ML20129A657
| ML20129A657 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/14/1985 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20128G622 | List: |
| References | |
| NUDOCS 8507150360 | |
| Download: ML20129A657 (136) | |
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NRC/TUGC0 MEETING I
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VOLUME I MORNING SESSIO!4 j
i GODFREY & AMES COURT REPORTING I
CERTIFIED SHORTHAND REPORTERS I
1106 W. PIONEER PARKWAY, SUITE 400 l
ARLINGTON, TX 76013 (817) 460 2048, METRO 469 6100 l
COMPUTER ALOE 0 TRANSCRIPTION j
v10E0 TAPE SPECIALIST oAlty copy June 14, 19ca_
J 0507150360 030703 l
PDR ADOCK 0500 U
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3 NRC/TUGC0 MEETING
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5 APPEARANCES:
6 NRC:
TUGCO:
Vince Hoonan William Counsil 7
Larry Chandler John W. Beck Robert Bosnak John Marshal 8
Larry Shao Fred Madden t
Jose Calvo 9
Angelos Marinos CASE:
Jim Milhoan Jerry Lee Ellis 10 Charlie Trammell Dr. David H. Boltz Howard Hunter Fred W. Beck 11 TENERA CORPORATION:
TELADYNE:
12 John Guilbert Jim Mollonson Howard Levin j
13 STONE AND WEBSTER:
14 John Hansel Ed Siskin 15 Cris Mortgat Martin Jones 16 17 MEETING HELD before Jayne Ames, a CSR, and Notary Public, in 18 Tarrant County for the State of Texas, on the 14th day of June, 19 1985, beginning at 8:00 a.m., at the Sheraton Hotel, 1500 Stadium 20 Drive East, Arlington, Texas.
21 22 23 rl 24 a
25 GODFREY & AMES COURT REPORTING
3 1
SECOND DAY r.j 2
3 June 14, 1985 4
5 P R0C EED INGS 6
MR. NOONAN:
We would like to go ahead ano start 7
this meeting this morning.
This is tne secono day of 8
the utilities presentation to the NRC on the program.
9 And I don't have any comments, other tnan people please 10 speak up when they identify themselves, so the recorder 11 can write down their names and so forth.
With that, 12 I'll turn it over to you, John.
13 MR. BECK:
Thank you, Vince.
If I could nave une 14 first slide, give you an outline of what we're going to 15 be covering today in the presentation on the design 16 adequacy program.
We will have an intro that wilt give 17 a good solid background and outline the program 18 structure and the organization.
19 We're going to spend a considerable ac:ount.of time 20 on metnodology so tnat it's clear the approacn tnat's 21 being taken in all the areas.
I guarantee that we will 22 get to the bottom line of understanding and dealing witn 23 root cause and generic implications, whetner they may 24 lie or wnether they may lead us.
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25 And we're soing to spend probaoly r.a.f tne GODFREY 4 AMES COURT REPodTING Metro 469-o100,-(517) 4o0-2046
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presentation in that neighborhooo talking aoout the
[j 2
specific discipline reviews that will give a 3
demonstration clearly of how the methodologies apply.
4 Howard Levin is going to be the chief spokesman.
5 He will be assisted by others who will be introduced 6
later.
Howard, as you recall from our discussions 7
yesterday, has been a review team leader to date on cae 8
issues, specific TRT questions, several structural and 9
mechanical.
10 When in February we adopted the policy of covering 11 all outstanding issues under the CPRT umbrella for tne 12 Comanche. Peak project, the SRT, at Mr. Spence's Fl 13 direction, with regard to undertaking enose tasks, shows L.J 14 Howard Levin the head of the design adequacy effort.
15 That effort has been under development and evolvin6 16 since that time.
17 For those who aren't familiar with Howart 16 background, Howard has an MS in structural engineering 19 and a BS in civil from Massachusetts Institute of 20 Technology.
He's got over 13 years of total engineering 21 experience, 11 of whien are in nuclear power.
Architect 22 engineer with the NRC staff, and 4 years in the 23 consulting business, focusing primarily on construction 24 and design verification.
25 Howarc's a vice president witn tne Tenerc Division GODFREY & AMES COURT REPORTD.G Metro ud9-o100, (61'/) 460-20ud
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of Tenera Corporation Nuclear Subsidiary.
Anc without 2
further ado, Howard, the mike is yours, and it's going 3
to be a nice long day, I'm sure.
4 MR. SHAO:
I have one question here.
5 M R.- BECK:
I'm glad to hear, Larry, there's only 6
going to be one today.
But now is a good time to start.
7 MR. SHAO:
Yeah.
On the discipline that's 8
involved, you have mechanical assistant, electricaA, 9
EHC, piping and supports, civil, structural.
But I 10 don't see any of the mechanical components like pumps 11 and valves.
Is that an oversight here or --
12 MR. BECK:
It's not an-oversight.
It's included.
13 And Howard will get to it later this afternoon.
And
,u-14 there are going to be lots of pumps and valves involved.
15 MR. SHAO:
But it's included?
16 MR. BECK:
Yes, sir.
17 MR. LEVIN:
It's in the 18 MR. SHAO:
Including systems and components?
19 MR. LEVIN:
That's correct.
20 MR. SHAO:
Okay.
21 MR. LEVIN:
Okay.
As John has indicated, our 22 presentation today is segmented to tnree sections.
Tne 23 first being introduction, and I will oe running through 24 that.
25 In this portion of the presentation, I'd like to l
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present some background on the evolution of events that L _.
2 brought us here and has led to the creation of the 3
design adequacy program.
4 The charge that John referred to by Texas Utilities 5
Management in terms of our goals and objectives, and 6
given these responsibilities, how we are prepared to 7
execute.
In the process I plan to briefly identify the 8
issuds and their sources, the functional elements of our 9
program that wil'1 direct -- that will be responsive to 10 these. issues, our organization personnel and the roles 11 of our people and the project.
12 Okay.
As many of you are aware, issues have been 13 raised by various external sources that are design 14 related.
The source of these issues include the 15 independent assessment program; the NRC ASOB licensing 16 proceedings; the NRC's staff's licensing review itself, 17 including the TRT work; SIT; and SSER
's, as well as the 18 NRC inspection program, which includes Region 4 19 activities and CAT.
20 As mentioned, in view of these outstanc.ing issues, 21 TUGC0 has charged tne CPRT witn responsibiiity for 22 development and implementation of a program that will 23 address and resolve a'11 identified issues.
24 However, for enhanced confidence, TUGC0 has I
u a 25 expanded that charge to include responsibility for GODFREY 4 AtiES COURT REPORTING Metro 469-6100, (317) 460-204d
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1 in'suring that there are no undetected safety issues.
2 MR. CHANDLER:
Howard, let me may at this point ask 3
you.
This is Larry Chandler.
You used the word 4
" resolved", while ago, identified issues.
Could you 5
define how you're using the term " resolve"?
6 MR. LEVIN:
By resolved I really have to address 7
that in two segments.
We have responsibility for 8
capturing the issues, reviewing them, assessing their 9
significance.
And where issues are identified, that in 10 particular, that may have safety significance, or wnere 11 there may be deviations from commitments.
We have a 12 responsibility to bring those to the attention of TUGCO.
I 13 And oftentimes, particularly if there are J
c 14 deficiencies, some corrective action may be required.
15 So the resolution, is a processing that oftentimes 16 includes our identification of an issue and definition 17 of an issue.
But when it comes to corrective action, 18 the total course of resolution will undoubtedly, tnrough 19 effort on the part of TUGCo, and in many cases, as you 20 will be evident through our presentation, you will see 21 how we will be involved in the verification of tnat 22 resolution where they have responsibilities.
23 MR. CHANDLER:
If a corrective action is taken on 24 the basis of one of your recommendations, do you taen
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25 follow-up on the same issue, or is tnat still left w:th GODFREY & AMES COURT REPORTI:G Metro 469-6100, (617) 460-204d
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the project?
2 MR. BECK:
Larry, if I can say my. piece on that 3
issue.
It's a responsibility of CPRT, as Howard said, 4
to identify, and in cases of where necessary, r e c o ar.:e n d 5
resolution of an issue.
6 The responsibility for execution of the 7
resolution, if you will, is clearly that of the owner, 8
TUGCO.
It's the further responsibil'ity of CPRT to 9
agree that that resolution will in fact resolve the 10 question.
So it's a matter of identification, passage 11 of that recommendation through the SRT and TUGC0 12 management, to see that it happens.
3 1
13 MR. CHANDLER:
Does the CPRT though, then go back, t.J 14 after corrective action has been taken, to, in a sense, 15 verify that that action recommended nas been properly 16 implemented?
17 MR. BECK:
The program, as it's set up rignt now, 18 does not include a -- an audit of implementation by 19 CPRT per se, but it will be very clear what their 20 resolution path is.
It will also be very clear that 21 TUGC0 has that responsibility.
It's a process tnat 22 takes place exactly as I have described it.
23 Obviously, CPRT is not in tne implementation of tne 24 corrective direction.
'~
25 MR. CHANDLER:
That helps.
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MR. LEVIN:
The goal of the' design adequacy prodram 2
is to provide reasonable assurance that safety 3
significant design deficiencies have been detected ano 4
resolved.
5 And with this goal, I think we all may ask the 6
question, you know, just what about the unknown?
I 7
personally consider this to be the most important 8
challenge before us in terms of meeting that goal.
9 And we have developed, and you will have some 10 understanding of our program'that will in fact address, 11 not only those issues that are on the table, out those 12 issues that we may not know about today.
13 I guess it's conceptually easier to deal witn c_
14 issues on the table.
I think in all' cases, that I'm 15 aware of, engineering solutions are available.
16 MR. BOSNAK:
Howard.
This is Soo Bosnak, NRC.
17 Yesterday we spent, I don't know if you heard, we spent 18 quite a ' bit of time discussing licensing commitments and 19 their rcle, visavis safety significance.
And I wouic 20 hope that this would include the licensing commitments.
21 If they to have to be revised, that would be part 22 of their goal, to include those and seek resolution witc 23 ene staff.
24
!! R. Dr.VIh:
I'll be gettins into unat in a c.o m e n t.
25
'd e have some o'ojectives tnat might serve support nnat GODFREY & AMES COURT REPORTING Metro 469-6100, ($17) 460-2043
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support this goal, and we'll be getting directly'into 2
that.
I agree, Bob.
Your point is well taken.
4 3
MR. CHANDLER:
Howard, I'm sorry.
Before you move 4
on, I asked both John Beck and John Hansen, yesterday, 5
for their definition of the term safety significance.
6 Could you tell me how you have defined the term for your 7
purposes?
8 MR. LEVIN:
Okay.
I'll give you yeah, an 9
engineer's definition of that.
And fundamentally wnat 10 we're talking about is the ability of a system or 11 component or structure to meet its intended safety 12 function.
13 MR. CHANDLER:
All right.
14 MR. LEVIN:
Just for Bob's question, I address 15 issues that are on the table, and in fact that, there is 16 a road. map for addressing those.
And engineering 17 solutions are available, and you will hear some of the 18 initiatives that are associated.with that.
~
19 But getting back to the question of unknown for a 20 moment, the initiatives that are required to address 21 that question, require a combination of both 22 exploratory, and'sometimes investigative type of work.
23 And as part of this presentation, you will be nearing 24 about a particular functional element of our program I
J 25 that will help address that question, i
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MR. CALV0:
Excuse me.
I thought yesterday was our
_J 2
- perception that the goal for the construction adequacy 3
review and the senate adequacy review was, when you 4
finished with it, you had reasonable assurance tnat you 5
had quality in the design and quality in the 6
construction.
7 And you may be trying to say tnat in here, but it 8
doesn't quite come through with your goal.
You could 9
have found safety significance deficiencies.
But 10 suppose you had not found anything, and everything is
.11 all right, you still have got to reach that conclusion, 12 that you have the same quality in Comanche Peak as in i
13 the electrical station; is that correct?
Is this what 14 you have in mind?
15 MR. LEVIN:
Absolutely ~.
16 MR. CALV0:
It doesn't-come through, then, in tnat.
17 MR. MILHOAN:
Jim Milhoan.
Your definition of 18 safety significance about a system bein'g unable to 19 perform its safet) function is a rather high threshold.
20 Are you considering failure of components to perform 21 their safety function?
22 MR. LEVIN:
Absolutely, Jim.
If it didn't come 23 across, I really prefer to the ability of systema, 24 components, or structures.
So it's not suen a
' road o
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25 definition.
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For example, it's not one that includes
_ b 2
consideration of -- for example, let's say there is a 3
deficiency in one train that may make that train 4
unavailable.
We're not going to rely on the other train 5
or a. diverse system, okay, as part of that definition.
6 Okay.
So it gets down to a much more local level, to 7
the co=ponent level, in some cases, where that's 8
important.
9 MR. MILHOAN:
'd h il e you're concentrating on 10 hardware, and I agree with your statements tnere, 11 there's also programmatic deficiencies, sucn as failure 12 to implement FSAR commitments, or figure to update --
i
'l 13 maintain and update an FSAR.
Will tnat be included in t...J 14 the safety significant category, or how are you 15 resolving the programmatic issues as related to safety 16 significance?
17 MR. LEVIN:
Basically, we'll be getting into this 18 in a moment, but there are three segments to our 19 program.
One of which is our programmatic and generic 20 implications evaluation.
And it's a one of tnree 21 principal elements in the program, and I will ce 22 addressing that in some detail.
Okay.
23 Our goal has led to the development of a list of 24 objectives.
As I alluded to earlier, when we were in
,_,I 25 the development phase of our program, there were clearly l
I f
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two aspects that we had to address.
One, our program 2
had to address all external source identified issues.
3 And, two, it had to be developed in such a way that_we 4
had reasonable assurance of detecting significant issues 5
tnat are presently unidentified.
6 Importantly, our program required the investigation 7
of root cause of safety significant deficiencies, as 8
well as generic implications that Jim Milhoan just 9
alluded to.
10 Bob, the point you brought up, the program also 11 includes an assessment, the compliance to licensing 12 commitments.
i 13 Getting oack to safety significance again, we L J 14 indicate here, we will assess it.
That is, its -- the 15 ability of systems, components, and structures to meet 1
16 their performance requirements.
17 And we will, be looking from the standpoint of 18 deviation from commitments and deviations that may be 19 identified with respect to existing issues.
And others 20 that-may be identified during the course of the program.
21 It goes without saying that any significant 22 deficiencies will be corrected.
That's an objective.
23 However, we will also trena deviations from 24 licensings commitments.
And we will ce descri' ng ho',;
o 25 we're going to do tnat.
A deviation means sometning GODFREY & AilES COURT REPORTI.NG lietro 4o9-6100, (d17) 460-204d
14 1-1 less significant than a deficiency.
l 2
And this really gets back to how we plan to do our 3
business.
But it will be evident that we plan to 4
address many of these issues in an integrated manner and 5
try to understand the meaning of the issues as a wnole.
6 I mentioned that there are three functional 7
elements to the program.
The first being the external 8
source issues, evaluation and resolution.
Those are the 9
issues that are derived from the sources chat I 10 mentioned earlier.
11 Secondly, self-initiated evaluation, which is very 12 analgous to John Hansel's discussion in the construction I
13 program, where the emphasis of that program is L. J 14 addressing some of these potentially unknown issues, as 15 well as providing additional confidence.
16 And lastly, the root cause and generic implications 17 programs.
Now we have s tructured ou r prog rac: along 18 discipline lines, because we're going to be d r a w i r.g 19 conclusions on that basis.
And with any of tnese 20 cisciplines, there are these three functionai elements.
21 MR. N00 N Ail:
Howard, I have got to asx you a 22 question first.
One thing, we were talking about tne 23 external sources, and I cidn't near a word saic aoout 24 the CYGMA language, what all CYGUA has done.
- i 25 MR. LEVIN
I referred to tne independent GODFREY & AMES COURT REPORTI.1G Metro 469-6100, (317) 460-204o
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assessment program.
Yeah.
But'it certainly includes 2
that work.
3 MR. NOONAN:
I guess my question is, this CYGNA has 4
done four phases, what's known as the four phases.
When 5
do you expect to receive the fourth phase and put tnis 6
in the program?
7 MR. LEVIN:
Okay.
I will have to defer the timing 8
aspect of your question to John.
But I will state 9
categorically that a significant amount of information 10 has been folded into this program, okay, in the way of 11 generic issues that they have identified, and through 12 letters, as well as their open issues lists.
13 And also information that's been communicated to I
u -
14 us.
For example, our meeting in San Francisco sometime 15 back.
So that information has been captured and nas lec 16 to the development of certain technical aspects of the 17 program.
16
.1 R. NOONAN:
Before you answer, let me address my 19 question again.
CYGNA has, I said before, done phases.
20 When you're done with all that, is CYGNA going :o ce 21 afforded the opportunity to see wnether or not parts 22 that they have identified and implemented, will they be 23 involved in tnat process?
24 MR. SECK:
Tne answer is yes.
As I indicated
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25 yesterday, any issue CYGNA as raised t ria t is unresoived GODFREY & AMES COU3T REPORTING Metro 469-6100, (017) 460-2046 l
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in their mind will be resolved by the CPRT effort.
We 2
are going to provide CYGNA -- they have -- 2et me back 3
up a little bit.
4 We asked them a couple of months ago to please 5
provide us, in lieu of the fourth phase final report, 6
which they're not prepared produce at that time, a 7
listing of all concerns that they have identified 8
throughout all phases of their effort, which they did.
9 That list of concerns and identified findings nas 10 been gone over with a fine toothed comb by the design I
11 adequacy following under CPRT, and factored into the 12 program plan.
l 13 We're going to provide shortly, after publication
-J 14 and distribution of the program plan, a road map snowing 15 where each CYGNA identified issue is treated winnin the 16 program plan and the specific action plans.
17 And we have asked CYGNA to iterate with the CPST on 18 the identified resoluti'on path, and to satisfy 19 themselves that the resolution we have identified witi 20 resolve any of the issues they put on the table.
So in 21 that context, we will have treated everything that's 22 come from that program.
23 MR. NOONAN:
Has CYGNA given you a date wnen they 24 will present this?
l
" " ~
25 MR. S E C T. :
To publish their fcurth paase report?
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think it will be only appropriate that they hold off s
2 publication until they have looked at our program plan, 3
and we have gone through this reiteration.
So it will 4
stand as a complete document.
5 MR.-SHAO:
Will CYGNA give you the root causes of 6
the problems they --
7 MR. BECK:
CYGNA will have made some comments about 8
root cause of the problem.
But we in CPRT are not 9
relying on CYGNA's effort in that respect.
10 We're going to do our own root cause and generic 11 implications evaluation, and treat every one of the 12 CYGNA issues within that overall context.
It would be 13 premature for us to rely on root cause identification by u-14 CYGNA, simply because of the scope of the effort that 15 they did.
I certainly won't ignore anything that they 16 might 17 MR. NOONAN:
Not necessarily my point.
But it 18 would probably be helpful if they had' indication of root 19 cause, if they could identify them.
20 MR. BECK:
Sure.
21 MR. MOLLONSON:
My n arae is Jim Mollenson.
I'm wit.1 22 Teladyne.
Back to your objective.
I don't find any 23 records to what the quality assurance aspect, either tne 24 identification of the quality assurance criteria, or 25 compliance wita QA requirements.
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I realize that can be picked up in the root cause 2
of the defect, but I would suggest that the quality 3
assurance aspects of your review would be added to tne 4
objectives.
5 Now, if you address this somewhere else in the 6
program, it may be more appropriate someplace else in 7
the program, but enat certainly is one objectives we 8
view.
9 MR. LEVIN:
Okay.
You are correct in identifying 10 that it's through the root cause and generic 11 implications aspect of our program that, if there are 12 programs, whether they be quality programs or whatever, t
13 that recommendations from approval of those programs
>'J 14 would involve that activity.
15 MR. MILHOAN:
Howard, I was assuming wnen you were 16 talking aoout licensing commitments, you were not only 17 talking about on your previous slide about trending 1d deviations from licensing commitments, not only are 19 hardware commitments, but the commitments of tne quality 20 assurance program to implementation of the ASSi 45.2.11 21 standard of QA requirements for design.
22 In other words, the trending, for example, of 23 documentation of engineering judgment or the lac: of 24 documentation of engineering judgments, tnat type of
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25 commitments would be trendeo also.
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MR. LEVIN:
That's correct.
Okay.
If we can Let a
2 back to these elements from our program, now will be 3
configured from an organization point of view to 4
execute.
This is a slide of our organizational chart, 5
and I'd like to identify the key components and 6
individuals that are assisting me.
7 The first is Frank Dougherty, who is serving in the 8
capacity as design adequacy manager.
And Frank has a MS 9
in nuclear engineering and 16 years of nuclear power 10 industry experience.
Twenty years with an AE and design 11 consultant experience.
He's a past member of AS 50 12 Gyphene.
Currently a member.of ANS 3 on reactor 13 operations.
c-14 Frank was involved managing in the design aspects 15 of the review in the Midland independent design and 16 construction verification program.
And ne brings with 17 him a significant amount of experience in design, as 18 well as design control.
19 Serving in the position of construction quality 20 interface manager is Dr. John Honecamp.
John's 21 responsibilities include interfacing witn the 22 construction aspects of the CPRT program.
Tcat 23 interface being witn the work that Joan Hansel is 24 doing.
It's an on site interface.
25 Principal responsibilities ' include interfscin;, witn GODFREY & AMES COURT REPORTI:;G Metro 469-6100, (d17) 460-2048
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the site safety evaluation group; work where that group 2
is working under John Hansel in evaluating construction 3
deficiencies that he may uncover.
4 And in view of the fact that those deficiencies 5
need to be evaluated from the standpoint of design 6
implications, a very strong interface is required.
And 7
John Honecamp is responsible for insuring that ena 8
information gets back to the design adequacy t e ac: such 9
that the collective significance of that can be incluced 10 in an integrated sense with everything else that evolves 11 from the program.
12 John has a PhD. in chemical engineering, and over 6
1 13 25 years of engineering experience.
He has 9 years of L.J 14 experience in fuel and design startup operations, 11 in 15 nuclear reactor research and development, 5 years witn 16 the utility.
And in that capacity was deeply involved 17 in the design and construction verification of tne 18 recent recently licensed facility.
19 And in the past two years, has been in the 20 consultins world, participating in management and 21 technical assessmentments that are muco like the one we 22 nave nere.
23 MR. SOSHAK:
Howard, wil1 ne have any role in root 24 cause, or will
.t n a t ce in one of tne otner ' locks?
o I
' ~
25 MR. LEVIN:
Chay.
'd e - - I was about resdy to ge:
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to the individual that has that responsibility.
As far J
2 as root cause, Bob, that's -- everyone has that 3
responsibility.
I want to say that that is -- that 4
extends throughout the program.
5 However, okay, there is a focus in dealing _with 6
.that.
And that comes in our programmatic engineering 7
implications program.
We have a manager for that 8
program.
So it's really -- that focus occurs in that 9
box.
And that box is led by Ed Blackwood, whom I'm 10 about to introduce.
11 MR. 30SNAK:
I wondered whether or not that did 12 include rott cause.
That's wny I put a question mark by i
13 that box.
But yesterday when we talked with John u -
'14 Hansel, there was the interface with QA and design, and
.15 somehow or other I hope we're going to cover that 16 interface,.where we can determine how root cause is 17 going to be here.
13 MR. LEVIN:
Root cause is something that by 19 necessity -- see, the generic implications program was 20 created to provide an umbrella, okay.
And oftentimes 21 the root cause has a very important input into assessing 22 the generic implications of a problem.
But root cause 23 oftentimes gets down to a very, very technical level, 24 okay.
And it's best dealt with, okay, by tne people
-25 that are doing those evaluations, o!: a y.
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The focus for insuring that those root causes don't 2
have generic implications and going through tnat is a 3
systematic way, okay, is provided in this one element on 4
the program.
5 MR. 80SNAK:
But root cause may also be very 6
generic and very sweeping across the whole --
7 MR. LEVIN:
And that's why there's a focus for 8
bringing all these various locals into one place.
9 MR. SHAO:
Howard.
Yesterday, wnen John Hansen 10 made a presentation, I didn't see in a lot of so-called 11 concrete QA/QC problems.
They are identified in our 12 SSER, and John Hansen said it will be handled by Howard l
13 Levin on the so-called structure QA/QC.
But I con't see L_ J 14 any organization here to handle tnis compound.
15 MR. L.EV I N : Okay.
That actually -- Larry -- tae 16 as I indicated, one interface in my description of the 17 role that John Honecamp had with the construction 16 quality interface.
That's one interface with John 19 Hansel.
I described that role.
20 Another very important interface is one.
Anc toe 21 second principal interface with him is tnrough tne 22 programmatic and generic implications.
And tnat 23 coordinator, Ed Blackwood, has responsibility for 24 cutting across our -- the responsibilities of review
,__q 25 team leaders, okay.
And most importantly into Jonn.
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And particularly where there are QA or QC implications
- J 2
of what we found.
So it occurs in two locations.
.3 MR. SHAO:
But who would do the_ structure QA/QC, 4
you or John?
5 MR. LEVIN:
It -- both.
We have structural 6
reviewers that are involved dealing with issues in some 7
cases, and in other cases doing the self-initiatec 8
reviews, okay, which are more.
We'll get to that in a 9
moment.
10 But there are more design verifications oriented in 11 an additional sense with Boing forward and reviewing 12 selected areas.
13 And if through their activities, okay, there are t -
14 root causes identified or not identified, but suspected, 15 and there is a need for further evaluation in the 16 program or process, that gets communicated to Jonn.
And 17 John has a responsibility for evaluation of those 18 problems.
19 MR. SHAO:
But right after John's view, doesn't 20 have any structure QA/QC.
21
!! R. HANSEL:
Do you want me to address taat?
Jonn 22 Hansel, CPRT.
We will investigate all QA/QC issues 23 regardless of where they're at, Larry.
Several 24 structural, mechanical, electrical, I:iC.
'le have not
' ~
25 broken them down, specifically, by Onose disciplines.
GODFREY & AMES COURT REPORTING Metro 4o9-6100, (617) 460-2046
24 1
Anything that we have that indicates a concern or 2
an issue of QA/QC regardless of wnere it comes from, 3
which discipline, we will investigate.
Now we may find 4
some issues in our reviews.
l 5
Howard's people and his teams may well also 6
identify concerns and issues that looks like it's a 7
process problem, a procedure problem, a craft p r o b l e r.:,
8 inspector problem, and they will send those to me and I 9
will look at it from a QA/QC standpoint.
However, make 10 certain that the design process is proper.
11 MR. LEVIN:
And the principal flow point, Jonn, to 12 you, is through this generic implications box.
And Ed 13 Blackwood has that responsibility for -- it's assuring L
14 that that's a very stong --
15 MR. NOONAN:
Let me pick"up on this.. We will have 16 a lot of questions about QA and on who is doin6 what.
17 There's three areas that we need to make sure we fully 18 understand.
19 The interface with John Hansel.
The Stone ano 20 Webster, how tnat-interface because -- both my 21 viewpoints, both the Hansel work and the Stone and 22 Webster work, their starting points nave to be correct.
23 It seems to me you're the one enat's going to cetermine 24 that; is that correct?
I s t h e d e s i g n -- a r.: I in effect i
25 drawing whatever the program is?
GODFREY & AMES COURT REPORTI:10 Metro 469-6100, (617) 460-2040
25 1
So those starting points have to be corrected.
2 Seems to me you have to be out in front.
Is that the s
3 way it's going?
I'm just. basing questions.
4 But yesterday there was a lot of questions on tne 5
QA, who is looking at QA, and I think they're still 6
doing it today.
7 MR. LEVIN:
Clearly, Vince, you're correct in 8
observing that what where John starts and where I 9
end, so to speak, they have to be reconciled.
I don't 10 think that's a necessary impediment to initiate the 11 program and find reasons.
12 Fundamentally, what I'm trying to do is verify the 13 adequacy of the design outputs.
And those outputs are, t.
14 typically, in the form of drawings and specifications.
15 On the other hand, John takes those drawings and 16 specifications and is attempting to determine wnether 17 or not the plant was constructed in accordance with 18 those.
19 So we can start our evaluation.
- Jow if something 20 cnan6es in the design, it goes without sayin;, tnat 21 where -- and that's useful in assessing, yuu know, hou l
22 well the project did in, let's say, constructing to l
23 these drawings, or how well they did in arriving at 24 tnose drawings.
25 However, in teems of final oesian adequacy, if 00DFREI 6 AMES COURT REPORTl:;G Metro 469-6100, (617) 460-2043
I 1
something changes, a drawing, something part of tne 2
evaluation is modified to a drawing change, or 3
specification change occurs, obviously, and often times 4
that occurs, or may be some modifications associated l
l 5
with that to bring the constructed facility in 6
conformance, then John is going to have to verify that, 7
in fact, those are congruent.
But I don't tninx it's a 8
necessary impediment, logistica11y, in starting tne 9
program.
10 HR. CHANDLER:
So if I understand the interface i
11 here, if you're tracking a design problem whien has 12 construction implications, that moves over to John.
13 Likewise, if John is doing somethir.g which t- -
j 14 identifies a construction problem, it's moved over to 15 you, to the design side, so that the process coesn't det 16 lost.
You would also pick up on the design potential 17 question, anyway, to assure that, or to determine 16 whether, there was a design associated problein that led 19 to the construction problem tnat he's identifieo.
20 MR. LEVIN:
That's absolutely correct, Larry.
And 21 I will be showing you some of tne logic fo r tria t.
t 22 MR. MARIU0S:
Howard, am I understanding tnat your j
23 individual reviewers will have dual responsibilities?
24 Namely, they will ascertain tne quality of tne d e s i.;n.
l6 a
25 And at tne same time, keeping t r ac:: of the quality i
1 i
GODFREY & AMdS COURT RIPORTIUC Metro 469-6100, (317) 460-2048
I 27 1
assurance or the design process that is used ir. order to 2
decide wnether the process is correct?
3 It is one thing to determine that the final procuct.
4 is correct.
And another one to decide whetner the 5
process used was the appropriate process.
So how are l
6 you going to determine two of -- both of those elements 7
in the -- in-your detailed review?
8 MR. LEVIN:
Okay.
The most important problem is 9
verifying the quality of the end products of that l
10 process.
But it's also important that if those l
11 processes or programs had witnesses, that they be 12 corrected, with regard to ongoing processes, okay.
And J
13 it's -- the way we will determine that is througn the i
l 14 generic-implications evaluation process that I will oc 15 describing.
So if we could get back to that.
i 16 HR. MARINOS:
What my question is, is this l
17 individual, will be in charge with the responsibility to la flag that there is a design process problem in spite of 19 the fact that the product is correct?
l 20 MR. LEVII;:
Absolutely.
1 21 MR. MARINOS:
So this man tnat you have assigned in 22 a particular area, he will be qualified to do botn?
An 23 engineer does not necessarily nave both capoo:11 ties, or 24 is mindful of, or assess the same s16nificance to
'~
2$
quaiity.
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MR. LEVIN:
The way it occurs, that engineers 2
witnin their discipline, okay, will be identifying tnose 3
potential witnesses.
But and where there s e e.m s to be T
l 4
something, you know, a systematic problem, possibly, 5
okay, that will be getting evaluated, you know, in toe 6
generic implications thing.
7 But where there is a need to review a specific 8
program from the standpoint of looking at it on paper 9
and selecting implementation, okay, that is the 10 responsibility of John Hansen.
When those needs are 11 identified, their request is sent for him to get 12 involved.
I 13 MR. MARINOS:
Well, the individual reviewer will be c J 14 totally familiar with the N-45 211 process.
15 HR. LEVIN: Absolutely.
And I will be descricing 16 our methodology which parallels that process 100 17 percent.
18 MR. MARINOS:
Parallels it through another process?
19 MR. LEVIN:
Through the 211 process.
20 MR. MARIHOS:
Otner individuals will follow that 21 process, you say?
22 MR. LEVIN:
That's in the program.
If I coulo get 23 back 24 MR. CALV0:
My turn.
The foundation of tne l
'~
25 construction adequacy review, tne wnole tnin; t t; s t 00DFREY & AMES COURT REPCRT1;G Metro 469-6100, (d17) 460-2048
29 1
depends on this population -- by the -- to population 2
areas.
And then we're going to select some sample 3
populations, and we're going to apply to each population 4
different attributes.
5 You haven't,quite yet got to the foundation of your 6
program.
But I'm looking at the interface from your 7
program with that foundation.
Ycu're going to be 8
designed review and you also have some walkdowns.
9 How you decided adequacy review?
How your
~
10 walkdowns, when you~get into the construction?
Somehow 11 is it going to interface with the concept of population 12 areas on the plant.
Are you -- going to be a 13 coincidence that the same walkdowns you had, it may 14 affect certain areas, certain systems, that you 15 selected?
Or will the systems that slow out the 16 shutdown systems?
How are you going to interface wita 17 the, say, construction adequacy review?
Will you review 18 the interfaces?
19 MR. LEVIN:
Okay.
In several cases we anticipate 20 tnat those walkdowns may be done with teams tnat include 21 both quality peopAe as weli as engineering.
I thin;:
22 it's important to differentiate the fact that John is 23 looking for something a little bit different tnan wnat 24 we're looking for.
' ~
25 MR. CALV0:
Are you soing to take credit for GODFRZY & AMES COURT REPORTING Metro 469-5100, (017) 460-2046
l 30 l
I l
1 sometning John has done, or are you soing to go t
2 independent with what John has done?
Suppose Jonn 3
selected a population on a certain system?
You can 4
confer, if you want to.
(
i 5
MR. LEVIN: I'm sorry?
6 HR. CALV0:
Suppose you go -- whatever system you j
7 select, whatever task you selected, and you come bac;; to l
}
8 the construction to the walkdown, and you found out that 9
John Hansel already covered that area, are you going to i
/
{
10 cover it too, or are you going to pick up a different I
i.
11 area?
4
)
12 If you don't know the answer, you can think about i
.I 13 it.
But it I think it's an important interface.
! u J i
]
14 There should be some way to address it.
15 MR. LEVIN:
Jose, the answer varies from time to r
{
16 time.
It largely -- they're independent, and it gets 17 back to the fact that I am trying to confirm, okay, tne 1
18 adequacy of the design as reflected on drawings and 19 specs.
Okay.
That's my goal.
20 And Jonn is starting froa there.
Oftentimes when 21 it is done together, it's because of efficiency in i
22 execution.
And tnere -- that may be a principal resson l
23 from time to time.
l; _-
24 MR. CALV0:
Yean.
But it can have advanta/,o--
cnc i
a i.;
j 26 disadvantages.
If Jonn Hansen does cometa:ng anu finos i
4
)
GODFREY 4 AMES COURT FEP03 TING l
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31 1
everything okay, and you go back and do something else, 2
and>still find something wrong, you nave got to 3
reconcile the-difference, or you say, "I don't have to 4
do this in the walkdown, because John Hansen has done 5
it.
Therefore he did the same thing I was going to do 6
anyway," and take credit.
7 or you say, "I don't care what John Hansen hac 8
done.
I'm going to do anything else irregardlesstof 9
what he's done."
e' i
10 MR. LEVIN:
John -- we're doing different enings, 11
'okay.
I differentiate between a QC or QC in s ra ec t io n,
12 ~ okay, in an engineering walkdown.
[
13 A QC inspection, okay, goes out with the precefinea 14 set of attributes that -- and criteria for an 15 inspection.
16 Oftentimes, it's a black / white kind of process, 17 okay.
It is either in conformance or it is not, and 18 that's indicated in that inspection proce:s.
19 On the other hand, when we do engineering 20 walkdowns, we're looking for something a little bit 21 different, okay.
Principal differences,"tne en3.neiss 22' ire going out to typically.to understand, for examp.e, 23 physical behavior of'a system, you-know, icok at now 24 it's constructed, now'fuu aould e:: p e c t it to benave, 25 sucn that that is input into a design evalua; :n 4
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process.
2 Judgments are being made, engineering judgments in
_m 3
that process, that are not typically made in a 4
construction quality inspection.
5 MR. MARINOS:
Such as what?
Would you give us an 6
example of what you mean by that?
7 MR. LEVIN:
Okay.
For example, one of tne issues 8
that has been -- one of the needs that has been 9
identified, has_been to reconcile the behavior of pipe 10 supports in the plant, that which has been assumed in 11 the piping analysis.
12 A part of that activity, okay, includes going cut 13 in the field and understanding, getting better physical L -
14 understanding, of how we expect those to respond.
That 15 is an engineering type of an activity, as opposed to 16 John Hansen, where he says, "I have got to go out there 17 and look at welds and size of tne weld, maybe an 18 important attribute."
19 He's simply soing to gauge it and record what he 20 found, okay.
4 21 There's not the saae type of jud.;aenn in that 22 process.
It's a different process.
23 MR. CALV0:
I don't understand.
is that all tne 24 judgments tnat you do?
The desi;n to ce convertec naa
'~
25 crawincu, and tnose drawings are used t o o e t e r. :. r. e t c. t t GODFREY a AMES COUMT RE? ORT:.1d
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33 1
the design has been -- adequate?
I con't see what is
_ J 2
the difference -- what you do in a walkdown, and I con't 3
see the difference what John Hansen has done.
And I 4
don't see what John Hansen lacks in this and cannot do 5
what you do.
If ne lacks the expertise, I don't see way 6
he's going to tell you the design deficiency that he's 7
found out, to send back to you to be taking care of it.
8 Is th'ere somehow you cannot answer the question?
9 MR. MARINOS:
-I can see an example of walkcown 10 confirmation, a two over one seismic kind of -- that 11 might be something that you would look at.
But 12 supports, I don't know.
And I'm not a supports expert, 13 but I don't know how to assess -- well, I was hopin.3 I
u -
14 that you would give me something --
15 MR. LEVIN:
A walkdown falls into that same 16 category, and may have even been a better example.
17 MR. MARINOS:
Or hign energy line interference.
13 MR. LEVIN:
I tnink maybe another way to look at in 19 is the engineering walkdown is attemptin6 to confirne une 20 adequacy of design.
- dhereas the construction inspection 21 1: L 3 ~try to determine the quality of essentially the 22 craft's work.
And those are two separate things.
23 MR. CALV0:
'inen you're talking about the acequacy 24 of design, now where is design reflected into tne
,, __q 25 crawing in the document?
It's not enose drawin;s GODFREY i AMES COURT REPORTI:iG Metro 469-6100, (o17) 460-203 0
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34 1
documents, also available to John Hansen.
If he's not 1
2 using the same document you're using, but looking at it 3
from a different place, enat's the problem that I am 4
seeing.
5 HR. LEVIN: Jose, we may see the design reflected on 6
a drawing, and we may go out in the field and see tne 7
same thing.
J 8
But, for example, that Angelos gave seismic twu 9
over one, that's -- that type of evaluation is not 10 something that you can easily reflect in drawings.
You 11 cannot do that evaluation on drawings.
You have to go 12 out, because of things like field run pieces of conouit, i
13 all kinds of things --
t J 14 MR. MARINOS:
You will confirm the same nace plate 15 information and pumps, motors, valves, and rotation type 16 information?
17 MR. LEVIN: That's correct.
18 MR. MARINOS:
This is your walkdown?
You will give 19 us a detailed listing of how -- what tne walkoown is 20 going to assess then, at one time or another?
21 MR. LEVIN:
Yes.
Absolutely.
And wall:down uia: be 22 controlled by a procedure.
I 23 MR. CALV0:
You also sayin3 tnat wnat Jonn Hansen 24 has done will 'o e incomplete, something is missin; anu
'~
25 that part that is missing, you're going to thke care of?
L GODFREY S AMES COURT REPORTIuG Metro 469-6100, (017) 460-204d
35 1
MR. LEVIN:
Together.
They go together and create 2
a whole package.
3 MR. CALV0:
This program so comprehensive, you'll 4
'oe as equally comprehensive to compensate for tnat 5
part.
That's what you're saying?
6 MR. LEVIh: Yes.
7 MR. CALV0:
And you're going to commit to de taat?
8 MR. LEVIN: Yes.
9 MR. CALV0:
Okay.
Thanks.
10 MR. NOONAN:
Maybe a couple of things before you 11 get to. start the part up here called QA/QC review.
I 12 would like a better definition of that.
13 MR. LEVIN:
That is the QA/QC review team leader, 14 that is John Hansel.
15 MR. NOONAN:
That's John Hansel?
16 MR. LEVIN:
Yes.
And it's shown him, of course, 17 reporting to the same. senior review team, as I co.
And 1d the dashed line indicates our interface.
~
19 MR. NOONAN:
Okay.
I see what you're saying.
I 20 interpreted that somewhat cifferently.
The price wouid 21 be sole duties.
He's the interface between you and 22 Hansel, right, wnen Hansel is doing his inspection.
23
' dill both of you be involved in those to some cesree?
24 MR. LEVIN:
He will be knowledgeable, as a minimuu,
,_ q
' ~
25 knowledgeable of those outputs.
And provisions have GODFREY & AMES COURT REPORTI:!G Metro 469-6100, (617) 400-2046
36 1
been made that that information will flow over his desk 2
entirely.
And it's up to John Honecamp to ceter:aine,
3 basically -- sort through that, evaluate anc determine 4
what needs to happen, if anything, if it has, for 5
example, design related concern, such as that, and he 6
will make sure it gets to the appropriate place in the 7
organization.
8 MR. NOONAN:
I guess what I was talking to, any 9
future meeting with John, he will be fully knowledgeable 10 of John Hansen.
He will be aware of what Hansen is 11 doing?
12 MR. LEVIN: Yes.
i 13 MR. CALV0:
I have a suggestion.
'I think yestercay i
L J 14 and today, we keep going back to this interface in 15 construction and design.
In some kind of way, when you 16 present, it appears that you have some of the answers.
17 But it also reflects maybe you had not considered as 18 fully as you should have considered.
19 I think you, maybe your action plan, wnen you 20 submit it to us, I will appreciate.it if you can clearly 21 define those things, so we know how you're going to t a 2.:
22 to each other.
23 MR. LEVIN: You're undoubtedly aware of the for:an 24 for those, the past TRT action plans in, I celieve, i
s J
25 Section 43, addresses the reponsibility of interfaces, GODFREY & AMES COURT R EPO RT I:iG Metro 469-6100, (517) 460-2040
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37 1
and we'll make sure that that's absolutely correct.
2 MR. GUILBERT:
John Guilbert, SIT.
This.is kind of 3
revisiting the comments I made yesterday, but I enink 4
there may still be some misunderstanding of now these 5
two programs interrelate.
You have got to remember tnat 6
each of these programs have certain elements.
7 But let's just deal with what I'll call the 8
category 2 activity, by John Hansel.
It is 9
self-initiated across one board construction program as 10
-it relates, for example, to Howard's, across the board, 11 as it were, look at design work activities.
Just a 12 minute.
13 They both -- John Hansel starts, okay, witn tne 14 design drawings, design specifications, including wnera 15 the change tapers associated with that.
He goes out ana 16 does his inspection to that.
Howard starts with tne 17 design criteria and et cetera.
And ultimately goes 18 througn implementing documents, as you'will hear 19 shortly, and compares that to determine whether.ic was 20 adequately reflected in those design documents anu
~
21 design drawings and ~ design specifications.
22 John Hansel, as you. heard, is d o i n '; tnis on a 23 population. basis to a random sampling on a static ical:7 24 sounc oasis.
Howard is coing i; to make sure that ne
~
25 has a representative numoer of tnings that ne's ico.: n; GODFREY J AAES COURT R E P O.< T Z :!G
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at across all the design work activities.
2 But I think the point you're missing, perhaps, is 3
that they aren't necessarily going to be looking at tne 4
correlation between the hardware that he looks at, anc 5
the specific components of design that Howard looks at.
6 There is not going to bs a one to one correlation 7
between the things they're looking at.
There may be 8
some cases where they have to look at the same thing, 9
and this is just part of those two.
10 MR. CALV0:
John, I had not missed any point.
Ali 11 I hear yesterday that Howard Levin was volunteering for 12 a lot of stuff that John Hansel is supposed do.
And 13 want to be sure Howard Levin understood what he t J 14 volunteered for.
I understand what you say.
I want to 15 be sure that -- Howard was not here yesterday, you 16 know.
Every time John Hansen has a problem, Howard 17 Levin will be taking care of it.
16 And I'm Glad that you don't say others nave a 19 problem that somebody else is going to take care of it, 20 but somebody else.
I will understand the difference.
21 But again the record shows that Howard Levin was [oinG 22 to do'whatever John Hansen couldn't do, yesteraay.
And 23 I want to be sure that Howard Levin understands that.
24 MR. GUIL3ERT:
Just to recall where that e nta n a ; e d I
=6 J
25 from yestercay, is Larry referred to some Append:x ?
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items, whien were going cack, basically, what I'll 2
called the compendium of the TRT issues.
3 And referring back to, you have gone througn a 4
Appendix P of SSER 11, and called out what you guys 5
believe to be the QA/QC implications of the TRT ltems in 6
civil, structural, mechanical, miscellaneous, and 7
electrical.
8 Now since Howard is also review team leader for 9
those disciplines as they relate to TRT issues, he wears 10 two hats, recognize the -- excuse me.
For those 11 activities as well as review team leader for cesign 12 accuracy.
]
13 His charge has been to go out and resolve those 14 issues, and in the resolution of those issues to do 15 basically the same thing you do.
It comes across 16 implications in those that relate to construction QA or 17 QC.
He's been charged with identifying those from the 18 point of view of how they may have generic implications, 19 and passing those on to Mr. Hansen.
And that has been 20 done through that activity.
21 What he's alluding to is, through his review of 22 these other aspects, if he happens to find any cener 23 similar implications that may. fall oack to construction 24 or QA/QC, he will also pass those on to Mr. Hansen.
gq
~
25 MR. CALV0:
All I'm saying, when you consider your GODFREY & AMES COURT REPORTI?;G Metro 469-6100, (617) 400-204d
40 1
final plan, will you please, some kind of way, clearly j
2 indicate this interface.
Thanks.
3 MR. LEVIN:
Yes.
Okay.
Getting on to the 4
organization, I'll run through the principal people 5
that are coordinating the activities in various 6
discipline.
Martin Jones was also review team leader in 7
the TRT, through the electrical area, is leading tnis 8
effort, and I&C effort as well.
Martin has over 27 9
years of engineering experience, 20 years of whien were 10 in the nuclear utility involved in design construction, 11 construction management, quality control.
12 Martin was a manager of quality control for nuclear l
13 unit,.as well as manager of construction.
Martin has L J 14 also participated in construction and design 15 verification 'a c t i v i t i e s, and served in the capacity of 16 construction verification manager in' the Midland Revieu.
17 Tim Snyder is leading --
18 MR. MILHOAN:
Excuse me, Howard.
Jim Milhoan.
How 19 many years of direct design experience has Mr. Jones had 20 at on being a designer himself?
21 I assume the program plan your prograa plan will 22 assess or give us an idea of identifying separate y the l
23 direct design experience of your individual reviewers?
24 MR. LEVIN:
Yes, in fact, Jim, we will ce p ro v id in;;
i I
l e
25 you with recu.ies of all the people that wiiz be involved GODFREY & AMES COURT REPORTING Metro 4o9-6100, (617) 460-2046
41 1
in -- I will be discussing here.
2 MR. MILHOAN:
Will those resumes be of such a 3
nature that we can determine the years of direct 4
commercial design experience.
5 MR. LEVIN:
Yes.
Tim Snyder is coordinating tne 6
piping and supports discipline.
Tim brings with him 14 7
years of experience in nuclear power plant design and 8
operations.
Six of which in -- directly in tne piping 9
analysis and support area.
10 MR. SHAO:
Howard, let me ask some question on this 11 diagram.
Yesterday you say the cable trays support is 12 going to be done by Abasco.
I don't see it on the graph 13 here which -- where will that fall on.
t -
14 MR. LEVIN:
That interface will be described in 15 detail later.
And it is directly witnin the civil 16 structural coordinator's responsibility.
17 MR. SHAO:
So Abasco cable tray would fall witnin 18 tne civil structure here?
19 MR. LEVIN: There's an interface there that we wi_1 20 be describing, yes.
21 MR. SHAO:
Also, I have a general question aere.
22 If I.look at pipe supports and piping, is another slice 23 out here of a third party coming, Stone anc uebster, 24 they have a lot of. horsepower and snird party anc 25 all tne others is done oy TUGC0 suppor coord:naccr.
GODFREY & A:!ES COURT REPORTII:G Metro 469-6100, (317) 460-204o
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Does that mean that the TUGC0 people is going to do 2
their own analysis?
3 MR. GUILBERT:
In the case of piping and pipe 4
supports, Larry, just referring to that.
As you 5
recognize that was basically a separate discipline area 6
in the way the Comanche Peak Project was establisned, so 7
showing Stone and Webster there encompasses all items in 8
that particular discipline problem.
Let me continue.
9 In the area of -- in the other areas, in tne civil 10 structural area, there are a number of action plans that 11 you're going to hear about today, one of which goes to 12 cable trays.
The notion inclu' ding the TUGC0 support 13 coordinator is indicated -- who is the interface fcr L.
14 information and data to assist these team leaders in 15 obtaining information.
16 In some cases -- basically, in some cases, there 17 may be some work being done by the project that is 18 requiring a third party overview.
The Abasco effort 19 which is being done for the project in the cacle tray 20 area falls under tnat category.
21 In other cases, essentially, all of the actions 22 plans in a given discipline area are ceing in.piementec 23 directly oy tne enird party.
I think that 24 MR. LEVIN:
Larry, maybe it would be bect
-.:s t i
25 was trying to do here was g;ve you the overa:1 GODFREY & AMES COURT R E P O RT i::G Metro 369-6100, (J17) 460-204o
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framework, and as we get into the discipline 2
2 descriptions, okay.
In fact, that's the third portion 3
of our presentation.today.
4 The first item we'll address in each of those 5
discussions will be the organization and now it will be 6
configured and the interfaces in those activities.
So 7
if we.can ~ get kind of -- develop the overall framework, a
8 and then' fill in the middle -- in the rest of our 9
presentation --
10 MR. SHAO:
I have two general comments.
I think 11 I have no problem with the middle column, because tney 12 have a lot of horsepower as an independent assessment.
13 On the other column -- let me finish my comment.
On the I
u-14 other column, first, I'm afraid of not enough 15 horsepower.
And the second comment is, will the review 16 be independent?
17 MR. BECK:
Let me ask you to be a little patient.
18 And we're going to spend half a day' talking about 19 precisely how those boxes are going to be covered.
20 This is an organization chart.
But I want to
.c 21 back for just for a moment, to one of tne Guiding 22 principals in the whole CPRT efforts.
23 Analyses, calculations, will eitner ce done by a 24 third party, or overviewed by a tnird party, in the case
~
25 where a TUGC0 project is doing analyses, their evervleu, GODFREY & AMES COURT REPORTII:G Metro 469-6100, (617) u60-2040
44 1
period.
,j 2
There is no instance where that's not the case.
So 3
its either done by third party or overviewed by third 4
party to the satisfaction of the third party.
5 MR. NOONAN:
I guess I'd like to go and get off tne 6
organization chart.
John, I want to make sure, one 7
point tne staff is concerned about tne organization, wno 8
is doing the work.
They want to fully understand wnc is 9
actually doing it, in all cases, the number of people 10 involved.
And also how that all gets put back into that 11 organization.
I think that these concerns being voiced 12 now, maybe later in the day, you will get to those.
13 They want an answer.
t L -
14
!! R. CALV0:
I had one more seneral comment.
That 15 again, in view of this extensive effort enat you're 16 going to embark on, doing -- I think it would be 17 appropriate to consider the make-up of this senior 16 review team, and maybe move there with some people wnc 19 has experience in construction, engineering, electric, 20 instrumentation.
21 I think, my opinion, I think you're lacking s o.a e o f 22 that.
I know before you indicated that you're goint; to 23 use consultants.
But it was somebody else wnc r.: i n c s the 24 shop on a routine basis.
I Onink it would be s o.T.e t h i n.,
25 for you to give very serious consideration.
GOD? REY a A:4ES COURT REPORT 1..'G Metro 469-6100, (617) 450-2040
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MR. LEVIN: 'de --
J 2
MR. BECK:
The point is made and well taken indeed, 3
Jose.
Thank you.
4 MR. LEVIN:
Jose, since you brought that up, it may 5
make sense to address that issue.
And as you nave 6
indicated, we have retained quite a few recognized 7
individuals in the field, in the piping area, supportin; 8
us.
9 We have Everett Rodenball, who I'm sure many of 10 the s'taff know, who has a significant expertise in the 11 area of ASME components.
12 Jerry Slacas, who heads the ASME code analysis J
13 piping work team.
Moe carnon, who is the committee on 14 the HI support committee.
These individuals are 15 assisting us in the piping area.
16 In the civil structural area, we're ueing assisted 17 by Bill Hall and Bill Munci from the University of 18 Illinois.
Cris Holly and John Bigg from Hansen.
Holly 19 and Bigg and MIT.
Ed Cosel and Daniel Luciano f r o r.i 20
'MIT.
'21 And Paul Gunnes from Abasco, and he's assistin; us 22 in the, specifically, in the testing area.
Ana as we so 23 through our presentation, we might get into taa; in s a:.: e 24 core detail.
i 25 These individuals participate at alt levels, GODFREY & AMES COURT R E P O RT I::G Metro 469-6100, (617) 460-204o
46 1
including review and evaluation on the front end of tne a
j 2'
action plan participation in the execution of those 3
action plans and evaluation of results.
4 MR. CALVO:
You took care of our group, but.you 5
left me out.
6 MR. BECK:
Jose, we're not going to leave you out.
7 MR. LEVIN: In that regard, I specifically mentiened 8
-- Daniel youre being too nice.
9 I specifically mentioned two disciplines tnat are 10 under Larry's responsibility.
However, I wanted to 11 point out that the the electrical I&C area has just been 12 initiated.
It is self-initiated, and it's clear to me 13 that the need may arise in the, future.
We will L -
14 supplement our staff as required.
15 MR. CALV0:
Don't make me work too nard.
16 MR. MARINOS:
So you want to talk to us about the 17.
mechanical systems a little bit, too?
Howard, uno are 18 the people that will man these, not tne components 19 necessarily, the hydraulic?
20 MR. LEVIN: Just point out t h e m e c h a n ic a l.:r.e e t in:;
21 systems and it is Fred Schaffer, o!:a y.
Fred nas an 22 MS in nuclear engineering.
He nas eignt years of 23 arenitect engineering experience in design and 24 construction, nuclear plants,
,__,t J
6 25 The experience is it's focusec in particular on GODFREY.
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(
I 47 l
1 AFU systems _ design, and additionally the types of 2
evaluations that are involved in some of the 3
multi-discipline area tasks that I think you brougnt up 4
before.
5 MR. MARINOS:
The hydraulics aspects of tne design 6
he has experience in or others --
7 MR. LEVIN: That's correct.
At the particular --
8 that he was previously associated.with -- Fred was the 9
lead in tne AFW systems cesigns, was his focus.
So he's 10 particularly well suited for this e f f'o r t, in view of the 11 fact, as,you will be hearing, the AFW system is one that 12 we have selected as a further test of tne design 6
-l 13 adequacy as planned.
>u.J 14 MR. CALVO:
Who will take care of the testing 15 aspects?
John Hansel?
16 MR. LEVIN:
No, the testing here is a little bit 17 different than the testing that John is involved witn.
18 The testing that John is involved with is in some cases 1
19 non-instructive examination.
In our case, we're talking 20 about structural testing and that's -- One 21 responsibility for that is with AHC0 engineers.
22 Leading the civil structural effort is Dr. Cris 23 Marouet from Stanford.
He has nine years of nuclear 24 experience with a specialty in seismic hazarcs analysis, t
25 structural design in civil en ineering.
He's a aer.ber GODFREY & A:!ES COURT REPORTING Metro 469-6100, (317) 460-2048
4d 1
of the ASC committee on cable tray design.
[j 2
Cris also participated in the design verification 3
efforts, where he had a similar responsibility.
4 MR. MILLS:
Excuse me, Howard.
Does he have any 5
direct commercial AE design experience?
6 MR. LEVIN:
Yes.
7 MR. MILHOAN:
How many years?
8 MR. LEVIN:
Several.
I don't have the exact 9
number.
10 MR. CALVO:
Can your program plan -- when you 11 submit it to us, you're going to emphasize --
12 MR. LEVIN:
It will be on the resumes.
What I'd 13 like to do here is clarify the roles of two principal 8L]
14 entities that are contributing to the CPRT efforts.
And 15 those entities being the third party efforts as well as 16 the project.
And both are contributing to meetin5 the 17 goals of the CPRT program.
18 On part of the third party, these individuals nave 19 responsibility for defining the overall program plan, 20 also providing an end process overview anc guicance to 21 the project during any activities that they may have 22 that are associated with the program.
23 Concurrence with project quality progran desi;n
~
24 procedures and specs governing the current CPdT wor;.
,__q J
25 Selected verification of project implementation of toe:r GODFREY & AMES COURT REPORTI:30 Metro 469-6100, (S17) 460-2046
49 1
design basic activities, where tnese may be required,
_.J 2
including verification of design criteria, analyses, and 3
the outputs of that process, the drawings, and specs.
4 And most importantly, the third party is 5
responsible for tne' evaluation of root cause generic 6
implications and safe.ty significance.
7 MR. BOSNAK:
Howard, what is the role with the 8
third party, with groups like Stone and Webster, and 9
Abasco?
10 MR. LEVIN:
Okay.
I will be Setting into that in 11 more detail.
But in a nutshell, Bob, we will
'o e 12 verifying their work.
13 MR. BOSNAK:
All of their work.
a....
14 MR. LEVIN:
Design verification overview.
It's an 15 overview of their -- the project, as John pointed cut 16 earlier, is responsible for the execution of design 17 basis analysis.
It's their responsibility.
And third 18 party will not ce involved in that, although we w ll be 19 overseeing.
20 The project also gets involved in the collecticn of 21 information that the third party may need to conduct its i
22 evaluation.
And also goes without saying, tne project 23 is responsible for implementing any corrective action 24 that's identified as part of the program.
~
25 We come to tne second segment or my presentation.
GODFREY & A;lES COURT REPORTir.G lletro 469-6100, (d17) 460-204d
50 1
In this segment, I plan to go through the methodology j
2 for the design adequacy program.
3 First, I will provide a general overview of tnac, 4
and then get into the specific functional parts of the 5
program.
That is, the external sources evaluation, 6
self-initiated evaluations, root cause and generic 7
implications evaluation, and how we will close tne 8
program.
9 As many of you arc aware, we have to have a 10 mechanism for controlling our activities.
There neecs 11 to be traceability of our process, our results.
And in 12 an effort to -- we have defined an issue classification 13 system that will help us manage that.
And specifically, L...
14 identify ~three categories of issues.
15 The first being that of a discrepancy.
A 16 discrepancy, a situation, where we're meeting 17 inconsistency in criteria or documentation.
And 18 typically that will be something that is trivia and a 19 insignificant typo, or math error.
20 I think it's important to note that those tnings 21 will be detected by the system, and tnat judgment w111 22 be made, in fact, to this insignificant or tne l
23 alternative.
l 24 MR. IlARINOS:
Do you intend cc retain recoras for 6
25 viewing of all these errors that you have passec GODFREY a AMES COURT REPORTI::G Metro 469-6100, (617) 460-204o
51 1
judgment as insignificant?
Of course the significant 2
ones we have no problem.
But identify --
2 3
MR. LEVIN:
These will be obtained in audible form.
4 MR. MARINOS:
Okay.
5 MR. LEVIN:
The second category is that of a 6
deviation, which is simply a failure to meet the
?
criteria.
An example might be an FSAR commitment nat 8
is not met.
9 MR. BOSNAK:
But if that commitment were a failure 10 to meet a general design criteria, I hope it would not 11 be a deviation.
It would be done in an afficiency 12 column.
13 Do you have a set of attributes that you pass out 14 to the people doing this, so they can determine what is 15 a discrepancy, wnat is a deviation, and what is a 16 deficiency?
In other words, how will they know-whether 17 to put something like a general design criteria railure la in one column or another column?
I hope it would be 19 fairly clear.
20 HR. LEVIN:
Well, yean.
I guess my reply to
- nat, 21 Bob, is everything will get revieweo.
It w;11 be 22 documented.
The classification will be apparent.
And 23 the judgments that are made in that regarc can be 24 well, you know, it will be traceable anc can ce l -
l l
25 revieued.
I really believe that the cerinitions here GODFREY a A:iES COURT REPORTI :G
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52 1
are fairly straightforward.
2 The principal if it's really almost a binder 3
scheme, the discrepancy's there, primarily because we 4
need to manage the program.
But the key things are 5
deviations and deficiencies.
And the deviation is a 6
commitment made, may not have been met.
That's pretty 7
straightforward.
A deficiency is something that has 8
safety significance.
9 MR. BOSNAK:
Well, we're getting back to the same 10 question again, as to what safety significance.
But I 11 think --
12 MR. SHAO:
What do you include right now?
13 MR. BOSNAK:
We need a set of attributes that you L -
14 will be using to come to some degree of judgment on 15 this.
16 MR. LEVIN:
Bob, where you will have an opportunity 17 to see that is in your check list, and I will be setting la to that in a moment.
19 MR. CALV0:
It's too late.
Again, you will be 20 asking us to review a program plan and approve it.
So 21 we have got to have that front -- only if you suouit the 22 check list at the same time 23 MR. LEVIH:
I will be cescribing our approach and 24 our timetable for submitting taat, Jose.
But I assure
,_ _,l
'~
25 you tnat tais is something that is happenin;.on une GODFREY e A:iSS. COURT REPORT 1:lO Metro 469-6100,.(d17) 460-2048
I 53 1
front, and it's not a. situation where it's being made up 2
as it goes along.
3 MR. CALV0:
So you're going do make a commitment to 4
provide information to what Bob is asking?
5 MR. LEVIN: We will be making that commitment, and 6
it will be a fine point in time where you will nave an 7
opportunity to look at.
8 HR. TRAMMELL:
Howard, what bothers me in icoking 9
at this list is it sort of implies, but it doesn't say, 10 that discrepancies are okay.
Deviations is a maybe, I 11 think.
And the deficiency. probably will be correctec.
12 But I think that's causing a lot of trouble here.
13 MR. BECK:
No, Charlie.
Let me go back to what we u__
14 said yesterday to make it very clear, that anytning 15 CPRT discovers goes to the project.
Deviations tnat 16 they are discrepancies, if they need to be corrected, 17 will be.
Deviations, certainly, will either be 16 corrected and/or the commitment that is not being 1.:e t 19 will be pointed out as.an exception requested.
20 Now until we get co specific issues, I can't siy 21 wnich way it will be resolved.
But it will eitner ce 22 resolved either by correcting it, or by seeking anc 23 o'taining NRC's staff's approval let me f i r. ; s h.
o 24 That's not CPRT.'s job to dc.
Tnat's our job, as TUSCO,
' '~
25 to make sure tnat it happens.
GODFREY & AMES COURT REPORT 1JG Metro 469-5100, (317) 400-2040
54 1
So it's not going to drop througn the crack.
But 2
it's also very important to recognize that CPRT is 3
looking at safety significance of all these issues, and 4
they're going to characterize them in that regard.-
5 That doesn'.t mean we're not going to address it if 6
it doesn't have safety significance.
But it's very 7
important of, in the standpoint of making Unis bottom 8
line resolution, that we have reasonable assurance that 9
there aren't any. safety significance discrepancies in 10 that plan before we're ready to stand up and so swear.
11 So that's why this gradation is being made in tcis 12 part of the program.
But we in no way are ignoring
! 1 13 deviations on the project site.
But we don't want t_.J 14 CPRT effort to get lost in that process, which is the 15 project's responsibility.
16 MR. LEVIN:
But, John, there's things that -- I'm 17 sorry.
That I consider my responsibility.
And maybe an 18 example, I believe tnere's circumstances, Charlie, where 19 a typo could be a deficiency.
Okay.
A typo cou:d be a 20 safety significant item, tnat's possible.
It's part of 21 the process to determine wnether or not that, in fact,
~
22 is the case.
23 And so this was an e x a cip l e.
It would I prefaceu 24 my statement on the typo, that it was insignificant.
' ~
25 Sun tnat is not out of the logic train.
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MR. CHANDLER:
So how your check list will provide 2
us the road map necessary for the reviewer then to look 3
at a typo or a math error, for example, to determine 4
whether it fits simply ;s a discrepancy, or perhaps that 5
math. error indeed could be a deviation, or perhaps even 6
a deficiency.
7 MR. LEVIN:
Absolutely.
8 MR. CHANDLER:
These are not exclusive categories 9
as they're listed here?
10 MR. GUILBERT:
They're the end', after all-that 11 process has been done, everything is going to fit into 12 one of these three bins.
Everything starts at 13 discrepancy level.
14 MR. CHANDLER:
Just so that the math error coesn't 15 remain forever.
Only a discrepancy?
16 MR. NOONAN:
One thing, the way you said it, John, 17 you said if FSAR commitment if you can't meet the 18 FSAR, you will ask for an exception.
19 MR. BECK:
No, I didn't.
I said we will resolve it 20 one of two ways.
We will meet the commitment, or it 21 appears that we cannot or con't want to, we'_1 tel; you 22 about it.
23 But I can't predict.
I say the very n;gn 24 percentage of the time we're g o ir.; to enan;e waatever it I
~
25 is that acesn't meet the FSAR coar.itment.
'! e r y nign.
GODFREY & AMES COURT REPORTI.';G
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But I'm not going to make that hundred percent guarantee
'. j 2
that will be the case.
3 MR. NOONAN:
The point I'm going to make, is the 4
staff is going to look at the FSAR.
5 MR. BECK:
Yes, sir.
That's the driving force on 6
the -
our side of the fence.
I'm just not going to say 7
one hundred pe-reent right now.
Not knowing what may be 8
on the table that we won't -- that we won't make a 9
change in a commitment that's been made in the past.
10 And it will be wide open for everybody to look at and 11 approve, if that's the case.
12 MR. TRAMMELL:
Thank you for the response.
That's 13 the reason I asked the question.
And I certainly agree w.-
14 wit'h grading the seriousness of the things that you 15 find.
16 MR. BECK:
We have to.
17 MR. TRAMMELL:
And I mentioned that yestercay.
Ano 18 I gather from your response that any or all of these i
19 could lead to corrected action and all to be evaluated?
20 MR. SECK:
Yes, sir.
21 MR. CALV0:
All I want to say, that if you want to, 22 we like to know the criteria they are covering, going to 23 cover your decisions, wnat you're doina here, your can 24 choice, you want to wait to the end, you want to put at
' ~
25 the beginning.
We will 1cok at it at that time.
T:.a t GODFREY & AMES COURT REPORTING Metro 469-6100, (617) 460-204a
57 1
is your choice.
~..
2 MR. BECK:
I appreciate that, Jose.
And I think
_ s 3
something that I want to get in the record, is that 4
we're not asking, on the basis of our presentation 5
today, for staff to approve or disapprove anything.
6 This is intended as an overview to get give you a 7
good feel for what's going to be coming down, and give 8
us the opportunity for your feedback.
And that's very 9
important that we get that.
And that's the purpose.
10 But in this overview context, many of the comments 11 that have been made certainly have been helpful to me in 12 making sure that our focus in that written documentatien I
13 is appropriate to the concerns the staff is pressing.
u-14 And in every instance, it may not be right now, but 15 week and.a half from now, it will be.
16 But I don't either want to leave the impression 17 that.we're asking, the day after the written 18 documentation is on the table, that-NRC staff give a 19 judgment, yea, nay, it's on the mark or not.
20 I suspect there will be furtner modifications after 21 that point.
And when we get to tne intense e x a.n i n a t i o n 22 of the implementing procedures and the documentation anc 23 the check lists, I dare say there may be furtner 24 question and further change at that point.
25 Suc we're not professing to be one nuncred percen:
GODFREY & AMES COURT REPORTING Metro 469-6100, (617) 460-204c
58 1
pressient of what staff may or may not find acceptable.
Lj 2
I think we're going to have a very high success 3
rate in understanding it as a result of meetings such as 4
we're having today and ones we have had before, and ones 5
that will continue.
6 MR. CALV0:
I just want to say, also, within'the 7
same subject, that what we're trying to do is bring 8
these things to you for consideration.
We are not 9
trying to dictate you in any way, you want to do it.
i 10 But tell you those are the things -- kinds of 11 things we don'.t g'et a warm feeling in your program.
I 12 hope you take it in that kind of a context.
13 MR. BECK:
Absolutely.
We do.
We're structuring
'.']
14 the program.
We think will be sufficient to satisfy 15 ourselves.
It's obviously a program that's going to 16 require, and as our system does require, rigorous 17 regulatory review.
And this is part of it, and we 18 welcome --
19 MR. SHAO:
As Vince said, unless you have very 20 strong justification, the staff is looking for 21 FSAR commitment.
22 MR. BECK:
Yes, sir.
23 MR. NOONAM:
Yes.
As I said, we will not be giving 24 you an approval or disapproval by your program ccday.
'~
25 Ue will giving ourselves to basics 11y provide tnat kind GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2043
a' f
r 59 1
of response witinin 30 days after we receive the m
L.a 2
completed plan.
And'we'll do it that way.
. f' 3
The staff feedback here today is basically to give
^
4 you a feel of areas you need to concentrate, in 5
particular by-de. sign ef fort.
We're looking at that very 6
hard.
I d o n ' t '.th i n k -- I think I want to get on.
I
'7
.think the reporter needs a break.
8 (Whereupon there was a recess.)
9 MR. LEVIN: The next element of the pr.esentation,
/
Y for documen$ation of 10 I'd like to describe our pro _ cess 11 the review in terms of the process and our conclusions.
~
12 And there are various mechanisms t' hat we ha've
~
13 established for that.
t __
14 I might add, for example, Jim Milhoan, that it's 15 very similar to things you have seen bero e, okay, in 16 terms of, you know, how we're going to_ document, you r
17
- know, the evolution, ~~ oth how we approach the procesa, o
18 how we -- where we document a con 61usion.
19 MR. MILHOAN:
Howard, I thinA you 'ougnt to put that 20 in context of what I have seen'before f r.o m the 21 standpcint that I'm from INE. ' !!e ' re 're s pon s ible for tne 22 integrated design and construction program and the 23 independent design verification program., I have not 24 seen anything, previously in Coaancne Peak in ' ti.13 area.
l
' ~
25 MR. LEVIN:
Comanche Peak, yes.
What 'I was GODFREY.& A.'iES CO U RT REPORTIliG Metro 469-6100, ( o l '( ) 460-2046
60 1
referring to is programs we have been responsibility for
_J 2
managing that-that INE has been reponsibility for 3
reviewing before.
4 MR. CHANDLER:
Howard, on the issue of 5
documentation, I'm sure that the message tnat was passed 6
on a number of times to John Beck about frequency of 7
reporting.
And things like that will also be applicacle 8
to your activity here.
9 MR. BECK:
Yes.
10 11 R. LEVIN:
Okay.
Fundamentally, going througn the 11 mechanisms.
The first being check lists.
And the 12 purpose of check lists are to assure the completeness of
- -l 13 due process and the traceability of items reviewed.
14 More specifically, these check lists correlate tne 15 systems design criteria to system design documents.
16 They're used during the system document review to verify 17 commitments are incorporated into the system design.
18 The check lists also documents the methoc of 19 verification used by the reviewer, and summarizes tne 20 adequacy of the design criteria and implementation.
21 Cneck lists also provides a cross reference to 22 calculations ano evaluations performed by tne tniro 23 party.
And the eneck list also cross references to any 24 of tne reports that are generated to the classification g_
' ~
25 system tnat I described earater.
GODFREY 1 AMES COURT REPORTI:!G Metro 469-o100, (317) 460-2045
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61 1
We plan to have the full set of enecx lists s
j 2
available in the August time frame, such that they would l
l 3
be available to look at both the breadth and tne depth 4
of tne investigation in the specific design areas.
And 5
we'll get back tp that in a moment.
But if we could 6
leave that for a moment.
7 There's anotner category.
The results of toe bcres 8
which document the results of specific action plans.
9
!!ow there are segments that may be documented in 10 engineering evaluations, okay.
For example, if a 11 particular action plan is more comprehensive than 12 others, it may require some subordinate documentation t
i 13 that would then get wrapped up, finally, in the results ua 14 report.
15 But fundamentally, we're committing to provide a 16 results report on each and every action plan.
And most 17 importantly, we intend to wrap the results of those 18 individ'ual reports into an overall design adequacy 19 report, which will document the~ overall conclusions of 20 design adequacy of Comanche Peak.
21 At this point I need to note i r. tne aandout, enere 22 are several pages that nave 'oeen folded ever.
I will
'e c
23 getting to those in a few moments.
Tney snoula ce 24 inserted at toe location of tne paperclip in the
~
25 package.
GODFREY u AMES COURT R E P O RTI:!G Metro 469-6100, (617) 460-2043
\\
62 1
So if we go to the slide directly after the folded 2
corner, I will proceed with the presentation.
F r a~n k,
3 could you put up the agenda, so I can show people wnere 4
we are in the program?
5 I have just, completed the overview of var.ious 6
aspects of the program that are relevant to managing of 7
our process.
And what I'm going to get into next are 8
the three functional elements of the program.
9 Starting first with tne methodology for evaluation 10 of external source issues.
I do not plan to go through 11 this busy diagram.in detail.
It's a logic diagran that 12 governs the process for evaluating external source 13 issues.
L -
14 We discussed it in a fair amount of detail in the 15 past in another public meeting.
But what I have done is 16 broken it down into its six major components.
And we 17 will go through them in summary fashicn, starting wita 18 the first, wnich is the identification of issues.
19 And our objective in this phase of the program ia 20 essentially to capture all potential issues from 21 important sources.
'd e have some examples here, anc we 22 discussed them at the beGinning of cne presentation.
23 This process will include a' review of 24 documentaticn, an attempt to qualify taese potentia _
,-__,i
' ~
25 lasues, and identify issues that require furtner revieu.
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63 1
MR. CHANDLER:
Howard, very quickly, for those of
_d 2
us who didn't have the benefit of any earlier meeting on 3
this, the initials in the boxes, CD and E,
refer to 4
what?
.5 MR. LEVIN:
Yes.
They just refer to continuation, 6
~ match points, or continuation down into another location 7
in the logic.
8 MR. CHANDLER:
Okay.
9 MR. MARINOS:
Where is CD, E?
Where are you?
10 MR. CALV0:
You discussed before?
This is the 11 first time I -- I'm sorry.
You say that I mentioned 12 this to you.
You had discussed this previously with tne l
13 NRC.
That's what you're saying?
t J 14
$R. LEVIN:
Yes, this was at a meeting on toe 15 site --
16 MR. NOONAN:
Yeah.
There was the meeting we had in 17 February, March time frame.
I can't remember exactly 18 what week time it was, but the staff refers to taese as 19 the Howard charts.
9 20 MR. CALV0:
The what?
21 M3. LEVIN:
The Howard charts.
Basec upcn taat 22 earlier reaction, we are dissecting this b_cck by l
23 block.
And we'll go on to the next block.
24 MR. CALV0:
You will tell us about it?
25 MR. TRAMMELL:
I'll tell you about it.
GODFREY e AMES COURT REPORT ;;G Metro 469-6100, -(o17) 460-204u
1 64 1
MR. LEVIN:
I think the diagram indicates the rigor j
2 of the processes required and the complexity.
The next 3
stage, having identified issues, having captured triem 4
from all sources, we're -- next step is define tnem.
5 And what we're trying to do is identify the potentially 6
affected scope and hardware and group issues.
And this 7
is being done such that it will lead into the 8
development of action plans and to det' ermine juat how to 9
structure the response of it.
10 MR. MARINOS:
Howard, you have a special group of 11 people that will be doing all these things?
How are 12 you -- the organization that you identified earlier will t
13 be the ones that sit down and identify the issues and L.-
14 define them, or you have a special group that will do 15 that?
16 MR. LEVIN:
That is correct.
17 MR. MARINOS:
What?
~8 MR. LEVIN:
Unich?
The responsibility for 1
19 coordinating that effort is with Ec Blackucod and the 20 generic implications.
And, if you will, he is our issue 21 manager.
It's his responsibility to capture them, track 22 them.
I guess you might say he is the guy with tne 23 responsioility for making sure every issue is in a 24 ncpper, and that there are no loose ends, anu somethin,,
25 doesn't fall through tne cracks.
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MR. MARINOS:
By definition, you will define tne
- J 2
issues also?
)
3 MR. LEVIN:
No, the technical issues will define 4
the issues.
It has responsibility.
We need to have 5
some central point of coordination.
For example, going 6
through all the source documents, as there will be 7
spreadings and outputs and doing that in a systematic 8
way.
It just happens that's where.it resides in-the 9
program.
10 MR. MARINOS:
Okay.
And t'he definition will
'o e 11 done by experts?
12 MR. LEVIN:
Technical, in their specific
~13 disciplines, tnat's correct.
u -
14 MR. MARINOS:
The people that you have in table, 15 that you show us before?-
16 MR. LEVIN:
That's correct, yes.
Okay.
17 Now I guess at the process of identification, in 1d may include, to try to get these things into taese 19 various groups, a degree of evaluation, possi'oly 20 walkdowns, it tnere may come a point where rl;nt at 21 that stage, it's judgea enat some direct corrective 22 action is needed as opposed to an investigation or 23 exploratory type effort, waien is o f t en t i:ae s ine_ueed in 24 action plans to try to, you know, qualify ne t
25 significance of issues or coundaries of issues.
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The next step is very straightforward naving the j
2 issues grouped.
You need to define initiatives.
Tnere 3
is a typo there.
The logic for implementing the plan 4
and also the responsibility.
5 At this stage, even at this early stage, potential 6
root -- having gone through the issues, defined them, 7
potential root causes are apothesized, if you will.
Ana 8
it's the activities that are such of the implementation 9
of,the action plan that these hypotheses are qualified, 10 either rejected, or there may be further exploration.
11 But that really drives the nature of the initiatives.
12 Okay.
Some idea as to what the problem may be.
i 13 MR. CALV0:
Is the construction adequacy plan also t.J 14 has something similar to this?
'd a s that thing -- cr 15 this is something -- maybe John Beck.
16 MR. HANSEL:
John Hansel, CPRT.
We basically 3o 17 through the same type of logic flow, same thought 18 process.
19 MR. LEVIN:
I might add, Jose, tnat this process 20 applies to external source issues.
And in tnat r e.; a r d,
21 we applied virtually the same process as our deveicpment i
22 action plans in the TRT.
Essentially identical.
23 MR. MARINOS:
S'o you will develop your action u an 24 after you, as you say, you m al: e some assessmer.: nou, ;ne 6__,i L
25 significance hypotheses of what is s :; n i f : c a n t, or to ce GODFREY & AMES~ COURT H E ? O c:T U :G Metro 409-6100, (317) 460-20u5
67 1
carried out or left out?
2 MR. LEVIN:
This really'isn't an assessment of 3
significance as much as an identification of issues that 4
have potential significance, issues that require further 5
investigation.
That's what occurs at that st. age.
6 MR. MARINOS:
And when you make that decision then, 7
you will develop the action plan to address the ones 8
that you have put in one category --
9 MR. LEVIN:
And that's the reasonably low 10 threshold.
It gets in that box fairly easily.
11 MR. MARINOS:
And at this stage we will have an 12 opportunity to comment and look at your decisions 13 before you develop the action plan, or what is your plan u -
14 in that regard?
15 MR. LEVIN:
I guess, you know, there is an 16 opportunity to see it before.
But it's my understanding 17 that you will see it at the action plan stage.
And the 18 action plan will address the issues and the process that 19 led to develop identification of those initiatives.
So 20 you would be able to see that in the action plan.
21 MR. CALV0:
Review the mechanism to do this?
22 MR. LEVIN:
Yes.
23 MR. MARINOS:
So assuming this agrees with your 24 categorization, is your action plan will be 25 compr'ehensive and broad enough to include other things GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
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68 1
that we may convince you you should have been included, 2
or would require restructuring your action plan to meet 3
this need?
4 MR. LEVIN:
It could be either.
But I --
5 MR. MARINOS:
I'm trying to save you time.
6 MR. LEVIN:
The process is flexible enough that it 7
can accommodate that.
They're not cast in concrete.
8 And these action plans aren't.
Notwithstanding your 9
involvement in the -- in overview, you know, reviewing 10 our process.
The nature of the program itself is that 11 way.
It's a series of decisions that are made that lead 12 to restructuring in the plant continuously.
It's a 13 dynamic process.
As you learn something, go off in a u _
I 14 different direction.
15 The implementation is straightforward.
16 Fundamentally, what we're after there is determined in 17 the E-4 corrective action.
Essentially in that phase, 18 we will execute our action plan tasks.
At the same time 19 determine the root cause and generic implications.
20 And the corrective action phase will determine 21 specific corrective actions that may be required.
In 22 terms of the process for deviations, for example, with 23 safety significance, the deviation would be corrected, 24 either most typically with a hardware modification.
' ~
25 However, for deviations without safety GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
69 1
significance, the resolution of that could involve 2
either. hardware modifications or changes in 3
documentation.
Or both.
4 As I have mentioned earlier, the last -- we plan 5
to document the results of our process and our 6
conclusions.
And I described the forms of that 7
documentation that will take place.
8 MR. MOLLONSON:
Excuse me, Howard.
I'm Jim 9
Hollonson.
May we go back to corrective action for a 10 minute?
Within the design process you say corrective 11 actio'n.
Corrective action method and design crosses are 12 by, for example, modification -- design deviation 13 reports, design change authorizations in some other form 14 of documentation.
15 Is it proposed that the corrective action will be 16 kept within the constraints of the engineering 17 department,,or is the corrective action proposed to be 18 accomplished under the site QA system?
19 MR. LEVIN:
Site QA.
20 MR. MOLLONSON:
Under site QA7 21 MR. LEVIN:
Yes.
22 MR. MOLLONSON:
Thank you.
23 MR. NOONAN:
I'm not sure I understand that, 24 Howard.
Would you please explain that a little bit?
25 Elaborate a little bit more?
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MR. LEVIN:
Well, essentially the project has 2
responsibility for implementing corrective action.
And 3
site quality people ultimately have the responsibility l
4 for insuring that it's carried out.
i 5
MR. CALVO:. The same thing we discussed yesterday, i
6 MR. NOONAN:
That's why I'm asking.
7 MR. CALV0:
They find something wrong with the 8
construction adequacy review, the same quality review, 9
they give it to the project.
The project will use their 10 own'QA/QC, assisting QA/QC.
And we brought the 11 question, will you please consider the fact that it has 4
12 challenged to your program?
i 13 And you say, you are going to look at it.
And then t J 14 determine whether you're willing to proceed at your own 15 risk or whether you're going to correct it.
16 MR. NOONAN:
I guess my question is a little bit 17 different than it was yesterday.
And what I'm looking 18 at more is your interface with site QA in these 19 corrective action processes, the interface between your 20 group.
You just give it to them and they go back and 21 correct it?
22
.MR. LEVIN:
Yeah.
Basically my interface, the most 23 direct interface, is through John deck.
And he serves 24 as a -- I will raise the issue up to the SRT, who is d
25 overseeing review team leaders' activities.
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And John has met both in the capacity as a member 2
of CPRT and involved in the TUGC0 management chain and 3
will forward it, incorporate it into the TUGC0 4
organization.
5 MR. BECK:
This will be a documented transfer of 6
problem.
Recommendation for resolution, or what will be 7
adequate to resolve it in the eyes of third party.
And 8
it's up to the TUGC0 project to implement that 9
correction, whatever it may be, whether it's a change in 10 design, modification of hardware, whatever the 11 correction process is.
And it' falls under our 12 QA/QC program by regulation.
.'.. J 13 MR. NOONAN:
Okay.
14 MR. MOLLONSON:
Can we have a very simple 15 explanation of that, modification to support, the two 16 people that determined it necessary from a design 17 standpoint?
There will be a deficiency report, 18 nonconformance report, evolved from your review, or your 19 results of your review, and QA would then implement the 20 corrective action?
21 MR. BECK:
QA doesn't implement corrective action.
22 Within our program -- and you are proper and correct in 23 saying that NCR
's will be generated for deficiencies 24 that come out of this program or any other source.
~
25 MR. LEVIN: The project will have -- will be j
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72 1
delivered, our report, like, for example, a deficiency
,_j 2
report that is generated within the design adequacy
~
3 program.
4 MR. MOLLONSON:
Even in the design adequacy program 5
a result in QA forcing the issue for corrective action.
6 MR. LEVIN:
That's correct.
7 MR. MOLLONSON:
Okay.
Thank you.
That's site QA7 8
MR. BECK:
Yes, sir.
i 9
MR. CALVO:
Can we some way correlate the way the 10 quality -- I mean the construction adequacy review is 11 going to do -- let's look at the TRT team action plans.
12 What is the role of the QA/QC7 Let's say in the 13 electrical specific issue action plan?
The QA/QC third L_
14 party is what you use to implement the plan.
15 What kind.of support it provide to the TRT 16 electrical group, the QA/QC group to do, actually, is 17 verify that it has been done correctly?
Can you --
18 MR. LEVIN:
The answer is yes.
But John Hansel can 19 answer it much better than I.
20 MR. HANSEL:
Martin Jones was the issue coordinator 21 for the electrical issues.
And Martin Jones defined 22 what he wanted to be done in terms of investigation or 23 inspections.
l,_ _,
24 When it got down to the inspection, he came to see 1
{'~
25 us.
We worked with him to develop the inspection check GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
73 1
list that_would satisfy his requirements.
We trained
- _J 2
the inspectors.
We went and conducted the inspections, 3
.and then provided him with a report on those 4
inspections.
And then from that data plus the other 5
data he has derived, he's drawing conclusions.
6 MR. CALVO:
And the QA/QC or that particular 7
inspection was governed by your own QA/QC7 Developed by 8
you?
9 MR. HANSEL:
Exactly.
10 MR. CALV0:
How do you do that?
When you go to the 11 walkdowns adequacy review, hcw do you accomplish?
Are 12 you going to call upon somebody like John Hansel to help 13 you with the assessing of these as built configurations?
u -
14 MR. LEVIN:
If there is a need for--
15 MR. CALV0:
How do you do.it?
16 M3. LEVIN:
Okay.
17 MR. CALV0:
You develop a plan for the walkdown --
18 MR. LEVIN:
That's right.
19 MR. CALV0:
-- and then you know what to do now.
l 20 Somebody have inspect it now?
Who is going to do that?
21 MR. LEVIN:
If there is a requirement for a 22 QC inspection, I ask John to do it.
23 HR. CALV0:
If it's a requirement to verify the 24 design, this is the next step, you're going to go
_ _7 25 walkdown, you selected a system --
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74 1
MR. LEVIN:
It depends on the nature, Jose.
I 2
think we kind of got to this a little bit earlier.
If 3
you're trying to qualify an aspect of design that's 4
related to construction qualities.
I used the example 5
of well sites.
I will ask John to do those 6
inspections.
Okay.
7 If it's to make judgments as to something like 8
seismic two over one, okay, I will have design engineers 9
walking down the plant to procedures, doing that 10 activity.
And they're --
11 MR. CALVO:
So you're going to come up with your 12 own QA/QC program procedures to reflect that kind of the l
13 judgment you expect from the engineers?
uJ 14 MR. LEVIN:
Yes, there will be procedures.
15 Definitely.
16 MR. CALV0:
So you can go -- you have got two 17 forks.
One going to him worrying about QA/QC aspect.
18 And then you have got.our own program doing that.
i 19 MR. LEVIN:
For design, that's correct.
20 MR. CALV0:
And the results of those inspections, 21 in both cases, you have got corrective actions.
You go 22 back to the CPRT, and you go back and you forward this 23 to the project.
24 MR. BECK:
Go through the established procedures,
' ~
25 NCR's be generated, and it will go into the corrective GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
l 75 1
mode.
J 2
MR. CALVO:
Okay.
So if I can understand when John 3
-- when the inspection, John does, and goes to you and 4
forward it to the project.
You use the project QA/QC.
5 But what' kind of QA/QC do you use when Howard Levin 6
sends you something that it was predicated on that 7
judgment, that he's looking into the design?
How are 8
you going to implement that one?
That was a judgment.
9 How -- what kind of QA/QC do you use that one?
10 MR. BECK:
That would be executed within the TUGC0 11 QA/QC program, appropriately dealt with.
12 MR. CALV0:
So that type of program deals with the,
,{
13 program.
14 MR. BECK:
Yes, sir.
Wherever the source may be; 15 whatever the source may be.
16 MR. CHANDLER:
John, the point of corrective action 17 for a moment.
Something gets funneled back to the 18 project with a recommendation for corrective action.
Is 19 there any discretion left with the project to decide l
l 20 whether corrective action will in fact be taken?
You l
21 mentioned it -- does everything then go into an NCR that 22 must be resolved?
23 MR. BECK:
Yes.
24 MR. CHANDLER:
So no identified need for correction 25 action will go -- will subsequently be determined to be i
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76 1
unnecessary by the project?
_j 2
MR. BECK:
That's a possibility.
It could be used 3
as is.'
If that's the case, that will have to be 4
documented and justified to the satisfaction of the 5
system.
6 MR. CHANDLER:
The judgment on use as is, is whose 7
judgment now?
8 MR. BECK:
Project's.
He will have to be satisfied 9
that that resolves the issue.
10 MR. CHANDLER:
All right.
11 MR. BECK:
If he's not, there's an issue still 12 outstanding.
{j 13 MR. CALV0:
I don't know too much about QA/QC, so 14 help me with this one.
The problem that we had, the NRC 15 has reviewed it, was construction QA/QC, Now all of 16 this, it's another program that is designed QA/QC.
We 17 can never review that program.
Well, we can never 18 address that particular program'QA/QC for the design; 19 right?
20 MR. TRAMMELL:
Yes, it was reviewed in the FSAR.
21 MR. CALV0:
All right.
22 MR. LEVIN:
I think that --
23 MR. CALV0:
He tells me it had been reviewed in the 24 FSAR.
That's all right.
t
'25 MR. LEVIN:
We can forget -- all right.
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MR. MARINOS:
Howard, I think your explanation to 2
my question, and I'm going to restate it, you know, my 3
understanding, when I asked about design process, I got 4
the message that N-45-211 will be your guideline to 5
establish the design process as correct, as you, at the 6
same time, reaffirming the design of the quality of the 7
design; is that correct?
8 MR. LEVIN:
Yes.
9 MR. MARINOS:
And that will be your tool of QA, so 10 to speak?
11 MR. LEVIN:
Right.
About to get into that 12 discussion.
Good timing.
13 But before I get into that, I wanted to identify i'-
14 several of the external issues that will be discussed 15 in the third segment of our program.
And that goes 16 along discipline lines.
17 But as many of you are aware, for example, in the 18 civil structural area, this has been identified in the 19 cable tray conduits supports area.
That's an external 20 issue that falls under that coordinator's 21
'-responsibility.
22 There were several issues that were raised by the 23 independent assessment program in the mechanical 24 systems, electrical systems area.
Those issues are also 25 being addressed.
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In the piping and supports area, the issues 2
identify there.
But in the ASLB, as well as the
_ a 3
assessment program, all fall into this general category.
4 MR. SHAO:
About valves.
Are you going to talk 5
about valves?
6 MR. LEVIN:
- Yes, In another broad category within 7
the external issues, however, are TRT design related 8
issues.
These are issues that evolved out of the TRT 9
investigation that had some design relevance.
And for 10 purposes of creating an umbrella over all issues that 11 have design implications, they are programmatically 12 being considered herein, so that we can form an i
13 integrated saaessment of significance of all issues.
L J 14 Examples, we include, for example, 5arry in the 15 piping area, item Sc.
You know, the pipe between 16 buildings and the piping isolation type issues?
17 We can move on.
We can get into -- yeah, we're now 18 back to the folded pages.
We get into the second 19 functional element of the program.
That is the 20 self-initiated evaluation.
21 The purpose of self-initiated evalu'ation is to 22 verify that design related issues identified by the 23 various external sources do not exist in the same or 24 similar form elsewhere.
~ ~
25 It's intended that this evaluation would compliment GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048 i
79 1
the scope of activities that I just completed a 2
description, in that together, the external issues 3
evaluation with the self-initiated evaluation, will 4
basically give us complete coverage of all the design 5
disciplines, areas, design activities, and processes.
6 Okay.
And I will be getting -- the next part of my 7
presentation will specifically address how we're going 8
to accomplish that.
9 We have in our determination, as scope for the 10 self-initiated effort, divided into this four distinct 11 phases.
First two phases are associated with our 12 initial determination and scope, which will be described 13 today.
And there are two additional phases that are u._
14 associated with our final determination.
15 Phase one --
16 MR. MILHOAN:
Excuse me, Howard.
On the previous 17 slide -- Jim Milhoan.
The previous slide, correct me if 18 I am wrong, issues do not have to be necessarily limited 19 to those identified by the external sources, your first 20 bullet, to be included in the self-initiated program?
21 MR. LEVIN:
In fact, those issues are not in the 22 program, Jim, in the self-initiated program.
23 Specifically the self-initiated program starts without 24 any prior knowledge of any issue.
Okay.
25 If you will, it's a test of another area where, GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
80 1
typically, where issues are currently unidentified.
2 MR. MILHOAN:
That was my impression.
But reading 3
the slide alone does not give me that assurance.
4 MR. LEVIN:
Okay.
I was attempting to do that in 5
the second slide, but I hope my comments clarify that.
6 In phase one, we have taken a step back and 7
evaluated industry and NRC design verification type 8
programs, such as IDVP's and IDI's.
And we have taken a 9
look at the areas these programs have addressed and 10 basically --
11 MR.- MARINOS:
You will identify which ones you are 12 assessing or using --
13 MR. LEVIN:
Well, basically what we have done, L..J 14 Angelos, is from the union of everything that IDVP's 15 have looked and IDI have looked at, we developed the 16 list of areas that have been addressed.
17 And then what we did is, we develop a profile of 18 our initial scope in the design adequacy program against 19 that list.
Okay.
It's to determine, just in a general 20 sense, okay, did we have the breadth and depth of those 21 types of evaluations.
What we also took a look at was 22 the findings that came out that.
23 Now we not only compared our initial scope, but we 24 also compared the scope of previous evaluations on the i6 25 Comanche Peak Project.
So what we took a look at was l
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81 1
the CYGNA Independent SESNA Program, NRC activities, and 2
all those activities that generally fall into the design 3
verification type box, and looked at what they covered.
4 And basically what we confirmed is, is that, 5
through the combination of those efforts and this 6
effort, that the initial scope of the self-initiated 7
review, that in fact, we had pretty good coverage of all 4
8 those design areas.
It turns out that the coverage in 9
that evaluation -- we determined that the coverage even 10 went beyond that.
11 MR. SHAO:
I have one question.
I don't know i
12 whether it's called external source or self-initiated j
13 action.
Let me give an example.
Suppose I don't see a i
14 deficiency.
Wel'1, that deficiency was created by 15 certain design relation, certain group, certain company.
l 16 And the same group of people now working on this 17 particular area, you found deficiency, but they made the 18
-- also they're in charge of other conformance or 19 structures, how they handle this situation?
20 MR. LEVIN:
Okay.
By the end of -- I'm going to 21 get to that.
By the end of phase three of this scope 22 determination, you will be able to ask me the question.
23 Okay.
24 You may address, "What have you found in the 25 particular design area?"
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82 i
1 And I will be able to tell.you either that we have 2
directly evaluated that area, or that it has been 3
enveloped by some other evaluation, i.e.,
we have tested 4
that area by some other means, such that we have 5
complete coverage of specific design areas and 6
activities.
7 MR. SHAO:
Are not design area and design 8
organizations?
9 MR. LEVIN:
Yes, that's true.
I will be getting to 10 that in a moment.
And I hope you will get a better idea 11 of what that is.
12 Mt. CHANDLER:
Howard, you were asked a minute ago 13 whether you would be identifying those presumably L -
14 enternal IDVP type of activities that you looked at in 15 assuring the adequacy of your scope.
16 MR. LEVIN:
That's the initial scope.
17 MR. CHANDLER:
Right.
And you answered by 18 referring to basically NRC internal activities and 19 Comanche Peak related activities.
Did you look at other 20 IDVP's performed in the industry, which is what I think 21 you're saying here?
22 MR. LEVIN:
Yes.
We have looked at both together.
1 23 MR. CHANDLER:
And will you be identifying those i
24 that you looked at?
,--,I
' ~
25 MR. LEVIN:
Tes.
I can tell you that, in terms of GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048 r
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IDI's, we reviewed the Callaway, the sembrook, the 2
Byron and Harris IDI's, okay.
3 And in terms of IDVP's, we took a look principally 4
at Midland and Diablo, because those were the most 5
robust programs in the industry.
And it was through 6
looking at the activities in those six individual plant 7
investigations that we developed a -- an integrated set 8
of what is the yardstick, ao to speak, the biggest 9
yardstick that has been applied.
10 And it was to that that we compared the past 11 activities, as well as our initial scope.
And the 12 reason is simply to see, do we have a reasonable point 13 of departure for setting started.
And I will describe t
14 next how we're going to confirm that our final point is 15 correct, ekay?
16 MR. CHANDLER:
Okay.
17 MR. LEVIN:
And next we -- phase two.
We have i
18 selected two systems that concentrate our activities.
19 Actually it's -- some may interpret it to be broader 20 than two systems, but essentially it was the -- we're 21 going to take a cut through the AFW system, mechanical i
22 system, as well as the total scope of Class IE, on site 23 electrical system, okay.
24 And that's, as you are all aware, includes quite a 25 rew systems.
But essentially we're covering the full GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
84 1
scope of electrical power on the site, as well as the 2
I&C consideration is back into the AFW system.
a 3
MR. MARINOS:
This phase two doesn't reflect --
4 this is more general.
Yau just adding --
5 MR. LEVIN:
No, what I have done, Angelos, is to 6
try to develop a profile of those systems versus other 7
safety related systems in the site, so that we can 8
insure that, in fact, they are fairly good tests of the 9
safety related design effort of the site -- on the i
10 project, as compared to other systems.
11 MR. SHAO:
Well, when you say, " systems', are they
]
12 including any buildings?
{}
13 MR. LEVIN:
This effort is related to systems.
14 We'll get to how we treat buildings later.
This was, 15 you know, it turns out that buildings are somewhat 16 unique, and most of them are safety related, with the 17 exception of one.
18 MR. SHAO:
When you cut to the system, does that 19 include all the organizations that can be involved in 20 the plant?
21 MR. LEVIN:
Yes.
And basically what we did, we l
22 developed categories of attributes in the comparison of 23 these systems.
We took a look at the applicable general 24 design criteria, the design organizations, the design
'~
25 disciplines, the design interfaces, system functions, 1
i i
GODFREY & AMES COURT REPORTING j
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applicable operating modes, type of hardware involved, 2
type of calculations performed, and the applicable 3
design procedures.
4 Now at this stage, the comparison is being done at 5
the area, design area level.
In a moment, I'm going to 6
describe an even more intense activity that occurs at 7
the activity level or process level, an area being, 8
let's say, area concrete design.
9 Okay.
Phase 3.
We even cut it even finer.
But to we're looking at a subset of that.
To be sure that you 11 can create a thread and answer the question you just 12 asked, to get down to smaller homogenous units like, not 13 people, but organizations or groups, what percentage 14 were they found?
15 MR. SHAO:
Concrete may be found designed by many 16 organizations.
17 MR. LEVIN:
That's correct.
18 MR. SHAO:
Maybe one organization and other 19 organization --
20 MR. LEVIN:
What we're seeking in phase 3 is to get 21 the lowest common denominator, the smallest homogenous 22 block, and say that we have tested that in some way, 23 either directly, or have enveloped it to some other 24 path.
25 MR. MARINOS:
Howard, have you covered, or should I GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
86 1
wait, to discuss the basis of your select. ion?
Or is it j
2 I don't want to steal your show 3
MR. LEVIN:
We will be getting to that.
And if you i
4 have any questions, I will be glad to answer them.
5 MR. MILHOAN:
Howard, similar question.
Once you 6
have selected these systems, named the systems, maybe 1
7 you will address it later on, is how will you maintain 1
8 the confidence that these systems that you selected are 9
still representative of the design process?
I 10 In oth'er words, that calculations have not gone in, j
11 or special reviews have not gone in to look at these 12 systems that you selected.
l l
1 l
13 MR. LEVIN:
Okay.
I think there maybe two aspects t J 14 to your question.
Number one, we already are aware, as j
15 you can well imagine, it's very, very difficult to 16 select a system that can cover every aspect of the J
17 design.
18 And we're trying to do that.
And there will be 19 selected areas that fall out of this evaluation process, 20 that may not fall within the boundaries of these J
21 systems, that will be added to the scope.
And that will 22 occur principally in phase 3, which I'll get to in a 23 moment.
Does that --
24 MR. MILHOAN:
That does not answer the question.
__q 25 MR. LEVIN:
I'm sorry.
Oh, the -- okay.
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We have established a cutoff in time th t we're i_j 2
essentially -- we have frozen what we're~. going to look 1
3 at.
And essentially, that's the point in time that we 4
in the CPRT recommended to the review team, my_ team, 5
made a recommendatien to the SRT that we felt these were 6
pretty good systems to consider.
And that's 7
approximately the April 1st time frame.
8 So therefore, we will not be taking a look at 9
design effort, you know, for calculation was done after 10 that point in time.
We will not be looking at that.
We 11 vant to look at before the point it was frozen.
12
'MR. MILHOAN:
Okay.
Thank you.
13 MR. TRAMMELL:
Howard, just a question on testing.
u..
14 I know this isn't exactly what you're talking about i
15 here, but this plant is largely constructed, if not 16 totally constructed.
And it's been tested to quite an 17 extent.
18 AndIwonderifyouebuld address now or later to 19 what extent the testing that has gone on, would help you 20 cut across some of these design boundaries?
21 For example, component cooling is a nightmare of 22 pipes that go to maybe 80 different heat exchangers.
i 23 And I would hate to see you spena your time verifying, 24 say, the flowing of each one of these legs with design 4
25 calculation, when, for example, the startup test on that GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
- - ~ _ _
T 88 1
system might have been totally successful, that would be i _. I 2
a waste of your time.
3 At the same time, I would hate to see you go 4
through and do a design verification on a system, and 5
declare it totally healthy, when the test results were 6
unfavorable.
I mean you have got to consider that.
7 It's like Stone and Webster is doing some reanalysis of 8
piping.
I hate to see,them reanalyze the piping, only 9
to find out in the field the as built are not what the 10 design called for to begin with.
11 So we would address at some point to what extent 12 the testing program going on can help you with this I
13 design process, and at the same time provide a benchmark iLJ 14 for your conclusion.
Maybe not now.
Maybe later.
But 15 at some point, I think it can help you, and might add 16 some credibility to your results.
17 MR. LEVIN:
Okay.
I think there are several good 18 examples of that.
And possibly in our discussion, the 19 electrical area would be a good one, Charlie.
I 20 certainly agree with your -- what you're suggesting.
21 And at this point, I might suffice to say that that 22 information, that testing information that's available, 23 certainly would be used to reconcile things.
24 And, you know, we're using any piece of information
' ~
25 we can get to direct this effort.
We want to get the GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
89 1
biggest benefit for our activity.
2 And to the extent that that can assist, it's 3
certainly going to be considered.
4 MR. NOONAN:
Just me s a note of it now and u
5 consider it, because that's something I think would be 6
valuable to you in terms of cutting across some of these 7
design lines, and at the same time helping us in seeing 8
a brief assessment of how the tests went, and to what 9
extent it confirmed your conclusions.
It would help us.
10 MR. CALVO:
I think it would be helpful to add what 11 is a -- what -- all Charlie is saying here, will be just 12 another element that is going to help at the end to l
13 prove the reasonable assurance.
m.J 14 And what he's saying, don't discard, because it can 15 be very important, especially in those areas that you 16 indicated yesterday.
17 Your sampling program, you have no access to it.
18 You're going to select another one.
It could be those 19 you can rationalize.
We had some preoperational testing l
20 we can do.
We got normal operation.
l 21 Others, we have got some tech specs that govern 22 that equipment.
So you can use that as an element, will I
23 govern in overall reasonable assurance.
24 MR. MARINOS:
One more question.
You have decided 25 on the cutoff date already for that system.
Can you GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
90 1
tell me that date?
Is it before or after the PRA was
.j 2
submitted and evaluated by the staff on the maile l
3 field water system.
4 MR. BECK:
I'm sorry.
What PRA are you referring 5
to?
6 MR. MARINOS:
You have submitted a PRA on the 7
maile field water system on 1980 -- I'm not certain of 8
the date that -- and that PRA may have resulted in some 9
redesign.
I am not certain about the real 10 facts.
And I was asking with regard to the cutoff 11 date in evaluating the design, whether that would 12 include or exclude that PRA result.
13 MR. BECK:
The cutoff date Howard referred to is L.
14 April 1,
1985, and that --
15 MR. MADDEN:
That reliability analysis was done 16 several years ago.
17 MR. BECK:
That's Fred Madden, TUGCO.
18 MR. CALV0:
I guess the question we have, when you 19 did that reliability analysis for the feed water system, 20 you can come out with some kind of implications that may 21 reflect it back on how the design was being done.
22 And those implications, the design was corrected.
23 The reason behind ite that was done, you had selected a 24 system pretty much going to look all right because of 25 the PRA indicated.
GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
91 1
So you want to know whether you found out about the
)
2 PRA, that thing reflected back into the design.
And you 3
made those corrections, or didn't do nothing to the i
4 design?
That's what I want to do.
j 5
MR. MADDEN:. Fred Madden, TUGCO project.
The 4
6 reliability analysis is a simplified reliability f
7 analysis which was done in accordance with the 8
guidelines.
And the FSAR did not result in any system i
9 guidelines.
It was used as a yardstick to compare the 10 reliability of the comanche Peak feed water system 11 against other systems.
l 12 MR. CALVO:
Was that because of the TMA?
Does the l'
13 sample -- reliability to demonstrate the --
- e-14 MR. MADDEN
Yes.
15 MR. CALVO:
You mean check the result of what he 16 found out, and the impact and how the design, or -- for 17 maybe that was not -- maybe somebody did something to 18 it.
19 MR. LEVIN: You want to be sure you're testing.
20 MR. CALVO:- Nice and clean.
And all the 21 information that you hope to obtain is right on that t
22 system.
4 23 MR. LEVIN: I understand your objective.
24 Could we move on to phase 3 in the phase 3
__q 25 evaluation?
We will assure that the scope of the t
)
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92 1
self-initiated view is adequate and broad there, as I
_j 2
mentioned earlier, is a more detailed evaluation than 3
conducted in phase 2 to assure that all the activities 4
will be directly sampled, or that the activity is 5
sufficiently similar to that already sampled, and is 6
reprasentative.
This effectively assures that all 7
homogenous design activities are covered to assure 8
cos.plete coverage of design activities.
9 These will be correlated with safety related 10 structures systems and components at Comanche Peak.
So 11 at the conclusion of phase 3, we will have confirmed or enlarged, which is -- there are some areas that we 12 i
13 believe -- for example, the ma'in steam isolation valve, LJ 14 for example, is a critical valve.
But is not within the 15 boundaries of this system, that we are considering 16 adding to scope for that reason, that you just didn't 17 get coverage.
18 And in similar situations, like that would come out 19 of this activity, and would possibly be to 20 supplementation of the scope.
But we will have 21 determined the coverage.
But at the same time, we will 22 also have to find the minimum depth, and that warrants, 23 of our program, and that warrants some explanation.
24 We intend at the conclusion of phase 3, which is
' ~
25 targeted approximately the August time frame, that in l
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93 1
addition to having this evaluation, you know, down to 2
the activity level complete, we would also have 3
available our check list, which would really define, in 4
many respects, define the depth of the investigation 5
available.
So that, at that time, notwithstanding, 6
findings that may evolve later, I, you know, you 7
essentially defined the minimum scope.
That scope may 8
increase even further, because of where findings have 9
led you.
And that's how we get to phase 4.
10 Phase 4 is really the final scope determination.
11 MR. BOSNAK:
Howard, before you go on.
How would 12 you -- are you going to cover, how you would extrapolate 13 to other systems?
Is this in your minimum guidelines 14 that you would have had?
Is that what you mean my 15 extrapolation?
16 MR. LEVIN:
Yes.
17 MR. BOSNAK:
You will have a set of guidelines, 18 then, that --
19 MR. LEVIN:
This will justify it.
It gets back to 20 the question that imposed to Larry, that he could ask me 21 a question, and I would be, you know, "Did you cover 22 this," or, "How did you evaluate that?"
23 And I would be able to say, I did directly, or I 24 could show him the road map to why I could extrapolate
~
25 to that.
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94 1
MR. BOSNAK:.
The same design organization, for 2
instance, in other things that would make it similar.
3 MR. LEVIN:
Controlled by the same process, the 4
same organization did it, the same -- yeah.
5 MR. CHANDLER:
How would you pick up the interface 6
issue in this one?
7 MR. LEVIN:
Similar interfaces would be another 8
attribute that would be considered.
For example --
9 MR. CHANDLER:
But when you -- you're not 10 necessarily -- when you say AE design scope, that would 11 pick up all associated interfaces, I presume?
12 Excuse me.
It wasn't a response to your answer.
5
-13 MR. CALV0:
Repeat yosr question, Larry.
t.
14 MR. LEVIN:
The answer is yes.
15 MR. CHANDLER:
Okay.
See, that one passed.
16 MR. LEVIN:
The final determination is as 17 important, I guess, is a derivative where all design 18 verification processes should lead you.
And in effect 19 what occurs there is that we take a step back, we look 20 at the specific root causes that have been identified, 21 the generic implications, the deficiencies that have 22 been identified, and then taking one step back, looked 23 at that collectively, and made a judgment as to, you 24 know, do we need to expand the scope further on the
,-_q 25 basis of whct we found.
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95 l
1 And so that at the completion of phase 4, you will 2
have already confirmed the coverage and breadth.
We 3
will have confirmed the final scope.
Effectively, phase 4
4 occurs at completion of the program.
5 In other words, the scope determination never 6
really ends until it's over.
7 MR. CALV0:
I guess you get to the foundation of 8
your program.
-This is the most important part of the 9
program.
The determination of that scope so you, at the 10 end, come out with reasonable assurance, even though you 11 don't find anything wrong with it.
Enough correlation, 12 therefore, with the depth and the breadth, equivalent to 13 John Hansen talking about the formulation, all those u.._
14 populations there.
That's also equivalent to what he's 15 doing.
That's the two key elements.
16 And all I'm saying, when you submit the program 17 plan to us be sure that you have anchored those things 18 up with good -- with a good basis, good rationales.
19 Because if you failed your test, your program will i
20 collapse.
That goes the same for the construction 21 effort.
So do the best you can on that one, because 22 that will be the point of departure for everybody.
23 So you have been giving us some good works in 24 here.
But still you have got those anchor bolts in 25 there to hold it down, because that -- everything is GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
96 1
depending on those two.
La 2
And be sure that they are level, so you can 3
interface from one to the other.
And I think you're 4
missing some of that in detail.
Okay.
5 MR. MILHOAN:
Howard, with respect to your comment 6
about phase 3.
You gave us an August date.
Would you 7
explain that August date again?
8 MR. LEVIN:
Okay.
That's the time frame that we're 9
targeting completion of this process of correlation down 10 to the activity level, where we will have made a 11 determination of, you know, areas that we may -- scope 12 that may need to be added, okay, to insure that we have l
13 the coverage of.those activities.
L 14 So in addition to the scope that you will hear 15 about today, you may hear items like main steam 16 isolation valves, electrical penetrations, fault current 17 type considerations, that we may have added, because we 18 didn't really feel we had an adequate test in that 19 design activity, i
4 20 MR. MILHOAN:
Does the August time frame now on 21 this determination of scope, does that include the l
22 completion of your independent reviews?
23 MR. LEVIN:
No, not at all.
That is a stage where 24 we have the --
' ~
25 MR. CALV0:
The anchor, the foundation.
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97 1
MR. LEVIN:
It's Jose's anchor.
And also, at that 2
point in time, Jim -- the check list would, the full set 3
would be available such that you could get some insight 4
into the depth of the review as well.
5 MR. MILHOAN:
I know John went through an overall 6
schedule later in the day.
Do you plan going through an 7
overall schedule on your program at the end of this?
8 MR. LEVIN:
Yes.
9 MR. MILHOAN:
Okay.
Thank you.
10 MR. LEVIN:
Okay.
Now we need to go back to the 11 paperclip.
12 MR. NOONAN:
Before you go on.
The -- you say 13 you're going to ta'.k about the scheduling aspects later m -
14 on?
15 MR. LEVIN:
Yes.
16 MR. NOONAN:
I'm looking for a place where-we 17 interface between these -- into this whole thing here.
18 MR. LEVIN:
Okay.
I.believe that, for example, the 19 August time frame is one example where we clearly were 20 going to interface.
There may be others.
But that c
21 seems like a critical junction.
22 MR. NOONAN:
I guess in that respect, John, I will l
23 be talking to you about the overall program plan and 24 MR. BECK:
Yes.
I think it's clear that that's a l
~
25 required interface.
Between now and then we may well l
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98 1
vant to or you may well want to examine.
And I would 2
encourage that.
3 MR. NOONAN:
Okay.
All right.
4 MR. BECK:
That's clearly one.
5 MR. LEVIN:
Okay.
Now after having described, you 6
know, how we're going to address our scope, I would like 7
to address our general approach to self-initiated 8
review.
And as I indicated earlier, the approach 9
parallels that of the ANSI N-45-211 process.
10 And I guess what I would like to do is chara'eterize 11 this review a little bit differently than the external 12 issues review, to the extent that, what we're doing here i
13 is we're starting from the foundation, if you will, in L'J 14 terms of the criteria.
How those criteria were 15 implemented and through that implementation, where they 16 appropriately portrayed on design output, design 17 outputs, such as drawings and specifications.
18 That's a process that I characterize as kind of a 19 broad band filter that marches systematically through 20 the areas that we're looking at, as compared to, in some 21 other cases, some other external sources evaluation, 22 where it's a much more directed type of an 23 investigation, where the problems identified, and you're 24 trying to sort out the boundaries.
' ~
25 What we're trying to do here is take an entirely GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
99 i
1 new untouched area and march to it in a systematic way,
.J 2
and catch a couple of things.
And when you do catch it, 3
we get into that investigation type of phase.
This 4
process will do that.
5 We start off by capturing the design inputs, using 6
N-45-211 terminology in the form of esoteric commitments 7
codes standards.
Anything that govern the design.
8 Then given that, okay, how were these things 9
implemented and utilized, and calculations or 10 engineering evaluations by the project.
- And, 11 ultimately, given those implementing documents, where 12 they probably reflected on drawings and specs such that J
13 we have an assurance that in fact the design criteria 14 were implemented.
15 MR. MILHOAN:
Excuse me, Howard.
On that design 16 analysis portion of your slide, a lot of computer codes 17 are used in design.
What are your plans with respect to 18 the review of computer codes?
19 MR. LEVIN:
We plan to verify in fact, that the 20 codes were -- that there was a -- in fact, the codes 21 were verified, and'take a look at the actions that the 22 project took to verify the use of codes.
But we didn't j
i 23 anticipate completing that verification ourselves.
24 Criteria identification and review.
25 MR. MARINOS:
Howard, can I go back to that design i
l GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
100 l
1 input area?
This leg of review is actually the I
j 2
paperwork, and you will be checking it against the 3
N-45-211 criteria to establish that design process was, 4
you know, was carried out, basically, along the lines of 5
that?
6 At the same time, my understanding is," your actual i
7 reviewers, your reviewers will do independent l
8 calculations in some areas or all areas, to confirm that i
9 the design inputs that have resulted from the process 10 are the right ones that the guys used to arrive at the 11 correct calculations.
Are we doing that?
J 12 MR. LEVIN:
That's exactly correct.
And the I
13 methods will be somewhat multi-faceted in some cases.
t J 14 It may be just a review of a calculation.
It may be an 15 alternate calculation, may be completed.
Essentially, 16 those verification techniques that are described in 17 N-45-211 are within the tools that we will apply in the 4
18 verification process.
19 MR. MARINOS:
The point being that the design 20 process may be very good.
The inputs are brought down 21 correctly, but the wrong ones, and vice versa,' the other 22 guy is doing the calculation wrong so --
23 MR. LEVIN:
Exactly, yes.
1 24 MR. MARINOS:
We're going to confirm those too.
i_,
s
~
25 MR. MILHOAN:
Howard, let me follow up with a GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
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comment on that, or question on that one.
With respect
- J 2
of -- to your performance of independent calculations, 3
the purpose of those, I would assume, would not be to 4
justify the design itself, but to review the design, the 4
5 justification.
If you find something wrong, we'd go 6
back to projects for their input.
7 MR. LEVIN:
That's correct.
And those calculations 8
would not be design basis calculations.
9 MR. MILHOAN:
Thank you.
10 MR. LEVIN:
Okay.
The objectives of the initial 11 phase criteria identification and review would be to 12 determine.the criteria that the design was intended to J
13 meet, okay, and then factor that into our subsequent 14 reviews.
15 Now this doesn't mean to say that we are accepting 16 that carte blanche.
We're going to take a look at that 17 with a critical eye to assess it.
It's complete and 18 also consistent.
The process will be to simply identify 19 these design inputs from a variety of sources such as 20 the FSAR codes and standards, interface criteria that 21 may have been promulgated by Westinghouse, and then note 22 these.
In fact, many of these things will be noted on 23 our check list.
24 MR. SHAO:
What do you mean by Westinghouse
,q
~ "
25 interface criteria?
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102 1
MR. LEVIN:
Okay.
Westinghouse may have a j
2 requirement for balance of -- for example, in the 3
AFW system, may have flows or heat removal requirements, 4
that Gibbs & Hill, for example, was required to meet.
5 And what we will do is, given that requirement, 6
that interface with the interboles, determine whether 7
or-not that was a method.
8 MR. MARINOS:
You then, independently will try to 9
sort of develop a design -- a design description 10 document to evaluate the design.
Or you will use what 11 Gibbs & Hill may have used to confirm that design?
12 MR. LEVIN:
It's really a performance.
We will 13 have effectively have created that kind of a document.
t J 14 And that document will effectively be the check list.
15 The check list will have that kind of information 16 there.
So if you looked at everything on there, you 17 might say that was the criteria spec, so to speak, for 18 the system.
19 MR. MARINOS:
You will not develop a design 20 description document then?
21 MR. LEVIN:
It's not our intent to do that, 22 specifically.
There's certainly analogies to what will 23 be created, and what a document like that typically is.
24 MR. BOSNAK:
Howard, are you going to look for, I 25 might call it, design improvements?
In other words, GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048 i
103 1
things that the original designer did that may have not 2
been optimal?
Could have been done differently?
Not 3
that they didn't meet the criteria, but they could have 4
been improved?
5 For instance, a snubber that was not needed.
6 That's going to be included in your process?
7 MR. LEVIN:
We -- I guess -- the way I generally B
characterize that, Bob, is that -- I think that into a 9
category of practice as opposed -- for example, there 10
~ could be a snubber that's not needed.
And with or 11 without the snubber, you know, the commitments codes and 12 requirements could be met, but it's not a good practice I
13 to have that in there.
J m
14 MR. BOSNAK:
That's what I'm talking about, good 15 practice.
16 MR. LEVIN: We will identify good as well as bad 17 practices in the process, because our interest is not 18 only in verifying the quality of the design, but 19 insuring that there are improvements to make --
20 MR. BOSNAK:
The reliability of the design.
That's 21 what I would be looking toward.
22 MR. LEVIN:
Yeah.
And even carrying that further, 23 if we can make recommendations that will help TUGC0
[,---
24 improve their programs for future work, then we want to 25 make sure that that information gets communicated.
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MR. BOSNAK:
In other words, you won.'t crossover 2
something that is -- maybe, met all of the standards, 3
but in fact is, perhaps, poor engineering practice.
You 4
would make that recommendation and change.
5 MR. LEVIN:
Yes.
6 MR. MARINOS:
Howard, I want to continue a little 7
more on that design description.
Your check list is not 8
going to be 'an adequate document, at least for our 9
purposes, to determine whether the design is correct 10 the requirements from the various needs of the various 11 systems that it serves.
12 So a design description document serves that 13 purpose, to put together all the requirements that had a J
'4 to be met.
Now unless you make a judgment about the 1
15 design description that has already -- it's in place 16 through Gibbs & Hill, I would not be able to tell 17 whether your check list reflects the correct one or 18 anything else.
19 MR. LEVIN:
That judgment will be documented and 20 for an evaluation the check list.
We're doing that to 21 catch everything and to insure that that we're complete 22 as we march through our evaluation of various criteria.
23 MR. MARINOS:
If you make judgments about the 24 design description as it exists today, and you find some
' ~
25 flaws -- problems, deficiencies, unless you define what GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
105 1
should be'the correct one so that we can decide on that 2
basis, we will not be able to get that from your check 3
list.
4 MR. LEVIN:
Not through the check list.
But the 5
combination of the check list and our engineering 6
evaluations and other category documentation I 7
described, you will be able to get that.
Checking the 8
evaluation isn't done on the check list.
Our evaluation 9
of the adequacy occurs elsewhere.
Occurs in the 10 engineering evaluation, the results reports and even 11 more broadly --
12 MR. MARINOS:
But the design document is a living i
13 document, it tells you, it carries you, it's a 14 walkthrough of the system.
What the system is designed 15 to do, and how it's going to achieve it.
And unless you 16 give me some write-up that would parallel that or a
17 supplement it --
1 18 MR. LEVIN:
One thing I want to make sure that we 19 are understanding, is that the check list will not 20 describe how it's going to be achieved, but it will 21 describe the requirements.
Okay.
22 MR. MARINOS:
Okay.
23 MR. LEVIN:
Whether it was achieved will be 24 evaluated in the engineering evaluation.
Our evaluation
~
25 of how it was achieved or wasn't will be documented in 1
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those documents.
Okay.
2 Those documents, the calculations, evaluation 3
studies, that group of documentation that implemented 4
the criteria, will be reviewed to be sure that these 5
criteria were, in fact, correctly implemented.
We will, 6
as part of that process will evaluate the adequacy of 7
these analyses and evaluation.
And what we intend to do 8
is be sure that there is traceability to that decision 9
process.
Okay.
10 That the relevant documents would be identified, 11 would be a cross reference between the design inputs and 12 the documents that dealt with these design inputs.
Key I
13 assumption, inputs and assumptions, would be identified t J 14 and evaluated.
15 And as we mentioned earlier, the tools for doing 16 that are some of the same tools documented in N-45-211 17 to include the review of calculations, alternate 18 calculations, whatever is required to reach that 19 judgment.
20 MR. BOSNAK:
That would include possibly things 21 that are missing.
In other words, if there are no 22 implementing documents, that would take the design 23 inputs and be able to translate them into outputs, or 24 that would be flawed in your mind.
Either missing or
~
25 riawed, they would be identified.
GODFREY & AMES COURT REPORTING
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MR. LEVIN:
They would be identified, and, most
[_J 2
probably, in that case, directed to the project.
And 3
that deficiency would have to be corrected.
4 Essentially, we want to be sure as a bases -- there's a j
5 bases that -- for those inputs to having been 6
implemented.
7 MR. BOSNAK:
That's right.
I want to be sure that 8
you are not just looking at whatever is provided.
That 9
you're looking to make sure that something that's not 10 there and should be there, will be there.
11 MR. LEVIN:
That occurs at -- not only, for 12 example, is there a missing -- we had, I think the
'i 13 example you gave there, is an input.
And there's a c..-
14 drawing or a spec, but you didn't see -- it wasn't an 15 intermediate or inputting document that took you to 16 that.
17 So obviously that would be the other category, 18 where we capture all the commitments that the project 19 may -- even at the criteria level, while there is a fair 20 amount of given NRC's review and other type reviews at t
21 that level, relatively low likelihood that things are 22 releasing from the company criteria level.
If they are,
.L 23 we would identify it there, too.
l g _ _.
24 And add that to our list.
You might say ours is an
~
25 integrated list of what we believe is necessary for GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
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those systems.
_. j 2
MR. MILHOAN:
Howard, before you go to the next
\\
3 slide on implementing document review slide, you earlier 4
said you had reviewed NCR integrated design inspection 1
5 report with respect to the depth of review.
l 6
I assume you got a fairly good feeling with respect 7
to the depth of review we do in an integrated design 8
inspection.
Would it be your intent that this 9
self-initiated review would be consistent with that 10 depth of review or greater than what we do?
11 MR. LEVIN:
I would characterize it as being 12 significantly greater.
i I
13 MR. MILHOAN:
The depth of review?
L J 14 MR. LEVIN: Yes, greater.
15 MR. MILHOAN:
Thank you.
l 16 MR. LEVIN:
Design output review.
And that's on l
l 17 drawing and specifications.
We are going to determine 18 the consistency of the design outputs with the design 19 inputs and implementing documents.
In that process, we 20 would identify the documents relevant to the system 21 structure component, ensure that there's a correlation 22 or cross reference between those outputs, and the 23 criteria in implementing document results.
24 And lastly evaluate whether design outputs are 25 consistent with those documents.
You know, it's one GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
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thing to have a calc that said this is the way it ought m
_.]
2 to look.
We want to be sure that the drawing in fact 3
reflects that.
4 MR. MILHOAN:
Howard, with respect to design, are 5
you also considering the design change process, both at 6
the site and at the AE's organization?
7 MR. LEVIN:
Yes.
8 MR. MILHOAN:
Okay.
Thank you.
9 MR. BECK:
Vince, could we take a five minute stand 10 in place stretch, and --
11 MR. CALV0:
That's a good idea.
Don't go away.
12 (Whereupon there was a recess.)
i 13 MR. LEVIN:
Can we get started?
We're at a point u..
14 in our presentation where we can go through the generic 15 implications and closure, I believe easily before a 16 lunch break.
17 And then we're at a stage where we can do the 18 detailed review, discipline review descriptions after 19 lunch.
So in fact we will have completed the first two 20 segments of the presentation.
21
~And those presentations, for planning purposes, 22 have prepared presentations -- are approximately 20 1
23 minutes apiece.
There are four.
So notwithstanding 24 discussion, it should be, you know, approximately an i
' ~
25 hour2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> and a ' half af ter lunch, we should be able to GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
110 1
conclude.
- .j 2
MR. SECK:
That's not a commitment, 3
MR. SHAO:
Just you talking?
4 MR. LEVIN:
Yes.
There will be other speakers in 5
the discipline group.
6 MR. MOLLONSON:
Before we go on to a new subject, 7
please?
I would like to go back to the criteria 8
indication and review.
In all of those subjects, 9
implementation document review, where you stated an 10 objective, we find that one of the outstanding issues is 11 a statement on a fully implemented QA program.
An 12 implemented program may have detected some of those F
13 deficiencies in the design area.
L..
14 I believe it's rather important that you state in 15 your objectives for each one of those criteria, where we 16 didn't include QA in the beginning sections of this 17 outline, that you state that your objectives in all of 18 these reviews, also include the satisfaction of the 19 QA/QC requirements.
20 I think even to the extent that that may be added 21 to your check list, that attribute for QA/QC 22 requirements, should be adequate for the check list.
I 23 think that should be highlighted in the objectives 24 portion of the program.
' ~
25 MR. CALV0:
Do you agree?
Do you want to make a l
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commitment, or do you want to think about it?
. J 2
MR. LEVIN:
Yeah.
You know it's something that I 3
think I'd like to consider -- I.think it's a comment 4
well taken.
I'd like to consider it.
I think that 5
aspect kind of weaves through the entire program, and 6
that's probably why you don't -- it's just indigenous to 7
our process.
8 MR. MOLLONSON:
I don't have any problem 9
understanding the collective assessment of it.
Place 10 it's in between the different groups.
The end of 4
11 phases, between the different groups who evaluate 12 whatever the results of groups are.
I think, however, 13 that the QA/QC aspect of every function performed by the 14 response team is a significant item in that assessment.
15 MR. LEVIN:
I' agree.
16 MR. CALV0:
So you agree you ought to do it, right?
17 MR. LEVIN:
We think we are, Jose.
}
18 MR. CALV0:
You agree -- okay.
All right.
19 MR. LEVIN:
If we can get into the generic 20 implications program.
I will define the purpose of that 21 program, the scope of it, and the source of inputs into i
j 22 the program, and the description of our approach, and 23 how we will draw conclusions.
24 Our statement of purpose is to establish a i
~
25 framework for systematic identification and evaluation 9
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't 1
of generic implications related to the Comanche Peak
_.. j 2
design programs, processes or controls.
3 We will develop action plans or expand 4
self-initiated action plans to, one, identify potential 5
generic implications of design related deviations 6
deficiencies and their potential causes; to determine 7
the extent of applicability of design related 8
deficiencies and potential root causes; to ensure that 9
any resulting adverne effects on hardware are evaluated i
10 and resolved; to identify necessary corrective actions; 11 to preclude reoccurrence; t'o provide reasonable i
12 assurance that generic effects of root causes and design 13 deficiencies have been identified and resolved.
14 Now on this diagram, I think this reflects a 15 concept that we discussed _ earlier.
And the concept of S.
16 feedback.
And I look at the generic implications 17 program as an integrator information, will flow both 18 ways, from the various functional elements of our 19 program.
That is, where we're dealing with external 20 issues, where we have self-initiated actions in 21 progress, design related deviations, or deficiencies or 22 root causes get considered within the generic 23 implications program.
l,_,
24 And after that consideration, generic effects on
' ~
25 hardware, design are then, oftentimes, go back the other GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
113 1
way.
1 2
And suffices to say that this process not only 3
occurs within the design adequacy program functional 4
elements, but also between our program and John Hansel's 5
construction and.QA/QC program, to the extent that there 6
are issues that are design related.
7 The first step of the process includes a definition 8
of issues.
And that is generic issues.
And our 9
objective in that process is to identify common 10 attributes among identified deviations, deficiencies, 11 and potential root causes.
12 What we're trying to do here is to find the lowest 13 common denominator, so to speak, so that we can put 14 these items into like hoppers, such that we can then 15 ident.ify whether or not there is a generic implication.
16 And the attributes that we might consider, would be 17 the sources, the symptoms, the bounds, the affected 18 organizations, the inner relationship with other issues, 19 et cetera.
20 Fundamentally, the question that we ask as we go 21 through the process are, what common attributes exist 22 among these various inputs into the generic implications 23 program?
Where else have deviations or deficiencies 24 surfaced?
25 And ultimately, we're trying to answer the GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
114 1
question, where else could deviations or deficiencies
.2 exist?
3 MR. CHANDLER:
Howard, you have here, seemingly, 4
with some deliberation, I would assume, omitted 5
discrepancies.
Now you have included, for example, 6
under discrepancy, math errors.
Could you explain why 7
discrepancies, for example, are not included on -- in 8
the generic implications program?
9 MR. LEVIN:
Okay.
We need to get back to, I think 10 an earlier comment, that math errors was an example, and 11 the way --
12 MR. CHANDLER:
I just used that example.
13 MR. LEVIN:
But the way it was being used, was that J
14 already was -- would have to be determined to be 15 inconsequential and 1.solated for it to remain a 16 discrepancy.
17 Essentially a discrepancy category cannot be an 18 ites that has a consequence at all, okay.
So there's 19 really no need.
If you will, Larry, we created that 20 category, okay.
It's more a logistical need for 21 managing programs.
22 You have to have, ultimately, a state of final 23 disposition for anything that flows into the hopper.
24 HR. CHANDLER:
Then you would associate no generic
' ~
25 implications or no significance to a discrepancy which GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
115 1
has generic implications?
That is to say, if you find a t
2 pervasive discrepancy, it says nothing to'you from a 3
programmatic standpoint?
4 MR. LEVIN:
No.
That is a possibility that it 5
could say something.
6 MR. CHANDLER:
But where does'it get picked up, if I
7 you're not looking into discrepancies in this category?
8 MR. LEVIN:
It essentially wouldn't be a 9
discrepancy if it had -- that has significance, Larry.
j j
10 MR. CHANDLER:
But you're going to lose it infthe 11 front end of the process, it seems to me, if you 12 determine that it's simply a discrepancy under the 13 definition you have given it.
And if you have lost it 1'
14 at the front end, how is it going to be' retained over i
15 here in the generic implications area?
16 MR. LEVIN:
I' don't recall a single discrepancy 17 that's inconsequential, okay?
And I guess you're 18 concerned about a series of discrepancies that are also 19 inconsequential.
20 MR. CHANDLER;.
In terms of safety significance, 21 inconsequential.
But in terms of programmatic 22 questions, are you going to' pick that up?
23 MR. LEVIN:
I'd say they're inconsequential in 24 terms of other things, too, if they didn't -- a failure l
~
25 to meet a commitment.
I mean, they have absolutely no 4
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consequence to the design at Comanche Peak.
So I guess 2
our view is there is no need --
3 MR. CHANDLER:
You are making some assessment, 4
aren't you, about adequacy of QA/QC?
5 MR. LEVIN:
Yes, that's correct.
6 MR. CHANDLER:
And that factor, then, doesn't plug 7
into that determination.
8 MR. LEVIN:
My belief, Larry, is that we're talking 9
about items of such a low level of consequence, that to they're below the threshold of really concern, from the 11 standpoint of QA/QC, 12 I think we all have to recognize that there is a i
i 13 level of discrepancies that we'll never be able to get L J 14 out of this system or any other system, and they will 15 remain.
16 MR. CHANDLER:
You will build in some kind of 17 definition then, perhaps, to put bounds on that; right?
18 MR. LEVIN:
Yes.
19 MR. GUILBERT:
Perhaps, I think in-reality now, 20 what we tend to do is for anything to remain a 21 discrepancy, you would have to reach a conclusion that 22 it did not have generic implications that could be 23 safety significant, i.e.,
it's inconsequential.
24 MR. CHANDLER:
I'm staying away --
I
~
25 MR. GUILBERT:
In order to stay in that category --
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MR. CHANDLER:
I'm staying away from safety f..j 2
significance.
I have raised in the context of 3
QA/QC from a programmatic standpoint.rather than from a 4
hardware standpoint.
l 5
ilR. GUILBERT:
Okay.
I 6
MR. LEVIN: Yes.
l 7
MR. BOSNAK:
Howard, maybe what Larry was trying to 8
get at, you could kind a lot of errors that would be l
9 indicative of sloppiness in the process.
But, yet, each 10 one in themselves is, you know, is not of consequence.
11 Maybe each one is taken care of by the margin that 12 you have in the particular piece of equipment that 13 you're looking at.
But accumulatively, if you got rid 14 of all of them, you would never know that the whole 15 process is sloppy and --
l 16 MR. LEVIN:
As part of insuring that, we also have 17 to determine that a collection of discrepancies have no l
18 adverse cumulative effects.
I mean they're truly 19 isolated.
They're inconsequen'tial amongst the 20 individual item, as well sv vr.1 considered as a group.
e 21 And I guess maybe we need some examples.
22 Suppose, for example, is, you know, we had a 23 typographical error, and it had to do with primary 24 cooling system pressure, okay.
And that pressure, we 25 all know, is of the order of 2500 pounds.
But it said GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
118 1
it was 250.
Decimal point was off.
_j 2
And we do an assessment to determine, well, no one 3
has misinterpreted that, you know, it's -- and it's kind j
4 of hard for someone to have a lack of understanding of 5
an order of magnitude, such that that could -- I mean, 6
we needed a way to deal with that.
I think you need to 7
appreciate that our system is going to have the ability 8
to capture something like that, and we want to be able I
9 to to deal with it.
10 MR. 80SNAK:
Like modeling errors, where somebody 11 picks off the wrong dimension, and in itself, it doesn't 12 make any difference.
But if you do that, and it's 13 pervasive, then there's some indication that this design u
14 process is not as good as it should be.
That kind of 15 thing.
16 So that that doesn't get eliminated at the top end 17 of your process.
18 MR. LEVIN:
I agree.
Certainly the cumulative 1
19 effects have to be considered.
20 MR. MARINOS:
Howard, can you give me an example of 21 common attributes among the inputs?
I do not understand 22 what that means.
I 23 MR. LEVIN:
Okay.
Yeah.
We have got an example, 24 in fact, in the next slide.
, _q 25 MR. CALVO:
Wait a minute.
What are you going to GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
119 1
1 do with this one?
2 MR. LEVIN:
I'm going to --
3 MR. CALV0:
No, no, not this one, 1
4 MR. CHANDLER:
My question --
5 MR. CALV0:.It looks to me like you're thinking of 6
doing the same thing that you're doing for the 7
deficiencies and deviations in some kind of way, not 8
quite coming through it.
Do you want to consider it?
9 HR. CHANDLER:
My concern again, Howard, is that i
10 discrepancies don't get lost in the process in terms of, 11 not only potential significance from a safety 12 standpoint, but also from a quality assurance 13 programmatic standpoint.
u -
14 MR.' SHAO:
I think you should treat this the same 15 way you' treated appendix P in John's section.
We have 16 appendix P, we have a lot to find out -- a lot of 17 incidences that we assembled in appendix P.
This is the 18 same way.
19 MR. NOONAN:
That's going to be hard.
You're 20 basically saying what you feel is the discrepancy at
)
l 21 such a' level that they're not really going to get 22 involved, at least from your standpoint.
23 MR. LEVIN:
We anticipate to maintain them at such 1
24 a level that it would not have a l
25 MR. NOONAN:
Substantially, would require about GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
120 1
you have a number of discrepancies.
If you put them all
_ j 2
together, they don't add to some significant matter, 3
maybe I can associate that with an individual who is at 4
work.
Maybe a number discrepancies may prove S
insignificant to me, but the fact that he allowed them 6
may indicate poor quality of work or something.
I think 7
that's what they're worried about.
8 MR. SHAO:
You have to address programmatically.
9 MR. LEVIN:
Yeah, I guess, you know, I think the 10 comments are well taken, and we'll consider that in our 11 program description.
12 Getting back to your question, Ed.
On this slide 13 it may give you a conceptual idea of how we're going to L_
~
14 try to get these common attrib'utes and deal with them.
15 MR. MARINOS:
Can you give.me an example?
I'm 16 having difficulty understanding.
What are the common 17 attributes?
Or something specific?
18 MR. LEVIN:
Okay.
They start off at several 19 levels.
This diagram shows a three level approach.
20 Really, what we have, a three dimensional matrix, if you 21 would.
And remember what's coming into this process-is 22 a potential root cause, a deviation or a deficiency, and 23 we're trying to -- or a series, okay.
24 And what we're trying to do is find out, okay,
,-_ I
'~
25 basically, keep being on -- you know, what activities it GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
121 1
applied to, what discipline was involved, what
-I 2
organization, what procedure may have been involved.
3 And that's at the highest level.
4 Then we go down into the next level.
And each of 5
those broad categories, they subdivide into another 6
category.
You get, for example, out of the design 7
activity area, you see the arrow coming down.
It may 8
affect a program.
It. inputs the process, the design 9
verification itself, design change control, and 10 discipline area.
11 Obviously, it could affect any discipline 12 organizations.
It could affect any organizations or
[
13 subtier organizations within those, and the design 14 verification.
It may have involved, when we get down to 15 even a further level, specific methods that were 16 selected to conduct the design verification in review of 17 correcting 45-211.
18 It could have been alternate cale.
Or it could 19 have been a test that was in question.
What we're 20 trying to do is take the series of deviations, and find 21 out, is there a common thread through all these things?
22 And through identification of that, and getting it down 23 to the lowest common denominator.
Identify in some 24 respects.
Confirm the root cause and generic
~
25 implication.
Now that's kind of a first step.
l l
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The next step is, once you have suspected that, you 2
want to define the boundaries on -- it's one thing to
.2 3
- say, "I think this is the root causes.
This program is 4
weak."
5 Then you have to ask yourself, "Okay.
That program 6
was weak.
What could it have affected?
Where was it 7
applied?
What hardware did it apply to?
What design 8
products did it apply to, okay?
And then you go out and 9
test that.
10 And then those boundaries see -- whether or not, 11 you see the same kinds of problems.
If you do you have 12 a generic problem here.
And that's what this is all I
13
- about,
- t. J 14 MR. SHAO:
One suggestion on mechanical.
I presume 15 all the pipe and pipe supports are in the mechanical.
16 MR. LEVIN:
Piping and pipe supports is -- well, 17 okay, you're looking at this chart?
I mean, this just i
18 served as an example, Larry.
This is to provide a 19 conceptual idea, how it would work.
Piping and pipe 20 supports is a discipline.
21 MR. SHAO:
What I suggest, is on the discipline, I 22 think you group a mechanical, including mechanical --
23 consistent.
And mechanical component together.
Is 24 there really two disciplines?
,_ _q 25 MR. LEVIN:
Yeah, I agree.
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MR. SHAO:
Different depth.
Different people.
2 MR. MARINOS:
Howard, can you walk us through this 3
with the physical system?
Take a component system and 4
whatever, and walk us through the attributes and the 5
various decisions you make for the benefit of more than 6
just me?
I understand more of us do not understand this 7
process.
8 MR. LEVIN:
I'm trying to, Angelos.
9 MR. MARINOS:
P ty up something.
I can suggest to 10 you, or you can give us a physical --
11 MR. LEVIN:
So that I can do that completely, could 12 I suggest that we, for example, mark up on this with an 13 example, and do.that right after we come back from 14 lunch?
15 MR. MARINOS:
That's fine.
16 MR. LEVIN:
As opposed to going off the top of my 17 head?
I may hold together.
18 MR. MOLLONSON:
Excuse me.
When we come down the 19 right-hand side, level two, identifying TUGC0 the A need 20 and contractors.
I don't know whether it's appropriate 21 to say contractors /vendora, because I don't know what 22 level of contractor you're talking about, whether or not 23 we should be adding vendors to supply us.
We have some 24 principle equipment supplies that weren't contractors.
25 MR. LEVIN:
Correct.
This is meant to be a GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
124 1
conceptual framework, okay.
This list at every level is j
2 not complete on this diagram.
However, it is complete 3
in our program.
4 MR. MOLLONSON:
What I'm -- I guess what I'm after 5
is that your reviews don't start at contractor level, 6
because there is a definition, I guess, of contractor, 7
to go beyond the contractor level.
Supply a vendor.
8 MR. LEVIN:
Yes, that's correct.
]
9 MR. MOLLONSON:
Okay.
10 MR. CALVO:
I guess, Howard, when you submit to us 11 the limitation plan -- I mean the program plan, be sure 12 that you reflect -- consider that happening.
I 13 MR. LEVIN:
Yes.
In fact, the list of the L a 14 attributes in those categories will be provided.
15 The next step, having identified a potential 16 generic concern, we have to determine, you know, what 17 areas of the design have been affected, okay.
18 And in many cases, the simple identification of a 19 generic concern will lead to an action plan.
We're 20 going to have to carry out certain tasks and activities 21 to define those boundaries.
And after having defined l
22 those boundaries, evaluated the problems we find within 23 that box.
1 24 Basically, the investigation techniques that, you a
t 25 know', we have talked about, are very similar.
It may i
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include some sampling.
We may have to' expand the depth J
2 or breadth of our review to accomplish that goal.
But 3
after completing that, we will have fully defined the 4
boundaries of the issue.
That is, its extent, where has j
5 this generic pro.bles promulgated?
~
6 We will have identified the impact on specific 7
hardware down to, you know, individual item level.
And 4
8 also where applicable, in most cases generic problems, 9
get back to some need to improve a program.
We will 10 provide recommendations for improvement of those 11 programs, processes or, controls.
12 MR. CALV0:
I guess the question that I have, as
!t 13 you have evaluated in the generic implications, that you l
14 have found discipline.
That you can look at, and you 7
15 say, "Well, this looks like.'
You may be problems in 16 some other areas.
17 Now you also may have another effort in the other 18 areas, and you could, possibility, could have been that 19 you missed some of those generic implications.
20 So there's got to be some kind of reconciliation.
21 And you have got to feed it back into the front end of 22 the program, and say, "Maybe what we did in here was not 23 quite kosher," or something like that.
How do you cover 24 that?
1 i
~
and those things are 25 MR. LEVIN:
I agree, GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
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dovetail.
And I guess that flow chart that I showed
_.j 2
previously shows that.
I agree entirely, because the 3
generic implication -- it could be interdisciplinary.
4 MR. CALVO:
But it could very well be the random 5
sampling.
Whatever you do, you miss something in one 6
discipline, but is reflected in the other one, who shows 7
.probably what this discipline is.
8 MR. LEVIN:
Absolutely.
When you develop those 9
plans, you develop means of testing, whether or not 10 that's the case across the boundary.
11 MR. CALV0:
I think that's a good point.
You are 12 checking all over from one discipline to the other at 1
13 different levels.
L.J 14 MR. LEVIN:
That's correct.
Having identified the 15 specific hardware affected, we then move in to resolving 16 and closing the generic issue.
And we consider that the 17 issues are resolved and closed when we have nailed the 18 extent, the corrective action is developed, fully 19 defined and evaluated by the third party as being 20 acceptable.
21 This corrective action, as I implied, could apply 22 to a design process, program, or the design control.
23 And may include hardware deficiencies that need to be r
24 corrected.
i 25 In either case, the results of'this program are fed GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
127 1
back into the self-initiated design evaluation.
And 2
that program might be evaluated -- expanded 3
accordingly.
May be a need -- just want to get'into 4
other areas in more detail than you have been.
5 Finally, the bases for these conclusions drawn in 6
this generic implication will be documented in the 7
results.
There will be a section in each results report 8
that will address the generic implications of the 9
activities governed by that report.
10 Part and parcel to this entire process, whether it 11 be generic implications or just the execution of the 12 action plans, is the need from time to time to consider
[_
13 expanding scope.
The reasons are many.
14 One, we may need to investigate the trends of 15 deviations further.
May need to investigate root cause 16 further.
We oftentimes will have to identify whether 17 we're talking about a random or programmatic type of 18 deficiency.
We want to provide reasonable assurance 19 that all the -- all deficiencies are identified and 20 corrected.
That is, the areas that are reviewed or 21 bound the problem.
22 There are specific conditions that require 23 expansion.
clearly deficiencies require expansion to 24 confirm that there are not other deficiencies.
~
25 Deviation, a deviation or deviations that coul'd be GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
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a deficiency if occurring elsewhere.
That is, we're
_ j 2
not just going to say that -- we're going to recognize 3
the fact, this may get back to a train of thought that 4
you had indicated earlier, Larry, that a deviation here 5
may be found not to be a deficiency because of inherent 6
margin in that particular location.
7 However, we want that deviation in another 8
location.
9 MR. CHANDLER:
And I would make my same comment 10 here, Howard, that perhaps you ought to consider, 11 including discrepancies in this exercise as well.
12 MR. LEVIt:
Okay.
We'll consider that.
I think, as I committed to earlier -- but it recognizes the fact t
L -
14 that the margin may be here.
But we had the deviation 15 over here and the margin wasn't there, it could be a 16 deficiency.
17 MR. SHAO:
I think what Larry suggested, including 18 deficiency and disciplines.
19 MR. CHANDLER:
Yes.
My concern in this area, in 20 particular, Howard, is that when you talk about 21 expansion of scope, conceivably, if one found a number 22 of relatively minor discrepancies, it may suggest a 23 programmatic type of problem, which might lead you then 24 to a deviation or deficiency in the next piece of work d
25 that went through the same process.
GODFREY & AMES COURT REPORTING Metro 469-6100 (817) 460-2048
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But what you found earlier was simply a 2
2 discrepancy, and you may have several of those 3
discrepancies.
If you would include that through 4
generic complications, it may lead you to a point of 5
identification.
Something of more significance.
6 MR. LEVIN:
Thank you.
Another condition requiring 7
expansion would be identified group causes that can 8
affect design activities outside or inside the scope of 9
review.
10 And fundamentally, you know, after the decision to 11 expand, you need to expand to within a certain 12 population.
The scope would be extended to similar 13 designs or processes, based upon the nature of the 14 potential root cause.
It's not just a, you know, a 15 random process..
It's a directed process, based upon the 16 nature of the issue that you're dealing with.
17 This gets us back to the basis for closure of the 18 design adequacy program.
Fundamentally, closure occurs 19 when third parties activity associated with a specific 20 issue or group of issues have provided reasonable 21 assurance that no significant design deficiency remain 22 undetected, and there are certain conditions associated 23 with that.
24 And that statement is very close to the goal of our 25 program that must be met.
For an issue to be closed GODFREY & AMES COURT REPORTING Metro 469-6100 (817) 460-2048
130 1
safety significant, deficiencies and trends of j
2 non-safety significant deviations must be identified.
3
. Conclusions regarding root causes and generie 4
implication for each, and determinations for corrective 5
action made.
6 Program closure occurs when all issues are closed, 7
and the third party has completed an integrated
~
8 assessment, enabling us to make recommendations for 9
improvement of construction and operation of management 10 and quality programs.
)
l 11 Since we have reached a stage in our presentation, i
12 the end of the second phase, where it might be useful to 13 break for lunch.
We could go on to the next review
- L -
14 description -- discipline review description.
It's up 15 to you.
16 MR. NOONAN:
I think I'd prefer to go ahead and 1
17 break for lunch.
18 MR. LEVIN:
Okay.
19 HR. NOONAN:
But before we do that, I'd like to --
20 Mrs. Ellis with CASE has asked me to, along with Billie 21 Garde, to address this group.
She has to catch an early 22 plane, and there's no reservations to catch a later 23 plane.
So if it's okay with you, John.
24 MR. SECK:
Sure.
Hot seat Billy.
,]
' ~
25 MR. COUNSIL:
Okay.
John, I'm starting to.
I just a
GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
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have some comments I want to share on this morning's
-2 program.
And I'm disappointed I'm not going to be able 3
to heer the rest of it.
But I knew Howard was giving 4
the program, wouldn't get it all done this morning.
5 There was a.few comments which go to the scope of 6
the program, now that I have seen Howard's presentation, 7
that I think are significant.
The most significant 8
being that the third party groups' exit from this 9
project is, in my view, extremely premature.
10 As, you know, both John and Howard, at the Midland 11 Project, which you, you know, referred to this morning 12 as kind of one of the bases for putting your program
[_
13 together here.
14 A very significant part of what you did and why we 15 the intervenors and the public relied on the program, 16 was because you retained a large degree of overview and 17 accountability over your recommendations.
18 And I think in this particular case, that that type 19 of authority is extremely significant.
I don't think 20 it's enough for you to just recommend closure of an 21 item, and then draw the conclusion that there is no --
22 that there is reasonable assurance.
I think that 23 conclusion cannot be drawn until the implementation is 24 acceptable and, in fact, has been accomplished.
'~
25 And if that is not retained, then I don't see how GODFREY & AMES COURT REPORTING i
Metro 469-6100, (817) 460-2048
i 132 1
you can draw that particular conclusion which I L.)
2 understand is your objectives.
3 So that I have a real problem with.
4 Second, I don't see any hold points or integrated 5
points at which either the NRC or the public puts their 6
comments in at a -- in a way that is meaningful in terms 7
of designated resolutions, 8
Clearly, your recommendations may include, you 9
know, there may be two or three other ways to solve a 10 particular problem that you have identified.
You give 11 those recommendations over to the project -- a project, 12 and the correct solution is chosen, and then the project Lj 13 jumps into corrective action.
i 14 Well, that point, obviously, is going to be reached 15 for different -- particular systems at different times.
16 It isn't going to be a single line where the whole 17 operation gets to that point, and 'then you move into 18 corrective action.
And I understand there will be some 19 dynamics involved.
20 But I think if the NRC and, of course, the public 21 doesn't have input into those decisions, that you will 22 enter into corrective action, and that may not be the 23 choice that the NRC accepted.
And intervenors may have 24 some strong reason why we don't believe that that type
,-_,l
' ~
25 of solution is acceptable.
GODFREY & AMES COURT REPORTING Metro 469-6100 (817) 460-2048
i l
133 1
And I think that you need to consider integrating
- 2 2
hold points, I think, as a matter of efficiency, as well 3
as making sure that all your bases are covered with NRC 4
before you proceed into corrective action.
5 Piggybacking on one of the concerns discussed a lot 6
this morning in terms of the deviations, and not 7
trending the types of deviations that I understand 8
you're referring to as very, very minor.
9 I think I see the frustration on your face, Howard, 10 because I know what you're thinking of as very, very 11 minor problems, and you want to be very thorough.
You 12 want to identify everything.
i 13 You have got some splatter on a weld, you have got 14 a particular type of bolt that has a very minor problem, 15 which is essentially cosmetic, that you could get real 16 bogged down on a lot of paperwork for not a lot of 17 problem.
18 The problem I see with that particular approach is 19 that, unless you're willing to assume a worse case 20 analysis, unless you're willing to go into that cosmetic 21 problem and say that there are all -- all welds have 22 splatter and all welds with that type of cosmetic 23 problem, even if they all have that, it won't matter.
24 Unless you're willing to integrate that kind of
'5 review, I don't see how you can exit at the front end on 2
GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
134 1
minor deviations, particularly when you get to the issue j
2 or sloppiness and poor workmanship, because that's 3
extremely significant in making some kind of 4
determination when you evaluate workmanship later.
5 That has to all be included.
And if you're 6
operating on the assumption that you get from a lot of 7
small minor housekeeping or cosmetic problems, you have 8
got to take that into consideration when you consider 9
the larger problems.
10 So I think that that's a problem.
Two things that 11
-- overall comments that I heard yesterday and today 12 that I want to make, and this goes botn to what I have F-13 heard this morning and yesterday, is that I'm really
.L 14 arraid that this program is too confusing.
15 And that's a very simplistic way or saying that, 16 from what I have seen, at least at this point, and --
17 there are too many overlays, there are too many 18 consultants, there are too many contractors with 19 dirrerent charges.
20 And I don't see this ever coming together as a 21 cohesive working well-oiled machine that is going to be 22 able to very easily identify all the problems on this 23 project, come to some kind or overall view or what the 24 corrective actions need to be, and move into a
' ~
25 corrective action phase.
GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
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135 1
The more people and the more systems and the more i
2 different methodologies and the more separate i
3 QA/Qc programa you have got, it's just going to become 4
extremely cumbersome.
It's always been our position 5
that the best way to do this type of thing is to bring 6
in one major contractor, for instance, Stone and 7
Webster, which did a very good job at Midland to the 8
point until the project was cancelled, that came in, did j
9 a particular. thing, had a particular charge, and there 10 we just worked with one or two contractors and one or 11 two charters.
12 This just is almost mind boggling in the different 13 levels that are supposed to be integrated.
And I don't i
c.
14 think that goes just to me sitting here listening to 15 this.
I think that goes to implementation.
16 Second point I want to make in terms of an 17 overview, and I didn't make this one yesterday.
There 18 was some discussion yesterday about the harassment and 19 intimidation issued, and how Mr. Hansen was going to 20 handle that.
21 And his statement today, which was the same thing i
22 that he said back in February on the l
23 harrassment/ intimidation issue, was that, based on the 24 summaries provided by TUGC0 attorneys, he had, as I 25 understand it, pulled out t'he technical issues.
He was i
i GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
136
]
1 going to check those technical issues, and then if the j
2 technical issues resulted in hardware problems, could be 3
a problem.
i 4
And if they did not, if the hardware was okay, then 5
he had to assume. that the problem wasn't there.
6 And Mr. Hansen, you consistently abused the phrase 7
that you can't get your arms around the problem any 8
other way.
And I want to be on the record saying I i
9 think that's a radically incorrect approach.
And that 10 if I was in your position, Mr. Spencer -- or Mr. Beck, I 11 would make sure that he got his arms around the problem 12 in a way that's acceptable to the staff and to the board
][]
13 at the front end.
Because the problem isn't going to go 14 away.
15 The question is still going to be raised, and this 16 isn't the definition given by Mr. Hansel, is not one, as 17 I understand it, that is being accepted by the board.
18 And I don't think that that adequately resolves the 19 problem, particularly when the basis of Mr. Hansel's 20 information is given by the attorneys that have to 21 advocate a particular position in the hearings, and have 22 done so.
23 And so I want to be on the record as being 24 extremely concerned about how you, and I think it is e_,
' " ~
25 your problem, how you are going to handle that.
I would i
GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048
137 1
be glad to sit down at a meeting, because I have some
~-
2 ideas on how you could get your hands around it.
And I 3
think that it can be done.
And I think it needs to be 4
done.
5 okay.
Thanks.
And I thank you for interrupting 6
your regularly scheduled program.
7 MR. NOONAN:
Okay.
Thank you, Billie.
John, I 8
guess I would like to go ahead and break for lunch.
9 MR. BECK:
One o' clock 7 10 MR. SHAO:
Can we --
11 (Whereupon there was a recess.)
12
((',
13 14 15 16 17 18 19 20 21 22 23 24 gg GODFREY & AMES COURT REPORTING Metro 469-6100 (817) 460-2048
.