ML20154F715
| ML20154F715 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 02/28/1986 |
| From: | NRC |
| To: | |
| References | |
| NUDOCS 8603070512 | |
| Download: ML20154F715 (77) | |
Text
i I
O UNITED STATES NUCLEAR REGULATORY COMMISSION IN THE MATTER OF:
DOCKET NO:
BEAVER VALLEY UNIT 2 ENGINEERING ASSURANCE PROGRAM O
LOCATION:
BETHESDA, MARYLAND PAGES:
1 - 76 DATE:
. FRIDAY, FEBRUARY 23, 1986
=
ls p'o.
o ACE-FEDERAL REPORTERS INC.
V
- l Ctf. inal R;vnrn 444 North Capitos Stret Washington, D.C. 20001 (202) 347-3700 I,[hU[f>bk$
)
,l[
20 NATIONWIDE COVERACE
_ _ _ -.. _ ~__ _ - - -
U%Cs-Ac.
m k'[
TL c o n : :7
, a rg/ m Ylfek.Sf' A n sw'
~4 e
i v
Jiu % t-s u7 t
CR26026.0 l
OMT/Cjg 1
l' UNITED STATES 0F AMERICA 2
NUCLEAR REGULATORY COMMISSION I
l m--
MEETING OF NRC STAFF AND DUQUESNE LIGHT COMPANY 3
BEAVER VALLEY UNIT 2 4
ENGINEERING ASSURANCE PROGRAM 5
6 Nuclear Regulatory Commission Room 550 4350 East-West Highway 7
Bethesda, Maryland l
8!
Friday, February 28, 1986 9,
I l
go The meeting of NRC Staff and Duquesne Light Company l
representatives convened at 9:10 a.m.
gj 12 l PRESENT:
i
()
13 [
PETER TAM, NRC - Beaver Valley Unit 2 Project Manager l
3 TED DEL GAIZO, WESTEC Services /NRC Contractor ja HAI-BOH WANG, NRC/IE E. V.
IMBRO, NRC/IE AN M, NRC/IE 15 BRIAN GRIMES, NRC/IE GARY BEATTY, Duquesne Light Company 16 ROGEx MARTIN, Duquesne Light Company R. W.
TWIGG, Stone & Webster Engineering, Inc.
17 JOHN THOMAS, Duquesne Light Company P.
K.
EAPEN, NRC/ Region I pg L.
E.
TRIPP, NRC/ Region I W. M.
EIFERT, SWEC, Chief Engineer, EA HUEERT MILLER
)9 l
20 21 1 2?
23
]
24 '
4.e Feseval Ceoorters, Inc.
25 h
Il
'l t
0260 01 01 2
LIVEbw 1
PROCEEDINGS 2
MR. TAM:
Good morning.
This is the Beaver 3
Valley Unit 2 meeting.
I am Peter Tam, the Unit 2 Project 4
Manager.
5 The purpose of today's meeting is to talk about 6
Beaver Valley's engineering assurance program, and of 7
course, our IDVP program.
8 But before we go into the meeting, I would like, 9
for the benefit of our court reporter, to have each of us 10 introduce himself so he knows where he is seated.
11 I already introduced myself.
12 MR. TRIPP:
I am Mr. Tripp.
I am Chief of the 13 I Project Section in Region 1.
It has Beaver Valley Units in
(])
14 it.
I am Ted Del Gaizo with WESTEC 16 Services.
I am an NRC contactor for IDI/IDVP support.
17 MR. WANG:
My name is Hai-Boh Wang, IE.
18 j MR. EAPEN:
My name is E. K.
Eapen.
I am Soction 19 Chief for Quality Assurance in Region 1.
20 MR. IMBRO:
My name is Gene Imbro.
I am Acting 21 Section Chief of the Licencing Section in the Quality 22 Assurance Branch.
23 l MR. ANKRUM:
Ted Ankrum, IE.
24 MR. GRIMES:
Brian Grimos.
Director of OA,
()
25 Vendor and Technical Training Center, IE.
ACE. FEDERAL REPORTERS, INC.
202 347 3700 Nauonwide Coverage 800 33HM6
0260 01 02 3
LIVEbw 1
MR. MILLER:
Hubert Miller.
I am Brian Grimes' 2
deputy.
3 MR. TWIGG:
Dick Twigg.
Stone & Webster 4
Engineering Corporation, Engineering Assurance Division.
5 MR. EIFERT:
Bill Eifert.
Bill Eifert, Stone &
6 Webster, Chief Engineer of Engineering Assurance.
7 MR. JOHN THOMAS:
John Thomas, Duquesne Light 8
Company, manager of Project Engineering for Unit 2.
9 MR. MARTIN:
Roger Martin, Duquesne Light 10 Company, Manager, Regulatory Affairs.
11 MR. BEATTY:
Gary Beatty, Duquenne Light.
12 MR. TAM:
Okay.
Now we all know who we are.
O 13 3u e tiett ate or 6 cx ro=#a-e 14 On November 22, 1985, the Commission sent a 15 letter under the signature of Hugh Thompson to Duquesne 16 Lig ht.
And this is the letter, requesting that Duquesne 17 l Light say something about IDVP or whatever they are i
18 proposing.
And this is as a result of a request from I&E 19 about a year ago to snnd such a letter.
And Duquesne Light 20 responded by a letter dated January 17, 1986, basically 21 saying that we have a number of programs and activities 22 '
going on which we believe would be a good substitute.
23 I The purpose of today's meeting is that we can get 24 together and hear some ideas about some of these programs, 25 especially the so-called " engineering assurance program."
ACE. FEDERAL REPORTERS, INC.
202 347 3700 Nansenwide Coverese too.3)H 646
0260 01 03 4
LIVEbw 1
With this kind of opening, I would like to turn 2
this over to George Ankrum, who is the Branch Chief 3
responsible for this activity.
4 MR. ANKRUM:
I would like to lay a foundation, 5
and in particular, address some of the points in the January 6
17, 1986 letter.
3 7
MR. MARTIN:
First, may I ask, you will be 8
following up with a written response to our letter?
Is that 9
the plan?
10 MR. ANKRUM:
Why don't we cover that at the end.
11 MR. MARTIN:
All right.
12 MR. ANKRUM:
To give you the background of why
()
13 you received the original letter from the Division of 14 Licensing, following the Diablo Canyon mirror image design i
15 problem, it became apparent to the NRC that the QA 16 programmatic audits that most licensees had undertaken were 17 not effective in detecting potential errors in design.
And 18 it became apparent to us that what was needed were technical 19 audits, as contrasted to programmatic audits.
The NRC at 20 l that time was f aced with a rather large number of plants 21 that were in the final stages of licensing, NTOLs, as we 22 call them, and the director of NRR determined that he would 23 ask each utility to provide whatever assurances they could 24 that they didn't have similar kinds of design errors as 4
25 those found at Diablo Canyon.
ACE FEDERAL REPORTERS, INC.
202 347 3700 NatenwWe Covernee 800144M6
0260 01 04 5
LIVEbw 1
A number of utilities performed then -- or 2
contracted, I should say for a third part to come in and do 3
a technical audit of the design of their plants and offered 4
that as a justification -- or perhaps justification is the 5
wrong word -- of fered that as further evidence that the I
6 designs were adequate and met NRC's regulatory 7
requirements.
8 Those adopted the name IDVP or Independent Design 9'
Verification Program, and we reviewed and accepted those 10 undertakings for the purpose that they were intended.
1 11 Beginning in January 1 of '84, now, was it, I&E took over 12 responsibility for review of the design efforts, and the
()
13 program has expanded since that time to other things than 14 simply third party reviews of a utility's design.
They have 15 l taken the form of direct NRC inspections, the IDI or I
16 Integrated Design Inspection.
They have taken the form of a 17 readiness review, in which design was one aspect reviewed by i
18 the utility in their readiness review.
And it has taken the 19 form of an engineering assurance program which was a larger 20 and more comprehensive set of technical audits performed 21 i in-house by the utility or its AE firm or sometimes a third 22 party AE firm, but did not have the degrees of independence 23 that the IDVPs had.
24 The I&E Staff has determined -- has reviewed all 25 of those different methodologies and found that we were able ACE-FEDERAL REPORTERS, INC.
202 347 3700 Nationwide Coverage 800 3364M6
0260 01 05 6
LIVEbw 1
to come to useful conclusions about whether or not the 2
designs of plants met the NRC's requirements through any of 3
those methodologies.
4 In work where NRC did a direct inspection, we 5
performed the performed the inspection ourselves and issued 6
an inspection report which said, essentially, that we have 7
inspected the design, and we believe that the design 8
complies with requirements.
9 Where one of the other methodologies were used, 10 we provided a safety evaluation report to the Division of 11 Licensing, again, giving them our conclusions as to whether 12 or not the design met regulatory requirements.
13 With that background, a similar letter was sent 14 to Duquesne Light with regard to Beaver Valley Unit 2, and 15 that is what we are here to discuss today is what has 16 Duquesne Light done over and above the QA programmatic 17 audits to establish that the design meets NRC requirements.
18 :
Now I would like to address in particular in your 19 January 17 letter, you closed by noting that the Staff 20 i should apply the backfit requirements, shouldn't we be 21 talking about and IDI or an IDVP.
22 i I would like to say that.the NRC Staff has never 23 required an IDVP, and to do so would clearly be a backfit.
24 '
We do not have any intention of requiring Duquesne Light to 25 do an IDVP.
I might add that what we have asked is the ACE. FEDERAL REPORTERS, INC.
202 347 3700 Nationwide Coveraos M3M4M
h 0260'01 06 s
7 LIVEbw 1
question -- the question we have asked of each utility is, o
2 what additional means beyond QA programmatic audits have you 3
done to assure yourselves that the design meets regulatory 4
re uirements?
f 5
Some utilities have elected to do an IDVP, which a
6j we flave accepted.
They have also offered other 7
alternatives which got to the same purpose, and we've 8
accepted those alternatives.
9 With respect to an IDI, that is a direct NRC l,
10 inspection, and it is not subject to any backfit 11 requirements, regulations, analyses, whatsoever.
Should we
~12 elected to do an IDI, that is within our regulatory 13 prerogatiN.s, and we will undertake that particular endeavor 14 as the circumstances warrant.
So with that' foundation, I would like to turn 15 l
.i 16 )
'over:the presentation then to Duquesne Light.
17,
MR. MARTIN:
All right.
Duquesne Light t
18 l appreciates the opportunity to talk with you people about 19 some of the things that we have done.
I think it is very vitaEthatwesharethehistoryofwhathastranspired.
20 21 one of the things that you mentioned is the 22,
in-depth technical audit versus the programmatic type 23 audits.
24 We have performed on Beaver Valley 2 project, 21 25 programmatic audits, and we have performed to date, three ACE-FEDERAL REPORTERS, INC.
202-347 3700 Nationwide Coverase 800-33M646
0260 01 07 8
LIVEbw 1
with you.
One would be our preliminary schedule for the 2
engineering assurance audit.
We have a limited number of 3
copies.
We could maybe make more available or discuss this 4
handout.
5 What is your pleasure?
6 MR. ANKRUM:
The key people that need the 7
handout -- well, we'd need probably two copies over here, I 8
think.
9 MR. MARTIN:
All right.
We will provide a copy 10 for the record.
11 The other handout which we have is a document --
12 we have a documentation of the technical audits which have
()
13 been completed, and as I mentioned, those audits, the first 14 audit was held between November of '83 and February of '84.
15 Let me see if I am correcty here.
Yes.
16 That utilized approximately 2000 man-hours, and 17 it was of the fuel pool cooling and clean-up system.
There 18 were 16 individuals involved in that particular audit, and 19 they were Stone & Webster specialists and Duquesne Light 20 personnel.
There were several Duquesne Light personnel that 21 participated in this particular audit.
22 The second audit was frcm August '84 to June of 23 '
'84.
It required approximately 2000 man-hours, and here 24 again, it was of the engineering activities at the site, and (O
_/
25 it included auditing of instrumentation, controls, ACE-FEDERAL REPORTERS, INC.
202 347-3700 Nationwide Coverage 800 3M46M
0260 01 08 9
LIVEbw 1
engineering, mechanic, structural and electrical and power 2
disciplines.
There were ten people involved in that 3
particular audit.
4 The most recent audit of the hazardous analysis 5
program, which dealt with the calculations to address the 6
potential for pipe failure, pipe width, internally generated 7
missiles.
That was in a 1000 man-hour effort, and it took place from November of '85 to January of
'86.
Here there 8
9 were six people, Stone & Webster and Duquesne Light 10 personnel involved.
11 I think what we would like to do would be -- we 12 also would like to call your attention to our own Duquesne
[h 13 I Light initiated internal auditing program.
Our engineering 14 confirmation program and our design basis endorsement l
15 l program have been under way since March of 1983, and we have 16 i dedicated approximately 11,000 man-hours.
We have had 48 17,
Duquesne Light corporate engineers involved in the review of 18 l systems, and Stone & Webster has had 50 Stone & Webster 19 l engineers following up on the items that have been 20 reviewed.
21 This was a four-part internally initiated and 22 administered auditing feature, where we took the criteria documents and took the design information, the drawings, the 23 l 24 l construction type details that came from those design 3
i 0
25 documents and followed it through some calculational I
ACE-FEDERAL REPORTERS, INC.
202 347-3700 Nationwide Coverage 80433MM6
0260 01 09 10 LIVEbw 1
review, particularly electrical and structural calculations 2
with considerable emphasis upon electrical and structural 3
calculations, and then verified in the field, so that the 4
engineer who was responsible for looking at the design 5
criteria initially -- as you are familiar with the two BBMs 6
and the engineering assurance procedures.
You are all 7
familiar with those.
8 Those were reviewed for correctness, 9
completeness, up-to-date current value, and they were taken 10 and compared with the design documents, the drawings and the 11 calculations.
Were they complete?
Did they follow the 12 codes and standards?
^'
13 i Then those design documents were utilized to go 14 into the field and check wiring, to check piping runs, check j
i 15 !
hangar designs, things of that order, to verify, from i
16 beginning to end, that the controls were satisfactory, not 17 only the controls but calculations.
I 18 j We rcognized the programmatic, checking that the 19 right signatures appear in the right places and the detailed 20 j design, the reviewing the calculations.
21 l We have identified some discrepancies, 22 particularly in some voltage drops on electrical cable.
4 l
23 l kV.
I think Lowell is familiar with some of those things 24 l that we have identified, and necessary corrections havae (J
25 been made to update those calculations and, if necessary, ACE FEDERAL REPORTERS, INC.
202 347-3700 Nationwid: Coverage N336-6646
0260 01 10 11 LIVEbw I
actually replace a portion of cable in one particular 2
location, as I recall.
3 The engineering assurance program which Stone &
4 Webster has carried on -- and we participated in that.
I 5
mentioned that previously.
The Duquesne quality assurance 6
program, which is another parallel program.
In addition, in 7l our letter we mentioned the fluid system design l
8I finalization.
Maybe we could touch on that a little bit.
9 That began -- early in '78, we had an outside contractor 10 review the fluid systems and review flow calculations, 11 review the pressure drops, the drops across the valves, the 12 pump, the discharge pressures.
Things of that o rde r.
Heat 1
(^')
13 i balance through the heater drain system.
14 And then in addition to that, we recognized that 15 ;
we needed to finalize the flow diagrams, so that we could 16,
incorporate the requirements of the testing program and also i
17,
the requirements of the interface with the nuclear ateam l
18 l supplier and the AE.
There we identified some 19 discontinuities which we called to the attention of the 20 l designers and addressed those.
21 We also have come items which are peripheal 22 1 type. We have used the NUS Corporation for review of the I
23 equipment qualification program.
We have had a considerable 24 '
amount of effort in PO, particularly getting one of tnese r~'s j
)
25,
hydrogen recombiners to be qualified.
We have had other i
ACE FEDERAL REPORTERS, INC.
202 347 3700 Nationwxie Coverage 8@33666M
0260 01 11 12 LIVEbw 1
people work with us on our ASME program, the soil structure 2
interaction, and other independent design reviews have been 3
undertaken.
4 I think that the message we bring that we would 5
like to present, the fact that by doing system audits, by 6
doing site activity audits, by doing a hazard program audit, 7
by actually having our Duquesne Light people who are 8'
specialists in their areas, some of these people from our 9
corporate offices have a number of years of experience on 10 Beaver 1, so they were familiar with the type of design 11 controls.
12 At the time we were reviewing Beaver 2, we were
()
13 establishing our in-house, independent design capability, 14 and we have divorced ourselves from the AE on the Beaver 1 15 in doing in-house design to you.
So we felt that those 16 {
people were qualified personnel to do, as you have 17 indicated, the very important detailed design review, i
18 l actually going through the calculations and checking the 19,
adequacy.
1 20 '
21 22 23 24
()
25 ACE FEDERAL REPORTERS, INC.
202 347 3700 Nationwnie Coverage M33Mee
0260 02 01 13 OMT/bc 1
MR. MARTIN:
I think that we would, with this 2
introduction, if John Thomas, would want to add any comments 3
from the engineering end.
Have I overlooked some items 4
there?
5 MR. THOMAS:
I don't think so.
I think our 6
letter we intend to be very complete, what routine line is 7 1 done in the way of assuring the design, completion design 8
wholeness, to use that term.
l l
9 Also, on Donald Webster plan and approved by l
10 Duquesne Light includes for it indepth technical audit
(
11 performed by engineering people in Donald Webster's home 12 office.
So that they are not part of the project staff.
]
13 I'd like to turn it over to Mr. Eifert now, who, 14 our plan is to discuss this next upcoming audit, and get any 15 comments that you might have or whatever, and just really l
l 16 review our plan.
And we have the schedule tentatively laid I
l 17 ;
out here.
It shows sort of the...I guess you'd call it a 18 plan for a plan.
19 But, also, as you can see, the detail work of 20 getting the audit plan together has not come in.
21 MR. MARTIN:
That's on page 3 of the handout.
22 It's Donald Webster, Engineering Assurance Technical 23 '
Audits.
The first two pages describe past audits; page 3 24 describas the upcoming audit.
25 MR. EIFERT:
Okay.
Thank you, John.
That's in ace FEDERAL REPORTERS, INC.
l 20b347 3700 Notionwide Coversee 800 336-6M6
(
l i
0260 02 02 14 l
1 OMT/bc 1
the second handout that we gave you.
Why don't I just walk 2
through the remainder of that handout.
3 The third page describes the planned scope of the l
4 upcoming audit.
And I'd like to skip over that, just leave l
5 it for a minute, and look at the remainder of that package, 6
go over briefly what's in that package.
7 The next page is kind of an overview of our 8
auditing activities since 1981.
And again identifies the 9
tech audits that we have done and the one that we're l
10 planning.
l 11 Following that is a brief description of the I
12 evaluation process we go through when we complete the last Q
13 j audit in the series, where we look at the results of all the 14 indepth technical audits and draw our overall conclusions 15 with respect to the adequacy of the design and the design i
16 process.
I 17 And that is an activity that we plan to complete 18 on Beaver Valley II af ter completing the fourth technical l
i 19 audit.
l l
20 The next page is a overview of the indepth 21 technologic bar chart Webster has.
Beaver Valley is right 22 on the top of that table, indicating when and where we 23 perform these audits of this nature.
24 Following that bar chart is a typical auto-25 chronology in some detail that basically identifies the l
ACE-FEDERAL REPORTERS, INC.
20L347 3700 Nationwide Coverage M 336 4646
0260 02 03 15 OMT/bc 1
normal duration and the activities, the details of it.
2 Attributes in the planning area are performance 3
activities and reporting of followup activities.
This is 4
presented as a demonstration of the depth that's...and the 5
timing of these audits.
6 Following that we have a statement about 7
guidelines about how we select a system for a system audit.
8 We picked this one to give us a real good representation of 9,
the design process and interfaces.
I won't go into that in 10 detail.
We've been looking at the potential system for the 11 upcoming audit.
And I'll have Dick Ivigg in a few minutes 12 here go through what our thoughts are at this point.
We m
haven' t finalized the system selection, but that will show
(
i 13 j 14 how we've applied this kind of criteria.
15 Generation of an action item is the next page in 16 ;
this handout.
This demonstrates the technique we use in i
17 l conducting these audits.
The more traditional quality i
18 l auditing effort is where you have a planned audit period to I
19 '
prepare a report, issue findings and then get the responses 20 to those findings.
21 We have used an action item actually in 22 l progress.
In the prneess of performing the audits, wa give l
23 i this a quicker turnaround of information with respect to any i
24 j concerns or questions we have or need for information during oC 25 the audit; it makes for a much more efficient, timely i
ACE FEDERAL REPORTERS, INC, 202 347 3700 Nataormie Coverage WF33MM4
0260 02 04 16 OMT/bc 1
process during the audit.
2 And then the last three pages of this handout is 3
the guideline that we've written to give to our audit team 4
as a guideline in hcw to make the judgments and when to 5
write an observation, how to determine the significance and 6
guidance on how to handle potential concerns during the 7
audit.
That's presented here for your information.
O MR. MARTIN:
I think I'd like to make a comment 9
about the need that we felt for guidelines.
I think we all 10 agree that there is a question in the mind of a reviewer and 11 auditor if he has a question about the significance of an i
12 audit, a discrepancy, let's say, or an incomplete O
13 i"cor= eto"-
14 We recognize that those are important items that 15 need to be addressed and that the guidance is given here to 16 help that reviewer put in that information so others can 17 understand what he was doing and the basis for his 18 i detenniuation, whether it was significant or not.
19 '
This is very important.
We recognize that.
20 l MR. EIFERT:
That is a very brief overview of our 21 process.
We are planning work now for the fourth and final 22 technical audit.
The planning has identified that we want 23 to use a system and also cover site activities, so a 24 combined audit in that sense.
(
25 The first handout that we gave you is our ACE FEDERAL REPORTERS, INC.
202 347 3700 NatknwWe Coserage M33MM6
0260 02 05 17 OMT/bc 1
schedule for conducting that audit.
And with that 2
introduction, I think what I would like to do is turn it 3
over to Dick, and let's talk first about where wo stand with 4
respect to selecting a system.
And we've identified 5
candidato systems and we' re narrowing in on that.
6 I'll let Dick brief you on that, and then Dick l
7l can walk us through the schedulo, the first handout that wo l
8' passed out this morning.
9l MR. TWIG:
My name is Dick Twig.
As Bill had 10 indicated, we are in the process of selecting the system, as 11 we've done on other technical audits.
The critoria that wo 12 have indicated, or some of the critoria, is just, first of 1
)
13 j all, the system must perform a safety-related function.
I 14 l We' re looking for a system that is reprosentativo 15 i where we can look to see the Webster design effort, and also 16 '
a strong interfaco with the -- functions that.
17 The sort Webster performs is such in a lot of 18 '
casos of taking some basic critoria that may bo established 19 by the intern list, suppliers, locating it, hyping it, 20 instrumenting it.
I 21 l We ' re looking for systems and multiple functions, 22,
that there is a certain amount at depth to it.
Those I
23 '
systems may perform in two or three di'ferent modos and wo 24 feel that lo, king at the dif f erent modes is bottor insight rb
(>
25,
into the design process.
ACE. FEDERAL REPORTERS, INC.
202 347 mn Neon *We coverese wM1we
0260 02 06 18 OMT/bc 1
Another key feature in selecting a system is the 2
state of obstruction of the system and also the state of the 3
reconciliation program...the as built reconciliation 4
program.
5 Duquesne Light has instituted its confirmation 6
programs, which are extensive.
And we want to be able to 7
take advantage or to evaluate how effective those systems 8
have been.
So we' re looking at a system that's gone through 9
various stages of the confirmation program.
10 We have, in looking, prior to doing these indepth 11 technical audits, Stone and Webster has done smaller, many 12 indepth technical audits, many technical audits on various O
13 v==
tehi" ea ea-2==te-14 In reviewing those that we have looked at and 15 reviewing other systems that have been reviewed by other 16 organizations, like INPO, three systems came to my pot.ential 17 for review.
i 18 The first one is the service water system.
It 19 j has got a very high level of Stone and Webster involvement 20 in it and very little interface with the interface 21 supplier.
But we are supplying a certain amount of levels 22 l to the various heat exchangers.
23 And also the service water system was reviewed, I 24 believe, by INPO.
So that we dropped that from our 25 consideration.
ACE. FEDERAL REPORTERS, INC.
202 147 1700 Nadon=6de Coverage ern13HM4
0260 02 07 19 OMT/bc 1
The second one was the auxilliary feed system, 2
which has always been a problem with a number of different 3
plants.
That is a system that has both Stone and Webster 4
involvement and also some Interbles involvement as a 5
potential candidate.
6 The third one, which is the safety injection 7
system, is a dual train system.
It has got -- the majority l
8 of the basic design is done by the Intrablus supplier.
9 r{owever, we feel that it still is a good example of taking 10 their criteria, installing it, piping it, which is a large 11 amount of work, as far as Stone and Webster is concerned, l
l 12 and doing the electrical systems that support it, that right O
ta ao
'r t
- imoco re ta revt=$cetoa vt 14 We have looked to both Gain Light and also the l
15 project in looking for particular areas that may be of j
16,
concern to them or that have not been looked at, and we're l
l 17 j open to comment on those selections.
I 18 MR. TRIPP In the auxilliary feedwater system, l
19 Roger, your folks looked at that in my confirmation program, 20 didn't they?
21 MR. MARTIN:
Yes.
22 MR. EMBRO:
I guess my only comment, this is Jim l
23 !
Embro, as you point out, the safety injection system is l
24 primarily designed by Westinghouse.
25 I guess that wo agroo, you know, Stone and l
ACE. FEDERAL REPORTERS, INC.
202 347 3700 NeuenwWe Coverage n00 ))HMe
0260 02 08 20 OMT/bc 1
Webster, goes from the piping.
And they have to, you know, 2
examine Westinghouse...and make sure that it all operates.
3 But I guess that the basic design is really, you know, 4
5 So I guess you have to think about how adequately 6
that's going to be evaluated across the Stone and Webster 7
design process.
8 Would you also be looking, if you did that 9
system, at the modes of operation, like RHR7 10 Well, let me say this.
When you were talking 11 about safety injection, I told you about both high pressure 12 and low pressure?
(])
13 MR. TWIGG:
Yes.
14 MR. EMBRO:
And the RHR modes of operation, in 15 addition.
The actual safeguards function?
4 I
j 16 MR. TWIGG:
Well, again, we're in the process of 17 seeing how far we're going to go.
We don't deal with it 18 l into the spray loads or the tying of the spray system.
But
(
19 the safety injection system, with both the high pressure and 20 the low pressure aspect of it.
And we do have a lot of 21 interfaces there.
You have a lot of high and low pressure 3
22 intorfaces involved which are important to look at.
i l
23 And we have a tie-in to the primary system i
24 directly.
(
25 MR. IMBRO:
Lot me ask another question.
i ACE. FEDERAL REPORTERS. INC.
302 347 3700 Nas6onw6de Covernoe sco))HM4
l 0260 02 09 21 OMT/bc 1
Scope of supply in terms of components, is that a 2
Westinghouse scope of supply in terms of turbine sink pumps, 1
3 heat exchangers, or others?
4 MR. TWIGG Those are supplied by the Interbles 5
cupplier, those are Westinghouse.
The amount of equipment 6
that is specified and ordered by Stone and Webster is 7
limited on system.
There is a limitation for the system f
8 that is supplied by Stone and Webster.
9 Some of the instrumentation also is supplied by 10 Westinghouse.
But we felt that because of the nature of the 11 system that it was a credible system and were able to look 12 at the total interface in that regard.
]
13 MR. IMBRO:
You knew, certainly, we agree it's a 14 critical system, but since it's predominantly a Westinghouse 15 design system; whereas they supply the IND's, plus they also 16 develop the logics to determine how the system operates, 17 basically, you're taking Westinghouse criteria and l
18 ;
implomenting it.
19 You know, which it's a very good example of the 20 system we have having an Interplus interface.
21 But it seemed like in this system the majority of l
22 the Stone and Webster effort would be geared pretty much j
23 toward piping, running piping, piping supports.
24 MR. TWIGG:
Piping, instrumentation and 25 l electrical, yes.
What Stone and Webster does is they take ACE FEDERAL REPORTERS, INC.
202 347 1700 Nationwide Coversee ars.))MM4
0260 02 10 22 OMT/bc 1
the elementarios that are furnished by Westinghouse and then 2
Stono and Webster develops the logic, diagrams and follow-3 through of design.
4 But I understand.
That's why I mentioned that it 5
does have very heavy interbles involvement in it.
6 MR. IMBRO:
Ukay.
I guess we'll go back and look 7
at your system selection critoria.
And one of the primary L
8l ones is, you know, extensive Stono and Webster design l
9 responsibilities, with interbles involvement.
10 It seems like the intrables involvement is the 11 !
more heavily predominant factor in this system, and not as 12 l much the select design responsibility.
I guess, from our I
(g) 13 point of view, we'd probably like to see you review a system 14 i that's moro, you know, select original design system.
15 i MR. TWIGG:
Well, as I say, we' re open for 16 '
comment in that regard.
The first technical audit wo 17 performed was on tho... cooling system.
And that has gotton 18 much heavior involvenent of Stono and Webster.
19 MR. ANKRUM:
That would have boon my comment, is i
20 that we needed to look at some of the earlier audits and 21 '
see if this particular question had boon resolved in one of 22 I the first three.
23ll But you've received our first-cut commenta on 24 this and I think we've made our point, so...
T'T
May I ask a question?
Rog e r 'ia r t in.
ACE. FEDERAL REPORTERS, INC.
2 2 347 3700 Natmnenk Covet see Un33MM4
0260 02 11 23 OMT/bc 1
For clarification, the desire for a system which has more 2
Stone and Webster involvement than the venicular steam 3
supplier is that it might be unique, that the NSS's 4
supplier's input might be more standardized or more 5
uniform.
And you're directing your interest for the system 6l that would be...
7 MR. TWIGG That's correct.
8 MR. ANKRUM:
One of a kind, maybe.
9 MR. TWIGG Not necessarily one of a kind, but 10 something which tests, which fully tests the capabilities of 11 the Stone and Webster design capability.
12 j MR. THOMAS:
I think Mr. Twigg is making the
()
13 point that we've done that once or twice now.
...is how 14 well you can take someone else's...and really make it work, l
15 recognize it's a little bit the other side of the coin, so 16 to speak.
17 And it's a real important attribute sometimes, 18 that interface maagement is more difficult than when you're t
19 trying to do the whole thing yourself.
20 MR. ANKRUM:
We agree completely.
Interface I
21 management is probably the most difficult thing to do.
And 22 it's the area that is most susceptible to problems.
Tha t 's 23 been our experience in previous design reviews, that many of 24 the problems occur either in interfaces between disciplines 25 or interfaces between organizations.
ACE. FEDERAL REPORTERS, INC.
202 347 3700 Nationwide Coverage 800 33MM6
0260 02 12 24 OMT/bc 1
So we agree that that's a very important thing to 2
tost.
And it's important, I believe, for you to look and 3
for us to also look and agroo with your across-the-board 4
reviews.
You've dono a lot of things here.
5 And somewhere in that should have boon a good 6
test of the capabilities of the Stone and Webster design 7
organization itself.
I 8
And somewhero else should be a good test of the 9
interfaces.
So it's necessary to look at the whole picture.
10 11 12 I
( )
13 1 14 15 l i
16 l 17 i
18 19 4
4 20 '
21 1
1 22 i l
23 l 24 l q'
25,
l ACE. FEDERAL REPORTERS, INC.
202 347 3700 Nationwide Coverage
- 80) 33MM6
1 1
0260 03 01 25 OMTbur 1
So I don't want to focus on just this fourth l
2 audit and whether or not it covers the Stone
- t. Webster l
3 orlainal design ef fort.
4 I think we have made our point, and it is i
5 necessary to look at the total program.
Somewhere in there 6
this should have been covered, not necessarily in the fourth 7
audit, and somewhere the interf ace should be covered, which j
8i sounds -- your propoual certainly does that in the fourtti i
9 audit.
10 I think I would just like to say our comments --
l 11 we have given you our input on this, and I don't think we 12 can add any more to that at this point in time.
[
O 12 aa raoa^s' r
ao=
ativ a t-to $u==
14,
pick the system to death.
I 15 MR. ANKRUM:
No.
Exactly.
1 l
16 MR. THOMAS:
Nothing like that.
You know, kick i
17 it around a little bit.
And I do appreciate the point that l
18 l it is intended to be a total thing, including all four 19 audits.
l t
20 MR. ANKRUM:
Yes.
l 21 MR. THOMAS:
And it is a good point that we 22 I should consider that when we are doing this other design.
23 MR. ANKRUM:
Yon, I would like to concentrate 24 today's discussion on how do we go forward from here to the O
25 eventual licensing decision on this plant.
ACE FEDERAL REPORTERS, INC.
l - - - -..
202 147 3700 Natnonekle Covernor 800 3)HM6
0260 03 02 26 OMTbur 1
MR. TWIGG:
As we have indicated in our l
2 preliminary schedule here, the timing of the schedule is 3
critical with a number of respects.
l 4
One, as I have indicated before, you want to look 5
at a system that has gone through the as-built t
6 reconciliation process, confirmatinn programs, and so that 7
we can' t have it too early because some of those systems may l
8 not be t.otally available or suf ficient samples withiri chone i
9 areas.
10 The second thing is that these audits are a lot 11 and dif ficult and that we don't want to get to the point 12 where we are impacting fuel load.
O ta ra een r i a ce or aet aei t i a ce cuta
\\
i 14 on the project would be as far as the scheduling of the i
l 15 l CAT.
It is our understanding that the CAT was originally 16 scheduled for April, but there was some indication that it 17 may be delayed.
18 So again that is an interface that we would be 19 concerned about and should be factored into the overall 20 schedule.
21 The plan --
22 MR. MARTIH:
May I clarify?
The source of our 1
23 l information was Mr. Taylor had given an indication that 24 because of the TVA activities there might be some of fact on O
~r 25 schedules such as the CAT, and these are two which wero ACE. FEDERAL REPORTERS, INC.
202 347 37tM Nanoide Coverase sto))6-Ande
[
0260 03 03 27 l
OMTbur 1
identified.
2 MR. TWIGG:
As affacted the schedules --
3 MR. MARTIN:
I think that is very obvious.
4 MR. EIFERT:
Including TVA.
5
( Laughter. )
i 6
MR. THOMAS:
I guess our question on that would 7
bei does anyone here have any information on what is 8
occurring?
9 MR. EIFERT:
Not specifically, no.
10 MR. THOMAS:
Well, do you think that ought to be 11 a consideration in this schedule, that the CAT - other than 12 not having people there at the same time doing similse
.O 12 tataa, whica, vo= xao,
ity o ta a occ=atea ia sother 14 project?
15 !
MR. IMBRO:
Not necessarily.
If the CAT is done i
16 prior to our type of audit, we try and pick up on the CAT 17 findings, and so in the process I suppose this ought to have 18 been done prior to the CAT.
19 '
MR. THOMAS:
It doesn't matter.
The two are 20 coordinated, in whatever order.
21 MR. TWIGG Where we are looking at the typical 22 audit chronology, you will see what we have indicated ss i
23 preliminary planning.
It is obtaining the scope of 24 completion of the various systems, getting input from the
(
25 project, from the client, and so forth.
1 ACE. FEDERAL REPORTERS. INC.
202 347 3700 Nationwide Coverses eno.))ume f
0260 03 04 28 OMTbur 1
The next stop would be to preparo a draft audit 2
plan.
And within the audit plan wo would identify what 3
system we are going to look at, and we would identify in 4
more detail what we feel the scope of the audit should be.
5 And the scope of the audit is something which we 6
feel that wo should got agrooment on up front so that we 7
don't have problems later on as far as adding to the 8 !
scopo.
9 I don' t want to speak necessarily for Duquosno 10 Light, but this is a concern that the scopo of the audit bo 11 bounded, and we railize that when one goes and finda f
12 i problems in a partscular area it is normal to expand the Il 13 '
scope and to datormine the extent of thoso conditions.
Wo 14 fool that is totally appropriate, and we understand that.
15 so that in this next --
16 MR. MARTIN:
We would like to address that, and 17 maybe it isn' t appropriate right here, but if there are somo 18 determinations about a doficiency, what guidelinos or rules 19 '
could be unod for expanding or controlling the -- lot's say 20 l a judicious soluction of which way to go.
21 If one calculation has difficulty, is it 22 appropriate to use the so;opling method of that typo of 23 calculation to assure e,uraolvou that that hopefully was an 24 isolated caso?
25 '
This is whoro wo are coming from.
Acc FEDERAL REPORTERS. INC.
I
- 02 341.Jun Nanonwale Coverase M4))WM
r l
l l
I 0260 03 05 29 OMTbur 1
MR. ANKRUM:
We have used that in the past.
2 MR. MARTIN:
Yes.
3 MR. ANKRUM:
I don' t believe we have ever gotten 4
into a situation in the design area where a wall-to-wall 5
review was necessary.
6 MR. TWIGG Right.
Let me just continue in the 7
area of the schedule.
8 Mid-April, we would expect we would be formally 9
into the audit preparation, preparing review plans and 10 reviewing documents.
11 About the 5th of May, we would start the active 12 part of the audit and interviews with the project
()
13 personnel.
We have essentially the month of May that we 14 l have slotted for that activity.
15 One week or maybe less will be involved in a site 16 review.
What we do at the site, we -- reviewing the actual 17 hardware and the site is effective from getting a feeling 18 for what the system in and how it relates with tne other 19 surroundings.
That is very important.
20 We also look at site activities that are 21 performed at the site, the ENDCRs, changed documents, the 22 nonconformance reports that we will be doing at the site, 23 '
and also any other types of drawing preparation that would 24 be done at the site.
25 This effort would be looking at within the ACE. FEDERAL REPORTERS, INC.
M.M731oo Nem
- cense son.) M w e
0260 03 06 30 t
OMTbur 1
particular system that we pick.
So the week of 5/19 to 5/23 2
would be what we have presently scheduled for the site 3
review.
4 We have tentatively set up a post-audit 5
conference date of 6/24, which time extends to a period from 6
the end of May through June.
We will be preparing a report 7
and a post-audit conference 6/24, and we issue the report l
8 approximately July 17.
9 At that point we would go into the follow-up f
10 phase, where we would be resolving whatever action items t
11 that had not already been resolved.
?
l 12 And the action items, I am quite sure everyono is O
is e
iti ten te, but ea v a to o = r i" ta
a
14 of the condition, the cause, and the corrective or
{
15 preventive actions that are appropriate.
16 In each case engineering assurance and the team 17 of individuals who are performing these verify as tho 18 adequacy of the project response and verify as the 19 completion of the design activity that has to be resolved by l
20 these -- from these action items.
[
l 21 MR. IMBRO:
C.et me ask a question to Duquesne.
j 22 I How would you envision the NRC participation in l
\\
23 this audit?
r 24 MR. ANKRUM:
Let's navo that for later.
I think 25 that is premature.
ACE. FEDERAL REPORTERS, INC.
0260 03 07 31 OMTbur 1
MR. TWIGG:
In conjunction with tho audit or the 2
inputs that wo uso -- and I am talking about Phaso II, whero 3
we -- the individual audits that are performed are each 4
evaluated for corrective and proventivo action for each of 5
the particular Ltoms.
6 In the ovaluation report, wo accumulato the data 7
together and wo look for tronds.
Wo look for particular 8
areas that nood additional attention.
9 Somo of this work is dono early on prior to the 10 audit itself, so that any potential problems wo 800 on the 11 past audits that have more of a trend can be factored into 12 the fourth audit to resolvo thoso conditions.
r's
()
13 Likowiso, attor the complotion of the fourth 14 audit, all the data is added together.
Wo summmarize the 15 !
data and wo group it to soo -- group it by cause, by typos 1
16 !
of problems wo find, then mako recommandations based on all 17 '
the roviow of tho data as viewod as approved.
18 '
MR. MARTIri:
I think that is uignificant, that wo l
19 '
use the value of the knowledge wo havo gained from previous 20 l audits, not only to establish the scopo for this fourth 21 audit but to also tako an ;vorview at tho end of the project 22 through the porlod of growth in the project.
23 '
MR. TW1GG:
And wo would expect that that total 24 offort will bo completod by tho firnt of tiovembor.
gs 25 MR. CITERT:
- Okay, I think that concludos our l
Act 1 lio!!nAL llEPonTI!as, INC.
- 021U439 Nem*We omene m14'M4
0260 03 08 32 T sOMTbur 1
overview of what we are planning, and it is early in tho
()
2 planning.
We are really scheduled to get started on this 3
next month.
4 I will turn it back to John and Rogor.
5 MR. TWIGG Unless there's any questions.
6 And we have gone through it very superficially 7
because we know that some of you have boon through part of 8
the process beforo.
9 MR. EAPEN:
This is P.K.
Espen.
I got two 10 questions.
11 Number one, how are you incorporating the 12,
experi.nces you have gathered from other sitos like Seabrook
()
13 and Nino Mile in developing this audit plan?
14 Number two, I had a lot of safety considerations, j
l 15 and there is another aspect coming up out of the woodwork; 16 namely, probably the risk assessment.
17 Are you ascribing any merit to the caunal 1
18 probability of this electric system?
19 That is my nocond question.
20 ftR. TWIGG The answer to the first question:
21 what we have dono in engineering assuranco, we have taken 22 all of the 10tr that have been performed and we have 23 reviewod the IDIs.
We have also roviowed the Cars, and we 24 have entered those into a program whero we can look at tho 25 data and group the data, and we havo tried to koop up with ACE FEDERAL REPORTERS, INC.
202 347.)m)
Nanon.we coversee allwm
0260 03 09 33 t
OMTbur 1
all the different new problems that are coming up.
2 So we do have a program where we go in and we 3
look at the IDIs and the CATS and use that information for 4
some of the detailed questions that we would be asking; also 5
the experience we have had most recently in Nine Mile and 6
Millstone.
There are particular areas that we know that we 7
should be looking for.
8 The second question, maybe if you can clarify i
9 that a little bit for me?
l 10 MR. EAPEN:
Well, I don' t know whether this I
11 particular site has PRA or PSA study.
My personal 12 experience in the past is when you look at the core melt
()
13 contribution probability for a given system it opens a few 14 extra eyes.
You know, it opens up certain areas where l
15 traditionally people did not spend a whole lot of time.
l 16 Disciplines are there, you know, that type of l
I 17 in fo rmation.
There is a whole host of information like that 18 available in the industry today if you don' t have your own 19 PRA or PSA.
20 MR. TWIGG:
Well, we have the studies that we 21 would review as f ar as the failure mode and the ef fects --
22 MR. EAPENs That is right.
I 23 '
MR. TWIGG:
-- on all of theue, and wu have I
i 24 traditionally looked at portions of these as we go in and do i
25 the audits.
Au:E. FEDERAL REPORTERS. INC.
l l
202 347 3700 Naionwtde Coverage aoS1 4 4646
0260 03 10 34 MTbur 1
As f ar as f ailure rates and these type of things, 2
they traditionally have not been included within, I believe, 3
the IDIs or the IDVPs.
4 MR. EIFERT:
You know, this is an audit of the 5
design process.
It is not an offort to identify all of the 6
' industry problems that may have occurred somewhere and 7
determine if it happens to apply or has been taken care of 8
with respect to the system.
That is not what we are doing.
9 We use our experience and our intelligence to 10 look at the general areas where there have been concern, but 11 we don't use this as a way to investigata if this particular 1
12 plant would have a problem -- inay, a problem that was O
13 L r part a ia, r
s broo ' tor-14 MR. ANKRUM:
I would like to reinforce that by 15 saying that this is a measure of how well the plant has been 1
16 ;
designed, given the design that NRC requires in its 17 regulations and as the utility is corr.mitted to do in its I
18 l PSAR.and PSAR, and those are the bases against which we 19 l measure things.
)
i 20 If it is in the PSAR or FSAR, that is the basis 21 against. which we are measuring the design process, and we 22 are not trying to nonsure how good this particular design 23 lI vis-a-vis some other design but how well did this design get 24 implemented within the scopo of the licensee's commitments 25 and NRC's regulations.
ACE. FEDERAL REPORTERS, INC.
202 347 3700 Nanon*6de Coverase
- 10.))H M4
0260 03 11 35 OMTbur 1
MR. TRIPP:
Do you consider things like the 2
number of information requests, number of EMDs, and so forth 3
in selecting a system?
4 I mean, they might be an indicator that there was 5
a lot of problems with the engineering design when the field 6
tried to implement it.
7 MR. TWIGG:
I think we are looking on a more 8
general basis.
I think the systems we select based on the 9
criteria that we have mentioned here do not achieve all of 10 the criteria in a particular system that you would like.
11 The way.that we look at FNDCRs and EMDs, we go in 12 and we are testing the implementation of the design process
()
13 of the work performed by the individual groups.
In other 14 words, we are looking at electrical, ENDC Rs, EMD, which is 15 '
our mechanical.
We will be looking at the power, 16 calculating the power ENDCRs, structural ENDCRs.
17 So what we do is we go in and sample the design 18 -
process -- and that is what we are doing.
We are sampling 19 or evaluating how effective that design process is.
It is 20 very difficult to be able to -- if you go in and look for a 21 known problem area, you may not be doing justice to the type 1
22 (
of review which we are trying to perform.
23 MR. MARTIN:
I might amplify that.'
In the 24 Duquesne design basis endorsement program that was initiated 25 and performed by our people, we looked at the installation l
ACE-FEDERAL REPORTERS, INC.
202 347 3700 Nationwide Coverage 800-3366M6
0260 03 12 36 OMTbur 1
specifications, particularly 977 and some that had a number 2
of ENDCRs -- this is engineering design change requests --
3 attached to them and incorporated, and we reviewed those 4
with special attention to make sure that they were updated 5
and that the information was timely and was incorporated in 6
the design and that that was not only design but also 7
governed field activities.
8 That is a little bit more than the engineering 3
9 phase.
Actually it is some of the workmanship type of 10 things go into those specifications.
11 MR. TWIGG:
The number of the ENDCRs in a f
12 particular area is always a question of whether the design
()
13 was thought out as well in advance or not, also the 14 indication of an ENDCR that the problem was picked up and 15 identified, and we are looking for areas where the problem 16 may not have been picked up.
17 So that looking at the ENDCRs certainly has --
18 there is an influence on the design process there, but those 19 are the ones that have been picked up.
20 MR. MARTIN:
Along this line, since we do have 21 the benefit of the presence of some of the region people, 22 i what is the relationship -- for my information -- between 23 the headquarters I&E staff and the region?
24 I think I understand, but maybe if you could help b
\\'
25 me.
I realize that maybe the objective is more site ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coverage 800-336-6646
0260 03 13 37 OMTbur 1
related than it is base, home of fice design activities.
2 Is that correct?
3 MR. ANKRUM:
No, not exactly.
The relationship 4
in the design area is a little different than you would find 5
normal region-headquarters relationship.
6 The region has site responsibility of the plant, 7
retains site responsibility for the plant.
However, again 8
following Diablo Canyon, one of the things we learned was 9
that the NRC really had never done technical inspections of 10 design and design process.
11 NRR reviewed the permittee's promises, if you 12 will, in the PSAR and FSAR, but no one ever checked to see
()
13 l if those promises were actually implemented in the designs 14 themselves.
15 It was determined that that required such a 16 degree of specialization and talent that we couldn' t put 17 that in each of the five regions, and so that inspection I
18 capability was centralized in headquarters in IEE, as it 19 happened in the QA Branch.
But there is no reason why it 20 couldn't have been in some other branch.
It just happened 21 to be there.
22 And so we are performing a direct inspection i
23 function for this design area strictly because we couldn't 24 afford to distribute that kind of talent throughout the (d
25 regions.
ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coverage 900 33MM6
i 0260 03 14 38
% OMTbur 1
And then let me go an extra step, and this now is 2
feeding into tha licensing process, and it is similar to the 3
regional administrator's determination at the end of the 4
process that the plant has been constructed in accordance 5
with the design.
6 But the Division of Licensing also looks to I&E 7
headquarters for some input as to whether or not the design 8
to which the plant was constructed actually complies with 9
the licensee's commitments and NRC's regulations.
10 11 12 0
13 14 15 16 17 18 19 20 '
21 22 1
23 24 25 ACE-FEDERAL REPORTERS, INC.
ll02-347 3700 Nationwide Coverage 800 336 6646
0260 04 01 39
/30MTbur 1
So you will find that the region participates
(/
2 with I&E on these design reviews so that the region --
3 because the region remains responsible for that plant.
It 4
is in their region.
But the repository of the design 5
expertise is within this group of people at IEE 6
headquarters.
7; MR. TRIPP:
Roger -- I certainly don' t disagree 8
with Ted -- what might have confused you a little bit here 9
is that, as you know, we in the region had the perception 10 that there was engineering / construction interface problems, 11,
and we hit on that in the SALP area, and so we monitored 12 that area closer with your pr:oject than with most other
()
13 projects.
14 And we also, for example, then took a look at 15 some of the confirmation activities that Duquesne Light did 16 I because we regarded that as part of the utility's overview 17 and control of your arenitect engineer.
18 l We took quite an interest in the site engineering I
19 ;
activities because we saw them as a key link in this 20 interface process, and as you pointed out in your submittal, 21 ;
we specifically looked at that one audit there that was 22 focusing on the site engineering activities.
In fact, I was b
23 i personally involved with that.
l 24 Again, it was in the context of our larger 25 concern about the engineering / construction interface and the ACE FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coverage 800 336-6646
0260 04 02 40
'm.OMTbur 1
site engineering group has been the key link in that 2
interface.
3 We typically don' t have a staf fer do the detailed 4
design inspections that Ted is talking about.
5 MR. THOMAS:
The region peopla have been involved 6
in the program, though, I believe.
I think there was a 7
presentation made at the region headquarters on the design 8
confirmation program.
9 MR. MARTIN:
Oh, yes.
John is referring to our 10 i presentation, in which we mentioned about our design I
11 confirmation program.
We will be -- initially approached 12 you people in the region to tell you that we were planning
()
13 this.
That was prior to some of the difficulties of Diablo i
14 Canyon.
i 15 MR. TRIPP:
Well, that was in '83, and we were 16 already concerned about the engineering / construction I
17,
interface at that point in time, and so as I recall, 18 Duquesne Light came in to assure us that they were doing 19 something to look into thia area and control this area.
20 MR. MARTIN:
That was presented October 21st, 21 1983.
i I
22 i MR. DEL GAIZO:
Can I just slide in a few things I
23 here?
24 l MR. MARTIN:
Certainly.
25 MR. DEL GAIZO:
A few quick questions before we ACE-FEDERAL REPORTERS, INC.
3)2 347 3700 Nationwide Coverage 800
., _. - _.__ _ - _-33 H 646. _ _ _ _. _ _
0260 04 03 41 S SOMTbur 1
go on.
.)
2 Ted Del Gaizo, Westec Services.
3 The hazards analysis review you just finished, I 4
take it was high energy line break, seismic 2 over 1 5
flooding?
6 MR. MARTIN:
Yes.
7 MR. TWIGG:
That is correct, yes.
8 MR. DEL GAIZO:
Was -- when the Stone & Webster 9
people who did it -- any of it that we have seen before in 10 Nine Mile, Millstone, or Vogle?
11 MR. TWIGG:
No.
12 MR. DEL GAIZO:
Thank you, r~'
t 13,
Just one other thing.
You mentioned NUS did the l
y 14 EQ review.
You also said there was a third party review on 15 fluid systems.
16 Who did that?
Can you tell us who did that?
17 MR. MARTIN:
Quadrex.
18 l MR. DEL GAIZO:
Quadrex?
19 MR. MARTIN:
Yes.
20 MR. DEL GAIZO:
Okay, thanks.
l 21 j That is all I have.
22 MR. MILLER:
Ted, can I go back and ask a 23 question?
24 What has been the experience of other utilities
\\-
25 in terms of the breadth of the design reviews that they have ACE-FEDERAL REPORTERS, INC.
312-347-3700 Nationwide Coverage 800 336 66 4
0260 04 04 42 V]OMTbur
/~
1 performed in terms of the number of systems that they have 2
typically covered?
3 MR. ANKRUM:
It has varied.
I would say that 4
from what I have heard with the efforts on Beaver valley 2 5
is consistent with what we have seen elsewhere.
There are 6
other utilities that have done what would appear to be fewer 7
systems, but because they recognized that you couldn' t 8
satisfy all questions of one system they would review parts 9
of other systems.
10 We have had utilities that have done more systems 11 because they found problems in the first one and it was 12 necessary to decide whether or not we had an isolated
()
13 incidence or whether there was a generic problem.
14 But the effort that Duquesne Light has undertaken 15,
sounds consistent with that which other utilities have i
16 undertaken.
More than some, less than others.
And the ones I
17 that they are less than were ones that had problems.
18 j MR. MARTIN:
Well, I think we have talked about l
19 an overview of our past activities and discussed the audit 20 plan, discussed the assistant report.
We are to the 21 question of the NRC role, and we are interested -- do you 22 want to take that up now?
23 '
MR. ANKRUM:
Sure.
This is a good time.
24 MR. MARTIN:
Whatever.
I')
~'
25 MR. ANKRUM:
Well, let me summarize that then.
ACE-FEDERAL REPORTERS, INC.
312-347 3700 Naionwide Coverase 800-336 4646
0260 04 05 43
?S OMTbur 1
As I mentioned earlier, we are obligated -- and 7V 2
when I say "we" I mean I&E -- are obligated to give the 3
Division of Licensing some evaluation of design process and 4
whether or not the design process in fact resulted in a 5
design that complies with NRC's regulatory requirements and 6
your commitments.
7 That will take the form of either an SER or an 8
inspection report.
9 Now, we have several things that we could do.
10 The first thing we could do is we could do a direct 11 inspection, an IDI.
12 I don' t favor that because you have undertaken a
()
13 considerable effort on your own, as you have described to 14 us, and in particular through the engineering assurance 15 i program which, as you observed, is one that we are familiar 16 with, comfortable with, and believe that it effectively 17 answers the questions that are on the table.
18 l So we would not desire to do an IDI.
It is very i
19 labor intensive on our part, and it would be duplicative of 20 what you have done.
21 The second thing we could do is come in and look i
22 over your shoulder on the EAP and the other things that you 23 '
have done, and by looking over your shoulder I mean test the 24 implementation.
We are not talking about changing your 25 schedules.
We are not talking about changing necessarily ACE-FEDERAL REPORTERS, INC.
202-347 3700 Nationwide Coverage 80433HM6
0260 04 06 44 OMTbur 1
what you are doing except that we would be pleased to review 2
in advance things which you plan and tell you whether or not 3
we think that in our opinion you are achieving what you are 4
setting out to achieve with what you are doing, and we would 5
endeavor to the greatest extent possible to stay off the 6
critical path, and we have managed to do that in every 7
instance.
We have yet to have been on the critical path 8
towards a licensing decision.
9 So we can look over your shoulder of what you are 10 currently doing and then prepare an SER to the Division of 11 Licensing, giving them our opinion.
12 The third option we could do is essentially
()
13 j send -- you know, if we did not look over your shoulder l
14 l during this process -- and it is similar to what we did at 15 Nine Mile Point 2, it is similar to what we did at Millstone 16 3 when I say look over your shoulder -- that if we don' t do 17 ;
that --
18 MR. THOMAS:
Can we talk about that, pleaso?
19 MR. ANKRUM:
Sure, I will come back to that.
20 If we don' t do that, then our third alternative 21 would be essentially to send an SER to NRR that says we have 22 i reviewed on paper, we have reviewed your submittals of what 23 you were doing, and what you were doing has the elements of 24 answering the question that we have been asked to answer, O
25 but that we have not reviewed the implementation and ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nanonwide Coverage 800 336 4646
l 0260 04 07 45 J
l
[3 0MTbur 1
therefore we are not in a position to come to any conclusion V
2 as to whether or not the design in f act -- it would say your 3
methodology could provide that answer, but having not looked 4
at the implementation, we can't tell you, Division of 5
Licensing, whether this has met the requirements or not 6
because we haven' t looked at the implementation on it.
7 And one of the significant lessons of the past 8
few years, for our part, is that implementation is the key.
9 Wonderful plans are just that, plans, and it is the 10 bnplementation that delivers the product.
11 So as I see it, we have three alternatives.
One 12 is an IDI, which we do not favor, but if we didn' t take the
()
13 second path and NRR believed that the third path was not 14 satisfactory, or was not satisfactory on our part, then we 15 l would have to go back to an IDI.
16 So those are the three options that are before us 17 at this point in time, and I would like some feedback from 18 !
you as to whether you would prefer to pursue any of those 19 three.
20 MR. THOMAS:
Well, I would like to say a couple 21 of words.
I was on the Nine Mile project last summer when 22 that in-depth technicai audit was performed, and there wau a 23 lot of work put in on it, a lot by everybody.
I 24 j My concern is that there was like 29,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />
(
l 25 ;
time of the auditors -- that was about 15,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />, and i
ACE-FEDERAL REPORTERS, INC.
202-347 3700 Nationwide Coverage 800-336 6M6
0260 04 08 46
(~)OMTbur 1
project poople was about 14,000.
\\_/
2 MR. MARTIN:
These are Stone & Webster project 3
people and Stone & Webster auditing types.
That was alone 4
for them.
5 MR. THOMAS:
So that my concern is that seems 6
rather a lot.
I don't know what it is in your experience.
7 Although that is a good process, I think we want to, you 8
know, do what we need to do for you to be able to provide 9
this assurance.
So we want to cooperate and don' t even want 10 to appear to be uncooperative because we are not.
11,
At the same time, you recognize that we are I
12 i between a rock and a hard place here, in a way, because I am
()
13 sure you have heard of PUC auditors and folks like that --
i 14 MR. ANKRUM:
Absolutely.
15 MR. THOMAS:
that are around.
16 So we would like to -- I would like to and I 17 f think that is Roger's position also -- we would like to l
18 {
reach a meeting of the minds and agreement here where you 19 can do what you have to do, yet we can still be responsive 20 and be assured that we have been prudent, that we have done 21 what we had to do.
And maybe things are not absolutely, i
22 mandatory but were prudent to do in expansions.
23 So we would really like in the over-the-shoulder 24 !
thing -- that seems to be the reasonable solution here -- is i) 25 a middle ground, I think, though three, I don't know how we ACE-FEDERAL REPORTERS, INC.
ll02 347 3700 Nationwide Coverage 800 3 4 6646
0260 04 09 47 N OMTbur 1
would do Item 3, frankly, b
2 Do you?
Have you ever done Item 37 3
MR. ANKRUM:
No, never done 3.
In fact, you 4
would stick out like a sore thumb.
5 MR. THOMAS:
I don' t know what that means even, 6
frankly.
7 MR. ANKRUM:
Neither do we.
Neither do we.
8, Given the questions that we received from the 9
Commission, the Commission might wel'. not accept that on the 10 path of the licensing.
On the other hand, the Commission 11 might accept it on the path of the licensing.
I 12 I don't know.
It has never happened.
Unplowed O
oround, end I aoree wien you that the Option 2 is the 13 3
14 preferred, and we are perfectly willing to work with you in 15 advance on your audit plan and basically come to an 16 agreement ahead of time that what you are doing, what you i
17 plan to do meets the objectives.
18 Now, if it turns out we can't agree at that point i
I 19 in time, our subsequent evaluation will simply be 20 qualified.
To the degree to which we are able to come to a 21 conclusion, that is how much of a conclusion we will come 22 to.
23 If we feel that what you are doing isn' t 24 sufficient to answer one particular question, then our SER 25 would say in this particular question we don't believe that i
ACE. FEDERAL REPORTERS, INC.
0260 04 10 48 OMTbur 1
- he audit ef fort was suf ficient to answer and answer the 2
question.
3 On the other hand, we may come to an agreement on 4
an overall plan of attack that completely addresses the S
questions that are on the table, and I would like to 6
basically turn that question over to Gene Imbro and Ted Del 7
Gaizo and our team that does this and basically work 8
together with your team and come up with a review of what 9
you plan to do and where we would fit in and come up with 10 the bottom line.
11 Now, as to the number of hours necessary, I think 12 it would be premature to say so many thousand hours are
()
13 needed to answer the question because every utilit.y is 4
14,
unique.
You have done a number of things already, and you I
15 may have dealt with many of the issues that have had to be 16 l dealt with at the last minute at other utilities.
17 So we have not looked in great detail at what you 18 l have done.
We basically have your letter at this point in r
19 !
time, and the next step in our view would be the planning 20 for how we would integrate with your schedule that you have 21 given us and a discussion as to whether or not that what you 22 have planned to do, if implemented as you plan to implement 23 it, will allow us to weice the coniprehensive SER to the 24 Division of Licensing.
O
\\'
25 MR. THOMAS:
I am sure we can reach agreement.
ACE. FEDERAL REPORTERS, INC.
202,347 3700 Nationwide Coverage 800 33H666
0260 04 11 49
[d
^xOMTbur 1
I don' t want to say that we can' t.
I am sure we can.
2 However, you know, assuming that for some reason 3
then we didn' t, or whatever, just go back and explore the 4
third alternative, which looks like kicks you back to the 5 I first alternative, which is you say no alternative at all, 6
but the IDI.
l 7i I guess it would go back to are you obligated by 8
the Commission, or whatever the rule citation might be, to 9
provide that assurance or not assurance?
If you can' t 10 provide assurance, is that in effect saying that -- I mean, 11 you can' t -- you got to either say yes or no, that it is 12 adequase or not, I assume.
A) 13 {
MR. ANKRUM:
Well, the Commission's rules
(,
14 obligate you to do a design which complies with the FSAR, I
15 l PSAR, NRC's regulations, and what we would be facing is can 16 l we, the staff, offer independent testimony to the 17 Commissioners that in fact your design does meet those 18 l obligations?
i 19 That is the bottom line, and that is really where 20 we have been going with all of the plants -- is can we, the 21 staf f, give some independent testimony -- and by i
22 independent, I mean separate and apart from your 23 assertions -- and arrive at that independent testimony l
24 [
through our own inspections or reviews of what you have
(
25 done?
Can we tell them that you in fact have complied with ACE-FEDERAL REPORTERS, INC.
I 202-347 3700 Nationwide Coverage 800-336 6646
0260 04 12 50
[')OMTbur 1
NRC's regulations?
\\_/
2 MR. THOMAS:
That you have taken independent look 3
and you can say from your own knowledge --
4 MR. ANKRUM:
That is right.
5 MR. THOMAS:
-- that you are satisfied with what 6
went on there?
7 MR. ANKRUM:
And Option 3 is for us to say, from 8
our own knowledge we can come to no conclusion because we 9
haven' t done the things that are necessary to come to that 10 conclusion.
11 MR. THOMAS:
The question then is:
is that an 12 essential piece of the licensing puzzle?
n
(_)
13 I MR. ANKRUM:
I cannot answer that question.
All 14 I can tell you is that the Commission -- following Diablo 15 !
Canyon, the Commissioners wanted that independent look -- or 16 I shouldn' t say the independent look -- but that independent i
17 assurance from the staff.
18,
Whether or not enough time has passed and enough 19 water is now over the dam and enough experience has been 20 l gained by the Commission in this area that they no longer 21 feel they need that is a question for the Commission to 22 decide.
23 But I want to make sure that you understand that 24 we are not talking about new regulatory requirements.
It is O
25 the existing ones and the Commission desiring a finding by ACE-FEDERAL REPORTERS, INC.
202-347 3700 Nationwide Coverage 800 336 4646
0260 04 13 51
/w)OMTbur the staff that staff is independently able to conclude that 1
(_
2 those regulations have been complied with.
3 MR. THOMAS:
I understand.
Well, then that --
4 MR. MILLER:
Making a finding of reasonable 5
assurance, to put it simply, and your question really might 6
be:
is there anything in a review plan or in regulation 7
that specifically calls for the staf f to do something?
And 8
the answer is no.
9 MR. THOMAS:
Now, I am not trying to play lawyer 10 with you.
What I am really getting at is, you know, if -- I 11 mean, if you don' t do something like Option 2, it sounds 12 like that you are going to have to do Option 1.
()
13 j Because I have obviously asked you the question, 14 you have got to provide an answer.
15 l MR. ANKRUM:
I can't tell you we would have to do 16 it.
I can only tell you that if the Commission didn't 17 accept the Option 3 answer we would have to do Option 1.
If 18 l the Commission will accept --
19 MR. THOMAS:
Prior to obtaining a license?
20 MR. ANKRUM:
Prior to obtaining a license.
21 MR. THOMAS:
Which may, you know, if we go down 22 this t al --
23 MR. ANKRUM:
Put you on the critical path.
24 MR. THOMAS:
-- and can't conclude on Option 2 or O
25 3,
then that might take some time?
ACE. FEDERAL REPORTERS, INC.
l 202 347-3700 Nationwide Coverage 800 336-6646
0260 04 14 52 f'S)OMTbur 1
MR. ANKRUM:
Exactly.
s_
2 You are ploughing uncharted ground because 3
heretofore, since Diablo Canyon, the commission has asked 4
the staff to provide this assurance.
5 If we tell the Commission we can' t provide that 6
assurance, the Commission then will have to decide whether 7
or not they are accepting the information you are providing 8
or whether or not they will go back to the staff and say, I l
9 am sorry, we have to have that, and I can' t predict what the 10 Commission will do.
11 MR. THOMAS:
A couple other questions.
Duquesne 12 Light has done a number of things, as Roger has outlined
()
13 here.
You know, they have been a responsive owner and 14 responsible owner as the NRC continues to urge owners to 15 l become more in charge, more directive in all their 16 projects.
17 I It sounds as if though you can't take credit for 18 Duquesne Light and 12 independent design reviews, the 12 19 I different contractors.
That couldn' t be part of your 20 decision because obviously that is not your own firsthand 1
21 ;
knowledge that things were right, even after you had done 22 all that.
I 23 '
MR. ANKRUM:
If you are willing --
24 j MR. THOMAS:
Should that be a discouragement to 25 I the utility to do that sort of thing in the future?
ACE-FEDERAL REPORTERS, INC.
202 347-3700 Nationwide Coversee 800 3 % 4646
0260 04 15 53 f g OMTbur 1
MR. ANKRUM:
Not at all.
Not at all.
,V 2
MR. THOMAS:
Why not?
3 MR. ANKRUM:
If you are willing to go before the 4
Commission and say here are the things that we did and not 5
have us standing next to you saying we looked at those and, 6
by god, they did them and they did them right, then --
7 MR. THOMAS:
But it doesn' t meet your 8
l requirements for this sort of firsthand knowledge of your 9
own?
10 MR. ANKRUM:
No.
I am saying if we go back and 11 looked over your shoulder, we would be standing next to you 12 before the Commission saying, yes, they did all those things
()
13 and wa agree that all those things achieved exactly what 14 l they think they achieved.
15 Okay, that is one step.
16 The other path is you can stand before the 17 Commission and tell them that without the staf f's 18 corroboration, and the Commission may very well accept your 19 assertions because you are a responsible licensee and you 20 have done all these things.
21 MR. THOMAS:
Yes.
22 -
MR. ANKRUM:
It is simply a judgment call on your 23 part --
24 MR. THOMAS:
So you would say --
O 25 MR. ANKRUM:
as to whether or not you want ACE-FEDERAL REPORTERS, INC.
202-347 3700 Nationwide Co< erase 800 33H446
0260 04 16 54
/~~s OMTbur 1
the staff standing next to you before the Commission.
d 2
MR. THOMAS:
And you could say we have no opinion 3
because we haven't investigated it?
4 MR. ANKRUM:
That is right.
We wouldn' t say you 5
didn't do it, we wouldn' t say you did do it.
We would say 6
we have no opinion because we --
7 MR. THOMAS:
So you are not required to come to a 8
conclusion then; that is all you are saying?
9 MR. ANKRUM:
I am saying we are not required to 10 come to the conclusion and therefore --
11 MR. THOMAS:
Well, is that different than the 12 construction?
Because someone has to come to a conclusion
()
13 it was constructed according to plans and specs?
14 MR. ANKRUM:
That is right.
15 MR. THOMAS:
So that is different in that sense, 15 is that right?
17 18 19 20 4
i 21 l 22 23 j 24 25 ACE-FEDERAL REPORTERS, INC.
202-347 3700 Nationwide Coverase 800 336 6646
i l
0260 05 01 55 i
1
['LIVEbw 1
MR. ANKRUM:
Well, the Commission ultimately 2
makes the decision, not the Staff.
3 MR. MILLER:
I see.
4 MR. ANKRUM:
The Staff makes the recommendation 5
to the Commission.
The Commission has to conclude that you l
6 have designed your plant in accordance with the 7
regulations.
The Commission has to make that decision.
The 8
Staff doesn't have to make that decision.
The Staff may be 9
willing to come to that conclusion, based on your assertions i
10 without an independent move from the Staff.
Somebody does l
11 have to come to that conclusion, and it is the 12 Commissioners.
()
13 MR. MILLER:
I think what you are focusing on is 14 the ultimate decision.
The Staff, of course, makes a 15 recommendation to the Commission.
16 MR. THOMAS:
Well, you do make a statement, 17 though, I think you said earlier, about the construction l
18 side.
Yes, that you have, in fact, met all the published 19 requirements.
l 20 MR. MILLER:
Before it ever comes down to the l
21 Commission, the Staff will have to make some sort of a 22 determinacion.
l 23 MR. THOMAS:
It looks like you you would at least 24 have to come to the conclusion that at least it wasn't I
25 wrong.
I ACE FEDERAL REPORTERS, INC.
312 347-3700 Nationwide Coverage 800-33HM6
0260 05 02 56
/')LIVEbw 1
(Laughter.)
(>
2 I'm not trying to argue with you here or be 3
a rgumentative.
I am just trying to understand.
This is a 4
big impact on the project.
It would get into the larger 1
5 things at Nine Mile, because it wasn't just the hours, 6
directly applied, but it was the impact onthe project at the 7
time.
And I am not trying to cop, you know, the " poor boy" 8
plea either, but it is a fact.
9 MR. MARTIN:
One of the concerns that we have, of 10 course, is that if a plan is established and can be adhered 11 to with guidelines, it would prohibit -- what is the term 12 they use -- oh, frivolous changes in the program.
I am
()
13 trying to think of the lawyers term, but nevertheless, if --
14 the more that is known about the scope than the less ef fect 15 it has on the policymaking in the upper levels of 16 supervision, because it is more than just going through 17 '
the motions.
If you have a plan established and you have 18 j the people identified to support that, then you have your 19 work program set out.
But if there were other areas -- if I
20 l you could identify something that is significant, to the 21 point that it would require some changing program, yes.
22 But I think the criteria -- and establishing that criteria 23 {
is very important.
Ilow significant that must be, because 24 then you have to bring in man-hours and manpower, which are
\\,'j 25 dedicated for some other location.
ACE-FEDERAL REPORTERS, INC.
202 347-3700 Nationwide Coverser 800 3364446
0260 05 03 57 7'TLIVEbw 1
You have slice of time for this audit program, V
2 and these people are dedicated, as we have done with the CAT 3
audits and other type of audits, these EA audits.
The 4
people are not available for the day-to-day work in this 5
final push to construction.
You ara well aware of this.
6 I think the most signi2icant thing that we felt 7
about -- and John has sharea this with me in the Nine Mile 8
situation, is that tne scope had expanded significantly.
9 Is that a correct statement?
10 MR. THOMAS:
Well, that's correct.
11 First of all, I think we started out there, and I 12 know that Dick was part of that, and I know your folks were
()
13 involved too.
14 The estimate -- you know, I think it is like 5000 15 or 7000 hours0.081 days <br />1.944 hours <br />0.0116 weeks <br />0.00266 months <br /> in the beginning, and it ended up, the final 16
-- I don' t think the final one is in yet.
The last number I 17 heard off that project was like 29,000, which you are 18 looking at $1.5 million plus whatever.
19 It seemed like that it had a growth to it.
And I 20 wasn' t as directly involved as Mr. Twigg, but at the same 21 time, I was aware that for weeks, you know, that the boards 22 were filled with findings and resolutions and people that 23 were trying finish designing of sapport construction were 24 also involved in that.
And recognizing that you can' t do O
25 this without some impact.
ACE-FEDERAL REPORTERS, INC.
202 347 3700 Nationwide Coverage 800 3444d6
l l
0260 05 04 58 l
/)LIVEbw 1
MR. MILLER:
Well, John, can I ask you a LJ 2
question about your number?
3 MR. THOMAS:
Sure.
You go ahead and ask anything 4
you want.
I really don't have that document, but tha t's --
5 MR. MILLER:
No, I am just curious, because what 6
you are basically saying is that you had to review plans, 7
and that review for the addition of NRC participation 8
expanded significantly.
And you mentioned something like 9
from 5000 to 29,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />.
10 Is that your estimate of --
11 MR. IMBRO:
I think you compare a little bit 12 apples and oranges here, because I don't think that whole 13 29,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />, as you said, was really EA audit time.
14 MR. THOMAS:
No, it wasn't, Dave.
About half of 15 that was EA audit time, but half of that was the project 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />, you know, providing information, answers.
17 MR. IMBRO:
I think the other point is, too, that 18 I mean, you were going to conduct an audit anyway, so you 19 would have had -- you know, while I am sure NRC added 20 something to that, I can' t -- I don't know exactly how much 21 that is.
So I think it's really - you know, a little 22 unfair to --
23 MR. THOMAS:
No, I am not here to accuse 24 anybody.
I am not here to do that.
That's not the O
25 purpose.
I am just saying, what we would like to do, to go ace FEDERAL REPORTERS, INC.
202 347 3700 NationwWe Coversee 800336eM6
0260 05 05 59
[N LIVEbw 1
on with what we have here, is to -- as Roger has indicated -
\\_]
2 is to sit down, you know, plan this in a cooperative way and 3
reach agreement on how we are going to decide things in the 4
future.
And when titere is something that leads to you --
5 well, maybe a requirement.
Maybe you' ve found a great big 6
hole somewhere, and you do need to go back and redo, but 7l let's kind of elevate that to the management level and not 8
sort of have management from the bottom up, of what the 9
scope, in fact, ought to De.
1 10 MR. ANKRUtt:
Well, let me add a couple of --
l 11 MR. THOMAS:
I'm not even saying that that i
l 12 happened, but you know what happened.
()
13 MR. ANKRUM:
Let me add a couple of comments.
l 14 The first is that we have found through our experience over i
15 the last couple of years that -- and this includes us in the 16 very beginning -- thore's been a underestimation of tne 17 amount of time necessary to do the job properly.
18 l MR. THOMAS:
Of course, we need to define the i
19 job; right?
20 MR. ANKRUM:
Well, to answer the question.
i 21 MR. THOMAS:
Right.
22 MR. ANKRUM:
The number of hours that it has 23 i taken to answer the questien in a rigorous way, has been 24 underestimated by every utility and was underestimated by O
25 l the NRC when it first started its IDIs.
That's just a flat I
ACE FEDERAL REPORTERS, INC.
312-347 3700 NationwWe Coverage 8043364446
0260 05 06 60
)LIVEbw 1
statement.
2 MR. THOMAS:
Would our track record influence 3
favorably that number of hours?
4 MR. ANKRUM:
Well, I think the fact that you have 5
done the number of reviews that you have done in the past 6
will definitely affect that, and what we need to do is delve 7
into all of the audit reports and the paperwork associated 8
with those prior reviews, and then look over your shoulder 9
while you are actually doing one, so that we can offer 10 independent testimony to how you bnplement these things, and 11 I have a suspicion that you have done a significant amount 12 of work already which other utilities had to do at the last
()
13 minute.
14 And so without our people getting into this in l
15 de ta il, I can say that it appears that you have done a 16 significant amount of ef fort, and we want to make sure that 17 you are getting credit for all of that effort in coming up 1
18 l with the final conclusion.
19 I also want to add one more thing, and that is 20 that when you start these efforts to define the scope in 21 advance and you define the criteria for elevating an issue, 22 first of all, I will assure you that those things are 23 handled at the senior level in NRC.
Secondly, if a i,
24 I significant item is identified during the review, then at O
25 that point in time, the number of hours involved become a ACE FEDERAL REPORTERS, INC.
202 347-3700 Nadonwide Coverage N3M 6646
0260 05 07 61 1
function of the issue and the issue resolution.
And you are O'sLIVEbw 2
now off the planned path, as it were.
3 Now the reason the number of hours escalate has 4
typically been that some issues are identified in the first 5
rev iew, and in order to determine whether or not those are 6
isolated instances or whether they are generic has required 7
more hours than was originally budgeted.
8 MR. THOMAS:
I think that was a major factor in 9
the Nine Mile One.
10 MR. ANKRUM:
Now, I will also say that in every 11 instance to date, we have been able to -- with the exception 12 of one -- we have been able, with those additional reviews, (3
x,)
13 to bound the the problems identified and establish that they 14 were isolated instances and were not generic to the design, 15 which is very important to not have an indeterminate caso.
16 No cne wants an indeterminate case.
17 We have been able -- we feel we have been very 18 l successful in settling whether or not something is generic 19 or an isolated instance, and that is where the unbudgeted 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> come from in settling that.
21 Now I think that the path we are on here is 22 basically Option 2, and we are perfectly willing to sit down I
23 and agree with you in advance about scope, agree with you in 24 advance on a methodology for escalating issues and to 25 basically follow your schedule, so that we don't become a ACE FEDERAL REPORTERS, INC.
202 347 3700 Nationwide Coverage 800 33MWW6
0260 05 08 62 j
LIVEbw 1
critical path item.
2 The best way to work that out is probably by 3
getting the people who are going to actually do these things 4
together and hammer them out.
5 MR. THOMAS:
Would it be best, in your opinion, 6
if we -- you know, as Dick Twigg has indicated, we have gone 7
through some preliminary planning and ha've given some 8
consideration to certain systems as candidate systems.
9 Would it be better, in your experience, that we 10 would maybe flesh that out a little more and then came back 11 for a sit down, kind of working session?
You went through 12 this a number of times, I gather.
r'T
(_/
13 What would be your recommendation?
14 MR. GRIMES:
Can we caucus just for a moment?
15 l MR. ANKRUM:
Certainly.
i 16 MR. THOMAS:
Sure.
17 MR. TAM:
If you need a caucus, why don't we take 18 a break?
19 (Recess.)
20 MR. TAM:
During the half hour break we had the 21 I opportunity to caucus and came to some conclusions.
I 22 Do you want to talk about those conclusions?
23 i MR. IMBRO:
Well, I think the next step for NRC l
24 '
is that we would like to conduct an inspection, perhaps at O
~
25 Stone & Webster would be the most convenient place or i
ACE-FEDERAL REPORTERS, INC.
I 202 347-3700 Nationwide Coverage 800 33Mm46
h 1
0260 05 09 63 7s 1
at Duquesne Light headquarters, however you want to do it, L.]LIVEbw 2
to inspect the scope of the forthcoming audit.
And at that 3
time we can sit down with'you folks, and you know, come to 4
some agreement as to what the scope of the audit will be.
5 Also we would like to ask that prior to this we 6
receive the three previous SWEC audits, so that we can more 7
accurately assess the scope of the review that has already 8
been done and have some basis to determine what additional 9
needs to be looked at in this final audit.
10 MR. EIFERT:
Okay, if I can ask a couple of 11 questions.
12 MR. IMBRO:
Sure.
()
13 MR. EIFERT:
The inspection of the scope, as you 14 indicated, you anticipate that that would be conducted at 15 the point *where we had an approved audit plan, as well as 16 prepared check lists.
I 17 '
Is that/ thet proper understanding?
l 18 l MR., Itt3RO:
No, I think'we would like to come in 19 '
a little bit before.
I am not sure what you mean by i
20
" approved audit plan."
Do you mean approved by NRC?
21 MR. EIFERT:
Approved by us.
22 MR. IMBRO:
Approved by you?
Yes.
Yes, I guess 23 when you come to a conclusion, SWEC and Duquasne as, you 24 know, what you feel comfortable in doing.
Then I think that
/~
25 is the appropriate time for NRC to get involved, and we can ACE-FEDERAL REPORTERS, INC.
202-347 3700 Nationwide Coverage 800-336 6646
0260 05 10 64 LIVEbw 1
make an assessment to whether or not you think that will
{
,2 cover the areas the previous three audits didn' t cover.
3 MR. EIFERT:
Okay, and a point of clarification, 4
with respect to the third audit that we've conducted on the 5
hazards program.
The audit is completed, but that report is 6
not issued yet.
It is in final draft form and will be 7
issued very soon here, but if we respond to your request for 8
the three previous audits, we may transmit the first two 9
without the third one, and with the third one to follow 10 shortly thereafter.
11 MR. IMBRO:
That would be all right.
We would 12 also be willing to accept the final draft, if you choose to
()
13 send it.
That is certainly your decision.
14 MR. TAM:
Do you have any idea when you can send 15 it, approximately?
16 MR. EIFERT:
Within three or four weeks, 17 '
approximately.
18 MR. WANG:
Also may I ask that when we go to t
19 '
Duquesne Light for the inspection, we would like to have a 20 copy of your preliminary plan, audit plan or approval --
21 whatever you want to call it, and we would like to have it 22 at least a week or so to study ourselves, before we can 23 discuss it with you.
24 MR. MARTIN:
This is prior to your visit?
O 25 MR. WANG:
Right; r ig ht.
Otherwise, we will ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coverage 800 3)(Hl646
0260 05 11 65 (v") LIVEbw spend two or three days just reading this plan.
1 2
MR. BEATTY:
Do you have any check lists or 3
attribute lists of things that you would be looking for in 4
our audit, we could use to help define our scope?
5 MR. THOMAS:
Like on your IDIs, you number them.
6 Do you have some kind of things that we could, you know, 7!
anticipate some of your questions or requirements?
I 8'
MR. IMBRO:
Okay.
Generally, we like to do a 9
comprehensive review covering the major disciplines as we 10 see them, which is instrumentation and control, electric 11 power, mechanical systems, piping and pipe stresses, 12 component review and civil structural.
()
13 l That is -- typically, we like to look at each of 14 those five areas and be able to come a conclusion in each of 15 them.
We understand that you have done previous reviews, 16 and I guess to the extent that your previous reviews have 17 covered these areas, you know, that will -- you know, give 18 l us a handle on the scope of the final review.
But I guess 19
-- you know, we'd like to be able to come a conclusion in 20 each of those areas, and we would like to be able to use the 21 previous audits that you've done, you know, to the extent we 22 l can.
l 23 MR. EIFERT:
Yes.
I would like to make a couple 24 more comments about scope and how we are going to try to 25 identify and manage the audit to a given scope.
ACE. FEDERAL REPORTERS, INC, 202 347-3700 Nationwide Coverage 800 336-6646
0260 05 12 66 J~
1
\\ j)LIVEbw Before the break, we talked about our past
~
2 experiences, the past Stone & Webster experiences performing 3
these, and we talked about the increase in the effort, and I 4
think it is fair to say that after our planning meetings in 5
the past, we identified a level of effort that we thought it 6
would taken and essentially that level of effort doubled, 7
okay, in completing these.
And there's a lot of factors 8 I that contributed to that.
9 For example, I don' t think that we anticipated 10 that we would have to document the audit itself to make it 11 auditable, as you would require to make your decisions, and 12 we understand that now, that we didn' t in the past, and we
()
13 understand the need for that, and we don' t have a problen 14 with that.
And certainly, we have learned ways to be more i
15 '
efficient and still being totally effective in the audit i
16 ;
process, as well.
a 17 our experiences indicate, though, that there was 18 increased scope in certain areas that are very cbvious.
We 19 f had an example where a structure was added, for example.
We i
20 <
had an area where an additional sample of pipe supports were l
21 added.
In those kinds of areas, we felt -- at least my 22 j udgment was that we probably didn' t need them.
And I will 23,
qualify that, because we didn' t study it.
Based on our i
24 interactions with you, the decision was made to proceed and O
25 do those, and those were rather obvious increased scope ACE FEDERAL REPORTERS, INC.
202 347 3700 Nationwide Coverage 800 336-6646
0260 05 13 67 i
?~SLIVEbw 1
kinds of things.
NJ 2
We are going to be looking at how we can mancge 3
and be conscious of those and make an appropriate decision 4
in this case, before we go on and perform additional' 5
inspection or auditing in that area.
6 Another area that is very, very difficult to 7
quantify, and we touched on it this morning in the 8
discussion, when the question was raised, do we use input 9
from IDIs and other experience to identify attributes to 10 look at.
I believe in our past experiences there were items 11 like that where your staff and your consultants, based on 12 their experience, were aware of specific problems or
()
13 l specific concerns that either have been identified by others 14 and maybe identified by themselves in other inspections that i
15 !
they have been performing and in reviewing our specific work l
16 i plan or audit plant completion activities in a given 17 discipline would ask another question.
18 There is no way I can quantify those.
I don' t 19 know if there were ten of those or were there were fifty of 20 those.
But each of those probably took from ten to twenty 21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> to answer the individual questions.
That is where it 22 is really difficult to control.
I think we have to be 23 conscious of that and aware of that, that we don' t turn the 24 I audit into a specific identified problem in the O
25 investigation process, but we need to be conscious of that JACE. FEDERAL REPORTERS, lNC.
.. -. - - _.. _.. -.. - _ _ _ m297.m___ -,_ y pim w w co m ase_ __
soo.nm
0260 05 14 68 I
when we establish some sort of a mechanism to control ks)LIVEbw 2
scope.
3 MR. IMBRO:
I guess we -- you know, we certainly 4
would like to tie the scope down as much as possible, before 5
we start this final audit.
Hopefully, we -- if the systems 6
you choose are systems where there are no industry problems, 7
we would anticipate that you would be looking into those, 8
just as a matter of prudency.
9 But I guess to comment on the increased scope, I 10 think that perhaps some of the increase in scope was 11 initially to achieve comprehensive reviews in those previous 12 audits.
So there is that part, and in addition, I think
()
13 that maybe some of the increase in scope came from the fact 14 l that SWEC themselves did a creditable job of their audit and 15 possibly identified areas that needed to be pursued a little 16 bit further.
So I think it is kind of something that ou 17 need to do, if you find - - in the process of the audit find 18 things that you consider problems, you obviously have the 19 responsibility to follow them up and come to some conclusion 20 J whether they are generic and what to do with them.
21 I think the question of scope, it's a hard thing 22 to j udge when you first sit down, and maybe people, you know 23 tend to be somewhat optimistic and say that we' re going to 24 accomplish this in X number of hours, and when they finally 25 get into the thing, it's X plus some delta, a.' d I think ACE FEDERAL REPORTERS, INC.
ll02 347 3700 Nationwide Coverase 300 33M646
0260 05 15 69
}LIVEbw since we've participated with SWEC before and SWEC has done 1
2 a number of these audits on their own, that we probably have 3
a better handle on what the final number or total scope is 4
going to be, in terms of when people try not to, you know --
5 MR. THOMAS:
We don' t want to hammer this scope i
6 issue, you know, to death now.
We just wanted to bring it 7,
up.
As long as we can manage it.
We know that you can' t be 8
definitive in all its detail.
If we can just find a way to 9
manage, you know, adders to it.
That is really all we are 10 saying, so that we can make sure that the management, you 11 know, agrees with the fact that you ought to do this or 12 that.
And I think we can reach a suitable arrangement 13 l there.
14 Now that is really my concern, to find a way to 15 manage it and not just let it happen.
That is really what 16 the point is.
17 MR. EIFERT:
Another question I would like to 18 raise on scope, and we haven't finalized our scope, but one 19 of the things that I would like to consider when we are 20 defining the scope is, for example, do we really need to do 21 a full scructural design evaluation as part of this audit?
22 We have, in the past, and I am not familiar with all ene 23 IDIs and other IDVAs, and I don' t know to what extent that 24 they've looked at the full structural area, but my 25 subjective feeling, okay, as we start this planning process ACE. FEDERAL REPORTERS, INC, 202-347-3700 Nationwide Coverage IWJ0-3 % 6646
0260 05 16 70
/~T LIVEbw 1
is that the structural area, in many respects in the
\\._)
2 industry, hasn't been the problem area that the systems 3
equipments have been, and so if you are going to expend your 4
resources, we want to expend our resources looking at the 5
most likely areas where we will have a quality added.
l 6
There have been other activities, as Duquesne l
7' Light has identified in their letter, which have addressed 8'
this area.
I am wondering if we propose, if we look at it, 9
and we conclude ourself, which we haven' t yet, that we would 10 rather not look at structure in depth, but for example, look 11 at the interface and the load reconciliation programs, for 12 example, and bound the structural area like that, if we go
()
13 back and look at this, what kind of consideration would that 14 get and what kind of information would we need for you to be 15 able to accept something like that?
16 MR. IMBRO:
I don' t know.
I guess it is hard to 17 !
answer at this point.
I would like to, you know, first of 18 all, se noted that there was some structural review done in 19 the previous audits, and we would like to look at that.
I 20.
MR. EIFERT:
And I haven't looked at that -- I 1
21 haven' t either at this point.
22 MR. WANG:
They are pretty much in-depth.
This 23 l is the fourth one.
You can save some time there, but, 24 however, if the previous three just did what you just did O
25 you just said, you have to do something to show us this ACE. FEDERAL REPORTERS, INC.
33 H 646-202 347 3700 Nationwide Coverage 800
0260 05 17 71 LIVEbw I
structure was done right.
2 MR. MARTIN:
We'd like to offer the Duquesne 3
Light design confirmation review program.
That was one of 4
the areas that we concentrated on, particularly on the 5
concrete design.
I think the question we' re asking is that 6
the concrete design in determining the adequacy of the 7
building under a seismic event maybe has significance, but 8
the total loading, the incremental loading, the final 9
loading on the columns, due to the changes during the 10 construction of the plant, the necessity to add it, 11 additional pieces of equipment.
That would seem to be an 12 area that would be of more value.
There is a changing sort
()
13 of thing in the classical up front concrete design review, 14 the review of those calculations.
15 MR. IMBRO:
Well, I would tend to agree with you 16 that structural has not really been an area where we found 17 significant problems, and where we did find some 18 discrepancies, generally, the designs are so conservative 19 that the problems disappear anyway.
20 So I guess what I am saying is, I would be 21 amenable to looking at, you know, some proposal on your part 22 and a little less work in the civil structural area.
23 MR. EIFERT:
We will come back to you with a 24 recommendation.
25 MR. DEL GAIZO:
Yes.
I think along those lines ACE-FEDERAL REPORTERS. INC.
202 347 3700 Nationwide Coverage 800 336 MW6
A260 05 01 72
}LIVEbw the sooner that we have the scope inspection the better, 1
2 before, you know, you what is intended before you get in 3
concrete.
Because I think once we get a chance to look at 4
these old audits, and I look through the list, I see names 5
of people that we have known and seen in the past, and I 6
know are very good auditors.
And I think when we get into 7
some of the details of this stuff, we can probably reach 8
several agreements on things that should or shouldn't be in 9
here, and the sooner we do it the better.
L 10 I think you should give us your best shot and 11 your recommendation of what you think and the basis for it 12 and, you now, obviously, we want to give you all the credit
)
13 l we can for what has been done.
We don' t need to retread 14 that ground.
15 MR. THOMAS:
We would like to do that too.
16 Particularly, I think Duquesne Light has done considerably 17 more than a lot of owners have and done their own reviews.
la i They have a lot good engineers and experience, and that 19 would be a same if we couldn' t take some credit for that at 1
l 20 least.
So we do want to do that.
l 21 I think what we would like to, I guess -- I don' t 22 l know if this is the proper time to num up, but I think our 23 l feeling is the next step would be for us to go back and, you 24 l know, review and digest what we have heard here and then get 1
25 together and come back with a suggested schedule for doing I
ACE FEDERAL REPORTERS INC.
t ll02 347 3700 Nationwide Coversse 800 33MM6
1 A260 05 02 73
[]LIVEbw 1
exactly as you said, to come up with our draft audit plan
%J 2
and suggestion that we get together the next time to discuss 3
this and reach agreement on how we are going to do these 4
things and what we are going to do.
5 Does that seem reasonable to you?
6 MR. TAM:
Yes -- the next thing we would like to 7
do is inspect your plant.
8 MR. THOMAS:
Well, we would come up with at 9
least a tentative schedule of how we see it, of when we 10 would submit certain things and talk, but we don' t want to 11 waste your time just, you know, sitting in a place out of 12 town reading things that you could read here.
So you need
)
13 to know that tentative thing, and we need to know if that 14 suits your needs.
15 MR. MARTIN:
What mechanism should we use for 16 providing you the tht ae previous reports and the preliminary 17 audit plan or program for completion of this audit?
You've 18 asked for that, and you've asked to review the scope, which 19 would be in the program plan.
Is it sufficient to provide 20 that material written -- I mean, to send it to you and'then 21 have your meeting in Boston?
Is that --
22 MR. IMBRO:
Yes.
That would probably be 23 preferable.
24 MR. MARTIN:
All right.
We can -- is that on the O
25 docket and that sort of thing?
Is that the way we handle ace. FEDERAL REPORTERS, INC.
M*M4M 80043MM6
- _ _ _ _ _ _ _ _ _ Nationwide Coverage _ _ _ _ _ _ _ _ _ _ _
A260 05 03 74 b)LIVEbw it or -- if we are sending you a a copy of something that r'
1 2
says " Draft Copy of So-and-So"?
How do you choose to have 3
it?
We would like to do it the most direct and easy and 4
convenient way.
5 MR. IMBRO:
It *<ould be preferable to have it on 6
the docket, I think, but particularly if, you know, we're 7
going to try and use previous audits for a basis for 8
determining the scope of this one, I think it is probably 9
preferable to send the usual letter.
10 MR. TAM:
W'e can not really review undocketed 11 material.
12 MR. MILLER:
Let me ask a point of clarification
()
13 here.
The three previous audits that you are talking about 14 were the SWEC audits, and you were talking about the 15 additional work that Duquesne has done, the reviews in this 16 concrete area.
17 Would it be advantageous to get some of that 18 l other information, so you can build on that as well or not?
19 MR. DEL GAIZO:
Well, I think the point is 20 whatever they are using for the basis to say that they don' t 21 need to do X, they should send it.
If it is Duquesne's, 22 maybe it is NUS.
I don't think we would want to gat it all, 23 because we would have to spend all our time going through 24 it, so if you could focus us in on what your basis is for 25 certain recommendation, that is what we need.
ACE FEDERAL REPORTERS, INC.
202 M7 3700 Nationwide Coverage 800 33HM6
A260 05 04 75
,73 LIVEbw 1
MR. IMBRO:
I think the thing you need to V
2 recognize, you know, whatever it is you send us, it should 3
be auditable to us, or else it is really not of much 4
relevance.
5 From our previous experience with SWEC, you know, 6
they do things that have been auditable to us in the past, 7
and I think we can have some confidence in looking at those 8
documents.
And Duquesne Light documents, I have no 9
experience with.
10 MR. TAM:
Okay.
Any more comments?
11 MR. MARTIN:
We thank you for the time and the 12 understanding that we have had with you.
(
13 MR. TAM:
This hearing is adjourned.
14 (Whereupon, at 11:40 a.m.
the meeting was 15 adjourned.)
16 l
17 1
18 l l
19 20 l
21 22,
f I
l 23 l l
l 24 25 i
l ACE FEDERAL REPORTERS, INC.
3700 Netionwkle Covernoe 800 336-4M6 202 347
]
76 CERTIFICATE OF CFFICIAL REPORTER v
This is to certify that the attached proceedings before the UNITED STATES NUCLEAR REGULATORY COMMISSION in the matter of:
NAME OF PROCEEDING:
MEETING OF NRC STAFF AND DUQUESNE LIGHT COMPANY ON BEAVER VALLEY UNIT 2 ENGINEERING ASSURANCE PROGRAM DOCKET NO.
PLACE:
BETHESDA, MARYLAND DATE:
FRIDAY, FEBRUARY 28, 1986 were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission.
(sigt) wAh b
(TYPED)h O
JOSEPH R.
MAGGIO Official Reporter ACE-FEDERAL REPORTERS, INC.
Reporter's Affiliation O
_