENHUT: Okay. What I would like to do, at 4 the end of that, I would like to ask if'there is any 5 members of the p-ublic. I'd like to ask the official 6 intervening organization whether or not they have any 7 comments up to this point at this time.
8 And I would like to entertain those comments later 9 on.today. So I'll go ahead and plan those in the 10 agenda, to hear any comments or feedback. Obviously 11 there's going to be more than ample time duwn the road, 12 but I wanted to give them ample time. *
! ! 13 MR. NOONAN: The only other comment I wanted to t J 14 make, the staff is looking at the program plan from our 15 prospective. We're looking at, of. course, the design 16 issues and the -- and the common treat of -- both these 17 issues the staff is looking for that..
18 I can understand we have to hear from Howarc more.
19 I think we will be looking at, how does Howard Levin 20 address quality assurance issues, and how are those 21 things communicated tc John Hansen? Okay.
22 MR. HANSEL: Okay. Let me take just a couple of 23 minutes and make sure that I -- I want to try to clear
_ _ , 24- up any misunderstandings that exist cn tnis etcer
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25 subject. We're going to put the hardware in the GODFREY & AMES COURT REPORTING Metro 469-6100, (817)-460-2048
222 1 populations.
_ _ 2 We will select random samples from each of those 3 populations. Within those populations on a population 4 by population basis, we will define attributes for 5 inspection. You may have, and I. don't know what the 6 numbers are. I have seen attributes for those ranging 7 anywhere from 78 to maybe 15. You will have two 8 samples. One will be a random sample totally selected 9 at random, of 60.
10 You will have a second sample that currently is 11 planned to be based on those systems required for safe 12 shutdown.
13 There will be an inspection checklist put together u - .
14 on a population by population basis that will be based 15 upon released drawings and specifications, and any codes 16 or standards that they reference.
17 We do not plan to inspect for attributes that are 18 not significant. If there is an attribute that can have 19 any impact, any impact on the safety of that hardware, 20 we're going to inspect for it. I would not expect us to 21 go out and inspect for -- let's classify t a e.: as 22 cosmetic type defects. That's the only ones tnat are 23 going to be left out. I want to make certain that you
_ _ , 24 feel comfortable with that.
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25 Any deviations from the drawing or specification GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
223 1 that the inspectors pick up will be documented. They
_. 2 will be turned over to the project on an'NCR system, and 3 each one will be evaluated on a case by case basis to 4 determine if in fact that defect as it stands on that 5 piece of hardware, is it significant enough to cause 6 that item to not perform its safety related function.
7 If it is such, it will be classified as safety 8 significant. And then we will go about the root cause 9 and generic analysis or generic implications analysis on 10 a case by' case basis, what caused it and what are the 11 implications of that defect.
12 We may find that that leads us back into more
(
l 13 hardware inspections, and a sample re-expansion or a LJ 14 sample expansion. We may finds that it leads us off 15 into other types of investigations or other~ action 16 plans.
17 But we will stay with that until we understand tne 18 causes and the implications, and we have made 19 recommendations on how to fix the issue or issues.
20 That's the total intent of that self-initiated program.
21 When you take the 30 populations, approximately 30, 22 all the attributes ~and all those inspections and the 23 documentation reviews, we will have covered all of tne
.,_ _, 24 work processes and' inspections of the type tnat are on
' ~
25 that plan. Okay. Let's move right alchg.
GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
-, 1 224 l l
1 MR. CALV0: Not yet.
. _ 2 MR. HANSEL: Okay, Jose.
3 MR. CALV0: This populations in here, I'm looking 4 at some of the -- you indicated they have to be 5 homogenous, base.d on the attributes used in each 6 population; right?
7 MR. HANSEL ~: Yes.
MR. CALV0:
8 Now is your program plan -- is going to 9 indicate -- you're going to analyze, for instance, the 10 electrical design for the construction design. And you 11 come up with population for conduit population, for 12 cable tray electrical equipment installation.
' i 13 And I understand you -- in the recess somebody e J 14 said, "Well, maybe we had to put instrumentation, some
. 15 kinds of words not indicated."
16 But that's beside the point now. On the cable, for 17 instance, I got cable terninations, wiring separatien, 18 and ali that --
those are the attributes. Okay.
19 Now assuming that for any one cable in that plan, 20 all the attributes are homogenous to the sample that you 21 have picked up. That's what you saying?
22 MR. HAllSEL: Yes.
23 MR. CALV0: Then you're going to have tc prove that
~
, ._ . , 24 case. For instance, if I'm saying terminaticns,
~
25 attributes to cables, if all the terminations in tne GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
225 1 plant are homogenous, are same, or you can give the
__ 2 same, tnen they become some attributes that are not the 3 same. Maybe --
4 MR. HANSEL: Then I may have to have another 5 population. This is a preliminary list.
6 MR. CALVO: That's very important, because the 7 self-sufficient program that you had -- my wish is roing 8 to come from this one. And I have got to understand, if 9 this 30 populations are representative of what is on 10 that plan, and the attributes under those populations 11 are homogenous, so the case you have got to present in 12 the program plan is the basis, the rationale, how you 13 arrive to these third populations, and the attributes L;
14 and the homogenous for those attributes. You're going 15 to do that.
16 MR. HANSEL: A certain amount of detail will be 17 included in the program plan. Yes, I think enough to
~
18 satisfy you. The details of that are in detail 19 procedures that we are developing and have developed at 20 the site.
21 I think to really answer your question, ycu're 22 going to-have to come to the site and see the popu_ation
'l 23 descriptiens, and the attribute list, and the cheex list
_ _ , 24 to really satisfy yourself we have included e v e r y ; r. i n ; .
~ ~
25 MR. CALV0: I'm going to the site.
GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
226 1 MR. EISENHUT: He'd love to go to the site.
_ _ 2 MR. CALV0: Hold it. But you have also got to
. 3 submit us-by-the 28th.
4 MR. HANSEL: We have given you sufficeint 5 understanding to --
6 MR. EISENHUT: No, have to submit the detailed 7 program plan whenever they're done with it.
8 MR. CALV0: They said by the 28th.
9 MR. BECK: That will not include procedures check 10 lists.
11 MR. EISENHUT: But should include enough of the 12 criteria, or how you go about ginning up this?
13 MR. HANSEL: We have to give you enough information w-14 to where you know -- you can understand what we're 15 doing, and how we.'re doing about it. The specifics at 16 the site.
17 MR. CALV0: Yeah. A little more than what you give 18 us. Give us a preview now, we need a'little deeper than 19 that, to want to understand how you come up --
20 MR. HANSEL: We will do that. But for eacn of 21 those steps on that flow chart, we have a detailed 22 procedure at the site that's either develcped or is very 23 close to being completed. It will get down tc the
_, 24 really nitty gritty.
25 MR. CALV0: My concern is the foundation of it GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
227 1 right now. I would like to see how you put a foundation
. . 2 together so you can build it, the rest of it.
l 3 . MR. NOONAN: John, you say those procedures are at l 4 the site now.
5 MR. HANSEL: We have, Vick -- what do we have?
6 MR. HOFFMAN: Seven out of the ten.
7 MR. HANSEL: Seven out of the ten procedures are 8 completed. The other three are close, should be 9 completed probably by this time next week. That's the 10 detailed procedures, Vince, that tell our engineers 11 exactly how to do those jobs.
12 How to identify the population, how to select a i
13 sample, how to prepare the check lists, and the detailed L_
14 methodology of what that engineer needs to work with to
! 15 do that job. .
16 I think really that's what folks like Jose, Herb
- 17. Livermore, and then others are going to --
18 MR. CALV0: Some of that. Not all of that at this 19 time. You talk about implementation. I'm not wendering 20 about the implementation of the plan. I'm wondering i
21 about the foundation of that plan. That's any I ' ~.
22 asking right now, is the foundation.
23 MR. HANSEL: We'll make sure you get that.
__ 24 MR. SHAO: Okay. I nave one question en tne c a rc e
' ~
25 page as -- what do you mean by mechanical e q u i p m e r. t GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
228 1 installation? What kind of mechanical equipment do you
_j 2 have in mind?
3 MR. HANSEL: I can't answer that off the top of my 4 head, Larry. It's any type of mechanical equipment, as 5 compared. There.'s also electrical equipment 6 installations on there. So I would say it's probably 7 pumps, valves -- A1, give me some others. Just two or 8 three.
9 MR. PATTERSON: Heat exchangers.
10 MR. HANSEL: It's that type of electrical 11 equipment, Larry.
12 MR. SHAO: The reason I ask the question on piping, 13 you have many, many items. But in equipment, you have 14 one long. What's the difference between piping and 15 equipment? In this case you can look in more detail in i
- 16 piping and less equipment?
l 17 MR. HANSEL: No. Again, I approached this list 18 from -- now that list of mechanica) equipment may be 19 very long.- But I approached this through work processes 20 -and inspection processes. And the disciplir.es required 21 to install mechanical equipment usually are pretty well 22 the same. Alignment procedures, rigging, installatien, 23 folding, torqueing, shimming, et cetera. And that's tne
,_ , 24 way we get at it. Okay.
25 All right. In addition to the -- see, where we're GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
229 1 at, in addition to the safety significance evaluation,
_ j 2 we will also take the deviations that did not result in 3 deficiencies, and do an analysis .for adverse trends.
4 And then from there if we see that there is an 5 adverse trend, we're going to go about the analysis of 6 root cause and generic implications for those. And that 7 may spawn new evaluations. Next chart.
8 I have six charts that I'm going to whisk through 9 here rather quickly. I think most cf us are familiar 1b with what you can do in root cause' analysis. All I have 11 done here is list some of the potential root cause --
12 root causes that you might run across.
6-13 Design, we're looking at unclear or un -- or L..-
14 conflicting directions of the field. We're looking, 15 really, at constructability issues. "Was it unclear, 16 and as a result, did it get constructed wrong?"
17 Looking at documentation, we may nave had an 18 incomplete drawing, incomplete procedures, confitet 19 between drawings and procedures or specs, and so forth.
20 Looking at workmanship, there's a wide nutber. You 21 could have inadequate standards, tooling, training, 22 selection of personnel, insufficient time, whatever.
23 Moving right along to inspection, we coulc nave
,__, 24 some of the same kinds of root causes. Eitner the --
2 :n
' ~
25 I way ahead of you?
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230 1 MR. EISENHUT: Yeah. I think you are. I'm still
/
iJ 2 thinking about three slides back.
3 MR. HANSEL: All right. I didn't want to dwell on 4 these. We can if you like. It's just a shopping list-5 It can lead you down to root cause analysis. You just 6 have to take the data and try to found out what caused 7 that.particular issue.
8 MR. EISENHUT: And there's a large number of 9 different things that can get you there.
10 MR. HANSEL: That's all I'm showing by these six 11 charts.
12 MR. EISENHUT: Documentation, you're starting your 13 effort, though, with the assumption that the design L.,
14 drawings are accurate?
MR. HANSEL: Yes.
16 MR. EISENHUT: Let me understand again then, from 17 the previous discussion. In parallel with your effort, 18 there would be some checking to see that the 19 documentation drawing, the detailed drawings, are 20 accurate.
21 MR. HANSEL: That would be drawn through Howard 22 Levin's' effort, design accuracy.
23 MR. EISENHUT: Right. And what can you see f r c .,
,_ q 24 the time when would you see there would be enougr. of a 25 feedback so that you would know whether or not you need GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
231 !
1 to reconsider some of the work you are doing.
,) 2 Are you talking six months down the road, or are 3 you talking about-two months down the road, where you 4 start getting some feedback as to whether or not the 5 detailed drawings are accurate or not?
I'm trying to 6 get a feeling of whether you're going down one path the 7 long way before you get that. feedback, or how you 8 propose to do it.
9 MR. HANSEL: I really don't know what that time 10 period looks like.
11 MR. MARTIN: Are you, apart from that, establishing 12 a time line? Are you scheduling your resources to i 13 work -- start working in the areas in which Levin's 14 group's, confirmation of design, is currently working, 15 so time lag is the least?
16 MR. HANSEL: We're going to be in parallel. Yes, 17 we're both working --
,-18 MR. MARTIN: In the same topical areas in terms --
19 MR. HANSEL: Yes. We're trying to tie that 20 together. And I'm also attacking -- going to attack 21 those areas of the plant first that we feel where tnere 22 could be problems that would cause a delay in fuel icad.
23 MR. MARTIN: Okay. But there you're dealing witr.
24 areas in which you are concerned tnat there may in fact
'~
25 be -- there may in fact be deviations whien are GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
232 1 different from existing design drawings.
.-I
_J 2 MR. COUNSIL: Could I address that, please? Bill 3 Counsil. I'm right across from you, Bob.
4 We have two programs. John's program is assuming 5 the design is correct, because what he's trying to 6 determine, was the plant constructed in accordance with 7 the design? That does not say that that design is 8 right.
9 Howard's program is trying to ascertain, is the 10 design in fact correct. If the design is incorrect, 11 John's not going to get back into it again, because if 12 the~ design is in fact -- unless there are attributes 13 that he has to reinspect, if the design is incorrect, I u _
14 have got to fix it.
15 MR. MARTIN: Goes back to the project.
16 MR. COUNSIL: It goes back to the project where I 17 have to either rework or disposition. Do you understand 18 the difference between the two?
19 MR. EISENHUT: No. I understand -- and what I 20 felt, really looking, I think there may be a third piece 21 in there. And I was just really looking as to wnen.
22 My first question was when we would start expecting 23 to see Howard's effort produce some feed'oack en -- ce's
,__ 24 looked at enough of the design, and start settin6 a 25 feeling in some of the areas.
GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
233 1 But really my question is, the second part of the
^;.
- .J 2 question, really, is I think there's sort of two 3 pieces. The basic design may be adequate. Then someone 4 goes and makes detailed design drawings out on the 5 field, and they go through with revisions to the 6 electrical drawings or whatever.
7, And the way you did it here with your drawings-8 while the plant was being developed, you may have gone 9 through 25 revisions with the same drawing, where if you 10 went out'to the DCC, which is fine, the basic drawing, 11 then part revision, part revision you may have 25 12 revisions stacked u'p where you don't really have a final 0
13 design. There was no final design for a while, other
, c _
14 than original drawing plus sequential 24 more 15 amendments. .
16 And that was one of the things we 1 coked at when 17 which we went out and looked at drawings. So the-18 original design may have been all right. There was 19 design implementation through the design drawings and l
20 then construction adequacy.
21 So that's why I was really lo'oking at the bricge in 22 between, as the fact that the drawings, as to wnen you 23 would start seeing the cycle closing itself, ciestn on
,_ 24 itself at some point in time. I appreciate that 25 they're sort of totally separate. !
GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
1 234 1 John's really looking -- you're looking at the
, ) 2 adequacy of the construction. And the other one, you're 3 looking at design adequacy. And the thrust of where I 4 was going to come from was the interface between those 5 two.
6 MR. COUNSIL: Well, part of what John is doing is 7 the as built condition of the plant. He has to inspect 8 the final design drawing. And if in fact that design 9 was not translated through the system of revisions, when 10 he goes out and looked for his attributes, he's going to 11 find deviations.
12 And that would lead us straight back into the, i
13 quote, design drawing, and the as built condition of the L .. - ,
14 plant. And now to answer you more specifically on 15 timing of this, we'll start getting results out of his 16 program in July. Howard's program probably in the 17 August time frame.
18 MR. EISENHUT: I was thinking, there's a simple 19 answer to this question. When Howard is standing here 20 tomorrow, when are you going to start producing 21 reports.
22 MR. COUNSIL: That should be the tia.e fran e of 23 what we are going to be seeing.
24 MR. NOO N A N _: Let me ask you one question. Go b a ci:
'~ ~
25 to design for a minute. You find out you have a prob 2ea GODFREY & AMES COURT REPORTING Metro 46'9-6100, (817) 460-2048
235 l 1 th design. You will say.that you go back to your j 2 design. You find a problem. Look at design, that 3 you're going to fix it.
4 The question I would now have, is that design, that 5 same group of people, work someplace on that plant where 6 they right have also had a problem with design?
7 MR. COUNSIL: That's a valid question, and that 8 falls into our trending program and so forth.
9 MR. NOONAN: Is that Howard Levin's effort?
10 MR. COUNSIL: Under design, that's Howard Levin.
11 And 'll explain to you on his baskets and how he's 12 go. to trend it.
13 What he's going to do is tell you tomorrow u _
14 basically that he's going to cover every kind of design 15 activity, so forth, and all these activities. There 16 will be trends in them, and any ' place that they 17 touched, if there is a required expansion of a 18 program, he will make sure he covers all of it.
19 MR. SHAO: I have the same comment as Vince 20 here. He said maybe since design correlations is 21 not doing the wrong design, but is it p o s s i'ol e to 22 say that the construction may have some over nere 23 also, construction somewhere else have the same
_ _ , 24 problem?
25 MR. HANSEL: I'll be looking at that through GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
236 1 generic implications, either on a case by case or on a j 2 trend analysis.
3 MR. BOSNAK: Could we add to where we are now?
4 Where does Stone and Webster fit into this whole 5 picture, since they are -- we say piping and pipe 6 supports, and then we're told they're all going to be 7 redone.
8 MR.~COUNSIL: Are you ready for my answer?
9 MR. BOSNAK: Any time.
10 MR.'COUNSIL: Okay. Stone and Webster is not on a 11 sample basis. Stone and Webster is doing a hundred 12 percent redesign, reanalysis check of the as built i
13 condition of the plant for all class two and class three L .
14 piping supports. And they will explain that to you 15 tomorrow. They are not on a sample basis, period.
16 There will be a third party overview of the' Stone and 17 Webster effort.
18 MR. EISENHUT: Right. But there would be nc need 19 to go back. And you're not then doing a samplin6 of the 20 previous work, design work in that area, if it's going 21 to be redesigned. Or not redesigned, or recnecked, all 22 the way across.
23 What you're saying is that -- and I would take 1;
,_ 24 also tnen, e n a t i f 'j o u decided to go in;0 a t: o t h e r area ,
6 j
l 25 with a larger group, let's say, and just literally !
1 1
GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
237 1 recheck a hundred percent, then that piece would drop
. ; 2 out of the program of Howard's end, at least from 3 design, except for construction, you would look to see 4 if it's built adequately. And if you found a 5 deficiency, you would look to see whether that generic 6 deficiency may exhibit itself under different places.
7 MR. COUNSIL: That's right. Root cause, generic 8 implications. Even if we find that type of problem, 9 which I had anticipated that we might find in piping, 10 and that's the way I'm going to have to do piping to get 11 -- to do a hundred percent, if in' fact the population 12 samples that Howard finds or John finds requires a 13 continuing reanaly' sis, expansion of the entire program,
- u. -
-14 it might come to a decision making process, we'll just 15 do a hundred percent. Yes, sir.
16 MR. HANSEL: Okay. This is Ed Jordan. I have got 17 a question about the sampling. Is there any 18 relationship between the sampling for design and the 19 sampling for construction review?
20 NR.. HANSEL: Any relationship?
21 MR. JORDAN: Relationship between tne two sa.rpling 22 programs? Are there two samplings programs?
23 MR. HANSEL: There are two sampling progra.ms.
,_ 24 MR. JORDAN: Independent?
~
25 MR. HANSEL: Independent. We have, however, found GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
238
. 1 one case where it's convenient to define the same
_s 2 sample, and be used for both purposes.
3 And that's in conduits. And that's primarily 4 because of the way we can get to the population through 5 isometric drawings. That's the only case I know so 6 far.
7 In that particular case, we will both agree upon 8 the definition of the population. The sample will then 9 be selected randomly. We are going to develop one 10 checklist for inspection that includes both the 11 attributes that we need, and the attributes, the design 12 adequacy we need.
i 1 13 And then we'll go inspect the' hardware. The data LJ 14 will be provided to both groups. So far that's the only 15 one. But it is a possibility. We may have others, I 16 haven't seen it yet. But that one we're going to do for 17 pure economics. We can do it together and quickly, and 18 satisfy both reasons and still be statistically sound .
19 MR. JORDAN: Okay. Let me ask you one more about 20 sampling, then. The homogenity of the sampling, does 21 that include'who is responsible for the ucrk activity?
22 For instance, for putting in supports, ancncrs, for 23 instance. You may have several different con:ractorc
,__, 24 perfccmir.g that activity to have a ac t.:o g e n o u s sample.
' ~
25 It may not be appropriate to have one large sample out GODFREY & AMES COURT REPORTING ,
Metro 469-6100, (817) 460-2048
239 1 of that whole set.
. 2 MR. HANSEL: We're alert to that. We're looking 3 at, waiting to see that population, where we have enough 4 coverage, say two or more contractors. We may have to 5 have two populations. That's why it's a preliminary 6 list, again. But we do look at that possibility.
7 MR. CALV0: Wait a minute. You confused me.
8 Talking about the design effort, design review 9 adequacy. I was under the impression thtt there was 10 never going to be population for the souno review. It 11 was based on the basis, I will seu tiow you an do the 12 design review based on population.
13 I don't see how-you can improie homogenity there.
L -
14 I thought maybe you were talking about the populat..on 15 with respect to the walkdown. That is part of this 16 sound review? Is that what you're talking abouti 17 MR. HANSEL: Guilbert's got his hand up. _Let's let 18 John -- he's been closer to Howard in that respect.
^
19 MR. GUILBERT. Jose, you're goins to hear about let 20 more about this tomorrow. The specific example that 21 John gave you -- be associated with an action plan that 22 doesn't fall --
23 THE REPORTER: I can't hear you.
24 MR. GUILBERT: action plan that coesn't fall in
,_q
~
25 the category of tne self-initiated design GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
240 1 verifications. That's another design adequacy action
_j 2 plan. And actually it seems from the TRT issue.
3 MR. CALV0: But it really provides us with the 4 perception, but I don't believe it's the right 5 perception. Now we're going to do a design review, the 6 construction review, so.
7 But if that's case, I see some problems coming from 8 homogenity with the design review. So if you want to 9 say that the record will be cleared up tomorrow, that 10 will be perfectly all right.with me. ~
11 MR. GUILBERT: At the risk of stealing a little bit 12 of Howard's thunder, as you can see, John Hansel's i 13 approach is basically starting with construction and
- c. -
14 work activities, leading the populations, leading the 15 attributes to evaluation.
16 Howard's self-initiated design verifications, which 17 is only a part of his design adequacy program. It's a 18 self-initiated part, starts with design work activities 19 as its para'llel. And results in selection of 20 appropriate systems that he will review _through a e'of 21 attributes, as it were. flo t the same kind of 22 attributes, lookin5 through design process.
23 His intent -- he will be presenting to you an
. . _ , 24 initial set cf systems that he's acving out on. :ie';
I 25 got a verification program to insure that either those GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
241 1 cover the full range of design work. activities, or that
.) 2 we add additional systems or parts of systems until we 3 do accomp1.ish the full range.
4 Now there's a quote, unquote, parallelism in the 5 sampling routine; really gets down to the depth, like 6 the number of calculations that he looks at on attribute 7 A in system B. Okay.
8 It won't be done on a purposely statistical basis, 9 I don't believe, but it will be done on -- there's only 10 10 calculations in there. It will probably draw 10.
11 There are a hundred. They'll probably do whatever 12 sounds like a representative number. You can ask him
' 13 tomorrow.
u-14 MR. CALV0: Okay.
15 MR. SHAO: Tomorrow, Mr. Hansen, you will be here 16 tomorrow?
17 MR. HANSEL: Oh, yes. You bet. Wouldn't miss it 18 for the world. Moving right along.
19 Again with potential root cause, we would also 1cok 20 at corrective action programs to see if we had 21 recurring deficiencies that had not been fixed by 22 earlier correction action programs.
23 We would also look at records, was it a prob:e:r
,__, 24 that was attributable to incomplete and inecrrect 25 illegible records.
GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
242 1 The trending program has its -- as its objective '
j 2 goal --
3 HR. EISENHUT: Excuse me. Can you go back one 4 more? The last entry says unauthorized signature.
5 MR. HANSEL: Yes.
6 MR. EISENHUT: Do you think there is -- is that 7 just a potent'al root cause?
8 MR. HANSEL: Just a potential.
9 MR. EISENHUT: Okay.
10 MR. HANSEL: I d'on't know what I'll find there.
11 Just a potential. And that's a shopoing list of those 12 that I have been using for a number of years from
! 13 different programs. And there's probably a list twice L. _
14 that long if I wanted to develop it.
15 The objective, of course, in the trend analysis, 16 we're looking for adverse trends, and we're apt to 17 identify deviations. If you take them by themselves, 18 they're really not all that significant. But if you 19 take them in the collective sense, then they may have 20 some implications. Next chart.
21 What we're really after in the trend analysis, 22 again, and I have been asked the question many times, 23 "Can you identify what the level is when you have c 24 trend?"
' ~
25 I don't know what that number is. But it's wnen GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2046
243 1 you have a trend that indicates that you- may have a
,. s ,
- 2 problem with the population of hardware, a certain 3 attribute, a certain process, a certain specification, a 4 certain inspector, a certain shift or whatever.
l 5 It's any indication that says that you may have a 6 trend, and it says that it's undesirable. . That number 7 will vary, again based upon the complexity of the I
8 deviations, because not all defects or deviations are of 4 9 the same significance. If I go back to Ed's point, I 10 could have critical, major, minor, and sort from that 11 viewpoint.
12 So the aspect of identifying adverse trends really
- 13 is about -- that's the way we go at it. We analyze i V-l 14 those deviations on a population by population basis, 15 and look for trends.
16 If we do find what we classify as adverse trends, l
17 we're going to go after the root cause of that trend.
18 And what are the generic implications of that trend, 19 either in that population of hardware, other populations 20 of hardware,'or in a programmatic issue.
21 But what do we need to do, to research tnat cut, to 22 be certain we're satisfied ourselves that we nave 23 nothing further to worry about in tnat area. N e:: t
,_., 24 chart.
' ~
25 MS. ELLIS: Excuse me just a moment. I don't xnou GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
244 1 how the other'pages were, but I didn't have that 1
_ ; 2 particular one.
3 MR. EISENHUT: I think the last page was 4 missing.
5 MS. ELLIS: I wanted to be able to give it to the 6 Court Reporter, so it will be in the transcript.
7 MR. HANSEL: I'll make sure that happens. Now 8 we're going to talk very -- yes, Bob?
9 MR. MARTIN: John, before going on to these last 10 two elements. In the reinspection program, you 11 identified one box that you didn't dwell on, but you 12 discussed the verification packages. I presume this is t 13 just a work package. It's a combination of --
L ]
14 MR. HANSEL: It's a work package.
15 MR. MARTIN: -- the inspection to be done?
16 MR. HANSEL: It's got the drawings, the specs, the l 17 checklist, the specifications, any special l 18 instructions. It tells him -- it give him the NCR's he 19 may need for that inspection. If there are d r a w i r.g s or 20 specs that are not in there,'it tells him where to go 21 get those. It's a detailed work package 22 MR. HANSEL: In looking at the latter twc boxes, we 23 will receive information froa other CPRT issues, acticn
-- 24 plans, and from other investigative programs. I n i n.:
l
' ~
25 most of you are familiar with the other issue plans GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
245 1 written by the other folks. And you will hear more
_ ) 2 details tomorrow'on the ot.her investigative programs.
3 Next chart, John.
4 Going to talk just briefly, because I have covered 5 most of it today.. We have interfaces. My team has 6 interfaces with a number of folks, certainly the senior 7 review team, the other review team leaders, and issue 8 coordinators, the design adequacy group.
9 There will be occasion when we need to talk to the 10 author 1' zed nuclear inspector to be certain that we have 11 no disagreement as to our inspection procedures and 12 attributes. We will have and certainly need to interact 13 with TUGC0 management and Brown & Root management, L.-
14 scaffolding, access to drawings, inspection records and 15 so forth. Anc we have available to us Doctor Webster, a 16 statistician, that supports us in the review team.
17 The kind of things that take place between those 18 interfaces are discussed below, and this is -- we 19 exchange excessively on CA/QC issues between ourselves 20 and the other groups, from them to us and from u to 21 them.
22 We have and will continue do assist tnem if they're 23 going to do some inspections in the electrical area.
_, 24 This is a good example. We talked with Martin J r.es, 25 and developed the actual inspection procedures that we 1
GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
246 1 used for his inspections.
] 2 We then certified our people, and went and did 3 those inspections for him, analyzed the results on the 4 inspection formats, and provided that data to him.
S We'll be doing that in a number of other cases. In the 6 case -- well, there's just a number of others. We will 7 conduct for them inspections and documentation reviews 8 as required.
9 MR. CALV0: May I ask you a question? You 10 mentioned the electrical established procedures. Who 11 developed the procedures? Martin Hills or'you people?
12 HR. HANSEL: The actual procedures we developed,
! i 13 and he approved.
LJ 14 MR. CALV0: Right. And that's going to be in 15 accordance with some kind of QA/QC7 What kind is the ;
16 QA/QC requirements developed by your group? {
17 MR. HANSEL: I'm not sure I'm understanding you.
18 We develop the checklist for those inspections in 19 accordance with the TUGC0 and the drawings and 20 specifications for that particular hardware.
21 MR. CALV0: Which QC program controls those 22 inspections?
23 MR. HANSEL: Mine,
_ _ , 24 MR. CALV0: All right.
l
' ~
25 MR. HANSEL: It's totally independent from tne GODFREY & AMES COURT REPORTING Hetro 469-6100, (817) 460-2048
247 1 project. It's third party, independent.
.j 2 MR. CALV0: Any corrective actions as a result of 3 those inspections, who does, though?
4 MR. HANSEL: We provided those -- that information 5 to the project generated YNCC.
6 MR. CALV0:. Who controlled QA/QC? Controlled 7 NCR 's or corrective actions?
8 MR. HANSEL: The project, after we identified the 9 deficiencies, we notified the project, and assured 10 ourselves that NCR 's were written. It's in the 11 projects. And then they close them out'. They work them 12 and close them out.
13 MR. CHANDLER: Larry Chandler again. To follow-up '
14 on that. The project will be using what QA/QC program?
15 MR. BECK: The project.
16 MR. JORDAN: The project's?
17 MR. BECK: TUGCO.
18 MR. JORDAN: Will that program be subject to any 19 implementation prior to -- in other words, to go back a 20 little bit, a number of deficiencies have been 21 identified in a variety of staff documents over tne lass 22 few months dealing with programmatic deficiencies in a 23 CA/QC program.
24 And in my own mind, I'm wondering whether furtner 25 implementation of that program, uncorrected, will lead GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
248
.1 us to the reasonable assurance kind of finding, that,
_) 2 you know, we have been looking for as to the end of the 3 process.
4 MR. SECK: There have been a number of bodies 5 examining Comanche Peak from a QA/QC standpoint, 6 including the initial evaluation that was done at the 7 beginning of the summer in 1984 8 With regard to the adequacy of the programs in 9 place and being utilized, visavis continued 10 construction, for example.
11 We have looked ourselves very hard at the output 12 that's come from the investigation that's taken place so F
L.
13 far. We see no reason to not continue using the program 14 as it exists today for continued construction activity, 15 whether it be correcting deficiencies that are 16 determined as a result of CPRT, or whether it be in the 17 normal course of construction.
18 We are not blind in any way, shape, or form to the 19 necessity when it arises from time to time to modify tne 20 program, to improve it. And we're doing that on a 21 continuing basis as it goes on.
22 But we are using our program to do project related 23 work, as I said, be it construction, as things progress, 24 or be it correction of deficiencies that nave turrec up
, _ ,I 25 from whatever source.
GODFREY & AMES COURT REPORTING Hetro 469-6100, (817) 460-2048
249 1 MR. JORDAN: And, John, your comments would pertain
( %, ,
_ J 2 .in light of SSER number 11?
3 MR. BECK: They pertain in light of SSER number 4 11. Sure.
5 MR. CALV0: So, you know, one of your greatest 6 challenge that we have to the QA/QC program was the 7 inadequate, in your opinion, training with the QC and 8 also the QC inspections.
9 And I guess what I'm saying, you look into our 10 concerns on those areas, and you have corrected the 11 procedures to incorporate your concerns.
12 And the next question is, why are you waiting to i
13 submit that to the NRC so we can review it, and give you o ;
14 some kind of acceptance so we can proceed. Because you 15 risk it. All these inspections, and you may find out 16 later on the NRC have some problems with it. You are 17 proceeding at your own risk by adopting, going ahead 18 with a procedure that we can challenge.
19 I mean a QA/QC program, especially in the 20 certification of QC inspectors, wno is goinr, to help ycu 21 make all these corrective actions. And you proceed er 22 this basis, and later on whatever your corrective 23 actions are, and we don't agree, is going to invalidate
_ _ , 24 the resuits.
25 MR. BECK: That evaluation process is going on GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
250 1 continually, Jose. And I. appreciate fully if there are j 2 -- that's one of the things the CPRT program is going to 3 look at. And if that, quote, rework extends to 4 QA/QC efforts that have been going on, or subsequent 5 prior to the SSER number 11 issuance and needs to be 6 redone, we'll redo it.
7 MR. JORDAN: My concern, John, is the cart doesn't 8 proceed the horse.
9 MR. BECK: I understand. And perhaps in the nature 10 of the conversation we're having there may arise in fact 11 instances where we will have to revisit it. And we sure 12 as heck will do so. Point taken.
i 13 MR. HANSEL: Okay. We will be talking again with t j -
14 the other review team leaders in the definition of our 15 populations on the inspection attributes to put to 16 lay -- to rest one of Don Landers' concerns, and also 17 how we select our samples. Not for approval, but on a 18 day to day coordination basis to make sure what we're 19 doing is not in conflict with what they're doing.
20 MR. JORDAN: John? Larry Chandler? One mere time, 21 at the risk of beating the sample question. One r.cre 22 time, has any consideration been given to a biased 23 sample as opposed a statistical sample?
24 MR. HA"SEL: Yes. 'le
. look ed at tnat. T r. o s e are
, _ _,I 25 very difficult to implement and highly argumentative.
GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
251 1 MR. CHANDLER: Certainly the latter. But --
.J 2 MR. HANSEL: Very difficult to implement as well. We 3 feel that with our two samples, we currently have a good 4 -- we have a representative sample of the population.
5 We have one random, and we have picked from those 6 systems for safe shutdown. We did give consideration to 7 that, and decided not to go that route. It's a matter 8 of what are you really after. And we feel like we need 9 to test the population of the hardware. And this will 10 do it, the present approach. John Guilbert?
11 MR. GUILBERT: I just had a point. That's 12 conditions -- if when we find safety significant 13 deficiencies on the, adverse trend, the subsequent 14 standards required may include the -- on where we find 15 the root cause of that.
16 HR. HANSEL: I failed to point that out. If we 17 fail a sample, we will expand initially, again to 18 address the population. And that will still be 19 statistically. If we find a need to expand further, 20 then we may well go after a targeted population to 21 search out some area of concern. And tnat -- I'm going 22 to classify that as an evaluation type of sample.
23 MR. CALV0: But you have still got to mcve it en 24 the basis, that you don't find anything wrong with it, 25 because you're going to reach a conclusion on reasonsole GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2046
I 252 1 assurance. If you find nothing wrong with it, whatever .
,,_j 2 you did, it won't be sufficient to come up with a 3 reasonable assurance.
4 MR. HANSEL: That's right. That's correct. And 5 that's why I said, if I expand, I'm going to continue to 6 expand until I can continue to address that population 7 statistically.
8 MR. CALV0: If you find something wrong with it.
9 But if you find nothing wrong with it, you have still 10 got to prove your case.
11 MR. HANSEL: Right. I understand. We will also be l
12 talking and exchanging information with those folks, t 13 since they're going to have a lot of detail knowledge of L.
14 the current design in terms of what is safety 15 significance.
l 16 Now the data that we have received from this point 17 now, we will have had certainly the results of cur 18 inspections. We will have had information from each of 19 the specific ISAPS. We will have had information from 20 each population of hardware by hardware reinspection and 21 documentation. We will have the information from our i
22 root cause and generic implications evaluation. And we 23 will also have information from the adverse trenos
- , . , 24 evaluation. Let's go to tne next chart, Jonn.
l !
' ~
25 That will lead us then into our collective GODFREY & AMES COURT REPORTItiG Hetro 469-6100, (817) 460-2048
253 1 evaluation process. And that's going to allow us to
.j 2 take the aggregate of that data from those five sources 3 on the one chart. That we can now look for trends and 4 relationship that would not be apparent when you look at 5 it on a case by case basis.
6 We anticipate that this will allow us to draw 7 conclusions about the adequacy of QA/QC program and the 8 adequacy of the of the installed hardware. Next chart.
9 Based upon that evaluation, we may in this 10 collective sense -- now we went through it 'on a case by 11 case basis, population by population basis. In the 12 collective sense, we may still see some generic 13 implications that need to be searched out. And may well 14 result in the identification of new issues. And it's 15 through that collective evaluation process that we'll do 16 that. Next chart.
17 We'll also be looking at that same set of data to 18 evaluate the adequacy of the QA/QC program for 19 construction. And again, here we'll be looking at the 20 root causes and generic implications. And acain in s 21 collective sense, relating back to 10 CFR 50, appendu:
22 B.
23 This will siso alicw us to apply any lessons learned
,_, 24 froc: this process to unit two construction tnat c e r.a i n a 25 to be completed, and possibly into the operational GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
254 1 phase. But we'll look at that at that point in time.
m
,j 2 MR. MOLLONSON: Excuse me, John. If you're going 3 to do an evaluation of the results as they relate --
4 MR. HANSEL: I can't hear you.
5 MR. MOLLONSON: You're going to do an evaluation of 6 the results, collective evaluation of the results as 7 they relate to 10 CFR 350 appendix B criteria. And 1
8 where does that information then go?
9 MR. HANSEL: If we find any more trends in there 10 that tell us that we have not satisfied any issues and 11 concerns, if we find nothing further t' hat leads us, then 12 we're going to have to say we f. eel that the i
13 QA/QC program is adequate.
L -
14 If at that stage of the collective evaluation we 15 identify any more concerns or trends, we're going to 16 have to go research them. When we finish this process, 17 we should be able to address the QA/QC program.
18 MR. NOLLOUSON: I can't envision why the comparison 19 to violations of 10 CFR 50 are meaningful to your report 20 at that point in time.
21 HR. HANSEL: When I finish, I would like to ao oble 22 to say -- to make two statements. One is as to tne 23 adequacy of the hardware. And, secondly, the acequacy
,_ _, 24 of tne QA/QC program. Tne SSER 's certainly take is:uu i 1
' ~
25 with a good bit of QA/QC program. It's my chargo to 00DFREY & AMES COURT REPORTINO Hetro 469-6100, (617) 460-2048
, ..- . ~. -
255 1 evaluate that.
W
- .. j 2 MR. EISENHUT
- Is'it conceivable then, John, at the 3 end of your effort, you would come up and say, as you 4 look at the SSER number 11 and as you look at the result i 5 of your work, you could ultimately come down and say 6 that, "Here is a list of" -- in our jargon, "Here's a 7 list of violations of appendix B."
l 8 And enumerate them and say here is where you felt 9 the program did not really do what it was supposed to 10 during that t'ime. I guess in essence you would be l
11 agreeing or disagreeing with what's in the SSER 11 at i 12 some point, plus whatever you find in the broader r-- 13 scheme.
u-14 MR. HANSEL: That's conceivable. Our final report 15 in each -- and I will have a report on each of tnese, 16 will address our opinions as to the adequacy of the I 17 program, and did it or did it not meet appendix B. And 18 if, not what, remains to be done. And the same thin 6 in l 19 the construction area.
I 20 As I indicate from those two evaluations, we'i;
=
21 also be able-to make recommendations to the ut1Aity u:
22 to any corrective actions or otner improvements they 23 need to make for unit two construction to ce completec
- ,-= 24 and tne operational pnase. Next chart.
~
25 This is our organizational chart. ,
, GODFREY & AMES COURT REPORTING I
Metro 469-6100, (817) 460-2048
_ . _ . . ~ . . .. . - - . -. .
257 1 of effort at the Braewood facility, and brings to tnis 1
.- 2 project that experience. ?
3 MR. EISENHUT: When you say consult, is that a 4 full-time consultant?
5 MR. HANSEL:_ Right now it is. Right now it's been !
6 more than full-time. !
7 MR. EISENHUT: All right.
l 8 MR. HANSEL: Moving down to the safety significance 9 evaluation block, we have not identified a person there 10 yet, just primarily. We haven't been able to get time .
! l 11 with Bill Counsil. He stays busy. We have been busy. [
t 12 That's a very key job. We need the right kind of people i
! i 13 in that. We need senior people with good engineering '
14 background.
15 And that full function will be done by Stone and ;
l l 16 Webster personnel. And Mr. Counsil wants to select at I l 17 least the top five people in that block. And then from 18 that level below, we will have additional people I i l 19 supporting that area. [
l 20 The programmatic issues, Paul Crdstat is not r. o r o . :
21 Paul Ordstat has'a BS in mecnsnical engineerin;. Hit's a i
22 senior engineerin$ consultant with un full-time, he i i
23 came to us from TVA with 11 years nuclesr, 13 years [
. .. 24 quality assurance, and nas worked on tnree p. ants.
25 Al Patterson, who is in the oscK of tne room, i i
I GODFREY & AMES COURT REPORTINO Metro 469-6100 (617) 460-204d l
258 1 comes --
_ . 2 MR. EISENHUT: Excuse me. Before you leave tne 3 last gentleman, is he on loan from TVA, or --
4 MR. HANSEL: No. He's our employee. He's an 5 employee.
6 Al Patterson comes to us from Stone and Webster.
7 He has a BS, mechanical engineering, 24 years experience 8 in coal, gas, nuclear plants, and in both -- in 9 engineering design and construction.
10 He's still been very much active up until about tne 11 last week or so in the Braewood effort, and headed up 12 this very same effort at Braewood for Stone and r
i 13 Webster.
6 J '
14 And incidentally, in that particular job, ERC acted 15 as independent overview group of that effort. So Al 16 brings to us a lot of experience. He's been at Niagara, 17 Mohawk, Zimmer, Millstone and Surrey.
18 Dennis Alexander comes to us from tne Housten 19 office of Stone and Webster. And he has a BS in 20 industrial en51neering, witn extensive navy nuciese 21 schools. Ornduate or -- I'm sor'ry. .'l o t s aradua:e.
22 Attended the nuclear power reactor safety course s; 23 MIT. Sixteen years expertenso i n o n .; i n e e r i n .; . Ha:
_ . . 24 worked at Rivereend ano 9 milo point, too.
' ~
25 Chuck Spinks is not nere, the supervisor of GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2046
259 1 inspection. Chuck is a certified level 3 inspection, !
_ _. 2 and a level 3 mechanical inspection, and has 12 years of
- 3 nuclear experience in quality engineering and in 4 inspection. Had 20 years in the navy, which a part of l 5 it was in nucles.r. ,
6 And I don't know what they did in the army. But 7 apparent 1/ he had some experience in the army in 8 nuclear.
9 All highly qualified. Again, you may want to mark '
, 10 up your charts. The safety s'3nificance evaluation ;
11 group is Stone and Webster, and that's what they will 12 do. Evaluate deviations for safety significa'nce. They i '
13 will be high level senior people. The programmatic 14 issues are the category one issues I talked about from
) 15 external sources, as are the hardware issues under 16 Dennis Alexander. l 17 Al Patterson has a self-initiated program, and la primarily that group is made up mostly of Stone and 19 Webster engineers.
20 MR. NOONAN: John, the Stone and Veoster 7,rcup 'cu /
21 nave identified here under safety si;nificanco. Oc you 22 have nnraes of those people?
i 23 II R . HANSEL: We have proosely half a 63:en n a nt s .
.. 24 They're not nuaded yet at eno site. Tcoy won'; sc 25 needed until we really start crann:Ing out tne i 1
! l 1 i GODFREY & AME3 COUNT HEPORTING Hetro 469-6100 (817) 460-204d '
O 260 1 inspections. We will have most of those people on board
.. 2 by mid-July in the inspection block.
3 Chuck Spinks is an ERC employee. We have 4 approximately 14 ERC inspectors on site now. They will 5 be supplemented by inspectors from Daniels Engineering 6 and Construction out of Greenville, South Carolina.
7 The block in the upper right-hand side, you will 8 notice procedures and engineering assurance. We do have ;
9 our own QA plan. We do have procedures, and we will 10 conduct audits of ourselves. We also have a records and 11 management function, and our own training and 12 certification agent.
i 13 MR. EISENHUT: John, before you do the rive uJ 14 mainline boxes across the bottom there. Then with the !
15 exception of the safety significance evaluation and tne l
16 inspection group, the other three heads are in fact 17 TUCCO employees?
18 MR. HANSEL: No. None of these are TUGCC l 19 employees.
21 MR. HAUSEL: Tnoco are all ERC. Trore cra nu '"..,JC 22 people in here.
23 M3. EISENHUT They are all E3C car,.07i:;7 !
! i
( __ 2u MR. HANSEL: dMC or succontracter tv ; - .' .
L l
~
! 25 MR. DECK: All third party. ;
? l i
?
GODFREY & AMES COURT REPORTING Hetro 469-6100, (617) 460-2046 l
l 861 1 MR. HANSEL: Totally independent.
.i y- ~
. . 2 MR. EISENHUT: My question was the three in the 3 middle, are in fact ERC permanent employees versus the 4 two on either side. '
5 MR. HANSEL:. No. Let me go across the safety ;
} 6 significance. Will be Stone and Webster. Hordstat, ERC l
- 7 employee. Patterson, Stone and Webster.
l l 8 MR. EISENHUT: Okay. He's still with Stone and I 9 Webster?
! 10 MR. HANSEL: Alexander, Stone and Webster. Spinks, .
- 11 ERC employee. Next chart.
12 Let's go to the other one. Our report structure, I
i' 13 'very briefly. We will have results reports for each and
< u-
) 14 overy ISAP. I 15 For the hardware reinspection and documentation i
16 program, there will be a results report by population.
17 and a summary report of the total effort. We will nave ;
18 access to the results reports from the other teams issua 19 specific plans, and also the other investigative j l
j 20 programs. Those will all feed into tno ecliective 21 evaluation boxes into both of tneu.
h 22 We will prepsre o report on each of the collo:tive !
I j 23 ovaluations enst we conduct, and a suar nry rot:r, :n r.t r ;
I
-. 24 tats 1 effort. L l 25 Now let's go back tc tne senodule, Jonn. .19 s t'
- r 1
- i. l i
- 00DFREY & AMES COURT REPORTING .
Metro 469-6100 (817) 460-2046 !
E 262 1 well on track, as I indicated earlier this afternoon,
_ . 2 with our category 1 issue plans. Several of those are 3 even close to being ready for summary reports to be 4 written.
5 Our category 2 ISAP on the self-initiated program, 6 we have that documented in an issue plan, wnich you will 7 receive. We have ten procedures below that level.
8 Seven of those ten are prepared.
9 We have four of the 30 populations defined. And 4 10 check lists prepared. We have about 30 engineers on 11 board in that effort today. .And I would estimate some 7 12 to 8 other support personnel. We have detailed 13 schedules for every population, and how that effort will u-14 be conducted. And that program is well on its way.
15 We anticipate being in a position to conduct the 16 first inspection the first week of July. We have 17 inspectors on board wno are certified to ANSI 4526, and 18 we nave Daniels people comin6 on board this montn. So 19 by July 1, we're going to be ready to conduct tne fier,t 20 inspection. I think we'll do that that firct s'o c a o f 21 July.
27 MH. SHAO: Is tnis schacule includir.:; 5179 f:e 23 corrective actionn, supposing you f oun:1 arc 9tatn: 'r:n ?
., 24 MR. HA!.$EL: A.;ain, Larry, .?cs: of too :cers:t.Yv 25 actione snat nood to take place will oc providos to tr.o CODFREY & AHES COURT REPORTING Hetro 469-6100, (817) 460-2046
263 1 project. The only thing, this schedule is success
. . 2 oriented, and it assumes that we have no sample 3 expansion.
4 If we end up failing a sample or having a major 5 problem on an individual action plan, this schedule will 6 not hold.
7 MR. SHAO: This is assumption schedule?
8 MR. HANSEL: Yes. Any corrective actions again 9 will go to the project for their implementation. I 10 think the rest of that stands pretty well true. We hope 11 .to finish the last inspection no later than early 12 December. We will_ start preparing or conducting our F
13 collective evaluations when we finish up the first 6 .
14 individual plans and the early populations. We would 15 anticipate producing a final report sometime snortly 16 after the first of the year. As John said, in the 17 winter.
Id MR. EISEHHUT: Let's see. Corrective actions 19 that -- corrective actions that get sent over to tno 20 project. On this senocule, oeviously tney :sn c e : e n ; r. ;
21 out all alcng. But when would you oupect tne A1;;
22 corrective action to come? 'lo
, u l d it ce oeforo ene (tra.
l 23 report, or would it bo in tne correctivo ov:iusti:n
. .. .u program? Unore woul.1 tno last col]*:tivo ::;;cc: --
l 29 when would they be sent to thd projects?
GODFREY & AMES COURT REPORTING Hetro 469-6100, (817) 400-204o
_ .a e g . 4,.- .,__w
.,._,3o .- _ _ . _ _ _ . . . . _ . _ - - - . . , _ . .
I 264 1 MR. BECK: Darrell, I --
l l _ _ 2 MR. HANSEL: Hopefully there's none that come out i 3 of here. But there may be some that come of the -- of !
j 4 this collective evaluation.
l l 5 MR. EISENHUT: End of December, '857 6 MR. COUNSIL: Should be.
i 7 MR. EISENHUT: Should be. Now the other question, t l 8 then, is when we, the NRC, be seeing the products of ;
l 9 this effort? Obviously, I don't think you would want us ;
i 10 to go away and come back to see the final report i 11 January, end of January, 1986.
, 12 So I don't see a line anywhere on here where it [
l :
j 13 shows interim reports or progress reports, or any kind 14 of summaries of category 1 work, category 2, et cetero. !
15 Where do you envision on here, or have you thought scout 16 when you would see interim reports cocaing out of here, l i
17 or have you envisioned that? ;
18 HR. SECK: I think there are two different areas, ;
19 Darrell, we need to talk about in that regard. One are 20 interim progress reports with re; ara to tne enttro i
21 program where uo arc, and w.tn ro,; sed t o t h e s e r, q :u ' u ,
22 enat you soo nore, and snat Howarc will to tu;ttir,; ateut 23 t oflo r r ow .
., 24 Tne so:ond aspect to unen wo finion ::sas: :: 4: .f.:
l t
25 action plJns, We're foins to De producin,j r0Dult reports l l l i
l 00DFRE't & AMES COURT REPORTING i Metro 469-6100, (617) 460-204o
i 265 l I as a result, as the end point in those activities. ;
-we '
._ 2 What I would like to do, what I'm thinking about, 3 is to provide, those not as they dribble in one by one.
4 but say maybe on a monthly basis. And the first batch I 5 anticipate being ready for. release toward the end of !
t 6 July, provide a package. So for discussion purposes. I !
i 7 would put that on the table right now.
f 8 The SRT is going to be evaluating the end result 9 of these reports as they are produced. That process is l 10 part of our requirement and our procedure that SRT does 11 review them clearly. And the specific ISAP reports will l l
12 not of course contain anything as f ar as generic l
r~~ 13 implications. That's not going to take place until the I t .
j 14 end of the program. We're mintis1 !
15 MR. EISENHUT Okay. I think we, agree that there i 16 needs to be some vehicle for those reports, be they the l 17 individual issue reports, or however we can work that !
18 out. That perhaps a monthly report would do it. Just ,
r l 19 transmit them in or whatever. But I t h i n '< t h a t ' s i l
20 souething we do want to work out. And I thicW not : n a '/ ,
l >
21 on tnis progran, but on the other ;:ro,;rn: a bo'il no"e }
22 about tonorrow also, I l
23 MM. SKCX: Yes.
( , 24 MM. EIh&dHUT Tc na;to cure uo can Do (c..cu'.n, 25 what's going along as we do it, sort or staying in tunn, i
l i
00DFREY l AMES COURT HEPORTs!10 Metro 469-6100, (817) 460-2048 ;
266 1 not waiting on a final report at the end of the line.
. . 2 So it's something I think we'll need to work on. But 3 off the top of my head, something like a monthly report 4 isn't unreasonable. I think there's a number of things 5 like that we need to work out.
6 MR. HANSEL: Okay. Next and last chart. Just in 7 summary, this was the second chart that I showed you. I 8 feel that by these actions, there are individual plans, !
9 and our self-intitiated program that we will be able to 10 provide reasonable assurance that there are no 11 undetected and uncorrected safety significant '
12 deficiencies in the hardware.
r 13 Any final questions? ,
L- '
14 MR. WESTERMAN: Tom Westerman. You made mention to l 15 a QA plan and audits. Is that going to be prescrioed 16 coming the middle of June?
17 MR. HANSEL: We weren't planning to. We nave it on Id site, and we govern ourselves with tnat. Wasn't 19 planning to submit that.
20 !! H . 3ENISE: D ic i: Denise. I navo o que:t.:n.
21 Jonn. Rogion 4 l 22 You mentioned in your cr3ani:stion :nart 2 : a '. taa 23 qualificationa of sno people sn1 sa:ut *ac;r ,
. . . D6 inJopendence. l ta;na you, in respon;9 t: 1 laN:.:- ,
~
25 about the inclusion or it0C0 people, you ca:J. no, ina:
GODFREY & AMES COURT REPORTING t !1etro 469 o100, (017) 460-204o
4 267 l 7 1 was a completely independent effort.
t
- u. 2 You made a side remark. And I don't want to i 2 !
3 overdraw it. You said Bill counsil was going to select !
4 the people. Is that what you meant?
! 5 MR. HANSEL:. No.
t 6 MR. DENISE: Some remark like he was going to 7 select the top five people.
i i 8 MR. HANSEL: Bill Counsil is concerned, as I am, ;
I l 9 that we set very key people in that operation who do the [
]< 10 safety significano's evaluation. And he's got an ,
i
) 11 interest, and I think he should be able to voice his
(
) 12 opinions. Very key people.
i (
! "-- 13 MR. DENISE: You didn't mean he was going to select
- l
}s -
14 the people? ;
i !
i 15 HR. HANSEL: No. I'm sorry if I said that, j 1
j 16 MR. SECK: Dick, I think it's important to [
j 17 recognize that SR, that is -- has a function as far os
, i 18 the qualifications and the acceptability of those i 19 professional credentials on the part of all the revieu l 20 toan, as this tning is evolving. l 21 So, enock point number one is mino. '!nen .~. 11 c c.t o l
22 on board, and we began to examine tno stutua of tre It 23 projects at this point, ho pointed t o t n a ; e n t s ', o r ' , / J r 1 i
j , 24 no said, "I want to be darn cortain can tue p?o:.s unc !
25 fill that slot are qualified to make tne evaiuuttenu t
t l
GODFREY & AMES COURT REPORTINO Metro 469-6100 (d17) 460-204d !
l l
l 268 .
l 1 they are." And insisted on being part of the approval, l t
. 2 2 if you will, in that respect. !
3 MR. HANSEL: They're going to be making some of the 4 most critical decisions that we make. And he and I and 5 everybody else want those people to be the very best 6 people we can get.
7 MR. DENISE: Okay. Well, in that sense, I !
8 understand it.
9 MR. HANSEL: Any other questions? That completes 10 my presentation.
11 MR. NOONAN: I guess I would like to ask if there '
12 are any other staff questions to John Hansel at this F1 13 point in time?
6 )
- 14 MR. TRAMMELL: I'd like to get back point to the 15 safety significance. I don't need an answer to it riant 16 now. I would like to make the point. Something is 17 deemed to be safety significant, it seems you're 1d painting it all witn the same color. It's a,yes se no 19 question, basically.
20 And I con see things tnat would De criti: 31 Of 21 safety 1.ip o r t a n c e , and otnors tnot weula menctitutu e 22 mirrors no ends to an operstor, whien oro sti.1 in too 23 safety related basket, if you w'.11, :r safet/
. . . 24 s i;;n i f i c a n t .
' ~
26 And I would t n ini: that you would l'o c u s y o u r <
1 00DFREY 4 AMES COURT REPORTIt;0 itetro 469-6100 (617) 460-2048
269 1 resources on those items that are going to produce the
. _ . 2 biggest, safety bang for the buck, so to speak, and not 3 those which may be of some arguable consequence, but are 4 not in the important category.
5 MR. COUNSIL.: Bill Counsil. Let me take a shot at 6 it, please, Charlie. Looking at safety significance, 7 the SRT, Stone and Webster, whomever in this review 8 process, will look at the defect from the point of view, 9 is that piece of equipment or that hanger support, 10 whatever, is it capable of performin'g as a tendency 11 function? That's a go-no-go type check.
12 So -- and that is looking at, quote, critical 13 safety parameters. Straight bill, no-go. The other L -
14 part of this whole thing is that, even if they say it is 15 capable of performing its intended safety function.
16 But -- is a criteria of FSAR techniques with the 17 NRC or whatever, that will flow to tne project team as a 18 nonconformance. And it still may resuit in change: i r, 19 the plan, because it's a deviation from commitments we 20 have made.
21 So I don't uant y o u t o ;;e t the idos, n u t.Pa e r : r. e , 2 22 just go or no-go. Or, two, that we're not ,10 : n :, t e ::
23 anything about immediate deviations be:suco '.:e arc.
.. 24 Does snat clear it somewnst to you?
25 MR. TPAMMELL: No, not completely. Let's give it 2 CODFREY 4 AMES COURT REPORTI.'.C Metro 469-6100, (817) 460-2048
i 270 1 couple of hardware examples. Let's say you find an RTD, j 2 or a vice table is not properly designed. And if that 3 thing failed, it would produce a one out of four tr,ip in 4 the control room, and cause the operator maybe some 5 minor annoyances. Maybe not really a huge safety 6 problem.
7 Compare that to safe, let's say pressure vessel 8 bolting, where you found something's wrong on the bolts, 9 which you can have much higher significance in terms of 10 plant safety.
11 In other words, just a huge difference bctween 12 those two things. And I see you're going to do root 13 cause on both. And you're going to do the same tnings u -
14 to both. And it seems like you could focus more effort 15 on the one --
16 HR. COUtlSIL: Well, obviously the decisionmaking 17 process on the bolting, in my opinion, and I don't want 18 to presuppose what the safety review team is going to 19 do, would obviously raise greater concern. The one ycu 20 brought up with on a potential problem with sn 3 7 '.' , 3:
21 far as safety significance is concerned.
22 You're as well aware as I am if 1 in fa f::le, 23 and gives you a one cut of four, er one cu c r t r. 3 t.:"e?
.- 24 as a trip, it's failing, is a separati .re::::n. : '.
25 a nuch lessor concern. It would ee a roilactitty GODFREY & AMES COURT BEPORTING Metro 469-6100, (817) 460-2048
271 1 concern to me. And I'm going to do something about it.
m
._ 2 But, obviously, I~think, and there_you do, it would 3 just-go back to project. That's the way I would 4 interpret it, on the two specific examples you gave me.
5 And again, I don't want to presuppose what this group is 6 going to do.
7 MR. CHANDLER: Bill, as -- could using, reference 8 to part 21, assist in finding safety significant at all?
9 MR. COUNSIL: It may or it may not. A part 21 10 report can be a failure of a vendor's quality assurance 11 program, as an example. And, you know, on some of these 12 reviews we may find that. But that doesn't mean per se L 13 that that piece of equipment could not have been u -
14 performed, it's intended safety function. It presents a 15 problem to me on project. But it may not as far as 16 safety significance is concerned.
17 MR. CHANDLER: Has any part been given to using 18 part 21 as a definition?
19 MR. COUNSIL: I can't answer that question, cecause 20 I have not reviewed, quote, the safety si,Inift:ance 21 procedure. That's being done in :tr. Hance;': area, 22 MR. EIS EllHUT : Yeah. And I'm not sure -- I uc;.:
l 23 have problems if they did. I want to mai:e cure sv -- it 1
_, 24 doesn't sounc like ue're sugge: ting not to ja tnat ../, '
25 because enere may be difficultie: there.
GODFREY & AMES COURT HEPORTIll0 l Metro 469-6100, (817) 460-2046 L
272 1 MR. SHAO: One thing you have to watch out, even
_ 2 though you say it is still safe. But you throw some 3 margins, a lot of criteria efforts are the -- in doing I 4 margins. If you say it can still performs the 5 function. But in the mesntime, you lose the margin, we 6 would have problems with that.
7 MR. COUNSIL: I thought I addressed that, Larry. I 8 told you that a flow back is a nonconformance report, 9 such that I on project, as to if I have to address it, 10 as to why I have lost the margin. A'nd in fact if I have 11 lost margin, it is a nonconformance. I have to address 12 that problem. And that may result in equipment i
13 changeout, because of that loss in margin. But again L .
14 that's for the project to address and for you to audit.
15 MR. SHAO: So long as you realize that.
~
16 MR. COUNSIL: I fully recognize that.
17 MR. NOONAN: I guess I would like to make one 18 request of John Hansel. When you have defined the group 19 of people who will be working in the safety significance 20 area there, I would like to know who they are and t::e r 21 qualifications, 22 MR. HANSEL: Fine.
23 MR. EISE3 HUT: Yeah. I think there's a nurcer f
__,. 24 things. We went through a nucoer cf areas, q u e s t i o n .. ,
25 concerns, issues, where obviously you f o l;:s are ;oin; to GODFREY & AMES COURT REPORTING Metro 469-6100, (S17) 460-2048
273 1 have to go back and take a look through the transcript
_ _ 2 as a convenient way of enumerating what they are.
3 And in your submittal of the program plan, you're 4 going to have to lay out your organizational structure, 5 quite a bit of this detail, which is not officially on 6 the record anywhere.
7 So you will have to. So you will have to try to 8 lay that out. And certainly to the extent you can to 9 the staff, where it needs additional information to try 10 to wrap this up. So certainly the maximum, I think you 11 have to figure the factors together.
12 Mr. Counsil, you had another itam that you wanted t-13 to address. Then I would like to turn to Mrs. Ellis, L ]
14 for example, and see if there is any other items. So 15 why don't we go back to item --
16 MR. COUNSIL: All right. I had asked you to 17 understand, because I understand I need to correct the 18 record from this morning in one area.
19 When I discussed SAFE team with you, Darrell, in 20 particular, you askea me something to do with 21 wrongdoing, the question. And I have got a very 22 parochial engineering mind, from a point o f v i e '.. tnat 23 wronr,doing, in my mind is a failure to ou:lc :t rir .
_, 24 and design it right, or whatever. And that is 25 translated into, qucte, plant safety.
GODFREY & AMES COURT REPORTING Metro 469-6100, (617) 460-2048
274 1 I do not'have a legal mind, in that from a point of
_ s 2 view that when you mention wrongdoing, the sense of what 3 you brought it up, was that it was in the sense of such 4 things as falsification of records and things of that 5 nature.
6 Well, to correct that, I'm going to talk about 7 plant safety and numbers of issues or allegations that 8 have been raised to SAFE team. I was fairly close on 9 the number I gave this morning.
10 As of May 31, 1985 there have been 642 total 11 concerns brought to SAFE team. Of those 642 concerns, 12 185 relate to plant safety.
! ~13 The balance of the 642 relate to matters such as, L. J 14 quote, occupational safety or industrial safety, if we 15 will, personnel type relations, employee-empicyer 16 relations, and law enforcement, such as theft on site.
17 I don't have, to my knowledge, any that would fill 18 in the category that you asked the question of a 19 wrongdoing. I know of none myself right now.
20 How going baci: to plant safety. Of the 135 c: at 21 have been brought up, investigations by S A.? !: tear u " .-
22 been completed for 134. There are 51 that remain open 23 today.
_ _ _ 24 M R . . E I S E:l H U T : Gooc. I think snat does ^eap a
' ~
25 lot. And I have to admit some years ago I woul have GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2046
277 1 MR. EISENHUT: Okay. I think that helps me.
_ - . 2 MR. JORDAN: One question from the numbers you were 3 reading a moment ago. You gave some number there for 4 employee / employer relationship. Can you characterize 5 what that heading would cover?
6 MR. COUNSIL: What falls in -- that's.in -- cur 7 concerns are numbered one through five. Number one on 8 the list is plant safety. Two is security. Three is 9 management. Four is industrial safety, and five is 10 miscellaneous.
11 The employer / employee relations, things of that 12 nature, fall in the category of 3, which is management.
' t 13 These generally all fall back into the management.
t J i 14 category, and -- do you need some examples of who --
15 what those might be?
16 MR. . CHANDLER: It would help.
17 .
MR. COUNSIL: Well, a typical one might be, "I 18 haven't received a pay increase for three years. Wny 19 not?"
- 20 And out of that grouping in management, :nat's one i
21 of the predominant ones we have seen, as you m i .; n t ce 22 well aware or expect. There are others'that fa_1 :n :ne 23 same way into a management type catescry.
_ . _ , 24 " Joe Scult: has my sister-in-law, and he trea;; h-r 25 -- on staff, and he treats her better nan he treats i
GODFREY & AMES' COURT R EPO RTIt:G Metro 469-6100, (617) 460-2048
279 1 in these areas. And then I wanted to give you the
. . 2 opportunity to give us those comments, while certainly ,
3 most of the people who are here today, are here yet --
4 MS. ELLIS: I think we'd like to. Can we take a 5 brief break?
6 MR. EISENHUT: Certainly. Be happy to. Take a 7 five minute break.
8 (Whereupon there was a recess.).
9 MS. ELLIS: Thank you. I appreciate the 10 opportunity of presenting this information to you.
11 There are numerous things, obviously, that we would like 12 to say.
(
13 And one of the problems that.we're having is that, m .-
14 if you look back, historically, at Comanche Peak, which 15 has been mentioned, we have the -- with all the to-do, 16 since we have been at it for many, many years now.
17 One of the things that really has struck us is 18 that, in things like the Robin report, and the testir.:ony 19 of the CAT hearings, and the Mac report, which was just 20 supplied to~everyone recently, you will notice th:: cne 21 of the things that always shows up i.s tnat the u t ; _ : :;
22 always has a good attitude tnat comes throush very 23 strongly. There is always a ;oed attitude.
_, 24 The proolem is not there apparent.y. I: :: w ; ;:.
~
25 im p l ecie n t a t io n . I wanted to mention that as sort cf a GODFREY & AMES COURT REPORTI:iG Metro 469-6100, (817) 460-2048
279 1 in these areas. And then I wanted to give you the
.~
_ _ 2 opportunity to give us those comments, while certainly 3 most of the people who are here today, are here yet --
4 MS. ELLIS: I think we'd like to. Can we take a 5 brief break?
6 MR. EISENHUT: Certainly. Be happy to. Take a 7 five' minute break.
8 (Whereupon there was a recess.).
9 MS. ELLIS: Thank you. I appreciate the 10 opportunity of presenting this information to you.
11 .There are numerous things, obviously, that we would like 12 to say.
L 13 And one of the problems that we're having is that, 14 if you look back, historically, at Comanche Peak, which 15 has been mentioned, we have the -- with all the to-do, 16 since we have been at it for many, many years now.
17 One of the things that really has struck us is 18 that, in things like the Robin report, and the testimony 19 of the CAT hearings, and the Mac report, which was just 20 supplied to everyone recently, you will notice that one 21 of the things that always shows up is taat the ut:2ity 22 always has a good attitude that comes through ver; 23 strongly. There is always a goed att1:ude.
__ 24 The pro'lem c is not there apparent.y. I: ;; w;;
~
25 implementation. I wanted to mention that as sort Of a GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
. 280 1 word of caution. If you will go to the NRC people who
_ 2 are here. It sounds good, but follow-through is not 3 always there.
4 Another thing I wanted to point out, and those of 5 you have heard this before, please bear with me, because 6 I think there are a few here who should hear this.
7 The applicants made an agreement, which we all went 8 along with. And CASE, frankly, worked our rear ends' off 9 to try to meet our obligations under it, back in 1983, 10 December 28 of '83, the board's order on the design's 11 issues.
12 Part of the applicant's plan which they came up
! 13 with, which they chose the system, they chose the way to l t J 14 do it. They chose everything about the plan. It was 15 approved by the board and the NRC staff, and CASE went 16 along with it.
17 This was a plan which was to decide once and for 18 all the design adequacy of thg whole plant. That system 19 fell through. The utility is now in worse shape than; t
20 they were before. s 21 The motions for summary disposition, which we }
4 a 22 worked very hard to answer, we have heard nothing from _
23 the staff on those motions for summary disposition,
__ 24 except during meetings. We have not been officially
' ~
25 answered in writing. That's not part af the hearings GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
280 l
- 1 word of caution. If you will go to the NRC people who 2 are here. It sounds good, but follow-through is not 3 always there.
4 Another thing I wanted to point out, and those of 5
you have heard this before, please bear with me, because 6
I think there are a few here who should hear this.
7 The applicants made an agreement, which we all went 8 along with. And CASE, frankly, worked our rear ends off 9
to try to meet our obligations under it, back in 1983, 10 December 28 of '83, the board's order on the design's 11 issues.
12 Part of the applicant's plan which they came up 13 with, which they chose.the system, they chose the way to 14 do it. They chose everything about the plan. It was 15 approved by the board and the NRC staff, and CASE went 16 along with it.
17 This was a plan which was to decide once and for 18 all the design adequacy of the whole plant. That system 19 fell through. The utility is now in worse shape than 20 they were before.
21 The motions for summary disposition, which we 22 worked very hard to answer, we have heard nothing from 23 the staff on those motions for summary disposition, 24 except during meetings. We have not been officially 25 answered in writing. That's not part of the hearings GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
281 1 process.
.; 2 The utility still has many that they have not 3 responded to. And they have answered none of our 4 motions for summary disposition which we filed. We are, 5 after all, in a legal process.
6 We went into this legal process with great 7 misgivings, I might add. Because we felt that, even 8 though we felt the system was very imperfect, and that 9 it didn't work very well, we felt that our efforts would 10 be worthwhile, even if we could make the plant safer.
11 We think we have already done that.
12 However, as we have looked at things, we now found
' that the problems are much, much more severe than we 13 c - ,
14 ever even imagined.
15 And we realize that as we say that, this is with 16 the full knowledge of what we have seen is only the tip 17 of a very large iceberg. For instance, on the pipe 18 support issues, which were brought up in our hearings by 19 two engineers who worked at the plant, Jack Doyle and 20 Mark Walsh.
21 These are issues today, not because tney were 22 identified by the NRC, not because they were identified 23 by the utility, but because of our witnesses and their
_ 24 testimony.
25 The cable tray supports would not be an issue now, GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
282 .
i 1 had it not been that Mark Walsh decided to look at those
_ _ 2 cable tray supports as part of CYGNA review.
3 When he looked at them, we found that those also 4 had severe problems those were pursued subsequently by 5 CYGNA. When the,y looked closer at the things they 6 found, sure enough, there were more problems there than 7 they had realized before.
8 One of the things that historically has also 9 bothered us that is that we noticed here, for instance, 10 that Mr. Beck said that minutes of the meetings would_be 11 open for audit and inspection. He was careful to say to 12 the staff, not to the intervenor. This is typical, I 13 unfortunately, of the utilities attitude in the past.
L J 14 Many times we have been put in the position where 15 we cannot work with the utility because the utility 16 simply will not admit mistakes. They will not admit 17 that these problems were brought up by our people. They 18 will not admit they overlooked them.
19 And if they don't admit the mistakes, certainly 20 they cannot be expected to adequately correct them.
21 They have got to make that admission up front before 22 they can really proceed adequately to do anything about 23 them.
_- 24 Another thing is that, historically, with the
' ~
25 staff, the staff has the attitude that everything is GODFREY & AMES COURT REPORTINGs Metro 469-6100, (817) 460-2048
1 283 i
1 fixable. Now this is something that may be and it may l 1
_ _ 2 not be. ;
3 The licensing board, on the other hand, is charged 4 with deciding whether or not this plant is to be 5 licensed. I think that's a big difference, and it's one 6 that we are not willing to turn over entirely to the 7 staff.
8 I want to be very up font with you about that. We 9 are in the hearings process. We do plan to protect our 10 rights every way we can. Now what you're doing here 11 today I think is a very important part of the whole 12 process, and I certainly would encourage you to continue I
j 13 to have meetings like this.
u -
14 I do think that there needs to be some mechanism 15 set up during meetings of this sort so that, .ather than 16 being able to say a few words at the end, as we are now, 17 we will be able to ask questions during the meeting,'
18 along --
I don't mean a full discussion. I mean just 19 merely clarifying _ questions.
20 As things are now, we are left with no alternative 21 to go to the licensing board and ask for formal 22 discovery on many of these things. This takes. longer 23 for everybody. It would be such simpler to be able to
__ 24 ask and answer some questions along.
~
25 It would help tremendously in the process, and I GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
284 1 would urge that the utility listen to that and take
. _ 2 heed. As I say, you left us no alternative many times.
3 One of the things, too, is that, in listening 4 today, I'm a little concerned about the lack of 5 interplay with past identified deficiencies, the samples 6 that they will be using and so on. There are some 7 problems there. I realize that this is a very difficult 8 area. But at the same time I'm concerned that, 9 otherwise, when we come to hearings --
10 Now, Mr. Counsil, of course you are new. I don't 11 know you well. You-haven't been on the board for a long 12 time, and_I'm sure I certainly don't want to impinge
,'u J i 13 your motives . or your motivations.
14 At the same time, I can only, by the history that I 15 know this utility and these applicants, and I'm very 5 16 concerned that at some point in time we're going to go 17 into hearings and find ourselves in the same situation, 18 especially on the design issues, which are so 19 complicated and detailed anyway, that we will find l 20 ourselves in the same situation where we go into ;
i 21 hearings, and you're hit with the same situation that 22 CYGNA was hit with, where they came to hearings, thought 23 they had all their ducks in a row, but found that all of {
i
'_- 24 a sudden there are more problems there than what tney
' ~
25 had thought.
GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
285 1 They had to do back to the drawing board,
. _ 2 basically, and sort over on some of these things.
3 That's why it's so important that we be involved in 4 this process, and that.the utility open up the process 5 to us through discovery, before all of this happens, 6 before a lot of these things get out of hand, and before 7 the same things happen again.
8 I think that's basically the main things that I 9 wanted to hit on right now. And I anticipate that I 10 probably will have some more comments that I would like 11 to make at the end of the meeting tomorrow on the design 12 issues, because that's something that I personally have r
13 been very involved'with, in the design issues.
5 -
14 We'd like to take a-few minutes right now and have 15 Miss Garde, who is representing us, as you know, as the 16 legal assistant to Tony Royce, and and the other part of 17 the hearings. And she has just a few comments she would 18 like to make, if that's all right.
19 MR. EISENHUT: Certainly. Go ahead.
20 MS. ELLIS: Thank you.
21 MS. GARDE: I have a number of specific comments on 22 some'of the things that I heard today. As I have stated 23 in the other meetings that we have nad in the last
__ 24 couple months, we'll reserve our comments and do them in 25 a written form after the program plans are submitted, GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
286 1 apparently, at the end of June, so you will have a much
_ _ 2 more detailed look at our opinions and concerns about a 3 number of th'ings.
4 My first comment deals from this morning's 5 presentation with the QA/QC project personnel. It's of 6 great concern to me that these individuals, three of 7 them, are not TUGC0 employees. We have a DUKE person on 8 loan. We have two Daniels people on loan. I don't know 9 what --
the Daniels gentleman, and I have had only 10 limited contacts with the Callaway project.
11 .
However, I have had a lot of experience with Mr.
12 Wells in his background at Cadoba. And I want to say on l 13 the record that, and I'm sure the utility is aware of L J 14 this, that I'm extremely concerned about Mr. Wells being 15 placed in this particular position, because of an 16 experience at Catoba, in which he did not perceive or 17 recognize or resolve a problem dealing with harrassment 18 and intimidation of QC inspectors.
19 That situation has recently, within the last 20 several days, resulted in DUKE power companies being 21 levied a -- or a proposed 64,000 dollar fine.
22 And although there may be some dispute about Mr.
23 Wells' involvement in that, the fact tnat there is
_, 24 harrassment and intimidation. It was QC inspectors, and
' ~
25 it deals with the exact same problem that nas been GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
287 1 plaguing Comanche Peak. Is a very, very great concern
._ 2 to me.
3 Second of all, on the SAFE team, I have had 4 experience with the consulting firm, limited experience 5 with the consulting firm that is running the same team 6 projects. And I would have to say on the plus side that 7 never in any of the plants that this SAFE team has been 8 at, have I ever received a complaint that an 9 individuaA's confidentiality was breached under this 10 particular SAFE team. That doesn't apply to SAFE team 11 or quality plus programs across the country.
12 I am concerned, however, that since each utility 13 company has their own arrangement with a consulting 14 firm, that this SAFE team avoid some of the problems 15 that we have experienced recently at Wolf Creek. And .
16 I'm sure that's why the wrongdoing issues were discussed 17 in such detail today.
18 The things that I heard in the discussion on the i9 SAFE team that were the biggest concern to me was, first 20 of all, that wrongdoing issues be understood by the SAFE 21 team, that the members or the personnel that are on the 22 SAFE team, the investigators, the interviewers, and the 23 management, have an adequate understanding of what the
._ 24 NLC expects to be referred to the NRC. And I don't l 25 think that's going to happen in a vacuum.
l GODFREY & AMES COURT REPORTING l Metro 469-6100, (817) 460-2048 :
J
288 1 I think the NLC. bears some responsibility there,
_ _ 2 for briefing those individuals,-whether it's OI, whether 3 it's Mr. Noonan. But laying down a framework which says 4 fax have an allegation of falsification of records.
5 That has got to go to the NRC.
6 I don't think you can do this thing in hindsight, 7 at the end of the road. 800 allegations, 1100 8 allegations, figure out that.the process by which these 9 things were done was flawed.
10 Second of all, and equally in line with that, is 11 that there are issues which are relevant to the hearings 12 that are in the hearings. legitimately. Not new r
I 13 contentions in which the utility company has an ongoing L J 14 obligation to notify the parties and the board when that 15 information comes forward.
16 I think some m'onths ago we saw the board notify of 17 an allegation of falsification of records. Utility 18 company has a certain obligation to keep both 19 intervenors and the board notified. Because those 20 things are in the SAFE team track, does not mean tnat 21 that obligation is removed. And I think it's extremely 22 important that tnat be worked out at this point in time, l 23 rather than in retrospect.
24 Finally, I was a little concerned, Mr. Counsil, on
! 25 hearing your characterization after a lot of the GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
289 1 management concerns, as being compla.ints about pay
. . 2 complaints, about management. I'm sure that a lot of 3 those complaints are in there. GAP receives a lot of 4 complaints in that same vein as part of the process 5 nature of the business.
6 However, I think the way you characterized it was a 7 little bit much of a red herring, in some cases. And 8 I'll say frankly very few -- some of the individuals who 9 have gone to the SAFE team had also gone to GAP.
10 In most cases, those have already been passed on to 11 the NRC. But I know firsthand that there are concerns 12 which are serious which do involve wrongdoing issues, t
13 which do involve documentation deficiencies and hardware 6 -
14 deficiencies, which have been given over to the SAFE 15 team. That those have cot yet been answered.
16 I think the jury is still out, and I'm not making 17 that as a criticism. I think it's very important that 18 it not be characterized as a red herring, that this is 19 all pay complaints, because that's certainly not true.
20 My third point was also a concern from this morning 21 or early this afternoon, dealing with a consultant's 22 review of the QA/QC program.
23 Maybe, Mr. Hansel, I misunderstood what you said,
__ 24 and if so, I hope that you would correct it. But the 25 way that you present the consultant's status in regards GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
i 290 1 to regulatory requirements left a very, very large
_ _ 2 loophole. -
3 The statement that I wrote down from what you had 4 said, was that the consultant's review is not being 5 subjected to the regulatory requirements, i.e., not 6 written up, not subjected to QA/QC review.
7 That was a real red flag to me, and I'm real 8 concerned that that be clarified, because if in fact you 9 have consultants out there, they're essentially 10 eyeballing a project,' eyeballing a particular system, 11 and not submitting their findings into the regular 12 project loop. Then you have got an entire bulk of
! 13 people that are out there identifying problems, not L J 14 writing them up, and they are not being factored into 15 the process.
16 And I won't proceed on that point because it seems 17 s.o outrageous, frankly, that I think it may have been 18 either misstated or I misunderstood it. But if that's 19 true, then that's a big concern.
20 Fourth, there was some discussions, and I just 21 wanted to echo what Mr. Calvo said, tnat I think 22 periodic reports are critical. Most of the projects 23 that we have been involved in that have undergone major g__ 24 reviews or reinspections such as this have included some
' ~
25 kind of monthly briefings.
GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
291 1 I have found that those are most productive, that a
, ._ 2 monthly meeting format works very well, and they should 3 obviously not be this size. It gives everybody a 4 forum. They know the first Wednesday of every month 5 there's a meeting. Things can be bumped to agenda, and 6 those to me work the best. They work better than 7 written reports, because written reports only raise 8 questions.
9 You don't want to spend a lot of time writing 10 them. And I would hope that something would come 11 forward.
12 My fifth point, again, went to Mr. Hansel. Some of i
13 the things that you said, I'm very concerned that you're
]
14 relying on your Braewood work. Because I have just done 15 a little stint of Braewood work myself, and I'm sure, as 16 you're aware, that ERC did not find a lot of problems.
17 Then the NRC did find a lot of problems.
18 The reinspection program was stopped. There's 19 pending enforcement action. And now the Braewood 20 program is again essentially on track. But I think 21 there was some programmatic deficiencies at Braewood 22 which I don't want you to repeat here. And I'm 23 concerned that that's going to happen.
__ 24 And I'm also concerned that if you say it's not 25 going to happen, that you explain why, you know, une GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
292 I same type of program is acceptable without making some
. . 2 kind of changes.
3 Again, and my last point, deals with a discussion 4 on the attribute checklist and the procedures. I think 5 the most critically important document that apparently 6 does not yet exist is the attribute check list that's 7 going to be used in the reinspection. Those attribute 8 check lists must be accurate. They must be developed to 9 each. component.
10 They cannot be essentially a generic electrical 11 cable attr,1bute checklist. I believe that the strength 12 of the Midland construction completion program laid in i 13 the fact that the attribute check lists were ultimately e J 14 approved by the NRC, and by a group o*f individuals from 15 the NRC that made sure there was no loopholes.
16 So that there was a set of a check list, which were 17 publicly documented. And I'm sure that, John, if you 18 don't have a copy, you could easily get a copy.
19 But those check lists were very, very good, and 20 there were not eight or ten of them. We're talking 21 about 80. And I think at the end there was over 130 of 22 those check lists.
23 They were a very quality product, and they did not
__ 24 leave room for questions. You knew when something was
' ~
25 going to go through there, if it came through that GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
293 ,
1 program, even I was satisfied with it. And I think that i 2 that's the kind of thing you need to have.
3 And equally with the procedures, the inspection 4 procedures used in the reinspection program, have to be 5 unquestionable if the integrity of this reinspection ,
6 effort is going to withstand scrutiny on the board, to 7 the public, and to ourselves.
8 And I think that the details of those procedures -4 9 just cannot be simplified. They have got to'be even 10 better than they were in the beginning, and deal with .
11 all the little problems that left room for doubt. Left ,,
12 room for inspector judgment, that may have been flawed 13 or raises -- now raises the questions.
14 The only other comment, and my last one, is that /
15 you said you had reviewed inspection reports going back 16 two to three years, and you weren't going to go back any 17 further.
18 And, again, I!m not sure if I completely understood 19 that that was the scope of what you were going to look 20 at from your external sources. I think if that's true, 21 that would be a very big mistake, because the genesis 22 almost all the problems now on the table you can trace 23 back to '78, '79, '77. And many of them were in NRC
, 24 documents, and certainly should have been in some of 25 your own internal audits.
GODFREY & AMES COURT REPORTING Hetro 469-6100, (817) 460-2048
i 294 l
l 1 And I think you must go back to the beginning of I
l , . 2 construction, if you're going to' find the real root l
l 3 cause, because you have got to address -- for instance, 4 in the Mac report, I didn't have predictions of certain 5 failures.
6 Now you're finding that the predictions came true, 7 and all the way along you had, as Mr. Royceman 8 characterized, enn riaren, and the cole mine workers 9 saying, "This is happening, this is happening," and no 10' one caught that. I mean that's got to be explained.
11 And until you go back to the beginning of 12 construction and start looking at all those audits, you i 1 13 can't possibly deal with the root cause. Did I give a u J 14 lecture this time?
15 Okay. That's all. Thank you.
16 MR. EISENHUT: Thank you. I don't want to try to 17 argue about the issues now. Let me make one point on -
18 one thing we do intend, that there will be some forum 19 for a flow of information back and forth. There may
- 20 well be monthly reports. And I think there's actually l
21 going to be a lot more frequent than monthly meetings.
22 In fact, I told-the staff coming into this --
l 23 MR. CALV0: Don't repeat it. Don't put it in the i
,- 24 record.
' ~
25 MR. EISENHUT: That there is going to be a lot more GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
f 295 1
't meetings, and they ought to plan that, on many of these ;
. . 2 issues, layout to be either having meetings with the 3
utility, meetings here, comments, various parties, there I 4 ought to be considerable time spent in the plant. And 5
there's going to be quite a bit of that.
6 Now that's got pluses and minuses. It is going to 7
be a very intense effort, and it is going to be. There 8
3 are going to be status reports. There are going to be 9
meetings, which are going to be a lot more frequently 10 than monthly.
You're going to have to obsiously pick !
11 and choose which one you cover. :
I 12 We have taken the paEt here that we have tried to '
13 notice the meetings to the extent practical. We're 14 going to have we try to notice them with ample time to 15 the extent practical.
We're also going to be keeping a '
16 transcript of meetings.
17 Obviously, if you're going through a detailed 18 discussing, wiring diagrams, they just don't land 19 themselves to it. Obviously the staff is going to be 20 spending considerable time in the plant doing i 21 inspections.
22 I would expect there are going to be considerable 23 meetings going on discussions almost weekly. So I 24 expect there will
~
be considerable dialogue. Let's see.
25 Are there any other comments that tne staff, the l
GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048 I i
296 1 utility, anyone else wants to make before we break up W
2 today? I do understand we will be going through the 3 design issu es.
4 Vince telJs me you want to start at 8:307
! 5 WR. NOONAN:- I think we would like to. start about 4 i
- 6 eight o' clock, if that's okay with Mrs. Ellis and 3111.
! 7 MR. EISENHUT: I understand you estimated the 1
,. 8 meeting will last four hours. With these guys, maybe l
9 eight hours. That's why we suggested eight o' clock.
1 .
- 10 MR. COUNSIL
- I don't have a problem with eight i :
j 11 o' clock. I have a problem with 7.
. 12 MR. EISENHUT: Let's agree, at 8 o' clock toniorrow i
13 morning. I appreciate everyone sitting through the
. ~ $ a* .,
)
! 14 meeting today. The staff -- Mrs. Ellis?
1 i 15 MS. ELLIS: Yes. I just wanted to be sure, when l 16 you said you try to not. ice the meetings as much as l
17 possiole,_we'll still be getting phone calls.
16 MR. EISENHUT: I'm sorry. What I mean, a pnone 1
19, call or in writinc. And when -- I tried to correct
! 20 my: elf. .!e'll try to nctice tnem as far in advsnca :s i 21 possible. feu will 'ce notified of alt ae . meet;n,a .e j 22 nave, other tnan wnen ue're in tne ?.an ::;n , an 23 ina:e0010n, Onese ,:in:s Of :n;ng;.
- - - 24 All rir,nt. Tr.ank y:a very mu:n. ::'; ca:n s 9 -
25 lcng day. Tnanks an auful act. -
i GODFREY & AtlES COURT REPORTI:lG Metro 469-6100, (317) 460-2048