ML20155H742
| ML20155H742 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco, 05000000 |
| Issue date: | 12/30/1985 |
| From: | Whitney D AFFILIATION NOT ASSIGNED |
| To: | |
| Shared Package | |
| ML20155H523 | List: |
| References | |
| RTR-NUREG-1195 NUDOCS 8605160379 | |
| Download: ML20155H742 (41) | |
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//V p O Ul\ITED STATES NUCLEAR REGULATORY COMMISSION IN THE MATTER OF: DOCKET NO:
EXAMINATION OF DANIEL D. WifITNEY O
I LOCATION: liERALD , CALIFORNIA PAGES: 1 - 39 DATE: MONDAY, DECEMBER 30, 1985 I
' ACE-FEDERAL REPORTERS, INC.
Ctficial Reporters 444 North CapitolStreet Washington, D.C. 20001 0605160379 060306 U
b"^ hSk NATIONWIDE COVERACE
1 BEFORE THE NUCLEAR REGULATORY COMMISSION O 2 3
4 In the Matter of )
)
5 AUGMENTATION INSPECTION TEAM )
RANCHO SECO )
8 )
7
> g 9
10 EXAMINATION OF DANIEL D. WHITNEY 11 12 MONDAY, DECEMBER 30, 1985 13 O- i4 15 16 RANCHO SECO NUCLEAR POWER PLANT 17 14440 TWIN CITIES ROAD IS HERALD, CALIFORNIA 19 30 21 22 28 24 25 O
PETERS SHORTHAND REPORTING CORPORATION 3433 AMERICAN RIVER ORIVE, gulfE A ,
EXCRAMENTO. CALIFORNIA 98338 TELEPHONE (916) 973 3394
2 e 1
_A _P _P _E _A _R _A _N _C _E _S 2 NUCLEAR REGULATORY COMMISSION 3 AL CHAFFEE Nuclear Regulatory Commission 4 1450 Maria Lane Walnut Creek, California 5
J. T. BEARD g GORDON EDISON HENRY BAILEY 7 RON EATON Nuclear Regulatory Commission a Washington, DC ,
9 10 11 12 la O i.
15 16 17 18 19 20 21 22 33 24 25 O
PETERS BHORTHAND REPORTING CORPORATION 3433 AMCRICAN MlVER ORIVE. EUl?C A SACRAMENTO. CALIFORNIA 9553S TELEPHONE (916) 973 5594
3 i 1 PROCEEDINGS
- O 2 MR. CHAFFEE
~ ~ - ~-~~~~~~
Okay. We're on the record again.
3 This is an interview, Dan Whitney, who's going to go over 4 the generic guidelines the licensee is proposing to be 5 used in the development of their trouble-shooting a procedures associated with the equipment that's on the 7 quarantine list.
8 So Dan, would you just please describe to us 9 the -- share any comments that you have.
10 MR. WHITNEY: Okay. In the past several such 11 trip events that we have had, what we have done is to 12 operate a organization for the purpose of coordinating the 13 investigations and response thereto.
O i* 'o a ur ta t 'r 61 to o== ta ta i===
15 amount of information and data from the various sources 16 which might be available, be they written, analytical, or 17 experimental in nature.
Is To perform that analysis, the plant manager at 19 that time developed a letter which had within it the
) 20 criteria that he felt was important to such an 21 investigation.
22 And we have put that out, as the guidelines to 23 the people looking at these items of equipment which were 24 of specific interest.
25 Now, we did never have a true quarantine list, i
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4 1 if you would. But that's the same way as which we treated 2 the apparatus to which this program applied. What we have 3 done in this time is, back on December the 28th, George 4 Coward prepared a memo, which again chartered a transient 5 analysis organization, assigned people and 6 responsibilities into that organization.
7 And that's what I .have here for you now, which 8 describes the trouble shooting and investigation 9 techniques that we expect to use in investigating this 10 event.
11 MR. BEARD: Excuse me. Would it be correct to 12 say, instead of being a proposed document, this is a 13 document that's already been issued and is in force today?
O i4 Wa. Wa12ser: This is the -- ves, ie is. 1n 15 fact, this is a program we are using. We are certainly to 16 discuss with you any changes that might be necessary to 17 make it complete for your purposes also.
18 MR. CHAFFEE: Are there any changes in this 19 current document from the previous one, other than the 20 concept of a quarantine list?
21 MR. WHITNEY: They are administrative changes 22 only. Not la scope.
23 MR. CHAFFEE: Okay. Does anybody have any other 24 questions?
25 MR. BEARD: Would it be correct -- I'm trying to O
PETERS SHORTHAND REPORTING CORPORATION 3433 AMERICAN RIVER DRIVE, SulTE A SACRAMENTO. CALIFORNIA 98528 TELEPHONE (914) 973 3894
5 1 understand exactly where we are. With this being in 2 force, does that mean that people have been assigned to 3 look at particular pieces of equipment that were involved 4 in the event? And asked to develop individual action 5 plans for the trouble shooting of that particular piece of 6 equipment, in accordance with these guidelines?
7 MR. WHITNEY: Yes.
8 MR. BEARD: Okay.
9 MR. CHAFFEE: Okay. Any other questions? Okay, 10 thank you. Off the record.
11 (Thereupon a discussion -was held of f the 12 record.)
13 MR. CHAFFEE: Back on the record. Why don't you
() 14 take us through it, then. Explain how this system works.
15 What's involved in it.
16 MR. WHITNEY: Okay. The first thing that comes 17 up in putting this program into place, is to identify the 18 issues, items, equipment or events, to which we want the 19 program to apply.
20 And the way we' ve done that is to compile the 21 P i ece of paper called the action list. And on there, we 22 have identified those events or pieces of equipment that 23 bear specific investigation. And that, I think, you're-24 already familiar with. The copies we've had on that.
25 Now, not every item on that action list will O
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6 1 come under the auspices of the criteria in this-letter.
O 2 And the reason for that is, this is a convenient way for 3 us to keep in one place, on the action list, all of the 4 other administrative items that we're doing. And other 5 events that we think are important, or equipment 6 maintenance items that are important to get corrected, 7 coming out of this, before we would return to power.
3 So, what we then do is develop action plans for i 9 those which are identified with an asterisk on the action i
- 10 list as requiring trouble-shooting repair guidelines.
11 And as an example, item number three on the
- 12 current list is determine the cause, corrective actions 33 for the ICS power f ailure. That'whole category requires
() 34 the application of this program to it. And that action 4
15 P l an has not yet been prepared. It's in preparation this 1
l.
Ig afternoon, and I expect to have it tomorrow with that 17 specific example.
13 But that's the type of event that we would apply 3, it. I have a couple of action plans with me today that 20 can show you as examples of how we are applying the 11 Program. But I didn' t bring enough copies for everyone to 12 look at.
23 But here's one on the auxiliary feedwater flow 24 control valves. And it identifies the major steps in the 25 Pl an, that the man is going to accomplish in the actual O
PETENs SHORTHAND MrPORTING CDRMORAllON 3433 AMERICAN MIVE4 ORIVE. SulTE A SACRAMENTO. CALIFORNIA 9SSES TELEPHONE (9te) 973 8894
7 I work in the field. The actual work itself will be done 2 under.our normal work control program, which involves a 3 procedure -- excuse me, a work request -- associated with 4 the work itself will be a procedure. Where that procedure 5 is available or applicable or necessary.
6 We have standard procedures, for example, that 7 address teardown of valves for overhaul and repair. I 8 would expect that those would apply in this case. The 9 engineer identifies, in the disposition of that work 10 request, those necessar'j hold or inspection points which 11 would accomplish the intent of the work plan.
12 And those would then be documented by the 13 quality control group, or other inspections, as he designs
() 14 on the work request or in the working procedure. When 15 that is then completed, he would report back to us in a -
16 separate report the conclusions or findings.
17 Now, we haven' t progressed to that point on any 18 of the items on the action list. But I do have such a 19 report here, as an example, which deals with the auxiliary 20 feedwater initiation signal.
21 Now there was no concern with respect to that 12 occurring. We knew that it occurred during the event.
23 It is not an item on our action list. But it 24 was question that we felt was necessary to be reviewed, 25 from the standpoint of assuring that all of the various
()
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8 1
setpoints, pressure switches, and control logics which 2 caused that event to occur, in fact did do what they were 3 expected to do.
4 So we used this same method in approaching that 5 question. And here's the writeup on that. And you can 6 see the categories, if we look in resolving the question.
7 MR. BEARD: Excuse me, George. This document --
8 MR. WHITNEY: I'm Dan.
9 MR. BEARD: Dan. This is what document?
10 MR. WHITNEY: This is the closure report --
11 MR. BEARD: Closure.
12 MR. WHITNEY: --
for an item like an item on an 13 action list.
O i4 aa. BERRo= So this wou1d de af ter a11 the 15 trouble shooting is done. And the root cause is felt to 16 be at hand.
17 MR. WHITNEY: That's right. Yeah, this is the 18 format that we would use. And the type of information we 19 try to collect. These reports are then used by the people 20 preparing the overall event, or trip report. And how they 21 write up that event. And what caused each of the various 22 events along the way. And how they interrelated on unto -
25 the other.
24 Many of these investigations that we do, of 25 course, do not end up having any bearing on the actual i
O PETERS BHORTHAND REPORTINO CORPORATION 3433 AMERICAN RIVER DRIVE SulTE A BACRAMENTO, CALIFORNIA 95535 TELEPHONE (916) 973 3894
9 1 outcome of the event. They' re simply a way of collecting 2 information. And oftentimes gives you the justification 3 for not pursuing a particular path or potential failure 4 mode.
5 MR. BEARD: Dan, this set of guidelines you're 6 talking about were developed earlier. Like October? ,
7 MR. WHITNEY: Yes.
8 MR. BEARD: You had an event in October.
9 MR. WHITNEY: Yes.
MR. BEARD: I don' t remember the details of it, 10 11 but- that event was not investigated by the NRC, in the 12 form of either what we are now calling an instant 13 investigation team or an augmented inspection team, 14 was it?
15 MR. WHITNEY: I'm not sure what your 16 nomenclatures are. We received a confimatory action 17 letter in that situation, and prepared a formal is presentation to the NRC that were quite detailed.
19 MR. CHAFFEE: For the record, there was not an 20 AIT or an IIT.
21 MR. BEARD: Okay. But I understand in the 22 development of this set of guidance that you've just given 23 us, you did consider the general guidelines that were-24 developed at the Davis-Besse plant for their June 1985 25 event.
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10 1
MR. WHITNEY: We reviewed the 1154 report that 2 came from that event. And used that type of presentation 3 and that type of detail, in ensuring that we would be able 4 to capture all of the available information as we did our 5 trouble shooting. We felt like that was the best 6 guidelines that were available at that time, for the type i;
7 of information that you would be interested in seeing.
8 MR. BEARD: Well, let me give you an initial 9 reaction, okay.
4 10 Number one, I'd like to make a note that the 11 guidelines that you've given us consists of, essentially, !
12 a two-page memo with some attachments. One is apparently [
13 transition -- a transient analysis organizational chart. k O i4 ^=a tue eooaa te oae a se te on eae waioa wou1a de aa !
15 example plan format. h 16 This is two pages, versus the document that was '
17 used at Davis-Besse that was three or four, or something 18 on that nature. I'm not worried about the size. But I, 19 in glancing over this -- and I actually haven' t read it or "
20 had time to study it yet -- I recognize that a number of '
21 the aspects that were important at Davis-Besse are not t
22 included. I r
23 What example I'll give, is the concept of h 24 traceability. For example, I see nothing in here that 25 would provide a documentation of where an affected piece !
O .
PETERS SHORTHAND REPORTING CORPORATION 3433 AMERICAN RIVER DRIVE. SulTE A SACRAMENTO. QAUFORNIA 95535 TELEPHONE (916) 973 3894 .
1 11 1 of item is at the moment. Where has it been? What has l 2 been done to it? And maybe even where it's going to go
- 3 next.
4 I could see that there would be problems if an 5 item would to be, say, damaged or for some other reason, 6 you'd like to ship it someplace for a f ailure analysis.
. 7 That item could be off site before we, the NRC, were even
, 8 aware of it.
9 And I don' t see things in here that we felt were 10 very important before, such as a change analysis.
11 And I could go through here and probably pick -
12 out a lot of other items that aren' t in here.
13 Documentation of as-found conditions. To what extent are
() 14 you going to use vendor support in trouble-shooting, so 15 that you have the amount oi engineering expertise that
- 16 you' d like to have.
17 And there are a number of characteristics that 18 are not in here. And so, I guess the bottom line of what 19 I'm suggesting is, this procedure may have been very 20 adequate for what was done in October. But for this -
21 event, at the level that I believe the NRC perceives it to c
12 be, I think it would need a lot of enhancement before I'd 23 think it would appropriate for this particular incident.
24 MR. WHITNEY: Well, I haven't reviewed what 25 you're talking about on a line-by-line basis. But I know l
()
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3433 AMERICAN MlVER DRIVE. BulTE A
, SACRAMENTO. CALIFORNIA 95535 TELEPHONE (916) 973 5894 t
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i I that the functional steps that are in the procedure are 2 practically word-for-word. It is our attempt to capture 3 that information.
L 4 We have been able to capture that information
{
! 5 necessary to answer the questions of the Commission in the 6 previous events.
7 The program that we've put in here includes an i- 8 action plan. And the bottom line of the action plan is 4
9 the requirement that.the NRC sign off as to agreeing to 10 that action plan, as it being adequate for the purpose to i
11 which it's being applied. If that is not sufficient, then l 12 we would expect to see your comments, directing them what t 13 would be necessary to make that specific action plan i
O i. accertah1e.
! 15 MR. BEARD: No, no. Let me give you my own l 16 personal feeling. When.were were doing the Davis-Besse
' 17 investigation, which was considered to be a major 18 incident, the team adopted the approach that we did not 19 want to give specific, directive, detailed guidance to the
- 20 utility.
11 What we chose to do was to spend a lot of k 22 up-front time developing general guidelines. With the 23 understanding that if an action plan followed those i
- 24 guidelines to the T -- in other words, there were no
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O PETERS SHORTHAND REPORTING CORPORATION 3433 AMERICAN RIVER DRIVE, sulTE A j SACRAMENTO, CALIFORNIA 95555
) TELEPHONE (996) 973 8894
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- 13 1 deviations -- by definition, the action plan would be 2 acceptable.
3 Now, we did review them and provide comments.
4 But we specifically wanted to avoid the concept of having 5 given the same type comment on every single action plan 6 that's for a specific piece of equipment. That's why we 7 spent so much up-front time on the general approach.
8 MR. WHITNEY: Well, I'm not sure -- I have not 9 looked at the general approach that was used there, with 10 the idea of comparing that on a line-for-line basis to our 11 general approach. But we will certainly do that. And if 12 you want us to copy the Davis-Besse general approach, I 13 don' t know that that's entirely appropriate.
() 14 We can consider that. But it is our intent to 15 have a program that gathers all of the available 16 information, and does not overlook anything.
17 The complexity of this particular event, as we 13 see it right now, is not that it is a major event. And 19 the equipment failures that we incurred were not major 20 equipment failures. They were complicating problems with 21 every one of them. But we so far do not see that we have 22 a problem here that is terribly sophisticated in rooting 23 out. -. .
24 MR. EDISON: Okay, I understand. I think what 25 we'd.like is -- we'll review the program you have. And PETERS SHORTHAND *SEPORTIN[s DunPORATION 343?l'AMERICAN , MIVER DRWE. SUITE A SAURAMENTQvCALIFORNtA 95825 TELEPHONE (91C) 973-SP*i4
. m
14
, I what I would request is, that you would review your 2 program against the criteria again.
3 And then we will talk again. And we will 4 discuss the differences, and seek to understand why the 5 differences exist. And the significance of them. And I 6 think we'd like to leave it at that. We'll evaluate the 7 program, you know, see if we have a big problem with any a of it.
9 MR. BEARD: Let me make it clear that I'm not 10 saying that it's unacceptable because it doesn' t look
_ 11 verbatim like Davis-Besse. That's not my point at all, 12 you know. But there's some concepts that I don' t see you 13 have covered. But we have to look at this.
O i4 "a ""' Tam'= 'o= 1 o =eea to i=ct"ae with en t 15 an understanding of how we administer our work. And how 16 we control engineering here at Rancho Seco. And I think 17 that our engineering control, configuration control, and is work control programs are quite sophisticated and capable 19 of managing this kind of an effort.
20 And you need not develop a new program in order 21 to do those things that are already in place by the 22 existing programs.
23 MR. CHAFFEE: So what you may be saying, is that 24 this an umbrella document that references various other 25 control requirements that exist in other procedures?
A V
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r l
15 1 MR. WHITNEY: It does not reference them in 2 there in a by-reference line number. But when you go in 3 to actually acomplish work, or to do engineering, or to do 4 testing, or whatever the case may be, we have a very good, 5 detailed, and exacting set of procedures and programs in 6 place, which control that. It is not that we do not have 7 controls.
8 And that this document here is the only thing 9 that is going to be controlling work or gathering data 10 for us.
11 MR. CHAFFEE: I understand. I guess one thought 12 that crosses my mind, in light of that, is certainly if 13 you take ,your existing procedures and stuff for doing this
() 14 kind of work, to combine with this, it may be that there 15 is a basically, you know, very consistent with this 16 program that came out of the Davis-Besse event.
17 And you know, if that's the case, obviously the 18 effort will get done. The only thing I would point out is 19 that perhaps it might be clearer to people. Perhaps a 20 program that is outlined here could, somehow -- how do I 21 say it -- make the jump. I suspect that your procedures 22 and stuff, although probably may do it, but it's going to 23 be difficult to --
24 MR. WHITNEY: You' re going to have trouble, if 25 you want a stand-alone program that's directly comparable O
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16 1 to the Davis-Besse program. Because the two plants are O 2 unique, in the way in which the administer and control.
3 MR. CHAFFEE: I guess what my thought would be 4 is, okay, there's item A on this thing. You handle it 5 because you have another program that exists. It does the 6 exact same thing.
7 Guidelines might simply say, you know, that that g is done under this particular program X.
9 MR. WHITNEY: I believe what you're really 10 looking for is a cross-reference table to go back to the ji Davis-Besse programs. And that we will be -- we can try 12 to do that, if we make the assumption that the Davis-Besse jg description that you have here in four and five pages is a
()
14 comprehensive program description.
15 MR. CHAFFEE: Well, that's the other thing.
16 There may be differences that should exist.
17 MR. WHITNEY: Just in the quick glance that I ig had at the program, they use nomenclatures in there which 39 we do not use, which infer to me that they had assumed 20 that other things existed that in fact would not have a 21 direct parallel in our situation.
22 MR. CHAFFEE: You're right. This thing needs to 23 be tailored to the needs of the situation. And I 24 understand that. And I guess the worst thing is, we need 25 to do the review of this tning.
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17 y MR. EATON: If you take a look at the O 2 Davis-Besse one, would you perhaps be able to identify, 3 again talking line for line, something that they say that 4 you may cover? I guess it's that cross-referencing that 5
we're talking about.
6 MR. WHITNEY: I think I can probably simply go 7 through the Davis-Besse thing, and tell you how we g accomplish everything that they did. And then you can 9 listen to that and determine whether or not the program we 10 have outlined for you --
yy MR. EATON: Yeah. That would show the --
g MR. WHITNEY: -- gives you a similar level --
y, MR. CHAFFEE: That would be good. Because that
~
O 14 could go on the record and would make it very clear.
(J 15 MR. BEARD: That I think would be very useful.
16 But I'd like to emphasis a point again. At least I'm y7 personally not interested in word-for-word, line-for-line y, type comparisons.
For example, if the folks at Davis-Besse called 19 20 it a maintenance work order, and you want to call it an action plan, I could care less. I'm interested in l
! . concepts.
MR. WHITNEY: Yeah. I agree, 23 p MR. BEARD: And I'd be very interested in 25 knowing how you're going to provide concepts such as lO PETERS SHORTHAND REPORTING CORPORATION 3433 AMERICAN RIVER DRIVE. BulTE A SACRAMENTD, CALIFORNIA 95325 TELEPHONE (916) 972 3394
18 I traceability. And whatever system you use. And however
.O. 2 you want to do it.
3 That's fine. but I'd like to know that it is 4 going to be covered, and generally how.
5 MR. WHITNEY: In my situation, I of course need 6 to know what you mean by traceability. Because we have 7 traceability here for a lot of different things. But I 3 think right now, we may be talking on an entirely 9 different levels, as far as what we're talking about with 10 the term " traceability."
11 MR. CHAFFEE: For example, let me propose this 12 for a possible example. When you go out and do work, to.
13 what extent do you provide traceability in the sense of, h 14 to what detail do you document the activities that are 15 Performed? Is that the kind of thing you are talking 16 about?
17 MR. BEARD: Well, the simple way that I' ve 18 explained this in the past to various people was 19 traceability in my mind, is at all times the utility would 20 be able to say, here is where that device is. Here is t 21 where it's been. And here's what's happened to it .
t
~
a 22 already. Since the transient.
23 MR. EATON: Are you talking like, for instance, 24 the power monitor module?
25 MR. BEARD: Sure.
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19 1 MR. EATON: If they were going to do work on O
2 that, or f arm it out to somebody else, you' re able to 3 trace the trouble-shooting scheme and location --
4 MR. BEARD: All the way through.
5 MR. EATON: -- of the module --
6 MR. BEARD: All the way through.
7 MR. EATON: -- as it went through.
3 MR. BEARD: All the way through.
9 MR. EATON: Perhaps here to some engineering 10 concern to look at it or whatever, jy MR. BEARD: Physical location. Physical 12 traceability, and what actions have occurred to it in the 33 past. That kind of thing.
O 34 And et me bring ut that the concern is that, 15 sometimes you have failures of items that are not safety 16 related. They don' t have that magic title assigned to 17 them. And therefore, the degree or level of tender loving 33 care that one gives to non-safety related items is 39 typically far different from what it would be if it were 20 safety related.
21 All right. My experience has been, in these 22 events you want to have the kind of traceability and 23 tender loving care for the purpose of understan, ding and 24 diagnosing the event similarly. Okay.
f 1
23 MR. EATON: So just by virtue of the fact that '
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20 1 the ICS is a non-safety --
O 2 MR. BEARD: Non-safety related. The normal 3 procedures and level of control. Level of quality 4 assurance, QA checks.
5 Hold points is entirely different, in my mind, 6 at every plant in the country for a non-safety related 7 P i ece of system, piece of gear. And for the particular a few items that are associated with this transient, you may 9 want to have a higher level of involvement.
10 MR. WHITNEY: Let me tell you what we do in a 33 situation like that. We have -- on our class one 12 equipment we require inspection categorically. But in any 33 case, in every case, every item of work is done under_.a
() 14 work request. And everyone of those is dispositioned by 15 an engineer.
16 And the engineer is responsible for including in 17 his disposition those inspection requirements that are to is be applied to this particular device. Now on class one 39 equipment, it's already done. It's in the book. It's a 20 standard. You pull it out. And you do the same one every g, time.
22 He is not limited to that. He can also specify 23 any additional inspections or holds that he may happen to 24 want. For non-class one gear, the same exact requirements 25 exist. It's just that we do not have in the book a O
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A 21 1 pre-planned procedure in most cases, which says these are O 2 the inspection hold points.
3 Because the inspection hold points on class two !
4 type equipment are up to the dispositioning engineer.
5 What we have done with this program that I have presented 6 to you this afternoon, is to require that the 7 dispositioning engineer put in place those inspection hold g points necessary to obtain the failure data, and all of 9 the other historical data that would be necessary to 10 understand and resolve the issue with respect to that 3y piece of equipment.
12 What we have done, in fact, is to put in a much 13 higher standard than what we would put in for normal class "S"**"*"'- ****'"
~
O '4
"" '""' """* S"*'*"*"' " * ' "
15 the aux B waterflow control valves, which are class ene.
16 And we feel like the class one program is good 17 en ugh for routine work. But in this situation, we want yg this higher degree of control and involvement. The y, program I have here does that for us. We have, in the 20 past two times we have put this program into effect, we 21 have had no shortage of data.
22 No shortage of knowledge of where the various P i eces of. equipment are. They are status. There are 23 24 repair requirements. Any work done on those devices is 25 documented, including all of the things that the QA O
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4 22 1 program requires. Such as what instrument you' re going to 2 use for calibrations and cal checks. And what procedures, 3 and were they current, that were being used.
4 And what was the individual's name who did the 5 work. All of that kind of information is being csptured.
6 And it's a very high degree of control that's being 7 exercised on this type of equipment.
g MR. BEARD: Okay. It sounds like -- and I'm not
, criticizing your program.
10 MR. WHITNEY: I understand.
l . yy MR. BEARD: Don' t misunderstand.
12 MR. WHITNEY: No, I'm not, yy MR. BEARD: But it may be that, to help an
() 14 outsider like me understand the full significance of your 15 Program, what you need to do is to is to maybe add in some 16 flavors. That when the guy does carry out this thing, yy that as I understand the way you've described it, the yg requirements for QA for class one equipment would be 19 considered the point of departure.
20 And you should add the appropriate-points. Now 21 y u see, that gives me an entirely different flavor.
22 MR. WHITNEY: We can -- you know, we can put-gg words in here, if it would help, that would_say all_of .-
24 these are inspected to be class one or typical of class l
ne r better. Inspection requirements and documentation.
I 25 lCE)
I i
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23 1 We could do that. That's not a problem. Because our QA 2 program applies already to all class one and selected 3 class two equipment as it stands.
4 And we' ve always treated, for instance, the ICS 5 that way. We have a complete maintenance history on those 6 elements in there. We have a very sophisticated records 7 keeping system, for keeping track of all work ever done on 3 any module or end item. So we have those kinds of history 9 records on the equipment. And we'd have continued that, 10 whether or not this event had occured.
11 MR. BEARD:- It sounds to me as though, that 12 you've probably have a very good program. It's just that 13 it's not very accurately reflected in this piece of paper.
()
14 MR. CHAFFEE: Well, it's not f ully 15 characterized.
16 MR. BEARD: Yeah. .That's what I meant.
17 MR. CHAFFEE: On a piece of paper.
13 MR. BEARD: That's what I meant.
19 MR. WHITNEY: I only have the experience of 20 having operating this program twice in the past. And have 21 been able to obtain the quality and quantity of data that 22 was necessary. And I think that it's more than 23 sufficient. - -
24 MR. CHAFFEE: Oh, yeah. What we were saying, 25 not that program, the actual end product isn' t suf ficient.
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l 1 What we're saying is, that if somebody sits down and reads 2 this, they don' t get the full expression of all the things 3 you do. But that's probably because of the --
4 MR. WHITNEY: But recognize this was written not 5 for you people.
6 MR. CHAFFEE: Right. Right.
7 MR. WHITNEY: This was written for us. To g accomplish wh,at was deemed necessary. And our experience 9 has been that this, in fact, is an adequate and sufficient 10 Program.
3; MR. CHAFFEE:. Okay. Well I think we're -- okay.
12 We' re going to have to review this. I have a suspicion 33 that what we' re going to have to -- af ter we've reviewed
() I'4 this, we' re either going to have review additional 15 documentation to get the entire implications of this 16 document. And that in order for us -- and I have this 17 belief that it's going to possibly be the case, ja That 'for us to do that more ef ficiently, we' re 19 going to need some of your help. In the sense of helping 20 us figure out what these other documents are. And then 21 have possibly -- we may need to talk about this some more 22 tomorrow. The help may be in the form of what you were 23 talking about, a matrix.
24 Because I personally will need to sit down and 25 review this as well, as against the Davis-Besse, before PETERS SHORTHAND REPORTING CORPORATION 3433 AMERICAN RIVER DRIVE SulTE A SACRAMENTD, CALWORNIA 9SS25 TELEPHONE (916) 972 3394
25 1 I'm ready to talk more about it.
L 2 MR. EATON: I think it might be helpful to bring 3 the point home to you all in this whole process. That 4 there will be a document issued as a result.of our 5 involvement. And that document, I feel, will have to be a 6 stand-alone document. Because it will be in the public 7 domain.
3 And so, if people reading it in the public 9 domain don' t understand, because they would have come to 10 you to get the same level of detail that isn' t already yy expressed in your document, then it would not be a 12 stand-alone document.
33 MR. CHAFFEE: I think at this point, what the
. y4 rest is --- we need to review this. We will get back to
(}
15 y3u and talk to you about it again. - And at this point, 16 the team has a concern that perhaps the document itself 17 d esn' t -- it's dif ficult for us to see it standing alone yg in the public domain, y, And let us review that, and see if that position 20 stays constant when we talk again.
21 MR. BEARD: We want to -- do we want to talk 12 about this matrix type of comparison between these two gg documents?
24 As to -- I think number one, you said you're 25 going to do it. But do you have any feel for what sort of l
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26 1 time frame we're speaking about. As to when we would have 2 that kind of cross reference?
3 MR. WHITNEY: Well, I think we need to step back 4 just a little bit.
5 MR. CHAFFEE: Yeah. I think --
6 MR. WHITNEY: The whole -- what you' re asking 7 here now is entirely new. It was not until about two
, hours ago that we even knew that you had this higher level 9
of interest. And when we put this program together, this g was a program we felt that would serve our needs and meet yy your requirements.
And that's what we have.
Now, if' you' re telling us that we have to put y, together a program that provides you with a report that (a will stand the test of a stand-alone document in the public -- for public scrutiny, that's an entirely different organization here. We're talking orders of g magnitude, and more people involvement.
We' re talking orders of magnitude and more d llars to produce those kinds of documents. It takes an 19 entirely different flavor, if we're trying to make these educational and training manuals at the same tinae that we' re trying to put together a program that is effectiva for accomplishing work, nuclear safety related.
MR. CHAFFEE: At this point, what we' re saying 25 O
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27 1 is simply this. We want to review the document, okay, 2 then we --
3 MR. WHITNEY: Well, I can tell you right now 4 that that document is not adequate and sufficient for 5 educating the public as to how we do maintenance, to the 6 degree that they think we should be doing it in a nuclear 7 power plant.
3 You have to have the knowledge of people who 9 have expertise in the existing procedures. You have to 10 have people who understand quality control and quality 13 assurance programs, and know how work is done in a 12 controlled environment.
13 And that is not going to be suf ficient. It's
() 14 going to take, like I say, orders of magnitude,.more work 15 to do that. And I don' t know that we are prepared to 16 Provide that with you.
17 Now, we can provide to you the source documents, is from which you can develop yourselves a procedure, or 19 documents which would, in fact, be adequate for that kind 20 of scrutiny. But we are not prepared at this point in 21 time to do that for you.
12 MR. BEARD: Well, Dan, let me say something. I 23 think Ron was trying to give you an example _to. convey 24 another aspect of the program. Certainly to have it a 25 stand-alona document, in fact, it's going to be in the O
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1 l
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1 public domain, is a consideration.
O- 2 But in my mind, at least personally, first and !
l 3 foremost, we on the team want to understand your program i 4 to the extent that it's necessary for us to be convinced 5 it's adequate for this event.
6 That's the first and foremost thing, okay. Now, 7 if you want to do it with a cover memo with two pages and 3 a stack of references, that you can show us how this all 9 goes together, that's fine.
10 If you want to do it with a new document that's it more elaborate,.that may be fine, too.- But we need.to get 12 to that end point that we, as a team, understand how this 33 trouble-shooting's going to organized, executed, and the end product, so that we'll feel like that, in fact, the
(]) 14 15 root causes are determined, and that we'll be happy with 16 the end result.
17 The tutorial session for the public is is definitely secondary. It was only an example to bring up 19 the flavor, I think --
20 MR. EATON: Well, let me clarify what I meant by 21 "Public." I certainly didn' t mean the average person on 22 the street.
23 MR. BEARD: Right.
24 MR. EATON: When I'm talking about public, I'm 25 talking about the people that are really going to be PETERS SHORTHAND REPORTING CORPORATION 3433 AMERICAN RIVER DRIVE. butte A SACRAMENTO, CALIFORNIA 95535 TELEPHONE (916) 973 3394
29 1 looking at that. You know, the concerned scientists, 2 these type of people that are interested and have the 3 background knowledge, for the most case, in engineering 4 and nuclear power, and are vitally interested in the whole 5 area.
6 MR. BEARD: The ACRS and the Commissioners --
7 MR. EATON: ACRS, Commissioners, those type of 3 people are what I'm talking about, when I say a public 9 document at that level probably ought to at least exist 10 for their benefit. Similar to New Reg 1150, is it?
11 MR. WHITNEY: Well --
12 MR. CHAFFEE: At this point, let us review your.
13 documents, th'e documents you have.
O '4 "" """"': " 2 '~ cat 1r"risata -
15 that it will not meet your needs for that kind of an 16 application. It was not intended to, and like I say, 17 until two hours ago, we didn' t know that you had such an 33 interest.
39 And what we have done here has been adequate and 20 sufficient for the last two times the NRC felt obliged to 21 come and look at these things. And you know, this is a
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22 new Program that you want now, and it's -- you know, what 25 you' re doing is, you' re talking about days and weeks - to do__
24 hours worth of work.
25 And it's a whole new game.
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30 1
MR. BEARD: Well, let me mention just for the O 2 record that, informally, I have mentioned to SMUD 3 employees, since the first day we got here, that there 4 will be a quarantine list of equipment, and there will 5 have to be some plans developed as how to handle that 6 equipment.
7 And that, in my opinion, the point of departure a was the plan that's in the New Reg, as to the best 9 reference to go from.
10 MR. CHAFFEE: Yeah, and I also --
11- MR. BEARD: And that's been said f rom _the first 12 day.
13 MR. CHAFFEE: -- told your management the same 14 thing. That's okay.
15 MR. BEARD: Now, you may not have gotten the 16 word, Dan, and I'm not criticizing that. But this is not 17 a new requrement. We' ve been talking this ever since the is team first got here.
19 MR. CHAFFEE: What was told was that this was 20 going to be the guideline, that we were going to prepare 21 the program --
22 MR. WHITNEY: And we also told you that we 23 developed our program around those guidelines. The NRC._
24 was satisfied with the way in which it was used the last 25 two times.
O PETERS SHORTHAND REPORTING CORPORATION 3433 AMERICAN RIVEN ORIVE, BUITE A BACRAMENTO. CALIFDMNIA 95825 TELEPHONE (916) 972 3894
31 1 We felt like this program was sufficient to do 2 what was intended. We have got a quarantine list for you, 3 like you had requested.
4 We have treated the equipment on that quarantine 5 list as quarantined equipment should be treated, and we' re 6 here today to present to you what we are doing, in terms 7 of how we think things should be treated that are on that a list, and how we can get them off.
9 Because we're very anxious to get started in 10 doing some constructive work on this equipment.
11 MR. CHAFFEE: Okay. And we've accomplished that 12 in this meeting. We now have the document that defines 33 the umbrella scope of your talk with them. We now need to
- ve *** "a O i+ re't " it- "* " "***
- 9 9 9" *io" 15 we have a few, and we'll develop those and talk tomorrow.
16 MR. WHITNEY: Okay.
17 MR. CHAFFEE: Okay?
13 MR. BEARD: I appreciate your taking the time to 19 come over and present this and discuss it with us.
20 Because if we'd have had this document just handed to us, 21 it would have been much more difficult to understand, as
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22 I'm sure you can appreciate.
23 MR. WHITNEY: Well, definitely. That's why we 21 wanted to do that.
25 At the same time, I'd like to go ahead and talk O
PETERS SHORTHAND REPORTING CORPORATION 3433 AMERICAN RIVER DRIVE. SUITE A SACRAMENTO. CALIFORNIA 95525 TELEPHONE (916) 972 5594
32 1 for a moment about what we should do tomorrow. Because I O 2 understand we're going to meet at eight a.m. tomorrow?
3 MR. BEARD: Um-hmm.
4 MR. CHAFFEE: We want to go into sequence of 5 events.
6 MR. WHITNEY: Okay.
7 MR. CHAFFEE: And after going over the sequence 3 of events, we'd like to get into a discussion -- and in 9 that discussion, I intend that we be prepared to bring out jo specific comments, in terms of things that we feel are yy important, that basically describe what,we see in.this 12 guideline that exists from Davis-Besse, that we don't 33 understand how it's being implemented in your program.
() 14 And then, I guess, lead into a discussion of, yeah, this we don' t understand. How do you do this. This 15 16 we don' t understand, how do you do this type of thing.
17 Until we finally understand fully how, you know, yg either you don' t do it because there's a good reason for jp not doing it, you don' t do it because, somehow it's just 20 not the way it's done here, and it's appropriate the way 21 it is being done.
12 Or y u d it, and this is how you do it type thing. And so, we'll go through that type of discussion,.
25 24 MR. WHITNEY: Okay.
25 MR. CHAFFEE: So is that type of a discussion PETERS SHORTHAND REPORTING CORPORATION 3433 AMERICAN RIVER DRIVE. BulTE A SACRAMENTO. CALIFORNIA 95525 TELEPMQNE (916) 972=SG94
_ - . _+ . . _ . _ _ _ . . _ - _ _ . , .-. . - . _ _ ,
l 33 7-1 one that we can proceas here tomorrow morning at that 2 meeting?
3 MR. WHITNEY: Definitely. Yeah, there should be 4 no problem with that.
5 MR. CHAFFEE: Okay.
6 MR. WHITNEY: I'm still a little concerned about 7 where our final goal for being tomorrow is.
g MR. CHAFFEE: The goal is to understand how the 9 program you have is appropriate to --
10 MR. WHITNEY: Okay.
33 MR. CHAFFEE:. -- the activities that are 12 involved. And using this as a guideline of things to be 33 c'nsidered, o relative to going up and trouble-shooting this
() 14 equipment.
15 MR. WHITNEY: Okay. Do you envision us getting 16 to the point that, assuming that the program we have would 17 be sufficient, that we could then get on to identifying 18 those items which should be on the --
39 MR. CHAFFEE: Yes. At the meeting tomorrow 20 morning, irregardless of how we progress on this, as far 21 as identifying what should and shouldn' t be on the 22 quarantine list, we will state a position on that tomorrow
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23
- IniD9- '
24 MR. WHITNEY: Okay. Now, with respect to the 25 quarantine list itself, we need to come to some.
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34 1 understanding as to just how elaborate that quarantine 2 list should be.
3 MR. CHAFFEE: In terms of what items should be 4 on it?
5 MR. WHITNEY: Yes.
6 MR. CHAFFEE: As it stands right now, my 7 understanding is that the quarantine list should list g those pieces of equipment that failed during the event, 9 and their failure is significant to the evaluation of the 10 event.
yy MR. BEARD: Well, the word "f ailure" needs to be .
12 Put in quotes. But the pieces of equipment that y3 malfunctioned o'r had a significant impact on the event.
r~x And I bring that up because, for example, one U 34 35 could argue that the ICS did not fail. It functioned as 16 designed. But clearly, the ICS is an item of interest.
37 So all the items that are specifically a piece jg of equipment that can be identified, you know, valve j, number umpty-fratz (sic) --
20 MR. WHITNEY: Yeah.
21 MR. BEARD: Whatever it is. And it would be a 12 very simple, concise list of equipment.
23
_ MR. WHITNEY: Okay, well, let me give you the 24 example that's causing me some concern.
25 In the power supplies for the ICS, which I think PETERS SHORTHAND REPORTING CORPORATION 3433 AMERICAN RIVER ORIVE, SUITE A SACRAMENTO. CALIFORNIA 95535 TELEPHONC (gH6) 9h2=5594
35 1 we can all agree are of interest here, there are basically Uc 2 three different ways you can get power into the ICS. And 3 through one of those ways, goes out into the normal plant 4 buses, where electrical power comes off of the 480 volt 5 remote control centers.
6 All the way back to that bus, then there's a way 7 to tie that bus to a parallel bus. And so, in total,
, a there are some probably 60 major items of equipment, 9 including things like --
10 MR. CHAFFEE: Oh, I see what you're saying. The 11 scope -- .
12 MR.~ WHITNEY: Yes. .
y3 MR. CHAFFEE: You're talking about the scope.
14 MR. WHITNEY: The scope.
15 MR. CHAFFEE: Okay.
16 MR. WHITNEY: Because I've got things like 17 turbine building ventilation fans that come off the same gg bus that the breaker supplies the power which goes to --
39 MR. CHAFFEE: Okay. That's a good question.
20 MR. WHITNEY: And, you know, we're out there -
21 right now with that kind of equipment in so-called normal
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22 Operation.
23 And it gets turned on and turned off, whatever 24 turns it on and off. And I have put a quarantine on those 25 buses, but at this point, that quarantine means there lO l
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36 7.s 1 shall be no work done on those buses.
2 But the equipment on those buses is still in 3 normal operation.
4 MR. CHAFFEE: Okay. What we need is a rationale 5 from you for how narrow you can make the scope and the 6 justification for it, basically.
7 MR. WHITNEY: Well, I can sit here and give you 3 arguments as to why we should look at only the single 9 breaker that provides the power to the ICS, and quit at 10 that point.
31 MR. BEARD: I think that's the way to go, Dan.
12 MR. WHITNEY: Well --
33 MR. BEARD:- What I would like to see, and I
() 14 can' t speak entirely for the team, but I'll give you my 15 Personal assessment.
16 You should provide us the definition and scope 17 that you think is appropriate. We will look at it, if we 18 agree it's appropriate and reasonable, we'll say we' re 19 happy.
20 If there's some point that comes up that we say, 21 well, we think there needs to be just a little more, or, 22 like we did at Davis-Besse, we took items of f the gg quarantine list, because we said, those, in our opinion, 24 don' t have to have the degree of controls that the items 25 n the quarantine list are.
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37 i But I like your appropriate, what you suggested,
.g V 2 you lay out the way you call it. If we agree with it, 3 that's it.
4 MR. WHITNEY: Well, I guess the overall 5 structure I would like to do, like to see, is that we put 6 a process in place by where basically we're not penalized 7 for putting items on the quarantine list, just because --
8 because once we get them on there, they're difficult to 9 get off.
10 In other words, if I can put it on there --
11 MR. CHAFFEE: Items can be taken on- and putten 12 off (sic), with you providing justification for --
13 MR. WHITNEY: Okay.
14 MR. CHAFFEE: N o', thas's the fact.
15 MR. WHITNEY: If we can do that, then I have no 16 problem with this fairly broad definition is what I'm 17 using, like on these two breakers. And right now, just 13 keep all work from occurring on those buses, but as we get 19 further into our investigation, we'll have to decide on a 20 case-by-case basis as to where we want to move that 21 boundary.
22 MR. CHAFFEE: In effect -- our hope would be 23 that the appropriate boundary is picked, andcpart.of_that., -
24 appropriateness is that it doesn' t include anything that's 25 not necessary.
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38 g You know, I recognize that that may not always 2 be easy when you're talking about electrical stuff, but --
3 MR. WHITNEY: Well, the complicating factor in 4
that particular case is that we got a report from the security people, you know, at or near the time of the 5
event, that they lost for a few moments, some of the 6
security lighting.
7 And the electricians tell me that there's a way you can get security lighting off of some of these same buses, that they come through some of the same transformers, so -- _
MR. BEP.RD: If you go far enough upstream --
MR. WHITNEY: If you go far enough back upstream. And, you know, we're very interested in whatever it was that caused the ICS power to go away.
And we do not want to exclude anything that might lead us to finding the fault.
MR. BEARD: The only thing I can say to you, Dan, is that we can appreciate the problem you're describing. And we can work with you, and try to be' reasonable about it as best we can, 21 MR. WHITNEY: Well, I can accept that. There's no problem. ,
MR. CHAFFEE: Okay, any other questions?
MR. EATON: No, I think it's time to go off the O
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39 1 record, because I have questions that I'd like to ask off 2 the record, 3 MR. CHAFFEE: Anybody else have any questions 4 while we're on the record?
5 Okay. Off the record.
6 (Thereupon the interview was concluded.)
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40 I CERTIFICATE OF TRANSCRIBER 2 I, Ramona Wilson Gordon, an Electronic Reporter, 3 do hereby certify:
4 That I am a disinterested person herein; that 5 the foregoing Nuclear Regulatory Commission interview was 1
6 recorded and thereafter transcribed by me into 7 typewriting.
8 I further certify that I am not of counsel or 9 attorney for any of the parties to said hearing, nor in 10 any way interested in the outcome of said hearing.
11 IN WITNESS WHEREOF, I have hereunto-set my hand 12 this 31st day of December, 1985.
13 }
- h 14 bb ANb RAT 40NA71LSOlT GORDON "
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15 Official Reporter ,
16 17 18 19 20 21 22 25 -
24 25 PETERS SHORTHAND REPORTING CORPORATION 3433 AMERICAN RIVER DRIVE. SulTE A S ACRAMENTO. CALIFORNIA 9$525 TELEPHONE (916) 972 9594