ML20199L987
| ML20199L987 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/08/1986 |
| From: | Noonan V Office of Nuclear Reactor Regulation |
| To: | Asselstine, Palladino, Roberts NRC COMMISSION (OCM) |
| Shared Package | |
| ML20155B560 | List: |
| References | |
| TASK-AS, TASK-BN86-015, TASK-BN86-15 BN-86-015, BN-86-15, NUDOCS 8604110018 | |
| Download: ML20199L987 (2) | |
Text
{{#Wiki_filter:._ a v 'o UNITED STATES [';v-l NUCLEAR REGULATORY COMMISSION g g g C WASHINGTON, D. C. 20555 I i t c e g-j APR 8 ggg Docket Nos.: 50-445 and 50-446 MEMORANDUM FOR: Chairman Palladino Commissioner Roberts Commissioner Asselstine Comissioner Bernthal Comissioner Zech FROM: Vincent S. Noonan, Director Division of PWR Directorate #5 Division of PWR Licensing-A
SUBJECT:
BOARD NOTIFICATION - CLARIFICATIONS / CORRECTIONS TO NOVEMBER 19 and 20, 1985 TRANSCRIPT OF MEETING BETWEEN THE NRC AND CITIZENS ASSOCIATION FOR SOUND ENERGY (CASE) REGARDING SUPPLEMENTAL SAFETY EVALUATION (SSER) NOS. 7-11 (BN 86-15 ) This notification is being provided to the Comission in accordance with the revised Comission's notification policy of July 6,1984, to inform the Commission on all issues on the cases before the Comission. By Board Notification No. 85-093, we provided you with the November 19-20, 1985, meeting sumary and transcript of the meeting between NRC and the Intervenor CASE, regarding the Technical Review Team evaluations in the SSERs Nos. 7-11. During the November 19 and 20, 1985, meeting between the NRC staff and representatives for CASE, the staff stated that we would provide the NRC participants with a copy of the transcript for review to make any clarifications / corrections necessary. These clarifications / corrections have been compiled and the affected pages are enclosed in a letter to representatives for CASE. This transmittal letter is provided as an enclosure to this Board Notification. The parties to the proceeding are being notified by py of this memorandum. / \\ / ona, or W Proie Direc orate #5 Division f PWR Licensing-A
Enclosure:
Letter to representatives for CASE cc: See next page 041100
0., ? 1 i cc: P. Bloch, ASLB W. Jordan, ASLB K. McCollom, ASLB E. Johnson, ASLB H. Grossman, ASLB SECY (2) EDO OGC OPE ACRS (10) Parties to the proceeding j See next page i i i i a 1 1 } i, 4 i i j i 1 I. .i a i ~, .. ~... ,m,r ,m _~_.[_,_ .-,y. .,'..w.7 ,,r._, 4, 4 y
UNITED STATES 4 c,, NUCLEAR REGULATORY COMMISSION [ g W ASHINGTON, D. C. 20555 7.
- j
/ MR 8 58 + *** Anthony Z. Roisman, Esq. Ms. Billie Pirner Garde Trial L.awyers for Public Justice Government Accountability Project 2000 P Street, N.W. 1555 Connecticut Avenue, N. W. Suite 611 Suite 202 Washington, DC 20036 Washington, DC 20036
Dear Mr. Roisman and Ms. Garde:
SUBJECT:
Ct.ARIFICATIONS/ CORRECTIONS TO NOVEMBER 19 and 20, 1985 TRANSCRIPT As we identified in our meeting on November 19 and 20,1985, we provided the NRC participants with a copy of the transcript to make any clarifications / corrections necessary. These clarifications / corrections have been identified and noted in the enclosed transcript pages. These clarifications / corrections are marked by a bar in the margin and are on the following enclosed pages of the transcript: 1, 2, 15, 30, 43, 67, 94, 105, 147, 164, 165, 199, 208, 213, 224.1, 228, 229, 235, 245, 252, 267, and 273. In addition, my response to Mr. Roisman's question on page 232 needs to be supplemented. Mr. Roisman wanted to know if all of the TRT concerns are encompassed within the CPRT program plan. My response should be as follows: That's correct, with the exception of SSER 9. Actions l required by SSER 9 to document the status of some coatings and to j j implement a program for prctective coatings maintenance were responded to in a separate submittal, dated November 18, 1985. Sincerely, e W W .N n WR Proj ect rectorate No. 5 Divisior of t.icensing-A i
Enclosure:
pages of transcript cc: See next page 8604160234 860408 PDR ADOCK 05000445 T PDR
CR249'41.0 KSW/cjg 1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 MEETING OP NRC STAFF WITH CASE 4 Nuclear Regulatory Commission 7920 Norfolk Avenue 5 Room P-ll8 Bethesda, Maryland 6 Tuesday, November 19, 1985 7 The meeting convened at 9:02 a.m.,;pparence Chandler,j 8 Office of the Executive Legal Director, presiding. 9 ATTENDEES: 10 ANNETTE VIETTI-COOK, NRR/DL/CPP T. A. IPPOLITO, AEOD 11 H. H. LIVERMORE, NRC - Reg. II C. J. EALE, NRC - Reg. IV j, H. S. PHILLIPS, NRC - Reg. IV C. E. McCRACKEN, NRC/NRR i CHET POSLUSNY, NRC/NRR/DL/CPP 13 ANTHONY Z. ROISMAN, CASE / Trial Lawyers for Public Justice ~ 14 BILLIE GARDE, CASE / Trial Lawyers for Public Justice i i LAWRENCE J. CEANDLER, NRC/OELD [ 15 LARRY SHAO, NRC [ ' JOSE A. CALVO, NRC 16 VINCENT S. NOONAN, NRC j GEARY S. MIZUNO, NRC-ELD CHARLES M. TRAMMELL, NRC I7 RICEARD H. WESSMAN, NRC l SHOU-NIEN HOU, NRC 18 R. W. HUBBARD, NRC 'V. P. FERRARINI, TRT i 19 R. MASTERSON, TRT W. P. CHEN, TRT 20 SPOTTSWOOD B. BURWELL, NRC/NRR/CPP C. D. RICHARDS, TRT J. H. MALONSON, TRT 2I M. W. ELI, TRT R. W. BONNENBERG, TRT 22 V. W. WATSON, TRT VICTOR L. WENCZEL, TRT I ~ 23 T. E. CURRY, TRT ll WILLIAM C. WELLS, TRT ( 24 DAVID L. MEYER,.NRC/ADM/DRR/FOIA JOE GAWLEY, NRC/ADM/DRE/FOIA 25 AL SERKIZ, NRC/NRR/ DST i PAUL KESHISHIAN, TRT-Consultan't -- continued -- ~
24941.0 2 KSW l PROCEEDINGS Laid 2 MR. CHANDLER: Good morning, I'm S(drence 3 Chandler with the Office of Executive Legal Director. This 4 morning there will be a public meeting which has been 5 agreed to between the Staff of the Nuclear Regulatory i 6 Commission and Intervenor, Citizens Association for Sound 7 Energy. 8 Citizens Association for Sound Energy this 9 morning is represented by Anthony Roisman and Ms. Billie 10 Garde. I will turn it over to Mr. Roisman in a moment for I 11 any opening comments or thoughts he may have. 12 Notice of this meeting was provided -- and in ( 13 addition I see representatives of the Applicant in the rear 14 of the room. Mr. Noonan, in a moment, will make some 15 opening comments, and further discuss the conduct of this 16 l meeting. 17 Essentially, this meeting is being conducted as 18 outlined very generally in the joint stipulation of Staff 19 and Citizens Association for Sound Energy Request for 20 Subpoenas, a document dated October 23, 1985, filed with 21 the Atomic Safety and Licensing Board in this proceeding on 22 that date. 23 The general subject of this meeting will be a 24 discussion and questioning.by Citizens As'sociation for 25 Sound Energy on the matters discussed in the Staff's k ACE-FEDERAL REPORTERS, INC.
24941.0 15 KSW ,( l that. If there were elements of wrongdoing, they would 2 look at that portion of it. We would cooperate -- in their 3 review of investigating wrongdoing there were possible 4 technical issues involved, then we would cooperate with 5 each other. We would extract from that portion of the 6 issue, the technical issues. I would then transform them 7 into " allegations," and insert them into the technical 8 review team review process. But the technical review team, 9 Nor NRR, as far as I know, looks at wrongdoing, and as I 10 understand it, intimidation and harassment is included as a 11 responsibility of OI. I stand to be corrected but that was 12 my understanding at the time. 13 MR. ROISHAN: Is it -- I'm troubled by the term 14 " wrongdoing." If a QC inspector -- if you learn that a QC 15 inspector approved something that shouldn't have been 16 approved -- you're doing a review, you find something, you 17 check back and see that he signed off on something as 18 satisf actory and it wasn't satisfactory, and it was a 19
- mistake, Is that wrongdoing by the QC inspector, without 20 getting to the question of why he did it?
21 MR. IPPOLITO: I think it is a judgment call on 22 the part of whoever uncovers this. If it looks like a 23 typical human error, that's one thing. If it was 24 determined to be premeditated or whatever "have you, 25 purposefully done, that's another matter. And if we { ACE-FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coverage 300 33M
24941.0 30 KSW k 1 didn't know what he was doing. Would the technical review 2 team consider that part of what its responsibility was, 3 then, to go and inspect all of the things that that 4 inspector had evaluated to determine whether other 5 technical problems slipped by the process because this one 6 untrained inspector was doing the inspections? 7 MR. IPPOLITO: No..We idenLified -- the modus 8 operandi, if you will, of the technical review team is to 9 determine whether or not they feel, after doing their 10 review, that there was or was not -- that the allegation 11 was substantiated or not. Ifitwas([3substantiatedwe 12 would stop there, and the burden as to the depth and g 13 breadth of that problem was placed on the licensee. 14 MR. ROISMAN: Do you know why that decision was 15 reached, why it was decided that the technical review team 16 would stop at that point? 17 MR. IPPOLITO: Because I could not possibly 18 follow that course of action in everything that technical 19 review team was doing. The 40 or 50 people on site was 20 totally inadequate to review each of the things for breadth l 21 and depth. That was not the way we set it up and clearly C00 22 not the way -- we just couldn't afford it and,it was not 1Mr 23 responsibility. 24 The responsibility for building that plant, for 25 building it safely, was theilicensee.'s, and once we had the ACE-FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Cowrage 800 33646M5
24941.0 I KSW 43 l MR. IPPOLITO: Paul Bemis. 2 MR. ROISMAN: Do you endorse what's there? 3 MR. IPPOLITO: Yes. I signed it. 4 MR. ROISMAN: Did you endorse it because you 5 knew it was right or because you trusted Mr. Bemis wouldn't 6 have said it was there if it wasn't right? i ogeted of I [:$$;I;gh st\\tt%on; p;Yp S I had 7 MR. IPPOLITO: d 1 8 good people. This was the conclusions of their findings, 9 and that was satisfactory with me. 10 MR. ROISMAN: Looking at the executive summary 11 on page 4, this statement appears: "The team's findings 12 indicated that r I the applicant's management control over the i 13 construction, inspection and testing programs is generally 14 effective and is receiving proper management attention." 15 What is meant by that statement? ~ 16 MR. IPPOLITO: Within the context of this quick 17 look, the degree of control of the applicant's management, 18 I had to determine as to whether construction should 19 continue. Some of the information that I was receiving 20 early on was describing the construction control as out of 21 hand. I had to make the finding personally myself whether 22 or not this was in fact the case. Is construction out of 23 hand, and what that means is that, hey, we looked, 10 days 24 or whatever it was, less than 10 days. What we saw, it is 25 not out of hand. That's all it says. 1 ACE-FEDERA1. REPORTERS, INC. gg,y w-- .s... . -.., ~,,. _ -. _ _ -., _ _ _,.. _ - -...,.
24941.0 67 KSW ( l MS. GARDE: If you had an allegation -- you said 2 you had about 300 allegations -- 3 MR. IPPOLITO: Not at this time. g-i C 4 MS. GARDE: You hadn't looked at ani allegations? 5 MR. IPPOLITO: No, my people were in Washington 6 trying to come up with whatever that New Mexico one was. 7 This was not with me. That is what they were doing at the 8 time. 9 MS. GARDE: Knowledge that the Nuclear 10 Regulatory Commission as an organization had was not 11 necessarily transmitted to the team at all? 12 MR. IPPOLITO: That's correct. ( 13 MR. CHANDLER: If I could ask you to wait until goos +'s on e r-14 the requ ;t-is through so we have the question on the 15 record and then the answer, rather than mid-way through the 16 question, it might help. 1 1 17 MR. IPPOLITO: I will do that. 18 MS. GARDE: Which of the members were in charge 19 of the quality assurance / quality control look? 20 MR. IPPOLITO: On page 3, executive summary, 21 Paul Bemis, section chief. He had -- we tried to identify 22 who was expert in what area. l 23 MS. GARDE: Okay, I didn't understand that the 24 in the executive summary, the people's names with their 25 expertise necessarily would coordinate with who did what in 4 s i ACE-FEDERAL REPORTERS, INC. 2c2-347 3m Nanonwde Coverage 300 336 4646
4. 24941.0 KSW 94 k 1 connection to the rest of management on the site, which of 2 course is an impossibility of appendix B being complied 3 with -- how could it not matter? 4 Let's say that it was 10 people, they had their 5 own supervisor, own OA/QC people and worked only on the 6 auxiliary building, and the applicant comes back and says, 7 we've checked the concrete strength for everything in the 8 auxiliary building and it all passed muster. We did not 9 find out why.. In a number of pours we didn't look at the 10 stuff but it doesn't matter because we know they only 11 worked on one building. Why is it not still important to 12 know, was the reason we didn't look at those whether they I 13 themselves had a flaw or whether it was Ae.cause they were not properly instrdcted by the supervisors for concrete on 14 15 the plant, or the supervisors for QA/QC on the plant or 16 something like that? 17 MR. CHANDLER: I think we're veering off course 18 here somewhat and straying into what Staff may look to in 19 the future in terms of requirements for activities we will CPRT 20 be looking at, in terms of get well programs,-07ETs, 21 whatever, rather than the retrospective of what the TRT did 22 and how it did it, and why it did what it did as documented 23 in the various SERs, and rather than go into speculation as 24 to what the Staff will be looking for and 'why, if we could 25 maybe keep our focus back on the point. ~ ACE-FEDERAL REPORTERS, INC. A-347 3700 Nationwide Coverase 300 336 4646
m =- l s 24941.0 105 I we talked to somewhere between 15 and 20 a egers. Those 2 were the ones we felt we needed to talk to to clarify 3 issues they already raised or in a couple of occasions they 4 were identified to us as a new alleger during the course of 5 our time on site. 6 MR. ROISMAN: What was the value, in your 7 judgment, of site visits as compared to the work done after 8 the site visit? What were your people getting*by be'ing on 9 site that they couldn't get if they didn't go to the site? 10 What sort of things? 11 MR. IPPOLITO: We had -- at the site we had all 12 that we needed. We had the documents right there. Those 13 were the documents we wanted to see, not something that 14 could be sent to us. The systems were installed there. 15 Right there. Let's g$ look at them. Let's see beyond the 16 problem that was identified. In other words, if it is a 17 hanger in this area, let's look at hangers in other areas. 18 The third dimension is that you could not get out of 19 working out of an office up here. 20 MR. ROISHAN: In your judgment was it valuable 21 to be able to go in and see the whole file in which some 22 particular document that you may have been. interested in 23 was placed, rather than to rely on the applicants to send 24 you the document? 25 MR. IPPOLITO: Cur objective was to ACE. FEDERAL REPORTERS, INC.
24941.0 147 KSW k 1 to my attention or Vince's attention. It then might be 2 referred to OI to look into. 3 MR. CALVO: You can go further than that.- If 4 the situation is there, it wouldn't come to me because the 5 way the system was set up that had been taken care of. I'm 6 here nice and clean, looking at the quality of the 7 installation. It will never reach my level because I only 8 look at the technical merits of the allegation, not if l 9 there was wrongdoing. That's somebody else's 10 responsibility on that level. 11 MR. ROISMAN: Let me ask Mr. Ippolito a question. 12 Is it your understanding that to the extent that the root t 13 cause of a particular problem when traced all the way back 14 was that management had an attitude about safety that was 15 not to do what the regulations required down the middle but 16 to try to get by as cheaply as possible,.that if.that were 17 the root cause, that that's a root cause which would be of 18 interest and the investigation would be being done at 01 19 and not* by the technical review team at all? 20 MR. IPPOLITO: You are coming at it rather 21 strangely. We went out and looked at a number of 22 allegations. Some were proven to be correct. We asked the 23 licensee, go and determine the root cause. We expect it. \\ sH ors 24 Were they not 5054f f10:ters? o { 25 MR. CHANDLER: I don't think so. ACE-FEDERAL REPORTERS, INC. 202 347 3700 - Nadonwide Coversee 800 33MIM6
24941.0 KSW 164. k 1 MR. ROISMAN: What I'm trying to understand is 2 when you were incorporating into the orginal technical 3 review team the results of OI investigations, some of which 4 had findings of wrongdoing and proposed fines were issued 5 or are still outstanding with regard to that, the technical 6 review team did not use those as generic implication 7 indications to define the scope of how far you would look 8 to see how bad the problem was. 9 MR. NOONAN: Let me interrupt here a second. 10 I'll take an example. If there was a wrongdoing finding by 11 OI that says a QA inspector falsified records, it would be 12 our responsibility to see what that QA inspector did to \\ 13 find out how that work was affected. That's what the 14 process calls for. That's what we're doing. 15 MR. ROISMAN: What do you do with a finding that 16 the inspector was harassed by a high level supervisor? Do 17 you look at all the people that high level supervisor 18 supervised to detcrmine whether their work was also 19 affected? 20 MR. NOONAN: Our process calls for us to look at 21 the quality of that plant. How was the quality of that 22 plant affected by that intimidation. That's what the 23 process calls for us to do. R ois m c.n 24 MR., effAO: The qu9stion is, how did you handle ( 25 the OI findings on Messrs. Dunham and'Atcheson? (%c. thc4Noe i W6 WooN6 nan b_ essng n Amea o9 io6 W ocAs m r. R oh mo.n : Th ca ri w h s' i n 6s v's 6 ocb g ore mg c_\\(cnb ACE-FEDERAL REPORTERS, INC. w3 w.wn w.. w-ez
- - - - ~ - 24941.0 165 KSW k 1 MR. NOONAN: I can't remember Dunham. I think 2 you need to ask the particular group leader. 3 MR. ROISMAN: And Mr. Atcheson? 4 MR. NOONAN: Mr. Shao. He would look at those 5 particular allegations, technically. 6 MR. F.OISMAN : Both those gentlemen are public. ~ 7 We can speak without fear. 8 MR. CHANDLER: We have made commitments to 9 various individuals not to disclose their names, of 10 irrespective wrdr the arrangement you have with them. 11 MR. NOONAN: I do have at least verbal promisas 12 we would not use people's names. i 13 FROM THE FLOOR: Can we strike the names from 14 the transcript? 15 MR. CHANDLER: Off the record. 16 (Discussion off the record.) 17 MS. GARDE: I'm not going to ask anymore 18 questions on AQE-1. Let's go back to the beginning. I'm 19 still on the first sentence on J-4. We got up through 20 potential generic implications. The next phrase is "any 21 indication of potential management breakdown." Now, how 22 did you determine that, whether there was indication of 23 potential management breakdown? 24 MR. CALVO: I thjn'k I based -- I don't remember ( 25 that I addressed that subject, but I'believe that the SSER s ACE-FEDERAL REPORTERS, INC. c u...... e % .nn cu we
24941.0 199 KSW ( l MR. IPPOLITO: b he ah" dN h n cA espor*. 2 MR. ROISMAN: How would we document Brookhaven's. 3 further input into the technical review teata if there's not 4 a final report from them? Mr. McCracken? 5 MR. MC CRACKEN: The Brookhaven people who 6 remained involved were contributors So the various 7 categories in the back of appendix M, which is attachment 2 8 to it. The names of those individuals are listed upon page 9 l-3, again with their various affiliations. 10 MS. VIETTI-COOK: Instead of reporting to 11 region 4 they reported to Phil Matthews as technical review 12 team team leader. 13 MR. MC CRACKEN: Yes. { 14 MR. ROISMAN: But when they were reporting to 15 region 4 they issued an interim report and when they 16 reported to Phil Matthews there's no document that they 17 signed and sent to represent their final conclusions on 18 l this; is that correct? So in that sense they changed their 19 role. 20 MR. IPPOLITO: That's exactly what I said. 21 MR. MC CRACKEN: The role changed for the 22 sections, the categories that they were responsible for in 23 appendix M, they signed them. Those were transmitted to us 24 and signed by them. 25 , MR. ROISMAN: IfpI want to see what is their f ACE-FEDERAL REPORTERS, INC. 202 347-3700 Nation @ Comase 800 336 4646
.;_;..-.__.2. l 24941.0 208 CSW I i 1 insignificant amount of the total coatings area because 2 they were talking about small areas. They were specific 3 examples of areas a couple of square feet instead of large 4 areas of coated surfaces. If we had only look'ed at the 5 individual allegations instead of doing a broad generic 6 review of the coatings area, we would have come to a i 7 totally dif ferent conclusion, I suspect. 8 MR. ROISMAN: In doing a broad generic review, 9 you did not go back and reinspect the entire paint coatings 10 in the plant; is that correct? 11 MR. MC CRACKEN: 4. Yos,4o beth gvesHons. 12 MR. ROISMAN: You made a judgment as to what you 13 i would look at to be able to say that you could make some s i 14 l generic conclusions aboyt the paint coatings program? 15 MR. MC CRACKEN: Yes. 16 MR. ROISMAN: Where in this document have you 17 set out the criteria you use for deciding what that 18 investigation should look like to know that it would be 19 adequate to draw generic conclusions from it? 20 MR. MC CRACKEN: We did not set out those 21 criteria in this document. Those determinations were made 22 by the group of people who were assigned to the TRT who 23 were put there because of their expertise in this area. 24 MR. ROISMAN: Did they document that? Will I 25 have to go through the paint coatings documents, assuming ACE-FEDERAL REPORTERS. INC. .,--.,.,,n.-,. .,_m ,. - -,, -,, ~ - - -
24941.0 213 KSW k I coatings can fail, which would'then be, what is in the sumps 2 coatings exempt log and where is it'in relation to sums and 3 so on. 4 MR. ROISMAN: You might have had a conclusion in 5 appendix L that enough of the coatings could fail without 6 having an effect on the.emergen~cy core cooling system and 7 the nature of where they were in the plant that what was on 1 8 the coatings exempt log would be, admittedly after the fact, 9 okay, even though the way it got on the exempt log was not 10 okay? 11 MR. MC CRACKEN: I don't think I concluded in 12 too many cases that the way it got on the coatings exempt Har I 13 log was okay. There were some cases that we felt things 3 14 should be on the coatings exempt log that were not, but I 15 don't think we concluded that anything put on the coatings 16 exempt log was incorrectly put on there. 17 MR. ROISMAN: Then I need you to explain on M 18 119 you have a statement, and maybe it is the difference i l 19 between calling something indeterminate and making a 20 conclusion about it, but the next to last paragraph says 21 "The implication of the 20 percent CEL value is that the 22 remaining 80 percent of the coatings are of satisfactory 23 quality. However, such an implication cannot be considered 2 24, valid until the resolution of other technical review team 25 concerns such as assurance of DBA qua.lifications of 1 ACE. FEDERAL REPORTERS, INC. 2n.1471700 . Narinnwide Coverase _._.,,._ _[iblin.M M
n 224. ATTENDEES (Continued): 2 V. L. WENCZEL, TRT 3 J. H. MALONSON, TRT R. H. WESSMAN, NRC/NRR/DL 4 WILLIAM C. WELLS, TRT R. W. HUBBAUSS, TRT VICTOR FERRARINI, TRT 5 f R. MASTERSON, TRT C. D. RICHARDS, TRT 6 j W. P. CHEN, TRT BOB PHILLEO, TRT r 7 CHARLES HOFMAYER, TRT DAVID C. JENG, TRT 8 C. E. mcCrar k m T RI 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 J 24 's newnon, sna.
1942.0 IW 228 I the context of the CPRT and what is that and how does it 2 fit into it? 3 MR. NCCNAN: Let c:e read the paragraph here. 4 Okay, reask the question. 5 MR. ROISMAN: Beginning about the middle of the 6 paragraph on page M-6, there's a discussion of the NRC 7 meeting or the TRT meeting with.TUEC representatives to 8 s discuss something described as the proposed program plan, 9 and then in the next sentence, a partially revised program 10 plan; then the reference is made to a November 29 letter 11 and finally to the January 8, '85 letter. What is this 12 revised and proposed program plan and how does,iti fit into 13 { what we now know as the CPRT7 I ,14 MR. NCONAN: We have in front of us, I guess the 15 program plan tha we now have on the docket is the revised 16 ' program plan for the CPRT. That is the only program plans 17 I'm aware of that are called revised program. That's the 18 CPRT activities. It ha's the work done by C, the. Tera tsms 19 work,1 sets, the self-initiated programs, and that is also 20 the same program plan the Staff has now sent out questions 21 s on which we call the programmatic question, 11 programmatic 22 questions and all the other questions we had on individual 25A9s 23 5651 % Did that answer your question? 24-MR. ROISMAN: Well, you.qtre answering bu,t I 25 don't know whether I'm understanding. ACE. FEDERAL REPORTERS, INC. 3534 3?to NetsswWecesusnes mmam ~ _... E.r~ M - - i -- fy _ _ " ~ - . g. g.- __ _...,_.. _.. A
24942.0 KSW 229 ( l (Discussion off the record.) 2 : MR. NOONAN: My staff member reminded me. 3 Initially the applicant submitted a program plan in civill sirv o u e m af d i a+ pregn j 4 response to the lette @. The electrical, letted te th: QA 5 4+e4+sa. dcdad tapt.1t,v433. 6 MR. ROISMAN: These are the CPRT letters? 7 MS. VIETTI-COOK It just was the first -- 8 because we -- I don't think we issued the QA let.ter. It 9 was just they might have been the first, like SSER, the 10 electrical, mechanical, just the first couple SSERs and it i 11 addressed the specific technical review team issue. 12 MR. NOONAN: That was the first that came out. 13 When we had sent the QA letter out, it had not included it. 14 We said this is not really what we 're looking for. What we 15 need is a program plan to respond to the global problem. 16 That was really what I call the global problem, all the 17 safety things on the screen, and we asked for the so-called 18 1 revised program plan, it was the first plan where they put 19 it all together,in one document to address all the SSERs 20 and how the CPRT is going to respond. 21 MR. ROISMAN: There's a reference to a revised 22 program plan on November 21 of '84 being submitted by TUEC. ~ 23 Did you understand at that time that that was the CPRT or -- 24 MR. NOONAN: No. That was not t'he CPRT at th'a t i i 25 point in time. i ACE. FEDERAL REPORTERS INC. sa.w.nw m c e. -, - _,_, -. _ num- -,. - -, - -..,.. -,. am
24942.0 235 KSW l-1 you feel that that was going to be the result of that 2 review? 3 MR. MC CRACKEN: Sometime in February of 1985. 4 MR.-ROISMAN: And the letter, the technical 5 review team letter related to the paint coatings had 6 preceded that -- correct? -- at the time that the letter -- 7 MR. MC CRACKEN: There was not a coatings TRT e, 8 letter to the applicant. '9 MR. ROISMAN: You had just the Brookhaven letter 10 that raised the concerns; is that right? 11 MR. MC CRACKEN: The April of '84 Brookhaven 12 letter had gone out prior to formation of the TRT. 13 NR. WESSMAN: Mr. Roisman, the November 29, 1984 P 14 letter that dealt prim'arily with mechanical letters had a 15 one-paragraph comment concerning our status of the coatings pa; 16 review. I think that's the only time in our letters to the 17 applicant that we actually addressed the coatings issue. 18 MR. ROISMAN: Did you from the outset of this 19 investigation into the paint coatings matter decide that 20 you would not either look for root causes or that you would gg 21 not direct that somebody else look for root causes? Was 22 that a decision that had been made from the outset of the t 23 review? - (ncCr ac k co 24 MR. RCIS;1 ann I think it is nece,ssary to define fgg 25 what you mean by " root cause.} ACE. FEDERAL REPORTERS, INC. 202-347 3700 Nadonwide Coverage N336-6646 s
24942.0 245 gsW 1 the statement, you are saying it is almost a tautology. It 2 didn't work. It must have been inadequate performance. Is 3 that correct? p,. 4 MR. MC CRACKEN: Yes. F 5 MR. ROISMAN: Not trying to find out whether it tj 6 was an inadequate performance by some deliberate effort to 7 get around some procedural requirement or negligence or f 8 fear or anything else like that? 1 ~_ 9 MR. MC CRACKEN: That's correct. 5 10 MR. ROISMAN: All right. Now on page M-11, in a 11 the.very concluding paragraph, you indic, ate that "The ~ 12 deficiencies which were found, although now determined not 13' to be of safety significance, will be considered in 's 14 evaluating the effectiveness of TUEC's overall program." 15 Do I understand that you were making a 16 determination, based, I assume, on part L, that there is no 17 safety significance, not only the design basis accident 18 safety significance but no safety significance to the 19 status of the paint coatings at Comanche Peak at this point? s 7, 20 Is that what you are intending to say there? Is that 21 correct? g 22 MR. MC CRACKEN: What I am saying thero is based L 23 on the findings in appendik k, the coatings no longer have 24 to be qualified, that these deficiencies are not safety ca nd - 25 significant in the coatings afea. ACE-FEDERAL REPORTERS, INC. 202 347 3700 Nadonwide Coverage 800 336 6646 g
M O' s i 24942.0 252 24f A KSW KSV 7 S' 1 intent cf that ig to snow that it is a sufficiently small
- j) 2 amount that you would not have to be concerned about the
.cy 3 effect if all of it failed on ECCS systems.
- _f 4
MR. ROISMAN: Is there a criteria that ,y-5 determines what is a sufficiently small amount? Is there a 6 numerical guide of any kind? 7 MR. MC CRACKEN: No, there'isn't. That's 8, evaluated on each specific plant. 9 MR. ROISMAN: Is there any criteria for deciding, 10 other than just the applicant deciding to do it, what you 11 put into the coatings exempt log to begin with? 12 MR. MC CRACKEN: The material that goes into the (k 13 coatings exempt log would typically be that,which you did h 14 l not apply according to the Q standards. For instance, you 15 would get some small components from the manufacturer that 16 you couldn't assure exactly how it was coated but you 17 { didn't want to go through and strip it and recoat it. That 18 you put in the coatings exempt log. 19 MR. ROISMAN: Would it also be perfectly 20 permissible for you at the end of a day of paint coating, 21 the supervisor realizes that the wrong mix was used, no one 22 picked it up and they don't want to have to paint it again. I 23 Is that all right to put that in the exempt log? gI i 24 MR. MC CRACKEN: Yes, as long as you at the end 'IbeMfL 25 c.:difi_ the total you put in and can demonstrate that if j,,, i l $Y 2 4 c Ali
- k 47 4,h M-{
ACE. FEDERAL REPORTERS. INC. i
f 494,2.0 ' 267 KSW 1 significant impact on what was. going on in OA/QC. 2 MR. ROISHAN: Well, I assume that the number one 3 or two, you are probably right about. But we can only talk about them one at a time and none of us want to stay for 4 5 the rest of the day and go through all of the allegations 6 in the paint coatings area to see how many others by using 7 the global review you stopped your investigation and did 8 not answer the question, why did this dirty wall get 9 painted in the first place, and that would be foolish. 10 My point is to make sure I understand that it is 11 your judgment that you had enough data points to reach your 12 global conclusions and to say that these -- to the extent =, 13 .that you made those conclusions, these were plant-wide 14 failures in the paint coatings area, not isolated areas 15 that didn't add up to enough to make me be able to say they 16 are plant wide. 17 MR. MC CRNCKEN: I believe that's what I said 18 yesterday. Let's take about a 10-minute break, please. I ot su a b N 3 19 (Recess.) in Cracke n c 20 KR. NOONAN: Let's go back on the record. 21 MR. CHANDLER: Before we resume Mr. Roisman's 22 questioning, I have a, conc'ern. I think we're here at about 3 23 halfway through the morning on the second day. Staff is [ 24 somewhat concerned in light of,the agreement.that we 25 provided to make available for tour questioning, the l ACE. FEDERAL REPORTERS, INC. i 202 347 3700 NationwideCoverage " 800 336-6646
h 24942.0 - 273 a ESW e 1 appeared to be dealing with the issue to some extent -- you l 2 were not attempting to go back before the backfitting k 3 program to locate the technical reasons that there had to h# 4 be a backfit program at all; is that correct? 5 MR. MC CRACKEN: We had read the reports that 6 led up to the initiation of the backfit test program so we 7 were aware of why it was initiated. 8 MR. ROISMAN: You were aware of why the report 9 said it was initiated. You relied on the report rather 10 than an independent evaluation of your own? That's my only 11 question. 12 MR. MC CRACKEN: Part of our review included a 13 review of documents that existed prior to 1981. We did not ( 14 ignore documentation pre-1981. We looked at NCRs and irs e ( 15 and so on back in that area. We looked at the procedures ,a reN. g 16 from revsew-zero to the time we were at the site. ( 17 MR. ROISMAN: Still back on page M-43, you 18 indicated that as to AQO-37-C -- and this is another one of [ 19 the ones TRT could not draw a conclusion as to forging or ( 20. falsification. Why don' t you tell me what you meant by 21 "could not draw a conclusion"? 22 MR. MC CRACKEN: I think if you go back to the 23 write-up on 37-C -- ] 24 MR. ROISMAN: On page M-38. ft discusses the backfit 25 MR. MC CRACKEN: L ACE-FEDERAL REPORTERS, INC. I 202 347 37 3 Nadonwide Coverage 800 336 6646
y o / DISIRIBUrlCN LIST FG1 BOARD lOFIFICATICN Conanche Peak Units 1&2 j Docket Nos. 50-445/446 Pcter B. Bloch, Esq. Wi11fam L. Brown, Esq. William II. Burchette, Esq. I Mr. W. G. Cotmsil Mr. James E. Ctamins 'lhanas G. Dignan, Esq. Mrs. Juanita Ellis Joseph Gallo, Esq. Billie Pirner Garde Ellen Ginsberg, Esq. Henca Hicks, Esq. Robert A. Jablon, Esq. Elizabeth B. Johnson, Esq. Dr. Walter II. Jordan Roy P. Lessy, Jr., Esq. Robert D. Martin, Esq. Dr. Kenneth A. McCollom i Mr. James T. McGaughy Nicholas S. Reynolds, Esq. Anthony Z. Roisman, Esq. Mr. Lanny Alan Sinkin Robert A. Wooldridge, Esq. Mr. Robert E. Ballard, Jr. Mr. R. S. Howard Ms. Nancy H. Williams Resident Inspector / Comanche Peak Regional Administrator, Region IV Larry A. Sinkin Ms. Billie Pirner Garde David R. Piggot Nancy E. Weigers M. John W. Beck GDS Asociates ACRS (10) Rev. 02/19/86 t .}}