ML20137J828
| ML20137J828 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/07/1984 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML17198A292 | List:
|
| References | |
| FOIA-85-59 NUDOCS 8512030051 | |
| Download: ML20137J828 (90) | |
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NUCLEAR REGULATORY COMMISSION i-13 l
Technical Review Team Staff 14 l
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Carmen Gooden, CSR, RPR November 7, 1984 8512030051 851106 PDR FOIA G ARDE8 5-59 PDR
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l
2 TECHNICAL REVIEW TEAM i
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5 TECHNICAL INTERVIEW 6
Wednesday, November 7, 1984 7
Fort Worth, Texas 8
This interview was consnenced at 4:00 p.m.
9 PRESENT:
10 MR. JOHN J.
EUDANS Technical Review Team Staff 33 Nuclear Regulatory Commission l
Washington, D. C. 20555 12 MR. VINCE NOONAN j
13 I
Technical Review Team Staff Nuclear Regulatory Commission g
Washington, D. C. 20555 l
15 MS. ANNETTE VIETTI Technical Review Team Staff 16 g
Nuclear Regulatory Commission Washington, D. C. 20555 l.
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MR. ROBERT PHILLEO Ib
-Technical Review Team Staff Nuclear Regulatory Commission 39 I
Washington, D. C. 20555 Ii 20 MR. IAWRENCE SHAO s
Technical Review Team Staff 21
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Nuclear Regulatory Commission
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Washington, D. C. 20555 22 l
I' MR. JOSE CALVO 23 Technical Review Team Staff Nuclear Regulatory Commission 24 Washington, D. C. 20555 25 1
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PRESLNT:
(Continued) 2 MR. RICHARD KEIMIG Technical Review icar Etaff 3
Nuclear Regulatory Commission Washington, D. C.
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MR. WARD F. SMITH
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MR.
R. L. BANGART 10 Region 4 Nuclear Regulatory Cormission Arlington, Texas 11 :
12 MS. JUANITA ELLIS Dallas, Texas s
I 13 MR.. IRRY ELLIS ja Dallas, Texas MR. MARK WALSH j-Dallas, Texas 16 i
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-1 PROCEEDINGS 2
MR. NOONAN:
We're here today,to talk to Juanita and i
i l
1 3
Jerry Ellis to talk about the allegations at Comanche Peak.
4 For the record my name is Vince Noonan, and I'm also the 5
Project Director for Comanche Peakr What we'll do here l
6 today is basically try to address as many concerns as we 7
can talk about, and those we can't talk about we'll take 8
back and see if we can get the proper answers for you.
l 9
What I'd basically like to'do is to get Larry Shao, who 10 is the Group Leader for the civil and mechanical areas, talk 11 basically about the civil stuff.
With that, Larry, do you 12 want to start?
13 MR. SHAO:
My name is Larry Shao.
I'm the Deputy 1
14 Director, Division of Engineering Technology, NRC, assigned 15 to Comanche Peak as a Civil / Structural and Mechanical / Piping j 16 Group Leader.
I l
i 17 Altogether, in the civil area we have about.47 alle-l i
l IS gations and in the mechanical area we have 150 allegations, 19 so altogether in the civil / mechanical area we have about 200 i i
l 20 allegations we're working on.
These allegations are related
'. 4 to design, construction, testing and inspection of civil l
N 21
~
structures and mechanical components.
22 When I was given the job, I tried to get experts on this 23
. team.
The experts are in the piping area, component support 24 area, civil structure area, and the concrete area.
One of 25 r
F 4
I my experts here is Bob Philleo.
Bob is going to just talk 1
l 2
about construction.
By way of a little background on Bob i
3 Philleo, Bob used to be the Chief of Structures in the U. S.
4 Corps of Engineers for about 40 years in charge of construc 5
tion of mass structure in the Unit'ed States. 'He was past I
6 president of the American Concrete Institute, and also past.
l 7
presi ent of-ASTM.
8 MR. PHILLEO:
I was a director.
9 MR. SHAO:
He was the' director of ASTM, and he has 10 written many books related--as a matter of fact, one of the l
11 handbooks you cited is one he co-authored, so he can address 12 some of the concerns you have in the three. areas you had.
13 One is on the concrete base mat cracking, one is on the con-l 14 crete cement tests and concrete strengths, and the other one.
i 15 also addresses the control of the designs.
These three areas, 16 we're going to address in ucre detail today.
l l
l
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37 Altogether, in my team we have about 17 people, six l
18 working on the civil structure and 11 working on the mechani-'
i 19 cal piping, and they're all supposed to be experts in.their 20 areas.
There's a letter you wrote to Ippolito about a month E
21 i
.g l
g ago relating to concrete strength.
Bob, why do'n't you address 22 v
that letter, what your findings were, and maybe try to 23 eXP ain a little bit in general.
Bob was involved in the l
l 24 development of the concrete codes also, so he knows the 25 i
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1 background behind these codes.
2 MR. PHILLEO:
The letter apparently was triggered by l
3 some concerns on the Richmond anchors, but it got into the 4
general discussion of concrete strengths, per se, and winter 5
Protection.
It was pointed out--Attachment D to that letterI 6
has all the meat--that there were 18--or 36 cylinders, just i
the standard moist-cured cylinders that are used for accept-l 7
l 8
ance of the concrete which failed to make the strength of j
9 4000 pounds per square inch which, in general, was the design 10 strength ror the project.
We went through and checked all the mixed designs and 11 12 found without exception all those cylinders that failed to l
13 make 4000 were for a 2500 PSI mixed design.
So we have foun f
14 no place in our investigations where any of the standard l
cylinders on which acceptance of the concrete is based fell 15 16 below the design strength.
There were, in fact, 36 of l
those below 4000, but for those 2500 was the design strength.l j
37 I'
MR. SHAO:
There are certain concrete differences; jg 19 for instance, only 2500 PSI.
These are concrete mainly a
used for over-excavations where they've over-excavated the i
20 r ek and then tried to fill it up.
These are not really 21 t
~
structure e ncrete.
They are mainly filling concrete.
22 MS. ELLIS:
This was one of,the things.
We didn't know 23 and'couldn't tell--
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MR. SHAO:
I think Bob did quite a deep investigation 25 O
6 I
and found out that most of the cylinders that were mentioned 1
I 2
that failed--
l i
3 MR. PHILLEO I have a copy of Attachment D with all 4
the mixed designs indicated for every cylinder that was cited.
5 there,so if anybody wants to go into any degr'ee of detail, I
6 we can do that.
As a broad-brush statement, none of the 7
cylinders cited in Attachment D and none in any of the work l
8 that I have done failed to meet the design strengths.
There l-l 9
may be some because I did not look at all the cylinder 10 strengths, but all those that were associated with allega-11 tions plus a bunch that we picked at random where the alle-l 12 gations were not specific, we never found any where the l.
13 standard cured cylinders failed to meet the design strength.
14 MR. NOONAN:
How many did you look at?
l 15 MR. PHILLEO:
We looked at three or four thousand, I l
Welookedatal 16 guess.
I'd have to go back and add them up.
3 l
l 1;
bunch of them.
IS Now, the second half is~how they deal with field-cured 19 cylinders.
There, there were quite a few field-cured l
i 20 cylinders that did not meet the requirements.
It should J
be noted, however, that there is not a rigid requirement for
.i 21 8
acceptance of concrete based on field-cured cylinders, but 22
-the job specification says--and what the ACI, American 23 Concrete Institute, code that it's based on says--that if the 24 field-cured cylinders fail to meet 85 percent of the 25 s.-
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7 laboratory-cured cylinders at 28 days, the contractor shall l
1 2
improve the protection.
So it~doesn't reject the concrete; I
3 ;
it merely rejects the contractor's protection devices and l
4 requires that he improve them.
However, it might also be 5
pointed out that the requirements for the field-cured l
6 cylinders that were invoked on this job were those for 7
structural concrete out of the ACI building code, and there i
8 is indeed some--a fair amount of concrete in the plant for i
9 which that is a legitimate requirement.
Anyplace where you l 10 have suspended concrete slabs and beams, that is the correct '
11 requirement to use because you want the strength to be l
12 attained fairly early, because when you strip, the thing has.
1 13 no support under it and you want to be sure you have the 14-strength.
i 15 MS. ELLIS:
Is that the 4000 PSI?
16 MR. PHILLEO:
Well, it's the requirement--85 percent of l l
The standard cure usually ran over 5000;l-17 the standard cure.
i IS however, if it fails to meet that, it should exceed the 4000 i
19 by 500 PSI.
l
'Now, it's also true in the ACI standard for cold weather 20 J
concreting that for concrete that doesn't have the support
'd 21
.itself, like a slab and a beam, there are much nore ienient
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22 requirements which apply.
And much of the concrete in the 23 l
plant would meet the categories that they define as the j
24 concrete not having support itself.
They did not choose to 25
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8 1 !. invoke those more lenient requirements on the job.
I can't 2.
really criticize the engineer for doing that because it makesl l
3 the job complicated if he got two sets of requirements to l
4 adhere to, and the inspectors always have a big row of which,
5 one applies.
So they wrote the more stringent requirements l
6 into the specification.
So the 108 field-cured cylinders.-
7 that are cited in Attachment D did, in fact, fail the require-i 8
.ments established in the specification.
That is, because j
9 they were low, the contractor should have'been required to I
10 improve the protection.
Whether he did or not, I don't know..
l 11 That's largely a matter for the Quality Control-Quality I
12 Assurance people to wrestle with.
The thing I was concerned g 13 with from the standpoint of safety of the project is to see l 14 whether those failures were in the suspended structural l
concrete or in the more massive concrete for which the more i 15 16 lenient requirements could have been applied.
Out of the 108' i
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17 there were only three that were in slabs or beams, and of
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is those three, two just barely failed to make the 4000; they 19 were right around 3900.
One was down about 3500, so that was one for which there was some legitimate concern.
That l
20 l
J wasdhaltwithatsomelengthonthejobandwasultimately '
21
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disposed of by making Schmidt rebound hammer tests'on the 22 questionable concrete and comparing it with sound concrete, 23 and it was found to be satisfactory.
g So the other 105 were in the more massive concrete that
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1 is not a suspended structure for which they could have, if 1
2 they had wanted to complicate the job, they could legitimately 3
have used more lenient requirements, in which case there 4
would have been no concern for those.
So I have to concede l
5 that there was a failure to meet the requirements in the
~
6 spec, but for a 105 out of 108 the specifications could have 7
been more lenient and there's no problem with safety.
8 MS. ELLIS:
But it was a procedural failure--
9 MR. SHAO:
It was a violation procedure.
10 MR. PHILLEO:
It's a QA-QC matter, not a safety.
N jj MR. NOONAN:
One thing that I'm trying to do in all of 12 this is:
We go through and we look at the technical reasons 13 why it's either okay or not okay; we will do that.
Now, we t
14 might say that it's okay because we've done some tests or j
i l whatever, but we are going to try to identify--we'll call it l 15 I
root causes--why it happened in the first place, and then 16 i
l l
we'll turn that over to the proper group of people to look
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17 i
18 at.
. )
MR. SHAO:
Also, we are looking at two things.
We're 19 a
looking at certain FSAR specifications and procedures.
If a
20 they violated this, we look at it further.
Sc the violation, Ji 21 l
we can cite them, but safety impact you really'have to fix
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them.
You have to maybe modify or do something, so when we 23 an see a Potential they are violating and they are safety 24 impact, we can--
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1 MR. NOONAN:
You could also have a violation with no 2.
safety impact.
l 3
MR. SliAO:
In that case we just cite them.
4 MR. NOONAN:
In your SER do you explain--
I 5
MR. SHAO:
In SER we would differentiate them.
There'sl I
6 a violation and a violation in safety impact.
7 MR. PHILLEO Now, this letter thing leads naturally 8
into the third major point made in your letter, having to do with the validity of the Schmidt rebound hammer for the l
9 10 application in which it was used.
One of the interesting things--we'll probably discuss this in more detail with Mr.
33 l
Walsh--in saying it was not valid, he used one of my books l
12 13 as a reason for citing it.
MS. ELLIS:
Let me make one comment there.
On the 34 Richmond insert answer, we were under severe time restraints 15 to get it in.
In fact, we were doing so under heavy protests'j 16 i-I to get it in.
I don't know if you noticed in the letters'
.j j-it took four mailings to get all the attach !
that were sent, 33 i
ments to the Board.
But during that time, I think that Mr.
39 r
Walsh tried to make clear in there that he hadn't had much 20
~ f time to really look at this,' and what he did look at bothered 21 him.
That was basically what he was trying to-say. ~~He did l
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not have time to thoroughly research ANI or. ANSI or anything, g
l else that might apply to ASTM.
He didn't have time to really' 1
k at it thoroughly.
25
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MR. PHILLEO:
He was correct in citing references that 2
the Schmidt hammer should not be used as a substitute for 3
normal compression tests for accepting concrete.
I am very 4
adament about that point, that we not throw out the moist-cured cylinders in the laboratory which are the basic accept!
5 l
6 ance medium for ccncrete and substitute the rebound hammer; 7
but it is a very handy device for comparing concrete.
That's 8
about all you can do. - The manufacturer puts a calibration 9
curve right on the side of the instrument, and I wish he l
10 would take them off because it leads to more trouble than l
11 it's worth to the people that get a rebound number and look l
12 on the side of the instrument and convert it to compressive l
13 strength.
It takes a great deal of' carefully controlled i
14 laboratory work to get a calibration curve for a given set of materials, but it is a good device for comparing two con-15 16 cretes; so if you have a concrete that you're completely I
I l
satisfied with, that is not in question, then you make a
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37 I
family of-tests on that concrete, and then you're in a 33 19 position to take concrete that is in question and if -it's of j s
aPProximately the same age and moisture condition, you can i
20 i
test that.
If the questionable concrete gives as high numbara 21 l
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as the concrete you're confident in, then you~have a reason 22 able basis for saying that the questionable concrete is no 23 j
longer in question.
4 MR. SHAO:
I think Mr. Walsh is right when he says that 25
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t if not used properly, the Schmidt hanner test, that some of 1 i l
2 the people just like Bob say just use a calibration curve and, 3
convert to the actual number.
You can't do that.
If you do 4
it right, compare with same age and same moisture and then compare with good concrete, something comparable you know the' 5
I 6
strength and you compare it, that could be very useful, too. ;
I 7-MS. ELLIS:
This is one of the things I think that has l
8 concerned us a lot is that on any retesting that someone like' 9
you be there and see what-the-Sam-Hill they do rather than 10 relying on the same people who looked at it to start with, i
11 MR. PHILLEO:
There were some cases involving possible l
12 freezing of concrete during cold weather where they used it g 13 and only reported the numbers, and thats fine; that's the way t
14 it should be done.
In sonie of the work cite.d in Attachment I
15 D they were converting the compressive strength.
I much l
16 Prefer the first procedure, and all they report is the raw l
data.
Then you have a good basis for comparison without I
t i
17 l
l worrying about calibration figures that are probably incorrect.
i 18 l
I think that's all I need to say about the general l
2 19 i
strength issue that was raised in your letter with the i
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4
.e attachment deal, although we're willing to pursue it to what-
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over length you wish to pursue it.
22 MS. ELLIS:
No, I think we can go into more detail when 23 i
Mark gets here.
24 MR. SHAO:
The second issue is the concrete base mat.
25 saw.w-e s
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1 MR. PHILLEO Okay.
This is the cracks down at the i
2 bottom in Unit One.
There was a great big massive donut-shape l
?
3 pour, and there are, in fact, cracks across the narrow part 4
of the donut just as the alleger said, and one would expect 5
to get them.
Concrete always reduces in volume as it dries l
6 out, and that's something you've always got to worry about.
That's why they put joints'like that in concrete walls to get' l
7 i
8 the cracks in a groove where they can't be seen.
That's 9
always a design problem to work around the fact that concrete' shrinks when it dries and massive placements also shrink l
10 I
because of thermal contraction.
They heat up when the cement ji l
12 dehydrates.
I 13 This placement was designed to go in two pieces where j
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'14 the construction joined across the middle.
I think that woul'd' I
have been the proper way to do it.
Somewhere along the line, 15 by the time they got into construction, the contractor was l
16 i
I given the option of doing it in two pieces or in one; and he l
[
37 chose the option to do it in one, which I guess most con-i 16 i
tractors would do.
It's a little cheaper to do it that way.'
l l
19 i
i So he did it in one.
As I said, there was a rigid form on 20 s
the inside of the donuts; so when the concrete shrank the 21 crack's right where the construction joints 'muld have been. !
g Essentially there is the same condition there as if they'd 23 done it in two, except if they'd done it in two pieces g
there would be a nice straight joint across there.
- Instead, 25
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there's a jagged crack along there.
Structurally the thing l l
2 behaves the same.
i l
3 h'e can go into a lot of structural discussion to show
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4 that it's not particularly significant.
One of the cracks 5
comes across a very thick beam where all reinforced ~ beams l
i 6
have to crack.
The only way the steel can take up the j
7 tension is for the concrete to crack.
They'redesignedthat!
l 8
way.
Usually we distribute the steel so we get a lot of very, 9
fine cracks, but the total length of cracks, th'e total width of cracks, is going to be the same whether there's a pre-10 11 existing crack or not.
Probably the most compelling answer l
to this is that the c itical design condition in there is 12 I
13 for a postulated accident insida.the containment where the l
whole thing is subjected to internal pressure.
So the steel.
I 14 l
in there is designed to take that accident condition, and 15 i
l when that happens all the steel goes into tension and the 16 I
l concrete cracks in so many places, the concrete just doesn't ;
1 g
3-I figure at all in that most-severe condition; so the existence i
16 i
of a crack in that part of the containment is immaterial as 39 far as the most severe loading condition in that containment 20 n
i
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Essentially, the thing--just the way it's designed, only 22 instead of having a nice, neat joint across there, there's 23 I
a jagged joint which has been repaired so that there--on top,'
g and that has no structural significance; but it's essentially 25 1
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in-the design condition the way it sits there.
I 2
MR. NOONAN:
Let me ask a question.
The contractor was '
3 allowed to pour the concrete in one piece?
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MR. PHILLEO:
Yes.
4 l
5'
. MR. NOONAN:
Is that a. violation of procedures to do l
6 that?
7 MR. PHILLEO:
I doubt if you can cite it.
It's just l
l 8
merely a change in the design concept.
The designers had i
9 considered that as being done in two pieces.
For that very j reason I doubt that-there's a piece of paper anywhere that 10 i
says it must be done in two pieces.
That was just the design 12 concept.
I can't say for sure; I haven't searched every i'
13 piece of paper that might be relevant.
l 14 MR. SHAO:
For this particular allegation we tried to I
ci se out the original alleger.
That was last week, and he 15 i
was happy with our findings.
He had no problem with that l
16 finding.
I don't know whether you know the name of the I
[
alleger or not, but we did close out with him last week.
16 MS. ELLIS:
The original alleger:
I'm not sure if I gg l
g know who the original alleger was.
20 R. SHAO:
I have the name, but we can't say it.
21
, 'MR. NOONAN :
I would prefer not to say it, and'inake sure we keep the confidentiality.
We met with him last 23,
l week and Dick Wessman from my staff was down here.
MR. SHAO:
On the phone.
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16 I
MR. NOONAN:
On the phone?
Excuse rne, this was one he 1
2 did on the phone.
If you need it, I'll ask Dick if that's 3
one of the CASE people.
4 MS. ELLIS:
Yes; all right.
l 5
MR. SHAO:
The third issue is -the control room ceiling.
i 6
I think the original alleger is Mr. Walsh.
I think his 7
original allegation said that the fueling conduit, the dry-8 wall and the piping going in the area above the ceiling panel 9
in the control room are classified as non-cite and are 10 supported only by wires and that these are either made for or are the result of seismic event.
This allegation was 13
.12 originally attacked by Mr. Jose.
He looked into it.
He also.
13 found some allegations is valid.
He then turned it to my 14 group and also I found it as valid.
We even expanded the investigation a little bit and went beyond what he said.
We l 15 l
looked at the whole control room ceiling.
16 I don't know whether you're familiar with the regulation l, I
j 37 I
i, 18 Regulation 129.
There is Seismic Category one and non-Seismic 19 Category One.
Seismic Category One is non-safety function.
i I
20 You,have to design.
The design should be in such a way it cann t fail.
The non-Category one can't fail, but our 21
-s regulati n say when it fail that there must be'done in such 22 a way that failure would not adversely affect the safety 23 fun tion of the safety-related components.
24 So in Comanche Peak for non-Seismic Category One, they 25
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17 I
do a so-called Damage Interaction Study.
When they do a 1
l 2
Damage Study, they look at physical geometry, do some analyses.
3 Then they reclassify the non-Seismic Category into two, one 4
called Category Two and one non-Seismic.
Non-Seismic is when 1
5 it fails, supposedly the geometry of the layout in such a way l
6 it will not affect the safety of the component; but Category l
7 Two are close to safety-related components so they have to 8
perform in such a measure that Category Two cannot fail.
9 So in the Control Room ceiling there are heating, l
10 ventilating and air conditioning.
They were classified as l
11 Seismic Category One.
We have no problem with that.
p 12 The safety-related conduits that are classified as Seismic
-[
13 Category One we have no problem with, but there are non-i 14 safety conduits and lighting fixtures which they were j
classified as-Seismic Category Two, and they're supposed to 3
15 l
16 provide an analysis to show these seismic Category Two I
l l
3, 3-components in such a way that failure would not affect the
^
I i
15
' component; but they do not have very good analysis.
We are 19 not happy with the analysis.
Instead of doing a good dynamic analysis, they do a lot of clone study analyses and then take 20
.1 e
interaction effect into account.
So we point out to them
.i 21
~!
I and they_ agree with our finding.
22 Also, there are non-Seismic items such as sloping sus-g 23 pended drywall ceiling, acoustical ceiling and louvered 24 ceiling.
They should be designed in such a way that their 25
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18 1
failure would not cause--adversely affect the function of l
I 2
safety or cause injury to operators.
We found out they 3
didn't do a good job in this area either.
So we wanted them to provide either analysis or modify their ceiling in such a,
4 5
way they meet Regulation 129, and they are committed to do l
6 that.
But because of this problem, we are looking at I say that we see this problem with'the Control Room; 7
area.
i 8
what about the rest of the plant?
Is it possible the same i
9 kind of problem occurs somewhere else in the plant?
They l
10 submit a program plan--that was October the 18th--I was not 11 happy with the program plan.
They addressed concurrency l
12 quite well, but they did not address the generic issue I 13 was asking for so I'm still waiting for that.
Where did you make the money in case your--!
14 MR. NOONAN:
l MR. SHAO:
They were going to try to rip out some of j
15 l
16 the drywalls.
ThelasttimeIwentdownthere,outthere!
MR. NOONAM:
j 17 l
to the site, they had a lot of construction.
They were j
jg taking out most of the ceiling and putting in aircraft l
l j9 i
wiring and so forth.
Are we going to go back and look.at i-20 i
that?
21 t
This whole thing is--as I said, the Eirst MR. SHAO:
22 Part, I'm not happy with that plan in this area.
I'm not 23 l
happy with that Category Two analysis and also the generic j
24 9
attachment.-
25
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19 I
]
MS. ELLIS:
One of the things that concerns us is that l
2
'whenever they have to redo something like this, it seems like I
3 they always have a tendency to go out and either contract to
~
4 have it done or start doirter it themselves and just go ahead l 5
and do it before the NRC e ten has a ch'ence to look over what l 6
they're planning to do.
7 MR. SHAO:
That would cost them money if they start to 8
do it and we tell them we don't agree.
That's their problem.
9 If they're smart enough, they talk to us first.
10 MR. NOONAN:
They are in the process of redoing it.
33 When I was there, I was looking at it and I did talk to them.
l 12 there.
They've got the ceiling out.
13 MR. SHAO:
Yeah.
I told them don't use judgment so they 14 say this thing fall down it won't hurt the people.
It 15 doesn't take a lot to hurt people's eyes or nose and people j
16 can't function, so you better modify the structure, rather l
g 37 than try to prove it.
You see, their original judgment is 16 something very light can fall down, hit somebody on the head 39 or eyes.
I think--I said don't do that to us because nobody 20 can be sure about five pounds, ten pounds falling down; it may hurt somebody.
i l
MR. NOONAN:
It seems to me we ought to go'back to the ite and check to see what they're doing.
23 MR. SHAO:
Okay.
MS. ELLIS:
That's one of the things that bothers us.
2a.
e e -= =. - --=
m r-
20 Of course, we have another concern which goes into the cost 1
2 aspect of this as well.
In addition, I think it puts an I
additional unnecessary burden on the NRC because once they're 3
started doing something and have already done some work on 4
it, it puts a pressure there.for them to go ahead and finish 5
6 doing it.
7 MR. SHAO:
Maybe you can bring it up to management, 8
Vince.-
9 MR. NOONAN:
I will.
MR. HUNNICUTT:
Specifically, Unit One will be held up 10 until they finish the main--
33 MR. NOONAN:
Maybe you better, at this point in time, 12 identify yourself.
13 MR. HUNNICUTT:
I'm sorry.
I'm Doyle Hunnicutt, Region l
34 Four.
j 15 MR. BANGART:
I'm Dick Bangart, Region Four.
l 16 l
MR. NOONAN:
Dick is one of the directors here for the g
miscellaneous areas on the TRT Tear..
j IS MS. ELLIS:
I recognize the name.
g9 7
4MR. SHAO:
I think that's all the issues I have today.
4 20 TherE is one issue on the heating and ventilating support.
" ^
Dick, that's your area, right?
22 MR. NOONAN:
We can go to that.
Maybe at this point 23 in time--I'd like to ask you if there are other things that 24 we need to know about?
25 s-
~
es e we
-m
-m-
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21 I
l MS. ELLIS:
There's a lot of stuff here.
I think it j
l 2
would probably be easier for me for y'all to go ahead and 3
f r me to just start going through my stack.
MR. NOONAN:
Maybe I'll have Dick start on the heating 4
~
I 5
and ventilating system.
6 MR. BANGART:
The concern I was writing in regard to, 7
the HVAC-Supports was assigned to the Miscellaneous Team to j
8 follow up on.
There is a relatively extensive inspection history related to the issue of the box and work done at the !
9 cite and a lot of work that was done by the Utility themselve's 10 in response to the concerns that were raised.
We had two 3;
l 12 people involved in the detail look at that issue.
Mr.
Hunnicutt was one.
Mr.LeeEllershawisaReactorInspectorl 13 in our Region, but he was also previously an inspector in the 34 Vendor Program Branch, so he has been involved in inspecting i 15 HVAC vendors for whoever is supplying the components.
Mr.
I 16 i
i Ellershaw is not available today so Mr. Hunnicutt is going to g
l summarize the details cf the investigation that we undertook.
gg MR. HUNNICUTT:
This allegation was where they'had been 39 alleging that the HVAC had not been analysed for seismic a
20 loads and stated that all HVAC components and supports t
~ ~
8 inside the containment were not properly considered in regard 22 to the treatment of missiles.
In other words, some other movable object could penetrate through the HVAC.
And that the HVAC failure during the postulated accident would allow the e
_--g--w-n..,-
22 I
1 temperatures to rise to an unacceptable level inside the WehadpreviouslyinspectedthisonReportNo.l 2
containment.
i l
3 445/8318 and again on 8324 where we identified the violation 4
pertaining to the fabrication, installation and inspection 5
of the HVAC system components.
l 6
The licensee responded with corrective action and to I
)
7 other identified violations on June 28th of '83.
This 8
response also addressed analysis of the identified worst-9 case conditions being performed by Corporate Consulting and l Development Company, which had been the HVAC mupport design 10 l
enginecr.
l l
12 During our other inspections we sampled the HVAC ducts 1
-13 and supports in the Unit one cable shradding room and the l
Unit One containment air circulation and cooling system.. The 14 NRC staff observed certain dimensional and welding discrepancies
[
15 l
similar to those that we had previously identified.in the two l
i 16 I
{
reports because nearly all the fabrication and installation j
37 l
l had been performed by bondsmen prior to the identification g
33 of the first violation.
It appeared that the discrepancies 39 obWerved by the NRC staff were very similar--no worse, in 20
(
f other words--to those that h'ad originally been identified.
,, l Ji We requested that TUC submit a discrepancy evaluatEo'n' by 22 their contractor, which was again related to Corporate 23 Consulting and Development Company.
We will call that CCL
~
25
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=_
23 1 l So our staff again made an inspection that included the 2
CCL report and according to the CCL, we found that all the 3
pertinent liVAC supports were analyzed for seismic loading.
4 The NRC staff also reviewed the CCL report entitled " Seismic; 5
Qualification Report of Seismic Category One Duct Work and 6
Hangers for Comanche Peak Steam Electric Station."
This 7
report is identified by CCL as No. A-424-81-06.
The latest l
8 revision listed here is June 1, 1983.
That's Revision No.
9 6.
This CCL report included the engineering work sheets, I
10 hanger data sheets and computer printouts that referenced 11 and indicated the inputs and the analyses used to make their l
12 calculations.
l3 The NRC staff also determined that the CCL-engineered l
14 hangers were analyzed using two different methods.
One is 15 the well-known hanger-based code called Stardyne, S-t-a-r-d-l 16 y-n-er and the hanger-based analysis consisted of two codes: I I
.l l
17 hanger which is used to qualify your single duct transfers I
18 hangers using your finite element models and the FEASA, a 19 much more complicated analysis technique, which can accommodate i
multi-duct transfers and axial hangers.
i 20 f
'I'll be happy to go into the Stardyne if anyone is 21 8
i interested; otherwise, I'll just quickly say that it is 22 a program that can be used for complex arrays of multi-duct 23 hangers and,for thermal expansion analyses of duct systems l
g, l
simulating a load.
25 5
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24 1
The CCL report--paper is not important, but there are inotherwords,youhavetodoquiteabitl 2
48 volumes of it; I
3 of work to_get through it--presents a seismic qualification documentation for all the Bahnson Company Seismic Category j
4 5
One EVAC ducts and hangers installed at Comanche Peak.
The l
6 NRC staff determined from the CCL data that the HVAC ducts I
7
'and' hangers are structurally accurate to withstand the post '
i I
8 ulated seismic loadings hs CPSES.
i 9
Furth'er, on CCL's seismic qualification report it shows '
10 that the seismic-qualified HVAC duct work is classified as i
11 Seismic Category one.
Also, safety-related equipment bonded l
12 in the duct work is seismic-qualified either by dynamic j
13 analysis or by shaker table testing using a full responsive j
14 spectra or by static analysis using one-and-a-half times the l
15 peak of the floor response spectrum.
i Due to the fact that all the components are analyzed l
16 l
to assure that they are structurally adequate to withstand i
3-l the postulated seismic loadings, there appears to be no need
[
IS I
19 for missile consideration with respect to the HVAC systems.
l I
In our report 8324 we indicated that the reactor containment i
20 w
p heat removal system did not rely on the HVAC system, but is
,j 21
-t really c mp sed of two' separate containment spray'recircula-22 tion trays, each of which has 100 percent capacity and, of 23 course, the containment spray has two functions.
One is to j g
remove the heat from the containment after postulated load, 25 j
[.
~ $'
25 I
1 and the second, of course, is to wash entrained and suspended 2
material out of the atmosphere after postulated load.
3 The NRC staff reviewed the FSAR and found that the f
containment heat removal system was desi,gned to assure that l 4
5 the failure of any single active component, assuming.the l
availability of either on-site or off-site power exclusively,!
6 7
did not prevent the system from accomplishing its design 8
safety function.
9 I'll be happy to answer any questions related to it.
l 10 MS. ELLIS:
I have one question.
I'm assuming from l
11 what you said that the answer to this is yes, but just to be 12 sure and also I'm a little out of my element:
In the con-13 tainment, the sides of the containment, where you have the 14 HVAC system ducts going up the sides of the containment, 15 arethoseseismically--notseismically--laterallysupported?l 16-MR. HUNNICUTT:
Yes, ma'am.
They are laterally supporte
~
I 17 to where they can only move within the seismic requirerents.
j is These are large ducts.
They transfer very large arounts of 19 air.
Roughly--let's see, the height of the containment is 7
8 i
20 252 feet, and I've forgotten the circulation capacity; but 5
~
t 21 the fans do continually circulate the air to keep from j
^$
22 stratifying.
Inotherwords,thebottomwould'bea$80 23 degrees and the top at 190 or some other numbers, but they l
are seismically restrained to assure that under the postu-l 24 25' lated seismic conditions for the area--I have forgotten the w--wm
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.u 26 I
exact number--related to a seismic category.16 or.12.
l 1
Oneofourconcernsthere--I'dhavetocheckl 2
MS. ELLIS:
l I
3 the transcripts to be absolutely certain about this, but it is my recollection in June of '83 hearings testimony was that 4
I 5
they were not laterally supported, and that was one of the l
6 things that was brought up.
This was during the hearings 7
on CAT Team findings.
8 MR. HUNNICUTT:
As I understand it--I hope my informati 9
is correct--they were laterally supported to withstand any l
l 10 postulated seismic event for the maximum allowed or permitted l by the FSAR as Mr. Shao pointed out,.12. f That's one thing--I'd have to check on that l 12 FE. ELLIS: 13 to be certain. 14 MR. NOONAN: That was a June 30th-- MS. ELLIS: There was a June 3983 hearing. I'm not j 15 sure what the date was. I'd 4 v+
- o check.
16 MR. NOONAN: You say the NRC did a review? Who was that? j 3-MR. HUNNICUTT: I was one; Mr. E11ershaw was the other; gg i 39 and if you will permit me to go back a second, I will tell you 20 who the other people were. Mr. Taylor was the thiid, and if my mem ry doesn't fail me, those are the three principals. j 21 -t ~ Now, we have had some input from a Mr. Cummings wh'o is the g current resident, and due to de fact dere's a draft report 23 under consideration right now. I don't recall but I know he g and I had authorship on portions. I can't remember the numbe r. 25
1 27 I 1 Now, on 8416, in my infinite wisdom and hurry, I just copied 2 the three pages that related to it; and I do not know who the' 3 author was on the 8416. It was issued on October the 4th-- l 4 of this year, of course--and I only have pages 12, 13 and 14. 5 I apologize for not having this entire package, but when you l 6 are in a hurry--of course, I didn't take it out of the site. I I 7 MS. ELLIS: I think that's one we just got recently. 8 MR. HUNNICUTT You would have just gotten it because 1 9 it was mailed--it left our office on October the 4th, and l l 10 pages 12, 13 and 14--in fact, it would be paragraph 6--cover l 33 a minor amount of your HVAC; and there's another one coming l 12 that really went through the CCL Phase 1, 2, 3 and 4 docu-l 13 ments that compared it to a licensee's evaluation. l 34 Specifically they had made a probability analysis that--I think it was 280 elements needed to be checked and CCL had 15 i i done 285 so, in other words, they probably listed calculations 16 I l between the licensee and CCL were certainly within the basic j 3-i mathematical realm. We hope to get that report issued short-Ib 39 ly. I won't make a stab at the number because I may be wrong!. i MR. NOONAN: What concern was there? 20 MR. HUNNICUTT: Again, they neglected the use of the ,, I core spray system and containment spray, which~each of the l two systems is 100 percent available, and that is supposed 23 to reduce the temperature within a reasonable amount of time from the highest postulated value to a reasonable value. =<e-- -w+.--.. i-
28 1 MR. NOON AN : But the concern would be that the tempera-l 2 ture gets too high and the equipment won't work? 3 MR. HUNNICUTT: That was our understanding of the ~ ~ 4 allegation, yes. 5 MS. ELLIS: And also it wasn't.. supported properly. l 6 MR. HUNNICUTT: We'll go back and check the supports 7 and reconfirm that. 8 MR. NOONAN: I'd like to do one other thing, too. As far as the equipment inside, do we qualify the equipment forl 9 what we call the high energy line, which is the main steam 10 1) line, or ALOCA people. I don't remember the exact tempera- ~ 12 tures, but I'll get them for you. Equipment is usually qualified to within a range of somewhere around 300 degrees. 13 14 MR. HUNNICUTT: Let me correct that; it's 275. MS. ELLIS: I was kind of thinking 280. i 15 16 MR. NOONAN: We don't tell you what the equipment is l 3 l l 3-actually qualified for. We'll give you the upper value. l MR. HUNNICUTT: If I remember correctly, it was 50 PSI } }s i as designed and 40-something as the maximum calculated and j 19 i 275 Fahrenheit would be the ~4aximum temperature. i 20 MR. NOONAN: Do you have anything else on that one? t - J,. 21 t Do we have additional questions'~o5 this MR. BANGART: 22 I that might be raised at some later time? 23 MS. ELLIS: Mark could have; I don't. 24 MR. NOONAN: With that, I think I'll get Jose Calvo 25
29 1 start with the electrical. l 2 MR. CALV0: My name is Jose Calvo. My background: I 3 work with the NRC for the last 12 years. I spent one year l l 4 with the International Atomic Energy Agency. I also worked j 5 for~ Westinghouse in energy-related matters. I also worked l l 6 for Bechtel Corporation and Louisiana Power. 7 Before, I think you had one allegation that I'm con-l 8 ~ cerned with. Before we get back to the allegations, I think l l 9 it's appropriate to tell you how we handled the a'llegations. I i i l 10 As you know, the quality control in::pectors were interviewed I I 11 and a number of allegations came up as a result. Most of l 12 them were general in nature; some of them were. specific. 13 What we did is some kind of way we_ correlated all these l 14 allegations. One allegation was talking about terminal I 15 locks.- We're talking about bat splices; we're talking aboutl 16 cable installation. We put them into about nine categories. ! And regardless of the allegation which has safety significancle -l 17 l 15 or no safety significance, we went beyond that point. We l t f 19 kind of bound the subject categories with our own sampling, l looking in areas where we felt there was a real concentration' 20 . 4 21 of cables and problems of terminal locks or bat splices so we can identify whether there was some kind of' generic 22 23 implications as a result of this. The allegation you brought up, I think, touches terminal 24 1 eks, touches cable splicing, touches cable installation, 25
30 1 l and I think also it touches nonconformance reports with i 2 regard to cable o'peration where the cable was installed. We l I 3 acknowledged the' fact that this particular allegation, the 4 formation brought up by the alleger was--the concerns brought 5 up by him, there was no safety-related matter but we say lets 6 see if the same problems are in the safety-related matters. 7 So maybe we can give him credit for these things. I guess 8 what we did, we focused in that kind of direction. We did 1 9 find some problems with bad boxes. I want to give credit l 10 to this lady as I do to all the allegers who contributed to i
- j
. force us to look into that area so we did find problems there. 12 We also have problems with terminal locks. He have I 13 problems with terminations as we indicated in previous j i 34 meetings with the Utility and in our letters summarizing l ur conclusions. One thing we did in that case is we had 15 s me allegations which were quality control-quality assurance' 16 I i related, so every time we looked at those we went beyond the g y7 l paper work. We went up there and we ascertained the quality g 33 l of the hardware. I was involved with a similar team who 39 j ' i was responsible for assessing the quality of the hardware 20 at the similar plants, and i had some background on'how to I work on this type of review. 22 ~ Now, this is what we did. I'm looking at specific allegation 813 and I guess the alleger we used to call j "*' * ~~ 25 i -em en --.-e.
s, 31 I I t$. VIETTI: She doesn't know what 813 is. That's our j 2 NRC number-- 3 MR. CALVO: She knows Oklahoma. One of the allegations 4 brought up has to do with the use of locks for some different 5 size cables, 750,000 circular mill versus the 1,000 circular 6 mill, but that one located in the circulating water system. 7 That system normally is not safety--I mean, it is non-safety 8 related, so we did not concentrate on that because why waste. l 9 our time about the non-safety related. Let's concentrate on l 10 similar problems with the safety-related. g 11 Also, the other allegation he had was building locks-- l 12 I go back to Switch' Gear Room-Reactor One. I guess this l We went and checked this out l 13 allegation came on 1981, 1982. i 14 ourselven and found out that that thing was involved with l 15 some black cable, but definition of black cable is non-safety l 16 related so we don't b'cther with that one_either. I i i 17 We did look into also unmachined panels, like panels-- i 16 Centrol Roor panels. Those a' Iso were associated with black 19 cables, also non-safety related, so we don't bother pursuing ' i 20 that one. No reason to spend our time. i There was another one that had to do with patching of 2] l f 22 cables and with operation. There was some nonconformance 23 report. I think the nonconformance report.was indicated as in 1981. Those had been handled in a manner that was satis-24 25 factory. Whether they were safety-related--they could or ~-v m w m -,.,,,y m. g wn ,&g,---v,-
32 1 they couldn't be construed as non-safety related. We did l 2 also'look at nonconformance reports in several areas to bound I 3 all'these allegations, so this contributed an input to the 4 other category for nonconformance reports. j 5 The only one that had some safety-related flavor was the 6 Switch Gear Room in Reactor Number.One. There was some prob-7 lem there in No. 10 terminal locks. So what we did, par-8 _ticularly for the terminal locks, we went and we reviewed 9 the safety-related areas and we looked up in the order of 10 about 16 safety-related panels and the control panels, l terminationcabinets,notorcontrolcenters,andswitchgear.l 11 12 he inspected them for the proper size locks and relative to 13 cable sizes and screw sizes. We look for tightness in the l 14 bars, ground wires. So we look at all these things that were, t 15 Presumably brought up in 1981.- We find nothing wrong in this 16 particular area. We did find something wrong about the I I i 17 splices and the excess bending in the terminal wires. l l IS The other one in the cable installation was a whole 19 category. We went back to this with the other allegations l ' i 20 and we didn't find nothing out of the ordinary. We looked j i l g ~j 21 into the cable tray. ) l .,In summary, all the allegations with everybody contribut+l i 22 23 ing to them, I guess the terminations, we had problems with them; we had problems with the cable separation; we had prob-24 25 lems with the electrical equipment separation,_and also with i me., ,,-r r-.--- y
33-i 1 Control Room ceiling fixture and that we passed to the l 2 Mechanical Group. 3 Now, we haa some other--that was the hardware allegatio. 4 We had also the QA-QC allegation and we look into the elec-3 5 trical NCR activities. We found no probleps insofar as our 6 small input from the electrical standpoint. We are waiting j 7 for the big overall input that QA-QC must link--couple with 8 ours. We also looked into procedures, and we identified 9 problems and we identified corrections to those problems. I 10 Again,'also, that one is not complete because the overall 11 QA-QC programatic review-got to couple with that one. The 12 other one that we wrote, the electrical QC inspector training 13 and qualification, I think we find problems with the elec-l. tricalqualificationandtrainingthatwecameoutwithsomej 14 15 Procedures and some requirements and actions to be accom-i g plished. However, those gave me a chance to look more broadly I l i' and the QA-QC found additional problems with the electrical I i gg procedure. 19 I guess in essence that summarises your particular s I 20 allegations, but I think the important part of it is that t + all f them contribute to making this categories. Not any ,j 21 l .5 single individual gets to take credit for thi'. Also, the g s 22 team also has found other things that were not covered by the 23 allegations. g MR. NOONAN: You say the QA-QC; this is the-- 25 l ~ l g
14 1 MR. CALVO: Livermore; the group. They are supposed 2 to couple all the' disciplinary with the programatic one and 3 come up with--in some cases we already had concerns and we 4 confront those concerns. Now, when those concerns get bigger I ~ 5 because they found something else,* mechanical or coatings 6 or whatever it is, those have to be put together; and just i 7 because they found that everything is okay doesn't mean that i 8 that subject is complete. It's okay from the standpoint what I 9 the allegation may focus in, but when the others come 10 together, maybe this whole thing will open up and maybe l focus on those areas, even in our area, but we don't know 11 I 12 that until we finish the work. j 13 MR. NOONAN: Have you given Herb Livermore all these l l 14 things? l 15 MR. CALVO: He has copies of all my NCR's for quite some time and we've been communicating. As you know, when l 16 I I these NCR's become available and they all have the stigma i 17 that they are--they say it is complete as far as the electri-j is 19 ' cal input, but these conclusions can be changed as a result of the overall programatic reviews. 20 ~ At this time I say the Utility as well as the'intervenors 21 l ~ are at a disadvantage because you only know the r'esults and ' ~ 22 the conclusions, especially on the electrical area. You 23 don't know how we got to those results and conclusions, which, 24 l test, what method we used, how we bound the thing up, why 25 -,--g wv-,--m-w y-,,y-, m-p --nn,w-w -, _7,_ w e--'
35 I we picked this up, and where we picked it up. Knowing those' NowIcanl 2 things, you can say, "I know hew they go about it. i I ~ 3 develop a plan; I can critique a certain anount, and I can 4 understand what the overall scope of the problem is." You 5 have to have the whole picture to try to understand what we l 6 did was either good or not good. At this~ time it is very 7 difficult to ascertain. 8 MS. ELLIS: When you come out with the final report, 9 will that be included in the report, how you did all this-- l 10 MR'. CALVO: Yes, it should be. Then people can under-11 -stand whether we did a good job or bad job. By this time l 12 all these people on the report that we saw say those by it-l 13 self don't mean nothing and there should be no basis for l i 14 coming within the actual plan at this time. That is not fair I 15 to anybody to do that. 16 MR. -NOONAN: On these reports we called them safety l l 17 evaluation. Uc were going to handle it. It's a charge from l I jg what was being done before. We will have one of my staff 19 members in charge of the so-called safety evaluations, and i under her we will have three consultants for various areas i 20 .J we're talking about'here. We'll have a consultant for the j 21 We'll have a consultant for the mechani-l l ..a r-coatings on QA-QC. 22 . cal and miscellaneous areas. We'll have another consultant 23 for the civil and the electrical and testing areas. Their l g j b is to, after all this comes together, basically sit there 25 ,w, e-n- -.e.., .m.,,.,,--e -+-..,,--,,e
36 - l 1 and look and see if we have addressed the evaluation properly, I 2 if there's something that we've rissed. It's sor.ething like. 1 3 a coordinator to'look.over the picture. We have three out-4 side consultants to do this, sort of, for us, to give you an; l 5 independent viewpoint before we finally put it out to the ~ i 6 public. 7 MR. CALVO: Our effort was not encompassing to pinpoint l 8 what the root cause, but it was focusing at the problems; and, ~ l 9 now when we established the actions that needed to be taken by Comanche Peak Utility, then after they do that work, then 10 the root cause is established. It doesn't make any difference }} l whether they reinspect the whole plant or take a sample, l 12 13 a representative, regardless of what the confidence level, 14 what the acceptance or rejection. The only problem we have g with the rejection is simple: whether that one is reflectivei 15 It could very well be that you will say, I of the root cause. 16 f I 9t have met the acceptance criteria and that means that I have g 37 a root cause probler. and I have to go further regardless of j 16 whether you meet the criteria or not." They've got to under-gg stankthat. It's not a part of whether you passed the test. 20 g
- )
t It's because you found when you passed the test that you had 21 i to go forward. 22 MS. ELLIS: That's been one of our big concerns from 23 the beginning on all of this., Nobody seemed to really be 4 addressing that before. 25 ,_v-. .__..c....e, --,,__,.m. r m-
I ! MR. CALVO: Now we know it's a concern, that it is a 2 problem. How big that problem is we'll know after we do l 3 further samplings. That's all I have to say. ^ 4 MR. NOONAN: These three coordinators, their job is also ".~ 5 to look for what they can tell--as best they can, look at ' l 6 the root causes. Make sure you address these areas that 7 we're worried about; why did they happen in the first place? l 8 MR. CALVO: Do you have any questions? 9 MS. ELLIS: On a lot of 'the electrical stuff, as you're I 10 aware, Billie Garde has been working with some of the 11 other allegers. She's much more knowledgable about that I 12 and what they have to say. l 13 MR. KEIMIG: My name is Rick Keimig. I was the leader l 14 of the group that was looking into the concerns in the test 3 l 15 Program area. By way of background, I have had in excess of, 16 12 1/2 years with-the NCR Region One Office in various I i i t ) 17 positions in the areas of construction, testing and operation's. I j is. There are three other members on.my team: Ward Smith, who q 19 is sitting on my left, who has been assigned Resident } r 20 . Inspector at Comanche Peak since January of this year; and 4
- j 21 there were two contract persons from the Idaho National Engineering Laboratory with experience in testing.
22 23 We looked into 19 specific concerns or allegations and ~ Put them into seven discrete topic areas. As Jose n.entioned 24 I 25 before, the specific allegations we put into_ topic areas I 4 9 y y ww----r*9m-.--v7~r-W-tw-i-' rey-r+
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J 38 1 I because of their similarity. The concerns expressed in 2 CASE-Proposed Contention 26 were included in topic area 1, 3 3 and 4. I'll start off.with topic area 1 which is the 4 largest area and concerns eight of the items in Proposed I 4 5 Contention 26. i 6 - The first concern that was expressed in CASE-Proposed 7 Contention 26 was that the applicant failed to conduct an 8 adequate prefueling hot functional test program in that not 9 all components or modifications were installed with required 10 functional testing. TRT reviewed this particular concern and found that.the hot functional test was conducted with 11 12 several minor components and equipment not having been 13 installed at the time of the test, and also found that 14 rodificaticns remained to be completed after the test was l 15 completed. In addition, we also reviewed some of the inspection 16 l reports of inspections conducted at Comanche Peak including l g l the Construction Appraisal Team inspection and several others, [ 16 i 19 as I mentioned. The ones that we reviewed we looked spe-g I cif'ically for any evidence in those inspection reports that 20 J. would give indication of any undocumented--I emphasize 21 a r undocumented--components and equipment. We fotand no 22 P evidence of any of those inspection reports. Therefore, we 23 l had confidence in the system that the applicant was using l 24 for documenting missing componer.ts and equipme_nt. 25 1 0 ,--nw,--ww-,
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39 i 1 our review found that all the equipment required by the 2 hot functional test procedures was either installed or was j 3 'cocumented as not being installed on either a test efficiency J 4 report or a test procedure deviation. Both of these items, 5 the test efficiency report and the test procedure deviation, 6 are the administrative mechanisms that the applicant uses 7 for discrepancies found either during the test or before the l 8 test. Approximately 95 percent of the test efficiency reports 9 issued against the hot functional testing documented piping l 10 and equipment supports and restraints that were not installed l 11 prior to start of the test. 12 We reviewed specifically those applicable test efficiency i 13 reports, and we also reviewed two test procedure efficiency 14 reports which had been generated by the conduct of the hot l 15 functional test. We found that the documentation of the 16 rissing equiprent components was proper and that outstanding i l l I 17 testing which remained because the components were not l l 15 installed at the tir.c of the test was trached by the appli-19 cant and his administrative tracking system. 20 ye also concluded that the applicant's decision to - i
- 5 21 Proceed with the hot functional test despite the numerous t
t P eces of missing equipment was a conscious decision, and it i 22 23 appears to have been influenced by the economic impact of i 24 delaying the testing program. This is not unusual. We also found that the appl cant at the -time that we 25 p
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40 1 did our review was planning a preoperational testing program.' i 2 That is, they wanted to load fuel and then proceed with the 3 tests which were not conducted prior to fuel load. I guess 4 now this is up in the air as to whether they will complete 5 all the testing that was not previously done before fuel 6 load or whether they will finish some of it and have addi-7 tion'al remaining af ter fuel. any testing that is deferred beyond fuel I 8 In any event, l l 9 ing will have to get NRC approval. I i 10 MR. HUNNICUTT: The licensee has prepared to do many 11 hot functional.which will cover the items that ".r. Keinig l 12 has mentioned.- They lost a coolant pump that is being 13 replaced right now. Between now and probably the weekend 14 they will test that, and their plan then is to go ahead and 15 complete the hot functional items that are covered here; and; I 16 then prepare at a later date to remove the head and prepare i j 17 for fuel loading. The number of days is up in the air l l 16 because of the pump and, of course, it's the licensee's 4 19 schedule. e
- ~
20 .MR. NOONAN: May I ask a question? Pump motor burned t out? 21 j ~~ MR. HUNNICUTT: Yes, sir. 22 MR. NOONAN: Was that a defective pump motor? 23 MR. HUNNICUTT: No, sir; a piece of foreign material l 24 was found. 25 9 i .1
41 1 MR. NOONAN: In the casing? In the motor? In the 1 2 l pump casing?-- 3 MR. SMITH: In the motor area. MR. NOONAN: It wasn't what they were pumping? 4 l 5 MR. HUNNICUTT: No, it was foreign material on the 6 outside. It certainly wasn't on the inside. 7 MR. NOONAN: Something that was picked up in the manu-l 8 facturing process, you think, or do you have any idea? ~ l 9 MR. HUNNICUTT: No, the pump has been used a number of I i 10 times. We have not finished our reviews nor has the licensee', l l l 11 but the appearance is that they did not close it up soon l 12 enough after the last testing, and for one reason or anotherl 13 foreign material was introduced and sat there. The pump 14 had been used a number of times by jogging it to remove air j 15 from the primary system, and they started to do a two-minute, 16 test and about 15 seconds they riaw a flash of light and I l l l 17 smoke and they shut it down and secured all the testing until i i 15 they determined the problem. They do have a spare pump, and i 19 the old one is being moved out, pump number three moved out I: 20 and a new one is being put in. -~ g 21 MR. SMITH: We should point out that this is an open-l type motor that has areas you can look in and 'see the areas. 22 I 23 where this foreign material was, so it's not normally closed 1 and sealed. It's accessible. l 4 g 25 MR. NOONAN: Could have been placed there?
42 l 1 MR. SMITH: Yes. 2 MR. HUNNICUTT: You can't rule it out. It could also have fallen and bounced once or twice because from the 3 4 operating floor down is a path of probably 40 feet, and 5 there are two levels on the. steam generators and people can 6 work and drop something mid-level and above the steam gene- ; 7 rators. i 8 MR NOONAN: Is that going to be a report published-- l 9 MR. HUNNICUTT: They haven't finished their investi-gation so I can't answer the question, sir. 10 I !E. ELLIS: Say the plant had been operating and some-g3 l thing like that happened, what would have been the in. pact 12 13 of it? They have other pumps available-- The worst case would have been a locked l MR. HUNNICUTT: 14 motor in that pump which would have stopped all flow from g 15 moving through the immediate reactor scram and you had the 16 I other three pumps plus natural circulation for cooling, so j 3-l the postulated accident should not have caused any serious l IS S 39 problem. j i MR. KEIMIG: You have tc be carefull it's the pump 20 d motor, not the pump. ..I. 93 $..,If.there are no further questions on the reactor coolant 22 Pump motor, I guess I'll summarize our findings with regard 23 l to that concern, and that is that we found that while some l mp nents and equipment were not installed during the 25 n..em.n.,
43 l i 1 initial hot functional test program, they were documented 2 and were tracked to be included in the deferred operational l 3 testing program. 4 The next concern expressed by CASE-- { 5 ~ 'MR. h00 NAN: Could I interrupt you? When you went i 6 through this process and looked at whether they had done i I 7 the documentation properly, tell us in a little more detail l ,8 what that was. What did you do? l 9 MR. KEIMIG: What we did was we reviewed pertinent 10 start-up administrative procedures, NRC inspection reports, 11 the preoperational test index, the system-subsystem turnover 12 index, and we reviewed this documentation against the facility 13 ~ safety analysis report or the final safety analysis report 14 and the applicable NRC requirements and regulatory guide j 15 conducting preoperational test programs We also reviewed l 16 17 of 25 completed hot functional tests and interviewed 8 l 17 cognizant personnel in the test program area. l l 1s, MR. NOONAN: Was that both supervisory and workers? 19 MR. KEIMIG: Yes. As I mentioned, we also looked at 20 many of the test efficiency reports and test procedure i i 21 deviations. MR. NOONAN: When you say "we", that's TR5, 'ight? r 22 23 MR. KEIMIG: Yes. MR. CALVO All the things will be documented; how we g 25 went about doing it. A b
44 i MR. KEI!:IG: The next concern expressed in CASE-Proposed 1 2 Contention 26 was that the applicant did not intend to 3 check some components in the system until heat-up to hot 4 standby or during power escalation. We reviewed that concern 5 by'looking at the integrated plant operating procedures-- i l 6 procedure, rather- " Plant Start-up From Cold Shutdown to liot 7 Standby". As in the case for hot functional. testing, this 8 procedure specifies that the plant be taken to normal 9 operating pressure and temperature using reactor coolant 10 pumps as the heat source. The system preoperational testing that was not done prior to the--would not have been done l 11 12 prior to the fuel loading. At that time, again, this is l 13 somewhat complicated because of the change in the applicant's i 14 planning now because of the delay in the hearing process. l We looked at the preoperational tests that we made and found l 15 l that none would be safety significant if done after fuel 16 } I loading because of the nature of the testing and also because' l 17 the fuel was new fudl and self-radiating and, therefore, j jg could not cause a radioactive release that would harm the 19 I j 20 public health safety. i Additionally, there are some tests that can only be / 21 done after fuel loading. We reviewed those tests, or the 22 plans for conducting those tests, and found that they were 23 consistent with the licensee's final safety analysis report g and also the Regulatory Guide 1.68 which is the NRC guide on 25 f 4 e .-_,%_-,-nn-,,p --.,,__._.9,._. +m__o _.m.-g, . - _, ----~ w .-m -c.ec -v- -a-. 7 -ey ,p, t -v
~., -45 I conducting preoperational testing. 1 We also found that there were several hot functional 2 ; I 3 test items that were scheduled to occur during the power- ~* 4 essential portion of the start-up testing. But those par-5 ticular items do require reactor power in order to conduct 6' the testi, so in summarizing our findings on this concern, I 7 would say that while we found that some of the tests were 8 going to be deferred until after fuel load, we found no 9 safety significance with that deferrment process, and that I l the licensee again had tracked those tests and had done 10 evaluations and, as a. matter of fact, has submitted those 11 l evaluations to NRR for their approvals and if I'm not mis-12 13 taken, they did receive NRR approval to conduct those tests ~ after fuel loading. l 14 MR. NOONAN: Do you have any questions on this one? j 15 16 MS. ELLIS: No. I have a feeling Mark may have some. 5 i HR. NOONAN: We'll take a short break then. [ g7 I (A short recess was taken.) i 15 >,F 19 MR. NOONAN: We'll go back on the record now.
- Rick, I
do you want to continue with-- 20 i MR. KEIMIG: Yes. The next concern that was expressed .j 21 in CASE-Proposed Contention 26 was that the applicant--neithe:r 22 the applicant nor NRC Region Four staff noted the missing 23 equipment and components during the hot functional testing and failed to keep the Atomic Safety Licensing Board infornec 25 ..__,_y__,-----..-._ _,,_ _~.,,. _, ., ~,. ,.m
40 ] cf the probler:s that were encountered. The TRT reviewed, 2 as I mentioned earlier, hot functional testing related test 3 efficiency reports and also the master data base and the 4 I master data base was an integrated tracking system the appli- >. i.-.i n O ' x D f cant tAse's eit's a compute'rited'syst%m, in any eveht*-that w,+ s 6 tradke all sorts of different h ngs, but included amongst qL 6, w~ rd test efficiencies,[ed'uip' ment deficiencies,' things ~ 7 g., g-s
- 4 g
like that. As an example, there were 20 test efficiency' 9 reports identifying missing" hangers and supports associated witn the thermal expansion test. Each of these test effi-10 ciency reports was initiated by the Start-up Group and was 3y evaluated by the applicant's engineering organization for 12 its impact on the test results. The applicant performed 13 calculations and installed temporary supports and weights y during the conduct of the hot functional test so that the 1,. installed supports which in normal operation would interact I with the missing supports would not yield erroneous data. g g Ko also deterreined that the reason that thcrc was no g < documentation in NRC inspection reports, indicating")pIgion 39 g*d, owl.dge of missing. cyponenes was hecause tf,,~.is [ t:
- c.,
ym~ - 9 w ~ - components and equipment were' documented and were being g '.N '* U ( trackhd in accordance with the applicant's administnative 22 g l procedures. Those administrative procedures are reviewed g prior to the Utility's initiation of preoperational testing prior to their initiation of the prerequisite test by the
47 I 1 NRC staff to assure that they are adequate to track those types of things. That was done by Region 4 previously. 2 4 3 With respect to keeping the Atomic Safety and Licensing Board informed of matters that surfaced during the testing. j 4 I t program, we did not find anything that we considered relevant 5 4 to any of the issues that were then presented before the 6-l 7 Atomic Safety and Licensing Board. Therefore, there was no l 8 need for any notification to the Board before any of those } deficiencies that were identified during the testing prograt.I 9 i I might add that the testing program is performed to 10 i identify the deficiencies with the components and equipment,l 1 11 and probably that's the. reason the Loard refus<1 to admit 12 ~ thatparticularcontentionsincethey'reawareoft,nereasonl 13 for conducting the testing program. 14 Now, in the case of something coming up there in the 15 I testing program which would have been considered a safety 16 i I issue or an issue that could not have been resolved to the 37 satisfaction of the NRC, that then would have been brought I 16 to the Board's attention, even though it was not a matter j 39 Pending before it at the' time. That would have been the 20 p g only reason for Board notification. ~ 21 Did the TRT look at the adminis~trative MR. NOONAN: 22 Procedures at all? 23 MR. KEIMIG: Which administrative-- j MR. NOONAN: Are you talking about the administrative 25 1 4 .m. -.e ~, - ..._,__,___--.%,..,,.,__,y.y,__.,_-3,,, .r_,_.e__m. _,,._~-.v.-.-.m.h,,_.,,.,,.y
48 I procedures set up by the applicant? 2 MR. KEIMIG: Yes. 3 MR. NOONAN: Did TRT look-- 4 MR. KEIMIG: Yes. - t 5 MR. CALVO: We looked at one time and you guys went i 6 back and looked again. ,7 MR. K2iMIG: Yes. When you asked me before what did we 8 do to review this thing, that was the first thing we did was 9 look at the administrative procedures. We also found it to i 10 be sufficient for the job ihtended to do. I I 11 MR. NOONAN: Let me ask another question. has that 12 always there as far as you could determine? Those pro-13 cedures were in place; they weren't suddenly fixed? 14 MR. KEIMIG: Well, during the testing program, procedure,s f l 15 get revised as problems are found with the procedure, the way; t i l 16 it was written. Some of these procedures have gone through i i i 17 many revisions, hopefully to improve the procedure, though i l 15 we did not go back to see that each subsequent revision to 19 a previous revision improved that revision. We did go back l 1 I i 20 in several cases to a previ,,ous revision because we couldn't e figure out how it was done from the revision that was in [. 21 i e place at the time that we were looking at it. 'In other ~ 22 l words, it may have appeared that it was not done in accord-23 ance with the current revision to that procedure, so we had 24 to go back to the revision that was in place when that 25
49 1 particular evolution took place to see if it was done in I l accordance with the procedure that was in place at that tire.l 2 . e found it to be okay. W 4 3 4 MR. NOONAN: From your standpoint, the revisions were l what you'd call the normal administrative-type revi'sions that' ~ 5 6 would occur? 7 MR. KEIMIG: Yes. 8 MR. SMITH: I might add that their administrative pro-cedures require them to retain each of the previous revisions l;, 9 10 so it's not difficult for us to look at a given time frame and then go into the vault and pull the revision that was in l 33 l 12 effect at that time to see that they, in fact, complied with i 13 that revision. In some cases, you could even see where it ja caunc-1 a problem and they made a revision to improve that; i so it's a?'. there. 15 j 16 HR. KEIMIG: I don't want to leave the impression thet I l we did that in the case of each one of these administrative [ 3-procedures. We did not. gg 39 MR. CALVO: We did challenge--we did look at the pro-j i cedures, in particular the post-construction inspection of 20 .J electricalequipmentandraceways,andIguesswedid$iot 21 ~ accept the revisions for the sake of the revisions. We did g I actually--it was a great deal of concerns with these 23 l revisions, and the concern was whether the revision was put j there to improve the procedure or whether the revision was 25 ,n, w,..
50 1 Put theie to circurvcnt the problet, so we went back in history and we went from Revision 6 to Revision 18 and we found those cases that was brought to our attention that it 3 4 i was some justification for. Like I said before, these. pro-o .a &., cedbrels hre just an input to this who'bei progiamatic r$ view e 5" ei +.. s ..o that ens going to be done by 19e QA-QC and how all these 6' 4 F< r.. th$p71!1ed together, or wh$ther we were being too ni'rsow 7 w ee- .,,a ~. in our scope at this time', with the p'rosramatic rev 8w#saying, ~ g w,..,,.< "It appears that you might have to go and look deeper or 9 broadcr." I don't know. Mine, I guess--an approach to 10 looking at procedures as an approach to looking at procedures y, I think indicates that those two had to be coordinated with 12 the overall QA-QC programatic review. i j3 MR. KLIMIG: The next concern expressed by CASL-rroposet y Contention 26 was that there were numerous problers identi-l a. ) fica during the conduct of the therral expansion test and, g indeed, thort were. It was allegcd that 60 percent of the 1 test pcints in the therral expansion test itself failed the 16 g Acceptance criteria, and also that the. traceability of'the 39 . ee,.. may ging devices was lo's.t ecause they were not logg~d with e e yy.:. 3 :;g-;;.
- %pt. t. e. q
.:y Y., ,, P. S the data, and that the applicant's engineering organization r. ,,, 2 1 l ,g j .had provided no justification for the use-as'is determintticn ( c2 on piping which did not meet the acceptance criteria._ l The TRT, through discussions with applicant's personnel 24 i and by reviewing the corpleted portions of the thermal i
~. i 51 expansion test not'ed that about 28 percent of the test points' 1 2 failed the acceptance criteria. The reasons for the failure 1 .3 were not totally unexpected in the course of doing this hot j = i 4 functional' testing, either by the applicant or by us. There 5 were TDR's issued to document all test failures so that the l ~ l 6 applicant could provide corrective actions subsequent to that. 7 Additionally, about 12 percent of the monitoring locations 8 were not measured because of missing equipment. These were 9 also documented. Seven percent of the monitoring locations a l 10 were invalidated because the equipment was removed subsequent 11 to the completion of the test. These were also documented. l 12 In total, about 50 percent of the monitoring locations } t These measurements will be done-l 13 still require measurements. t 14 so these additional measurements will be taken during subse-l 15 quant hot functional testing that's to be conducted now, I l 16 guess, before fuel load. l l The concern was also expressed that terporatures were l 17 l taken and. logged during the test but that the specific j Ig 19 measuring device could not be traced back to the locations f 20 that they were used at. -TRT staff found that the completed J test data package did not contain that traceability} however, ..j 21 t i r there was a test engineer who kept a separate log which could 2,, Provide that traceability. The fault was in the test pro-23 cedure which had undergone a revision and the revision that g was used during the test they required that the serial 25 3 ~, -.. _..., _ ~...
o. 52 1 1 numbers of the measuring devices be recorded somewhere in 2 a test procedure and not specifically on the data sheet on 3 which the engineers were going to record the temperatures. 4 but that loss of traceability of the calibration of the 5 instruments, fortunately'the test e'ngineer did keep a 6 separate account of which instruments were used at what 7 locations so they were able to go back and have included 8 that data in the completed test package. Ward, have you 9 verified that's been done? 10 MR. SMITH: No. They have that data package pulled out }} to get it ready for the next hot functional where they're 12 going to do the balance of the support package. l 13 MR. KEIMIG: We will be reviewing the entire procedure, 14 not only what was done in the previous lift--that's hot i 15 functional test--to verify that the logged data was incor-16 Porated, but also to see that they did it in the hot functicnal i i i 37 test they're about to do now. l [ lb MR. NOONAN: Is that a procedural change because--why 19 did it happen? Do you know? I ij 20 .g 5R. SMITH: They may have--let me back up. The adminis-
- e..
trative procedure that controls the format procedures has .j 21 l
- "' w rds in there that were a little bit on the vague 22 side as to how you must maintain this traceability between 23 the instruments that you're using to measure with and the 24 point that you're measuring, and apparently when they made 25
53 I I 1 the change they said, "Well, look, we've got a whcle bunch I t 2 of temperature instruments here. Let's get it on a nice, j 3 clean summary sheet. We'll put it in front of the test 4 procedure." And that's what they did, and it's a nice clean 5 summary sheet in front of the test
- procedure that tells you 6
what this calibration data is, what the serial number is, 7 and the instrument is. But as Mr. Keimig indicated, there's, I 8 no connection between that and the data sheets. But this ( 9 separate log provided that. What they will do is incorporate 10 that log in the data package so that you can make the con-11 nection anytime. I 12 Now, the significance of that is if for some reason they, 13 find out later that a temperature measuring instrument is out 14 of calibration when they check it again, then you know where I 15 you have.to go to recheck. If you don't do that, what happens I is they end up doing the whole test over; so it's more of an 16 I ( i economic than a technical problem. l 17 I g }g MR. KEIMIG: It's more to their advantage. 19 MR. NOONAN: You said they are correcting it, though? i MR. KEIMIG: Yes. Rather than characterize the procedur'e 20 i which tells you how to format a test procedure having vague .i 21 j j ~ langu ge in it, actually what it provided for'was several 22 Options for recording the traceability for maintaining that 23 traceability, but when you use more than one instrument, then' g you have to record the instrument serial number on the data 25
54 I sheet that you used to take the measurements with that 1 and by putting a whole bunch of them in front of l 2 instrument; l 3 the procedure, it just didn't cut it. If you were only using = 4 one instrument for a test, that would then be all right to 5 do, but if you use -several of them; you can't do it. Therein 6 was where the fault lies. 7 We also reviewed a representative sample of test 8 efficiency reports including those specifically mentioned in 9 the CASE-Proposed Contentions which were DDR 853, 854, 855, 1033,1034,1035,1112 and 1113, which identified questionablle 10 11 data or deficiencies during the thermal expansion test'. We 12 .could find no cases where the applicant's engineer had not f 13 Providedback-updataorcalculationssupportingajustificaq I 14 tion for the use-as-is determination. l The next concern expressed by CASE-Proposed'Nontention g 15 26 was that the hot functional test was conducted without l 16 I l 1 l consideration of accident conditions. During our review of l l 17 I the test procedures, wc found that the applicant tested l
- i 15 l
19 safety systems with consideration for accident conditions j l to,%he'extentthatitwas'possiblabysimulatingcertain 20 u .s. P"F", meters such as temperature, pressure, flow, etc., that .. i 21 l t might.be encountered during an anticipated accident or an 22 emergency condition. Moreover, the NRC doesn't require an 23 applicant to test under actual accident conditions. What is 24 required, however, is that the applicant include in his 25 4 4
55 1 application the.crincipal--or how he intends to corrly with 2 the principal design criteria for the proposed facility and 3 the principal design criteria contained in 10CFR50, Appendix 4 l A, and they established necessary design, fabrication, con-1 6% 3 s. l stret: tion testing, performarree r6qfirements for structure d' 5 .s 6 system'domponents important to) safety. We found that the 4
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l 9 accident. 10 The next concern expressed was that the applicant and 3; Recion 4 staff were willing to accept the deficient tcst result. Our review of the completed hot functional testing 12 13 1 and other preoperational test documents indicated that with y few exceptions--I'll get to those later--there were no I deficient test results accepted by the applicant. The final j g3 l acceptance of the test results does net' occur until after l jn I I l j g-the Joint Tcst Group reviews and approves those test results. I 1:e found three minor instances where the Joint Test Group dic 3 g \\ review and approve a procedure where the test obje'ctives 39 .n ha(angt been completely me,t. There was one in maci case of j W.e,$.20 ~. 4 r w, three procedures. 21 -s 6 t-n- - ~ ee'. MR. NOONAN : Rick, can you give an example of one of .2 those? 23 I MR. KEIMIG: I sure can, if you want ce to go into it. MR. NOONAN: Just one. 3
56 I MR. KEIMIG: Let ce take the least corplicated one. l MS. ELLIS: I'll have some questions probably, but I 2 want to wait till Mark gets here. ~ 3 4 MR. KEIMIG: Okay. Test Procedure PT3405 entitled l 5 " Steam Generator Narrow Range Level Verification" intended 6 to dernonstrate at hot no-load conditions that the narrow 7 range level. channel for eac steam generator indicate properly at the upper and lower instrument panels and compare properly 8 i 9 with each other for actual changes in steam generator water 10' level. When this particular procedure was conducted, there 11 were three level detectors that were found to be defective, and temporary equipment was installed in their place in order 12 I 13 to perform the test. After the test was completed, the ( l temporaryequipmentwasremovedandatsometimethereafter,j l 14 the correct level detectors were received by the applicant, j 15 and then they were installed; however, the only testing they! l 16 l i old on the three newly-installed level detectors was cold } le l l calibrations, so they did not meet the test objective which l l lb I l was demonstrated hot no-load conditions that the narrow range l* 19 I level channels for the steam generators indicate properly. f 20 (- f 21 They tracked one of them. That particular portion of the test l t will be included in the hot functional testing that will be t 22 23 conducted shortly. That's one example. As I said, there ( were two others, very similar type of thing. 24 The next concern expressed was that the Atomic Safety 25 = N--_.
57 1 and Licensing Board cannot rely on the NRC staff to monitor I 2 that program for any future inspections. When we did our 3 review--TRT did their review of the hot functional test, 4 Preoperational test, the Region 4 staff had not yet begun i. ~ 5 their* inspection of those test procedures or the completed l 6 test packages. Therefore, it was not possible for them to 7 be tainted by this concern. As a matter of fact, they just l 8 had not started their review yet. Anything that one wanted i 9 to make out of that allegation or that concern was'not l 10 appropriate at all. We did not find any lack of candor on 11 the part of the applicant or the Region 4 staff during our 12 review. 13 MR. SMITH: I think, for the record, I need to point out 14 one thing. Mr. Keimig indicated that the applicant intends to 1 .15 perform this test on the steam generator detector during this next hot functional test. Right now it is not scheduled. It 16 I I l 17 is our contention that it must be done~and, hopefully, it will i g 33 be donc, but it's not on the schedule right now. That par-19 ticular problem was not an oversight by the Joint Test Group.! ThIy' consciously said this is the way we're going to retest i 20 Theirpositionwasl ,g .w this thing. We're going to test it cold. .h 21 that we have tested 13 out of 16.so we've proved generically l 22 + that these things work, so they're still looking at it. 23 -They're still evaluating it, so the issue is not closed one g 25 way r the other at this point in time.
~ 58 1 MR. KEIMIG: The NRC staff is on record as telling the applicant that it is not in compliance with the spirit anil 2 g intent of Regulatory Guide 1.68. 3 MS. ELLIS: There is one question I'll go ahead and ash 4 When they do these' retests and when they do the tests,l 5 now. I where is NRC when those tests are being done? Is someone 6 from NRC there? 7 g MR. KEIMIG: We do a sample inspection program of the We're not there for each and every test. l 9 test program. We're not there 24 hours a day, but we do a sampling program 10 I and then we review test results, again on a sarple basis; i 3g l but I would say that the majority of the engineering safe-l 12 i guard testing is reviewed by the staff. 13 MR. liU'INICUTT: To further clarify what 11r. Keitig said,' j4 l l we corne in unannounced on all shif ts; it isn't just an eight 15 to four. We have people there late at night and early in l 16 l the morning, and if it's a test that has problems or sic- [' 3-l nificance, we do have people for around-the-clock coverage. 16 But normally this isn't necessary. We certainly do cover j y9 [ what is necessary to assure ourse1was.nd, of course, other 29 L.. ;; people that are interested that we do cover the test,
- x..
the procebures,qualificationsofpeople,etc.,toass'dfe'that e 22 they do meet the requirements. j MR. NOONAN: Do you have the benefit of their schedules 1 MR. IlUNNICUTT: Yes, sir. Not only the schedule but 25 =
59 I I they're updated schedules daily. In other words, if they slip 1 l 2 six hours, we know they slipped six hours. l 3 MR. NOONAN: llow often would you call in help? Do you 4 have an idea? e 5 MR. HUNNICUTT: It's a hard question. Specifically, we ~ 6 have a senior resident and a resident on the operation site, 7 and I have a construction resident who is qualified in opera-8 tions, but at another facility, and he is there, and myself, 9 if necessary. So w'e do have--without calling in other help--J 10 we do have the entire Regional staf f in the event we need I 11 them. I guess my last question was triggered more l 12 MS. ELLIS: 13 by the problem with the containment integrated leak rate tes. 14 MR. KEIMIG: That's coming. i 15 MS. ELLIS: I guess that's one of the things that l 16 triggered that question: What. happened with that? l l h 17 MR. KEIMIG: Why don't we pick up with that? The i 16 concern expressed by CASE was that the leaks encountered i 19 during the containment integrated leak rate test were numerous I and of such magnitude that it would have to be corrected and 20 . )i. the test repeated before fuel loading. As a condition for 21 j Parating license for a full power reactor such as Comanche 22 Peak, the licensee has to test--or the applicant; the appli-23 cant has to neet the leakage test requirements set forth in l 24 10CFR50, Appendix J. Appendix J of 10CFR50 requires 25 e-t -r, y.
=- 60 1 l preoperational' testing of the overall leak tightness of the 2 Containment Building. That establishes acceptance criteria l 3 for the test, and this testing is conducted to assure that 4 the total leakage through all designated penetrations and/or, o building floors, if any, does not. exceed the value specified I 5 in Appendix J or the applicant's proposed technical specifi I 6 l l 7 cation. The TRT reviewed the as-performed containment inte-8 grated leak rate test, and the resultant test data would 9 determine that as alleged numerous leaks were detected during 10 the first of three attempts to conduct the test. On each of 33 the first two attempts when it was determined that the leak-l 12 age rate would exceed the maximum allowable leakage rate, 13 the licensee terminated the test and reduced the contaliunent 34 pressure to a safe level for personnel entering into the 15 containment, and searched for, found and corrected the leaks., 16 Prior to the third attempt, test personnel identified- 'l l [ y-three containment electrical penetrations that had excessive I leakage rates. They isolated those three electrical pene-ig 19 trations prior to the third attempt at conducting the test, l i and then they performed the containment integrated leak rate i 20 test. That third attempt was successful. The test was el 93 . observed by two NRC inspectors and those NRC in'spectors, also g " *P'" "" Y 23 the completion of the test,-the applicant performed individual leak tests on the three penetrations that were isolated during 3 w
- i-*=-
.-,w-+ g.
61 the integrated test and found that the--and then looked for 1 2 the cause of the excessive leakagc. They found it anc it was 3 in the penetration--happened to be in the seals; they hacn't ,,. -.. 4 l been properly sealed--and penetrations were reassenblod and .,,, ; ce ye, e 'then again individually leak tested. v The results.of that s e 4 4 u 6 leak wate test, after the problem was corrected for each of A t;- e., t e w, W, e e,. u.. p thFt$ree ' electrical penetStlons, were then added tio the 7 w... ,, s..r overall '.eak' age rate for tN coritainment. That w'as the p e 8' ..et 9 result of the third attempt. This addition was insignificant and did not alter the significant figure in a previous total jo gi leakage rata. MS. ELLIS: Tne problem that I was referring to was-- J2 f 13 i uocs anybody have a copy of the TRT report here? I don't re:..ouiser the exact wording, but-- 33 l MS. VIETTI: Which report are you talking about? Thc 15 18th of Septerber letter to the applicant? y I "E. ELLIC: Yes. ':'he part that I was referrinc to which g-concerned us is on page 14 where it says, "Though the leaks ? g ,jg l were subsequently repaired,andj ndividually tested with (actory_results,NRbapprovalwasnotobtained,tdjer-na Y,,. g20 That 's'{'the form the CIO with these peneh. -J.s.; psW +,.Q: 1:.~ .-s ..~ n er n r ver ations isolated." u: '21 W 6, 3 .w. kind of thing that has always bothered us whenever anything .22 . eg la.ke that comes up because we're not always certain,tha,t' things 23 l like that would have been caught if there hadn't been this 21 i This is one of our higher level of review by the TRT tear. 25 s
62 1 continuing concerns with this, that sometimes in the past l l' 2 we don't know if NRC has looked at things closely enough. l 3 This is what triggered my concern about the other. 4 MR. KEIMIG. I understand. It concerned us also. 5 MR. NOONAN: Do you think that from what.you've done l 1 6 that this thing would have been caught? l 7 MR. KEIMIG: It wasn't a matter of catching it. The applicant reported it in'their summary leak rate test report,[ 4-8 9 in its amendment. It was there. We happened upon it before ! i 10 the Containment Systems Branch of NRR got around to reviewing I }} the applicant's report. It would have been picked up. They l 12 were not trying to' hide it, as evidenced by the fact that the 13 put it in their report. Again, this is a matter of conducting l 14 a preoperational test were the system not in the configuration i 13 or very nearly in the configuration it would be in during 16 . normal operation. That's what bothered us. I l-i 17 MS. ELLIS: One of the things that bothers us is, if I remember correctly, what came out in.the paper when that jg s 39 third test was performed was the applicant saying, "Yes, we'vh l ~ 20 Passed and everything is wonderful", and so forth; not even l g mentioning anything being cioned off. In other words, without ,' h 21 any mention that there still might be some problems h at 2, they had to correct. This is the sort of thing-- 23 l ) The problem 's not of any great significance, i MR. KEIMIG: 24 but I think if they would have--I shouldn't be speaking for 25
63 the Containment System Branch--if they had asked the contain-! 1 2 ncnt System Eranch if they did do that, that is, isolated 3 those three electrical penetrations, and then proceeded with ~ I 4 the test,. they would have probably been turned down. 5 MR. CALVO: Excuse me. When this was submitted to the ! Contai,nment System Branch, it was submitted in amendment to j 6 7 the FSAR7 8 MR. KEIMIG: No. It was just in the test summary report I 9 that's required by Appendix J. l 10 MR. CALVO: It's practice in the NRR to accumulate l AtsomepointintimeyoJ 11 these things that impact the FSAR. l 12 write a supplemental safety evaluation report which covers l 13 all these amendments up to that time. If you had not indi-14 cated otherwise, that means that you accepted what they had l done and you assume they have no great significance that canl 15 16 be implied by that. If you feel that it's safety significan%, i then you so indicate it in the supplemental safety evaluation 1 17 The j 18 report. It happens to us in the case of the splices. l applicant told that to the NRR and NRR has not done the 3-19 I i i 20 review up to that time. The TRT requested NRR, "We need the "d evaluation now so we can have a decision on this, matter." l 21 They say, "Well, you precipitated our review. We're not 22 going to get into it until we have a couple of more amend-23 1 ments." They say,."This one has a bearing on what we're 'l 24 25 doing", so they did prepare a supplemental safety evaluation i i ~ w-w.w e e w A
64 I I I report. Most of the branches in the NRR work on that bauis. 2 Whether this particular report was to be considered as a i ~ 3 supplement to supplemental safety evaluation report, that's 4 something that we can determine. ~ 5 pm. NOONAN: I'll find out on-this kind of test what i 6 the CSP procedure is on looking at this test. Then I'll have l 7 to look at this transcript and let them come back with.a 8 written reply. 9 MS. ELLIS: Okay. 10 MR. KEIMIG: They have already required that, and I l intend to take action. l it 12 MR. NOONAN: They have? l 13 MR. KEIMIG: Yes. 14 MR. NOONAN: I'll have a'look at it. MR.KEIMIC: When we surfaced this problem, I turned it l 15 l over to NRR, by the way, Containment System Branch, because 16 it was really out of our realm, TRT.. As Jose pointed out, j 37 it's not for us to evaluate those things. j 16 MR. CALVO: Containment leak testing, leak rate testing, 19 r. y is part of the standard review plan, and I know is addressed 20 .y .j* in the safety evaluation report. How much of the fo1 low up 21 f they do after that, I think Mr. Noonan is going to determine. 22 MR. NOONANi Annette, help me on that. When we get 23 back let's get some assistance to look at the record, to brind 24 the containment leakage tests and let them tell us what the 25 t m
65 1 procedure is, how thsy handle it, any plants going through I 2 licensing--not Comanche Peak, but any plants, j 3 MS. ELLIS: I might just mention again something that--i ~.~ first of all, we still think that there have been problems 4 t 5 in the past with-Region 4's handling of the allegations and ~ l so)gth,andthatsometimestheyhavenotadequatelyinvesti-6 l 7 gated;'but in addition to that, I think a lot of the problem' I 8 with NRC and whistle-blowers and intervenors has been a lack 9 of communication, like what we're doing right now. I think gg so many times that has~been lacking. I want to say again how i 33 much we appreciate all of you taking the time to come talk to 12 l us about this. I think this is a very important part of what should be going on and should have been going on all the! 13 14 time, not just with this plant but probably with others as well. I think a lot of times it's been--a lot of NRC's l 15 prblemsasfar.aspublicperceptionhasbeenduetolackof! 16 i I communication a lot of times. g 37 l MR. KEIMIG: There was another problem that surfaced
- g during our review of the containment leak rate test, and
.g9 i that was the applicant had committed to perform the test in i 20 accordance with 10CFR50, Appendix J, which requires the g test to be performed in accordance with ANSI Standard,N45.4-1972. While the applicant did perform a test in accordance g -with that standard, the data computation of.the leak rate test results were reported to us as having been performed 9
66 1 in accordance with a later Standard, ANSI 56.8, which is l 2 not endorsed by the NRC. Now, because of the consistency 'i 3 of the data that was obtained during the test, the calcula- ~ l 4 tional method probably--the calculational method by the l 5 Stafida'rd, Appendix J, requires the applicant to use as I I 6 opp $ sed to the Staridard that the applicant did use--probably 7 doesn't make any difference. As a matter of fact, the 8 Containment System Branch is also looking at that and has l 9 come to that conclusion, but has asked the applicant to 10 identify any other deviations from the ANSI N45.4-1972 I 11 Standard that they may have implernented during that test. i 12 MR. NOONAN: Let me interrupt. Why did they do it that ' 13 way? Why did they do that in the first place? MR. KEIMIG: I don't know. 14 i 15 MR. NOONAN: Have the QA-QC people been informed of 16 this? Do they know about this kind of procedure? I 't j 17 HR. KEIMIG: What they should have done is amended the I i 18 FSAR. First, they should have gotten approval to do.the 19 calculations in accordance with the Standard. That wasn't j 20 done. They also should have' amended the FSAR which was not l done, and they characterized that as being an oversi@ t. l 21 MR. NOONAN: The applicant did? 22 MR. KEIMIG: Yes. But they should not have elected to 23 use the ANSI 56.8 method without our approval. g MR. NOONAN: Sounds like you basically fixed the problen 25
67 i i 1 ' tut it seems like the root enuse in still there. Why did t 2 it happen in the first place? 3 MR. KEIMIG: We did conclude that the containment is I 4 sufficient to meet its designed function. 5 The next and last concern expressed by CASE-- 6 MR. NOONAN: Let me interrupt you. I guess we had 7 another member join us. We're on the record, so if you 8 wouldn't mind identifying yourself so the reporter can pick 9 it up. I 10 MR. WALSH: My name is Mark Walsh. jj MR. KEIMIG: The next and last concern expressed by 12 CASE was that unless ordered to do so by the Atomic Safety l 13 and Licensing Board, the applicant will not conduct a tost-i y ing program on Unit Two, but will rely instead on the results of the Unit One testing program to support Unit Two opera-l 15 I tions. The TRT reviewed the applicant's preoperational test' 16 I i l ing program for Comanche Peak Unit Two as outlined in the [ 37 final safety analysis report and found it to be consistent l g gg gg with the NRC Regulatory Guide 1.70 entitled " Standard Format I l and Contents of Safety Analysis Report for Nuclear Power 20 l Plants", and also Regulatory Guide 1.68 entitled " Initial 21 <E Test Program for Water Cooled Nuclear Power Plants".__ The 22 applicant is committed in FSAR to meet both of these regula-23 tory guides. l 24 t' The FSAR Chapter 14.21 states that the purpose of the 25 O e w-r.-
66 1 start-up progran for Comanche Peak steam electric station 2 is to assure that the installed station structure systems 3 and components will be subjected to tests to verify that the plant has been properly designed and constructed and is 4 5 ready to operate in a manner that will not endanger public 6 health and safety. That FSAR is applicable to both Unit One 7 and Unit Two. Therefore, that statement is applicable to 8 both Unit One and Unit Two. 9 The reviewed the preoperational test schedule and Figure l 14.2-4 which is the initial start-up test schedule. Both 10 indicate that the schedule for conducting the preoperational; tests is applicable to both Unit One and Two. We also l 12 reviewed the Unit Two acceptance test preoperational testing} 13 ja dated July 18, 1984. This document provided an index of acceptance tests and preoperational tests including test 15 l N numbers, revision numbers and procedure titles, and were 16 t i { 37 l projected in Unit Two testing program. We compared the j Unit Two test index with Regulatory Guide 1.68 and with the l g gg s Unit one index and found them to be consistent. Only systeras. i 39 i i which are shared by Units one and Two and were fully tested j 20 f du ing Unit one testing program were not scheduled to be 21 ~- t ratested during the Unit Two preoperational test program. 22 "" 9 **'I " * ** ***"E ** 'I' ***~~"*"
- 9"
'I' '" 23 control room, heating and ventilation system, telephone and l radio system, and so forth--and the basis for not testing 5 . - = ~ T~ =- ~
69 them'again for Unit Two is that they were tested satis-1 n l 2 j factorily during the Unit One testing program, and when the t Unit Two testing program is undertaken, those systems will 3 4 be in operation. So we concluded that that concern was without basis. 5 I Overall, we concluded that there was no information ~ 6 that surfaced during our review of those concerns that would 7 l' '8 preclude the ASLP from making a decision pursuant to 10CFR50.57A. We did find some potential violations, but 'i 9 nothing of any' safety significance or with any generic 10 implications subject, again, to a review of the findings of jj the QA team. 12 MR. NOONAN: Based on what he's found out, they haven't 13 14 l found anything of safety significance. Again, we need to go back to the OA team LLS have them look at the procedural l 15 t matters that were generated. 16 I I MS. ELLIS: I might also mention that a lot of the I 17 things that I think you mentioned were allegations in there. g jg I'mnotsureifyouwereworkingfromasummary,orwereyouj 39 w rking from our actual pleadings that we sent in with all r 20 the attachments? l l 21 MR. KEIMIG: We're working froc the proposed contentions. I think I characterized them as concerns. They were not 3 really allegations, but because they were techn!. cal concerns expressed by you and the Board refused to consider them, we 25 9 n ,an-- ---a +,-
70 l 1 I took them as being legitimate concerns.and did review them. 2 MS. ELLIS: I just wanted to be clear that all those 3 were based on the documents that we received from the appli-t I 4 cant. 5 MR. SMITH: Can I ask a question? You spoke earlier I 6 about communication. I was thinking of that as I was read-7 ing the area about Unit Two testing. Did you actually 8 receive information that led you to believe that they are 9 not going to test the systems in Unit Two? Did we under-l l 10 stand that properly?. l t 6 i 11 MS. ELLIS: I'm not sure. That's one of the things that' l 12 I need to go back and look at, our original contention. One 13 of the things that'I personally was concerned about was that 14 they would use it as the basis--since they're asking for b 15 an operating license for both units--that they would use that i 16 as a basis for saying go ahead and give us a license for l l Unit Two also. l ?g j-In other words, they used the test fer Unit I l one whereas they actually hadn't done tests for Unit Two. j i jg I l 39 That's one of the things that I was concerned about. I don't i remember the exact wording of what was said. That's one of 20 i the things that immediately comes to mind that I remember, y 21 s MR. KEIMIG: That's the way I thought that you'h'ad con-22 stmed eat. 23 MS. ELLIS: Also, you need to remember, too, that what we were asking for primarily in this contention was that we g
71 1 wanted discovery about these matters; and I think at some l point in there we v.entioned that we weren't certain how I 2 l 3 much or the extent of the prolalens that there might be, and 3 4 we wanted a discovery to try to find that out. In effect, 5 what y'all are doing is doing some of the discovery on it l 6 now. I'm awfully glad to find out some of these things, and 7 like I said, we'll probhbly have a few more questions later.' 8 Within the context of the hearing, it's a little bit 9 different from when you're asking for discovery about a i i 10 contention. It's a little bit different, in other words, i from raking an allegation like "I went in the field and I j 11 l 12 saw something wrcng and this is what it was." 13 MS. VIETTI: We went through the various documents, l f 14 hearing transcripts, depositions, Office of Investigation reports, old inspection reports that were written by the 15 Region, trying to get a comprehensive list of technical l 16 l concerns, sore of which were allegations, sore of them had I l i 3-come out of other areas that were concerns, and that's how g_ g 19 we grouped them and gave them to the people in the TRT to j { 20 investigate. But that's how some of them get all inter-I ' twin d--they're used to using the word " allegation", but ,. j 21 .t that's not necessarily the case. l 2,, MS. ELLIS: We were looking strictly at their documents 23 l when we developed these concerns. That was the basis for j 24 the contentions. 25 e
72 1 MR. NOONAN: Juanita, if it's okay with you, I'd like 2 to take a break at this point in time. I 3 (A short recess was taken.) 1 4 MR. NOONAN: Mark Walsh has joined this group and we'll. l 5 basically talk to any of the concerns that he might want to 4 6 address--have us address to him, but I want to know first: l 7 Do you want to go through this first or do-- j 8 MS. ELLIS: Why don't we go ahead and start with these l 9 and I'll try to work ther in as we go. Then if I've got h 10 anything right at the end-- MR. NOONAN: Mark, we have pecple here from the civil ~ }} l and mechanical area and we also have--in fact, I talked about '12 i the HVAC--we have electrical and prestart testing area. In 13 order that maybe I could let some of theue people go home, -j4 i would you want to talk about the HVAC first or--it's your 3 15 i option, whatever you want ta do. jg 'I l 'r MR. WALSH: Well, the HVAC. It was written in a report i j7 with the control room and I pretty much forgot about it until l 16 the TRT came along. Just looking, the ceiling in the control a 39 I I room I had forgotten abcut,)ecause of the same report. It I 20 l 4 The HVAC problem is 'was the investigation by Robert Taylor. '-i 21 when he went to investigate it, he did not look'at the HVAC ~
- 2 within the containment.
He looked at the HVAC within the 23 The HVAC within the control room was seismically control room. qualified just looking at it. 25 ~ - - -
73 !!R. S!!AO: It was also sitting on top of the slab. y MR. k'ALS!!: There was bracing. Okay. It seened to bc 2 bracii:c, in the three principal directions. It was the 3 i Containnent Building that I saw one particular line duct, 4, 34 pa.maybe thirty' feet? @ggha $g,up the side of th~e y 5., q q con h ment that did not conta4n any vertical restraint exceit 6 s. .s . se :'. the duct itself. I did notesee.any horizontal restraints l ws a-which would be tangential direction of the containment. There 8 was some restraints that would be radially--of the contain-9 ment--to hold it from falling in, but nothing from going side-10 ways or vertically except the duct itself. There was other areas that I saw that were similar within 3,, the containment. Offhand, I can't remember exactly where, 13 They con't stick cut. g 11R. 5hAO: Sc he's concerned mainly sideways restraints. M r.. % A L Sit : I would think--I did not see many sideways i restraints throughout the building. The containrent was a concern of mine while I was there because Bahnson was y'- supposedly finished, and I can understand if they're not done .f 19 witWin-the Safeguards Building that the seismic restraints ._ 20 44 a g. niigk $oY be up yet; but b d n'Nhe b tainme $, I was 4 21 i p. 1 w. there.., they were supposedly done and there was no restraints. ~' ~~ y. The problem may still be within the Safeguards Building or ...- 23 the Auxiliary Euilding excluding control room. .? ! !!R. NOONAN: Okay. Dick?
74 1 MR. BANGART: We sumtrarized the work that we did and I l l 2 think that we did understand the concern when we finally I 3 looked at this allegation as part of the CRT.
- Indeed, 4
Bahnson problens were well known, have been for some time, 5' andthere'sbeenagreatdealofbothinspectiononthepartl 6 of Region and also TRT, and effort on the part of the Utility;, 7 and they hired a consultant t do an analysis of the supports 8 and conductors associated with the containment or the venti-9 lation system inside containment. Indeed, there were dis-l l 10 crepancies identified in the fabrication and construction of it the HVAC system. The engineering analyses that were conducted I 12 by CCL which is--we previously put the title of the company 1 13 in the record, I believe--but the bottom line is that the 14 engineering analysis supported the accuracy of this syster.:. liR. KALSi:: Is this the sane con.pany that did the 15 i 16 original analysis? l l 5 17 MR. BANGART: 'Yes, it is; Corporate Consulting and l They expanded it through a four-phase evaluatioln g ig Development. that--I have forgotten the date that the four phases came l 19 out--but they did this statistical analysis of the worst I 20 4 That report has not been issued yet, and I hesitate ',j 21 cases. s to give you the numbers because it's too easy to corifuse 22 numbers, but the worst case was one that was found in two l 23 l Nel s that were either missing or improper. Even with that 24 no, there was still something over 98 percent probability 25 I
75 1 of meeting the requirements. I t 2 MR. NOONAN: Did they go back an,d do that analysis 3 given that there were some deficiencies? 4 MR. BANGART: Yes, they did. 5 MR. NOONAN: And they recognised those deficiencies and 6 they went back and did the analysis? l 7 MR. HUNNICUTT: The four worst pipe hangers are listed I 8 in the report that I've got in draft form, and no way do I 9 remember the numbers. i 10 MR. NOONAN: I guess what I'm driving at is: They didn',t i look at the deficiencies themselves? 33 l 12 MR. SHAO: Did they do an original analysis? j 13 MR. HUNNICUTT: They did a supplemental if'I remember l 34 correctly. MR. SHAO: Why did they do a supple.etental? { 15 MR. HUNNICUTT: I can't answer that question. I don't 16 I know. Evidently they did the original analysis. In.3une 37 I f '83 I think they finished one and the next one was later, 15 39 if my memory serves me correctly. I i MR. CALVO: This report has not yet been made available 20 + g to the NRC, therefore. i 21 t n. .j MR. SHAO: These are seismic category one structures, right? They should have original calculation. 23 MR. HUNNICUTT: They probably do. MS. ELLIS: If the original calculations were all right, 95
76 1 l why did they have to do another one? l 2 MR. BANGART: Because of the problems found. i 3 ".F., EU:;NICUTT : Specifically, when there wcre wciding l problems identified, it was necessary to do a re-evaluation f i to determilth what worst case was with what was found, and ] ~ ~ 5 6 the worst case that I recall being found was one support related to it that had two welds missing or undersized--I 7 8 can't remember right offhand--but there was a problem with this one specific one and three other ones that were worst 9 As I say, part of it we can only go so far with the case. 10 draft report before we start getting on the limb that we're ) 33 l not supposed to be on, specifically, releasing draft informa-l 12 l tion. As I say, the report is getting near final review. 13 MR. WALSI:: My concern, though, was not so much if a y,; l weld was g d r n t, but it was just total lack of support is r lack of engineering of the support on a particular duct l 16 i. I run. If they just went through deficiencies from OC, OC g 3 l does not tell them they need a support. l 18 MR. BANGART: That point was raised by Ms. Ellis earlier. 39 l l W8 Committed at that Point in time to go back and look at l 20 the %e%igned and' installed':stpports and get back to you to n r 8 1? confirm whether or not these supports that you!re concerned ! 22 about perhaps may not be there or, indeed, are or are not there. If they are not in any sense there, we'll find out why they are not there.
77 MR. WALSH: That was the concern. l j Ms. ELLIS: And there's another aspect of this that 2 l i we're concerned about in the overall context of this whole 3 thing and any of these issues, and that is when things were 4 done and if they were done because the Utility noticed them l 5 and did something about them, or if they were done because i 6 they were brought to their attention by us or by somebody i 7 else,' and whether or not they would have been caught'if they 8 hadn't been brought to their attention by some other means. l 9 In other words, whether they would have actually been caught 10 by their own QA-QC program it. normal operations. There's l 33 another thing that we'd like to find out: When they did 12 I what as far as if the supports are there now, when they put l 13 i them there and why they put them there, that sort of thing. 34 l MR. EANGART: This is all part of feeding these indi-15 vidual areas of concern to the big QA-QC picture. { 16 I i MR. SHAO: Why did they redo their analysis? g 37 MR. NOONAN: We took some action on this and I'll repea g gg i that we said we would go back to see if the supports are i g9 i there. Maybe Dick could also check and see when they were j 20 >f put ih there, have they been there all the time, were they 21 added, when, what titee? .l V
- 22
- 9
- Y 23 l
a picture we would like to show you. MR. NOONAN: Also, Larry's concern is why did they go
- ' ~
e=r77 -y + -. - ,e ,. - e .m -e
78 1 back and redo the analysis? Did they do it because-- 2 MR. HUNNICUTT: As I recall, it was because of the 3 identified problem. 4 MR. BANGART: That's.a fact. We know that. Concerns l 5 with Bahnson have been well know,+as I mentioned, for some 6 time, and there has been separate action taken on the part i 7 of the NRC to deal with Bahnson as a. vendor who's doing l 8 work at the power plant, what led to deficient work on their l 9 part, and what was delinquent in their own OA program that allowed them to have--so that's been a two-pronged effort, 10 11 I know, in regard to the Bahnson Company. 12 MS. ELLIS: Will information about that be included in, I 13 the report also? MR. BANGART: That's not in our report. I believe l 14 that's being handled through the vendor program people l 15 l 16 located in 1;ashington. l 8 + l 17 MR. NOONAN: Is that Elvis? l 16 liR. DANGART: Garrizet. 2 19 MR. NOONAN: Is that report available? l MR. BANGART: I don't,know if there's been a report j 20 ,g y, r s issued. I know there has been correspondence between the 21 I '~ dr I've Director and Victor Young and the Bahnson Company. 22 lost track of exactly the sequence of events that occurred. 23 I know that Bahnson has been inspected by the other program 24 branch. Where matters have evolved to at this point in time 25 na-
79 1 l I can't tell you. t Annette,maybeyoucouldmake--let'scheckl-2 MR. NOONAN: l I 3 with the I&L people back in Washington anc find out wherc l 4 that is and if we can release it, if there's anything that i 5 can be made public at this time. l ~ 6 MS. ELLIS: That's another aspect of the applicant's i 7 OA-QC program that we're interested in. How is it that they. 8 had a vendor and did not know the. status of their work? 9 MR. BANGART: That's another matter that we are involved i 10 in just at this very moment. We do have an inspection report 13 in preparation of the applicant's vendor-audited program. I 12 That inspection was conducted late this summer, and that I 13 report is in final stages of preparation. 14 MR. NOONA'l: !! ark just stepped out of the room. Let's 15 go off the record for a minute until he g,ets bacl-I (A brief recess was had.) l g i l 17 MR. NOONAN: I'm going to go back on the record for a r.inute while Mark Walsh is out of the room. Maybe Juanita g g l 5 I 19 would like to talk about some things that she brought with 20 h*E* Eu 4 MS. ELLIS: There's one that has to do with the 21 t ele trical information, and what I've brought with'He is ~ 22 Nonconformance Report E-81-00088 da'ted 3-25-81. This we 23 received on discovery--I don't know exactly when; it would g have been.in the time frame of March to about, maybe, April 25 9
80 I 1 or so of '82--and at that tire this was still open. It 2 states four safety-rclated Class lE meters (2 diesel 3 generator watt n.eters, 2 diesel generator var n.cters)werc e 4 removed from the installed main control board without pro-g 5 cedure, were sent off site for modification to an unapproved I 6 facility, and were reinstalled in the control board without ; 7 procedure. 8 DCA 9714, Revision 1, was prepared / approved following theworkclearingsirilarmodificationofUnitTwoinstrumemi 9 10' tation. The quality status of the four instrunents in the control board for Unit One is indeterminate as a result of 11 l 12 the work performed on the safety-related instrument / board l 13 as stated above. This is one that I've been concerned about for sor.e 14 time, and I'd like very much to know what happened.
- Also, 15 i
I'd like to know how all of this got done outside procedure.I 16 i It appears that they did all of it outside procedure, took' [ }- it to the unapproved-facility, brought it back and reinstall d i 18-i it'outside-of procedure, and then set up a procedure whereby a 19 they could do the same thing for Unit Two. I think clearly 20 there)areproceduralviolationsinvolved,andoneofthe i t- ,ei 21 t things that I'm concerned about, too, is whether there were 22 also safety implications with it. 23 MR. NOONAN: Did you read down to--what point? g MS. ELLIS: I read all of it there. 25 +
81 1 MR. NOONAN: Did you read this (Indicating)? ~ l 2. MS. ELLIS: No. l i 3 MR. NOONA.4 : For the record I'd like to go ahead and 4 refer to the following: It's referenced document Gibson e Hill Specification 2323-MS-605, or il DECDS-1700, Revision 1,l ~ 5 6 paragraph 3.2A, reported by John Lowry. It was dated March 7 25, 1981. It had a QE review approval signed by Mr. B. C. 8 Scott dated March 30, 1981, and it says, " Action Addressee Popplewell",P-o-p-p-1-e-w-e-1-1,"ElectricalEngineeringl 9 L. 10 Department." l 11. MR. CALVO: We'11 look into it. There is one other deal that has to do withl 12 MS. LLLIS: I 13 electrical very quickly, because I couldn't find the documen 14 to bring it with me. There was an audit done by the appli-cant and it's one of the exhibits that we were going to 15 introduce into evidence, but I don't think we ever did. I'mi 16 i I not sure if it was accepted into evidence or not. It might 17 l have been when we had a bunch of things accepted at one titre. g jg It had to do with--I don't remember the details--it had to do 19 i with having the wire which was supposed to be used--it was 1 i 20 backgradedorwhateveryou$allit, downgraded to use a ^ 21 muc smaller-sized wire. We didn't have any electrit:al I 22 experts at the time I came across this, but just from l 23 general knowledge of some of our members and some of the g People that looked at this particular document, it appeared 25
82 1 l to us that this could be a problem with using the smaller l 2 wire and could also possibly cause fires and this sort of-I 3 tning because of the use of tne smaller wire. I'll try my J 4 Lest to find that.- If not, probably I can identify it by 5 our exhibit number, and maybe the NRC can find their copy; .{ I 6 but hopefully we'll find it for you. That's one that I 7 ( just happened to think about when we were talking about some l l 8 of this stuff here. t 9 MR. CALVO: The significance of that--I guess we had 10 to know what kind of circuit the' thing is used with.
- Again, l
we got to establish up to what point that wire--what kind ofl 11 l 12 current it carries, what is the significance of having one 13 smaller sized than it's supposed to be. .14 MS. ELLIS: I'll try to find that. l 15 MR. CALVO: Keep in mind some of these things, you pick 16 them up from the preoperational testing. You keep in mind -i j i that this plant, Comanche Peak, it was the circuit required l -i jg. for safety. According to technical specifications you are r j 19 constantly checking the circuit electrically so it is very 20 important to relate this to the circuit and find out what .i kind of system is involved. Then the significance will be 21 d i** established. 23 MR. NOONAN: .Is it okay to have. Jose call you the first of next week? g MS. ELLIS: Yes, that will be fine. 25 - -++, s
83 1 l MS. VIETTI: I know that Gary Mozeno, the lawyer on this 2 case, keeps f airly good files, s6 if somehow we can comuni-l 3 cate and direct hin. to a particular document, he ray very 4 well have it in his files. 5 MS. ELLIS: I know where it is on our list of exhibits. l 6 If he's got them in order by exhibit number, which is what 7 I'm hoping, he'll be able to find it very quickly. Ithinkwe'llgobacknowtothestuffthatl 8 MR. NOONAN: 1 '9 Mark Walsh had. 10 MR. CALVO: Let me ask a question. Do you have any more electrical ones? 13 l 12 21S. ELLIS: I think that's all the electrical stuff that I 13 I have. 14 MR. BAMGART: Any more HVAC-related items? MR. WALSh No. 15 MR. BANGART: If there are any other matters, Doyle andl 16 i i I are Arlington Region 4-based. If there is anything you j 3-g gg wish to bring up-- 19 MR. WALSH: There are some items with the liner. I l, { l don't know which group would be-- j 20 5 MR. BANGART: We were also a part of the TRT and'we l 'sl 21 t "~ didn't' address that particular issue. l g l .= MR. NOONAN: Which liner is that? I 23 MR. WALSH: The liner plate of the containment. g MS. VIETTI: Is,it the walls in the spin-filled coil 25
4.. 84 1 l liner? 2 MR. WALSH: No, the containment liner. I l 3 MR. NOONAN: When we get to that, I think that will cote v. J 4 under. Larry's area. 4 5 SE. VIETTI: Why don't you go into it a little bit 6~ further and maybe we can identify it. ~ 7 MR. NOONAN: Let's go o'ff the record for a minute. I 8 (A discussion was held off the ;ccord.) l 9 MR. NOONAN : We're back on the record' right now, and l 10 we've decided that Dick Bangart and Mr. Hunnicutt can go 1 33 ahead and leave this reeting and the rest of us will stay I k 12 here. 13 I think what I'll basically do is we11 start with the 14 concrete area. We have the people to address poncrete. Let'.s l 15 go ahead and talk about that. 16 MR. SHAO: Let me introduce Bob. He is one of our TRT I l l -[ j-rembers. He's retired from the U. S. Corps of Engineers. l j ' He used to be Chief of Structures at the U. S. Corps of gg l l 39 Engineers in charge of these construction. He's now in l l t 20 Massive Structures, and he was a past president of American 4 Concrete. Institute and he also was past director of ASTM. 21 I think he is co-author of one of the handbooks you" Mentioned. a 22 With that introduction, he's working on a couple of i 23 ncrete areas that you have concerns with, maybe. 24 MS. ELLIS: This is the same stuff that you probably 25 -. =.
85 1 l already have. This is the Richmond insert stuff. Do you l l 2 have a copy of that? I 3 MR. PHILLEO: Yes, we read that. 4 MS. ELLIS: So you've got that. Why don't you go ahead; \\'. 5 and kind of go through what you told me earlier for Mark's l I 6-benefit, and as you go through if I have more questions, 7 I'll holler. 8 MR. PHILLEO: That insert thing apparently got you 9 concerned about strengths of concrete in general. In fact, I think somebody threw you a curve in saying that all the 10 i concrete was designed for 4000 PSI and the actual strength
- j l
was 4500 to 5000. 12 13 MS. ELLIS: That was the applicant. MR. PHILLEO: Yes, I sensed that. Because, for instance, 34 l y u went through the records and picked out 36 laboratory-15 cured standard cylinders that were below 4000. So we went 16 i back and looked at all the mixed designs for all cylinders. [ 37 l that you cited and found that without exception those 36 33 l that you pulled out were for a 2500 PSI mined design. Even i 39 O* applicant--and I might--there are some things that even l 20 4 Region 4 hadn't stumbled on--but, in fact, all those lower 'p; 21 g** strength ones were designed for 2500, so that prettp'well e na es a, that there was any unacceptable concrete 23 as judged by the standard acceptance tests. MS. ELLIS: Before we go further on that, there were 2a.
86 I I 1 a couple on page--do you have a. copy of our Attachment D? 2 MR. PHILLEO: Attachment D? Right. 3 MS. ELLIS: There were a couple specifically on that, ^
- a on page--I guess it starts on page 2, through page 4, where ;
?.. 4 2 .5 it's talking about the concrete pbur for the Reactor No. ) I 6 cavity wall. That one in particular was a concern. It i didn't appear that that one was ever retested. 7 I 8 MR. PHILLEO: Yes. There's a question of what needs 9 retesting. I guess according to the specifications you coul interpret that there would have to be some evidence someday 10 that the field concrete did acquire a strength of 85 percent 11 of the standard cured cylinders. I think the specificationsj 12 are a little vague on that as, in fact, are the ACI's, the 13 ACI Code from which they were taken. p ja As I mentioned, the ACI Code is a building code and 15 concentrates on building elements, which is norral bearn and 16 column and slab construction, and so it has very conservative i 37 l requirements for strength,that has to be attained by field I l 16 cylinders because it's geared towards fast-track' construction j9 i where.ethey're stripping early and the concrete has to i 20 r. 8uPPort itself, and if you back off at all on those early 21 . ~ r 1 1 l *", strength requirements, you have collapses as you do, indeed, 22 9*D I" * ** ****** 23 7 A sub'tantial amount of the concrete in the project is f s y-f that sort, but a larger part is not. They-chose to make 25
- ~+=~==ee w.,.s.,
--..___m.
_4 a w aA a.su,, n e 87 i 1 all the concrete meet that one rigorous spec, I think, pri-2 I carily because it's easier to build and inspect if you don't 3 have to decide which concrete meets which class. =2 f. 4 I have with me the ACI Cold Weather Standard which e 5' gives recommendations for different types'of construction, 6 and those recommendations for.non-flexural members are that-. l ~ 7 in a climate where they're going to eventually get enough l 8 heat from the environment to attain full strength where 9 they're not loaded in early age normally requires protection .10 for three days and then they just assume that eventually the, 11 heat will--get the heat from the climate and reach full f 12
- strength, 13 So it would have been permissible for much of the con-l crete to be judged that way, just to protect it against l
14 15 freezing until it's strong enough to withstand freezing, and ; l 16 just let it wait until spring and summer. and pick. up the i I j 17 strength before it needs it. They did not do that for, I think, understandable j 18 so there is a OA-QC issue in some cases in those 19
- reasons, i
i 108 cylinders that you cited that did not meet.phe require- ,I 20 n- .g nents of the specification. y 21 MR. WALSH: You said some of those mixes wers-2500 pounc. 22 ' mixes. The mix was designed for 2500. Was the analysis 23 where that concrete was used, did they assume 4000 or 25007 24 MR. SHAO: This 2500 PSI mix is mainly out of those 25 i
- =-
-w. ~.. b-w'm-- Nv r--w- '--w- -w- --*T-'------ w w-- w'--"-*-'" 9 4 -7 "-'-N*'-
m 88 1 so-called filling concrete. It is not structure concrete. l So what they do is excavation, rock and everything-- 2 3 MR. WALSH: Like mud mat? -9 4 7, 4 SHAO: Mud mat, yes. It's not structure. 5 ~MR. WALSH: So essentially it was non-safety related. 6 MR. PHILLEO: That would.be a good guess. I'm not 7 prepared to say that on the record because you can design 8 perfectly good structural concrete out of 2500 PSI concretc. ; 9 I really am not in a position to say for sure that there's 10 no safety-related concrete. 11 MR. SHAO: It may be safety related, but the thing is 12 mainly the filling concrete is not really structured.
- Mainly, 13 supposedly they excavate too much the rock and they fill up 14 with concrete and so on.
l 15 MR. WALSH: The documents we received, the requirement l 16 was for 4000. I l l 17 MR. SHAO: But these are actually 2500 PSI. l lb MR. PHILLEO: I've identified the mixed number on cvery 19 cylinder cited in Attachment D, and every one of those with 2, the double asterisk, the d,ouble asterisk indicating the I 20 m O d.I standard cure, has a mix number starting with a three. The 21 r _ ~ ~ ~ rf r - code is that if they start with a three, it's just 2500 PSI. 22 If it starts with a one or a two, it's 4000. I have this 23 piece of paper docunenting all that. 24 MS. ELLIS: Could we get a copy of that? 25 ~.. - - )
r
- f.. ~ *.*
89 1 MR. NOONAN: We're going to put this into our safety I l l report, and I'm trying to get this out within the next week. 2 3 I'm going to say that tongue-in-cheek a little Lit. ,6
- he don't want to push you on it.
4 MS. ELLIS: /, 5 MR. NOONAN: You're not pushing me. C t 6 MR. WALSH: They used the--like the Swiss hammer or Schmidt hammer--on the 2500-pound mix. I'm concerned with 7 them using a Swiss hammer on a 2500-pound mix, design mix, 8 a d qualifying at 4000-pound mix on something that--they're
- 9 n
10 not equivalent and they're testing-- t I woul'd certainly be concerned about that,I MR. PHILLEO: 11 I have no evidence that they did. The concrete that l 12 i too. wasmostatissuewasthe4000-poundconcreteandasnearasf l 13 I can figure out from the records, they always compared a l 14 questionahle 4000-pounc concrete with a confirmec 4000-pound, 15 - t There's very little of the 2500 PSI concrete that l 16 concrete.
- g I've never seen any involved in the Sciur.idt I can run down.
I l 17 i t hammer testing. } 33 Have we answered that for you, Mark, or MR. NOONAN: 19 l do yga think there's something else we want to go back and j j 20 n. S do 'foa you? pt j gg ?) 2500 is new information to me. -I have been MR. WALSH: 22 p g ing through the documents, and they were testing apparently-23 1 4000 or 2500. It seems to me the applicant was pretty f 24 MR. PHILLEO s 25 I g
(. l 90 I vague on this point,.too. Just to start running through f your document here, we just turned the crank on getting the 2 It just printout of all the mixes and identified each one. 3 ~1 turned out that all 36 cylinders that failed 4000 in the 4 b e We didn't standard cured cylinders were'2600'-p'ound mixes. 5 6 expec,t that. That's just the way it turned out. There's several aspects of this that' bothered 7 MS. ELLIS: l Part of them have to do with what you're talking about 8 us. I think and part of them have to do with the QA-QC part. 9 it's pretty self-explanatory what our concerns were about the 10 QA-QC part because I tnink there's obviously some real prob-11 lems here because they committed to go ahead and test all of 12 13 these; obviously, they did not do that. It eppears that some of the tests did not have every-14 thing that they should have had contained in the documenta-15 16 tion along with the test. Another thing that bothered me was that some of the 17 information attached to the nonconformance report which, 16 19 as I understand it, are supposed to be complete documents. osedly what we got on discovery of these nonconformance Supp& 1. 20 s 1* reports were the complete documents. If they were, some of 21 the information simply was not clear in here. 'I'll get into ~ 22 that in a minute. It has to do with the cracks in the base 23 This one in particular, this Reactor No. 2 mat again. 24 cavity wall, was one that I was really concerned about. This 25 - - - - - - - - _ _ _ _ _ _}}