ML20204H417
| ML20204H417 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/23/1984 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20204G840 | List: |
| References | |
| NUDOCS 8411120287 | |
| Download: ML20204H417 (173) | |
Text
, $: .a 1 ORIGINAL - f I
i 2 UNITED STATES OF AMERICA 3 NUCLEAR REGULATORY COMMISSION I
4 l
5 6 In the Matter of:
7 MEETING WITH TUGCO AND NRC/TRT ,
8 to l 11 12 13 14 15 16 17 18 19 20 Location: [g[/6)/, g[, Pages: 1 - 99 s
21 Date: October 23, 1984 22 23 841112O287 841102 24 PDR ADOCK 05000445 A PDR 25 FREE STATE REPORTING INC.
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2 I UNITED STATES OF AMERICA
. 2 NUCLEAR REGULATORY COMMISSION 3 MEETING WITH TUGCO AND NRC/TRT .
I !
4 1 I
i 5 l i
" Nuclear Regulatory Commission 1717 H Street, N.W.
7 Washington, D. C. .
I 8 October 23, 1984 l
8 The panel met, pursuant to notice.
i 10 il NRC STAFF MEMBERS PRESENT:
i Il R. H. WESSMAN ;
VINCENT S. NOONAN 12 HERB LIVERMORE ,
DAVID C. JENG ,
'3 R. E. PHILLEO ,
LARRY SHAO I R. R. KEIMIG CHARLES HOFMAYER l, 15 JOSE CALVO l 16 PRESENTERS AND STAFF SEATED AT THE TABLE: l i
I7 B. GARD' C. HOOTEN 18 R. CAMP J. BECK l.
I8 J. GEORGE M. McBAY 20 F. DOUGHERTY J. MERRITT 21 J. LANDERS 22 23 24 25 FRff STATE REPORTING INC.
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3 DISCLAIMER
- This is an unofficial transcript of a meeting of the United States Nuclear Regulatory Commission held on '
5 October 23, 1984 in the Commission's office at 1717 H 5treet, N.W., Washington, D. C. The meeting was open to 6 l' public attendance and observation. This transcript has not ,
been reviewed, corrected, or edited, and it may contain i 7 inaccuracies. f.
' 8 The transcript is intended solely for general infor- ,
mational purposes. As provided by 10 CFR 9.103, it is not ;
9 part of the formal or inforni record of decision of the :
matters discussed. Exprest, ions of opinion in this trans-10 cript do not necessarily 1.eflect final determinations or No pleading or other paper may be filed with the 11 l beliefs. Commission in any proceeding as the result of or addressed to any statement or argument contained herein, except as 12 the Commission may authorize.
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1 PROCEEDINGS
! 2 MR. NOONAN: I'll go ahead and we'll start this 3 ll meeting today. It's the... My name is Vince Noonan, ,
,1 4 the Project Director on Comcnche Peak. We're basically 5 continuing the meeting that we had last Friday. We i
6i didn't quite get done. '
.) 7 I would like to ask... Maybe to get start ..
, i 8 this off before we get started we will ask people to go l
9 I around the room and identify themselves so the court 10 reporter can... Go ahead, Dick.
i-11 MR. WESSMAN: Okay, I'm Dick Wessman from the ,
i 12 TRT Staff of the NRC.
i 13 MR. BECK: John Beck, Manager of Licensing, ;
14 TUGCO.
15 MR. GEORGE: I'm Joe George, TUGCO Vice i
16 President and General Manager of Comanche Peak, t
17 MR. SHAO: Larry Shao, Technical Review Team.
18 l MR. KEIMIG: Rick Keimig, Technical Review Team. .
19 MS. GARDE: Billie Garde representing both i 20 GAP and CASE. l 21 MR. LIVERMORE: Herb Livermore, QATC.
22 MS. COSELL: Adele Cosell.
23 MR. JENG: David Jeng.
24 MR. HOOTEN: Randy Hooten, Structural League, 25 TUGCO.
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'! 1 MR. FOYO: Bob Foyo, TRT. l 4
2 MR. CAMP: Dick Camp. l l
3 MR. McBAY: Mike McBay, TUGCO.
i 4 MR. DOUGHERTY: Frank Doughterty. i
'i i 5 j MR. MERRITT: John Merritt TUGCO. i i
6 MR. HOFMAYER: Charlie Hofmayer, TRT.
is j 7 MR. LANDERS: Jim Landers, The Dal:.as Morning .
8 News.
9 MR. NOONAN: We have the meeting basically i
10 l, set up this morning. Mr. Eisenhut is not here yet. I
!i il' 11 think I'll go ahead and start without him. He'll probably I i
12 come in a little bit later.
13 We'd like to start out with basically Larry 14 Shao having the section on the (inaudible) engineering 15 part, and we'll start with that part of it first in his 16 area.
17 I guess I don't have any real specific 18 comments other than those were made the other morning, .
19 the other day I mean at the meeting we had in downstairs l
20 here.
}
21 I would like to say for the record right now -
22 the time that we are planning to come down to Texas.
23 We'll be down there on, probably come down Wednesday .
24 evening, Dick Wessman and myself and a few other Staff l
25 people-l FREE STATI REPORTING INC.
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1 We are planning to me:et with the region on, on i .
2 Thursday morning and we will be out at the site on Friday 3 morning. ;
4 MR. GEORGE: This Friday or...
l l 5 MR. NOONAN: Yeah, we'll be out at the site 6 ! this Friday. I guess maybe this is basically a meeting !
> 7 to talk about the program. Why don't you go ahead and ,,
8 start off, Mr. George?
9 MR. GEORGE: Okay. We're prepared to present !
10 our action plan in the civil structural area, as well as 11 the start-up area. We're prepared to move right into ;
12 that with the team leaders, Mike McBay. ,
i 13 MR. NOONAN: Okay, why don't we go ahead and j l
14 start out. Maybe when we start this thing out, the i
15 people better, making their presentation, give us some l t
16 background, particularly for my benefit, so we know what i 17 they have done previous within this Comanche Peak i 18 organization.
19 MR. MERRITT: Can you all see that in the back j l
20 of the room?
21 MR. NOONAN : Are we effectively looking at 22 the same handouts we had on Friday?
23 MR. MERRITT : Yes, this is included in the 24 handout you had Friday.
25 MR. GEORGE: We will be speaking to the same FREE STATI REPORTING INC.
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1 handouts but we really propose to deal with the action ,
2 plan specifically.
l 3 MR. NOONAN: There are no new handouts for !
l A
4i anything (inaudible) this morning?
f i 5! MR. GEORGE: No. !
6 MR. HOOTEN: Okay, my name's Randy Hooten.
7 I'm a structural (inaudible) with TUGCO. First item... ,
1 8 MR. BECK: Randy, if you'd go into your 9 background on the project for Mr. Noonan's benefit, it to lj would be helpful.
1 11 MR. HOOTEN: Okay. Is this better. I have 12 been on the project approximately 94 years. I have a j l
13 B.S. C,E. I have been involved with the civil structural l 14 area of construc' tion engineering at the site with TUGCO.
15 First item...
16 UNIDENTIFIED SPEAKER: Excuse me. What is 17 the role now that you're involved in?
18 MR. HOOTEN: Right now I'm the discipline lead .
19 for Civil Engineering Department at the site for First item, II,A i 20 Comanche Peak Project Engineering. i 21 concerning the omission of rebars in the reactor cavity .
22 wall in Unit 1 containment building.
23 TUC, Texac Utilities Action Plan will include 24 an as-built analysis of the reactor cavity wall. This j 25 analysis will be performed to determine whether the FREE STATI REPORTIN3 INC.
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1 structural, integrity of the wall is compromised. Gibbs
'- e 2
l and Hill is going to perform the analysis and the design 3 .
review.
i 4
An external organization, IBASCO (ph) to be 5 li specific, will perform additional design review of 6 !
these calculations. As an expanded review of this issue, I we will review all omissions of rebar that took place at .
4 t 8
Comanche Peak to verify that we have appropriate i 9
engineerin'., evaluations and documentations on these items.
- , MR. SHAO
- That part is new.
Il MR. EdCTEN: Well, it's not... We have indi- f I
12 cated in this third bullet here that an external l' i
'3 organization will do a design review. We had that in
'# We nave named a party on that- j the -action plan.
'6 MR. JENG: Comment. My name is David Jeng.
16 It's impossible to (inaudible) independent review if
'7 there is anything to do with the possible construction 18 or design. (inaudible) ,
I
'8 I don't...
MR. HOOTEN: No.
20 MR. JENG: Randy, (inaudible) 21 MR. HOOTEN: Can you elaborate on that a l
i
[
22 second? Maybe I misunderstood you.
23 MR. JENG: Yeah. Third item...
\
24 MR. HOOTEN: Right. l l
25 MR. JENG: ... you are (inaudible) IBASCO l
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1 people to perform an additional design review. My question l
'I 2 to you is are these people to be involved in such a I
3 review (inaudible) involved in the Comanche Peak !
i I
I 4 activities of (inaudible)?
5! MR. SHAO: (inaudible) before it (inaudible) 6 MR. HOOTEN: Okay. Well, in the, in the civil
.)
I! 7 structural area, yes, they would be new. We have an
's 8 IBASCO involvement in other...
9 MR. MERRITT: We have used IBASCO from a 10 l consulting sense in some mechanical issues, but they have ii never been involved with us from a civil structural 12 standpoint at Comanche Peak.
13 But even in mechanical, they have been strictly 14 in a consulting role.
l MR. GEORGE: Gibbs and Hill has had total scope 15 16 in the design of Comanche Peak so that would be 17 independent.
MR. NOONAN: Did IBASCO work through Gibbs and 18 i
19 Hill all the time or do you put directly to utility?
MR. GEORGE: Directly to the utility.
20 I
21 MR. SHAO: Is that IBASCO in New York?
MR. GEORGE: Yes, IBASCO in New York , Dr. Ictti's 22 23 group in particular is the advanced engineering group i
24 there.
25 MR. SHAO: I saw his name in some of the FREE STATE REPORTING INC.
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electrical work. He was...
2 MR. GEORGE: We're going to be using IBASCO
(
3 in quite a bit of independent reviews as far as expertise :
4 is concerned. We think they have as good a credibility f 5'
as we can find. 3 i
6 MR. HOOTEN: Move on to the second item, which
.i j is action item II,B concerning the concrete compressive .
8 To strengths and the alleged falsification thereof.
8 follow up, as recommended by the TRT, we will perform I
10 Schmidt Hammer-Rebound Hammer tests on concrete placed I
at Comanche Peak during the time frame in question.
l 12 A review of our records indicates there were .
I
'3 327 safety related concrete placements in this time frame. !
l
'd We will perform 50 tests. Also, we will include 50 i 15 tests that were o,utside this time frame and we will
'8 compare the test results of these two data sets.
37 There's a letter by CASE that has !
MR. SHAO:
'8 been concerned about Schmidt Hammer Test. Can you ,
l
'8 discuss their concern and your response?
20 MR. HOOTEN: Well, we are handling that question 21 as a separate issue, but the complete concrete issues, 22 as dealing with ASLB, vill be enveloped into this test.
23 We didn't plan to specifically discuss it in this 24 response, although that will be covered in other arenas 25 with essentially the same information.
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I MR. HOFMAYER: The concrete that you're testing, l 2 I understand you have two design strengths of concrete, i i
I 3 4,000 and 2500 psi. Will you be addressing both of these l l l'
d in this study and do you intend to hopefully separate 1
5l these data sets? !
l 6 MR. HOOTEN: Yes, they would definitely have to 1
1 7 be separated from the standpoint you can't compare one to .
8 another there because you do have a different design I
9 strength and would receive different test results when 10 i you performed the Rebound Hammer Test.
1 i 11 MR. HOFMAYER: Do you :tnow approximately out l
i 12 of these 327 placements the split between 4,000 and 2500? j 13 MR. HOOTEN: No, I don't have that number 14 available with me right now. j 15 MR. HOFMAYER: But you have built that into 16 your program to separate them totally?
17 MR. HOOTEN: Yeah.
l 18 MR. PHILLEO: Well, I assume that the 50 i 19 which came out of the military standard was selected on l 20 the assumption that all 327 were similar. If there are 21 in fact, I'm Bob Philleo, by the way. j i
22 If there are in fact two different strengths l 23 involved, you'd probably have to select two numbers based 24 on the, on the two populations (inaudible) 25 MR. HOOTEN: We can review that and take that FREE STATI REPORTING INC.
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j into account in our action plan revision.
2 MR. SHAO: You imply you will (inaudible) 3 the rebound numbers of the hammer test into (inaudible) j calibration curve. Do you intend to do that?
5 Well, in comparison, when you run MR. HOOTEN: !
6 l a Rebound Hammer Test, you just have an arbitrary number i
- t 7 The testing apparatus has, based on test apparatus. .
. i.
8 will be calibrated to the, to a calibration block that's I 9 furnished with the apparatus by the manufacturer. i t
10 From the calibration block you can, or they i
i .
" furnish a graph that relates the arbitrary numbers ;
i 12 received of f the apparatus to an equivalent co.7e: rete ;
I 13 '
compressive strength.
14 MR. SHAO: I think we have some concerns in 15 this area. I don't think we should use Schmidt Hammer 16 Test to find out the extra strength, but use it only for i
17 comparative purpose.
l 18 8 MR. HOOTEN: Well, that is true. It will not l
19 give you the actual strength of the concrete, no, but it 20 will give you a basis for comparison.
Yeah, but somehow the action plan 21 MR. SHAO:
22 implies you can use it for getting the actual strength 23 of the concrete. (inaudible) use the calibration curve 24 established by the manuf acturer and then do a conversion.
I' 25 .MR. HOOTEN: Well, that... The intent of the FREE STATE REPORTING INC.
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' action plan was to use it for a comparison only.
i 2
MR. SHAO: Only for comparative purposes? ,
1 3 MR. HOOTEN: Right. ;
., MR. HODSYER: Will converting to the calibration lI In other words, 5li curve in any way distort the raw data?
I 6 '
you could compare the uniform strength of the concrete, 3
j 7 okay, on a statistical basis with the raw data as opposed ,
8 to converting it to an absolute number of what you believe 9 to be the compressive strength in comparing that, io : Ig it.s only one multiplier throughout, the 11 data set that you used would not matter, bat do you...
12 .You know, by adding the extra step of converting it to 13 an absolute strength, okay, which could have some .uncer- j.
i 14 tainty in it in that the calibration curve that you're l l
15 using, you know, is not for the specific concrete that !
I 16 you have at the site, are you introducing an extra uncer- l 1
I 17 tainty that's not necessary?
l 18 MR. HOOTEN: Well, no, the calibration curve ,
l 19 is the standard curve and I don't fee 1 like we're j l i 20 introducing any other variables into the test by using (
21 that curve.
l 22 MR. MERRITT: But, Randy, will we not be able j i
23 to have some degree of comparison with concrete test l 24 cylinders? Now, there's concrete test cyclinders poured 25 or placed four or five years ago. We'll be a little bit l l
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l off in age, but at least we'll be able to validate that 2
against concrete (inaudible) and make many tasks from 3
there... i 4
l MR. SHAO: Maybe... I would like to have Bob 5
Philleo talk to that. He also is the co-author of the ,
I 6 !
handbook that CASE letter quotes. Maybe let Bob Philleo 3
l 4 7 say something about the test. l.
8 l.
2 MR. PHILLEO: Well, no, I think as long as 9
you're going to make a statistical comparison, you might i 10 as well use the raw data. You're just making more work l
" for yourself if you convert every number to a strength :
I 12 value and you won't have gained anything and will have, 13 be using some questionable values.
The data themselves are all you need, so I -;
15 think it's by far more defensible and also easier just 16 to take the raw data and compare Rebound numbers of the '
l
'7 concrete in question with the Rebound numbers of the 18 concrete that's not in question. ,
l 19 And you get just as good a statistical 20 comparison that way. You have a more defensible 21 procedure and you've done less work.
22 MR. HOOTEN: We can take that into consideration.
23 MR. SHAO: Also, if we didn't compare it 24 (inaudible) with concrete about the same age. You don't 25 want to compare concrete with (inaudible) cne age with PRH STATI REPORTING INC.
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another age.
MR. HOOTEN: Correct, right.
3:!
MR. HOFMAYER: So then do I take it that the 4 i 50 placements that we're using outside the time frame l 5 i we've given you will be as close to that time frame as :
l 6
possible? Is that your intent?
7 MR. HOOTEN: Yes.
8 MR. SRAO: Okay, we have some concerns about -
I 9I your procedure (inaudible) j, l
10 Well, I notice in your program MR. WESSMAN: .
" plan of October 8th that you said you were going to ,
12 submit a program to us prior to starting the tests.
'3 Have you seen anything other than the program plan about t
your actual Schmidt Hammer procedures?
15 MR. HOOTEN: No. The Schmidt Hammer procedure 16 is basically as it's described in ASTM. There's no
'7 deviation f rom that.
18 MR. PHILLEO: But I think they would like to see a little more detail. For instance, you'll give ,
20 them the number of blocks to be tested. You have not 21 told how many tests will be run on each one. That's 22 a rather important factor so we know how many degrees i
23 of (inaudible) we're working with. So we'd like to have l 24 that sort.of detail. l 25 MR. HOFMAYER: Dick, there was a little bit of i
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i confusion on our part the last week or two. To make 2 contact, we were attempting to establish some communication 3 there. So now that we're on course, I'm sure this follow 4 up either the end of this week, you all's visit down ;
5d there, or else then at the site next week. We're ready i
6 to sit and discuss the details as requested in the TRT 7 report.
? 8 MR. JENG: Our main course of action (inaudible) l 9 do you propose to compute one mean number for the whole 10 50 (inaudible) and we are concerned that maybe the right 11 way or more proper way is to compute a mean number for 12 each (inaudible) so it would be 50 mean numbers (inaudible) ,
i 13 The detail of that would be, like Larry l 14 mentioned to you (inaudible) ,
15 MR. MERRITT: The data, in whatever form you 16 want, is there for full review and however we wish, you 17 all would like to see it we'll be prepared to submit it 18 in whatever format there. ,
19 That'll be part of the permanent record files 20 that'll be there with us and we'll be happy to share that 21 any way you wish.
22 MR. SHAO: The question is how to evaluate the 23 data.
24 MR. MERRITT: Yes, sir.
25 MR. SHAO: How to...
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' Well, there's a more immediate MR. PHILLEO:
2 The method of comparing the data later will question.
3 determine how many tests to run now, so this will have to i be decided in advance. ;
5 ! Yeah, I think that's an important MR. HOFMAYER: ;
I 6' distinction that, you know, how many tests do you run on
~
7 each individual placement to develop enough statistics l .
8 about that particular placement.
8 So your plan, the way I interpret it, will l
10 prepare, will basically get a mean for all 50 of each I
\
11 and compare it, and in no way, it doesn't tell you any- l i
12 thing about the individual placements which we're 13 questioning.
l#
MR. JENG: Do you know (inaudible) how many 15 tests you will perform on each placement (inaudible) 16 MR. HOOTEN: Well, there's a recommended number 17 of tests in ASTM for each placement, and that's what i 18 we will be following.
19 MR. PHILLEO: Well, that recommendation is 20 10 shots to get a single number. Our question is how 21 many groups of 10 shots do you plan? f l
22 MR. HOOTEN: For each placement? l 23 MR. PHILLEO: Yeah.
24 MR. HOOTEN: Okay, we can discuss those detal'.s, 25 you know, when we present the test plan, you know, when FREE STATI REPORTING INC.
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17 1 we review it.
2 MR. SHAO: Are you going to have any consultants 3 in this area or are you going to handle it by yourself?
i l
4 ! MR. MERRITT: From the standpoint of handling i
5 overall statistics, not only this but across the board, 6
we will be having a consultant helping us in the statistical
- 7 area of how to put this thing together from a statistics
-5 ,
8 standpoint.
l i
g i MR. SHAO: Not in the concrete area? Not in l 10 the con...
11 MR. MERRITT: We hadn't planned on it.
I 12 MR. JENG: One question. This converting you ;
I 13 were talking about, would he be the guy who earlier 34 involved in a similar test which I understand you people
. 15 performed some time ago. But you'll be talking different 16 person.. l l
MR. HOOTEN: No, these are different personnel l 37 18 MR. NOONAN: I think in this area of statistics ;
19 I'd like to make a general comment we made earlier. I still don't see the basis for the statistical sample.
20 21 S meplace in here you've got to have a criteria and tell us what that is, what's the basis for it, what is 22 l
23 going to be the confidence level you're looking for.
24 And again, I would like to emphasize the 25 independence of the people that are going to do this.
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1 They shouldn't really be people that have been doing ;
2 this for you in the past. It should be somebody that 3 you bring in from the, from the company that is, has l i
4 independence and can demonstrate that.
I
- i 5l MR. HOOTEN
- Shall we move on to the next item? ;
l
..j 6' It's Item II,C concerning the seismic air gap and 7 Separation between the Category I structures. Our action ,
8 plan will be to perform, reperform and document a QC l 9 inspection of the gap between Category I structures and 10 between Category I and non-Category I structures.
11 Any debris that may be encountered will be i
12 removed after documentation. We will perform the i l
13 engineering evaluation to determine the effects on any l
14 seismic or dynamic responses of the structures, and if j 15 appropriate, further engineering action will be deter-10 mined to evaluate the impact on components and piping. l 17 A review of the procedures for the establish- 1 18 ment of requirements for maintenance air gap will be !
19 performed to assure that no trash or debris get;s in the 20 !ap from this date forward.
21 And we will evaluate the need for any FSAR ,
22 updates based on our as-built conditions. Also, we will 23 furnish analyses, as requested by the plan, for any 24 permanently installed elastic joint filler that's 1 25 currently indicated on the drawings.
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- MR. SHAO
- Who are going to do all these
'l i 2 (inaudible)?
MR. HOOTEN: This will be done by Gibbs and i
4 Hill.
5 l MR. SHAO: And they did original?
6 Yes, they did the original analysis. !
MR. HOOTEN:
I
.t MR. SHAO: They don't know independent of .
7 8
- (inaudible) ?
MR. HOOTEN: We hadn't planned that at this 10 .
time, no.
MR. HOFMAYER: Or, as in the case of the reactor 12 cavity, you had a design review at least being done by ,
13 IBASCO. You don't plan to do such a design review for :
'd (inaudible) ?
15 MR. HOOTEN: No, we hadn't.
16 MR. JENG: Let me call your attention to a i
'7 l earlier statement on page 10 in your proposal. You
'8 indicate that the desirability of obtaining a standard ,
(
perspective is one of your program planning objectives.
20 rid like to know how (inaudible) in the 21 context of this Item II,C, and particularly you are 22 talking still (inaudible) of Gibbs and Hill (inaudible) 23 analysis. Who did the similar analysis before? We are I
24 a bit concerned.
25 MR. MERRITT : Okay. We hear what you're saying.
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20 1 We need to get together and we'll take a look at that. l 2 We hear what your point is.
i 3 MR. NOONAN: I think, I think for a general 4 comment, everything I heard the other day and I'm hearing I
5' again today and talking to the Staff, it's the same 6 concern we had.
7 You're not demonstrating to us that.you're ,
8 putting people in here to do this kind of work that 9 really can show independence from not having done it l
10 ' before. I really think you ought to go back and re -
11 evaluate your position on that. ,
MR. MERRITT: Of course, the main thing we were 12 {
l 13 interested in was to try to validate the gap as being l 14 open and adequate, that there wasn't construction to i 15 bring in the gap, and that's where we started the basis 16 from and that's what we were addressing the program 17 around, so...
18 MR. NOONAN: The program plan is a set up to, 19 you know, address all the concerns. You can't have 20 people addressing concerns that have already, were ,
21 maybe part of the concern in the originals. f .
I.
22 MR. MERRITT: Yes.
I 23 MR. WESSMAN: You all may be aware we've looked 24 at another issue relating to the gap between the reactor 25 pressure vessel insulation and I think the surrounding FREE STATI REPORTING INC.
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21 cavity. And again, the issue of possible debris occurred 2
in this one. '
3I Now, this to me means possible generic aspects
{ l 4 'I and it means that whatever evaluation and look that you h l 5l do concerning debris in tight spaces has to be looked at i
l i
6 from a wider standpoint than perhaps what you've just 7
- looked at here under Item II,C.
i 8 l You might give that some thought as you go ;
I 9 i forward with this particular action plan. ;
10 ,
! MR. MERRITT: All right, sir.
4 11 -
MR. HOFMAYER: Randy, another question. j 12 Your first item talked about you'll be inspecting the j 13 l' air gap between Category I structures and Category I
~
14
' and non-Category I. I assume that covers all Category I i
i 15 structures? - l 16 MR. HOOTEN: Yes, they would... :
17 MR. HOFMAYER: You're not taking a sampling j
18 basis? You'll be looking... j 19 MR. HOOTEN: No, it will be 100% .
20 MR. JENG: And a comment to give you a proposal.
21 You indicated af ter having done the analysis, you're 22 going to evaluate interaction effect between structures, 23 and our concern is the (inaudib,le) should not stop at l
24 the interaction effect in the structures.
25 It should encompass the change in the structure FREE STATE REPORTING INC.
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1 response, looks and the frequency and (inaudible) into .
2 the system's component equipment, a profile so the i'
3 comments (inaudible) you should look into the overall 4
- impact, not limited only to the reaction (iriaudible) i 5' '
structures.
i 6
MR. HOOTEN: Yes, it's a step-by-step approach.
7 First, we're going to review the structural aspects, .
8 and then, if necessary, we're going to go into, you 9
know, based on what our findings are go into other areas.
l ,
10! MR. JENG: In the connected comments we see
" quita a few occasions that so-called best ef fort judgment 12 criteria and so on, and we would like to see if we can ,
I 13 (inaudible) more. What do you really maan by best effort. l 15 And when you mention something that's more 16 conservative, then we'd like to know what the basis of 17 such a statement for review of the proposal. We stress 18 articulate response, make it more clear and, well, easy f i
18 to understand. !
20 MR. HOOTEN: Okay.
21 MR. SHAO: I too want to mention the great j i
22 difficulties concerned in this area because the responses (
23 have a frequency. It may be conservative at one frequency l l
24 and may not be conservative at another frequency. The j i
25 best way to make sure they have air gap (inaudible) that FR2E STATE REPORTING INC.
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- 1 don't have an air gap great difficulty (inaudible)
MR. LIVERMORE: I have one more question. Herb 3
Livermore, QAQC. You said you were going to do a re-l 4 !
inspection of all Category I structures. Are you talking 5 lll Unit l?
i MR. HOOTEN: No, we're talking Hope Lamp (inaudible). .
8 MR. LIVERMORE: Okay, the second question. !
I I didn't hear anything about doing an investigation into
' Why did management the management aspects of this.
I
" allow this to happen? Why was this breakdown? Why was 12 QC not inspected in the first place?
-' MR. HOOTEN: We are. covering tha.t as we get i
~
f into the plan. We have already looked at the future' i 15 concrete placement that took place after the rotofone (ph) 16 useage was stopped in late 19 77 and subsequently cleaned !
'7 out all the debris that could possibly be taken out.
18 And from that date forward, we changed our ,
forming techniques, and we do have valid documented QC 20 inspection based on the air gap for a free concrete 21 placement inspection.
22 MR. LIVERMORE: From '77 on then OC did 23 inspect it?
24 MR. HOOTEN: Yes, they did inspect them prior to concrete placements. The documentation that is not FREE STATE REPORTING INC.
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I l . 24
! I available is the maintenance of the air gap after the 2
concrete placements. So we're essentially talking about 3
' trash, wooden chips, debris, you know, anything that may !
, have been discarded into the gap. ;
MR. HOFMAYER: Randy, we've .scussed this ,
- 6 before. You know, I asked you a number of questions about 7 -
this in this review, and I really think it's important to ,
8 understand fully the perspective of who did what when, 9 '
okay.
'O When you were using rotofone, when you stopped 11 using rotofone, when you switched to steel forms, why 1
12 you feel that from that point on then an inspection was ,
I
'3 no longer needed, the inspections that were conducted, i 14 how they were fully resolved. g 15 I think you need a perspective here to fully l l
16 characterize the answer, particularly the question Herb l 17 raised on terms of, you know, what were your procedures 18 and why were they valid.
19 MR. HOOTEN: We will include all those items 20 in the final report.
( f 21 MR. BECK: I think it might be appropriate l I
22 here, Vince, to indicate we frequently in our discussions 23 so far have talked about root causes, and from our stand-24 point, in preparing our program plan and the action plan, 25 certainly that's paramount in our mind.
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We want to get to the bottom line root cause 2
of any generic consideration that may be involved across 3
the board or on issue-specific actions. What we have not done is to do that evaluation since we're really just at ;
5 the beginning of formulating our response to you.
6 So if the program plan or the action plans are 7 silent on the issue of root causes, it's not because it .
') ,
8 isn't paramount in our mind; it's just because we haven't t
8 l gone through that evolution yet.
t to - But certainly, that is a very key critical ,
" issue, and one that we have constantly in mind, although !
l 12 we may not have anything in print on that, in that regard ;
13 at this point.in time. I I
I# But I want to assure everyone that that's, l 15 that's a critical matter and one that we're paying very 16 close attention to throughout the whole effort.
17 MR. NOONAN: I think that's, I think tnat's 18 necessary, and I do agree that sometimes it's hard to
'8 put it into a program plan, but, like Larry's indicated, 20 we are going to make formal response back to you on 21 this whole plan.
22 MR. BECK: Yes.
I 23 MR. NOON AN : We are going to talk about what 24 I call the lack of independence being shown in this, in i 25 this procedure here right now and we are going to be FREE STATE REPORTING INC.
Ceeert Reporting e Depositions D.C. Aree 141-1902 e Belt.& Annep. 1694236
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26 i talking about determining root causes (inaudible).
2 MR. BECK: And I can certainly state today that the question of independence or a third-party verification, ratification, whatever, the point .was very well taken last 5
week. ,
- 6 We've spent considerable time since our meeting 7
Friday internally discussing that question. We're looking .
8 forward to getting your written comments, but even before 8 then, we 've done considerable deliberation and we ' re
'O l going to be modifying our plan to be responsive to that
" concern when we come back with Rev. 1, I guess it would 12 be called, and I think you'll find that it's going to be l
'3 a comprehensive response.
I# MR. HOOrEN: Item II,E concerns the possible 15 cutting of reinforcement steel in the fuel handling 16 building. The Texax Utilities Action Plan will include
'7 performing of design calculation to determine the
'8 structural adequacy of the slab even if a Number 18 rebar I i
in the first layer and the third layer were cut.
20 We will also, as an expanded review, take a 21 look at our programs controlling rebar cutting to deter- j 22 mine any changes that may be required in that area to 23 assure that we have an adequate program.
24 MR. GEORGE: We have no comment on this.
Okay, I'd like to... The two 25 MR. HOOTEN:
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1 other structural issues will be covered by Mike McBay.
2 I'll turn it over to him at this time.
3 MR. McBAY: I'm Mike McBay. I have been on the ,
i 4 ! project approximately 10 years. I presently, the last I
5 three.. months, have been the Reactor Building Construction
, i 6 Manager for Unit 2.
?,
j
^
7 Prior to that I was Engineering Manager for ,
i
-! 8 Comanche Peak, engineering for four years and procurement 9 manager prior to that, and then civil (inaudible) prior l 10 to that. ;
11 I hold a B.S. Degree in civil engineering and 12 I'm a registered professional engineer in Texas. Pretty l
13 much my background. Two issues that I'm going to be I
14 addressing.is Items I,C and II,D. -
+ !
~ '
. 15 Both issues address the proper design con-16 siderations, assurance that proper design consideration j 17 was given to nonseismic installations in Category 1 18 structures and their potential impact on safety related 19 systems if the integrity of the nonseismic systems failed. i l
20 on Item I,C is the first one. You all have it !
21 in your handout. Item I,C, the first one, deals with 22 nonsafety related conduit supports. During the TRT visit :
1 23 to the site in selected areas they observed that there l i
24 were some nonseismic supports on nonsafety related 25 conduits.
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And the, this is fo'r conduits greater than two 2 , inches. Now, at Comanche Peak we have nonsafety related l
3 conduits greater than two inches, nonseismically supported ,
i l 4 i in selected areas.
5 In resolving another problem at the project, f
6 basic congestion in some of these highly congested areas 7 and resolving this congestion for maintenance concerns, ,
8 we did select nonseismically supported non-safety-related 9 conduit in select areas.
!\
to ! The areas selected for areas where safety-related I
11 systems were not predominant, for example, all the conduit, 12 non-safety-related conduit in the reactor building and l l
13 the safeguard building is seismically supported or restrained.
14 In the Aux building, the fuel building and ,
15 ENC building there are rooms in there that we did not 16 a seismic support conduit, and in that case we evaluated 17 each conduit in regard to its ability if it failed to 18f impact a safety-related system.
19 This evaluation was done by our Damage Study 20 Group and it was done through a walk-down of each 21 individual conduit in these areas. We identified each 22 conduit that would be a source, source being an item that 23 could fall onto a Class 1, 2 or 3 system, and also we 24 identified each party in the room.
25 During the walk-down we identified the FREE STATI REPORTING INC.
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interactions that could result f rom SSE, and of, on a 2 case-by-case basis we resolved each interaction. In this l
3 program we found there was 500 non-safety-related conduits il 4
that had to be considered.
P .
5 Two hundred and fifty of them had interactions,
{
i 6 so we resolved each one. The typical means of Tesolving, 1 7 the majority was resolved by adding seismic restraint ,,
I .
8 tables. l i
9 The second means of resolving them was adding 10 ' seismic supports, and the third means is we moved the 11 conduit to a location where it could not be in danger i
12 of a safety-related target.
I 13 What we propose to do and provide is we want 14 to provide a summary documents which delineates the . i 15 philosophy and implementation of our Damage Study 16 evaluation for non-safety-related conduits.
17 This evaluation will give you all the criteria 18 we used, the methods of disposition and basically l
19 summarize this study that has been going on for the i 20 last two years.
21 This program was initially... The walk-downs 22 were initially done in 1983 and then per set of instructions 23 per QA program, this program was continued through a 24 maintenance program which we have defined by issuing 25 instructions to the present date.
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' We feel like as far as interactions with non-2 safety-related conduit greater than two inches, this program I
3 has covered it well, and we need to get that information !
i l to you. '
5 I'd like to ask a question, MR. JENG: j 6 MR. McBAY: Yes?
7 MR. JENG: This program you mentioned, has .
8 any evaluation of, by TUGCO or Gibbs and Hill, had a 9 chance to fully evaluate this (inaudible)?
10 MR. McBAY: We've had some review, Dave.
I I 11 MR. JENG: For whom? l 12 MR. McBAY: EBASCO looked at it a couple years 13 back, '83 time frame.
I# MR. JENG: EBASCO is the (inaudible) 15 MR. McBAY: More of a consultant, Dave. As 16 far as a formal independent review, we haven't had that, 17 other than our QA audits and so forth. ,
I think I mentioned it a couple weeks !
18 MR. SHAO: I i
19 ago. I don't think we have a problem with your criteria 20 and (inaudible). They're very good. (inaudible) so how fI
' ~
21 do we know the prominent control is not happening t 22 somewhere else?
23 MR. McBAY: Well, as you're aware, Larry, both 24 these issues fit together. Let me go on through, then 25 7 11 come back to that if I can. The second issue we FREE STATE REPORTING INC.
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' 1 have is the observation that our two-inch conduit was not 2 The design seismically supported. This is true.
3 philosophy for the plant was that it was not required to seismically support or put the two-inch and under conduit l
5l into our seismic support program for a few reasons. ,
I j 6 One is we're at low mast. The interface 7 criteria or interaction criteria we use with intervening .
i 8 members, larger or smaller, the situation we get into i 8 where the small issues could be an impact to safety-i
'8 related system is very small.
i 11 Secondly, the way we've had to do our typicals ]
12 in providing design for these small conduits, small
'3 conduits go in basically last. They give to any other
'd larger member.
15 In other words, the small conduits snake their 16 way through and to their destination. Being smaller, i
'7 they have to get through a large pipe, large conduit, 18 whatever. ,
18 The pressure we give the instructor requires 20 that our typical support design had to be installed at 21 certain locations in regard to bends, junction boxes.
22 I guess that's the main two, bends and junction boxes.
23 With that criteria and the way these small 24 conduits ran, we're now finding that our conduits, small 25 conduits gradually expand every six feet and the. . .
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' We revisited this question back in the summer of '83 and i 2
we did a seismic analysis to view with using our design i
3 I of what was acceptable as planned criteria. ;
I l 4
- The span criteria memory that we have is 14 ,
i 5i feet, so with the small mask, the Damage Study interaction 6 with the typical design we used, with the minimum span 7 we're using, minimum weight we're using, the two-inch and .
3 . under conduit was not put into our seismic support program.
9 Now, what we have proposed to do is we're going to to provide a seismic analysis which verifies the stability '
I !
M during an SSC of the two-inch and under diameter conduit ;
12 with the present support system.
I 13 We~ feel confident our present support system, !
- i l
3 14 disregarding conduit falling and doing no harm because j 15 of (inaudible) and so forth. We think our present support 16 system will verify that the seismic, the conduit will l'
17 not come down, but we will have to do this. . . We'll l
'8 have to do a field verification on a sampling program l
19 and we feel like that our sample size will be around 315 i l .
I 20 conduit runs.
21 we re looking somewhere in the range of 15,000 e
22 conduit runs, somewhere in there. Feel like doing a 23 sampling program of the 315, 315 conduit runs, we'll 24 analyze those, assure that we do not have a structural 25 concern, and close this issue on that conclusion.
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! 1 This evaluation will be done by Engineering.
2 MR. SHAO: Who are going to do the inspection?
3 (inaudible) group or the same group as before? ,
I i 4 MR. McBAY: We have planned the evaluation be l !
5 done by Engineering. We are mobilizing, plan to mobilize l.
6 some of our structural engineers that handle conduit all j 7 the time and have them do the, do the evaluation. ,
8 MR. SHAO: Are they the same group or the new j 9 group looking at it? l 10 MR. McBAY: Well, the same group. Larry D.
11 The people that actually go out and take the measurements i
12 will be the field engineers at the site, the same group.
i 13 MR. SHAO: My point is some people have done it j i
14 before, even though some people.may overlook it again.
l
~
We'll have a new group (inaudible). l 15 16 MR. McBAY: Well, Larry, you know, we could l 17 use almost anybody to take those type measurements if !
18 they were engineering savvy because you need to know what 19 you're looking at on that, with this type of system.
20 The consideration, though, gathering the 21 information... The largest problem we're having is 22 representative sample. .
23 MR. SHAO: Yes. And who will make the evaluation 24 of it?
25 MR. McBAY : Once we determine the representative FREE STATE REPORTING INC.
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3 sample, we want it to be realistic. Do you go for the 2
most congested rooms or (inaudible) ?
l 3
MR. SHAO: You didn't answer my question. Who is going to do the evaluation after you make the sample?
5 MR. McBAY: Okay, after we make the sample, 6 the details, we determine the sample, the details are 7 It will be turned over to taken by the field engineers. .
8 Gibbs and Hill to do the evaluation. ,
MR. SHAO: (inaudible) 9lP 10 Yes, that's right.
MR. McBAY:
Il MR. SHAO: (inaudible) very difficult for two j 12 people looking at their own work. They like (inaudible) 13 everything's okay. i f
1# MR. McBAY: Well, we can go the independent ,
15 route, I assume, but I guess the way I was looking at 16 this thing is we're not in this particular case ques-17 tioning a design bust. We're not questioning validity l 18 I of design.
19 We're just reconfirming this design. We're 20 just proving or showing that the system we have up is 21 seismically supported. The evaluation could be done by 22 any, any competent structural group in this country, I 23 guess.
24 MR. NOONAN: Well, why couldn't that be done 25 better by an independent group compared to people that FREE STATE REPORTING INC.
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are already there? Why wouldn't it be a better job?
2 Let me respond to that. Joe George MR. GEORGE:
3 here. John Beck said subsequent to last Friday certainly ,
l TUGCO's taken into account all that was said at the last i' l 5
j Friday meeting dealing with independence. ;
6 And certainly, we're not going to do any 7 activities that does not satisfy NRR. Now, if you're .
8 saying an independent, obviously we're not going to go 9 counter to that if that's what it's going to take to '
i '
10l satisfy you.
11 SO I understood you that you were going to ,
l 12 respond to our draft 1 in writing, the subsequent drafts 13 to just corrective action, to TRT. It's certainly got to
'd satisfy you people, obviously. l 15 we re not going to go out on our own and redo e
16 the same thing again if it's not acceptable. And that's l'
17 to do with the people doing the work, this guy standing 18 up there, or this one over here, any of them.
18 And that seems to be the problem, and certainly 20 we're going to be dealing with that. We're taking this 21 thing very, very, very seriously and intend to put a plan 22 together to satisfy you. j 23 MR. McBAY: So the analysis can be done 24 (inaudible).
25 MR. GEORGE: In any of these subsequent FREE STATI REPORTING INC.
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' speakers, I can save you some time if that's your question 2 Just give it to us and the revisions on independence.
3l that will be dealt with.
- ! MR. BECK: I might add here that it was not in 5' any way our concept that, that the results of investigations 6 or inspections or whatever that were part of these various 7 issues, specific action plans, would be impugned at all ,
8 by the fact that the people most knowledgeable about the 8 i systems themselves were actually doing the work.
l 10l The results of these programs will be maintained i
" in an auditable form, subject in some instances to CA l ,
12 verification, subject, as always, to witnessing or 33 questioning during the process or afterward by NRC Staff.
'd It was simply what we viewed to be the most j 15 expeditious way to achieve closure on the issues, namely 16 to have people involved who are knowledgeable about, in 17 some instances, fairly complicated aspects of the design 18 and construction of the facility. !
I l
19 It's clear that we may need to go further on 20 that issue and we're certainly not...
21 MR. GEORGE: One other words on damage study.
22 We feel that Comanche Peak has done damage studies second 23 to none in the industry. We have had this reviewed with i 24 EBASCO as a second look-see, and if I'm not mistaken, we 25 had Bechtel look at our ... ;
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37 i 1 MR. McBAY: We had a discussion with Bechtel, 2
Joe, but they...
3 MR. GEORGE: We had a discussion, but they didn't go into depth on it, so we were very serious about the l'
5l program and we think it's a good program and we think we 6 can show you gentleman'it's adequate, and we will do the 7
same thing on this issue that he's speaking of. .
8 It keeps surfacing because it is MR. NOONAN : 4 l
9 an overall concern from all the technict.1 groups. It's 10 one of the main concerns and I've heard it from everybody, 11 and that's why this thing on independence, root causes 12 and on a statistical sample...
13 I keep hearing you mention you've done a sample.
14 What is the basis for that sample? Is that that kind of 15 thing that rises out of the special (inaudible) ?
16 MR. GEORGE: I guess our, my concern at least, .
17 personally, is what is independence. And, you know, you 18 can get into quite z. lengthy discussion on just what 19 independence.
20 You know, it's difficult and we've gone through 21 some of the independents aside from this program. So 22 certainly we're, we're receptive to working with you and 23 considering what would be acceptable.
24 MR. McBAY: On this place that we've proposed, 25 this I,C, you're right, Larry. We did have... This is FREE STATE REPORTING INC.
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one of them that we had EBASCO named in. What we had i
planned to do is have Gibbs and Hill do the evaluation .
I I
3 I
and to have EBASCO review it. That's how we have set it I
4 I up. ,
i i
' ! Will EBASCO report to (inaudible)?
MR. SHAO:
6 MR. McBAY: Yes, that's right. EBASCO is in 7 -
the work plan for this I,C.
8 AE's normally don't like to report MR. GEORGE: i l
to each other and we are not in any great...
9f 10 The Gibbs and Hill payroll MR. SHAO:
i
' (inaudible) I mean subcontract to the EBASCO (inaudible) I i
12 they got the contract for a year. l I3 MR. GEORGE: We run an integrated operation l
~
l 14 and the owner runs the whole thing, and dny AE will be j l
15 reporting directly to the owner, as they always have. I 16 MR. McBAY: Is there anything else?
II MR. NOONAN: Yeah. For the reporter, we have 18 Jose Calvo back. He 's just entered the room. He's ;
l
'8 (inaudible) . I don't think you have his name down 20 there on your sheet. Jose Calvo. ,
21 MR. CALVO: The question that I have is you 22 want (inaudible) sample in that you're looking to con-23 centrating in that area (inaudible) greatest safety i
24 significance. 1 25 MR. McBAY: For example, control room ceiling f f
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i
- is going to be totally done in our program.
2 MR. CALVO: That's correct. (inaudible) 3
! Category I area, pick up those areas where the failure l 4
l of the systems (inaudible). I think you're doing the i
- l 5 i same thing with your (inaudible). l 6
MR. McBAY: That's a good point because there's
", 7 several ways you can approach a sample. You know, you ;-
I 8
take a list of 15,000 conduit numbers that are picked l 9' I through (inaudible) teams, but we've done looked at that ,
to ;
aspect.
i 11 We get a lot of very simple stuff that's not j 12 very meaningful to you. It's just a gimick, so we won't l
13 get into the heart of where, what...
I 14 MR. CALVO: And if you found problems that i 15 were very significant (inaudible) the root cause of why 16 you had that problem. And based on that root cause...
17 !
REPORTER: I'm sorry, I can't hear you.
MR. CALVO: Let me repeat it. When you do this...'
19 !
REPORTER: Louder.
l 20 ...this sampling and...
MR. CALVO:
21 Jose, come up to the table.
MR. NOONAN:
22 MR. CALVO: When you do this sampling, if you 23 found some problems, it will be advantageous to everybody 24 if you determine where the root cause of that problem is.
25 some So maybe by doing a sample, maybe you find out FREE STATE REPORTING INC.
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problems from that sample which could be under the i
2 rejection criteria, the acceptable criteria. !
I 3 Then you're saying yes, but this indicates !
l 4I a decided deficiency or something there that may require I
5i me to do something else to correct the situation. i f
6 MR. McBAY: Your point's well taken because 7 one thing, see, is we feel very confident unless we run ,
8 into a unique situation cut there that structurally we're 9 going to show that the installation will withstand an 10 i earthquake because of the short span.
f I 11 However, if it did not show to being structurally i i
12 sound, then the first thing we'd do is do a damage study 13 and evaluation if it fails what would be the impact of it.
14 And if it were not in the arecs that you're discussing 15 that were very concerning, our damage study would really 16 be, would not give us the total picture because we 17 wouldn't be evaluating just any important facts 18 (inaudible).
19 MR. CALVO: Right, okay. Let me see if I i 20 understand what you're saying. If you're doing a 21 sampling and you found something wrong with a particular 22 installation there and you concluded that this is generic
\
23 to all the installlations on the plant, then you don't do 24 no more sampling anymore.
25 From that point on, you're committing yourself PREE STATI REPORTING INC.
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41 to correct all the other installations on the plant.
2 Also, you have missed the acceptance criteria for that 3 sample.
ii
- I
- (inaudible) sampling of 500 You see, I'm, 5 conduits and my acceptance criteria, if I found 22 of i I
6 those or 21 of those, according to the 95% competence 7 level, okay, they both are okay but among those 21 you ,
8 found out that 10 of them are not okay, if the root source i 9 of those 10 are such that it brings into a case of a 10 generic problem, then you are in tie ballpark of the 1
11 sampling. i 12 You must attack all the other areas from the
?
13 point and correct that situation. Now, your action plan l l'
14 should reflect that. It should reflect that (inaudible) !
I 15 what happens, you are committed to do the rest. i 16 END OF TAPE 1 t l
17 l l
18 i
i 19 20 21 22 .
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JED NRC1023 T2 1 u 4g 1 MR. McBAY: If there 's nothing else on that, we 'll 2 go into 2D. Okay, on 2D, in the hand outs we gave to you 3- Friday, this plant is in that hand out. We'd like to go over 4 it a little bit because control roorn ceiling, that drawing is 5 a little hard to get proper perspective on what we 're talking ,
6 about.
7 We'll do the best we can with this.
8 This drawing here is a isornetric of the control 9 roo:n ceiling. This is the control board and this goes in a to horseshoe configuration this way in here to the center. This 11 control room ceiling is really based, comprised of three cei-12 lings, suspended ceilings.
13 One being the last, the lighting structures for 14 over the control boards, which is a grid system with lighting 15 fixtures underneath. The second ceiling system being a dry-16 wall or gyp rock Slanted slope ceiling, which is attached to 17 a structural frame, the dry wall is attached to a structural 18 frame. The third ceiling is another lighting ceiling system 19 out in the center of the control room with a U-strut grid 20 frame with the lights underneath.
21 The three key elements of this is the U-strut and 22 lights and the support structure for the dry wall ceiling are 23 all seismically restrained by air craft cable. Underneath 24 these, about a foot underneath each of these structural 25 members is the undercarriage of ceiling like this. It 's like FREE STATI REPORTING INC.
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v d _1 1 this, Larry, our engineering group issued thern correspondence 2 that told thern that this design, in our philosophy, Ineant the 3 intent of Reg Guide 1.29.
4 And for thern not, a design review of this configu-5 ration was not required. Now, before we..
6 MR. NOONAN: Can I ask the question.
7 MR. McBAY: Yes, sir, I 'in sorry.
8 MR. NOONAN: You said, Ineant the intent of that 9 regulation. What do you inean by that?
10 MR. McBAY: Well, Reg Guide forces to not perrnit 11 nonseistnic insulations that would be harinf ul to the perf or-12 : nance of centralized systerns, or in the control roorn, is injuries to the operator.
14 And we felt like, I guess our philosophy was that 15 if this panel here fell out, that it wouldn 't injure an op-16 erator. Because, you 've lif ted those up, they're very light.
17 That was the philosophy we went to.
18 Now, what we 're proposing. . .
19 MR. SHAO: It 's this kind of judgernent I would look 20 at, worry about, Inaybe you have judginent, so forth in the 21 plane, we think our judgernent inaybe we don 't agree.
22 MR. McBAY: Yeah.
23 MR. SHAO; Do you think you Ineet Reg Guide 1.29, 24 raaybe sornebody .else don't need Reg Guide 1.29.
25 MR. McBAY: That's right, Larry. Let rne tell you FREE STATE REPORTING INC.
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v.w s .j .j 1 this plus we have egg crate types ceilings you've all seen in 2 power plants. Ceilings very.similar to most power plants in 3 the country.
4 Except I imagine our dry Mall is a little bit 5 unique. I don't know how :nany have dry walls like this. .
6 Now, this undercarriage system under here is basi-7 cally tied back in, wired in, to this structural system. Now a the concerns that have been raised is ene, these, the force 9 we use, if we took all larger masses and that we thought were being the structural members, the lighting fixtures, any 10 11 large, the, pardon me, the gypsum and air frame, we took all 12 large masses and seismically constrained them off these air 13 craft cables so they wouldn't fall.
14 Our philosophy was that localized failure of the 15 undercarriage system of this ceiling here would not be det-16 rimental to the operation of the plant or the operator.
17 That's why the design is the way it is.
18 The concerns we have are, Larry and them pointed 19 Out, that the movement during earthquake of these structure, 20 of these tubes noying into each other, would give localized 21 or give impact loading, which could cause localized failure, 22 or failure of these undercarriage systemc.
23 Also, human factors-wise, was it a consideration 24 that who makes the decision of how small is acceptable to 25 follow. Our engineering group would then study, looked at FREE STATE REPORTING INC.
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'I 6 1 what we 're proposing as f ar as action. It 's debatable, it 2 is judgernent, just like you say. What we think 's best in 3 this area, is for us to take the Inost tirnely and direct reso-4 lution to this thing. Actions will be taken to keep any itern 5 frorn f alling out of the ceiling.
6 We're just gonna rnake it proof positive everything 7 will be seistnically hung frorn each one of these individual a panels to anything that could fall. So, we want to take that 9 action. We feel that we can take that action and Inuch incre to in a shorter tirne f rarne, direct approach, than we can the 11 continued debate what faults.
12 Now, what we would do en this, is we 're gonna 13 provide you a seistnic analysis, which dernonstrates cornpliance 14 with Reg Guide 1.29, SAR section 37B28. We 're going to have 15 to go in and add horizontal seistnic restraints. We 're going 16 to install those to prevent interaction between the ceiling 17 S ys teIns . The concern about the ceilings noving in at each 18 other, we're presently designing sorne horizontal restraints 19 to stop that interaction so we cannot inove the two ceilings 20 together. .
21 Because that was rauch rnore direct for us than try-22 ing to review irnpact loading and then what would f all, how 23 hard it would hit, that kind of stuff. So, we 're just going 24 to stabilize the three ceilings.
25 The other thing we want to do is the dry wall FRH STATE REPORTlHG INC.
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dO i ceiling will be replaced to expedite resolution in lieu of 2 verification testing. The dry wall ceiling that we have, the 3 question is we've got the structural members seismically sup-4 por ted by air craf t cables. We 've put the dry wall in, we 've 5 put a special configuration of screws in that carry about 60 ,
6 pounds pull out strength, to convince that the dry sali would 7 not separate from structural members.
g Well, we were getting the questions, well, if it g separates, will it come down in little pieces, big pieces, 10 what would it do. Well, we decided that the best thing for 33 us to do is to take the dry wall ceiling out and come up with 12 a ceiling of inverted side, a cork type ceiling where there 's 33 no question. Where the composition of the ceiling is not 34 subject like dry wall.
15 Now, we had the option, we looked into, actually, 16 our first plan was to test this. We feel confident that if we 17 Can put this on shaker test with our configurations, that our 18 :iry wall would stay up. But we could see what the impact of ig Committing to take this ceiling out was, we took a look, or 20 de tock a Unit 2 ceiling out this weekend.
21 It took us only three hours to do it. So, the 22 nmount of work is very small compared to what the testing a 23 progr m, waiting to get in line, why to get a test window.
24 3o, taking the dry wall ceiling out is the best approach for 2s -2s.
I i
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v 17 i Now, we haven't done Unit 1. We 're gonna wait 2 until our testing, hot functional testing, thermal measure-3 Inent testing is complete and then we 'll come in and address 4 Unit 1 after a testing program going into ours is complete.
5 But we're organizing such that we can do this in a very short ,
6 order.
7 The next issue, we 're gonna perform an evaluation 8 n each individual components of acoustical and louvered 9 ceilings and provide positive attachment if failure is a 10 concern. All we're saying there is all these T-bars and ij these louvered sections, we'll probably air craft cable every 12 ne of them back up to the lighting grid and then probably 13 1 p in every one of these panels to T-bars. So if the thing 34 shakes and falls, nothing can hit the floor, it 's all tied 15 together. And, that 's not a very big ef fort for us.
16 That is to make sure we can get lights in, change u out lights real quickly.
18 Okay, that pretty much covers it. The last issue ig on any of these installations regard a horizontal restraints, 20 holding the louvers down. All that installation will be 21 verified with QC. Larry, you had asked me about that before.
l 22 We 'll have QC verify further instruction procedures, regular 23 QE, category 2 type installation. We'll have QC verify all 24 this.
25 MR. SHAO: Need that appendix B, right?
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V 'I b i MR. McBAY: Yeah, that's right. Now, the last issue 2 that NRC brought back to Larry's question, the last issue NRC 3 asked was with this occurrence, how do you have confidence 4 and assurne our condition doasn't exist throughout the plant.
5 And I think that 's where you 're going to, what you 're talking ,
6 about, right.
7 What Joe stated, we have a long conference in our g daily study evaluation prograra. We always put a tre:nendous 9 arnount of effort into it. Very explicit regards details for in interactions of alot of evaluations done. Very docurnented ij approach. We think what we need to do here to get the con-12 fidence of you all into our prograra, is we need to provide 13 y u an surarnary docurnent of the daily study prograrn we've done a that would encornpass not only just conduits like in Itern 1C, 15 but our entire daily study prograin.
16 We do feel like, though, that for us to be convin-37 ced ourselves that we haven 't let sornething , interaction go 18 unresolved or unlooked at, we think that since the ceiling 19 area is a architectural feature that had to, that raised this 20 question, and there was a dif ference in judgernent between us 21 and NRC, we feel like the architectural probably-needs to be 22 reviewed.
23 We're gonna go back and re-review all tne architec-24 tural specs and drawings to confirrn that the architectural 25 features are prc,;.,erly considered in our darnage study prograra.
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U iO 1 This is a pretty good sized review that will take us so:ne 2 time. We do plan to use the same walk down teams, the danage 3 study teams that we 've used prior. We feel like it 's a con-4 tinuation with that prograrn. Now...
5 MR. SHAO: Let me understand your statement here. ,
6 You say you think there 's some problem with the control room.
7 You also may have some problem with your architectural fea-8 tures. Why do you say you are very, a lot of confidence in 9 the damage study?
10 MR. McBAY: The dataage study program, take n conduits, for example, every conduit was individually walked 12 down and viewed as a source against a target.
13 MR. SHAO; But what I'm worried about is alot of 14 time you use alot of judgement, just like in the ceiling 15 there. Some people doing the damage study suggesting it met 16 Reg Guide 1.29. Some people else, some other people think 17 you do need the Reg Guide 1.29.
18 MR. McBAY: Okay, I guess the judgement areas, 19 Larry, are much more predominant, are only predominant in 20 regard to architec.ture, because architecture has these 21 features that people are accustomed to seeing daily, that is 22 just part of your daily life and may not view them in regard 23 to damage study or ...
24 MR. GEORGE: Mike, let me interrupt you there. Joe 25 George here. I think in all of this design philosophy, we FRH STATE REPORTING INC.
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i u EiO i can't avoid the possibility that the engineers, when they're 2 working in an area where it 's the lowest vault that we know 3 of in the country, and they think there will never be an 4 earthquake there, if they had a judgment on how big is 5
allowed to fall, is it ever going to fall, they might be -
6 biased a little bit by that.
7 And I for one don't think we will ever have a 8
earthquake there. Obviously, we can 't prove that. So we 9 have to take all of this into acctunt and so we're proposing, in we're not debating this with you, by the way, if you were in ,
y terpreting this as a debate on whether we meet 1.29 or not, 12 it 's not a debate.
13 We 're going to convince you people that we meet it.
34 That's our objective here. And if we don 't meet it, then 15 we 're gonna. . .
16 MR. SHAO; Okay, my general comment is, I think you 17 proved it on the control room itself very good. Okay. But I 18 think you prove it in other parts of the plant, I think it's ig a big vague. I don 't know what you 're doing here. If I were 20 to approach it, I would approach it a different way. And I 21 would do a little bit independent audit, outside consultant 22 to look at it, measure your judgement, yes, it was right.
23 But I don't see that in the plan.
MR. GEORGE: Well, as I said earlier, we're 24 25 receptive to modifying. You need to just tell us what you, FREE STATI REPORTING INC.
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51 i it 's gonna take to satisfy you ...
2 MR. McBAY: We take that into consideration.
3 MR. SHAO: Talk about earthquake, earthquake can 4 happen everywhere, like a week ago it happened in Missouri.
5 And nobody ever think of ...
6 MR. GEORGE: Yeah, well, surely I'In not here to 7 discuss whether we 're gonna have an earthquake or not. But I e do point out that we 're on the lowest vault level that we 9 know of.
10 MR. SHAO: Yes.
n MR. GEORGE: And I would point out that we 're on i7 the seistnic owners group that 's dealing with these earth-13 quakes east of the Rockies and of the test plants, it does i4 turn out that when you take probability into consideration, 15 that the SSE's are decreased.
16 MR. SHAO: Instead of pointing to lower.
17 MR. GEORGE: Yes, sir. And there are sorne cases, 18 unfortunately that 's not the case.
19 MR. JENG: Mike, I 'd like to augtnent Larry 's coin-20 Inents , two cornInents.
21 MR. McBAY: Okay.
22 MR. JENG: In regard to the analysis of the control 23 roorn elernents, we feel that the way you have presented, by 24 rnerely referring to 3.7 129 Reg Guide, is not legally now, I 25 suggest that you, in your Reg 2, Reg 1, indicate what other FREE STATE REPORTING INC.
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d 52 i specific acceptance criteria in monitoring for seizures and 2
what judgement of adequacy insofar as the remodeling, 3 analysis and productivity obtained in such analysis.
, To activate the whole about the deeper aspects, so
, that we can understand what you are going to do and how, -
6 based on what judgement that we make.
7 MR. McBAY: Okay, are you going to put that in the a
write up y u'r g nna send me?
9 MR. SHAO: Yeah, we will send it.
jg MR. McBAY: Okay.
g MR. JENG: Okay, and the second comment, I think Larry mentioned but I'd like to make sure you keep the g comments clear. As to why are you only concerned in the g architectural features in your investigation. Whereas there 15 may be architectural features, however, they are still non-16 seismic items.
37 So I think since you abrasions or the non-seismic 18 items in your irradiation on the items elsewhere in the 19 pack..
20 MR. McBAY: That really goes to some type of inde-21 Pendent system of our damage study program, because we've 22 already looked at them and I guess, and I guess we need, that 's the solution to that, I guess.
24 MR. JENG: Because in your report, you state 25 architectural reaches are the ones to look at.
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53 1 MR. SHAO: But you, based on your judgIcents that 2 the previous work was good, then it can be, you say you have 3 alot of confidence in your previous work. Which we 're not 4 familiar..
5 MR. JENG: And my other point, outside, you have 6 done so called independent reviews, Larry saw this one. He 7 named one to do, audit of our own, outside people has done..
8 reserved the hard one. So that may be one of the items...
9 MR. SHAO: Okay, you current done seis:nic. Are you in going to discuss something related to category 2 structures 3, that insist on conformance, what's your approach?
12 MR. McBAY: On category 2?
23 MR. SHAO: There are t_wo basic questions. One 34 question is, how do you treat your damage study related to is n n-seismic ...
16 The other major comment that we had was we 're not 37 happy with your naciful category 2 structures different ccm-18 ponents. Because you do alot of equivalent status level, you 19 didn't take up conduit interacting because of the two masses.
20 MR. McBAY: You 're talking about specific on the 21 air craft cables?
22 MR. SHAO: I'm taiking about this category 2 23 sys ems component in general.
24 MR. JENG: You do some equivalent status in the 25 :ontrol room. We have problem with this. Our question is, FREE STATE REPORTING INC.
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i do you have any possible problern related to rnasses, ficw of 2 category 2 structure systern corne frorn elsewhere in the plant, 3
what you 've told us frorn that.
4 MR. McBAY: Larry, the control roorn ceiling, the 5 three ceiling configurations is a very unique situation for ,
6 us in the plant. We don 't think we have a problern in the 7 other category 2 designs. We have done sorne reviews into a
those.
9 ML. SHAO: Have you been to, did you do the original
,g analysis? How do you do the category 2 analysis, can you
,, describe to us, how do you do a category 2 analysis also in 12 the plant, or the approach.
13 MR. McBAY: Okay, need to get clear of the defini-3, tion of category 2, just to raake sure. Because ours is a
,3 little bit different than other plants.
16 ego y s as a y se Srnic design...
37 MR. SHAO: I understand the definition. I just 3g want to know how you do analysis, what the analysis approach 19 for category ..
20 MR. McBAY: Okay, the Category 2 analysis was 21 done in the sarne Inanner Category 1 is.
22 MR. SHAO: What's the difference?
23 MR. McBAY; Okay, as I was explaining, category 1 24 is seistnic design that 's required for safe shut down of the 25 plant. Category 2 is seistnic design that 's not required for FREE STATI REPORTING INC.
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56 i the safe shut down of the plant. A platform would be a, a 2 stairway could be a category 2 design.
3 And non-seismic is something that does not have a 4 seismic design to it.
5 MR. SHAO: Okay, in to analysis, what would be the 6 difference?
y MR. McBAY: Analysis would be the same.
8 MR. SHAO: Yeah, but the reason we sought the dif-9 ference in the control room, your category 1 analysis and in your category 2 analysis were not the saice.
33 Category 1 you did a dynam analysis, category 2 you 12 used a chromostatic analysis. My question is before you made 13 the statement that everywhere else was okay, you look into 34 the category 2 analysis and they ...
15 MR. McBAY: We can do.that. We had not planned to 16 do it. We felt like..
17 MR. SHAO: That wasn't the question we turned to is you. What your action planned for looking into the nonacces-ig sible category 2 structure system and component. But, you 20 see the distinct difference between category 1 and category 2 21 analysis, and you just told me that there shouldn't be any 22 difference.
23 MR. McBAY: I think what we were looking there, was 24 the air craft cable design, though.
25 MR. SHAO: In the control room seating, you used FREE STATE REPORTING INC.
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.1 56 1 the current status analysis. And also you didn't take the 2 interaction, taken into account.
3 MR. McBAY: I know, that's right.
4 MR. SHAO: So, we have a lot of trouble with that
~
5 analysis. So rny question is, you say this very unique .
6 control roorn, it doesn't happen sornewhere else. Can you give 7 Ine sorne proof to back up your staternent with?
8 MR. McBAY: Okay, we can do that.
9 MR. SHAO: You have already, this investigation to before you rnade such a staternent?
11 MR. McBAY: Well, we 've done sorne investigation 12 into it.
13 MR. SHAO: You Inean the last couple weeks?
14 MR. McBAY: Not in the last couple weeks.
15 MR. SHAO: How can you say then...
16 MR. McBAY: Well, when you're going back in, for 17 exarnple, we were re-looking at the control roorn ceiling 18 regard to the irnpact loading? We reviewed in regard to the 19 philosophy that was used on our seistnic design. We use peak 20 response spectruin ,on all of our seistnic design, which is very 21 conservative.
22 MR. SHAO: It 's a new rnethod.
23 MR. McBAY; Well..
24 MR. SHAO: Your dilernina in prescau.ng tried to Inake 25 a difference.
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v 57 1 MR. McBAY: Yeah, well, it depends on which 2 application factor you use. Like, we 're on the, one for this 3 for example, case factor 1.5 on verberating.
4 I guess, Larry, the best way to close this is me to 5 go ahead and include in our plan a action for us to go back ,
6 and re-review some category 2 designs. And if we see any y significant difference between category 1 designs, then be a able to explain .:.
9 MR. SHAO: Yeah, I think you should audit this on 10 the category 2 analysis. I think TUGCo should audit this in ij category 2 analysis to make sure the category analysis was 12 Properly performed.
13 MR. McBAY: Okay.
34 MR. SHAO: Yeah, I think you want to do some 15 auditing too.
16 MR. GEORGE: We hear what you're saying, and we a will expand it beyond the control room ceiling issue and 18 architectural issues, going back to other category ...
ig MR. SHAO: Yeah, I would not except the statement 20 that this is very unique. The problem is only here and 21 n where else.
22 MR. GEORGE: I understand. We hear you.
23 MR. McBAY: That is really all I have to presant.
24 There any questions?
25 MR. MERRITT: All right, next we've got start of PRH STATI REPORTING INC.
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bb I testing prograrn.
2 MR. WESSMAN: Joe, let Ine ask a digression, before 3 we start with the test prograin discussions. I know you are 4 all planning to do what 's been referred to a raini-hot 5 functional testing. I wondered if you could take a couple of ,
6 Ininutes and surninarize to use the test activities that you 've 7 got corning up in the next couple of weeks, or the next rnonth 8 or so that concern a hot functional testing activity and heat 9 up and cool down. And what sort of tirne f rarnes you expect io these things to happen.
11 MR. GEORGE: We'd be happy to do that and Mr.
~ '
12 Camp... .
13 MR. CAMP: I planned to do that during ray presen-14 tation.
15 MR. WESSMAN: All right. Why don 't we go of f the 16 record for a couple of Ininutes and let everybody get a 17 stretch or, no Inore than five Ininutes, because I think we 18 want to get on with things, don't you all?
19 (Off the record.)
20 MR. NOON _AN: I think we'll go ahead and continue on 21 with the rest of the rneeting here. We 're talking about the 22 start of testing area. And with that, why don't the utility 23 go ahead and start?
24 MR. CAMP: My naIne is Dick Carap. I arn currently 25 the start up rnanager at Corninanche Peak. I've been on the FREE STATI REPORTING INC.
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50-1 projec*. for just a'little over nine years now. I carne in in 2 '75 to assist in the preparation of the test prograrn.
3 Prior to that, I worked for Burns and Row on the 4 WMP2 project. And the early stages of construction, 5 assisting the utility in setting up test prograin there and ,
6 construction as well as preoperational testing.
7 Prior to that, I participated in the start up at 8 Cooper Nuclear Station in Nebraska. And prior to that, ap-9 proxirnately three years in the Newport News shipbuilding and io dry dock in the Navy nuclear prograin there.
ii Graduate engineer with a Inechanical engineering 12 degree. That 's pretty rauch rny background.
13 MR. KEIMIG: Dick, for the record, who do you work 14 for now? -
15 MR. CAMP: I work for Arntel Corporation. The first 16 issue is 381, deals with the review of hot functional test 17 data packages perfortned by the TRT. Basically, the TRT re-18 viewed several test data packages and identified three where
, 19 there were concerns expressed, where certain test objectives 20 Inay not have been .inet on those cornpleted tests.
21 Our action plan to resolve this issue is to review 22 each of the, each of the three tests expressed as a concern 23 by the TRT and provide justifications for the actions taken, 24 or perforrn retests for those tests.
25 In addition to that review, we will be reviewing FREE STATE REPORTING INC.
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G0 1 the seven remaining completed hot functional tests that were 2 not reviewed by the TRT to determine whether or not those 3 tests met the test objectives.
4 As a result of this review, if any retest is 5 required to demonstrate a test objective, that will be con- .
6 sidered as a recheck and require further review on a 7 sampling basis of the remaining 136 non-hot functional pre-8 operational tests.
9 The first sample review of 20 procedures, one lo reject will require the additional review of another 20.
ii If, in the second sample, if one reject is identified, all of 12 the remaining approved preoperational tests will be reviewed.
13 Are there any questions on this issue?
14 MR. KEIMIG: Yeah, Rick Keimig, TRT. For the 15 record, I would like to make note that TRT did not ascertain 16 the acceptability of the test results. That is, they did not 17 validate any test results. That statement is made in the la background section of this item.
19 MR. CAMP: Essentially what we did is we reviewed 20 the test procedures and resultant data to determine conformance 21 with your FSAR and Regulatory Guide 1.68. Validation of the 22 test results, I understand, is being done on a sampling basis 23 by Region 4.
24 That was a misunderstanding on our part relative to 25 the degree of your review.
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v 61 1 MR. KEIMIG: I have a question with regard to why 2 you 're restricting your initial review to the remaining 7 hot 3 functional tests that we did not review.
4 MR. CAMP: Well, basically, we considered, you 5 know, reviewing all of them. Since the concern was expressed ,
6 on three, we assumed that, our belief that we had done an 7 adequate review on all of them in the first place and that s there was no problem expressed by ghe TRT on the procedures 9 that were reviewed by the TRT would not indicate any reLson to to go back and re-review them again.
,1 If you will, took credit for your..
12 MR. KEIMIG: Except that in the case of the 13 containment integrated leak rate test, we also found the 14 same problem, where test objectives in accordance with 15 Regulatory Guide 1.68,'in our estimation, our opinion, were 16 not met.
17 There are 136 some additional preoperational tests 18 thats1 think need to be' included in the sample that you
. 19 people do originally. So, I would ask that you reconsider 20 and do a statistical sampling on those seven plus the 135 21 preoperational tests that haven't been looked at.
22 MR. CAMP: If I understand you correctly, are you 23 suggesting that we go ahead and proceed with the sample, re-24 gardless of any reject status on the three that you've iden-25 tified as a problem?
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u G2 1 ME. KEIMIG: That 's correct.
2 MR. CAMP: Or the seven?
3 MR. KEIMIG: That 's correct.
4 MR. CAMP: We'll go ahead and proceed with that in 5 Parallel. ,
6 MR. KEIMIG: And again, I would like to know the 7 basis for your selection of which preoperational tests that 8 you decide to select for review.
9 I have another question and 7 hope we 're not going to to waste anyincre tirne on this. But, . would like to hear it your opinion, Dick, on the pros and cons of having this 12 review done by the JPG, which is not an independent group of is this activity.
14 MR. CAMP: Okay, our plans were that the joint test group 15 is inade up of representatives froin engineering, Westinghouse, 16 froIn Start Up, plant operations, and is chaired by the 17 ;hanager of Nuclear Operations. Our plan on this additional 18 revie , was'to have that group responsible for the review and 19 the review actually perfortned by tha joint test group rnernbers 20 thernselves, or individuals designated by thern within their 21 organization that were not previously involved in any 22 previous reviews, to obtain sorne independence in terras of the 23 actual review process.
24 It was, has been our understanding that there was 25 not a conce' over the qualifications or independence or FREE STATI REPORTING INC.
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r 63 1 objectivity of the joint test group, but there was a concern 2 relative to the arnount of involvernent by the joint test group 3 on a daily basis during.the conduct of the testing.
4 MR. KEIMIG: That's correct.
5 MR. CAMP; So, we kind of felt that the joint test ,
6 group 's responsibility to perforin these reviews and to Inake 7 sure that they understood all aspects of testing relative to a test efficiencies, test deviations, that would be teore bene-9 ficial to have that group retnain responsible for that acti-10 vitY-11 MR. KEIMIG: That 's why I asked the question.
12 Because in this particular case, Vince, I'in not sure if it 13 would be of any advantage to get an independent group to do 14 the review of these pieoperational test procedures, because is of the knowledge of the individuals on the joint test group 16 with the procedures thernselves and the workings of deviations 1- and so on and so forth.
18 I think in the revision to your action plan, we 19 rnight want to see what you have to say about having the joint 20 test group do it and weigh the pros and cons.
21 Another concern that surfaced with respect to the 22 joint test group's review of the hot functional tests, which 23 Inay not corne out of our findings very loudly, it 's kind of 24 like a silent alarin, though, and that 's their interpretation, 25 that is the interpretation of the JPG, with regard to Reg FREE STATE REPORTING INC.
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1 Guide 1.68.
2 Apparently, they think that it's perfectly alright 3 to not have certain equipraent installed during a hot 4 functional test, conducting the test and then and installing 5 that equipinent when a test is cornpleted. I would like to ,
6 know how that Ineets Regulatory Position 3 of Reg Guide 1.68.
7 Now, you needn't address that now, but we won't be e asking you that when we give you our cunraents. It's a con-9 cern that I have, it 's a concern that the rest of the tearn to had, and I think it needs to be addressed.
11 In addition, we need to take that into considera-12 tion when you propose, whernever yoit decide to propose, to do 13 this review. How can we have assurance that they will be 14 properly interpreting Reg Guide 1.68?
15 MR. CAMP: You want us to address that in our 16 revision, our plans?
17 MR. KEIMIG: Yes.
18 MR. CAMP: I'd like to say one thing about that, 19 and that is certain tests that were pointed out in this 20 review, for exarnple, the stearn generator level instrurnenta-21 tion concern, that dealt with the three ternporary instru-22 rnents being installed for the purpose of doing the test.
23 That was a conscious decision to do that. It was 24 no*. a conscious decision to deviate frorn any Pegulatory 25 Guides or cornrnittnents. In essence, we had, each stearn FREE STATI REPORTING INC.
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b6 1 generator has four level channels. We have three that were 2 defective with a long lead tirne for replacernent of the PC 3 cards. The Unit 2 instrurnentation is not cf the saIne type 4 that Unit 1 is so we could not transfer those instruinents.
5 And we elected to proceed with temporary instru-6 Inents in place, based on the knowledge that 13 of the 16 are 7 permanent plan instruments, they would demonstrate, during 8 the conduct of hot functionals, they would dernonstrate the 9 adequacy of the loan instrumentation system, and the ade-10 quacy of the calibration procedures and scaling documents is used for calibration.
12 So, I, you know, it sounds almost like a flagrant 13 misinterpretation of Reg Guide 168 the way you described it, 14 Mr. Keimig, and I don 't think that 's the case.
15 MR. KEIMIG: No, as a matter of fact, I recognized 16 that it was a conscious decision and that 's what bothers me.
17 Because Regulatory Position 3 of that Reg Guide says that to la the extent practical, duration of the test should be 19 sufficient to permit equipment to reach its normal equilibriurr .
2c conditions. ,
21 And thus decrease the probability of failures, 22 '> including run in type f ailures f rom occurring during plant 23 Opera'. ' ans . And I don 't see how you can accomplish that if 24 indeed you do not have instrumentation installed at the time 25 you run a test. That 's my problem. Plainly, that needs to FREE STATE REPORTING INC.
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9 66 1 be addressed.
2 MR. CAMP: Okay, we will atternpt to do that in our 3 revision.
4 I said earlier I would get into a description of 5 the new decision to perforrn another heat up prior to fuel .
6 load. Approxirnately two weeks ago, two and a half weeks ago, .
7 the decision was Inade to re-perfortn, do another heat up for a the purposes of conserving tirne af t.er fuel load and take ad-9 vantage of sorne of the tirne that we perceive as f ar as a 10 delay in operating license.
11 What will be perfortned during that heat up, Inost of 12 the plant systerns have been turned over tc the operating 13 group for final acceptance now. The operating group will be 14 responsible for the conduct of that heat up, using norrnal 15 plant procedures. During the process of that heat up, 16 certain deferred preoperational tests, resulting f rorn the 17 last, f rorn the first hot functional test, will be perforrned 18 prior to fuel load.
19 Included in that next heat up will be the therrnal 20 expansion test of,tae deficiencies found the last tirne . The 21 current status is we have the head on, in the process of 22 putting the CRDM vent f an systern on and filling and venting 23 .cf systerns in preparation for arnbient ineasurercents f or the 24 deficient supports found during hot functional testing.
25 We expect to begin heat up sornetirne next week. Of FREE STATE REPORTING INC.
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G7 1 course, that's contingent upon getting one of the diesel 2 generators operable. As you know, we've disassernbled diesel 3 generators for the second tirne, to perforra bearing oil hole 4 inspections. Both trains are getting back together now. One 5 train is cornplete with preoperational testing in progress on 6 train A.
7 And we hope to finish that and have that diesel 8 generator operable next week.
9 MR. KEIMIG: Why is the operating staff being inade 10 responsible for this raini-test?
11 MR. CAMP: Basically, Mr. Keirnig, the reasoning for 12 that all of these tests have been deferred over into the 13 operations prograin that would be irnplernented post-fuel load, 14 under the auspices of the initial start up test prograin.
15 All of the plant systerns that will be involved have 16 been turned over and finally accepted by operations. It 17 basically cornes under the auspices of their norrnal operating 18 procedures and prograins. We felt that by doing that would 19 certainly exercise their procedures and operating procedures l 20 rnore fully and place the responsibility where the responsi-21 bility will be at the tirne of fuel load.
22 MR. KEIMIG: Okay, I understand that now. Will you 23 be raaking a transit FSAR to reflec.t who's responsible for l
24 these tests?
25 MR. CAMP: An FSAR change has been in the process FRH STATE REPORTING INC.
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GS 1 of being submitted.
2 The second issue, issue 382, will certainly be re-3 vised to reflect this new decision to perform another heat up 4 prior to fuel load. Basically, our feeling was, and I s certainly hope we didn't get caught up in words here, is that ,
6 the TUEC has currently a commitment for the station operating 7 review committee to review all initial start up tests, which 8 would include deferred preoperational tests.
9 The qualifications of this group are described in to the FSAR and we feel they are similarly qualified to the 11 joint test group. Our previous plan was to complete all the 12 four preoperational test prior to initial criticality, with 13 the exception of those portions of thermal expansion associa-14 ted with feed water system, which could not be performed 15 prior to initial criticality.
16 The results of those tests would be reviewed and 17 approved prior to initial criticality. The remaining portion 1
18 of the thermal expansion test, which is expected to be ccm-19 pleted at the 30% power plateau, would be reviewed and appro-20 ved prior to escalating to the 50% powar plateau.
21 However, due to this new decision, this action plan 22 will be revised to reflet; our current schedule on the 23 project. Are there any questions on that issue?
24 The third issue, issue 383, deals with TUGCo speci-
! 25 fications for deferred tests in that the observation was that FREE STATI REPORTING INC.
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v 69 1 certain plant conditions could not be, could not accorcinodate 2 the perforraance of deferred preoperational test in that tech-3 nical specifications could not be met.
4 The exarnple was given for snubber operability, in 5 that sorne snubbers would not have been tested. -
6 This actio'n plan will also be revised as a result 7 of this heat up. However, I would like to point out a couple 8 of things. We, the utility had evaluated several incomplete g preoperational tests for deferral after fuel load. During to that evaluation process, required plant conditions and tech-33 nical specifications, limited conditions for operation, were 12 evaluated and a request was submitted to NRR for deferral of 13 these tests.
i4 Approval for that deferral was received and during 15 that process, we did'not request any deviation from the tech-16 nical specifications.
p At the current tirne, we plan on finishing these in-18 Complete preoperational tests prior to fuel load, in which 19 case they will be reviewed and approved prior to fuel load.
20 Any kind of technical specification deviations that may be 21 associated with thermal expansion, we don't know the scope or 22 extent of those at this time, and we won't know until we 23 finish the re-tests associated with thermal expansion.
24 S , that will be evaluated and tech-spec exceptions 25 will be requested where appropriate.
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70 i MR. KEIMIG: Snubbers actually would be major items 2 that we were addressing.
3 MR. CAMP: Are there any questions on this issue?
4 MR. WESSMAN: Dick, let rae offer a little bit of a 5 cornment on this. Obviously, we'll have to kind of revisit -
6 this area after you finish the mini-hot functional testing 7 that you're about to do.
8 A little bit related to all of this, of course, is g the staff evaluation of the motion that you still have to pending before the Board pursuant to 5057 (C), because 33 obviously to do any hot testing after the core is loaded, 12 there is constraints for operability of various systems im-13 Posed by the tech-specs.
34 You may recall that to get yourself up to hot 5 levels after the core is loaded, that you have to meet the
, is operabilit.y requirements for these various systems.
17 MR. CAMP: That 's right.
18 MR. WESSMAN: And sometimes the difficulty in 19 meeting operability means that you seek an exemption to the 20 tech-specs. That requires a fair amount of advance planning 21 and review by the staff.
22 And as long as that motion is on the books, it 23 means that we have to consider the impact of that just as you 24 must.
25 MR. CAMP: Well, the only exceptions that we had FREE STATE REPORTING INC.
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j:d 30 71 i planned to have were related to snubbers.
2 MR. WESSMAN: My memory fails me but ray recol-3 lection is when CATAWBA did some similar hot testing after 4 the core was loaded, I believe pursuant to similar motion, 5 that there were a number of tech-spec exemptions or revi- ,
6 sions that they had to make to their technical specifications 7 to accommodate this unique operation of the facility.
8 So, at first blush, it may be more difficult that 9 appears. That 's the only reason I bring the subject up.
10 MR. CAMP: I'm aware of that.
33 MR. BECK: We 're looking at CATAWBA 's licensing 12 documentation in that regard, primarily as associated with 13 diesel generator availability, as I recall.
14 MR. CAMP: As I recall, that was the largest amcunt 15 of deviations associated with that docket.
16 MR. WESSMAN: That 's all I have on this area.
17 MR. CAMP; Okay, the fourth issue is issue 384, 18 deals with the traceability of test equipment. It was found 19 by the TRT that included in the thermal expansion test 20 package, which is,under final review, that adequate documen-21 tation did not exist for the traceability of temperature 22 measuring devices used during that test, from the calibra-23 tion of the instrument to the location that they were used.
24 It was also pointed out by the TRT that this in-25 formation was available in a personal log held in the FREE STATE REPORTING INC.
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72 1 engineering department.
2 The traceability of that instrumentation was, in 3 fact, not included in the test data package. We have 4 reviewed the information available from the personnel log.
5 It is adequate to provicle traceability from the calibration 6 of the instruments to the location used and that documenta-7 tion has been included in the test data package.
8 We have administrative requirements for the tracea-9 bility of test instrumentation. We feel that this is an iso-10 lated case where we used, or had, engineering personnel tem-11 porarily assigned to start up, for the purpose of doing 12 thermal expansion test only. They were indoctrinated in the 13 administrative requirements, however, they failed to comply 14 with them.
15 To prevent...
16 MR. KEIMIG: Could you expand upon that a little 17 bit, Dick? I tell you why I ask that. If the procedure had 18 been left in its previous revision, the recording of the test 19 instrumentation would have been on the data sheet that the 20 temperature was recorded on. When the procedure was revised, 21 and I don't know for what other reason it may have been re-22 vised, but when it was revised, somebody revised the require--
23 ment as to where to record the serial numbers of the testing 24 instruments.
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v 73 i package. I really don't understand how you can attribute 2 this to engineering personnel ternporarily assigned to do the 3 therinal expansion tests. Sorneone who revised the procedure, 4 and those that approved that revision, rnissed the fact that 5
when the test instrutnent serial nuinbers were recorded else-6 where in the procedure, that there would be no traceability 7 to the data which was being recorded on the data sheets.
8 MR. CAMP: I haven't personally looked at that 9 package, Mr. Keirnig, but I will. Do you recall if the re-in quirernent to record that inforination was in a dif f erent loca-is tion in the procedure as a result of the revision?
12 MR. KEIMIG: Yes, it was, definitely was. Now, the
- 13 ' start up adrainistrative procedure recognizes the need to 34 rnaintairt traceability, and it provides several options for 15 doing it.
16 In this particular case, the wrong option was 17 chosen when the proceddre was revised.
18 MR. CAMP: Well, I'll just have to look at that, I
. 19 don't have the answer right now.
20 MR. KEIMIG In addition, I think that your action 21 plan chould also include a review of the Unit 2 preoperation-22 al test procedures and the Unit 1 and 2 ISU and plant opera-23 ting procedures to insure that where instrutnent traceability 24 for calibration purposes is required, that the fortnat is such 25 that it indeed does get recorded where it should.
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'i .1 1 Again, because I think that somebody did not know 2 why the instrumenc serial numbers were being recorded on the 3 data sheets in the previous revision to that procedure. I 4 think that your action plen needs to be broadened somewhat.
5 MR. CAMP: To address other programs?
6 MR. KEIMIG: Yes. It may be a generic weakness 7 with people who are preparing procedures.
8 9 (End of tape) 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 FREE STATI REPORTING INC.
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1 MR. CAMP: Any other questions? The fifth issue 2 deals with containment of integrated leak rate testing, 3 issue III-B. TRT identified that during the time of the test 4 we isolated three electrical penetrations to complete 5 successful, for successful completion of the test as well as 6 the leak rate calculation method was in accordance with 7 ANSI 56.8, not 45.4 which we were committed to in the FSAR.
8 Since identification of this item we received a g letter from NRR requesting additional information on this 10 subject. It is our understanding this has been turned over it to the appropriate review branch and is counted as, carried 12 as an open SER item.
13 We intend to compare the test procedure to the 14 FSAR and ANSI 45.4, 1972 version to identify any other 15 deviations and provide justification for any other deviations 16 in response to the NRC letter dated August twenty-seventh.
17 MR. KEIMIG: Did that NRC letter address the three I
18 electrical penetrations?
19 MR. CAMP: Yes, it did.
20 MR. KEIMIG: Could you briefly tell me what it said 21 about the three electrical penetrations?
22 MR. CAMP: It said -
23 MR. KEIMIG: It's not mentioned in your background 24 here.
NRC 25 MR. CAMP: In essence the retest resulcs for T-3 PCC FREE STATE REPORTING INC.
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V 70 1 the electrical penetrations were provided in our summary, in 2 our report supplement that provided the data for the retest 3 leakage rate. A comparison was made for the retest leakage 4 rate to the overall containment integrated leak rate and 5 determined that it would be insignificant.
6 MR. KEIMIG: Thank you. I have some more questions 7 on this item and the kind of generic type. You mentioned in ,
8 the background here that the f act that the FSAR was not ,
9 amended was due to an oversight. Can you explain to me how I
10 ! that oversight occurred?
11 MR. CAMP: Well, it obviously occurred during the 12 review and approval of the procedures in the first place.
13 Whether the criteria used for rev,iew of procedures is to 14 insure that it complies with the FSAR commitments for 15 testing. So it was an inadequate review of the procedure in 16 the first place.
17 MR. KEIMIG: What is your normal process for re-Ils cording or documenting and processing identified deviations 19 from the FSAR?
20 MR. CAMP: I don't understand your question. What 21 is the normal process? We identify deviation, the necessity 22 or -
23 MR. KEIMIG: Yeah, how would you - i l
24 MR. CAMP: We would process -
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U 77 i
apparently elected to go another route to calculate tne 2 leakage rate. Perhaps you thought it was a better way to go, 3 but it's a deviation from what you committed to in the FSAR.
4 How would you normally have processed that through the NRC or I
5 through your own system to get to the NRC as an amendment to 6
the FSAR?
7 MR. CAMP: Start up or whoever identified the pro-8 blem, we would have ended up I think amending the test com-g mitment, processing FSAR change request through engineering, io from there to licensing, from licensing to the Commission.
13 MR. KEIMIG: My concern is that since we know of 12 one oversight, how do we know that there haven't been other 13 similar oversights? Have you considered reviewing your i4 process to see if there possibly are some others that may 15 have been overlooked?
16 MR. CAMP: Well, we had already discussed and I 17 didn't include in the background section or description of 18 either III-Alor III-B. We had planned to include that into ig cur acceptance criteria for review of these additional.
20 procedures that we were being required to review. Plus to 21 see that we did meet the test objectives as stated in the 22 FSAR as well as any other standard commitments we've made.
23 MR. WESSMAN: Joe, this is back to one of these 24 root cause issues. Again, I think we're dealing with a case NRC 25 where a test varied from the FSAR got by you. When we wrote T-3 PCC .
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V 78 1 our September eighteenth letter to you we asked that you 2 identify other deviations from FSAR commitments. Your 3 action plan focused very narrowly on the containment inte-4 grated leak rate test.
5 I think what we're trying to tell you is root 6 cause, generic approach means look at the tests versus the 7 FSAR and see whether you've got any others that slipped ,
8 through. I think the action plan that you've provided is 9 too narrow and you've got to look broader.
10 MR. CAMP: The reccon this specific cne looked l 11 narrower was because we knew that we were going to be looking 12 for this aspect in the review of the test as described by
-13 Issue I-II-Al and the f act that it was our understanding that 14 this had been taken out of the technical team and that we 15 only wanted, that we were only required to respond to the 16 request for information provided by, requested by the 17 review branch.'
18 MR. KEIMIG: That particular aspect of it, yes, 19 was turned over to the technical review branch. However, the 20 generic aspects of it were not and -
21 MR. CAMP: And I understand that and what we had 22 planned to do was address that in the review with III-Al.
23 !!R. WESSMAN: You need to clarify how you're going 24 to handle III-A -
NRC 25 MR. CAMP: Okay.
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u 79 1 MR. WESSMAN: Because obviously the story isn't 2 there. It didn't fall into place with those of us looking at 3 it.
4 MR. CAMP: Any further questions of III-B? The 5 sixth issue deals with prerequisite testing, Issue III-C.
6 TRT finding was that sort of management had an issue they, 7 an interoffice memo that conflicted with approved administra- .
8 tive procedure requirements for verification of initial 9 conditions for prerequisite or construction testing.
10 The subject memorandum has been recinded. The 11 start up craft, support craft as well as test engineers have 12 been reinstructed on their scope of responsibilities and all 13 additional interoffice memoranda are being reviewed for, to 14 determine if additional conflicts have been issued in the 15 past.
16 MR. KEIMIG: Let me make a comment about this par-17 ticular item. Somehow or other in the September eighteenth 18 letter a line got dropped or a word got dropped or something 19 happened. Because here again you haven't addressed the 20 generic aspects of this particular problem as we saw them.
21 Our September eighteenth letter says that the 22 review of test records revealed that craft personnel assigned 23 to verify initial conditions of test in violation of start up 24 administrative procedure 21 entitled conduct of testing.
NRC 25 This procedure requires this function to be performed by T-3 PCC FREE STATE REPORTING INC.
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-- 50 1 system test engineers, STE's.
2 Now, after that sentence something happened. The 3 prerequisite tests that we identify that involve the start i
4 ' up memorandum were not the only prerequisite tests where 5 craft personnel nad signed off on. There were also others.
6 So I think you need to look at which others and what kind of 7 impact that may have had on your preoperational tests. ,
8 I think I agree with the statement that you make 9 in your action plan here that the consequences associated 10 with the improper validation of prerequisites for prere-11 quisite testing are insignificant.
12 MR. CAMP: Well, that was in relation to those 13 two specific prerequisites. .
6 14 MR. KEIMIG: That's right. And I think that pro-15 bably will be your conclusion when you go and look at the 16 others that were also signed off by craft personnel, but I 17 think you do need to look at them and come to that conclusion 18 yourself. I didn't look at all the prerequisite tests. I 19 just looked at a sampling.
20 MR. CAMP: Okay. Was this, you say this was some-21 thing that was found and was not pointed out in the letter 22 or we misinterpreted?
23 MR. KEIMIG: Well, something was dropped from that 24 particular paragraph in the letter.
NRC 25 MR. CAMP: Okay. So it's something we're not T-3 PCC FREE STATI REPORTING INC.
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e O 1 aware of.
2 MR. WESSMAN: That's correct.
3 MR. CAMP: Okay.
4 MR. KEIMIG: Well, again, -'ou took a very narrow 5 view since we mentioned the start up management's memorandum.
6 I can see how you just easily have done that.
7 MR. CAMP: Another question? III-D , preoperation- .
8 al testing, Issue III-D, basically the observation made by 9 the TRT was that test engineers were not provided the latest to design information on a continuous controlled basis and 11 that's true.
12 We've tried several metheds of document control on 13 the project as well as within start up and what we ended up 14 doing was providing a document r:ontrol satellite center in 15 the start up complex to make access to controlled documents 16 easier without any significant burden. The current program 17 requires that prior to performing tests that the start up 18 engineer verifies that he is using the latest design drawing 19 as well as design change documents to perform that testing.
20 Other drawings used by start up is for reference or 21 for general information which we do not maintain on control 22 basis. In general we feel that the requirements for the 23 start up engineer to maintain the number of drawings that he 24 uses and may in fact use on a one time basis in a controlled NRC 25 condition would be an undue burden.
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82 1 At any rate, a satellite center is established in 2 the start up complex for ease of access to control documents 3 and to further, to further reduce the impact on the start up 4 , engineer for reviewing test procedures and assuring that the i
5! test procedures reflect the as built condition of the plant, t
6 administrative procedures will be revised to require him to 7 begin that process several weeks in advance of the scheduled ,
8 test date to relieve any last minute burdens for updating 9 procedures. And we plan to instruct the test engineers only tol to new administrative procedure requirements.
11 I would like to make one note. This item as I see 12 it doesn't relate to the discussion held last Friday on ccm-13 plex documentation systems or drawings with numerous design 14 changes outstanding against them. For the most part drawings l 15 used by start up from termination drawings to flow diagrams 16 are in good shape in terms of the number of design changes 17 outstanding against them.
18 The are in fact not like hangar packages or conduit 19 layout drawings or those type of drawings. So we're not 20 talking about a large number of design changes against any 21 one drawing used by start up test personnel.
22 MR. KEIMIG: You're not talking about it cn Unit 1 23 any more, but are you sure you'll not be talking about it on 24 Unit 27 Or are you sure that we will not be concerned with NRC 25 that same problem on Unit 27 Based on the discussions at T-3 PCC FREE STATI REPORTING INC.
8 Court Reporting e Depositlens D.C. Aree 161 1901 e Belt. & Anney. 169-6136
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1 that meeting last Friday and your statement with regard to )
2 this issue of large number of design documents are utilized 3 by start up, I would request that you reassess your action 4 plan with regard to this item.
5 MR. CAMP: On Unit 27 6 MR. KEIMIG: And Unit 1, also.
7 MR. CAMP: I'm not sure I understand, Mr. Keimig, .
8 what the concern is.
9 MR. KEIMIG: Well, there were statements made by 10 senior utility personnel at our meeting last Friday to the 11 effect that the records retrieval systems were very complex, 12 I believe the words were. I would like to be assured that 13 those people who subscribe to that don't have any problems 14 with that complexity with regard to the start up engineers 15 and how they may get design documents.
16 MR. CAMP: Well, I was trying to point out a dife 17 ferent thing, the discussion was held last Friday.
18 I think it got a little deeper than MR. KEIMIG:
19 what you -
20 MR. CAMP: Well, it led one to believe that not 21 only is the drawing system and associated design changes, not 22 only the inspection documentation complex but also the 23 design drawings and design changes associated with those 24 drawings as complex and that's not the case. The document NRC 25 retrieval system may be complex and cumbersome to deal with.
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84 i That may be the case. I'm not fami1iar with that 2
because I don't retrieve records from the vault, construction records from the vault on that much frequency. But I do know 3j 4 l for a fact that the drawing system is not complex. We have 5 drawings and design changes against those drawings and it's 6 readily available to anyone that wants them.
7 MR. KEIMIG: However, without going very deeply ,
8 into it, I'm not sure how often a system test engineer may .
g need to refer to construction drawings and I'm not sure that 10 if he does need to refer to a construction drawing that si he'll get the right one after what was said at the meeting 12 .last Friday. My experience is that systems test engineers 13 frequently have to refer to construction drawings.- .
~
14 MR. CAMP: That's for sure.
15 MR. KEIMIG: Now you admit yourself just now or 16 you admitted yourself just now that you don't have that much 17 occasion to test the system for retrieving those types of 18 documents.
19 MR. CAMP: No, I did not say that.
20 MR. KEIMIG: I thought that's what you said.
21 MR. CAMP: Not construction, inspection records.
22 MR. KEIMIG: Nevertheless, I think this entire 23 area needs to be reassessed. I think you probably should get 24 together with Mr. Vega to insure yourself that there are no NRC 25 problems.
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S5 1 MR. CAMP: Well, I'd liko to undsrrtand now bsfors
< 2 I leave here what we're talking about. I'm not talking about 3 construction inspection records. I'm talking about drawings, 4 design documents and that in my mind is not a complex system 5 and no challenge has been made on that.
6 As it was discussed last Friday there was a bit of 7 confusion as to what kind of documentation people were talk-8 ing about. Inspection documentation, I won't talk about 9 that. I don't know about it. Drawings I do know about.
10 MR. GEORGE: If I can interrupt here.
11 MR. KEIMIG: Go ahead.
12 MR. GEORGE: We're going to be giving drawings and 13 documentation and root causes one considerable lot of atten-14 tion. Now, as far as design drawings and flow diagrams and 15 test diagrams that Mr. Camp requires, we have a system 16 whereby any change modificatio..s are at the very minimum on 17 any drawing.
18 What is it? Three or four at the very most would 19 be outstanding. And of course on Unit 2 we have stabilized 20 the design on Comanche Peak. We know what we're going to be 21 doing over there. The evolving design on 1 has caused some 22 complications that are certainly manageable in working 23 change papers to drawings.
24 What Dick is referring to is if you take a construc-NRC 25 tion inspection program where they're inspecting a component T-3 PCC FREE STATE REPORTING INC.
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S6 1 in the plant such as an AMSE hanger, you may have several 2 pieces of change paper to a drawing. But once the verifica-3 tion of the as built condition of the support is there, that 4 , hanger will be there for forty years so there's not really 5 much dynamic need for having that change paper to that 6 particular drawing. Mr. Camp, is that what you're referring 7 to? ,
8 MR. CAMP: I'm trying to allude to the fact that 9 design documents that are used on start up which are flow 10 diagrams, -- logic diagrams, termination drawings, circuit 11 drawings , one line diagrams are not of the same magnitude in 12 terms of design changes against them that other types of 13 drawings are like piping isometrics or hanger isometrics or 14 conduit layout drawings or those type of drawings and also 15 that the drawing control system should not be confused or be 16 construed to be complex as the document, inspection document 17 retrieval system is. We're talking about two different 18 things.
19 MR. GEORGE: But we as a program will be giving a 20 lot of attention to that if that's what you're requesting and 21 I can assure you that.
22 MR. KEIMIG: I just want some assurance that the 23 complexity that was mentioned or discussed at the meeting 24 last Friday does not involve the kind of documents -
NRC 25 MR. GEORGE: We have a 160 man engineering group on T-3 PCC FREE STATI REPORTlhG INC.
12 Court Reporting e Depositions D.C. Ares 1611901 e Belt.& Annep. 169,4134
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v S7 1 .aite. Texas Utilities Generating Company Nuclear Engineering i
2 will be on site for four years of the operations of that 3 plant. Their role in life is to work and post every piece of 4 change paper, examine, rigorously analyze what impact there 5 is and keep those updated on a continuing basis.
6 Beyond that,on Unit 2 we're not going to employ- a 7 system of change paper that we've had to do on the system ,
8 in 1 where we've been on a evolving, unstabilized design and 9 by unstabilized design, that's not negative. We have to enhanced the quality and reliability of Comanche Peak through 11 all these years with TMI and all the chnages that have been 12 made have made that plant safer and safer and safer.
13 However, we're forever criticized with all the 14 change paper that's against it and that's very unfair. And 15 we're certainly putting it to the drawing. Mr. Eisenhut said 16 in the meeting last week and I heard him very clearly, you 17 may be asking inspectors and you're asking this man to 18 interpret drawings that are overcomplicated due to the fact 19 that the change paper is not posted to the drawing.
20 I can assure you as the general manager that won't 21 be the case. It has not really been the case as far as, it's 22 being overstated as how complicated it is. But we will 23 satisfy NRR's requirements on that, Mr. Nam, and your point.
24 MR. CAMP: Well, with that I'm not sure which way NRC 25 to go. You know, but I personally don't perceive the T-3 PCC FREE STATE REPORTING INC.
13 Ceart a:;:%, e Depeeltiens D.C. Ares 141 1901 e Belt.& Annep. 149-4234
u ss 1 document or design drawing process a complex system and I 2 thought, still think that this action plan will address your 3 concerns. If that has expanded as a result of last Friday, 4! then -
5 MR. KEIMIG: I very simply stated I think the dis-6 cussion that was had last Friday at the meeting led me to 7 wonder whether or not the system test engineers may have a ,
a problem with getting correct design information prior to 9 conducting a preoperational or prerequisite test. Now, I 10 think that's a logical thought that comes to anyone's mind 11 and I just would like you to take another look at it and 12 make sure that it does not involve design documents. Very 13 simp.y stated.
14 MR. CAMP: Okay.
I 15 MR. MERRITT: We can handle it.
16 MR. CAMP: That's all I have if there are no other 17 questions.
18 MR. NOONAN: I don't have any further quest'ons.
19 MR. WESSMAN: Is that all that ou all .sp' .:ifically 20 wanted to cover?
21 MR. GEORGE: Yes, sir. That concludes what we 22 propose to present and I guess I would say -
23 MR. NOONAN: I have a couple items. First of all, 24 I'd like to invite any members of the public to feel free to NRC 25 participate and give us comments on this thing. Ms. Garde, T-3 PCC PREE STATI REPORTING INC.
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v S9 1 'since you are there maybe you can go ahead and lead off and 2 represent both CASE and GAP. You may have the floor.
3 MS. GARDE: I think I'll go through my list back-4 wards so we can pick up where we left off on the discussion 5 on documentation. Mr. George, I think and I may be incorrect 6 on this, that you have incorrectly interpreted Mr. Eisenhut's 7 comments at'last 'riday's meeting to only apply to inspection ,
6 8 documentation and the requirement that document retrievabili-4 1 9 ty is necessary in order to complete an accurate inspection.
10 My understanding of your documentation system is 11 that it's a dynamic system and that design documents, change 12 paper-and utilimately inspections are pretty much P.apendent s 13 on the successful implementation of your-document control 14 system and that that system was reorganized to incorporate 15 the start up satellite as well as other satellites which Mr.
16 Camp has made reference to and I think it's the overall sis-17 tem and the complications of the overall system as opposed to 18 one particular part of that, that is inspection documents, 19 I think frankly that the system as which is of concern.
20 designed has no margin for error.
21 That is, if the documentation system itself is, has
~
22 an inherent problem or there is a piece of paper that is not 23 posted along the way that all things beyond that mistake are
' 24 subsequently affected by it and that includes design, in-NRC 25 cludes inspection, includes construction. And so what my T-3 PCC FREE STATE REPORTING INC.
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1 understand of the flaws in your documentation prc; ram is
'2 that where there is mistakes and ultimately in any construc-3 tion propject of this magnitude and dealing with the kinds of 4 incorporation of TMI and design changes, et cetera, there 5 are going to me, there is no margin for error.
6 And there is not an adequate QAQC check on the 7 design program that catches those errors in a timely manner 8 and t hat just complicates it and I think that's what he ,
9 meant. Now, I'm maybe misstating his concern, but that's la ! certainly what my understanding both of his concern is and of 11 the flaws in the documentation program.
12 Let me go back now to the beginning. I think 13 that there's been a great deal of discussion today about a 14 couple main flaws and what I refer to as fundamental flaws 15 in your program plan. One, that it is not in fact an inde-16 pendent review which is something that obviously you can see 17 there isn't any question that it's an inde, pendent review and 18 frankly in f airness to you I Hon' t think that your request 19 for information, Mr. Noonan, clarified that that's what you 20 wanted.
21 I mean, in the past where independent teviews have 22 been required of utility companies, NRR has said that. You 23 come back and tell us what the elements of the independent 24 review program are and there is a vast amount of difference 25 between requiring utility company to develope a point by NRC T-3 PCC PREE STATI REPORTING INC.
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point specific get well program for individual deficiencies 2 and a comprehensive independent review program.
E- 3 There was some question raised about what the 4
criteria is for independent and although I know that some 5 people know this, let me refer you to a February first, 1982 6 letter from Chairman Palladino explaining to Congress what 7 the criteria for independence was. In an overall way that .
8 criteria is divided into three categories.
9 Independence, first of all, which as stated in the 10 letter means that individuals or companies selected must be 11 able to provide an objective, dispassionate, technical 12 judgment provided solely on the basis of technical merit. It 13 also means that design verification programs must be conduc-14 ted by companies or individuals not previously involved with 15 the activities they will now be reviewing.
16 There is an additional delineation of this which 17 goes into the specific individuals involved. Usually NRR 18 requires them to sign a statement of independence, notarizing 19 that they don' t own any stock in t he company, their relatives 20 aren't employed in the company and they've never worked for 21 the project previously before.
22 Those, that independence criteria has been applied 23 most vividly if you will at both Zimmer and Midland although 24 other projects in the country, particular Diablo Canyon, have NRC 25 also been subjected to those kind of independent reviews.
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- v 92 1 That is a big step from the type of thing that NRR suggested 2 in its request for information.
3 However, if that's the criteria which Comanche 4 Peak and TUGCO must be engaged in, I think you'll find a 5 great deal of precedent about what are the next steps to 6 take. Clearly EBASCO does not fall under that category.
7 '
There's not way that EBASCO, given any stretch of the imagin- -
8 -ation will qualify under the Commission's independence poli-9 cy.
10l Essentially you're talking about someone, John's 11 former employer, Tera Corporation, Tory Pines, Stone and 12 Webster was used at Midland, Bechtel reviewed Zimmer. Com-13 pletely different, totally separate operation. I know that 14 you mentioned here that you had Bechtal look at some things 15 but not go into any depth into a particular pronlem that you 16 had..
17 I don't know if that disqualifies them or not. But 18 certainly there are a lot of people out there that could do 19 that type of thing and which would satisfy I'm sure NRR's 20 normal requirements. Second, I don't think that the program 21 is comprehensive and that comment incorporates a kind of 22 overall thread that we've heard that it does not deal with 23 root cause evaluation.
J.
24 Frankly, we think that the only way to deal with NRC 25 root cause evaluation is in a methodology program format T-3 PCC FREE STATE REPORTING INC.
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'1 ahead of time. It's inappropriate to get' half way into an 2i inspection and'then define how far your root cause evaluation 3 will go.
4 Those kinds of guidelines, just like statistical 5 decisions on how much you will look at and what is the margin 6 for error and what is the confidence level are best most 7 prudently decided upon ahead of time so that you know when ,
8 you come back to this table at the end of your conclusion 9 that their going to accept the confidence level that you in 10 fact have employed. It doesn't work to the~ advantage of your 11 company.
12 It only delays the project for NRR to say that, you 13 know, we reject that. It's far better, more prudent, to have 14 that kind of approval ahead of time from whether it's Mr.
15 Eisenhut or Mr. Noonan or whatever combination of review 16 the NRC provides.
17 There was another generic problem that I view in 18 your program as outlined and discussed today in which you say 19 that the data will be made available in any way in which 20 the NRC wishes it to be provided and in some cases you're 21 providing summaries of particular systems or information.
22 I think that in this case that's entirely inappropriate.
23 The summaries aren't going to tell anybody any-24 thing in terms of the kind of detail that the TRT requires
-NRC- 25 or certainly that public confidence is going to require in T-3 PCC FREE STATE REPORTING INC.
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1 order to agree with your assessment data being available on 2 site is a far cry from data bein'g provided on a regular 3 public basis to the NRC so that the public can also evaluate 4
what those findings are.
5 In several projects we've been involved in data has 6 .been, the NRC has required that essentially reports are 7 provided weekly, that copies of the report are p;'vided -
8 simultaneously to the NRC and therefore they are docketed as 9 well as to the company from the independent centractor. I 10 would think that that would be appropriate in :his case.
11 We certainly would object strenously to any kind of 12 conclusion that the NRC would draw based on data not avail-13 Let's see, another category was able for our own review.
l' in this area was that there was some comment made about 15 discussing when you get down there on Friday the TRT report 16 and certainly there are facilities on the plant site, parti-17 cularly the administration building, that if you're going 18 to continue this meeting I would expect that that would be 18 held at a place that we could have someone there if it got 20 into detail.
21 I understand that we're not going to have somebody 22 trucking round the site, you know, looking at everything 23 with you, but if as I think Mr. Merritt indicated that you're 24 going to discuss in detail the TRT report at the site, that 25 NRC that be done in a public forum.
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95 1- There's been two instances in the last two meetings 2 in which reviews or audits if you were have been conducted 3 in which I have no personal knowledge although I certainly 4 don't maintain that I have intimate knowledge of the entire 5 public record in this case. I don't believe that the self-6 initiated evluation using INPO methodology which was dis-7 cussed on Friday has ever been docketed or provided to NRR ,
8 -and that report at other projects has provided a wealth of 9 information because SIE is using INPO methodologies do by to their methodology require some kind of root cause determina-11 tion, overall review of the problems and I think that would 12 be very helpful particularly if you don't have it yet that 13 you would get that and if you would get that,that that would 14 be docketed because those types of things are required, that 15 type of review is usually in, well, it's in every SIE that 16 I've ever reviewed.
17 Second, the Bechtal kind of review I know was not 18 offered into either evidence of the case or is in t he public 19 record at any point. I think that there was some very com-20 ments that provided a lot of insight by a number of the 21 people presenting presentations this morning in which, 22 specifically I'm using two quotes I jotted down, that our 6
23 purpose, TUGCO's purpose, was to prove, improving the exist- l
}
24 ing design and construction was adequate and another I
NRC 25 comment that our belief is that we did it all right in the I i
+
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first case.
2 I think those two comments kind of summarize the 3
' reason that it's imprudent and frankly impossible for you to 4
review your own work and that is why independent audits are ,
5 required. If you come to this project with the already 6
decided position that there aren't any problems and you're 7 '
justifying what is found, then you're not going to get any- ,
8 where in terms of my understanding of what NRR's approach is 8
and I was real concerned that that was the type of attitude 10 that was displayed this morning.
" There was another comment made in discussing one 12 of the specific programs that you're proceeding on that you 13 realize that you were proceeding without NRR approval. That type of at your own risk procession I think includes in it 15 the full knowledge that if that is later rejected that be-16 cause a particular project is already completed, let's say 17 you do a review program based only on the request for infor-18 mction, you could end up in a situation that was just dis-
'8 cussed about the start up procedure, the preprequisite 20 testing.
21 Some, a line or a word was deleted and that entire-22 ly changes the focus of what you spent several weeks looking 23 at. I don't think that, taking action on that information 24 would be particularly appropriate.
NRC I think that's all, although I would, as you know, T-3 PCC FREE STATE REPORTING INC.
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Mr. Eisenhut, put me on a tight time t'able here to get my 2
_ own written letter done and I think just for your own pur-3 poses and discussion I'll read again, John, for you, the 4
kind of five areas that we're proceeding with our analysis 5'
and I won't do that if you don't want me to do that. That's 6 not necessary. I'll put it in a letter later. Would you 7
like me to do that or not? .
8 MR. BECK: It's your speech.
9 MS. GARDE: Okay. Inherent conflict of interest 10 and no organizational independence of personnel involved. I 11 discussed that last time. Two, fundamentally incorrect 12 program objectives and principles. Three, inadequate and 13 unacceptable program processes, methodology and lack of 14 quality assurance and by that I mean the quality assurance 15 specifically for the program plan.
16 Insufficient program record plans, overily narrow 17 and restricted inspection scope. Okay.
18 MR. NOONAN: Just a few comments here. Basically I 19 guess Mr. Eisenhut asked you for your comments by the end of 20 this week. I'd also like to make that same request. Any 21 additional comments you have as a result of this meetings I 22 would e.lso like to have them by the end of the week, if 23 post ible .
24 I do agree, I dr> agree with one thing. I think we 25 NRC do owe the utility what we mean by independence and I will T-3 PCC PREE STATE REPORTING INC.
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UW I plan to make that, make that availbe. I would like to make 2 .one thing here. Most people do not know me in this room now.
3 They don't know the way I operate. I do everything by public 4 meeting.
5 MS. GARDE: Pardon?
6 MR. NOONAN: I do everything by a public meeting.
7 Anything I may have a meeting with the utility and we're '
8 discussing anything in the general area we're talking about 9 will be done by a public meeting. Number two, all informa-10 tion I receive from the utility is docketed.
11 If it's handed to me I will put it in the docket 12 myself. I ask the utility to always put everything in a 13 docket, but if that's not done I will make sure it appears 14 in the docket. I don't know that EBASCO will meet the test 15 for independence or not. That's something for me to deter-16 mine and I'll be talking about that to the utility.
17 One other thing I do not do, I do not ask the 18 utility to bring me another rock. I will make, will make all 19 our letters going to the utility, any concern we have in 20 this TRT review, we'll have it done basically by the end of 21 November. We have put together a schedule that we're going 22 to present to Mr. Eisenhut this afternoon.
23 It's mainly to keep things moving along the track 24 that we've been trying to move along. I think Darrell said i
NRC 25 the other day that we will have all the TRT concerns -- to
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- 99 1 by November and we plan to meet then. I am not in favor of 2 requests for information. I don't particularly like that 3 particular vehicle because I think that's just strictly 4 asking the utility to bring another rock and we go back with 5 more information, that kind of thing.
6 I would like to basically state position on how t
7 we see it. We will, like I said, we will be down in Region ,
8 4 on Thursday. On Friday we're going to the site. It is 9 strictly for me, I have not been to Comanche Peak. I've been W to -- but not Comanche Peak.
11 I will basically be meeting with the resident 12 inspector down there and we will just be walking around 13 doing what we have to do. We will not spend more than about 14 four hours at thd site on Friday. Other than that, is there
~
15 any other comments to be'made by the public? Mr. George,
, 16 do you have any additional comments?
17 MR. GEORGE: We'll be waiting.
18 MR. NOONAN: All right. I guess with that I'll 19 bring the meeting to a close. Thank you gentlemen. Thank 20 you.
21 (Whereupon, at 1:50 p.m. the meeting was adjourned.)
22 23 24 NRC 25 T-3 PCC pagE STATI REPORTING INC.
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1 CERTIFICATE OF PROCEEDINGS 8
1 i
3 This is to certify that the attached proceedings before ;
4 the NRC.
6 5I In the matter of: MEETING OF TUGCO AND NRC/TRT, i COMANCHE PEAK l I
6 Date of Proceeding: October 23, 1984 7
Place of Proceeding: [ff//[,fp/, y,
- 8 were held as herein appears, and that this is the original 9
transcript for the file of the Commission.
10 i
11 3
i 12 13 Georgia Pinkard Official Reporter - Typed
>A4<E AY
'7 Of ficia'# Reporter - Signatiure 18
1Ajm T(anscriberf
" [/
21 22 23 24 g
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HOT FUNCTIONAL TESTING DATA PACKAGES ISSUE Ill.A.1
. DESCRIPTION OF CONCERN IEST DEFICIENCY ICP-PT-02-12 ACCEPTABLE VOLTAGES COULD NOT
" BUS VOLTAGE AND BE ACHIEVED WITH SPECIFIED LOAD SURVEY" TRANSFORMER TAPS, THEY WERE
, CHANGED. SUBSEQUENT ENGINEERING EVALUATION REQUIRED RETURN TO
~ ORIGINAL TAP SETTING, BUT NO RETEST WAS PERFORMED.
BACKGROUND
~
1CP-PT-02-12 -bus VOLTAGE AND LOAD SURVEY" ASSURE PROPER TRANSFORMATIONS ASSURd PRESENCE OF OPTIMUM CURRENT AND VOLTAGE AT BUSES 2
e HOT FUNCTIONAL TESTING DATA PACKAGES ISSUE III.A.1 DESCRIPTION OF CONCERN TEST- DEFICIENCY 1CP-PT-34-05 THREE LEVEL DETECTORS WERE ,
" STEAM GENERATOR REPLACED WITH TEMPORARY ECUIP-NARROW RANGE MENT OF A DESIGN THAT WAS LEVEL VERIFICA- DIFFERENT FROM THAT WHICH WAS TION . 103 BE EVENTUALLY INSTALLED 4
BACKGROUND 1CP-PT-34-05 " STEAM GENERATOR. NARROW RANGE LEVEL VERIFICATION" SETPOINTS FOR ALARMS / CHANNEL TRIPS AT REQUIRED VALUES ,
PROPER COMPARISON BETWEEN LEVEL CHANNELS PROPER INDICATION OF EACH CHANNEL AT UPPER AND LOWER INSTRUMENT TAPS J
n .
,.=.. .-- . . . - . - -.. ---
~
1 HOT FUNCTIONAL TESTING DATA PACKAGES ISSUE III.A.1 l DESCRIPTION OF. CONCERN LTEST DEFICIENCY 1CP-PT-55-05 A LEVEL DETECTOR APPEARED TO
" PRESSURIZER BE OUT OF CALIBRATION DURING LEVEL CONTROL" THE TEST AND WAS REPLACED AFTER THE TEST. THE APPROVED RETEST WAS A COLD CALIBRATION RATHER THAN A TEST CONSISTENT WITH THE' ORIGINAL' TEST OBJECTIVE, WHICH WAS TO OBTAIN SATISFACTORY DATA UNDER HOT CONDITIONS BACKGROUND 1CP-PT-55-0E " PRESSURIZER LEVEL CONTROL" PRESSURIZER LEVEL CONTROL MAINTAIN LEVEL IN ,
MANUAL AND AUTOMATIC CODE 1
77' i .
i HOT FUNCTIONAL TESTING DATA PACKAGES ISSUE III.A.1 TUEC ACTION PLAN ~
REVIEW EACH TEST IDENTIFIED BY TRT CONCERN -
REVIEW THE SEVEN REMAINING HOT FUNCTIONAL PREOPERATIONAL TESTS RETESTS TO MEET TEST OBJECTIVES WILL CONSTITUTE A i
REJECT ri ONE REJECT WILL REQUIRE, SAMPLE REVIEW OF REMAINING 136
- REVIEW OF FIRST SAMPLE OF 20 REVEALS ONE REJECT, I
l REVIEW ADDITIONAL SAMPLE OF 20 4
-
- REVIEW OF SECOND SAMPLE REVEALS ONE REJECT, ALL REMAINING APPROVED TESTS WILL BE REVIEWED l'
t L _ . _ . _ _ _ _ _ _ _ . _ , _ _ _ _ _ . . _ _ _
HOT FUNCTIONAL TESTING DATA PACKAGES ISSUE Ill.A.1 TUEC ACTION PLAN TEST DEFICIENCY REPORTS (TDRS) INITIATED FOR EACH .
OF THE THREE TESTS IDENTIFIED BY TRT l'
REVIEW EACH TEST IDENTIFIED BY TRT AND ASSOCIATED TDRS TO JUSTIFY ACCEPTABILITY OF ACTIONS TAKEN OR ESTABLISH ADDITIONAL RETESTS
- REVIEW THE SEVEN REMAINING PREOPERATIONAL TESTS, CONDUCTED DURING HOT FUNCTION TESTING, NOT PREVIOUSLY REVIEWED BY THE TRT, To VERIFY COMPLIANCE WITH TEST OBJECTIVES IF REVIEW OF SEVEN REMAINING HOT FUNCTIONAL TESTS REVEAL TEST OBJECTIVES NOT MET, OR INADEQUATE JUSTIFICATION IS PROVIDED FOR THREE SPECIFIC CONCERNS, REVIEW St.MPLE OF 20'0F 136 REMAINING IF REV!EW OF FIRST SAMPLE OF 20 REVEAL TEST OBJECTIVES
~
NOT MEY, REVIEW ADDITIONAL SAMPLE OF 20 IF REVIEW OF SECOND SAMPLE REVEAL TEST OBJECTIVES NOT MET, ALL REMAINING APPROVED TESTS WILL BE REVIEWED 9
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JTG APPROVAL OF TEST DATA ISSUE III.A.2
~
DESCRIPTION OF CONCERN .
TO COMPLETE THE PREOPERATIONAL IESTS PROPOSED FOR DEFERRAL AFTER' FUEL LOAD, THE JTG, OR SIMILARLY QUALIFIED GRO.UP, MUST APPROVE THE TEST RESULTS PRIOR TO PROCEEDING TO INITIAL CRITICALITY. THE TRT DID NOT FIND ANY DOCUMENT PROVIDING THAT TUEC IS COMMITTED TO DO THIS ACTIONS' REQUIRED BY TUEC TUEC SHALL COMMIT TO HAVING A JTG, OR SIMILARLY
, .QUALIFIED GROUP, REVIEW AND APPROVE POST-FUELING PREOPERATIONAL IEST RESULTS PRIOR TO DECLARING THE SYSTEM OPERABLE IN ACCORDANCE WITH IECHNICAL i SPECIFICATIONS l
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JTG APPROVAL OF TEST DATA ISSUE Ill.A.2 BACKGROUND TUEC IS COMMITTED TO STATION OPERATING REVIEW COMMITTEE (SORC) APPROVAL OF DEFERRED PRE-OPERATIONAL IEST RESutTS SORC QUALIFICATIONS DEFERRED PREOPERATIONAL IESTS RESULTS REVIEWED
!N SAME MANNER AS INITIAL STARTUP IESTS TUEC ACTION PLAN
- .ALL DEPERRFD PREOPERATIONAL IESTS, EXCEPT IHERMAL EXPANSION, WILL BE COMPLETED PRIOR TO INITIAL CRITICALITY RESULTS OF COMPLETED IESTS AND COMPLETED PORTIONS OF IHERMAL EXPANSION IESTS WILL BE APPROVED BY SORC PRIOR TO INITIAL CRITICALITY t
THERMAL EXPANSION IEST COMPLETED AT 30% POWER PLATEAU .
l THERMAL EXPANSION IEST RESULTS APPROVED BY SORC PRIOR TO ESCALATING TO 50% POWER PLATEAU f
TECHNICAL SPECIFICATIONS FOR DEFERRED TESTS ISSUE III.A.3 DESCRIPTION OF CONCERN
~
IN ORDER TO CONDUCT PREOPERATIONAL IESTS AFTER .
FUEL LOAD, CERTAIN TECHNICAL SPECIFICATION RE-QUIREMENTS CANNOT BE MET, E.G., ALL SNUBBERS WILL NOT BE OPERABLE SINCE SOME WILL NOT HAVE BEEN TESTED
+
ACTIONS REQUIRED BY TUEC EVALUATE THE REQUIRED PLANT CONDITIONS FOR DEFER-RED PREOPERATIONAL IESTS AGAINST THE PROPOSED
( TECHNICAL SPECIFICATION REQUIREMENTS AND OBTAIN L NRC APPROVAL WHERE DEVIATIONS FROM THE TECHNICAL l SPECIFICATIONS ARE NECESSARY l
I T
TECHNICAL SPECIFICATION FOR DEFERRED TESTS ISSUE III.A.3 BACKGROUND PREVIOUSLY EVALUATED SEVEN INCOMPLETE PREOPERATIONAL TESTS FOR DEFERRAL AFTER FUEL LOAD -
.REQu! RED PLANT CONDITIONS IMPACT OF INCOMPLETE PREOPERATIONAL IESTING ON EQUIPMENT OPERABILITY IECHNICAL SPECIFICATION LIMITING CONDITIONS DETERMINE REQUIRED EXCEPTIONS TO IECHNICAL SPECIFICATION
~
TUEC REQUESTED AND RECEIVED APPROVAL TO DEFER SEVEN INCOMPLETE PREOPERATIONAL IESTS TUEC ACTION PLAN PROPOSED ACTION PLAN TO BE REVISED
~
SUBMIT REQUEST FOR SPECIAL IEST EXCEPTION TO TECHNICAL SPECIFICATION FOR SNUBBER OPERABILITY, IF REQUIRED
l TRACEABILITY OF TEST EQUIPMENT ISSUE III.A.4
~
DESCRIPTION OF CONCERN TEST DATA FOR IHERMAL EXPANSION IEST DID NOT ,
PROVIDE FOR TRACEABILITY OF TEMPERATURE MEASURING
, INSTRUMENTS IN THE MANNER SPECIFIED BY STARTUP i PROCEDURE -7 ACTIONS REQUIRED BY TUEC INCORPORATE THE NECESSARY INFORMATION INTO TEST DATA PACKAGE
- ESTABLISH CONTROLS TO ASSURE APPROPRIATE TRACE-ABILITY DURING FUTURE TESTING T
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CONTAINMENT INTEGRATED LEAK RATE TESTING ISSUE _III.B DESCRIPTION OF CONCERN ,
ELECTRICAL PENETRATIONS ISOLATED DURING TEST METHODOLOGY FOR CALCULATION OF TEST RESULTS NOT IN COMPLIANCE WITH FSAR COMMITMENTS ACTIONS REQUIRED BY TUEC IDENTIFY AND JUSTIFY ANY OTHER DIFFERENCES AS A RESULT OF APPLYING ANSI /ANS 56,8 IN LIEU OF ANSI N45,4-1972 (REQUIRED ACTION CLARIFIED BY NRC LETTER DATED AUGUST 27,1984) .
,,-- a ITEM 1.D.1 QC INSPECTOR QUAllFICATIONS DESCRIPTION OF NRC ISSUE LACK OF SUPPORTIVE DOCUMENTATION REGARDING PERSONNEL QUALIFICATIONS IN THE TRAINING AND CERTIFICATION FILES FOR ELECTRICAL QC INSPECTORS LACK OF DOCUMENTATION FOR ASSURING THAT REQUIREMENTS FOR ELECTRICAL QC INSPECTOR RECERTIFICATION WERE BEING MET 5 SPECIFIC EXAMPLES CITED
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TRACEABILITY OF TEST EQUIPMENT I
ISSUE Ill.A.4 l
Q f BACKGROUND REQUIRED INFORMATION NOT INCLUDED IN TEST DATA PACKAGE INFORMATION WAS AVAILABLE FROM ENGINEERING LOG ADMINISTRATIVE CONTROLS FOR TEST EQUIPMENT TRACEABILITY ARE' ESTABLISHED CAUSE OF DISCREPANCY TUEC ACTION PLAN INCLUDE TRACEABILITY DOCUMENTATION IN THE TEST DATA PACKAGE REINSTRUCT TEST ENGINEERS ON EXISTING REQUIREMENTS
-FOR TRACEABILITY OF TEST EQUIPMENT
PRE 0PERATIONAL. TESTING ISSUE III.D
~
DESCRIPTION OF CONCERN CURRENT DESIGN INFORMATION NOT PROVIDED TO TEST ENGINEERS ON A ROUTINE, CONTROLLED BASIS
- ACTIONS REQUIRED BY TUEC ESTABLISH MEASURES TO PROVIDE GREATER ASSURANCE THAT TEST ENGINEERS ARE PROVIDED WITH CURRENT CONTROLLED DESIGN INFORMATION O
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PREREQUISITE TESTING Issuf III.C DESCRIPTION OF CONCERN ,
INITIAL CONDITIONS FOR PREREcurstTE tests VERIFIED BY CRAFT PERs0NNEL
- AcTtytTY IMPROPERLY AUTHORIZED BY STARTUP MANAGEMENT MEMORANDUM
. ACTIONS REQUIRED BY TUEC t
RESCIND MEMORANDUM i Assure No OTHER MEMORANDUM !ssutD IN CONFLICT WITH f
APPROVED PROCEDURES
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PREREQUISITE TESTING ISSUE III.C 2_ -
BACK6ROUND ,
CONFLICTING REQUIREMENTS NOT RECONCILED BY F0LLOWUP PROCEDURE REVISION AFFECTED PREREcuIs!TE TEST PROCEDURES MEGGER IESTING ,
MOLDED CASE CIRCUIT BREAKER' TESTING -
TUEC ACTION Pl.AN i
MEMORANDUM RESCINDED IEST ENGINEERS INSTRUCTED ,
CRAFT PERSONNEL INSTRUCTED Review ALL STARTUP INTEROFFICE MEMORANDA o .'
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CONTAINMENT INTEGRATED LEAK RATE TESTING ISSUE III.B r
BACKGROUND FSAR COMMITMENT TO ANSI N45.4 - 1972 .
INDUSTRY PRACTICE ANSI /ANS 56.8 - 1981 4
FAILED TO AMEND FSAR PRIOR TO TEST KNOWN ACTIONS ACCEPTABLE OPEN SER ITEM TUEC ACTION PLAN COMPARE TEST PROCEDURE TO FSAR AND ANSI N45.4 -
. 1972 TO IDENTIFY OTHER DEVIATIONS PROVIDE JUSTIFICATION FOR OTHER DEVIATIONS
- RESPOND TO NRC LETTER DATEDu A'suST 27, 1984 pN L -
ITEM I.C f ELECTRICAL CONDUIT SUPPORTS !'
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- DESCRIPTION OF NRC ISSUE
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- NON-SAFETY-RELATEQ CONDUITS OF ALL SIZES WERE OBSERVED IN SELECTED . .
i SEISMIC CATEGORY I AREAS WHICH DID NOT APPEAR TO BE SEISMICALLY SUPPORTED SUPPORT INSTALLATION FOR NON-SAFETY-RELATED CONDUITS LESS THAN OR ,
EQUAL TO Z INCHES IN DIAMETER APPEARED INCONSISTENT WITH SEISMIC !
REQUIREMENTS COMPLIANCE WITH REG. GUIDE 1.29 AND FSAR SECTION 3.7B.2.8 IS .! .
REQUIRED WHICH DEFINES THAT NON-SEISMIC ITEMS SHOULD BE DESIGNED l SUCH THAT THEIR FAILURE WILL NOT ADVERSELY AFFECT THE FUNCTION OF j SAFETY-RELATED COMPONENTS I i I
9 4
- ITEM I.C ',
! TUEC ACTION REQUIRED PROVIDE THE RESULTS OF SEISMIC ANALYSIS WHICH DEMONSTRATE THAT
- S ALL NON-SAFETY-RELATED CONDUI
- 'S AND THElB SUPPORT SYSIgMg,8.ATISFY [i l .THE PROVISIONS OF.NEG. bu!DE . 29 AND FSAR SECTION J./n.4. i VERIFY THAT NON-SAFETY-RELATED CONDUITS LESS THAN OR EQUAL TO 2 .
4 INCTES IN DIAMETER, NOT INSTALLED IN ACCORDANCE WITH THE REQUIREMENTS !.!
0F CEG. bUIDE 1.49, SATISFY APPLICABLE DESIGN REQUIREMENTS.
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t' ITEM l',C BACKGROUND -
SEISMIC SUPPORT WAS PROVIDED FOR NON-SAFETY-RELA"ED CONbu!T GREATER THAN 4 INCHES IN DIAMETER FOR AREAS OF CATEGORY STRUCTURES WHICH CONTAINED SAFETY-RELATED EQUIPMENT IN AREAS OF CATEGORY I STRUCTURES WHICH CONTAINED PIPE AND CONDUIT 0F SA[ETY-RELATED SYSTEMS, ALL NON-SAFETY-RELATED CONDUIT, GRFATER THAN Z INCHES IN IAMETE , WAS NON-SEISMICALLY SUPPORTED AND WAS !
EVALUATED BY THE AMAGE TUDY GROUP AND SEISMIC RESTRAINT PROVIDED .
IF IT WAS DETERMINED THAT THEIR FAILURE WOULD BE DETRIMENTAL TO SAFETY- !
RELATED SYSTEMS l' NON-SAFETY-RELATED CONDUIT 2 INCHES OR LESS IN DIAMETER WAS NOT INCLUDED IN OUR SEISMIC SUPPORT PROGRAM OR DAMAGE STUDY EVALUATION l-BECAUSE OF THE FOLLOWING:
SMALL MASS ! '
LIMITED SPANS BETWEEN SUPPORTS .
TYPICAL SUPPORT DESIGN ,
INTERVENING MEMBERS INTERACTION CRITERIA l
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- ITEM I.C ,
TUEC ACTION PLAN -
! PROVIDE
SUMMARY
DOCUMENT WHICH DELINEATES THE PHILOSOPHY AND I IMPLEMENTATION OF THE UAMAGE STUDY EVALUATION OF NON-SAFETY-RELATED j CONDUIT EBQVIDESEIjMICANALYSISWHICHVERIFIESTHESTABILITYDURINGAN
- d5t OF THE 4 INCH AND UNDER DIAMETER CONDUIT WITH THE PRESENT SUPPORT SYSTEM i FIELD VERIFICATION THROUGH A SAMPLING PROGRAM OF THE INSTALLED '
i i CONDUIT SYSTEM TO VERIFY AS-BUILT CONFORMANCE TO ANALYTICAL
! ASSUMPTIONS .
8 1
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ITEM'II.D SEISMIC DESIGN OF CONTROL ROOM CEILING ELEMENTS .
NRC DESCRIPTION OF ISSUE REVIEW OF THE CONTROL ROOM CEILING REVEALED TilAT ARCHITECTURAL INSTALLA-TIONS EXISTED THAT WERE NOT SEISMICALLY SUPPORTED.
NON-SAFETY CONDUIT 2 INCHES AND UNDER IN DIAMETER WAS ABOVE THE CEILING.
IN ACCORDANCE WITH REG. GUIDE 1.29 AND FSAR SECTION 3.7B.2.8 THE NON-SEISHIC ITEMS SHOULD BE DESIGNED IN SUCH A WAY THAT THEIR FAILURE WOULD NOT ADVERSELY' AFFECT THE FUNCTIONS FOR SAFETY-RELATED COMPONENTS OR CAUSE i INJURY TO OPERATORS.
REVIEW OF CALCULATIONS FOR SEISMICALLY RESTRAINED LIGHTING FIXTURES AND SLOPED SUSPENDED CEILINGS DID NOT ACCOUNT FOR POTENTIAL LOADINGS FROM ROTATIONAL INTERACTION BETWEEN CEILING ELEMENTS, NOR WERE SPECIFIC SEISMIC RESPONSE CONDITIONS REVIEWED FOR THE CEILING ELEMENTS.
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i TUEC ACTION REQUIRED , . .
PROVIDE RESULTS OF SEISMIC ANALYSIS WHICH DEMONSTRATES.THAT THE NON-SEISMIC ITEMS.lN THE CONTROL ROOM (OTHER THAN THE SLOPING' SUSPENDED DRYWALLICEILING)' SATISFY THE PROVISIONS OF REG. GUIDE 1,29 AND FSAR ,
SECTION 3.7B.2.8. . .
i PROVIDE AN EVALUATION OF SEISMIC DESIGN ADEQUACY OF SUPPORT SYSTEM FOR l LIGHTING FIXTURES AND DRYWALL CEILING WHICH ACCOUNTS FOR PERTlHENT FLOOR RESPONSE CHARACTERISTICS. i 54
! PROVIDE VERIFICATION THAT ITEMS NOT. INSTALLED IN ACCORDANCE.WITH THE
! REQUIREMENTS OF REG. GUIDE 1.29 SATISFY APPLICABLE DESIGN REQUIREMENTS.
i i PROVIDE RESULTS.0F AN ANALYSIS THAT JUST!FY ADEQUACY OF THE NON-SAFETY ,
I CONDUIT WHOSE DIAMETER IS 2 INCHES OR LESS.
i PROVIDE RESULTS OF AN ANALYSIS WHICH DEMONSTRATES THE FOREGolNG PROBLEMS
! ARE NOT APPLICABLE TO OTHER CATEGORY II AND NON-SEISMIC. STRUCTURES,
! SYSTEMS AND COMPONENTS ELSEWHERE IN THE PLANT.
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! ITEM II.D i
BACKGROUND i
l DESIGN PHILOSOPHY WAS TO SEISMICALLY RESTRAIN ALL MEMBERS WITH LARGE' l MASS.
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ARCHITECTURAL FEATURES WITH SMALL MASSES, IF LOCALIZED FAILURE OCCURRED,
-WOULD NOT BE ADVERSE TO THE OCCUPANTS OF THE CONTROL ROOM. , ,
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. r ITEM II.D' iF TUEC ACTION i FOR THE MOST DIRECT AND TIMELY RESOLUTION, ACTIONS WILL BE TAKEN TO ,
PRECLUDE ANY ITEM FROM FALLING. ;
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SEISMIC ANALYSIS WILL BE PROVIDED WHICH DEMONSTRATES COMPLIANCE W:TH i
. REG. GUIDE 1.29 AND FSAR SECTION 3.7B.2.8.
. HORIZONTAL SEISMIC RESTRAINTS WILL BE INSTALLED.TO PREVENT INTERACTION .j l BETWEEN CEILING SYSTEMS.
THE DRYWALL CEILING WILL BE REPLACED TO EXPEDITE RESOLUTION IN LIEU .
t OF VERIFICATION TESTING. ;
PERFORM EVALUATION ON INDIVIDUAL COMPONENTS OF ACOUSTICAL AND LOUVERED
! CEILINGS AND PROVIDE POSITIVE ATTACHMENT IF FAILURE IS A CONCERN. l
- i VERIFICATION WILL BE PERFORMED BY QUALITY CONTROL ON ALL APPLICABLE j j DESIGN REQUIREMENTS.
PROVIDE
SUMMARY
DOCUMENT WHICH DELINEATES THE PHILOSOPHY AND IMPLEMENTATION l 4 0F THE DAMAGE STUDY EVALUA'10NS MADE THROUGHOUT THE PLANT WHERE POTENTI AL INTERACTIONS EXISTED. j PERFORM A REVIEW OF ARCHITECTURAL SPECIFICATIONS AND DRAWINGS TO CONFIRM l!
i THAT ARCHITECTURAL FEATURES HAVE BEEN APPROPRIATELY EVALUATED IN OUR
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PRESENT DAMAGE STUDY PROGRAM. j l
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ITEM NUMBER II.A r ,i REINFORCING STEEL IN REACTOR CAVITY I
i DESCRIPTION OF ISSUE IDENTIFIED BY NRC
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A PORTION OF.THE REINFORCING STEEL WAS OMITTED IN A REACTOR CAVITY' CONCRE I
i WALL PLACEMENT BETWEEN EL. 812'-0" AND EL. 819'-0 1/2".
I ACTION IDENTIFIED BY NRC 4
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TUEC SHALL PROVIDE AN ANALYSIS VERIFYING THE ADEQUACY OF THE AS-BUILT l CONDITION.
j THE ANALYSIS SHALL CONSIDER ALL' REQUIRED LOAD COMBINATIONS.
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ITEM NUMBER 11'.A 1 BACKGROUND , {.
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! INVESTIGATED DOCUMENTED OCCURRENCE'0F REINFORCING STEEL OMITTED FROM A UNIT #1 REACTOR CAVITY CONCRETE PLACEMENT. .
REINFORCEMENT INSTALLED PER REVISION 2.
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! REVISION 3 ISSUED AFTER CONCRETE PLACEMENT ADDING REINFORCEMENT.
! 1 i
l REINFORCEMENT ADDED AS'A PRECAUTION AGAINST CRACKING OF CONCRETE WHICH
! MIGHT OCCUR IN THE VICINITY 0F THE. NEUTRON DETECTOR tunes SHOULD A LOSS
$ OF COOLANT ACCIDENT OCCUR.*
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BROWN & ROOT ISSUED NON CONFORMANCE REPORT CP-77-6.
l j Gians & HILL EVALUATION INDICATED OHISSION DID NOT IMPAIR INTEGRITY OF THE STRUCTURE.
REVISION 4ISSUEDTOPLACEAPORTIbHOFTHEREINFORCEMENTINTHENEXT l CONCRETE PLACEMENT.
- TRT REQUESTED DOCUMENTATION OF ANALYSIS PERFORMED SUPPORTING 61BBS & HILL ,
CONCLUSION.
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ITEM NUMBER ll.A 1
TUEC ACTION PLAN
- AN ANALYSIS OF "AS-BUILT" REACTOR WALL WILL BE PERFORMED. IHROUGH ANALYSIS IT WILL BE ESTABLISHED THAT STRUCTURAL INTEGRITY OF WALL IS NOT COMPROMISED.
, GIBBS & HILL WILL PERFORM THE ANALYSIS AND DESI'GN REVIEW THE CALCULATIONS.
AN EXTERNAL ORGANIZATION WILL PERFORM ADDITIONAL DESIGN REVIEW OF
- - CALCULATIONS. !
) EXPANDED REVIEW OF ALL INSTANCES OF REBAR OMISSIONS WILL BE PERFORMED.
l IT WILL BE ASCERTAINED THAT IN EVERY SUCH CASE PROPER ENGINEERING -
[ EVALUATION AND DOCUMENTATION DOES EXIST.
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ITEM l'I.B i,
CONCRETE COMPRESSIVE STRENGTH i
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I NRC DESCRIPTION Of ISSUE i-ALLEGATION OF FALSIFICATION OF CONCRETE COMPRESSIVE STRENGTH TEST ,
j RESULTS COULD NOT BE PROVEN VALID OR INVALID i ~
- CONCRETE STRENGTH LOWER THAN THAT,SPECIFIED IN THE DESIGN MAY REDUCE I~
l THE LOAD RESISTING CAPACITY OF STRUCTURES ;.
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! i l ACT. ION REQUIRED BY NRC -
- TUEC SHOULD DETERMINE AREAS WHERE CONCRETE WAS PLACED BETWEEN JANUARY l 1976 AND FEBRUARY 1977 AND PROVIDE A PROGRAM TO ASSURE ACCEPTABLE l CONCRETE STRENGTH I
TEST PROGRAM TO INCLUDE RANDOM SCHMIDT HAMMER TEST ON CONCRETE IN AREAS
! WHERE SAFETY IS CRITICAL
- ADDITIONAL SCHMIDT HAMMER TEST ON CONCRETE NOT WITHIN THIS SPECIFIED TIME FRAME l
COMPARISON OF THE TEST RESULTS TO DETERMINE IF ANY SIGNIFICANT VARIANCE IN STRENGTH OCCURS l * ;
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i BACKGROUND ALLEGED FALSIFICATION OF COMPRESSIVE STRENGTH TEST 4
! NRC REGION IV INVESTIGATED l
l '0THER ALLEGATIONS -
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AIR CONTENT j SLUMP j -
DEFICIENT AGGREGATE GRADING l
CONCRETE IN THE MIXER TOO LONG l Ev!DENCE SUGGESTS FALSIFICATION DID NOT OCCUR i
MATTER CANNOT BE RESOLVED BASED ON COMPRESSIVE STRENGTH TEST IF
! DOUBT EXISTS DUE TO FALSIFICATION i
- NEED CONFIRMATORY EVIDENCE ON TEST RESULTS i i i
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4 ITEM II.B i,
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TUEC ACTION PLAN ,
SCHMIDT (REB 0UND) HAMMER TEST, A NON-DESTRUCTIVE TEST,' WILL BE PERFORMED h
AS REQUESTED BY TRT -
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327 PLACEMENTS IN CATEGORY I - SAFETY-RELATED STRUCTURES DURING SUSPECT TIME FRAME 50 TESTS TO BE PERFORMED, BASED ON RECOMMENDED SAMPLE SIZES PER MIL-STD-195D 50 TESTS OUTSIDE QUESTIONED TIME FRAME STATISTICAL ANALYSIS TO DETERMINE IF A SIGNIFICANT VARIANCE EXISTS BETWEEN THE TWO DATA SETS 4
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. ITEM II.C .-
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MAINTENANCE OF AIR GAP BETWEEN CONCRETE STRUCTURES NRC DESCRIPTION OF ISSllE i
! ADEQUACY OF THE AIR GAP COULD NOT BE DETERMINED SINCE:
i - AVAILABLE DOCUMENTATION DID NOT PROVIDE LOCATION OR EXTENT OF
- REMAINING DEBRISi
- ADDITIONAL SITE FIELD INVESTIGATIONS WERE NOT DOCUMENTED ON
{ PERMANENT RECORDS. ,
- PERMANENT INSTALLATION OF ELASTIC JOINT FILLER HAD NOT BEEN SHOWN TO l BE CONSISTENT.WITH SEISMIC ANALYSIS ASSUMPTIONS AND DYNAMIC MODELS USED i TO ANALYZE THE BUILDINGS.
l TUEC ACTION REQUIRED ,
i
! PERFORM INSPECTION OF THE AS-BUILT CONDITION TO CONFIRM THAT ADEQUATE i SEPARATION FOR ALL SEISMIC CATEGORY I STRUCTURES HAS BEEN PROVIDED.
I
- PROVIDE RESULTS OF ANALYSES FOR ACCEPTANCE OF ELASTIC JOINT FILLER AND DEBRIS BETWEEN CONCRETE STRUCTURES CONSIDERING CHANGES IN SEISMIC RESPONSE j OR DYNAMIC RESPONSE CHARACTERISTICS OF THE CATEGORY I STRUCTURES, COMPONENTS AND PIPING WHEN COMPARED WITH THE RESULTS OF THE ORIGINAL l.
{ ANALYSES.
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l ITEM II.C BACKGROUND SEPARATION BETWEEN CATEGORY I STRUCTURES IS REQUIRED IN THE FSAR TO PREVENT UNACCEPTABLE SEISMIC INTERACTION DURING AN SSE ALL SEPARATIONS BETWEEN CATEGORY I BUILDINGS AND BETWEEN CATEGORY I AND NON-CATEGORY I STRUCTURES FOR THE WHOLE PLANT WILL BE INSPECTED IHE AS-BUILT SEPARATION CONDITION,WILL BE DOCUMENTED FOR ENGINEERING REVIEWJ INACCESSIBLE AREAS WILL BE CONSERVATIVELY ESTIMATED FOR SIZE AND NATURE OF DEBRIS 9 O 4
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j- .L ITEM II.C 1
i ' TUEC ACTION PLAN QC INSPECTION OF AIR GAP BETWEEN CATEGORY I STRUCTURES AND CATEGORY I AND NON-CATEGORY I STRUCTURES WILL BE REPERFORMED AND DOCUMENTED ANY DEBRIS ENCOUNTERED MAY BE REMOVED AFTER DOCUMENTATION BY QC !
ENGINEERING EVALUATION OF DOCUMENTED INSPECTIONS FOR IMPACT ON SEISMIC l' AND DYNAMIC RESPONSES i i EVALUATION WILL DETERMINE CHANGE IN FREQUENCY FROM ORIGINAL FUNDAMENTAL MODE AND EVALUATE STRUCTURAL INTERACTION EFFECTS. BASED ON THE SIGNIFICANCE OF THE FREQUENCY CHANGE, FURTHER ENGINEERING ACTIONS WILL
, BE DETERMINED FOR EVALUATION OF' IMPACT ON COMPONENTS AND PIPING j REMOVE ANY DEBRIS WHICH SIGNIFICANTLY AFFECTS THE ORIGINAL DESIGN i CALCULATIONS
} REVIEW PROJECT PROCEDURES FOR ESTABLISHMENT OF REQUIREMENTS FOR i MAINTENANCE OF ADEQUATE SEPARATION CONDITIONS l EVALUATE NEED FOR FSAR UPDATE BASED ON AS-BUILT CONDITIONS i .
ITEM II.E i
- REBAP. IN FUEL HANDLING BUILDING DESCRIPTION OF ISSUE IDENTIFIED BY NRC. .
l UNAUTHORIZED CUTTING OF REBAR ASSOCIATED WITH THE INSTALLATION OF THE ,
. TROLLEY PROCESS AISLE RAILS IN THE FUEL HANDLING BUILDING MAY HAVE
! OCCURRED. I h
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- I l LOSS OF THE REBAR MAY REDUCE THE LOAD RESISTING CAPACITY OF THE CONCRETE- ', '
l FLOOR SLAB. .
- i .
i ACTION IDENTIFIED BY NRC !
4 TUEC SHALL PROVIDE INFORMATION TO DEMONSTRATE THAT ONLY #18 REBAR IN ,
i 1ST LAYER WAS CUT, t i !
i OR i
PROVIDE DESIGN CALCULATIONS TO DEMONSTRATE THAT STRUCTURAL INTEGRITY IS MAINTAINED EVEN IF #18 REPARS IN BOTH ,
IST AND 3RD LAYERS WERE CUT.. j i
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ITEM II.E -
BACKGROUND IN PROCESS AISLE AREA 0F FUEL BUILDING AT EL. 810'-6", FLOOR SLAB TOP
! REINFORCEMENT HAS 3 LAYERS. 1ST AND 3RD LAYERS CONSIST OF #18 REBARS~
RUNNING EAST-WEST. 2ND LAYER IS #11 REBAR RUNNING NORTH-SOUTH.
LAYOUT OF TROLLEY RAILS AND TOP SLAB REINFORCEMENT AS WELL AS SPACING OF
{ HILTI BOLTS IS SUCH THAT BOLTS WILL NOT ENCOUNTER #11 REBARS RUNNING NORTH-SOUTH IN 2ND LAYER. BUT IF HOLES WERE DRILLED 9" DEEP, DEPTH ,
WOULD CUT l-#18 REBAR IN EACH IST AND 3RD LAYER AT ONE RAIL LOCATION,
! DUE TO SPACING OF RAILS AND SPACING OF #18 REBARS RUNNING EAST-WEST. -
ANALYTICAL APPROACH WILL BE USED TO RESOLVE THIS SITUATION. ,
- TUEC ACTION PLAN t 4
DESIGN CALCULATIONS WILL BE PERFORMED TO ESTABLISH STRUCTURAL ADEQUACY OF SLAB EVEN IF 1-#18 IN IST AND 3RD LAYER IS CUT AT ONE RAll LOCATION. ,
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! A REVIEW OF THE PROGRAMS CONTROLLING REBAR CUTTING WILL BE PERFORMED.
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PRE 0PERATIONAL TESTING ISSUE III.D
- BACKGROUND.
TEST ENGINEER USE OF DESIGN DOCUMENTS TESTING GENERAL INFORMATION SATELLITE DOCUMENT CONTROL
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-TUEC ACTION PLAN REVISE ADMINISTRATIVE PROCEDURE
-INSTRUCT TEST ENGINEERS ON NEW REQUIREMENTS D
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r COMANCHE PEAK RESPONSE TEAM ORGANIZATION PERSONNEL QUALIFICATION
SUMMARY
OF PROGRAM PROCESS ENGINEERING AND QA DOCUMENTATION 9
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OF PROGRAM PROCESS
- 1. RECEIPT OF NRC-TRT REQUEST FOR ADDITIONAL INFORMATION.
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- REVIEW TEAM LEADER.
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- 3. ASSIGNMENT OF-ISSUE COORDINATOR.
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- 4. OBTAIN ADDITIONAL, CLARIFYING INFORMATION FROM 4- NRC-TRT TO ENSURE FULL UNDERSTANDING OF THE CONCERN (IFNECESSARY[.
- 5. DEVELOP ACTION PLAN TO RESOLVE CONCERN USING GUIDANCE EROVIDED IN ATTACHMENT 2. ,
l 6.- ACTION PLAN APPROVED BY APPROPRIATE RrviEW TEAM LEADER, PROGRAM MANAGER AND SENIOR REVIEW IEAM.
- 7. IMPLEMENT ACTION PLAN.
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- 8. IDENTIFY ROOT CAUSE AND POTENTIAL GENERIC IMPLICATIONS.
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- 9. CONCURRENCE OF APPROPRIATE REVIEW IEAM LEADER, PROGRAM MANAGER AND SENIOR REVIEW IEAM IN ROOT CAUSE DEFINITION AND POTENTIAL GENERIC IMPLICATIONS ASSESSMENT.
- 10. DEVELOP REVISED ACTION PLAN (IF APPLICABLE).
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- 11. REVISEDACTiONPLANAPPROVEDBYAPPROPRIATEREVIEW TEAM LEADER, PROGRAM MANAGER AND SENIOR REVIEW TEAM (IF APPLICABLE).
- 12. IMPLEMENT REVISED ACTION PLAN (IF APPLICABLE).
- 13. DEVELOP ACTION PLAN RESULTS REPORT USING GUIDANCE PROVIDED IN ATTACHMENT 3.
- 14. ACTION PLAN RESULTS REPORT APPROVED BY APPROPRIATE REVIEW IEAM LEADER, PROGRAM MANAGER AND SENIOR REVIEW IEAM.
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- 15. IMPLEMENT NECESSARY ADDITIONAL CORRECTIVE ACTION (IF APPLICABLE).
- 16. IMPLEMENT NECESSARY CORRECTIVE ACTION TO PREVENT RE0CCURRENCE IN THE FUTURE (IF APPLICABLE).
- 17. ASSESS ACTION PLAN RESULTS REPORT AS PART OF COLLECTIVE SIGNIFICANT EVALUATION.
- 18. IMPLEMENT NECESSARY ACTIVITIES STEMMING FROM THE COLLECTIVE SIGNIFICANCE EVALUATION.
- 19. SUBMIT FINAL REPORT TO NRC'.
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TYPES OF ACTIVITIES PHASED REVIEWS SAMPLING TECHNIQUES TRT SPECIFIC EXAMPLES CHANGES TO ACTION PLANS
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. . .,..w. . .... .-.....,...L.m-INTRODUCTION OF SPEAKERS e i ELECTRICAUINSTRUMENTATION LEADER L. M. POPPLEWELL QA/QC LEADER A. VEGA CIVIUSTRUCTURAL LEADER C. R. HOOTON
- ISSUE Ic, Ilo COORDINATOR M. R. MCBAY TESTING PROGRAMS LEADER R. E. CAMP SCHEDULE .
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TUEC MkE"ING WITH NRC STAFF OCTOBER 19,1984 AGENDA INTRODUCTORY REMARKS .
M.D. SPENCE CPRT PROGRAM OVERVIEW J.T. MERRITT ISSUE-SPECIFIC ACTION PLAN PRESENTATIONS L.M. POPPLEWELL C.R. H00 TEN M.R. :MCBAY .
A. VEGA R.E. CAMP
SUMMARY
J.T. MERRITT CLOSING REMARKS M.D. SPENCE s
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k ITEM 1.D.1 QC INSPECTOR QUAllFICATIONS-i .TUEC ACTION REQUIRED 4
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- TUEC SHALL REVIEW ALL ELECTRICALLOC lNSPECTOR TRAINING, QUALIFICATIONS, ,
CERTIFICATION AND RECERTIFICATION FILES AGAINST THE PROJECT REQUIREMENTS -
l II i TUEC SHALL PROVIDE INFORMATION IN A FORM THAT CLEARLY SHOWS THAT THE REQUIREMENTS HAVE BEEN MET'BY EACH ELECTRICAL QC INSPECTOR ,
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- IF AN INSPECTOR DOES NOT MEET REQUIREMENTS, TUEC SHALL REVIEW THE
- j. 4 RECORDS TO DETERMINE ADEQUACY OF INSPECTIONS AND ASSESS IMPACT ON THE l SAFETY OF THE PROJECT 2
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ITEM l.D.1' i
ADDITIONAL NRC COMMENTS 4
'I IDENTIFIED DEFICIENCIES HAVE GENERIC IMPLICATIONS TO OTHER CONSTRUCTION
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ITEM I.D 1 BACKGROUND
- CPSES PROJECT REQUIREMENT REVISED IN.1981 TO REFLECT SUBSEQUENT COMMIT-
! MENT TO ANSI N45.2.6 AND REGULATORY GUIDE 1,58
. REVIEWED BY ASME-AUTHORIZED NUCLEAR INSPECTOR (ANI). l i, <
CPSES QC INSPECTOR CERTIFICATION PROCESS REFLECTS A MORE CONSERVATIVE ,
APPROACH THAN THE COMMON PRACTICE IN THE NUCLEAR INDUSTRY l I j TUEC REVIEW OF SPECIFIC EXAMPLES CITED BY NRC-TRT INDICATES THAT SUBJECT INSPECTORS MET PROJECT REQUIREMENTS I
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9 ITEM I.D.1 TUEC ACTION ;;
1 TUEC IS CONDUCTING AN EXPANDED REVIEW OF QC INSPECTOR CERTIFICATION RECORDS AGAINST PROJECT REQUIREMENTS'AND WILL ASSURE THAT TRAINING / CERTIFICATION 1
I FILES ARE COMPILED IN A FORMAT THAT CLEARLY AND CONCISELY DEMONSTRATES THAT PROJECT REQUIREMENTS ARE MET i'
SCOPE OF REVIEW WILL INCLUDE,ALL ELECTRICAL OC INSPECTORS WHO HAVE EVER f WORKED AT CPSES AND ALL OTHER QC INSPECTORS (EXCEPT ASME INSPECTORS)
CURRENTLY WORKING AT CPSES
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' ITEM 1.D 1 TUEC ACTION (CONTINUED)
PHASE ONE REVIEW OF ALL AVAILABLE DOCUMENTATION CHECKLIST WITH PREDETERMINED ATTRIBUTES CERTIFICATION
SUMMARY
FORM PERFORMED BY TUGC0 AUDIT GROUP (TAG)
PHASE TWO f
EVALUATE CERTIFICATION RECORDS NOT VERIFIED IN PHASE ONE SPECIFIC EVALUATION CRITERIA l
, BASES FOR DECISIONS DOCUMENTED ;
PERFORMED BY SPECIAL EVALUATION TEAM PHASE THREE ,
IF INSPECTORS ARE FOUND WHOSE QUALIFICATIONS CANNOT BE DEMONSTRATED, l
L REVIEW OF INSPECTION RECORDS WILL BE PERFORMED TO DETERMINE IMPACT l -
1 ON SAFETY OF THE PROJECT PERFORMED BY TUGC0 QUALITY ENGINEERING O
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u ITEM 1.D.2 GUIDELINES FOR ADMINISTRATION OF QC INSPECTOR TESTS NRC DESCRIPTION OF ISSilE LACK OF GUIDELINES AND PROCEDURAL REQUIREMENTS FOR TESTING AND CERTIFYING ;
ELECTRICAL QC INSPECTORS ,
ACTION REQUIRED BY NRC TUEC SHALL DEVELOP A TESTING PROGRAM FOR ELECTRICAL QC INSPECTORS WHICH PROVIDES ADEQUATE ADMINISTRATIVE GUIDELINES, PROCEDURAL REQUIREMENTS AND TEST FLEXIBILITY TO ASSURE THAT SUITABLE PROFICIENCY IS ACHIEVED AND MAINTAINED ,
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ITEM I.D,2 j BACKGROUND CURRENT PROCEDURES ALLOW QE PERSONNEL TO DEVELOP TESTS APPROPRIATE j TO THE SPECIFIC CIRCUMSTANCES I ADDITIONAL GUIDELINES WOULD REDUCE POTENTIAL FOR INCONSISTENCIES TUEC ACTION RELEVANT PROCEDURES WILL BE REVIEWED AND APPROPRIATELY REVISED TO PROVIDE MORE DEFINITIVE GUIDELINES THESE PROCEDURES PERTAIN TO THE TRAINING AND CERTIFICATION OF ALL INSPECTORS CERTIFICATION TESTS CURRENTLY IN USE WILL BE REVIEWED AND APPROPRIATELY REVISED TO REFLECT MORE DEFINITIVE GUIDELINES O
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t ITEM 1.A.1 HEAT SHRINKABLE CABLE INSULATION DESCRIPTION OF NRC ISSUE CONFUSION AS TO WHEN THE INSTALLATION OF HEAT SHRINKABLE SLEEVES .
WAS TO BE DOCUMENTED TUEC ACTION REQUIRED CLARIFICATION OF PROCEDURAL REQUIREMENTS ADDITIONAL INSPECTOR TRAINING
! ASSURANCE THAT SLEEVES ARE INSTALLED WHERE REQUIRED l
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-lTEM I.A.1 [
! BACKGROUND IRS DO NOT CONSISTENTLY INDICATE WITNESSING OF INSTALLATION AS AN ATTRIBUTE POSSIBLE UNCERTAINTY EXISTS AS TO WHEN DOCUMENTATION IS REQUIRED NO INSTANCES OBSERVED WHERE SLEEVES WERE REQUIRED AND WERE NOT ADDRESSED BY INSPECTION REPORTS '
TUEC ACTION t
REVISE INSTALLATION PROCEDURE REVISE INSPECTION PROCEDURE TRAIN AND CERTIFY INSPECTORS INITIATE INSPECTION SAMPLING PROGRAM TO ASSURE SLEEVES ARE PROPERLY INSTALLED e
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i ITEM I.A.2 i
INSPECTION REPORTS ON BUTT SPLICES
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i DESCRIPTION OF NRC ISSUE I i-LACK OF DOCUMENTATION OF BUTT SPLICE INSPECTIONS j SEVERAL SPECIFIC EXAMPLES CITED I TUEC ACTION REQUIRED ASSURE'THAT REQUIRED INSPECTIONS HAVE BEEN PERFORMED AND DOCUMENTED 2
VERIFY THAT BUTT SPLICES ARE IDENTIFIED ON DRAWINGS VERIFY THAT BUTT SPLICES ARE IDENTIFIED WITHIN THE APPROPRIATE PANELS i
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.lTEM I.A.'2 BACKGROUND CABLES-SPLICED IN ACCORDANCE WITH DESIGN DOCUMENTS ADDITIONAL INSPECTION REPORTS REVIEWED REQUIRED INSPECTIONS WERE DOCUMENTED TUEC ACTION PHASE I - VERIFY EXISTENCE OF IRS DOCUMENTING SPLICE INSTALLATION REVIEW ALL INSPECTION REPORTS FOR THE 12 CABLES REVIEWED BY TRT REVIEW ALL INSPECTION REPORTS ON 12 ADDITIONAL CABLES IF DOCUMENTATION EXISTS, CLOSE REPORT f
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ITEM 1.A.2 TUEC ACTION (CONTINUED)
PHASE II - FURTHER REVIEW IF PHASE I DOES NOT CLOSE ISSUE REVIEW DRAWINGS AND DESIGN CHANGES SHOWING SPLICES INSPECT TO ASSURE THAT.ALL BUTT SPLICES ARE INSTALLED IN APPROPRIATE PANELS 9
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6 ITEM l.A.3 BUTT SPLICE QUALIFICATION P
DESCRIPTION OF NRC ISSUE LACK OF SPLICE QUALIFICATION REQUIREMENTS
- VERIFICATION OF OPERABILITY OF CIRCUITS IN WHICH SPLICES OCCUR THEC ACTION REQUIRED
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- DEVELOP PROCEDURES TO ASSURE QUALIFICATION TO SERVICE CONDITIONS
- DEVELOP PROCEDURE TO ASSURE THAT SPLICES ARE NOT LOCATED ADJACENT
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- INSTALLATION PROCEDURES DO NOT ADDRESS OPERABILITY OF CIRCUITS WITH l SPLICES START-UP AND TEST PROGRAM ADDRESSES CIRCUIT OPERABILITY 1
- INSTALLATION PROCEDURES DO NOT ADDRESS QUALIFICATION OF SPLICES FOR j SERVICE CONDITIONS MILD ENVIRONMENT CONDITIONS d
SAME CONSTRUCTION AS TERMINAL LUGS l '
LOW POWER APPLICATIONS AS PER FSAR t
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- CONTINUITY CHECK TO BE ADDED TO CONSTRUCTION INSTALLATION PROCEDURE i .
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j QUALIFICATION DOCUMENTATION WILL BE DEVELOPED l
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- INSPECTION WILL BE MADE TO IDENTIFY AND STAGGER SPLICES l
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j ITEM I.A.4 AGREEMENT BETWEEN DRAWINGS AND FIELD TERMINATIONS DESCRIPTION OF NRC ISSUE i PHYSICAL LOCATION OF SELECTED CABLE TERMINATIONS DID NOT AGREE WITH .
DRAWINGS TUEC ACTION REQUIRED INSPECT ALL SAFETY-RELATED TERMINATIONS IN CABLE SPREAD ROOM CABINETS IN CONTROL ROOM CABINETS VERIFY LOCATIONS ARE ACCURATELY DEPICTED ON THE DRAWINGS e
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ITEMl'.AN :
! BACKGROUND NRC SELECTED CABLES REVIEWED i
i DESIGN CHANGES REVIEWED ,
TEMPORARY MODIFICATIONS REVIEWED l FINDING I
3CABLESAPPEARTOBECONNECTEDbORRECTLY f -
1 CABLE DESIGNATED AS " SPARE" 1CABLECONNECTEDCORREbTLYBUTCOLORCODEONDRAWINGINACCURATE l -
1 CABLE HAD INCORRECT TERMINATION I
' ISSUES HAVE NO ADVERSE SAFETY SIGNIFICANCE l
l TUEC ACTION l.
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- CONDUCT SAMPLE INSPECTION OF 500 SAFETY-RELATED TERMINATIONS
. REVIEW DRAWINGS FOR ACCURATE INCORPORATION OF DESIGN CHANGES RECONblLEAPPARENTDIFFERENCESBETWEENINSPECTIONANDDRAWINGREVIEW l
4 EXPAND SAMPLE AS NECESSARY IF CONFIDENCE LEVEL IS NOT AClllEVED
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' ITEM I',A,5 i l
NCR'S ON VENDOR-INSTALLED AMP TERMINAL LUGS . .
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DESCRIPTION OF NRC ISSUE l-l MONCONFORMANCE REPORTS CONCERNING VENDOR LUGS IMPROPERLY CLOSED TUEC ACTION REQUIRED
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- f REEVALUATE AND REDISPOSITION ALL NCR'S RELATED TO VEND 0R LUGS i
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! BACKGROUND
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EQUIPMENT INVOLVED FROM 2 VENDORS i
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- LUG VENDOR CONTACTED IN 1981 AND IN APRIL 1984 l
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- LUG VENDOR GAVE SPECIFIC CRITERIA ,
NONCONFORMANCES DISPOSITIONED USING VENDOR CRITERIA 1
TUEC ACTION ,
- ALL NONCONFORMANCES REGARDING BENT LUGS WILL BE REDISPOSITIONED J
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ITEM l'B.1 ..
FLEXIBLE TO FLEXIBLE CONDUIT SEPARATION ,
! DESCRIPTION OF NRC ISSUE
! MINIMUM SEPARATION REQUIREMENTS NOT MET 1
l MAIN CONTROL BOARDS l -
SAFETY-RELATED CABLES WITHIN FLEX 1BLE CONDUITS l
! TUEC ACTION REQUIRED i . _.
REINSPECT ALL PANELS CONTAINING REDUNDANT SAFETY-RELATED CABLES AND CORRECT ANY VIOLATIONS OR PR0v!DE. ANALYSIS SHOWING THAT THE FLEXIBLE CONDUIT IS ACCEPTABLE AS .
A BARRIER ;
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ITEM I.B.1 BACKGROUND ,
SWITCH MODULES ON THE MAIN CONTROL BOARD REQUIRE SLACK IN THE CABLES FOR:
REMOVAL / REPLACEMENT ,
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REMOVAL FOR TESTING l
e REMOVAL FOR ADJUSTMENT FLEXtBLE METAL CONDUITS USED TO PROVIDE APPROPRIATE SEPARATION SUFFICIENT DOCUMENTATION DOES NOT EXIST QUALIFYING THE FLEXIBLE CONDUli .
i AS A BARRIER TUEC ACTION
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PROVIDE SUFFICIENT DOCUMENTATION, INCLUDING ANALYSES, NECESSARY TO QUALIFY THE FLEXIBLE CONDUIT AS A BARRIER t-4 4
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. ITEM I.B.2 i
FLEXIBLE CONDUIT TO CABLE SEPARATION DESCRIPTION OF NRC ISSUE I-
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MINIMUM SEPARATION CRITERIA NOT MET IN MAIN CONTROL PANEL BETWEEN:
SAFETY-RELATED CABLES AND SAFETY-RELATED CABLES WITHIN FLEXIBLE CONDUIT l
SAFETY-RELATED CABLES WITHIN FLEXIBLE CONDUITS AND NON-SAFETY-RELATED CABLES SAFETY-RELATED CABLES AND NON-SAFETY-RELATED CABLES
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f ITEM i.B.2 i'
TUEC ACTION REQUIRED REINSPECT ALL PANELS CONTAINING SEPARATE CABLES AND CABLES WITHIN FLEXIBLE CONDUIT AND CORRECT ANY VIOLATIONS ,
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i ITEM I.B.2 BACKGROUND ISSUE CONCERNS CABLE IN FREE AIR TO FLEXIBLE CONDUIT SEPARATION TUEC ACTION -
PROVIDE ANALYSIS SHOWING THAT INSTALLATION IS ADEQUATE AND ACCEPTABLE 9
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ITEM 1.B.3 9.
3 CONDUIT TO CABLE TRAY SEPARATION i ;:
! DESCRIPTION OF NRC CONCERN l:
! ANALYSIS SUBSTANIIATING SE Rail 0N BETWEEN CONDUIT AND CABLE TRAYS l;
! HAS NOT BEEN SUBMITTED TO C ,;
i TUEC ACTION REQUIRED i l:
i SUBMIT ANALYSIS i; 1
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ITEM 1.s.3 '.
BACK6RolNID i-gaA I ITERIA BASED ON IEEE 384-1974 AND REG. Gu!DE 1.75 DOCUMENTS EXIST WITHIN Glass a HILL SUBSTANTIATING THE SEPARATION .
CRITERIA l; CRITERIA WERE NOT SUBMITTED FOR NRC REVIEW ;
. I TUEC ACTION e
l SusMIT SImas a HILL DOCUMENTS l
l SUBMIT SANDIA REPORT l i -
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,I ITEM l a.4 BARRIER REMOVAL
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DESCRIPTION OF NRC ISSUE CERTAIN BARRIER MATERIAL IN MAIN CONTROL BOARD HAD BEEN REMOVED l
TUEC ACTION PLAN REPLACE THE BARRIER MATERIAL ASSURE THAT REDUNDANT FIELD WIRING PEETS MINIMUM SEPARATION CRITERIA ;
ADDITIONAL ACTION CONTINGENT ON IDENTIFICATION OF ROOT CAUSES t I
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VEND 0R-SUPPLIED BARRIER MATERIAL HAD BEEN REMOVED I
TUEC ACTION l
REPLACE BARRIER MATERIAL REWORK CABLES TO RESOLVE SEPARATION CRITERIA VIOLATIONS 1
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- s. HOT FUNCTIONAL TESTING DATA PACKAGES ,
ISSUE III.A.1
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. DESCRIPTION OF CONCERN v
IN REVIEWING TEST DATA PACKAGES, THE TRT FOUND s.
THAT CERTAIN TEST OBJECTIVES WERE NOT MET FOR AT LEAST THREE PREOPERATIONAL HOT FUNCTIONAL IESTS ACTIONS REQUIRED BY TUEC REVIEW ALL COMPLETE PREOPERATIONAL IEST DATA PACKAGES TO ENSURE THERE ARE NO OTHER INSTANCES WHERE TEST OBJECTIVES WERE NOT MET, OR PRERF.QUISITE CONDITIONS d' WERE NOT SATISFIED. THE THREE I? EMS IDENTIFIED BY THE TRT SHALL BE INCLUDED, ALONG WITH APPROPRIATE JUSTIFICATION, IN THE TEST DEFERRAL, PACKAGES PRE-SENTED TO THE NRC 1
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