ML20141K049
| ML20141K049 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/18/1985 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20141K036 | List: |
| References | |
| NUDOCS 8601220150 | |
| Download: ML20141K049 (135) | |
Text
. .
ENCLOSURE 1
2 3
4
- 5
.y* . s}O,,..
r g,
.a.
~ ', g.
6 , ,
- ;y ; g s .- . , L, 7 ,;. - .;,; ._ n .-
- f - - ,
, i. .
8 . r. , ,, n.
i, . .
9 :B -
a.
-:o : w, 10 TUGCO MEETING WITH NRC :/c. 5.
'.. ~ j *-. l II CPRT MONTHLY STATUS
~'
12 . .-
December 18-19, 1985 1 4' 13 - i, 14 Arlington, Texas .
15
~...
16 , ')
. e 17 ?
...- i, 18 ..
19
- u. & ,-
20 '
- Pf*,,
l % ;p,. ,
. . wa 22
>1 act 23 45 y gg$0h$oB 60 DR 24 T December 18-19, 1985 25 Taken by: Carmen Gooden, CSR, RPR Cawasa @oodsn l AftJMSTON. TEJIAS W k M
l 2 i I PARTICIPANTS t 2 3 Name Gramnimation 4 J. Beck TUGCO i 5 W. Counsil TUGCO ,
i 6 H. Levin TERA i 7 J. Hansel ERC ,
8 T. Tyler TUGCO l r
9 V. Noonan NRC i
10 R. Martin NRC l 11 T. Westerman NRC 12 L. Shao NRC 13 J. Calvo NRC A. Marinos 14 NRC 15 C. Trammell NRC j
16 D. Jeng NRC
[ 17 R. Klause SWEC ,
i i 1% D. Lurie NRC
- i
! 19 A. Vietti-Cook NRC
.i r 20 I Juanita Ellis CASE 9 21 C. Hale NRC
$ 22 L. Chandler NRC .'
I 23 l i
1 23
(
.k*E- - -
NMM #E
....DsNNts A(.unnobe. . . .. Stosc./&ec. .- .
l
. -- . . v' l - H 1 i m.a ., .. . _
S la e &/M C - ..- ..
l
. Av k!susc . . sw s c- - . . . . . - . . -
f 6. & .
w,c . . . . _ .
.. -. . ..Yket r 7[0???b>?Scrn .-- -. . .- . . -. - . . -
/W?C2 -... . - .
boln L h d c)e . . . A) A C.- . .. ._ . - - .
Toha L.. FM Nc.H . . - . . . . . .._ . . . .. ... PinkASrwr Akd Ysis [*. .S@
iCAR V " 5. A/ W H . . . . . . WWM i /SR~ -- __
. __ 7* h fuihe< r-- .. . -. -_.
...rf D / . M r .._. -
A . 9 e v r 5 .._..--- . . _ . . . . . - . .Te.va. / (M- ~
.Jbw A Aewx_ __. __. ._ .._
nue _.. . . . . _. , _
) Alb~ '
4 A 6 1 % _-
=- - . . . . .-
A-A,wy,W 72/C 4 ---
t'
%A _u,, , 74 h_ Geo.y
% S. .A % %_ % , w 3 , h a n 44(L A 1 -
l TtyhL . nik v ,nu;n M MM __ _ . . _ . . . .
........_./ v/1//M e.r .... ._-
$ Y $ Af [*m M
- - _ . - . . ?d Tiwa O. m.t.se . . . . _ . . - AsAl_e.rtze.r ..
b h. e. r _ f c 1.... m a N. [ f a,. A t I C._ __
T(M. g,C._C l h. "Yok n _wounne.\ .Uts _. . .
l
._. WowA Le.f.n ..__ _ _ _ . . . . . _ . .... T t.S A .. . . . . . . . - .
, _0 Tg TgW . _...
. Te.sas U%GVs e4 . . . . _
^
_ NI(Ace N.. It&2A -- _ _ . . . _ .. . _ _ - L E / ( m 40c. w T ..
I OM l Mn vea.5. . . . .. . TIE S -
-- .. W. 00 or 1.'t _ . . . _ . . _ . . . _ . . . - - ..... D G C d. ._. . .. - _ . - .
~7~~u G 0 0 . . . . . . . - .
d..l6CLc d diny.
I U?d dio ._ _ . . . . . . _. .. . ...__.__.. N O M .-...__
' _ _f__
. ..=f.. .. . . ...._..m .. e. .a.* ... * ** N # * .u.
.- .....e . . . . . .. . . . . . . . . . ... .. ._
"e.'
i l t 4 l
. pac lmco- . Dec<msee s% :ger .. . . . .
Alaene. .. _ ... .. . . . _ . . . . . AfEGaM o n .
-. .FISc.
De& l' arty . . - - - - _ _ .... _-- . ..
C . T.hke _ _ _ . . . _ . . - . _ . . . . . . _ . . . . . . . . . . . D(LGiR.ii
< k '~b ed le y ... ._. . .. .... .... m 's M - '
~
f f. M d k
,]~efh . _ _ _ _ _ _ . _. . . _ . . . .._ . .. ... . .... 7V- 4 ._
O. K . 6 s-use-ll . ..._. _._ .. . . . . . . _ . . . . . . . . . _ _ . . . ._ .M G 5~ttd..E.&.... . _. ...._ . _ - . . . '7 W $ -. -- - .
. .Ao m Cs n s~ . . _ . . . =
OS . . - - . _
_ % & r.'t.. _ .. .
._ks R ( . . . . _ . . . .
._{q . . N.wwu __ _ ___ . hlBC. .-- EL.D __.
$ M 0 M4.N. btMt.,_ A_YR_& '~
, %Wes TJe : _ coHeg_c9.Idec&w Y h ,.
&j $h $ "
N* c.
Ja_.A. z, L , F_SH-/\o - JVA'C_.._
- .__r..r.,__a - , e c- -
O1 ._%1thnr.tll $C--
. .in co l S . M e w w n. .
NCC) u.
DAMrrA . EJ. A s1 M.TE *
. ]s e t. $l.I.IL 0AS2 . .-_
YW Att{A G .- . _ . . . . . ... ( W . S W -
. bR -
I k. /._A. M ~ i^'
. _ _ . . . .
- d<4 .e. ns= ret! _-- _ _ . - . . ... S .<r m 'd*JWWG S) h.-_
O %_. -
_ N M .. . ..._..
.__. DAME 3 N1.804'd. ._-. _ _ _ . . . . N$C. . . . _ . . . - . .
I h nne.k . Y e.rN -CCDK .----. _ . _ . .. . ._ A R . Q , . ... .- .
..l}3&*1GSric..lQ . . . .. . . . . . . .. . . .. .. - . .. ._ . . . .. . . . . . IT - Ett rgc)( .
b[_ h5"df [-- - ._.564dT . . . _ . . _ . _
160 . ..
._ m .M[. d' t o c_.) .Z) _. .. .. . . _ _ _ _ - . . _ . . . . _ . _._. _ .__24 C 4 i uti- . . . . LLC.AL/_~rM c o _
I 3
I PROCEEDINGS l
2 3 (This meeting commenced at 3:00 p.m.,
4 Wednesday, December 18, 1985, at the . , . .
5 Sheraton Hotel, Arlington, Texas.) ;,
6I "
s*
1
~
7 MR. NOONAN: Good afternoon. I guess we're here .
b::J S ;r today to talk to Texas Utilities and sort of get a status 9 briefing on progress they're making with the Comanche -
- j';
3G Peak Project. We're also going to talk a little bit [(
11 about the cable tray issue today.
12 I would like the people that are going to be .
13 speaking today to kind of introduce themselves. My name ?
14 is Vince Noonan. I'm the Director for the Comanche Peak
! 1 ". Project. :
16 MR. MARTIN: My name is Bob Martin. I'm the l '
i 17 Regional Administrator of Region IV.
j IS MR. WESTERMAN: I'm Tom Westerman. I'm the Chief of i i .'.
19 the Comanche Peak Region IV Group. !
20 MR. SEAO: I'm Larry Shao, NRC. .
21 MR. CALVO: Jose Calvo,'NRC.
1 22 MR. MARINOS: Angelo Marinos, NRC.
23 MR. BECK: John Beck, Texas Utilities. I'll serve f i
23 4 as our Master of Ceremonies here. ,
2; MR. COUNSIL: Bill Counsil, Texas Utilities ,
- * . - - . , _ _ _ _ _ . m
4 1
Generating Company. '
2
( MR. BECK: Any other speakers we have, we'll 3 >
introduce clearly before they speak.
4 MR. NOONAN: I'd like the record to also indicate 5 that Mrs. Ellis from CASE is also present at this 6 meeting, and we will allow the intervenor a chance to 7 comment again at the session tomorrow.
S I guess to start this meeting off, basically the
! first thing we'd like to talk about today is the cable 10 tray issue. I understand that Mr.. Counsil is going to be
!! addressing that from the Texas Utilities standpoint.
12 Just to set the -- the Staff went out and did an 13 independent audit. We came away with a listing of a j 14 number of findings that we felt that the Utility should l i
n have found before we were there in doing an independent I 16 audit. We told Mr. Counsil about our findings about the f 17 3rd of December. Mr. Counsil took immediate action to 1
i is look into the problem, and he's here today to kind of
! 19 talk to us e. bout it.
I 20 I'm going to have Mr. Westerman from Region IV kind 21 l of read into the record a summary of that NRC effort. ,
? )
3 22 MR. WESTERMAN: On November 18th through the 22nd of 23 ! '85, a group composed of NRR and Region IV personnel '
n ,
conducted an inspection of the Comanche Peak Unit 1 cable i
2; tray as-built program. The objective of the inspection -
i l
-- , ,,,_e
, ,y,-.- ,- -y-- - -- -,w-wp----r
5 I was to verify the accuracy of the as-built data obtained
( 2 by TUGCO project construction organization for the Unit 1 3 cable tray supports.
4 The inspection was based on the TUGC0 Nuclear 5 Engineering Procedure, TNE ABCS-1, Revision 1, September 6 30th, 1985. There were two teams composed of two NRC 7 personnel each, and one Ebasco expert. From a population j 8 of 789 supports with completed walkdowns, a sample of 32 <
9 cable tray supports were selected from the Reactor 10 Building, Fuel Building, Control Room and Safeguard 11 Building.
12 As a result of this inspection, deficiencies were il identified and major attributes associated with the I: redline as-built drawings for the Unit 1 cable tray ,
i n supports. The findings from the inspection indicated i
i 16 that the as-built program was not functioning as l
' 17 intended.
3 ,
I i is The Applicant informed Region IV on November 26th, E I
{ 19 1985, that work on the Unit 1 cable tray support as-built f
3 i t 20 program had been stopped. An investigation and
, 21 corrective action program had been initiated by the .
? I i
22 Applicant. Region IV and NRR are auditing the progress 23 l of the action. An NRC inspection report covering the i ;
24 Unit I cable tray support as-built program is being :
2, prepared, and final NRC actions with regard to this
6 l I
- matter are still pending.
i 2 I guess all I want to say at this point MR. NOONAN:
l 3 in time, and then I'm going to turn it over to you, Bill, 4 is that I was briefed by my staff on this matter December
, 5 the 2nd. I called Mr. Counsil's office on December 3rd 6 and ha took immediate action. I think he's here to tell 7 us about what those actions are. Bill?
8 MR. COUNSIL: I'm sorry that I have to stand up here i
9 in front of you, but this room is not set up so I can sit 14 over there and talk.
11 As Vince indicated, I did receive that call in the 12 morning on December 3rd. I had not been informed before 13 that time. My first and immediate response was to call i
i 14 the site to insure that work, in fact, had been stopped. ,
!' In other words, I issued a stop-work order on top of.
! I In The second thing was to work with the site personnel -
[ 17 via phone initially to work out an action plan. That i
! 15 action plan basically was to, number one, confirm ,
19 whatever, the NRC findings, if it were possible to do so, l f i i l
- 20 and as soon as possible. Secondly, to try to confine the
~
i .
, 21 problem, if it could, in fact, be confined.
i 5 l 7 22 Consequently, what was done immediately was to come up I
23 with a sampling program of the Unit 2 cable tray effort 23 and start there first, using qualified Level 3 l i 2: Inspectors; and in addition to that, to look at the Unit j
i
- . . , - - . . - . - - - - - . - , - -.-n g , , , , ---...,,..-,-,,--,y-.-,-,-v.--. , . , - - , ,
7 I
2 conduit as-built program. Subsequent to all that was i 2
to follow up, if we had teams available, and do an 3 additional sampling of the Unit 1 cable tray effort.
4 After that got underway that day, I also looked at 5 other areas where potentially that problem may exist.
6 Consequently, that resulted in a call from myself to Ed 7 Siskin at Stone and Webster Engineering Corps because 8
they were doing walkdowns on the as-built piping program.
Subsequent to that effort on December 3rd, one of the 10 workers that was doing the inspection work in the i
11 engineering side of the house, an employee of Ebasco, l I
12 came to one of the members of my supervision with some l
13 facts about the program. Those facts given to us had to I4 be confirmed or misproven, whichever, and consequently 15 with some of the information that was, in fact,
! 16 transmitted to us, I called Corporate Security and
[ !! started with Corporate Security to do an investigation i l i 15 into the allegations that were given to us. <
I l j 19 In addition to that, I used my executive assistant, l
, i ;
r 20 John Streeter, to conduct interviews of personnel on
, 21 site. I, in turn, last week spent four days on site to i
i 22 go out and look at cable tray supports myself, as well as l
23 to head the investigation.
21 ; ,
What did we find? Well, I want to preface what I 2r, found with the words, "These are' preliminary findings." i I
8 I
I'm basing my corrective action on preliminary findings, l 2
and today I'm only giving you a summary report on the 3
details to which we went.
4 We interviewed personnel and the quality -- the 5
engineering - not quality engineering but the 6
engineering effort - and we interviewed people in the 7
quality control area all the way up through supervision.
}
8 to find out where could this breakdown have occurred or 'i a
y 9
could we, in fact, prove that there was a breakdown, i 10 I have completed a 60-support sampling of Unit 2 , l_.
1I cable tray hangers. I have completed conduit support 1.2 samplings on Unit No. 2, as well as a 60-support effort I3 on Unit No. 1.
I found deviations from as-built program I4 on Unit No. 1. There were some deviations on Unit 2 and 15 on the conduit supports on Unit 2, but very small numbers 16 compared to the Unit 1 effort, f
17 f In working with Stone and Webster, I do not feel i
i 15 there was any breakdown on that portion of the walkdowns, I
j 19 so consequently I do feel that any breakdown that did
.i r 20 occur is isolated to the Unit 1 cable tray efforts.
, 21 Trying to find out what went wrong resulted in a i
I procedural review.
22 Looking at the procedures, the two 23 programs were different. Unit 2 was treated differently 24 from Unit No. 1. Unit 2 procedurally has an engineer and l; f
f
.5 >
a craft worker inspect the supports. They redline the l
9 I drawing for the support. That drawing is then put onto 2 the computer-aided design system for a final as-built
( !
3 drawing. Only when that drawing comes back do the QC !
4 i teams then go out to verify that the support was i
5 correctly as-built.
l t
6 In the Unit 2 program, however, we were finding some !
7 months back computer-aided design errors, more than we S felt we should; and some of those errors had to be 9 corrected by engineers. Consequently, the procedures for i
10 Unit 1, when we started that program, were changed to put i
!! Quality Control and an engineer on the same team. ;
r ,
12 The procedure called for those two people to make ,
i 13 independent verifications. The engineer was there in ;
14 order to answer QC's questions, but he was also supposed j i
15 to do an independent verification of the redline himself. ;
j 16 One of our supervisors in the engineering side of I
[ 17 the house misinterpreted the procedure on Unit No. 1.
1 i l' Bis interpretation was that the engineers were recorders
, E i j 19 and there to answer questions, and only Quality control '
- 3 20 should, in fact, do the inspection. That was wrong. ._
i r">
21 Instead of two sets of eyes,'two sets of determinations, !
I i
i 22 we had one. '
23 ,
In addition to that, the engineering supervisor, in i 24 ;
our opinion, puts undue pressure on his engineers -- not 23 Quality Control personnel; he did not supervise the ,
, . l 10 l i
I Quality Control people -- and by pressuring them, he gave i 2 them a quota of a number of inspections to do per day.
i 3 :
l If they fell shorr of the quota, they were visited by him 4 to say, "Get up to the quota." That, in turn, did, in 5 fact, cause - our opinion again - a speed-up of the 6
program.. And obviously in the Unit 1 cable tray effort, 7 quality suffered. The quality as-built program auffered.
i S
That engineer is no longer on site,_ that engineering !
" l supervisor. :
t 10 There were other breakdowns,in the program. With 11 the program change that we had done, between the Unit 1 12 and Unit 2 programs, what should have been done is we !
13 should have had quality surveillances on top of those !
1: inspection teams to insure that they were carrying out
- j ;
i 1; l the program correctly. There was a very informal i 16 program, and it was not formalized at all.
{ _
, It is now
[ 17 being formalized.
j l 1 i 1
! Is In addition to that, there should have been QA l
i [
i 4
,I s
19 audits done. Through a misinterpretation, the QA audit t
20 plan did not include audits. Corrective actions to the
, 21 program at this point in time - again, I want to stress
?
i 22 preliminary because all interviews are not done yet.
l 23 I some of the people involved in it are on vacation. I l 2.; can't get them, as f.ir as interviewing and to finish up I
- I 25 this whole process, for about two weeks. So we'll be
4 11 i
I completing by the end of the year. And if there are 2 revisions as a result of, or we find something else, we i
3 will make revisions for the corrective action, but right ;
4 now corrective action consists of: We've gone back to ;
5 the Unit 2 program, period. Procedures are being revised '
6 even today. There will be a craft worker and an engineer 7 doing the initial inspection and redline. That will then t
8 be put into the computer-aided design system on site. We 9 will have an as-built drawing, and only then will QC go 10 out and verify it. We will reinspect all 1800 supports
!! that had been inspected on Unit No. 1. In addition to 12 that, I have doubled the number of quality surveillance 13 personnel from 6 to 12. They will be doing surveillances '
11 on the teams doing the inspections.
15 In addition to that, the Quality Assurance I 16 Department has them on their audit plan. The audit will 17 be verification to procedure and actually do some in- l E i l i 14 process insp47tions, in addition. ;
i i 19 That's the summary of the report right now, and I l I
20 presume that once I get your inspection report, I should
, 21 be done and I will be able to' follow up in writing as to ;
! l i 22 what is occurring.
23 MR. NOONAN: What are the implications for Unit 1 as i l .
2-1 far as going back and looking at what's been done?
23 MR. COUNSIL: How do you mean that, Vince? j
l.
12 I
Scheduling or -- ?
I -
MR. NOONAN: Yes, a scheduling standpoint. Have you 1
3 figured that out yet -- !
1 4 MR. COUNSIL: In taking a look at it, I physically ;
5 went out and crawled many of those supports myself. It 6
is not, in many cases, easy to get to them. I personally 7 believe that the engineering team and the QC team, once S
i those packages come back, will be able to do 9 '
approximately two per day, and with 25 teams working, 10 after they're retrained, with the 25 teams, I feel that
!! overall they'll be done with that part of the program >
12 probably in an early-April time frame.
13 MR. NOONAN: Okay.
3 You said here that this is all 14 preliminary. Do you have any indications as to when you
!; think you'll have it finalized?
{
16 MR. COUNSIL: After Christmas. Some of the people
- 17 that I do want to have interviewed are not going to be i
i 15 back until after Christmas week. They'll be back.the 5
i 19 30th. '
i
- I 20 MR. NOONAN
- Okay. ,
, 21 MR. SHAO: How would the findings affect some of the i* .
22 analyssa that you have already completed?
23 MR. COUNSIL: Most of the analysis that's already 2- been done, Larry, has been done on Unit 2.
t F MR. SHAO: I mean Unit 1. .
---m --
- - - ,r ..--* , , . - - . ~ ,,y-,. ---,.---.w .<-,.,--,,-------+,.c- - - - - - - - - , ,..----m- ------w- %-
i 13 1
, MR. COUNSIL: I know that. What I'm saying, a lot
! 2 of the analysis that we've already done was testing out 3 the program and is on Unit 2. The as-built program on 4 Unit 2 is okay. As far as Unit No. 1 is concerned, if 5 there were any supports on the trays, if any analysis has 6 been done on those supports and the tray runs themselves, 7 they'll have to be redone. !
S MR. SHAO: You have no idea how many have been done? !
9 MR. COUNSIL: Very little, because at the time of to your inspection there were only 849 or 850 hangers in the '
11 vault, and until they're vaulted, we don't run the 12 analysis. And that also says that they aren't 13 necessarily the ones that are in sequence, such that I 14 could do a string of the tray analysis, because it's not i
- 1. necessarily done by a single hanger analysis. Some of it 4
{
16 is, but much of it is the dynamic analysis on a stringer 17 tray. I don't think a lot has been done, but I don't --
)
. i '
i 15 MR. SHAO: But you think it is very minimura.
i j
I 19 MR. COUNSIL: I think it is minimal on Unit 1, but
! i
, l !
- 20 if there were any done, depending on what we find, I
, 21 would have to say that that analysis would have to be
?
7 22 redone.
23 MR. NOONAN: Are there any other Staff questions?
l
' l 2; Bill, we don't have any other questions. We've been i l i
i l .
s l at the site, and we've been following closely what you've
~
- - q I
)
14 l
I been doing. I think what I'd like to do at this point, if you don't mind, is basically we'also have a concern l
3 with Unit 2. We looked at Unit 1 and we found the 4 ' findings we had. We wondered if that carried over to 5 Unit 2. Last week we brought an NRC team of people down 6 here -- NRR people, consultants -- and I guess at this 7 point in time, if it's okay with you, I'd like Charlie-8 Trammell to speak to that effort.
9 MR. COUNSIL: All right. Fine.
10 HR. TRAMMELL: I'm Charlie Trammell, NRC, As Vince .
!! said, we formed a team ourselves, David Jeng and myself. '
12 We formed three teams to look at cable trays on Unit 2, 13 cable tray supports, because we wanted to see if the 14 types of observations that Tom Westerman found earlier ;
i is carried over to Unit 2.
'i 16 So in the time available, we spent a day and a half ;
[ 17 looking at the cable tray supports. We looked at a total i l i B of 21. Most of them were picked at random on Unit 2. ,
fI 19 The ones that weren't at random were picked on I
20 engineering judgment, so we didn't look at the same type
,' 21 of hanger or support twice.
4 4
22 Of the 21 supports we looked at in the day and a ,
i 23 l half that we took, we looked and saw about a 1,000 .
- attributes or observations on each of the hangers. Of l 2, those numbers of observations, we only found 11
15 I
attributes that were out of tolerance with the as-built l
l 2 I drawing, which was about one percent of the number of 3
observations. The deviations that we did find - we 4 haven't finished looking at it -- but they appeared to be ;
5 structurally minor, not structurally significant.
6 In general, we did not find the types of problems on ;
7 Unit 2 that had been reported earlier on Unit 1.
S MR. NOONAN: I guess speaking for the Staff on this 9 matter, whenever the Staff goes out there and looks, we i
Ic always find something that we can report on, so it's not .
11 unusual. I think what made us satisfied with Unit 2 is 12 the fact that we did go look. What we did find was che 13 things I expected we would find anyway. Nothing unusual.
1: The numbers that we found, the types of things we found, 1; would probably be found in any inspection anyplace. It 16 indicated no real problems with Unit 2.
1
[ 17 I know you are working to complete your i
i l' investigations on Unit 1. I guess at this point in time j 19 I don't have any further things to bring up to you. I l i
t 20 would suggest maybe at the next public session you could l
, 21 talk a bit more as to what you did do, !
3 .
I 22 MR. COUNSIL: Fine.
23 MR. NOONAN: Any other Staff questions? i )
2; I think with that, Bill, let's go ahead and proceed s
2, with the rest of the agenda.
l i
16 I
MR. BECK: The next agenda item is a report from Ron 2
Klause of Stone and Webster Engineering Corporation, 3
Project Manager for the Comanche Peak piping system and 4 support reanalysis. Ron?
5 MR. KLAUSE: I'd like to give you the status of our 6 requalification effort. The stress problem production 7 continues on both Unit I and 2, with all work that's been 8
completed to date being marked as confirmation required, pending resolution of technical issues and finalization 10 of the design criteria and Projec,t procedures.
Currently there are about 250 pipe stress problem.3 12 in progress, with 100 of those reaching the confirmation-13 required stage. Over 2,000 supports are in progress, l'
with 500 of those being completed as confirmation- ,
1; required. This was the status as of December 1st.
I 16 Also as of December 1st, the technical issues that
[ !! affect this analysis, all that have been a restraint to j
i i !S the pipe stress analysis have tentatively been resolved; .
t i
{
19 and also all technical issues that affect the pipe I 20 support work requalification, with the exception of a
, 21 couple, have also been tentatively resolved.
i j 7
22 Now, as this resolution methodology is made l 1
3 available, we're incorporating that into the Project i l
i at design criteria, CPP-7.
[
2S Also, as I reported in the last monthly status
- _ _ . , _ . z ,_. .-
l 17 l I meeting, the walkdown by the experienced engineers was to 2 take place on Novomber the 12th. That walkdown did take i l
3 place as scheduled, and is now being completed. The I i
4 scope of that walkdown included 50 pipe stress problems 5 that were selected at random, and an additional 20 pipe 6 stress problems that were expected to see significant, or 7 any fluid transients, were also included.
8 So we trained the team in the walkdown procedures.
They were familiarized with the technical issues and also
! 10 *the design criteria as being used in the requalification 11 effort. You might recall that the purpose of that 12 walkdown was to, number one, determine whether any other ,
i li technical issues might exist out there, other than the ,
i 1; ones that are currently identified; and, number two, to l '- have SWEC personnel determine whether or not any l
l 4 i 16 modifications might be required to be made for the j i
[ 17 reanalysis procedures, the design criteria, or any of the i
i is guidelines that are being used in the requalification l 1 i j 19 efforts.
! i t 20 i Now, we had 20 men, engineers, selected; ten pipe l . l
, 21 stress engineers and ten pipe support engineers that were ;
@ l 22 selected based upon their experience and expertise to 23 walk these systems. Now, they were instructed to fill 21 ; out observation sheets for each of the 70 problems. We I
- - are now cataloging these observation sheets. We're t
18 l
I sorting them out into diffur ' types of observations l
2
! made. We are now into a validation process to determine 3 if, indeed, the observation was the correct observation, 4 and then we will be assessing the findings of the 5 walkdown.
l 6 Now, even though this evaluation is not complete at !
l l
7 this stage, it's still in progress. We do know that i i
S there's going to be some minor adjustments that are going 9 t.o be required to be made for our reanalysis procedures.
j 10 These are administrative in nature, just to make sure
! 11 that we have the proper design input for the reanalysis i
1' effort. The final report will be in progress, or is 13 beginning to be in progress here, and we will inspect 14 that at a later date.
11 Are there any questions?
i 16 MR. SHAO: Let ma say something about what the Staff i
! 17 did. On November 13 and 14, in the piping and pipe i I l i is support area, the Staff audited the activities associated i i
! 19 with as-built documentation. We also audited the i
i l
t 20 implementation of the Stone and Webster procedure, CPP , l
, i l , 21 Number 8, piping walkdown procedure. This review is in
!' 4 ~
i 22 Progress right now. In addition, the Staff is also ,
23 auditing the status of the Stone and Webster piping 24 ,
support requalification effort.
I r, t The one question I have is: When would TUGC0 or .
l
19 3
Stone and Webster issue formally the audit procedures so t 2 that the Staff can review formally the audit procedures?
3 MR. BECK: Are you talking about the TUGCO audit 4 procedures or the Stone and Webster --
5 MR. SEAO: The Stone and Webster so-called design 6 analysis procedures. As I understand, it was submitted 9
7 to TUGCO a couple of weeks ago but has not been released 8 yet.
9 Soon.
MR. BECK: !
i 10 MR. SHAO: How soon?
i l 11 MR. NOONAN: I guees to kind of follow up, the Staff 12 has been doing a lot of auditing with the Stone and 13 Webster organization, so I guess it is the opinion of the !
! 14 Staff that we were satisfied with the Stone and Webster I
15 walkdown. We've been following it very closely, and in I I 16 regard to any kind of similar type of problem occurring !
[ 17 on the Stone and Webster work that we saw, we feel that h that's not there, that indication is not there. We don't
- i
-j 19 have any particular problem with that.
!' i .
I 20 Bill, I'm just going to ask you to -- are you
, 21 Prepared to continue on with 'the rest of the agenda ;
$ I i 22 today? l 23 ,
MR. BECK: Vince, we're not. We'll be prepared to i
, 2; start tomorrow morning at 8:00 and have the schedule that
- 2. , should be ready by 1:00, ne later than 1:00
- . - . - . e ,. n- __.,,.--_n - - - - . . , . , - , ,_, ---,,,-,n---. - - ,. ,-,.,.-._-..n,_. ,_n ,
20 I
MR. NOONAN: Mrs. Ellis has asked if we could start i 2
at 8:30; is that all right?
- 3 MR. BECK: That's fine.
4 I MRS. ELLIS: Wasn't it 8:30 when it was noticed 5 before?
6 MRS. VIETTI-COOK Yes, it was.
7 NRS. ELLIS: I don't know who will be here, but I-
- 8 sent that out to some people.
9 MR. BECK: 8:30.
l t 10 MR. NOONAN: I guess with that, Bill, I don't have ; ,.
li anything further to discuss today. I think we'll start '
12 the regular status briefing at 8:30 in the morning.
13 Are there any other Staff questions?
14 Okay. I think we'll stand adjourned until in the 1; morning at 8:30. ;
}
16 (The meeting was adjourned at 3:30 p.m.,
17 to be resumed at 8:30 Thursday morning l [ !
t i
! it December the 19th, 1985.)
i
- i kh
- i t 20 l
, , 21 '
' I 22 21 2:
25
1 21 l I PROCEEDIIES l 2 i
I 3 (The meeting was resumed at 8:45 a.m.,
i 4 Thursday, December 19, 1985, at the l
5 Sheraton Botel, Arlington, Texas.)
6 l
7 MR. BECK: Good morning. John Beck with TUGCO. Our 1 .
S i presentation this morning, Vince, is going to consist of 9 four basic components. The first will be an overall CPRT l
10 status. Terry Tyler, the CPRT Program Director, will 11 handle it. Terry will then go over the second aspect of 12 the presentation, the TRT issues specific action plan l
Il status, and cover all of those aspects.
11 That will be followed by John Hansel, covering 2
i i I; quality of construction status, and Mr. Howard Levin
! ! 16 covering the design adequacy status. !
l 17 l
[ Everyone should feel free to ask questions at the
, i l
! i l' appropriate time.
i i j j 19 MR. NOONAN: I guess, John, the only addition to i l j
r 20 that: After some appropriate time, maybe after you're ;
i i
4
, 21 done, the staff will have a c'eport on their input and t 8
2 22 findings.
23 ,
MR. TYLER: Good morning. The CPRT has been i 21 , involved in a number.of major activities that have taken
.l f I
- 2. , , place since we last met and reported the status. In l
_--_m _ , . _ , , - - . - - - _ . . . , , . . _ _ _ . _ - - , , - . - - - _ , . _ _ _ . . . ,
,%____mnr ,,,.._.____,--._m__,-,,,_m,_,.,,-_-,.y,r,,,,-.
-. , , , . , . _ . . , , . , -.,,w,n.-
w,-o
D 4 22 i !
3 l general, we have participated in numerous audits 2 conducted by the internal QA groups within Mr. Levin's t
3 i Design Adequacy Program area and Mr. Hansel's quality of 4 construction area to check on the internal consistency 5 with regard to the way we're implementing the various '
6 aspects of the program. ,
7 In addition, we participated in numerous audits that 6 the NRC has conducted. In all three aspects of the 9 program, the TRT issued specific action plan i !
3 10 implementation of the Design Adequacy Program and the
- 11 Quality of Construction Program. I 1
12 In addition, the Review Team Leaders finished 13 preparation of, and the SRT reviewed and concurred with 14 the responses to, the NRC questions on the CPRT Program ;
t li Plan during this period. As you know, those responses :
I 16 were submitted to the NRC on November 22nd.
[ 17 Also, the SRT met on November the 21st and 22nd and l I
- Is reviewea anc contirmed that the Design Acoquacy Frogram
- 19 scope is consistent with the objectives of the Design j ! 20 l Adequacy Program as stated in the Program Plan.
, 21 A week later, on Novembe'r 25th and 26th, the SRT 8
1 22 reviewed and concurred with the homogeneous construction 23 l work activity description and the quality of construction ;
i 1 2: self-initiated inspection area.
2_ . In addition to all these other activities, the
23 I
Review Team Leaders and the Senior Review Team has been
( 2 involved in reviewing, in preparing and reviewing, 3 various revisions to the Program Plan, which we hope to i
4 issue by late January of this year. ,
- 5 I'd like to take a moment to preview some of the 6 changes that you will see in Revision 3 to the Program i a
7 Plan. In general, it's a revision to incorporate the f
8 responses to the NRC questions.
j In some areas the 9 changes are minor. In some areas they are very major.
10
- To highlight the major aspects, all of the action plans l l
11 utilizing sampling will be revised to state the question 12 the sampling effort intends to answer, to address the 13 homoganeity of the population being examined, and to I8 reference Appendix D, the sampling appendix to the li Program Plan, for an explanation and guidelines as to how l
16 sampling is implemented. Where we deviate from Appendix l
! i
[ 17 D criteria, the basis for that deviation will be stated i
i is in the action plan. '
j 19 Appendix A to the Program Plan, the Design Adequacy i
- 20 Program, is being revised to address the design adequacy I
. 21 scope and methodology questions that the NRC posed.
- i 22 Appendix B is being revised to be consistent with i
! 23 our responses to the NRC questions on it. That's the .
I j 21 l Quality of Construction Program Plan description. ,
j 25 You will see at least one new issue specific action
_ - . . _ _ _ _ . _ _ _ . - . , . - - _ , - . , _ . , - - _ ~ - , , _ _ _ _ --___.~ . ~.--_.-
24
! plan in the area of craft training. It will numbered i I
2 Action Plan I.D3. !
l 3 Discipline Specific Action Plan 6 on the civil l l
4 structural design adequacy area will be revised to l 5 appropriately reflect on-going activities, including the 6 involvement of the various organizations; that is, I 7 Ebasco, IMPELL, Project, and the Third Party.
S Appendix D on sampling is being clarified to state 9 the various sampling methods used in the CPRT Program and 10 , to address the NRC's specific questions. ;
II Appendix P on interfaces, which was submitted in the 12 original Rev 2 of the Plan, as we stated in there, was 13 incomplete. We have finalized the interfaces, and that 13 will so be reflected in the next revision.
l' Appendix G to the Program Plan is new. It is'the j 16 CPRT Third Party QA program description. j l
17 Appendix H to the Program Plan is new. That's the .
I
, I t i is CPRT procedure and policy for the development, approval e
! 19 and confirmation of implementation and corrective action.
.: l
- 20 I want to point out that revised Appendices E, F, G
, 21 and H were submitted as a par't of our responses to the i
8 7 22 NRC quections.
23 As I said, we anticipate submittal of Revision 3 of ,
2.! ! the Program Plan in late January. It will be a complete i
2, reprint of the document with change bara for subsequent
25 I
changes in the margin, with taba ao that it can assist us 2 *
- in getting through the Program Plan itself.
3 This concludes what I want to say about the overall ,
4 CPRT activities. I now would like to move on to a status l
5 of the issue specific TRT Action Plans. I will not be 6 giving a status on Action Plan I.Dl, QC Inspector 7
Qualifications. Mr. Hansel will cover that in his ,
8 !
presentation.
9 The Staff requested that we provide a more detailed 30 I status on several action plans. I will do that 11 throughout this presentation. Those are Action Plans j 12 II.C, debris in the gap; Action Plan II.D, the control l I3 l 4
room ceiling; Action Plan V.A, skewed welds; Action Plan ,
i 14 v.D on plug welds.
i l 15 Electrical Action Plans: There are eight of them.
I 16 There's I.Al through I.A4, I.81 through I.B4. They're !
l 17 all in the Results Reports' results evaluation stage. ,
1 i is As we said in our last meeting, we have a new Review
, e I
- l 19 Team Leader in that area, Mr. John Malanda. John has ,
- i
- t 20 been reviewing the files, reviewing the action plans for
, 21 consistency, and we are in the process of finalising some l 3 !
) 22 of those Results Reports. We anticipate that we will i
I
! 23 start some of the el,ectrical Results Reports through the .
1 ,
24 i
SRT approval process in January.
I
' l 2> Testing Issues Specific Action Plans III.Al through
- t
26 I III.A4, III.B through III.D, are in a similar status to ;
! 2 the Electrical Action Plan. The investigatory phase of 3 those action plans is complete. We are evaluating the 4 results and in process of preparing the Results Reports.
5 We likewise anticipate some of those Results Reports will l 6
6 go through the SRT approval cycle in January.
7 One action plan, III.A2, is currently at the SRT for 8 review and approval at this stage.
9 Civil Structural, Mechanical, Miscellaneous Action 10 Plans fall into basic categories. There are 13 plans, j ,
11 total, in this discipline area. We have 7 of those 13. .
12 Action Plan II.A on the reinforcing steel reactor cavity; i 13 II.B, concrete compressive strength; II.E, rebar in the
!* Fuel Handling Building; V.B, shortening of the steam ,
I 6
l '. generator upper lateral anchor bolts - I'm sorry -- V.D,
- I 16 plugs welds -- excuse me. I've gotten out place. Action 17 Plan V.A on skewed welds, Action Plan V.C Category 1-l
, 1 I
i is Noncategory 1 piping runs between buildings, V.D on plug 19 welds, V.E on the installation of the main steam piping. ,
i r 20 The investigatory phase of these action plans is
, . i 21 complete. We're in the process of evaluating the results s 22 and preparing Results Reports. Likewise, several of 23 these action plans we anticipate will go to the SRT for 3; approval of the Results Report in January.
I r , The remainder of the action plans in this category
27 j
- t I are still in the investigatory phase. Action Plan I.C, i 1
2 l train C conduit, engineering evaluations, walkdowns for l 3 I sway interaction. Third-Party overviews of those i
4 activities are on-going.
5 Action Plan II.C, debris in the gap between the 6 buildings. Activities in that action plan are pretty l ,
I 7 much centered on the Project side with Third-Party 1 i
8 overview. Cleaning of the gap is progressing well. I 9 The Fuel Building to the Auxiliary Building wall gap to is approximately 50 percent clean at this point in time,
!I and from Elevation 890 down to Elevation 852 is 12 completely free of debris. We are working on remoni of 13 the debris between Elevations 852 and plant grade at 11 Elevation 810. As we reported earlier, there are some j i
1- large plugs of concrete located around the 810 Elevation. I I
i 16 We anticipate sawing of that concrete plug with a 17 diamond-impregnated wire cable. We'll begin sometime in i
i is late January. Delivery of that cable is currently the t i
! 19 critical path toward getting those large plugs removed. l
}
- 20 We anticipate completion of the debris removal sometime
, 21 l in late February. ;
i i
22 To date, we've utilized all pneumatic tools, 21 grinders, circular saws and high pressure vacuums for the ,
21 ; debris removal. Portions of other wall gaps have been
(
2: cleaned, namely the Reactor Building, the Fuel Building,
28 i
I the Reactor Building, the Safeguard Building gaps. The j 2 debris between the Fuel Building and the Aux Buildings is 3
considered the most difficult debris for us to remove. l 4 Based on the results that we have seen to date, we do not j l 1
l 5 anticipate problems at this time with regard to being i 6
able to remove all the debris. ,
i 7 Action Plan II.D, control room oeiling. Structural !
i 8 and architectural design of the new ceiling is complete.
I 9
Third-Party review of that design is on-going at this i 10 time. They have started installation of the ceiling. ,
II The structural steel base plates have been attached to 32 the slabs above the control room ceiling, and they are in ;
4 l 13 the process of repairing general fabrication drawings to l l
!? start the installation of the remainder of the support
} -
i
! 1 ** steel to the ceiling.
! 16 Action Plan V.B --
i ,
[
I; MR. SHAO: On the control room ceiling, have you l !
i i i j e
l' i
looked at the generic implications of this problem?
(
! l 19 MR. HANSEL: Larry, could you be more specific? -
i i i 20 There's a couple of issues there. !
1 j 21 MR. SBAO: The control room is mainly seismic class l
!{
i l
i 22 II, also non-seismic events, non-seismic components, what t
i 21 ! the effects of non-seismic events on --
1 i 24 ,
MR. HANSEL: Yes, okay --
i t '
j 2 *, , MR. SHAO: Have you looked throughout the Plant?
1 1
29 I . MR. HANSEL: Yes, we've looked at the full scope of
- 2 the Comanche Peak damage study, including the Program as 3 defined, as well as we have had '.hird-Party people go out 4 into the field and they've taken with them the j 5 interaction of the packages, documentation packages, that t 6 show the interactions, and we've been in the process of 6 7 verifying that infors.ation.
S
{
MR. SHAO: Have you found similar problems in other i areas?
10 MR. LEVIN: We have found that the Program as l
!! implemented, implementation of the Program, is generally f 12 very good. The areas that we have questioned have to do 13 with input into the Prograin. Some of the assumptions 18 that guided the efforts, i.e., the criteria by which the
" people went into the field and identified some of tihe 16 interactions. And that's very much related to the
{
17 initial problem that TRT identified. For example, the ;
[ii 1% I.C conduit issue where there was an assumption that
- I j 19 conduits of two inches and under would not produce an i
r 20 undesirable interaction. We've been in the process of ,
1 21 verifying the adequacy of that assumption, so I'd say -
I 5 22 that the areas that we're still investigating really 21 ,
relate to some of the inputs into that study; but the ,
2; ! study as implemented, given the inputs that we've f
23 i defined, appear to be very good.
I
l 30 i
t 1
MR. SHAO: In this issue there was some problem ;
2 related to analysis of Category 2 structures and !
- 3 l components. Did you look at other Category 2 structures l 1
- 4 and components analysis?
5 MR. LEVIN: Yes. We particularly focused on 6 architectural features. There are some -- I'm not sure 7 of the exact number; 60 or 80 categories specification-8 wise -- that have been looked at by the Project. There i
)
9 have been certain areas where some remedial work will be i 10 done to assure no undesirable interaction. But that's 11 the principal category that may not have been adequately ,
i 12 dealt with in the initial damage study, but we are 13 looking at all Category 2 items.
14 MR. SHAO: A lot of Category 2 analysis was based on j 15 current static analysis. The question is: Have you 16 looked at all to see if they are good analyses?
l l [ 17 MR. LEVIN: We are looking at those analyses.
i f 18 Current static analysis, as you're aware, is an 19 acceptable method. We are verifying that, in fact, it t
t 20 was properly implemented. The fact that current static 21 analysis may have been used,'to me, is not as specific an
- 22 issue, but the way that they are applied, does that 23 represents an adequate method of qualification? ,
MR. SHAO: Can we come perform an audit on this --
l 24 25 can we come to have an audit on this Category 2 analysis?
i I
I
31 3
MR. NOONAN: Larry, we can't hear you.
I 2 MR. SHAO: Can we come over to have an audit of some 3 of the Category 2 analysis?
4I MR. LEVIN: Certainly. Maybe we can get together 5 and have a common understanding as to where we stand so 6 that your expectation of what you're going to see is in i 7 line with the status of the Project, but certainly.
S MR. JENG: I'd like to follow up on a couple of 9 points, assuming -- have you finished your ISAP Status I 10 Report? If you haven't, I'd like when you're finished, j 11 I'd like to ask a few questions. My name is David Jong, I'
12 NRC Staff. Have you done your ISAP --
13 MR. TYLER: No. ;
) 14 MR. JENG: Please continue. [
I ". MR. TYLER: I only have a couple of more, David.
! I 16 The next Action Plan is V.B, steam generator upper
' 17 lateral restraint. The analyses of the final design fix l ,
I for the steam generator upper lateral bolted connections
< is
! 19 is still in process. We espect that finalized and a
\ l r 20 report out in January.
, 21 Action Plan VI.A dealing with reactor pressure 7 22 vessel reflective insulation. We have several activities 21 ongoing there. The Third Party is in the process of j 24 reviewing the non-safety-related design changes that the
- t 2, definition of the population of non-safety-related design
l 32 1 . 1 I I changes that could have an impact on safety-related !
t 2 equipment. After that is completed, a sample will be l 3 selected and reviewed.
i 1 4 Also, we're in the process of finalising the i i
l 5 critical gap inspection targets at the plant. Once that j 6 is complete, we will go out and reinspect the critical 7 gaps for debris. . !
I 8 The last Action Plan is VI.B dealing with the polar l ,
crane shims. The Third Party is in the process of l l 10 ,
reviewing the original calculations for the girder, the t
11 ' girder design. The tests for the rail movement have been ,
) 12 ' completed, and the rail restraint design is in process.
i !
! 13 That concludes my portion of the presentation.
, r 11 MR. JENG: With reference to ISAP II.A, missing I
13 rebars on reactor cavity. I understand you have looked i
! i 16 into specifications of known missing robars through
\ \
' 17 searching of NRC's, and there are some 18, 19 cases, and
{
- l. ?
I i i is you have evaluated each and every one of those NRC's to s
I 19 assure yourself that the engineering configuration was l '
- l l
r 20 adequate. l 21 In addition, I understan'd -- if I'm wrong, please '
- i i 22 correct me later -- that you did look into the procedures i 21 covering those analyses and NRC searching reverification.
I i i; My question to you is: What is your philosophy or basis e
i 2- for assuring that there are no unknown missing l
l
)
33 I
reverifications? And if we are doing something in '
l 2
addition to what you have done, how can we assure that ,
i
! 3 there are areas which may have missing rebars but yet j 4 unknown to us? And what are you doing in that area to
- 5 assure that everything is covered adequately? I 6
MR. LEVIN: David,,there is one major activity that 7 you did not include in your list. Your list is fairly j i
6 complete, but it has to do with our review of the Pour Records. A Pour Record is a card that is documentation I i 10 of various things prior to the pour, including the li appropriate drawings to which the rebars were inspected 12 prior to the pour. In view of the fact that many things i
l Ii 3 related to the concrete area are inaccessible visually at 14 this time, what we thought would be appropriate would be li to look at other documentation for consistency to assure
,I 16 ourselves that, well, we had an NCR process that was i
l !" working, it identified 19. That wasn't sufficient for l 1A us. We wanted to be certain that, well, what if the 19 system did not detect certain other ones? So we asked '
\ i r 20 ourselves the question: What other kind of information
, 21 could give us some insight into that problem? So we went i i 4 l
! 2 22 to the pour cards, looked at the rev of the drawing to {
21 l which we poured, and then compared that to the existing 24 revision. What we were looking for were any changes in :
- I !
.' rebar configuration, and if there were any between the
_ , _ _ _ _ _ , .. __ _, ,__..,r. _ _ _ _ _ . _ . _ - . _ . _ . . . - - _ _ _ _ _ _ _ _ . . _ - - . _ _ _ _ _ _ . . _ - - _ . _ - , . _ ,
! 34 I
! existing -- which is the design today -- and what we l
! 2 poured, then we would have an indication that there 1
j 3 -
potentially could be missing rebar.
i
! 4 We've been through that process. We had a random i '
j 5 sample of pour cards, and we were unable to detect any !
1 6 such discrepancies. We have been giving some f 7 consideration, and it's , currently before the SRT to the i 8 question I think you're posing, and that.is: What l i
j 9 additional confidence could we get on this problem? I l
]
10 have to say that we have no indic,ation from the NCR [
11 Review from the standpoint of questions about the j 12 technical adequacy of the disposition of the 19. We were ,
' 13
, unable to find any discrepancies in the pour card review.
14 I would say that it looks very good. It's a question of
] n additional assurance. We're giving consideration tio some i
l I 16 of the points I think you've brought up in our audits in
. i l .
l [ 17 the past about ways of getting additional insight. ,
j .
! j l l : .ls MR. JENG: You say something more specific beyond !
19 just some consideration, or you are not prepared?
l t 20 MR. LEVIN: I'm not prepared at this time because l 21 it's before the -- I've ident'ified the issue to the '
f!9 22 senior Review Team, and the team is considering what, if r
y any, additional work may need to be done to provide l l 1 i y assurance beyond that which we could provide from the
- l f '
23 initiatives that we have completed to date. ; i I
i
T t i 35 1
MR. JENG: So we can expect some more definitive i 2 answers will be forthcoming.
3 .
MR. LEVIN: Absolutely. +
i 4 MR. JENG: I'd like to move on to the next item. l l
5 MR. HANSEL:
David, this is' John Hansel with the 6 CPRT. Through our concrete placement population, we will j 7 also be gathering significant data in each of those l 8 pours. We are as well looking at the pour charts and all 9 the documentation. Howard's folks will have access to ,
10
- that data and information, which 'will be another piece of li input to him. I don't know what the total number is 12 there, but I would estimate that we.'re probably looking i
. 13 at somewhere in the neighborhood of 90 additional pours, l
i 14 so that will be additional data for Howard an his folks.,
li MR. JENG: Okay. Thank you. Another question. On 16 the concrete strength test -- I think it's II.B -- based
{
! on our audit, I did understand that you people have some E
i t- preliminary results which indicate that the strength of j 19 the concrete at issue was consistently a bit lower than t 20 those not at issue, the so-called control concrete.
, 21 Given this finding, do you feel you actually need to look 8
i 22 into the concrete strengths in the areas other than the 23 area covered by the January 1976 to February 1977 work i 2; .
Period?
l 3; ; MR. LEVIN: The first thing I'd like to add, David, -
i #
36 1
1 is that, yes, from the statistical point of view, the j i
2 concrete at issue population is lower than the control '
3 concrete which we took, which was six months outside that 4 period.
5 Ind like to make two points. Number one In our 6 view the concrete at issue population in all cases is 7 above the minimum specified design strength. Secondly:
8 If you take any population, take a slice of any of those 9 records in time, and look at two populations and compare 1
10 them, there's always going to be a 50-50 chance that the 11 population would -- one population versus the other is 12 higher or lower. To the fact that this population was 13 lower, in my mind, is not a need for concern, given a 14 50-50 chance of that; but the most important point is 15 , that its strength has been verified to be above the I
i 16 I minimum design strength in all cases.
[ 17 MR. JENG: So you do not plan beyond what you have i
! ! is been doing today in regard to this item.
E j 19 MR. LEVIN: That is correct. We have essentially i
I 20 completed this Action Plan, and as Terry, I think, -
, 21 indicated, there will be two 'SRT approvals very shortly, 8
s 22 up for their approval.
23 MR. JENG: Let me go to Item II.C. I understand you ]
l i 24 have decided to take measure of sawing out just the 25 concrete blockfag the space. After having done this one, l t
l
37 I I do you contemplate to perform some seismic analysis to l f 2 insure that the space needed, based on the analysis, is l 3 consistent with what you have provided at the end of this 4 operation by physical sawing out the blocking debris?
5 MR. LEVIN: Number one: The sawine 4r actual !
6 restoring of the gap is being done in locations where 7 there could potentially be an interaction, and that's 8 being determined on the basis of the original seismic, or 9 the design seismic analysis. So it's knowing that 10 information and the gap associated with that at various 11 locations between the interface of these buildings that 12 we're restoring. The gap is not being 100 percent
,, 13 restored to the -- well, it was generally a two-inch 14 minimum requirement on the design drawings. It is being i
15 restored to the size that's required to prevent an
- l i 16 interaction.
3 17 Now, another possibility is a situation where -- and 5
l ! 18 we don't know if this will be the case -- material will 5
j 19 be impossible to remove, and if that's the case, that a
! 20 will have to be reconciled with the analysis to be sure
, 21 that we're not conflicting with those.
I h t i 22 You probably are aware that in certain locations j
23 certain material by design is specified, and there was l l
24 also a situation where in the past, when the rotofoam k
l 25 material was initially removed, that certain areas could 1
a .
38 I not be taken out; and studies or analyses were completed 2 at the time to understand the impact of that on the 3 ' seismic analysis. So if we have a similar situation 4 where we can't remove the material, then that will be 5 fully reconciled with the analysis of record.
6 '
MR. SHAO: Are you going to have a procedure to 7 maintain the gap during the lifetime of the plant?
8 MR. LEVIN: We are taking a look. There are 9 housekeeping procedures like that, Larry, and we're 10 , taking a look at that and making recommendations as to 11 i what changes, if any, would be required to assure that 12 ! this does not happen. In a particular case, between 13 t buildings, it's not as much of a concern as during the 14 construction phase, because there's flashing, and ,
13 material like that tends to protect the gap, debri's i 16 coming in from on top.
17 [ But with respect to gaps in general throughout the E I Z ?
i 18 plant and future housekeeping, I think that's probably 5
j 19 oven more relevant of an issue, and we'll be taking a ,
I 20 look at those procedures and making recommendations.
i
, 21 MR. JENG: Can we go to II.D control room ceiling i ?
) 22 issues? I understand the structure, which is the new 23 design being installed; is that correct.' The ceiling I i '
24 i structure, based on the new design, is being installed or l , i 25 is not being installed yet?
39 1
MR. LEVIN: At this point the design has been f 2 released by the Project, and as Terry indicated, a 3 .
nominal amount of base plates and items like that, that l
4 work has been initiated. Parallel to that, we are in the 5 process of reviewing the design analyses and -
6 calculations, we tite Third Party, and are currently j 7 reconciling certain comments and questions we had in l 8 regard to those analyses.
9 MR. JENG: There's the new ceiling structures in the 10 course of their seismic considerations. Is that correct i 11 ,
to say that three other motion components have been 12 simultaneously applied according to the SRT Provisions, 13 , Section 3.7, or it's being done otherwise? !
14 MR. LEVIN: I believe that's correct, David. I'd l 15 like to check with some of the people that have been
, l E 16 ,
reviewing. I've not personally reviewed it, but it's my l i i 17 understanding that would be the case. I can get back to j ,
I i i is you with that information.
! i i 19 ' MR. JENG: How do you plan to perform the audit, l 2
r 20 like Larry said earlier, on this one? -
l 21 MR. LEVIN: It's my understanding you wanted to i
[
i i i
22 initiate your audit after we, as the Third Party, have i 23 l completed our evaluation --
{
i 21 MR. JENG: Right. l i I 3, HR. LEVIN: -- and we will be completed as soon as ;
a _ _ _ ___ - * ,- ,,-w-- . ,. . , - , - - , . - - - - -
40 i'
I ! we have our questions satisfied by the design. I i
i 2 anticipate that to be within the next week to ten days. , i
. l l 3 MR. JENG: My last question is on the ISAP. Again, i 1 I
4 -
on this, one of the items on the II.D is compliance to j 5 Reg Guide 159 or non-cat 1 items, failure over cat one 6 items. What is your current updated criteria with so-i 7 called ints.rference between the two systems? How do you S define interference in affecting the integrity of the 9 safety-related component systems? What is your 10 definition? .
11 MR. LEVIN: Are you talking about in general?
i 12 MR. JENG: In this particular application of II.D.
., 13 i You are looking into other control room areas for a -
14 ,
potential interference between non-safety-related item I
i 15 failure, that over the safety items. What is your most '
i 16 definition on the interference?
17 MR. LEVIN: In the control room area -- ;
i V i is i
MR. JENG: Other than the control room. -
i 5 j 19 MR. LEVIN: The objective is to prevent the
- 1 2
- 20 interaction.
, 21 MR. JENG: How is the specific way you go about --
?
i 22 how do you go about doing that?
l 23 , MR. LEVIN: We can get to that, but there are two j l 1 -
24 ; issues there. One is an issue of anchorage and support ;
6 2; ;
and verifying the adequacy of it so that there's not the i <
d
, - - . - - , - - , - , + - -
-vw- -w
. i 41 I
~
possibility that the item will actually become disengaged
! l 1 2 i or fall. And the other item one has to deal with, even j 3 given that, is sway, and both of those issues are j 4 generally looked at. It's possible that the anchorage 5 could be acceptable, but there would be away into an 6 item, and that is also looked at. The objective is to .
7 prevent the interaction. l 8 MR. SHAO: I'd like to arrange an inspection meeting 9 on this Reg Guide 129, and also Category 2 analysis, i i
10
- MR. LEVIN: Okay. '
1I MR. JENG: This completes my quer:,tions at this time 12 for the ISAP. Thank you.
13 MR. TYLER: If there are no further questions, I'll 14 turn it over to John Hansel. ,
i 13 HR. HANSEL: John Hansel, CPRT. I'm going to begin !
I 16 with ISAP I.Dl, which deals with QC inspector 17 qual'.fications. We have completed our review and !
[
I i Ik provided to the program yesterday our review of all ,
! I j 19 current inspectors with the exception of 22 ASME 20 inspectors that we anticipate completing by mid-January.
, 21 Likewise, we will complete the reytes of the historical
?
i 22 electrical inspectors by mid-January. That work is j 23 progressing well. We will be working with the Project ,
24 now on the comments and the concerns that we have given i
r, i them, making sure that there's a good understanding of
42 I
those, and try and resolve those issues.
.j 2 On I.D2 dealing with the guidelines for i !
3 -
administration of QC inspector tests, that Results Report 4 is in preparation and will be submitted to the Senior i
.5 Review Team in January.
6 On VII.Al concerning material traceability, there 7 hasn't been much change in that particular area since the 8 last report. We've been concentrating in other areas; 9 '
however, we have been doing, selecting a significant !
10 amount of data from our Self-Initiated Program concerning 11 '
material traceability. As you probably recall, the data 12 from that Self-Initiated Program will be fed into this t
13 I particular ISAP for review.
14 , Concerning VII.A2 on the non-conformance and i ;
15 corrective action systems, which that also dealt with the I 16 50.55(E) reportability, we are currently about 50 percent i
[ 17 complete, and the reason for that number is that we have ;
i .
i 15 found other forms that require review, and we're in the I
j 19 process of reviewing those. We' re about 40 percent g ,
- i -
iI 20 complete, looking at the corrective action and trending 21 system, and about 10 percent complete on the
?
I 22 reportability issue. We did do a quick study for the 23 Senior Review Team to satisfy ourselves that the current j i
NCR system and corrective action systems were adequate to .
24 l I !
f 23 : accept information and findings from the CPRT effort.
i i
43 I
On VII.A3 document control, we are complete in our i 2 review of the results that we received from ISAP III.D 3 out of the testing area. They did a considerable amount i
4 ' of work in this area, and we've taken that input and have 5 analyzed it and input it into this particular ISAP.
6 Likewise, from all the inspections we do in the Self-7 Initiated Program input on document control provisions to 8 drawings and so forth, we've provided input into this 9 Issue Plan.
10 On the audit program and auditor qualifications, 11 ISAP VII.A4, we are pretty well complete there. We did '
12 decide to back up and do some additional evaluations. We '
13 are, I guess, internally within my operation, on about 14 the third draft of that review. Results Reparc 2 -
15 anticipate sud.aitting that Results Report to the Senior I
le Review Team in January. '
o ;
17 VII.A5 dealing with management assessments. We have
[ii l 15 not advanced since the last report. We've been applying i l ,
j 19 our efforts to other more pressing issues.
l 1
20 The same goes with the exit interviews, which is
, 21 VII.A6. ;
? !
3 22 ISAP VII.A7 dealing with housekeeping and system 23 cleanliness. I think this goes back, Larry and David, to 24 i' some of your concerns. We have looked at the procedures
{
25 ; that are currently in place for housekeeping and f
44 i
I .
protection of equipment. Part of that involves a review 2
l of the control of the debris in confined areas. We've 3l also been conducting surveillancos in that area to be 4 sure those procedures are being followed. That input and 5 the results of that effort will be provided to Howard !
6 Levin as additional input in that particular area. ,
7 We anticipate wrapping up the investigation and -
8 housekeeping and system cleanliness in January, and begin i 9 '
preparation for our Results Report.
10 The fuel pool liner documentation, we have not moved 11 on that, again due to other pressing activities. That 12 was reassigned yesterday, and I would anticipate being 13 able to wrap that up fairly quickly. l 14 VII.B1, on-site fabrication. We're about 75 percent ;
i 15 complete there in terms of our review of the procedures.
I 16 , We're now into the review of documentation, and we'll
~
[ 17 complete that early next year.
i !
i is VII.B2, concerned with the valve assembly- '
l i
-j 19 j disassembly problems. We have had a preliminary Results I
20 Report prepared in that area. My review and discussions 21 with the Senior Review Team identified additional areas
?
1.
22 we want to go back and investigate. I anticipate 23 resubmitting that Results Report to the Senior Review 2: Team in January.
25 VII.B3, those reinspections of the pipe support that
. t .
45 3
l were identified in Room 77N. Those inspections are 2 essentially complete.
{ I would quote 99 percent. There's 3 always one or two little areas that you need to clean up, 4l but they're basically complete. I would anticipate being I
5 able to wrap up the activity there and submit the Results 6 Report on that Issue Plan sometime in January.
7 On the hilti anchor bolts, VII.B4, the inspections 8 were going at this two ways. The inspections that are being conducted as part of the Self-Initiated Program, 10 we're about two-thirds of the way there; 60, 65 percent. ,
l' We have put together a procedure and agreed to with the i
1' program on sampling plan for verification of the torque, j
13 and that procedure has been agreed to, released t
14 yesterday, and will begin torque verifications 13 conceivably very soon. The packages are being prepared.
16 VII.B5, the electrical raceway support inspections.
l 17 About two-thirds of the conduit support inspections have i !
i is been completed, and I would anticipate wrapping that up '
- i j 19 late January or early February,.if not sooner.
i 20 l That completes my presentation on the specific ISAP l !
, 21 ! plans. If there are no questions, I'll go on to VII.C.
4 22 MR. HALE: Cliff Hale, NRC. John, are you going to 23 be doing the I.D3, and if you are, could you give us an j J
24 approach to that item, what the status of it is i
)
23 currently?
y- ---.-m ----,-,.___.__-i-------.- , m. .,-y ,. ,er4-r e_ ey-,-m.-.-.w-w+ , . - - , e-m - - - - - - = - -
46 I j MR. HANSEL: I.D3, we are doing. That has to do ,
2 with looking at craft training. There were a number of 3 findings and allegations by the TRT that they 4 investigated concerning craft training, the lack of or 5 the adequacy of. We have done a lot of work in that area 6 already in terms of looking to see what training was i 7 conducted, what records were kept. We had to get a lot 8 of that through interviews, but we have through both i
9 craft and through their supervision. Again, I would i i
10 estimate, Cliff, even though that.ISAP is not released .
1 11 yet, that we're probably 50 percent complete, if not 12 -
more. That's the approach being taken. We will have i
13 that ISAP in January. I would anticipate completing that 14 activity in January or February, as well.
1; MR. JENG: I have one question. You indicated that i 16 the other parts, a lot of progress is on each of those l 1
j [ 17 ISAP's you have listed. My question to you is: At least i i i 15 every issue when it is completed, you mean, they included j 19 the evaluation of root causes and the generic l ! 20 implications? I am right? When you say it's completed, l ,
I 21 you mean these two aspects of evaluation were also !
5, i l' l > 22 completed?
23 MR. HANSEL: When we finish, we will be able to go 2.; back and address each of the allegations.
1 23 MR. JENG: So they have not been completed yet to I
l 47 I
that extent.
2 I MR. HANSEL: No. As we complete each ISAP, that ,
3 will address certain concerns and allegations. When we !
> , i 4 finish that Results Report, then we'll be able to go back 5 and talk about the results of each of those. My question -
6 is How and to what extent are you going to factor into 7 that information listed in Appendix P group SSER No. 11, 8
into each and every one of those ISAP's in your (data) 9 stage of evaluation and the root cause and generic l l
10
- implications?
!! MR. BANSEL: Yes, we have a tracking system, as I've 12 indicated before, where we're taking each of the external ,
13 source issues, including Appendix P, and we're indicating 14 which specific action plan and/or which population of the li Self-Initiated Program will provide input to help answer i 16 the implications of that issue and concern. When those 17 individual ISAP's are completed and the populations of
[
E I 15 ,
VII.C, the Self-Initiated Program, are completed, we hope
! ! I j 19 l to be able to draw -- in fact I think we will able to 9
I j r 20 draw -- the conclusions as to whether or not we need to l
, 21 go further. We should be able to close out each of those i i .
> 22 issues.
23 1
MR. JENG: In that connection, earlier I had heard st . that there was an item, namely, craft training was added i
n, to your new Self-Initiated Program in this regard. Is
l 48 ,
1 i
3 l that based on some preliminary evaluation of the i 2 interrelationship between Appendix P items and your other 3 ,
information sources? Is this one of the results that we 4 are seeing?
5 MR. HANSEL: We have a continuing review of external 6 source issues which come from the TRT, CAT, SIP and other 7 areas. In that review, it became obvious to myself and 8 the fellows working that area that we had not done an l 9 adequate job of addressing craft training in those i 10 specific allegations, and that's the reason for that new 7
11 ISAP, I.D3.
12 MR. JENG: Thank you.
13 MR. HANSEL: Any other questions? i 14 I'll talk through our Self-Initiated Program now for l ~, VII.C. Since the last aceting, the highlights: We have l
I 16 completed our review and preparation of material i
[ 17 justifying the homogeneity of the initial 26 populations, i
! i is , and the documentation associated with that has been 19 prepared. It was reviewed with the Senior Review Team, 20 as Terry Tyler had indicated. We have had, I believe, at
, 21 least three visits, audits, by the NRC, and they have I
\
I 22 reviewed that material. We've received comments from 23 l both of those sources. Those comments have been .
l 24 incorporated, and that documentation has been completed. ,
i 27, We still have minor points there that we want to l
l
49
! clarify before saying we're totally complete, and that
' 2 involves sampling and this type clean-up of those. l l
3 Basically, I think the issue is solved. !
i 4 l All documentation on this area, including the new 5 populations -- and we have added some populations since 6 we met the last time -- will be completed by January 15, 7 so that we'll have the complete wrap-up and summary. i l
8 Concerning our populations, we combined two previous 9 populations, and that was large bore and small bore welds to and material. We combined those into pipe welds and 11 material, one population. We created five new 12 populations, and those new populations are tubing welds ;
13 and material, cement grout, epoxy grout, equipment _.
12 support and the lighting cables. We now have 30 1; populations compared to the 25 that you saw in the' I 16 October meeting. ;
1
[ 17 We have one population -- we were able to announce ,
i i
i 1A this yesterday -- where all engineering and inspection i E '
l j 19 work has been completed. That's less the review for j s
i i
20 safety significance, and that's on small bore pipe 1 ,
21 supports. We are basically finished with all the '
, 5
! 0 22 inspections and documentation reviews on that population.
23 We have put in place the process and procedures for i . ,
24 ; conducting adverse trending analysis, and work has ,
I 2r started in that area on that population and will be :
50 I '
followed soon by other populations.
I 2 As I indicated in an earlier question, our external 3 source issue matrix was released to the other Issue 4 Coordinators and Review Team Leaders, and we have ;
5 continuing dialogue with them assuring that, yes, they 6 agree that their issue plan or their investigation will 7 address a particular external source issue. So that's 4 S
living doccLlent that will be kept to date currently.
9 overall summary-wise, we. have 75 percent of our 10 checklists, inspection checklists, for inspection ,
1 11 activity and documentation reviews complete and released. l 12 , In terms of the inspection packages for inspections and l j
13 documentation reviews, 67 percent of those total packages 14 have been released and are in the hands of Inspection.
l l
1; For the reinspection activity, we have completied 53 i 16 percent of the inspections and document reviews, 17 documentation reviews; and out of that we have produced a .
i i ! 15 total of 3,562 deviation reports, of which 46 percent of s i j 19 those have been reviewed by the Safety Significant i
I 20 Evaluation Group. I need to clarify that the 3,562 were
, 21 initiated by Inspection. That number is cmaller when you
?
7 22 look at the validity checks. The actual number into the 23 ! Safety Significance Group I do not have at this point, l
i 2.; ) but of those that have been submitted to that group for evaluation, 46 percent have been complete.
2.; . -
i
51 I
We have had a rather active audit and surveillance ,
I 2
! period. We have our own corporate audits that we conduct ,
3 on ourselves. I'll just run through the findings, the i l
4 results, of these rather quickly. We had a corporate !
l 5 audit in September of '85. There's one finding, and that j 6 audit has been closed. We had a corporate audit this ;
7 month, December. There were two findings that are open. !
S I do not even have the results or the report back on that yet, but one of those is about ready to close, based on 10 post-audit briefing.
i 11 We've had a number of surveillances over our own 12 activity, which there are a total of 36 that have been 13 completed, and we have 11 open at this time. All others 14 have been closed.
15 We have issued 14 cards against ourselves; 7 have
+
- i i
i 16 been closed, 7 are open, with no overdue corrective 17 action.
[
- 1 !'
! 15 We have also implemented an over-inspection program
- 5 i I
j 19 of ourselves, with Level 2 and Level 3 inspectors '
i i
20 assigned to an independent group conducting over- j l
, , 21 inspections to assure myself and our team that our l
?
5 22 inspection activity is good. That program is in place, 23 and there will be more inspectors added at the end of ;
i !
24 ; this month. i e :
2; That basically completes my report on the Self- !
52 I I I . Initiated Program.
l
' 2 MR. NOONAN: I guess I have question for Path maybe i l
3 ' you and Howard. I'm wondering -- you've been out there ,
4 now for a number of months. What are you finding? What i 5 is the significance of your findings? Have you turned 6 stuff over to Howard to look at from a generating j 7 standpoint? Have you found any safety-nignificant t 8 things? .
9 As I indicated, Vince, 53 percent of MR. RANSEL:
1 i
10 the inspections and documentation, reviews are complete, i
11 It's a bit early to draw conclusions. :( do have several -
12 issues that we have discussed with John Honekamp at the ,
13 site, or Howard, of design areas we felt needed to be 14 looked at. I can't recall exactly what those are at this n time. There was one earlier this week.
I 16 We also have submitted it to the Senior Review Team
[ 17 for discussion, and it's preliminary at this point. Our !
i i 15 findings to date indicate that we have ewo construction .l i 19 deficiencies that we need to discuss with the Senior t 20 Review Team and one adverse trend that I just submitted j 21 yesterday that they're not even aware of yet. l
?
Y 22 In general, I'm pleased with the results of what ,
23 we're seeing. I think that the evaluation criteria is ,
3; very conservative. I agree with it, but it's very I
r, i conservative, and you're going to flush some things out.
l
_ , - , - _ _ _ _ , . . _ _ _ _ . . _ _ _ . _ . _ , , . _ _ _ , _ _ _ _ _ , , - ~ _ _ , . - _ _ _ _ _ _ . _ _ _ . - _
_ _ . . _ _ . , _ _ _ _ _ . _ . - .__,_..._w
53 1
- I think we're doing that. We now have to go further in
- 2 l
discussing them with the Senior Review Team and determine 3 the implications.
4 MR. TRAMMELL: Charlie Trammell, NRC. Just pursuing 5 that point just a little bit further, 53 percent of your 6 activities are done. Maybe you can give us an idea of 7 how many times did you have to expand the sample because 8 of the findings? Have you gone to a 100 percent of any 9 of these as a result of what you found? That type of to thing would give us an idea, some idea, of how it's.
!! going.
12 MR. HANSEL: The best answer to that, Charlie, is 13 that the very first one that we came up with ended up in 14 a problem with an open circuit in the emergency lighting i t, system, and that problem surfaced at the same time ~when i le we were looking at the homogeneity issue of the
,' 17 populations and the work activity. We chose, rather than ;
i i n expanding that total population, to create a new E
j 19 population to go look at at the electrical lighting l 3 -
, i r 20 service. You can consider that an expansion, if you l
21 l like.
8 1 22 The other three chat I talked about are into the 23 Senior Review Team for discussion. Before I expand the ,
24 sample, I want to make certain they understand our l
23 analysis, our findings and our background data, and then
, , c 54 I
i we'll go forward from that point. I would anticipate 2
those decisions being made right after the first of the 3! year.
4 MR. TYLER: Let me expand on that, Vince. We've '
5 also discussed missing cotter pin on pipe support in our 6 - last meeting, and the Project has initiated a 100 percent I reinspection for missing cotter pins in the plant. That 8
will be ongoing with another activity, staking bolts for 9 That's ongoing also.
locning devices on pipe supports.
l 10 , Did you have anything you wanted to add?
11 MR. NOONAN: I guess I was wondering on the safety 1
12 significant evaluation, where do you stand on those right l
i '
13 now? _
14 MR. HANSEL: At this point I have declared and given l
15 to the SRT two that I'm classifying as a construction i
j 16 deficiency and that we need to discuss further, and one ,
l z
17 of those is cotter pins and one of those is a problem I
i 15 with conduits where there's a barrier break at both ends j 19 of the conduit. I think in addition to that, Terry has ;
i I 20 indicated the response we've gotten from the Program, y c 21 particularly on the cotter pins and locking devices.
l 7 22 There are corrective action program being put together by l 23 the Program now that we will look at and agree to, an'd 24 then monitor that Program in accordance with Appendix B 25 which you received early on in response to t..e question.
l
55 I
MR. CALVO Somebody is bugging me here. They want i 2 '
to know why I don't ask any questions. I just want to 3 tell you why: because that will preempt our 1
4 presentation, and I want to be sure that this meeting 5 will last longer than the one we had yesterday. That's 6 why. So if you pace yourself, you will have our 7 questions when we give our presentation, and we can 8 entertain any discussion.
9 MR. LURIE: Dan Lurie, NRC. When you collapse two i i
10 populations to a single population, what was your j 11 original definition or criteria for a population? And f 12 what was your definition for the combined population? In .
1 13 other words, what allowed you to pull out the two.
.i .
( 1 populations into one?
13 MR. HANSEL: When we got into the evaluation'of the I 16 homogeneity of work processes, we came from the l t
' 17 population level down to the work activities or the work
, i
- e i !s processes. The work activities for large bore and small .
t j 19 bore were the same, including the craft, the procedures, S
t l
r 20 the codes of standards, the inspection folks; and we j And we will also have a good cut, and so !
21 combined them.
3 !
5 22 much of that other welding and other population we saw no 23 need for the two populations. It will give us plenty of '
n j data for reevaluation. ,
I John, I have one question for you. My 25 l MR. JENG:
56 1
question regards your earlier statement on the over-f 2 inspection by assigning Level 2 and 3 inspectors to form 3 an independent unit and look on what you guys have done.
4 My question is: What is your findings so far? What's
- l 5 the rate of discovering or finding some minor deviations 6 beyond your first inspection findings?
t 7 MR. HANSEL: I can't quantify that because I don't-8 have the numbers at the tip of my finger; however, as you 9 know, there are always going to be differences in 10 inspectors. The thing that I'm gaining out of this most ,
11 is another person looking at that and I'm finding where 12 there may be some need for clarification and attributes 13 or accept / reject criteria; or how do you measure 14 something, precision of accuracy, precision of 15 measurement? I have not found anything that disturbed me
, I 16 there yet.
I
, 17 MR. JENG: You are the expert in this area. I i 18 need your valuable opinion. In a normal engineering a
l { 19 measurement environment like the one we are facing in l !
I 20 the Comanche Peak Plant, a measurement was completed by
, 21 first party. The second party comes in independent to 8
5 22 do the same mea'surement. If the second party results 23 differ only in the order of one percent, could you 24 consider this to be within normal human means and i
25 therefore very good?
I
57 1 MR. HANSEL: Let me make certain I understood. You
- 2 said that there is a difference in the order of one j 3 percent?
I 4 MR. JENG: Right.
5 MR. HANSEL: I think you're going to see a 6 difference in the order of 10 to 15 percent.
7 MR. JENG: Well, that's good to know, because I'm 8 thinking in terms of ycur experience in regard to other 9 activities I am thinking. Thank you.
10 MR. MARINOS: John, a question on this emergency 11 lighting population that you have just created. Are you 12 having also the same approach with work processes 13 associated with that?
14 MR. HANSEL: Yes, sir.
15 MR. MARINOS: Which are those processes that you 16 have identified?
l
[ 17 !P . HANSEL: In the electrical lighting? You're i
i is asking which work activities for that?
E j 19 MR. MARINOS: Do you have processes? Do you have r 20 pulling, pre-pulling terminations, in that regard? Ia
, 21 that how you --
8 l 1 22 MR. HANSEL: Yes. We approach that just like we did 23 the other, Angelo, and there will be a complete write-up 24 just like you've seen on the other populations, with all f
25 the detail, discussing the attributes, accessibility,
58 l
1 recreatability. j i
2 MR. MARINOS: Fine.
i 3 MR. WESTERMAN: Let me clarify one thing that I 4 think might help Vince. On safety significance 5 evaluations, what percentage of those have been f i
6 completed? Do you have a number for that, or is that 7 something that is not - in other words, you have so many 8 deviation reports out. What percentage of those have 9 been --
10 MR. HANSEL: Out of the DR'S, the deviation reports, 11 that have been submitted to that group, there are about 12 50 percent. f g
13 MR. LEVIN: Vince, there's one other thing that I 14 think bears mentioning. Jo'n h Hansel and I have recently 15 recommended an SRT as-approved additional look into the I
i 16 dispositioning of NCR's, technical aspects of it, and we
[ 17 in the Design Adequacy .cogram will be taking advantage i I
$ 15 of the sample that John has been looking at from the i
j 19 standpoint of that process and looking at the technical t 20 disposition of those. And that's something that we felt
, 21 that we needed to do based upon our findings on his side i
e 22 of the fence, as well as mine.
l 23 MR. CHANDLER: John, you responded to Tom 4 Westerman's question a moment ago with a figure of 50 l <
25 percent of the DR's. Fifty percent of the DR's what?
l i i . . i 59 l t
.I '
Have been assessed for safety significance? l l
l 1
. 2 MR. HANSEL: Have been reviewed by the Safety i 3 Significance Evaluation Group, yes.
4 MR. CALVO: I just want to say something. We're l
1 5 talking about a lot of things about implementaticn.
6 w,e re talking about how things are going along, but I
\
l 7 just want it noted for the record that we have not yet 8 approved the Program Plan. Citing the question of the j
9 safety significance, we have not approved the methodology j 10 of the safety significance, so I don't get very excited t
j 11 on what you're doing now until we approve the foundation 12 of the Program Plan so it will put everybody else in the 13 position to understand how you're moving ahead with your 14 implementation. Again, although we're asking this 15 question to establish out of curiosity how you're doing, 16 we also are aware -- again we will repeat that in every l
[ 17 public meeting -- you are proceeding at your own risk, E
I i IS and we want to be sure that we're going to have this 5
j 19 Program Plan approved before, truly, anything about I 20 implementation has any meaning, because right now it has
, 21 no meaning because there is no plan that the Staff has 1
2 22 approved yet. That's all I want to say. ;
23 MR. NOONAN: I'd like to follow up on what Jose 24 said. Number one, the Staff is working on approval of l !
25 that plan, and I hope that's done by mid-January. We're l
60 I working on the drafted SCR right now, and we are, indeed, j f 2 getting parts of that in. As soon as I have a draft
)
3 complete, I will turn it over to Charlie Trammell, and he ;
4 will start working the process for NRC. We also will 5 have people down here at the site auditing the safety l 6 significance evaluation. We will do that prior to the 7 time of releasing the SER. !
8 One other thing we'll be doing is we announced 9 before in public meetings that we are continuing our
- 10 audits of the Stone and Webster work, and we'll probably i
So I do 11 do one more of those before we publish the SER.
l 12 see the Staff giving that approval -- or at least I l
l 13 should say giving our safety evaluation on the Program i
g, ,
14 Plan. We'll be saying a number of things. Things that 15 we see that we approve, we'll say that. If there are i 16 things in there that we think need to be still done, put
[ 17 them in writing to us, and we'll say that. It will be i
! 18 what I call the standard evaluation that we have. I'm a
i l 19 trying to very definitely get that out by mid-January.
l !
r 20 MR. TYLER: I'd like to suggest that we take a break
, , 21 at this time. It's now approximately a quartier to 10:00.
! i l 3 22 We'll reconvene around 10:00.
23 (A short break was taken.)
24 MR. TYLER: I'd like to make a clarification in 1
25 regard to the question that was asked before the break -
61 1 regarding the safety significance evaluation, to the 2 number that has been reviewed. I'll turn the mike over i l
3 '
to John Hansel.
4 MR. HANSEL: The process that takes place is the 5 DR's are written by the inspectors, and they then go back 6 to the population engineer who put that package together 7 for him to inspect to. Then there are further 8 discussions and reviews to determine if there's anything 9 else in the record that might invalidate that DR, some 10 other piece of engineering or DR that has been i 11 dispositioned. I gave you numbers this morning that said 12 that 47 percent -- either 46 or 47; I forget what the 7 ,
13 number was -- of all DR's have been reviewed by the Group 14 for safety significance. It ends up that they have 15 reviewed about 20 percent, maybe a little less, of those l 16 that are validated by the population engineers.
' 17 Howard?
I i IS I, MR. NOONAN: Howard, before you start, I need to s
j 19 clarify something from yesterday. When I reported that I ir called Bill Counsil on the 3rd of December, it was 20 21 actually a week earlier. It was November 26th, so 8
't 22 whatever dates I used yesterday, it was a week earlier 23 than that. I went back and checked the records, I 24 discussed it with Bill Counsil, and we were both in i
25 error, about a week off, so the actual verification to
62 I the Utility on the cable tray was November 22nd -- the t 2 26th, excuse me. 4 1
3 MR. LEVIN: If I can continue, my name is Howard r
4 Levin. I'm the Review Team Leader for the Design 5 Adequacy Program. !
6 This morning I would like to give you an overview of l 7 where the Design Adequacy Program stands and update a few
- 8 changes that we have made in the program, as well as 9 milestones that we have reached since our last briefing 10 in November. I will be summarizing some of our initial ..
11 findings to date. Things I'd like to discuss more 12 specifically have to do with some changes we've made in ,
13 our organization. I will status activity in the area of i 14 scope validation, self-initiated evaluation, as well as
! 15 the external source issues evaluation, unless they'just b -
i 16 ! generally characterize our findings.
l
[ 17 The most significant change we've made to our i
! IS organization includes the addition of additional E
i 19 resources. We have supplemented our work force by t 20 approximately a third by adding engineers from Gilbert
, 21 Commonwealth. These people will be participating in most 8
1 22 activities in the program in terms of being distributed .
l 23 throughout all of the DAP disciplines, and we will 24 specifically be incorporating some of Gilbert's 25 discipline management expertise into the program; and
- - . - - _ , - - - , - - _ _ - - . _ _ _ - ,--- . - - . - . _ _ , , ~ . - - _ . _ . _ _ , . _ - - . - . , _ - , - - . -
63 I we ll be looking for some of these people to help focus i
! 2 some of the reviews, asslat us in safety significance l 3 evaluations and other things where we can apply that 4 expertise.
5 In addition, previously we were configured with ,
6 discipline coordinators reporting directly to the DAP 7 management. We have added engineering, system 8 engineering, managers that will help us lead the project 9 engineering efforts. So in effect, we have bifurcated to some of the project management responsibilities of the 11 DSAP coordinators. They will retain all of their i
12 existing technical responsibilities, as you're familiar 13 with them to date, and they effectively will be the 14 people responsible for assuring the technical adequacy of i 15 the work in that area, and responsible for technical i 16 aspects of the Results Reports.
{
[ 17 There are four major activities that we've been i
! 18 involved with in the area of scope validation. As you i
j 19 recall, we had embarked upon a four-phase program, and we i
t 20 have been involved recerftly.in activities that are beyond
, 21 the acope definea L. E<r 2 of the Program Plan, and I'll l 3 1 2 22 be describing some or those in a minute. But just in the l
23 way of recapping where we left off at the last meeting, 24 we described our Phase 3 engineering evaluations, and 1
25 those have been completed. The second activity we've
64 I been involved with is the identification of the 2 constituents or population of the design documents that 3 are applicable to each of our design activities.
4 We have been involved in an activity to establish 5 with additional documentation homogeneity with rsspect to 6 the methodology inside of the HDA's, and I'll be 7 describing in a moment what we will be doing in process 8 to validate HDA attributes. .
9 As you aware, in November we had identified various 10 design activities that we would be verifying products or 11 designs in the Design Adequacy Program. What that really 12 amounted to was a master breakdown of the AE work process 13 relative to designs completed by Gibbs & Hill, as well as 14 other design contractors. What we did in that effort -
15 and this is documented in our Phase 3 engineering i 16 evaluation -- was to define the boundaries of these
[ 17 hoppers, if you will, as opposed to actually verifying i
! IS the similarity, let's say, within the hoppers -- and I'll j 19 be getting back to that in a moment.
I 20 The Phase 3 program at that point in time in our
, 21 mind provided a point of departure for our design
?
- 22 verification effort. It defined the hoppers from which 23 we would collect items to review, and given the status of l
24 the work and what we needed to do to reach our final f' l 1
25 conclusions, it was clear to us at that time that l i
65 1 additional validation needed to take place during the l I
' 2 course of the program by looking at the actual products, 3 as we became more and more familiar with the calculations 4 or specs or drawings that that, in fact, would be an 5 appropriate way of assuring ourselves that we had l l
6 adequately defined these design activities.
i l
7 We expected, as we looked at that documentation in 8 process, that there may be some minor changes to the 9 definition of HDA's, and we'll split them, combine them, 10 *whatever is appropriate, to meet the objectives that we 11 have stated.
12 To further augment the documentation of HDA 13 attributes, particularly in the areas of design criteria 14 and methodology, we embarked upon another effort. What 1
15 we did there is we developed a correlation for each of i
i 16 the HDA's, and we're talking about approximately 500 or l
j 17 more, with various design inputs, implementing documents i
- i IS and outputs. So what we now have is a correlation by HDA E
, j 19 to design criteria. We're talking about some 4,000-plus 20 design criteria that has been correlated to HDA's. Three j , 21 thousand calculations, over 300 specifications, 50 design
! 8 i
n 22 contractors and to our own DAP checklist, which numbered 23 approximately a 150. So, if you will, we define the I 24 constituents or the population of items that are I
25 applicable to each of these categories, and that activity l .
I
66 1
is complete. 1 I
2 J Currently in progress, we are involved in an f i
3 activity that will enhance the documentation with respect -
4 to the attributes of methodology within the HDA's. We i I
5 believe that we have defined the boundaries, defined the 6 -- or appropriately broke down the AE work process; but 7 we're taking a look at specific procedures, guidelines --
S and I'm talking about technical procedures now -- tha't 9 would govern the work within these hoppers.
10 Specifically, we're looking at procedures t:,c may have 11 been formerly used on the process and in the project 12 instructions memoranda, whatever forms of guidance were 13 given to people to actually do their work, and also the 14 training that may have given people guidance.
15 We're looking at criteria that are prescriptive to i 16 methodology for specific equations or highly -- criteria
[ 17 were high'y detailed, such that they mandate a specific i
i 18 methodology, correlating that specific HDA.
j 19 We're identifying where computerized calculations t 20 were used, and obviously a computer calculation was used 21 that provides certainly a high measure of similarity for i
i 22 the calculations involved.
23 We're identifying also calculation populations that .
24 will be scanned during the next phase of this process, t ,
25 which I'll describe in a minute. And to be more l
i 67 !
I specific, we will be scanning in some cases up to a 100
{ 2 percent of the populations'that are applicable to certain ;
3 HDA's. The purpose of this is to take a look in time 4 through the actual work products and verify, in fact, j i
5 that there was similarity from the standpoint of 6 methodology in the way the designers approached the work.
7 For example, in the INC discipline, that process will I
8 include looking at all the calculations, and in other 9 disciplines the scan itself will range from 35 t.o 50 10 percent of the full population of calculations. So that 11 activity will help us validate our original definition of 12 the HDA's.
13 In addition, we are identifying what I would call 14 unique methodologies where there may only be one way to 15 do a calculation, just straight forward, and it's i 16 generally going to apply to less complex-type 3
17 calculations.
! IS The way it's coming down, I would say from the s
i j 19 standpoint of procedures, instructions, memoranda that r 20 were promulgated formally, the coverage is approximately l 21 30 percent of the HDA's, and other forms of technical
! 5 I
i 22 guidance might bring that number up to about 50 percent 23 are covered by specific written instructions. And when ,
24 you get to the other categories, criteria that are 25 prescriptive to methodology, computer cales, unique
. . l 68 l
1 methodologies, et cetera, we are then effectively coming j 2 up with a statement for the vast majority of HDA's in 3 terms of on the front end of this process being able to 4 establish reasonable similarity within the hopper. This 5 is an activity that NRC has been auditing over the last 6 month.
7 Getting back to what we'll be doing in the future,-
l 8 during implementation of the review process, I mentioned 9 scanning of populations. And what we have committed to 10 in our DAP 21, which has been formerly issued as part of ,
11 our quality assurance plan, we wil.1, for each HDA, scan a 12 minimum of five calculations in that population, and if 13 there's less than five, of course, we'll do all.
14 However, it's an important caveat to this that, depending j 15 upon the need as defined by the particular reviewer, he 16 may need to expand that scan such that he can assure l
[ 17 himself of the similarity within the HDA. We will be i
i IS documenting this by a formalized checklist review.
E j 19 MR. MARINOS: Can I ask a question regarding your
- 20 sampling or your scanning? How did you select five?
l , 21 What was your basis for five from the infinite number of k 22 occupants?
23 MR. LEVIN: It was our view that the principal ,
24 factor that would lead to changes in time was, in fact, t
25 time and people and changes in organizations and things
69 1 like that, and what we really wanted to do is kind of j 2 break down the period of performance for that particular 3 activity, which in some cases it varies from several 4 years to --
5 MR. MARINOS: So you find or you further limited --
6 the population you'll be scanning will be limited to a 7 specific period of time anyway. Is this what you're 8 saying?
9 MR. LEVIN: Well, an activity, okay? Because of the 10 sequencing of the effort, the project's design effort 11 takes place during a period of time. We're ordering the l 12 population in time, and we felt that if we broke it down 13 basically into five periods within that, that we would !
14 get a fine enough cut to be able to detect if there were 15 any changes in approach over time. In some cases we're i 16 breaking it up into five hoppers for an activity that j 17 occurred in less than a year; in other cases, longer.
i i is You know, as appropriate, if we,see any indications where 5
j 19 we do see some changes, then that will have to be i
- 20 expanded. I think the important thing is that we're
, 21 really covering a substantial segment of the population.
9 .
1 22 In some cases, like INC, all, just because of the way, 23 the numbers of calculations involved. And in other i
24 areas, like, for example, in the civil discipline which 25 characteristically has -- completes a lot of l
70 1
calculations, I think the simple volume tends to make it
! 2 look like percentage-wise you're not getting as great a 3 coverage, but you really are from the standpoint of time, j 4 just simply because there are 50 or 100 engineers doing 5 it.
6 MR. MARINOS: Do you have a feeling of the 7 constituents for HDA you have decided to pick up only 8 five? You have a feeling of the number of them?
9 MR. LEVIN: The number that we will actually be 10 covering? .
1I MR. MARINOS: Yes.
12 MR. LEVIN: Yes. As I indicated before, there are 13 some 3,000-plus --
14 MR. MARINOS: No, I meant per HDA that you select 15 five for scanning. Do you have a feeling how many i 16 I
constituents are within that HDA that you have decided 17 five will be adequate?
i
! 18 MR. LEVIN: 'Yes. We know exactly in each HDA what js
! 19 the number of constituents are.
l l! : 20 MR. MARINOS: What is the average number? Do have a l
21 feeling right now?
8 s 22 MR. LEVIN: Yes. I can give you those numbers. It 23 varies in discipline. In the civil discipline there's an s
24 average of 26. In the mechanical discipline, 15. In the i
25 electrical discipline, 5. In INC, 2.
71 1 MR. JENG: Howard, to further Angelo's point, given 2 HDA after review, following your guidance in picking 5 3 and reviewing those 5 and finding some results, do you !
l 4 have specific guidance as to what necessitates this to 5 expand into more than 57 Is it pure judgment and 6 discretion?
7 MR. LEVIN: There is guidance in DAP 21 that 8 identifies the types of circumstances that would lead him 9 to expand his scanning sample, and fundamentally, David, 10
- if he finds differences between any items within the 11 population in terms of similarity and approach 12 methodology that in any way make him concerned that 13 people did it in a substantive way differently, then he's 14 going to expand it. And he'll expand if he finds one 15 that's different.
i 16 , HR. JENG: Since I have the floor, I'd like to l 17 take advantage of asking two or three more questions in i
! 18 the context of HDA's. The first one, earlier you s
j 19 mentioned --
! 20 MR. MARINOS: David, can I ask a question on the
, 21 scanning, one more question?
?
% 22 MR. JENG: Fine.
23 MR. MARINOS: What will be your criteria for ,
24 selecting 5, for selecting the 5, the specific ones? I'm
- I l 23 not talking about the numbers. It is the complexity of 1
L- _ _ . _ _ _ _ _
i 72 1
the 5 that you selected. What will be your criteria for
, f 2 selecting those?
3 MR. LEVIN: Basically, the criteria is simple.
4 They'll be ordered in time, laid out in terms of when the 5 calculations --
6 MR. MARINOS: No, I'm talking about the 7 calculations -- there are some simple calculations and 8 there are more complex calculations. Is any decision to 9 be made about which one of the 25 -- which 5 of the 25 or 10 30 of the population you will select for that scanning in j 11 terms of complexity of effort?
12 MR. LEVIN: In the scanning phase, Angelo, we're 13 just simply verifying similarity. That is a very
- 14 important consideration when we have to make the, decision 15 I as to which items we'll select for actual design i
!* 16 verification on our part. We want to be sure --
l
[ 17 l MR. MARINOS: I wasn't asking that. I'm asking:
i l E IS When you go to the population of 25,-for example, and you 5
j 19 select 5, will that selection be random or is it going to i:
20 be a specific selection of some complex ones within the
, 21 25 population?
9
> 22 MR. LEVIN: It's essentially random in time.
23 MR. MARINOS: I don't care about time. We've 24 already established that they fall into a category of 1
25 time, but there are 25 calculations, okay? And within
73 l
1 those 25 calculations there are some more complex than
'i 2 others. Are you going to use a criterion to select the 3 more revealing ones, meaning the more complex ones, or I
4 are you going to do it on a random basis? j 5 MR. LEVIN: It's essentially a random basis, for 6 purposes of scanning.
7 MR. MARINOS: Why don't you use a bias sample? If 8 you have more complex than simple ones, if your random is 9 very simple calculations, how would you justify the more 10 complex ones?
11 MR. LEVIN: Well, Angelo, I think you have to get 12 back to the purpose that we're doing it. We're trying to f 13 establish the similarity from one to the other. If we 14 find two that are not similar, I mean, if the methodology 15 or the approach, one being relatively simple relative to j 16 ! the other, such that they, in fact, are not similar --
,' 17 okay? -- then that would be a consideration for i
i is expanding the sample.
E j 19 MR. MARINOS: But the idea of doing the scanning is i
r 20 to confirm homogeneity, at least in methodology, so you
, 21 have not determined similarity yet. You are trying to i
n 22 establish this by doing a sampling basis for you, and 23 this is where you have --
24 MR. LEVIN: We will have determined it on the front i
25 end, given our review of specific technical guidance,
74 l
1 procedures, things like that. That's establishing it on l
l , 2 the front end. What we're talking about here is 3 validating it by looking at the actual calculations. As 1
4 you're aware, it was a two-step process. The first step, 5 we look at procedural guidance that establishes ,
6 reasonable expectations of homogeneity within that 7 hopper, if you will. And then later we say, okay, it's-8 o,ne thing, the procedure may have been written a certain 9 way, and what did they actually do? The only way to know 10 that and answer it conclusively is to go look at the ,,
11 product they created.
12 MR. MARINOS: Howard, I still expect an answer like 13 reasonable judgment will be made when you selected ones
, 14 that are representative or not of the 25. I'm not
~
! 15 anticipating. I cannot give you an example that it will i 16 be something that will be so trivial, that all 5 will be l o 17 so trivial, but some judgment also has to enter in af ter
! 15 you made that selection.
E i j 19 MR. LEVIN: Certainly. I heard you, and if one
! 8
! ! 20 suspects that, he's going to increase his sample for 21 scanning.
5 22 Are your questions still related to the scope 23 validation, David? ! ,
! 24 MR. JENG: Related to HDA's. You -- I think you 25 mentioned in the INC's you use 100 percent to check ,
1
_ _ ,._ _ _._____._.___ _ . _ _ _ _ _ _ _ _ _ . _ ~ _ _ - _ _ _ . _ _ _ - _ _ _ _
75 I questions in other areas. You are talking 35 percent to 2 50 percent. Is this determined by the time period, the 3 indication you mentioned, or are there other criteria for i
4 you to vary such a selection of different ranges?
5 MR. LEVIN: Mostly it reintes to the distribution of 6 the number of calculations per BDA. The INC discipline 7 characteristically has very, very few calculations. I 8 believe we're talking about something of the order of 10 9 total that were done. I'd have to check that figure, but 10 it's just on the basis that there were very few, and 11 relative to our criteria, it would have required us to 12 look at all.
13 MR. JENG: Next question ist You say in the course 14 of rour HDA conception of development you decided you 15 actually needed to actually check into the prolapse'of 16 each discipline. What are the key reasons for you to l 1 i
[ 17 come to such a position? Because in earlier discussions, i.
i is I wasn't aware of such a proposed action in the context I !
j 19 of HDAs. You say you have to decide to move into the I
- l. } l 20 actual outcome, the result of the -
lr
, 21 MR. LEVIN: It's simply, David, a confirmatory step i
i 22 where we want to factor in the knowledge that we're going l 23 to gain in the process. After we embark upon these l
i 24 design reviews, we're going to be much more knowledgeable LI 25 about what was done, populations, and we need to be able l
w
i I. o 76 I to verify that basically assumptions we made or judgments i 2 we made prior to that point about the HDAs are valid.
3 The reason we're doing it is because it's important to 4 the objectives of the program, and we want to be I
5 absolutely sure --
6 MR. JENG: Given that, I fully support Angelo's 7 point that given a selection of five to start, given j 8 discipline, I think you should consider some other things 9 to check into more complexity, more given, broader in 10 i scope; for instance, the seismic .and shim structure 11 areas, the seismic analysis containment, puts forth'a lot 12 of effort and activities to complete the course compared 13 to safety of design of steel column. So I think you 14 should really consider Angelo's point to give some 15 consideration to complexity and the depth and breadth of i 16 given items compared to others and make some appropriate i [ 17 selection in your criteria.
i i i 15 Let me go to the next point. I'm not quite clear.on l E l
i 19 how you are handling mini computer codes in a given i
r 20 discipline, and how to categorise these computer code i 21 variations in a given discipline into BDAs for that 5
l 5 22 discipline. Are they put together? For instance, there l
23 are 20 computer codes in the structure dynamics analysis 24 which are based on different assumptions or theories, 2.; like finite different versus finite elements approach or l - . _-_
! 77 I computer static analysis approach. Are these computer
' 2 codes put together in one HDA or are they separated into 3 several' categories of HDAs?
4 MR. LEVIN: I think it's a mixed bag, David. In 5 general, I believe they are separate, but I don't have i
6 that data in front of me.
7 MR. JENG: If it's a mixed-bag answer, then I would 8 like to hear what are the criteria for deciding one from 2 9 another in your decision process? Do you have criteria?
i 10 If you do not, later on we can discuss in future audits.
11 MR. LEVIN: I don't really have that information 12 with me in terms of the correlation of specific codes and 13 HDAs. That information exists and certainly is available 14 to you, should you want to audit that.
15 MR. JENG: Thank you very much. I'll turn it over 16 to Jose. I know he's going to ask questions.
l 17 MR. CALVO: Again, like I said before, our i
i 18 presentation will be coming up. We will bring some other j 5 j 19 things up. -
! a
=
i l : 20 MR. LEVIN: With that, I would like to continue and
, 21 atatus our self-initiated evaluation and break that 9
e 22 discussion down into two segments, the portion of our 23 scope applicable to Rev 2 of the Program Plan and the i
24 portion that has been added in Phase 3.
f' 25 The Rev 2 program design reviews were initiated on
---.--v-- - , , . - --.-,----,-._.-.--w,----,,,,y---, ---- - - -.- - - - . - , - . - - , , , - - - - -
! 78 1
October 18th. That's the time that the SRT authorized i 2 starting that activity. At this point in time I'd l 3 characterize that effort as being between 25 and 35 4 percent complete. It varies from discipline to 5 discipline, and by that I mean percentage complete in 6 terms of reaching certain earned value, if you will, 7 within milestones, as opposed to actually those 8 percentages being complete or gone through'the full 9 cycle, the design review process, whichf of course, i
10 includes the selection of the specific items, the actual i
11 filling out of checklists and writing engineering 12 evaluations. At this point in time there are no n.opical 13 areas that have been fully completed.
(,
14 In Phase 3 the reviews were inititated and l
15 authorized by the SRT, as I believe Terry indicated, on I 16 November 25th. Currently, the DAP 21 Validation Program i
[ 17 is in progress, and checklists required to support the i i i IS Phase 3 reviews are under development.
s j
19 Right now, the schedule of completion time frame for I
r 20 the self-initiated evaluation is April the lat. At this i
l 21 point I'd like to generally characterize that it, of l ?
i 22 course, is somewhat early to predict our ability to meet 23 that. It's certainly a function of the findings in our ,
24 program, our ability to make our Gilbert resources 25 productive and the amount of work that is going to be
79 I required in process to be sure that we get complete l
l 2 agreement on the part of the Staff on how we're going to l l
3 fulfill the commitments we made in this program. These 4 are three things that will impact the date.
5 In the external source issues evaluation, we are 6 coming to a close in terms of marching through the 7 documentation. We will be complete by the end of the 8 year. We have identified approximately 200-plus specific 9 documents that represent 25 to 30,000 pages of 10 documentation. -At this point in time we're trying to 11 complete that evaluation and consolidate issues. There l 12 have been over 1,000 issues identified that in many cases l, 13 there are some duplicates and overlap = in that they've j 14 been expressed by the -- the same issues have been 15 essentially addressed by various sources, and we want to j i 16 consolidate that and get them into specific categories.
l i
j 17 In that regard, in the civil-structural area there i
j i 18 are approximately 200 issues, and they are being
- l
' 5
{ 19 categorized into 35 categories. In the piping and 4
i r 20 support areas there are approximately 700 issues being
!, 21 categorized into 50 categories. These categories are i 8 5 22 more appropriate levels to actually take a look at the i
l 23 issues.
t 24 I'd like to get to our findings. These are items
( I 25 that have evolved out of the early stages of the self-
--e ,-,-,---na-. . --- - - - . . , ..--,-,,,,n---,,,,e , . - - - - - - - - --- - -- .-- - - r----------,-.e...me--ne--a, ,-,,--,,v, --+--e,,,--,,, ----,---a-
80 4
1 initiated review, as well as design-related items that i
2 have fallen out of some of'the TRT work to date.
3 !
! There are currently 19 items that are open.
l~
4 Thirteen have been classified as -- are discrepancies,
- 5 and they have not currently been classified as 6 observations, deviations or deficiencien. There have
- 7 been three items classified as observations, and three -
8 deviations.
q 9 In the way of an overview, most of the items 10 generally fall into a category that I call design ,
11 control, and more spsalfica.ly, the control of design l
12 input. Any ont of these things by themselves are not 13 viewed at this time to be particularly significant, but i 14 we're taking a look at them as a group to see what they 15 may mean in terms of the control of input and how i 16 important they are in the design process.
[ 17 I will relate to you --
i i l ! IS MR. SHAO: The 19 open areas are mostly in which E
i 19 discipline?
!j!
l t
20 MR. LEVIN: I would say generally in the engineering
- , 21 mechanics disciplines.
S
} s 22 MR. SHAO: In civil-structural or. mechanical?
l l 23 MR. LEVIN: Both. ,
24 Deviation 3 had to do with an issue that had been 25 reported to the NRC in 50.55(E) relative to the embedmont I
_ _ _ _ . _ , . _ - _ . . _ . . _ _ _ - . - - , . . . - . _ _ , . , . _ - _ . . - . . . . , ~ _ . _ . . . . . . . _ . . . . . - . _ _ . . . , _ _ _ _ _ . _ . _ _ . . . _ _ _ _ _ . . _ . . . _ ,
, 81 i
I of the steam generator upper lateral restraints.
! I'm i 2 sure that many of you are aware that that issue dealt i
3 with the design for pull-out and certain assumptions that
- 4 were made during the analysis that we found to be j 5 inappropriate.
6 Deviation 4 was related to building gaps which were 7 less than that called out in the design period. That is 8
an issue that was also communicated under 50.55(E) .
9 Related to that is something we're investigating, a 10 little bit of concern, which led to my earlier comment on l
11 additions in scope, but it had to do with the disposition 12 of an NCR in an area that we were not satisfied with the 13 technical adequacy of that disposition.
14 MR. JENG: Howard, I'd like to follow Larry's point.
j 15 You say you have followed 19 open items out of the 13 16 discrepancies, and most of these findings are in the l
4 l 17 design control areas. To that extent that you have t
i 18 fourad, do you see a trend of design control shortcomings it j 19 to the extent you would feel necessitated to report the
'i 1
r 20 cut in design control processes on ongoing design 21 activities to make sure they do not repeat similar l1 22 shortcomings?
l 23 MR. LEVIN: We've not identified a specific trend in .
l 24 our definition within the CPRT of an adverse trend as ;
I t 25 yet. We are currently feeding this input or data into l
l
82 I that kind of evaluation. We're certainly sensitized to
{ 2 that now. We want to take a look at that as we continue 3 through the design reviews. We're still at a very early 4 stage, and I personally would like to see more data into 5 our generic implications hopper before we embark upon it, 6 but we may.
7 The third deviation has to do with th's engineering 8 bases utilized for bond-repaired holes and cable tray 9 supports. That was provided in DCA 5347, which provides 10 generic statc.ents as to acceptable circumstances by 11 which holes could 'e left without being repaired and 12 spacing of the holes, et cetera. We found that the 13 technical justification for some of that was not 14 sufficient; however, I want to point out that we believe
! 15 that the current program, the cable tray design program j 16 being conducted by Ebasco, appropriately deals with this
[ 17 issue, so this is really looking backward instead of what i
i 18 we're doing today. What we're doing today we have found i
j 19 to be acceptable.
r 20 Areas of observations. I guess they fall into two 21 categories. Some of these have fallen into the general t 22 design control inputs, in particular. Two of them have
, 23 to do with concerns that we're investigating relative to l
l 24 the Gibbs & Hill-Westinghouse interface, and likewise I l
25 want to -- we're testing this interface very completely
- , , - - - , , - - - - - . + - - - - , , - ,:-,,---o-,,-- .---,.---,,y , - - + - - - - - - -,..y - - ,. ~,n- -- ,
i 83 I in other areas of the design that we've not gotten to )
i 2 yet. I want to see exactly how some of those reviews !
3 turn out before we decide what, if any, changes in l ,
4 direction we may want to take.
5 MR. TRAMMELL: Howard, can I interrupt just one 6 second --
7 MR. LEVIN: I'm essentially finished.
8 MR. TRAMMELL: For the record, so it's in one place, 9 could you refresh our minds on the difference between a I 10
- discrepancy, an observation and a deviation so when we J
11 read the record we'll have that in the same spot?
12 MR. LEVIN: Sure. A discrepancy is a generic term
,, 13 and is not a specific category in terms of a 14 classification. It's an item that there's some question 15 about. The specific classifications are observations,
,i o
16 deviations and deficiencies. A deviation is a specific l l 17 failure to meet a design criteria commitment in our i
i 18 program. A deficiency is something where that failure to 5
' i 19 meet that commitment represents a safety significant 8
f r 20 issue. An observation is certainly a lower category. It g
21 varies everywhere from observations of possibly poor
?
b 22 Practices, but something that's not as significant as to I
23 represent a failure to meet a commitment.
24 MR. TRAMMELL: Thank you.
f 25 MR. TYLER: If there are no further questions, we'll
84 1
turn it over to the NRC for their status.
! 2 MR. TRAMMELL: Terry, we'd like to take a short 3 break, probably about five minutes.
4 (A short break was taken.)
5 MR. CALVO: My name is Jose Calvo from the NRC 6 Staff. What I'd like to do -- I'm presenting this on 7 behalf of Larry Shao and myself. I'm trying to cover 8 both the systems and the engineering aspects of both the 9 CPRT Program Plan and Staff Evaluation. We figured out 10 that maybe Carmen can understand me better than Larry.
11 That's why I volunteered for this.
12 I'm looking at this overview of the Staff Evaluation 13 of the CPRT Program Plan. Now, the Construction Adequacy 14 Review, there are two main evaluations going. One is the 15 external source issues and the Self-Initiated Review.
i
! 16 With regard to the external source issues, Staff is
[ 17 looking now into the acceptability of ISAPs; that's the l S i ! IS issue of specific Action Plans. They are under review s
j 19 right now. Our results, I understand, will be presented r 20 in the Safety Evaluation Report. ,
, 21 The next one with regard to the external source i 22 issues is the structure for capturing future issues, also 23 under review. As you know, we have got some external ,
24 source issues that are currently identified, but as the i
25 result of implementing the construction adequacy review l
l _-. . - _ _ _ _
i
. . I 85
)
1 or any future allegations may factor into the program, 2 not knowing where they are, the Staff is very interested 3 at this time in trying to see if the structure is okay, 4 that it can handle these issues.
5 The other revisit is the Self-Initiated Review. We 6 can report on that one. All the audit reviews are 7 completed, the documentation trail is established and the 8 foundation is almost anchored. So it looks like for the 3
9 Construction Adequacy Review, we have a foundation that
- 10 is anchored. r 11 Now, the detailed presentation will be done by Ed 12 Tomlinson, who will follow me after I finish with the 13 overview.
14 In the Design Adequacy Review, again we've got 15 external source issues and Self-Initiated Review. With l
I 16 regard to the external source issues, the same two things I
17 are also under review that we had for the construction i
i 18 adequacy, the acceptability of the DAPs, the Discipline l
l j 19 Action Plans or the structure for capturing future issues l 1 t 20 is under review. Those two things will be reported again
, 21 in the Safety Evaluation Report.
h a 22 Now, the Self-Initiated Review, the audit reviews 23 insofar as the Staff is concerned, are completed. The <
24 documentation trail is almost established. The i '
25 foundation is floating but in place. But we feel that we 1
. _ - - _ . _ _ . _ _ . - . _ . - ~ . . _ - - _ _ _ _ _ _ . . _ . -
86 I
, can anchor that foundation with some additional i 2 information that we are awaiting from the Utility. l 1
3 Now, the detailed presentation, Mr. Marinos will do I
4 that.
j 5 Following all this, the list of presentations, we'll 6 c:me back again and I will give you an idea of what we're 7 doing with the Safety Evaluation Report. We'll give you 8 an outline and give you some of the things that we're 9 going to be addressing.
10 I'm going to give this back to Ed Tomlinson, and he ,
11 will take it from there.
12 MR. TOMLINSON: I have six slides, two of which I'm.
13 not going to present, because they are simply a recap of 14 what has gone on before. The latest effort thac the 15 Staff has undertaken is a technical evaluation of the i
i 16 ! Self-Initiated Construction Adequacy Program. This was
[ 17 done during the period of December 3rd through the loth i
i 18 of this year. During this time we looked at i
j 1
19 approximately 70 work processes. There were a total of 3
r gr. 26 populations that we looked at, and the procedure that 2
, 21 we followed was that we looked at the design documents
- 22 seated with the drawings and specifications that were 23 applicable to the populations. We looked at any 24 installation documentation -- these might have been on I
25 the Brown and Root, or they may have been vendor
~ - .
87 I installations or documents, or both. We looked at the l 2 quality constructions which were developed by ERC for use 3 by their personnel in the reinspection effort, and we i ,
4 looked at the checklists that accompanied these quality l' l
! 5 instructions. The overall purpose of this was to insure l 6 that there was a consistency throughout the design 7 documentations on down to the checklists.
8 There are four new populations that were not j 9 completed at the time of this review. John Hansel ,
10 touched on these briefly today. These new populations 11 evolved from other populations as a result of previous j 12 Staff audits and discussions with the Utility and 13 Contractor. We feel that we have reasonable assurance j.
14 that these population packages will be adequate, based on 1
what we have reviewed to date.
15 j 16 As a result of this latest effort, we have
' identified four programmatic concerns. When we say
} i 17 1
18 programmatic concerns, I mean concerns with a potential l t j 19 to affect the overall program adequacy. One of these is l I r 20 a necessity for reinspection overview program, and, I -
! 21 again, John Hansel touched on this briefly this morning.
j h 22 At the t'ime of the review, the program was not in l 23 place, according to what Mr. Hansel said this morning. ,
1 24 It is now in place. We have as yet to review the final l
l documentation on that program. Also in this area, Tom 23
, , - - , , - - .-,-,...,..-.n, . _ . - - , - . - . , . - - - - - , , , - - - . - - - . _ - . - . - ~ ,. . . . . _ . . , . . , - - - - - - - - - . . .
88 I Westerman from Region IV will discuss this at some
( 2 greater lengths in his presentation. ;
I 3 We identified a need for a procedure to evaluate f
4 changes to the QIs during the implementation to insure i
5 continuity of the reinspection effort. Once again, this 6 ,,as brought up as a result of the monitoring of the 7 Laplementation of this program by the Region IV people.
8 We identified a need for dealing - .a criteria for i
9 dealing with the inaccessible samples, to determine what j
i 10 constitutes an inaccessible sample and how it should be 11 handled.
12 Finally, there was a need for determining material a
i
- , 13 compliance. There seems to be a gap in the program in 14 this area, and once again, Tom Westerman will discuss 15 this more in detail in his presentation.
l l i 16 We had discussions with the applicant concerning i
l
[ 17 programmatic concerns, and the following commitments were i
! i 18 made by the applicant during our last audit. They i , .
l l 19 committed to an overview program, and once again, the a
! 20 word is this morning that this has been implemented.
I 21 A Procedure for evaluating changes to the quality '
l }
b 22 instructions will be developed and implemented. .
23 And finally, criteria for defining inaccessible 24 samples and how they will be handled has been in f
25 existence. This will be formalized and the criteria will
89 I be included in the population packages, in each
, 2 population package.
3 Staff conclusions to date. Basically, we feel 4 pretty good about what we've seen. The Self-Initiatied 5 Construction Adequacy portion of the CPRT program, when f
6 properly implemented, we feel will be a significant 7 contributor to the overall reasonable assurance 8 evaluation of the adequacy of the plant construction.
9 And the term " properly implemented" here means that the 10 ' programmatic concerns that we have identified have been 11 taken care of. Again, as I indicated, the acceptable 12 implementation is predicated on addressing the-13 programmatic concerns.
14 The outstanding items that we have at this time are 15 the issues on material compliance. Confirmatory issues i 16 are the other three programmatic concerns that we have
[ 17 addressed: the overview program, the evaluation of QI l
i 1 18 changes, and the criteria for identifying inaccessible 5
- j 19 populations or inaccessible samples within populations.
2 20 One thing we have, pending further evaluation by the
, 21 Staff, is how the items are selected for inspection.
8 l
3 22 MR. CALVO: As a result of -- all these findings and 23 conclusions came as a result of the Staff performing a ,
l 24 lot of audits and getting familiar with the program. We I
25 still have not revi1wed some of the Program Plans, some l l
90 1 of the answers to our questions, but the way it looks
{ 2 right now, the evaluation looks right now, if there is ,
3 any additional comments or additional feelings that we t
4 write the SER, that it will change it; and again, now, l
5 unofficially, this is the way the program, the self- l 6 Initiated Review, looks now. I'm still waiting for 7 comments from CASE, including the intervenor, to be 8 factored into our Safety Evaluation Report. Those will
! 9 be properly factored what we have done in the audit, and 10 what we will do in the SER. When we print the SER, then l
11 we establish the Staff position how the Program Plan in i
12 this area will be handled.
13 I guess we are at the point now if anybody has any j
14 questions -- I want to be sure that everybody, especially 15 the Utility side, this is the way we see things. These 16 are the results of our audits. If we are wrong, tell us.
{
[ 17 Don't tell us when we finish. We'd like to know that i
i 18 now.
j E
19 MR. BANSEL: I just want to make sure that we're" r 20 going to get through discussions from Tom Westerman on
, 21 the material condition.
?
% 22 MR. CALVO: Yes. Are you going to do it now, Tom, 23 or do you want to -- maybe we continue with this, okay? ,
24 MR. NOONAN: While Tom is doing this, I just want to' l
{ make one thing clear. When the Staff is out here doing l
25 I
91 1 these audits and we come up with certain concerns we have
{ 2 on the program and we look lii:e we're going to impact the 3 scope of the Utilities contractors presently working 4 there, I have made an agreement with Mr. Counsil that I 5 will notify him of the scope change so that from an 6 administrative standpoint he can reflect on what the cost I
7 of that is going to do.
8 MR. CALVO: One thing I want to add. Everything 9 that we have done, it will be an auditable trail. i 10 Everything. Special reports we have in preparation right 11 now we're going to document what we have seen. You will 12 find there is no conclusions and we properly want to put 13 that into the record.
14 Okay, Tom?
15 MR. WESTERMAN: In the material compliance area i 16 Region IV has made the observation that verification of l l 17 material and component compliance with procurement / design
- 1
! 18 requirements is not being addressed within the CPRT l 5 j 19 activity.
g -
t 20 In our look at the on-site CPRT activities, we have
, 21 observed that the documentation review basically takes ,
i i 22 that review to the bill of materials, certificate of i
23 compliance, and/or certified material test report.'. )
l' 24 I think we're just laying this out on the table.
l I
25 We're not saying that it is something that is required, )
i 9 , . , , , , . _ - , , . , . , , _ _ _ . - - . .___.p., 7 .----. , ___, ,, -. g -,y.,, ---_e.%- c.,
92 3 but I think it has to be addressed, either reasons 2 provided or justified as to why we had not picked that up 3 as part of the program or a program established.
1 4 It may be that Texas Utilities would like to respond I 5 to that.
6 MR. BANSEL: It's a valid We hear your concern. l 7 point. There is a point there, that we did not go bacir 8 t;o check the history of that material from the vendor. I 9 think all we should say now is we have your concern. We 10 will look at it, and we'll come back and tell you how we .
11 think we've covered what we think we need to do.
12 MR. CALVO: If there are no other questions from the 13 floor, Angelo Marinos will present what we did with the 3
14 Design Adequacy Review.
15 MR. MARINOS: As Howard Levin indicated earlier in
$ 16 his presentation of the CPRT effort of the Design f 17 Adequacy Review, they have broken down this review into
' = IS four phases. We have reviewed three phases. One and two
- i 19 phases were, of course, reviewed earlier under the CPRT
! 20 Program Plan --
c 21 MR. NOONAN: You need to get closer to the mike.
. i 22 MR. MARINOS: - the Program Plan that was submitted 23 to us June 28th, '85. I will leave it at this point. ! ,
l 24 Our principal effort of the last few weeks of audits have 4
25 concentrated on the revision to those phases which appear ,
93 I in Phase 3. The Phase 3 reevaluation, or validation, or l 2 the scope is consisting of the items that I have listed l 3 here, at least the items that we have audited; and the 4 areas that we have audited is the development of design 5 activities from review of Gibbc & Hill and Texas 6 Utilities and Engineering indices. Those are indices of 1
7 plant specifications, analyses, calculations, drawings --
8 MR. NOONAN: Excuse me, we can't hear you.
9 MR. MARINOS: Those are indices that we had seen at 10 the TERA offices of plant specifications as indicated 11 there, analyses, calculations, drawings, procedures, NRC 12 standard review plan, SSAR and other documents which
- (,
13 provide them with information of the various activities 14 that were done by Gibbs & Hill and Texas Utilities.
15 other documentation with the identification of i 16 design activities which appear in the engineering 17 evaluations of the -- there was a summary evaluation that
}!
i 18 covered all the disciplines. In that evaluation we found E
! j 19 areas addressing common elements of all disciplines.
l !
l r 20 Other engineering evaluations were a specific discipline, 21 like'the electrical, instrumentation / control, mechanical i
i 22 and civil / structural.
23 Other information was included for the establishment 24 o't homogeneity of desigr. activities, and the various i
25 attributes were listed as design criteria, mothodology, l
, _ . . _ . .w,,,_,,.--,_.__m.
94 I organization, design control and design interfaces.
( 2 Further documentation reviewed was the justification 3 of identified homogeneous design activities, which were 4 included at the time in a draft Design Adequacy 5 Procedure, DAP 21; and as indicated this morning by 6 Howard Levin, this DAP has been completed and is in final 7 form at this time.
8 In that procedure two areas that were significant to 9 us discuss the interpretation of homogeneous design 10 activity attributes and the homogeneous design activity 11 description and validation checklists. This checklist 12 will appear in the vehicle by which they will determine
,. 13 the methodology of other homogeneous attributes per 14 design activity.
15 That is the extent of the documentation that we have i 16 reviewed. Our findings with regard to this documentation j 17 are, of coarse, for Phase 1 and 2. We have transmitted i
i 18 to TUGCO through letters of August 9 and September 30th.
s t j 19 In the Phase 3, in the development and l !
l r 20 identification of design activities, which I included in l
l 21 the documentation of indices and engineering evaluations, h
3 22 we are presently reviewing this.
23 With regard to homogeneous design activities, the ~ g 24 design criteria are documented for all identified
(
25 activities, and we are presently reviewing that also. -
95 1
with regard to methodology, which appeared in the i 2 form of guidelines, it was identified for some 3 disciplines. We have yet to see the rest of them. As 4 Howard Levin indicated, they are in the process of ,
5 establishing that.
6 With regard to the design organization, we have..
7 found that the design organization is adequately 8 documented for the Gibbs & Hill and the TOGCO nuclear 9 engineering scope of design.
10 With regard to design control and interfaces, we 11 also found documentation adequately describes the 12 procedures that have been used from Gibbs & and Hill for
, 13 the scope of the design of Gibbs & Hill.
14 In the areas that we feel that are outstanding is 15 the CPRT review and document review methodology for all 16 the design activities which is in progress, and the l
' 17 completion of the DAP 21, which we heard this morning is i
i is completed.
s j 19 Additionally, the CPRT review and document design r 20 control and interfaces for the Texas Nuclear Engineering 21 scope of design is still outstanding for review, i
?
- 22 Any questions?
23 MR. CALV0: This part of the presentation is 24 included in the first handout that I had when I first
{ came in, the second page. I want to give you some of the 25
96 1
outline for the Safety Evaluation Report that we are in j 2 the process of preparing at this time. !
3 You see the Safety Evaluation Report will have four {
4 main chapters: An executive summary, Staff evaluation of !
5 the CPRT Program Plan, general; and then there are going 6 to be two specialized, one in design and one in 7 construction.
8 The second summary will have an introduction. It 9 will summarize the NRC reviews and evaluations and 10 conclusions. We have added two additional areas: the 11 summary of outstanding issues and confirmatory issues. I j 12 just hope that there will not be any outstanding issues 13 when we write the SER.
l 14 The next chapter in the Safety Evaluation Report is 15 going to be that that is common to both the construction l
i 16 -
and to the design. As you can see from there, we are
- j 17 going to start with an introduction. We're going to i
' i 18 describe what the CPRT plan is. We're going to describe 5
j 19 what the NRC review and evaluation was. Then we show'the l !
r 20 common requirements for the design and construction . ~*
, 21 reviews, the'QA/QC CPRT activities. And it seems that it i
, h 22 follows under the QA/QC -- this is what the Staff is l
l 23 going to do for each item. There's going to be an 24 introduction, the CPRT approach, the Staff evaluation, f and conclusions. The acceptance criteria, we had those 25
97 1 four things under the acceptance criteria thing; so l
[ 2 acceptance criteria, corrective actions, independent of 3 the CPRT/SRT organization and discipline interfaces.
- 4 Keep in mind that we have some questions. We have some 5 concerns when we first issue our first evaluation and 6 second evaluation of the Program Plan for Revision 2. .We 7 are addressing those things, up and the Staff will set 8 forth their positions or their conclusions when they 9 conclude that review.
10 And finally, it's going to be the overall summary 11 and conclusions as pertain to the CPRT Program Plan.
12 Now we get into the meat of the plan. One of the
. 13 things is the Design Adequacy Program Plan. Again, like
, 14 before, introduction, CPRT process for evaluation, what 15 the Staff did. Then we have two categories, external i 16 source issues, and we have broken them down into 8
17 disciplines; and again we're going to each discipline, i
! 18 and that can be broken down further into it, depending on 5
j 19 the significance or the peculiarity or how many issues a
! 20 are in those disciplines. So you have the electrical,
, 21 mechanical / civil, piping. And again we added one more, 8
% 22 the closed external source issues. We'd like to know, as 23 you indicated, that you are looking at the closed ,
24 external source issues, because at the end we're going to 25 use those; not only the negative part of it, we're also I
98 1
going to look at the good part of it, trying to help us t 2 to reach the overall reasonable assurance.
I 3 Then we get back to the self-initiated review l l
- 4 evaluation. We're going to talk about the scope. This 1
. i 5 is introduction. We're going to talk about the approach, !
6 and then we're going to be addressing the homogeneous 7 design activities, and then we're talking about the -
8 selection of review items. Then is going to follow a 9 Staff evaluation, and there's going to be conclusions.
10 Then, again, with the self-initiated evaluations, ,
11 we're going to talk about the electrical systems and 12 components design activities. We're going to talk about 13 the mechanical systems and the civil and structural 14 piping and supports.
15 And then one more item is the exclusion of vendors i 16 and other organization activities. We not only concluded 3
17 that the design from the architect engineer was good i 18 enough, has a good quality, we're also talking about the i
j 19 design for Comanche Peak, and we'd like to know if r 20 there's any vendors or any activities such as
, 21 Westinghouse that has not been deleted from the reviews.
8 5 22 There's a good reason for deleting them, so we can make 23 that conclusion at the end that, yes, in addition to tihe j l Gibbs & Hill, all these other activities were considered 24 25 and there's proper justification why we didn't go as deep !
I
99 I into them as we did with the Gibbs & Hill.
{ 2 The other one, again, is going to be overall summary l
3 and conclusions.
- 4 The next line, I guess the other main part of the 5 Program Plan, is the Construction Adequacy Program Plan.
6 Like before, we've got introduction, CPRT process for 7 evaluation, the Staff evaluation, and then again we've 8 got external source issues and the self-initiated 9 evaluation.
10 Now, with external source issues, right in that 11 category, that's where you're going to see all the 12 Technical Review Team, the TRT issues. Those are going 13 to be addressed. The action plans that were prepared to -
14 take care of those issues, they're going to be in there.
15 They're also going to be broken down into disciplines, j 16 and the reason they're broken down into disciplines is 17 because when you finish that discipline, you take all the i
! 18 external source issues, you take all the self-initiated E
19 effort and you combine them together and you can say, ,
i
- 20 yeah, the electrical system is okay or not okay. The .
, 21 same thing we can do for the civil and structural. This i
i 22 way we're trying to combine those into the disciplines so
~
23 we make that overall conclusion when we finish with the 24 Program Plan.
I 25 Again, we go to the self-initiated evaluation, and i
- s l 100 I again we're talking about populations and we're talking
- 2 about the CPRT approach; and we've got homogeneous l l 3 construction activities and selection of inspection I
- 4 items, Staff evaluation and conclusions. And then again, f 5 electrical populations, mechanical and structural, and ;
6 those will be further subdivided to address the subject 7 matter, depending on the significance and importance.
8 Again, we'd like to also know if there's exclusion 9 of vendors and other organization activities, and I'm 10 told that there is none in the Construction Adequacy 11 Program.
12 Again, the overall summary and conclusions.
13 I want to give you an idea of the resources involved 14 in doing all this. The NRC Staff has about 12. They've l
15 got 14 consultants. Now, these are some of the companies
, i 16 where the consultants come from.
[ 17 In summary, I'd like to say something. We are i
i 18 proceeding in writing the SER and the criteria. The SER b
j 19 is not going to be, as far as the Staff is concerned,~it ir 20 is not going to be outstanding issues or outstanding
, 21 items. The SER knows what he wants, knows what is i
- 22 expected of the Program Plan; so the SER, knowing that, 23 is going to establish some regulatory positions 24 irregardless of whether -- I think there's enough 1
(
- 25 information about the document that we can reach a
101 1 conclusion. We can reach those conclusions. We will
{ 2 establish our positions. Now, if the information comes 3 before the final issue of the SER, then we'll review that
- 4 information and then we will determine whether the 5 position remains the way it is or it modified to reflect 6 the new information.
7 We are moving ahead. We are proceeding to 8 final zation of the SER. Now, I understand the Revision 9 3 the Program Plan is due somewhere in January. I'm
]
10 ping by that time the SER will be in the final stages ff completion. If that Revision 3 for the Program Plan 11 12 w 1 not be there, the Staff will still come up with the 13 SER, wi N tablish positions; however, when the Program 14 Plan will come out, we will compare the position with the 15 new information and we will determine whether those
! 16 positions will still stand or they are modified based on
{
i 17 the new information.
! 18 Now, the other area, confirmatory issues. There's i
j 19 going to be two types of confirmatory issues. We're l @
t 20 going to say confirmatory issues must be resolved before
, 21 implementation can commence. I know implementation has y N.
1 22 commenced already, but we want to be sure that when we '
establish concerns, we feel strongly enough about it tihat
~
23 '
l
~
24 those have to be resolved before implementation can l
25 proceed at risk.
. a 102 1
1 I just want everybody else to provide that t
i 2 information to the Staff -- that includes the !
- 3 intervenors, Juanita -- so we can factor it into our SER i
- 4 so somewhere after the new year we can have an assessment 5 of the Etaff for the Program Plan. l 6 when I finish my presentation, if anybody has any i
i 7 more comments, I would like to entertain them.
8 Otherwise, I will pass that to Mr. Noonan for whatever he l 9 wants to do next.
10 MR. NOONAN: I guess, Bill Counsil, what Jose said 11 there about releasing the SER's recorded, I guess that's 12 not quite what I want to do. I won't do it that way. I 13 want to hold the SER's until we have the Program Plan to i
14 us, because right now I do believe that Plan should be 15 confirmatory, and before I release the SER, I will hold i
a 16 to that time.
j 17 Do you have any ideas as to schedule?
! i -
! 18 MR. BECK: Our current schedule, as was indicated E
i i j 19 this morning earlier, I believe, for the complete '-
Z 20 Revision 3 of all the issues, specific action plans and l
, 21 Program Plan and other plans and the design adequacy i $
k 22 appears to be in January, probably the third or fourth
.3 week.
24 MR. NOONAN: One other issue I would like to address f
25 for the record. The Staff has completed its work on the P
- . = . - - _ - - . - , .m.- - , --, . - _ . _ _ _ _ _ - .,_,,,,,--.m . . - - - . _ _
, l 103 )
I FOI request. All the information that I now have that
{ 2 was in our files has now been put into the system -- it's
- 3 not out of the agency, but it is out of my office.
. 4 There's a check by OI people and there's the normal work 5 that's been done by the FOI group. I expect that to 6 happen probably about mid-January. All that stuff'will l
7 be into the Public Document Room.
8 I guess at this point in time I'd like to allow Mrs.
9 Ellis a chance to comment on what she's heard today.
10 I forgot. I'm sorry, and I apologize. Mr.
11 Westerman has some things here. Before I turn it over to 12 Mrs. Ellis, I'd like to get this done.
13 MR. WESTERMAN: I'll move right along and make good g
14 time.
! 15 Region IV does have an inspection group on site.
l 16 That inspection group is composed of 10 Region IV
[ 17 personnel, and there are presently 10 contractor l 5
! IS t>ersonnel assisting Region IV. The majority of our s
j 19 efforts around 13 inspectors is being expended in "-
- 20 witnessing an independent man inspecting the hardware
, 21 inspections under Issues Specific Action Plan VII.C. We
?
22 do also have one of those contractors assigned looking 23 full time at some remaining TRT QA/QC allegations. We 24 intend to increase that staff for probably another I
25 contractor sometime in January.
l l
s ~ - -- -- --- v - ~ , ,_a,_
104 I
I We are also in the process of reviewing the TUGCO l
2 performance by the NRC Staff. This is a normal function 3 of Region IV.
4 MR. NOONAN: We can't hear you, Tom.
l l
5 MR. WESTERMAN: To kind of~give you a status of the 6 nature of'the type of inspection that we are performing l 7 with regard to CPRT activities, in the VII.C arena, which 8 is the quality of construction and QA/QC Adequacy Plan, 9 we have completed 252 witnesses of reinspection that have 10 been performed. We have independently done 99 11 inspections of ERC performance inspections. We have 12 taken the ERC checklists and essentially gone out behind 13 the completed inspection and performed it with our blank 14 checklists for comparison to the ERC findings. We have 15 also done approximately 91 documentation inspections.
I 16 I think in the future we're going to probably
[ 17 concentrate more on our independent inspections. We had i
E IS to set a goal of around 10 percent of inspections to s
j 19 witness. We're probably going to come down from that and a
! 20 look more at our independent inspection effort. ',
, 21 There was a question last time, I think by Mrs.
% 22 Garde, as to what we were doing in some of the other 23 arenas, or the other ISAP's, as far as actual hardware ,
1
^
24 inspection. Of course, we are following the VII.C, or 25 V.C, building gap inspection. It's an on-going effort, .
l
105 l
1 of course. We have where there were populations or
' 2 samples, such as V.A skewed welds, we have witnessed 9 of 3 the inspections that were performed, and we've
'- 4 independently inspected 7 of those.
5 Plug welds: We witnessed 48 and independently 6 looked at 10.
7 Valve disassembly: We witnessed 8 of those -
8 inspection and independently performed 7.
9 In the area of pipe supports, we've independently 10 done 9 inspections. ,
11 We are also following the painted weld issue. We 12 will be witnessing 100 percent of that sample population.
13 We will witness it, and we're also independently looking 14 at it, but' there's not a way to do that function without 15 it being like a witness-type effort. We'll look at' the i 16 weld before the paint has been removed to see if we agree
[ 17 with the findings, and then we will look again at that i
! 18 weld after the paint has been removed to see the s
, j 19 correlation. '
r 20 We are also -- as far as our efforts, we will be c 21 independently verifying conformance to each ISAP. Wea're
? -
i 22 in a number of these areas awaiting the Results Reports 23 to be issued.
24 The culmination of our efforts, of course, will be 25 our inspection reports. We issued one in August. I have
l 106 I I
1 a September report which is in final resolution, I guess, i 2 of comments. It should be out momentarily. The October I
3 report I would expect to be out in January and, of
- 4 course, the November report probably following in 5 February.
6 To give you an answer of the' size of the effort, in 7 the September report there's approximately 2900 man-hours
, 8 of inspection, and in putting together that large an 9 inspection report, it has taken us a little longer than i 10 it would normally to issue an inspection report.
11 I will talk in reference to what Mr. Tomlinson 12 brought up with regard to the ERC inspectors and our
- g. 13 inspection in that effort. You'll see that, of course, 14 in our reports as they start to come down. We have in 15 our looking at the inspector adequacy , as well as the i 16 procedure, the accuracy of the procedure, adequacy of the
'. 17 procedure; and I think at this point in time I'd say that i
i 18 there is a response to the findings that we've made with s
j 19 regard to inspector adequacy, the oversight program which 8
5 20 ERC is performing, and we'll be following that through 21 reso;ution.
c i
i 22 That's basically all I have to say. I'm kind of at 23 a disadvantage. Normally, within our inspection
~
24 activities, we refrain from talking about the details of l t 25 the inspection raport until they're issued. I will at
---...,.,,-.g,-n.-,,-w,--vn,,, -e----n--,.-,.
107 1 the time, when we have issued the inspection report, be i 2 glad to talk in any detail, but at this point in time I 3 really can't talk about any more detail.
. 4 MR. NOONAN: I think I just want to say for the 5 public record that basically the activities going on at 6 the site under the management of Tom Westerman have s s 7 really served us very well in Washington. He's been 8 doing a lot of work out there. There's'.2 lot of people 9 around, a lot of activity going on, and without him being 10 out there, we would be hard press.ed ourselves with our 11 groups. Tom usually briefs us once or twice a week when 12 I have one of my Staff meetings, and then he also keeps 13 me up to date on a daily basis of the Region activities.
1 14 MR. HANSEL: John Hansel, CPRT. I'd like to make 15 two comments. One is: We're taking the overview 16 inspections by the NRC very serious. The Region people l
j 17 let us know about the results of those almost as soon as i -
i 18 they happen. We get our Level 3 inspectors, the i
j 19 inspectors themselves, with those folks to investigate r 20 those issues to determine if there is a person problem or
, 21 Procedure problem. We're taking that very seriously. We y ~.
k 22 have also started our own overview inspection of that by 23 our own people.
24 The second point, going back to the Region's concern
}
25 on material compliance. We're working on -- and I told
108 1
Tom earlier that we were going to study this -- a 2 procedure to go do a review of those vendors that are 3 being looked at by the Design Adequacy Program and some
- 4 sampling of those type of materials through receipt into 5 the TUGCO process. When I get the details of that and
~
6 define them, owe'll share them with you.
7 MR. NOONAN: If there are no more comments, I'd like 8 to turn the mike to Mrs. Ellis and ask for her comments.
9 MRS. ELLIS: Thank you. The first comments are in 10 ' regard to some of the things that were discussed 11 yesterday. I think it needs to be pointed out that the 12 issue of having the QA audits and the surveillances and
,. 13 so forth were raised something like a year ago. I i 14 remember specifically Billie Garde talking at some length 15 about that, and it's a great concern to CASE that this i 16 was an obvious error, an oversight, whatever you want to j 17 call it, which should have been in place a long time ago i
! i 18 and should have been operating during this entire i
! j 19 process.
r 20 One of the things that we'd like to urge is that the l
, 21 Utility at this point in time step back and take a look i % 22 at the overall process and make every effort at this 23 point to be sure that the proper procedures, checklists 24 and so forth are in place before you do things. When we I
25 get to the end of this. when we finally get discovery on
i i
I 109 1 the checklists, which I certainly hope will be sometime i 2 soon, when we do have those in hand, we're going to be I 3 interested not just in the checklists that have been
- 4 finalized and in final form, we're going to want to know 5 what you were using while they're out there right now 6 doing things. What procedures and what checklists were 7 they using at that time.
i 8 So the sooner these things can be finalized and 9 proper procedures and adequate procedures are in place, 10 certainly is going to save all of us a lot of time and 11 effort in looking at things and discussing things later 12 on.
13 Another thing that needs to be pointed out -- and 14 I'm not sure how aware some of the newer people, for 15 instance, Mr. Counsil, are familiar with the testimony of I 16 Jack Doyle and Mark Walsh regarding the chilling effect
[ 17 of reactions of their supervisory personnel to their i
i 18 reporting things and looking into things. The attitude j 19 of the supervisor who had the quotas is an attitude that i
t 20 was talked by many of our witnesses. This same attitude 21 has been pervasive for a long time at the plant, t 22 including engineering, at least to a certain extent. We 23 do know of Mr. Walsh and Mr. Doyle who felt that feeling, 24 and it's indicative of an attitude where managenent wants i engineering personnel as well as other personnel to wear 25 -
l l
i . .
110 i
i blinders and to stay in their respective little boxes. l 2 It's really appalling to us that this is still happening 3 at this point in time, and I'd like to urge that the
- 4 Utility make every effort to go back and identify where 5 this has happened in the past, as well as what's going on 6 currently,gbecause if there are instances where this has 7 gone on in the past with engineering personnel in 8 particular, it may have a very great impact in not$ just 9 the actual intimidation aspects, which, of course, are 10 very obvious, but also in regard to the generic 11 implications and the root causes of some of the problems l 12 in the design area in particular. I wanted to point that 13 out because, as I mentioned, I'm not sure exactly how 14 familiar you are with some of the testimony which has f 15 been put into the record in that regard.
16 As before, we will have a lot of questions, and I
!j 17 guess we'll do these in writing, too, at some point in
! i i is time regarding the stop work order on the cable tray I
i
! j 19 supports and so forth.
r 20 I guess a final comment that I have is regarding the
, 21 Staff's moving ahead on their SSER. If the Staff is S
! i 22 trying to complete and give approval to it in January or 23 whenever, or shortly thereafter, even if they really want 24 input from CASE, we've got to see some of the things that
[ the Staff has seen. We've got to see things such as the 25
111 1 checklists, and we need those now. We need to have i 2 things in a more timely manner. I mentioned off the I 3 record that we only received the transcript of the
. 4 November 5th and 6th meeting on December lith. If we,. -
l
- 3.. l 5 don't get the transcript of this meeting until -- we may , '
l 6 get it about the time that the SSER is going to come out, !
7 the way things are going. .So I'd like to point out that 8 we need time to have these things in hand and to review 9 them. We also need to have time to have in hand and 10 review Revision 3 of the Plan. The FOIA information is ,
11 going to be very necessary to part of our review, and if 12 it's not available until mid-January, it's going to be 13 very difficult for us to handle all this information in 14 one clump, which is exactly the thing that we have spoken 15 about time and time and time again, as at the end we're 16 going to be loaded with all these things to look at and l
l j 17 five minutes to do it. We're simply not equipped to do i
i ! 18 that. It's unrealistic. It's totally impossible. I g ... .
j 19 think that we have to have adequate time to do this e .,
y v.y 2 20 before we can make comments which are reasonable and'"
- . r- 7 based on rational judgment and rational determinationd'.
l , 21 5 22 We can't do it off the top of our heads.
23 Thank you.
24 MR. NOONAN: I'd just like to make one i
25 clarification. When I spoke of the FOIA stuff, that's
112 I when the final part will be out to the rest of you. i
'; 2 About half of it, I would think, is already into the 3 system; I believe about 50 percent, somewhere in that 4 range.
5 I guess with that, Bill, I don't have any further 6 things to cover today.
7 MR. COUNSIL: I have none.
8 MR. CALVO: Vince, just one clarification, if you 9 don't mind. I think CASE -- go ahead, Ed.
10 MR. TOMLINSON: This is in regard to the concern 11 addressed on the QI's and what QI's were used for what 12 part of the inspection. This programmatic concern that 13 we have identified during our last technical evaluation, 14 this is precisely the concern that you will have raised, 15 and the commitment on the Applicant is to go back in time 16 and identify any changes made to the QI's during the l
l j 17 process of the implementation, and to do an evaluation of l i l 5 IS that. The Staff is very much aware of that concern and I 5
{ 19 is addressing it.
r 20 MRS. ELLIS: Thank you.
, 21 MR. NOONAN: Okay. With that, I'd like to thank i
k 22 everybody, and this meeting is adjourned.
23 ,
l 24 (The meeting was adjourned at 11:45 a.m.)
!(
l 25
113 1 CERTIFICATE OF PROCEEDINGS 2
3 This is to certify that the attached proceedings 4 before the Nuclear Regulatory Commission and Texas *
- i
.m.y .,. .
5 Util'ities.>mGenerating Company '#' ,' #*'*
a 2.,
6 In IheMatteref: NRC Staff" Progress in Revfe +[df ..,
- % .',':kW ?
. 4 7 .y the Program Plan and Applicank.
. - . =r ,,g, 8 Activities on the Program. Plan 9 Date of Proceedings: December 18 and 19, 1985 10 Place of Proceedings: Arlin.gton, Texas 11 were held as herein appears, and that this is the original 12 transcript for the file of Texas Utilities Generating
, , 13 Company.
I 14 15 carman Gooden 16 Certified Shorthand Reporter
'I 17
/.
18 /
, i.
. L r 19 /N )
i '
Certified Shorthand Reporter i 20 .
(f ' s. -
a w ~,
. . u.
21 9 ' * '-
3 J , . . w;ac
- ~ ~ ~ *
- ~!' > '
22 f, .,y
'2" * ^ "
23 24 1'
25 daussia hoodus
~ am MIUMSTON. f5 mas 7.es.
METIto le1M eaHeat
o q m g.gye, ,3, .
?le.((f 'l! .2: 5.f*
STAFF REVIEW 0F SELF INITIATED CONSTRUCTION ADEQUACY
~
PORTION OF CPRT PROGRAM PLAN STAFF APPROACH o PLAN CONCEPT o DOCUMENTATION o TECHNICAL EVALUATION o IMPLEMENTATION MONITORING o EVALUATION OF RESULTS .
4 I
- 9 "[ I., e
. x..fty:.--
! m " *
\ &, -y , ,
q $g% . - .' . 3,.
- ,- , . . .. .. * ^
- '.. a: .
SUMMARY
OF PREVIOUS ACTIVITIES o POPULATION B0UNDARY o SOURCES FOR POPULATION LIST t
o METHODOLOGY o WORK ACTIVITY (PROCESS) HOMOGENEITY o ATTRIBUTE APPLICABILITY o QUALITY INSTRUCTIONS o REINSPECTION / DOCUMENT REVIEW PACKAGES o FINDINGS o METHODOLOGY IS SOUND o AN AUDITABLE TRAIL EXISTS THROUGHOUT l o EXPANSION OF WORK PROCESS, ATTRIBUTES AND SAMPLE SIZE IS i
l POSSIBLE WITHOUT IMPACTING OVERALL PROGRAM j ;
}
4 I
4
- ['
~ ' -
. . r. ,
y , .7, ,
STAFF TECHNICAL EVALUATION o CONDUCTED DURING PERIOD OF 12/3-10/85 o 70 TOTAL WORK PROCESSES CAPPROXIMATELY) o REVIEW PROCEDURE o DESIGN DOCUMENTS o INSTALLATION DOCUMENTS o QUALITY INSTRUCTIONS o CHECKLISTS o F00R NEW POPULATIONS o EVOLVED FROM OTHER POPULATIONS AS A RESULT OF PREVIOUS STAFF AUDITS AND DISCUSSIONS WITH UTILITY / CONTRACTOR o POPULATION PACKAGES NOT COMPLETED AT THE TIME OF STAFF EVALUATION 1 *g ,
o ' ^ -
,7- .
^-
g ?j':f -
f '
PROGRAMMATIC CONCERNS l j d FOUR CONCERNS WITH POTENTIAL TO EFFECT PROGRAM ADEQUACY d A REINSPECTION OVERVIEW PROGRAM IS REQUIRED TO ENSURE ACCEPTABILITY OF PROGRAM RESULTS SOME REINSPECTION DISCREPANCIES HAVE BEEN IDENTIFIED o A PROCEDURE FOR EVALUATING CHANGES (REVISIONS / SUPPLEMENTS)
TO 01'S DURING IMPLEMENTATION IS REQUIRED TO ENSURE CONTINUITY OF THE REINSPECTION o CRITERIA FOR DEALING WITH INACCESSIBLE SAMPLES MUST BE DEVELOPED AND INCORPORATED INTO THE PROGRAM PLAN o PROCEDURES FOR DETERMINING MATERIAL COMPLIANCE MUST BE DEVELOPED AND INCORPORATED INTO THE PROGRAM PLAN
- ^ ^
APPLICANT COMMITMENTS o AN OVERVIEW PROGRAM WILL BE IMPLEMENTED o A PROCEDURE FOR EVALUATING CHANGES TO DI'S WILL BE DEVELOPED AND IMPLEMENTED o CRITERIA FOR DEFINING INACCESSIBLE SAMPLES AND HOW THEY WILL BE HANDLED HAVE BEEN IN EXISTENCE. CRITERIA WILL BE FORMALIZED FOR EACH POPULATION t
4 i
t - _ _ _ _ _
5'
, . m e m .
. .l 1
STAFF CONCLUSIONS TO DATE o THE SELF INITIATED CONSTRUCTION ADEQUACY PORTION OF THE CPRT PROGRAMPLAN7WHENPROPERLYIMPLEMENTED'iWILLBEASIGNIFICANT CONTRIBUTORTOTHEOVERALLREASONABLEASSURANCEEVALUATIONOF THE ADEQUACY OF PLANT CONSTRUCTION o ACCEPTABLE IMPLEMENTATION OF CONSTRUCTION ADEQUACY REINSPECTION IS PREDICATED ON APPLICANT ADDRESSING PROGRAMMATIC CONCERNS ,
OUTSTANDING ITEMS o MATERIAL COMPLIANCE CONFIRMATORY ISSUES o 0VERWEW PROGRAM o EVALUATION OF QI CHANGES o POPULATION INACCESSIBLE SAMPLE CRITERIA PENDING FURTHER EVALUATION o ITEM SELECTION FOR INSPECTION L _ -. _ _ _ _ - _ _
.s '%!
gr .
l l
l INSPECTION REPORTS SEPTEMBER REPORT OCTCSER REPORT NOVEMBER REPORT i
4
( .
O
, , , _ . - _ _ . _ . . , , _ . , , .I_,, - , ,.3,, - , , _ , . , , , .~ , - . _,y ,,m.., . . . - . . . ,_,,,. _ , _ _ , .
I
,,j;. l.deJ (W#
.. .g ,_
4
('x.' f" . ,.. i.
i' g9
?* .
l
.y. .
. F. .
NRC COMANCHE PEAK REGION IV GROUP 4
REGION IV ACTIVITIES CONTINUE WITH TEN RIV PERSONNEL ASSIGNED TO THE COMANCHE PEAK THERE ARE PRESENTLY 10 CONTRACTOR PERSONNEL ASSISTING THE RIV TEAM LEADERS ON SITE THE MAJORITY OF THE REGION IV INSPECTION EFFORT (13 INSPECTORS) IS BEING EXPENDED IN WITNESSING AND INDEPENDENTLY INSPECTING THE HARDWARE REINSPECTIONS(ISAPVII.C)
ONE CONTRACTOR IS ASSIGNED FULL TIME TO FOLLOWUP DN THE REMAINING
. TRT QA/QC ALLEGATIONS. ADDITIONAL CONTRACTORS WILL BE ADDED IN JANUARY TO ASSIST IN THIS EFFORT.
(. -
REGION IV IS ALSO ASSISTING IN REVIEW OF THE TUGC0 RESPONSE TO NRC STAFF EVALUATION OF THE CPRT PROGRAM PLAN l e :.)
,.N658 4.r5
- f. $,I. ,
.t ,
.j g' r j
lk ,
f <
-d ,
I e , *
'^4rJ ,fh3 f
= . x. . 4I
,y fp . ;jpI!.m
-_- _ _ -_ __ _ _ _ _ - _ _ _ . - - --,+-------,m- - - - .M
.o !
-)
- ,1., . -
E
( i
- f. INSPECTION STATUS CPRT ACTIVITY AS OF DECEMBER 11, 1985, REGION IV HAS PERFORMED THE FOLLOWING INSPECTIONS:
ISAP VII.C (UALITY OF CONSTRUCTION AND CONSTRUCTION QA/QC ADEQUACY PROGRAM PLAN
- 252 REI SPECTIONS WITNESSED 99 INDEPENDENT INSPECTIONS 91 DOCUMENTATION INSPECTIONS FOR BEST UTILIZATION OF MANPOWER WE WILL CONCENTRATE ON
. INDEPENDENT INSPECTIONS OTHER ISAP HARDWARE INSPECTIONS
- V.c BUILDING GAP ONGOING INSPECTION
- V.a SKEWED WELDS WITNESSED 9 INDEPENDENT 7 -
- V.d PLUG WELDS
{- WITNESSED 48 INDEPENDENT 10
- VII.b.2 VALVE DISASSEMBLY WITNESSED 8 INDEPENDENT 7
- VII.b.3 PIPE SUPPORTS WITNESSED 0 INDEPENDENT 9 ,
- PAINTED WELDS WITNESSED 7 0F 120 i
WILL WITNESS 100% OF THIS ACTIVITY l
- OTHER ISAPs INDEPENDENTLY VERIFYING CONFORMANCE TO EACH ISAP WAITING ON THE RESULTS REPORTS
(
l , - -
7 '
~
~
. l
~
l i MATERIAL COMPLIANCE THE REGION IV OBSERVATION IS THAT VERIFICATION OF MATERIAL AND COMPONENT COMPLIANCE WITH PROCUREMENT / DESIGN REQUIREMENTS IS NOT BEING ADDRESSED WITHIN THE CPRT ACTIVITY.
IN THE CPRT ONSITE ACTIVITIES. WE OBSERVE THAT VERIFICATION OF ,
MATERIAL AND COMPONENT COMPLIANCE BASICALLY STOPS WITH THE BILL OF MATERIALS, CERTIFICATE OF COMPLIANCE, AND/OR CERTIFIED MATERIAL TEST REPORT.
(.
I x
(
s .
1 2 gz y DESIGN ADEQUACY REVIEW "j;f,'
"SELF INITIATED PROGRAM"
{. . . .
...a d}$$.. . '
. ;.c- STAFF AUDITS:
- ic l
l l REVIEW SCOPE VALIDATION l
FHASE 1 - CPRT REVIEW 0F IDIS & IDVPS SELECTION T AFW SYSTEM PHASE 2 - CPRT CONCLUDES AFW REPRESENTATIVE & OTHER SYSTEMS IN PLANT
(.
(CPRT PROGRAM PLAN SUBMITTAL, JUE 28,1985)
PHASE 3 - DEVEL0FtENT OF DESIGN ACTIVITIES FROM REVIEW T G & H AND TNE INDICES T:
. PLANT SPECIFICATIONS ~
. ANALYSES
. CALCULATIONS
. DRAWINGS
, PROCEDURES
. NRC STANDARD REVIEW PLAN
,FSAR
. OTERS
l-0 N - IDENTIFICATION OF DESIGN ACTIVITIES .
( , ENGINEERING EVALUATION Sttf%RY REPORT i
1 I
. DISCIPLINE SRCIFIC ENGINEERING EVALUATIONS (ELECTRICAL, INSTRLENTATION/ CONTROL, EOiANICAL AND CIVIL /STRXT, URAL)
- ESTABLISWENT OF HOMOGEEITY FOR DESIGN _
ACTIVITIES CONTN ATTRIBUTES - DESIGN CRITERIA DESIGN ETHODOLOGY .
DESIGN ORGANIZATION DESIGN CONTROL DESIGN INTERFACES
{,
- JUSTIFICTION OF IDENTIFIED HOK)GENEDUS DESIGN ACTIVITIES i
DESIGN ADEQUACY PROCEDURE - DAP21 (DRAFT)
"HCF0 GEE 0VS DESIGN ACTIVITY VALIDATION"
. INTERPRETATION OF HOM) GENE 0VS DESIGN ACTIVITY ATTRIBlffES l
. H00 GENE 00S DESIGN ACTIVITY t DESCRIPTION AM) VALIDATION CEO(LIST
(
O
STAFF FINDINGS: .
EVIEW SCOPE EVALUATION PHASE I a 2 -
STAFF TRANSMITTAL TO TUGC0 (8/9/85, 9/30/85)
FHASE 3 -
DEVELOPENT AE IDENTIFICATION OF DESIGN ACTIVITIES INCUI)ED IN:
. DOClfENTATION OF IEICES AE ENGIEERING EVALUATIWS PRESENR.Y BEING EVIEWED HOT)GENEOUS DESIGN ACTIVITIES
(,
. DESIGN CRITERIA ARE DOCTENTED EJR ALL IDENTIFIED ACTIVITIES AND PRESENTLY BEING EVIEWED
. PETHODOLOGY IN FORM OF l ENGIEERING GUIDELIES HAS BEEN IDENTIFIED FOR SOE DISCIPLINES
. DESIGN ORGANIZATION ADEQUATELY DOClMNTED G & H AND TE SCOPE OF DESIGN f
O
j
- r. . DESIGN CONTROL AM) INTERFACES
.. ADEQUATH.Y DOCIM NIED IN PROJECT PROEDURE NAMJALS FOR THE G & H SCOPE OF DESIGN ClfTSTANDING AR.AS
. CPRT REVIEW AND DOClFENT REVIEW PEllE0 LOGY FOR ALL DESIGN ACTIVITIES
. CPRT COPPLETE DESIGN ADEQUACY PROCEDURE (DAP-21)
. CPRT REVIEW AM) DOCIPENT DESIGN CONTROL AND INTERFACES FOR TE TE SCOPE OF DESIGN l
(
1 l
- * 'JN
/ ~g .
l' b 4,;Yb
> c ,.
df.t OVERVIEW 0F STAFF EVALUATION OF CPRT PROGRAM vjy CONSTRUCTION ADEQUACY REVIEW o EXTERNAL SOURCE ISSUES
- ACCEPTABILITY OF ISAPs Uf0ER REVIEW
- STRUCTURE FOR CAPTURING FUTURE ISSUES UNDER REVIEW o SELF-INITIATED REVIEW
- AUDIT REVIEWS COMPLETED
- DOCUNENTATION TRAIL ESTABLISHED
- FOUNDATION ALMOST ANCHORED o DETAILED PRESENTATION - E. TOMLINSON DESIGN ADEQUACY REVIEW
,. o EXTERNAL SOURCE ISSUES
~. - ACCEPTABILITY OF DAPs UNDER REVIEW f-
'. , - STRUCTURE FOR CAPTURING FUTURE ISSUES UNDER REVIEW
( .
o SELF-INITIATED REVIEW
- AUDIT REVIEWS C(MPLETED .
. . .. . - DOCUMENTATION TRAIL ALMOST ESTABLISHED j.. - FOUNDATION FLOATING BUT IN PLACE o DETAILED PRESENTATION - E. MARINOS h.,SERONCPRTPROGRAMPLAN ,
"o IN PREPARATION l?, .
o PRESENTATION OF SER OUTLINE - J. CALVO
\ , _ j !. -
e l R. :3' I
?
( .., ;
.r
...i
- e 1 -
s .. ,
i
, I k
SER ON CPRT PROGRAM PLAN OUTLINE o EXECUTIVE SUP9(ARY o STAFF EVALUATION OF THE CPRT PROGRAM PLAN o STAFF EVALUATION OF THE CPRT DESIGN A9EQUACY REVIEW o . STAFF EVALUATION OF THE CPRT CONSTRUCTION ADEQUACY REVIEW 4
i i
i l
l l
l l
E
/
'hji;d.f ,
4 % ,-
u .g ~
. l s'
~
,,w .
EXECUTIVE SUPetARY
. ,4. ,
.* .h1,.0 .
> r....
" '-?~ ' o INTRODUCTION o Supe %RY OF NRC REVIEW AND EVALUATION o CONCLUSIONS
. o SUP9%RY OF OUTSTANDING ISSUES
. o CONFIRMATORY ISSUES 1
('
i i
i I
( .
- 1
\
(. Me Vp.:
- n ~
r'
- 7. %gy. ' f>> ,
SER STAFF EVALUATION OF CPRT PROGRAM PLAN o INTRODUCTION
- o CPRT PROGRAM PLAN DESCRIPTION l o NRC REVIEW AND EVALUATION o CPRT COMMON REQUIREMENTS FOR DESIGN AND CONSTRUCTION REVIEWS
, - QA/QC OF CPRT ACTIVITIES i
j, '
- INTRODUCTION
- CPRT APPROACH
- STAFF EVALUATION
(~'
- CONCLUSIONS
- ACCEPTANCE CRITERIA
- CORRECTIVE ACTIONS l
- INDEPENDENCE OF THE CPRT/SRT ORGANIZATION
- - DISCIPLINE INTERFACES o OVERALL SUPMARY AND CONCLUSIONS l
l
(
s' i .
~
n SER
{ STAFF'TVALUATION OF CPRT DESIGN ADEQUACY PROGRAM PLAN o INTRODUCTION o CPRT PROCESS FOR EVALUATION o STAFF REVIEW AND EVALUATION APPR0ACH o EXTERNAL SOURCE ISSUES
- INTRODUCTION
- EI&C SYSTEMS AND COMPONENTS ISSUES
- INTRODUCTION
- CPRT APPROACH -
- STAFF EVALUATION
- CONCLUSIONS
- MECHANICAL SYSTEMS AND COMPONENTS ISSUES -
- ClVIL AND STRUCTURAL ISSUES
- PIPING AND SUPPORTS ISSUES
- CLOSED EXTERNAL SOURCE ISSUES o SELF-INITIATED EVALUATION .
- SCOPE
- INTRODUCTION
- CPRT APPROACH HOMOGENOUS DESIGN ACTIVITIES SELECTION OF REVIEW ITEMS
- STAFF EVALUATION
- CONCLUSIONS
' (-
- EI&C SYSTEMS AND COMPONENTS DESIGN ACTIVITIES
- MECHANICAL SYSTEMS AND COMPONENTS DESIGN ACTIVITIES
- CIVIL AND STRUCTURAL DESIGN ACTIVITIES
- PIPING AND SUPPORTS DESIGN ACTIVITIES o EXCLUSION OF VENDORS AND OTHER ORGANIZATION ACTIVITIES o OVERALL St#9tARY AND CONCLUSIONS l
f 1
~ _
? .
( l i
SER STAFF EVIEDATION OF CPRT CONSTRUCTION ADEQUACY PROGRAM PLAN o INTRODUCTION o CPRT PROCESS FOR EVALUATION o STAFF REVIEW AND EVALUATION APPROACH o EXTERNAL SOURCE ISSUES
- INTRODUCTION
- E&I ISSUES
- INTRODUCTION
- CPRT APPROACH
- STAFF EVALUATION
- CONCLUSIONS
- TEST PROGRAM ISSUES
- MECHANICAL AND PIPING ISSUES
- CIVIL AND STRUCTURAL ISSUES
- QA/QC ISSUES
- MISCELLANEOUS ISSUES
- CLOSED EXTERNAL SOURCE ISSUES r, o SELF-INITIATED EVALUATION
( - SCOPE
- INTRODUCTION
- CPRT APPRQACH HOMOGENEOUS CONSTRUCTION ACTIVITIES SELECTION OF INSPECTION ITEMS
- STAFF EVALUATION
- CONCLUSIONS
- ELECTRICAL EQUIPMENT POPULATIONS
- MECHANICAL EQUIPMENT POPULATIONS
- STRUCTURAL POPULATIONS o EXCLUSION OF VENDORS AND OTHER ORGANIZATION ACTIVITIES 1 o OVERALL SUP9tARY AND CONCLUSIONS l
c
p --
SER ON CPRT PROGRAM PLAN RES0JRCES 'N o NRC STAFF - 12 o CONSULTANTS - 14 -
- TELEDYNE ENGINEERING SERVICES
- ENGINEERING ANALYSIS SERVICES INC. .
- WESTEC SERVICES, INC.
- ZYTOR INC.
- EG&G IDAR0, INC.
[" - BATTELLE COLUMBIS LABORATORIES
- INDEPENDENT l
r l
Meeting Summary Distribution
'Docke'tior.de$tralFile NRC Participants NRC PDR Local PDR V. Noonan PD#5 Reading File R. Partin, RIV J. Partlow (Emergency Preparedness T. Westenrun, RIV only) L. Shao Branch Chief J. Calvo Project Manager E.Marinos OELD C. Tramnell E. Jordan D. Jeng B. Grimes D. Lurie ACRS(10) A. Vietti-Cook C. Hale, RIV L. Chandler E. Tcmlinscn J. Knox D. Landers, (TES)
C. Early G. Mizu:m C. Haughney, (Camex Corp)
D. Norkin cc: Licensee and Plant Service List
.