ML20205Q720
| ML20205Q720 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak, 05000000 |
| Issue date: | 10/19/1984 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML20204J134 | List: |
| References | |
| FOIA-85-59 NUDOCS 8606030030 | |
| Download: ML20205Q720 (227) | |
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, UNITED STATES OF AMERICA '
2 NUCLEAR REGULATORY COMMISSION i 2
3 I THE bGTTER OF: '
, TUEC MEETING WITH NRC STAFF 5
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19 i 20 LOCATION: BETHESDA, MARYLAND , . i 21 OCTOBER 19, 1984 DATE: ,
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23 24 RECEIVED BY: DATE: TIME:
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1 UNITED STATES OF AMERICA 2 -__
3 NUCLEAR REGULATORY COMMISSION 4 ---
5 TUEC Meeting with NP.C Staff 6
7 Friday, October 19, 1984 g
9 10 The meeting convened at 9:00 a.m. in Rocm P-ll8, 11 7920 Norfolk Avenue, Bethesda, Maryland, Harold Denton, 12 presiding.
13 14 PRESENT:
15 Harold Denton Jose Calvo Larry Shao 16 Richard R. Keimig
- 37 D. R. Hunter
! R. F. Heishman I Jack Redding 18 j John Beck ,
3, Billy Clements
[. Michael Spence
- Lou Fikar
! 3 Joe George f 21 Richard Bangart R. Martin
! Darrell Eisenhut 22 J. T. Herritt L. M. Popplewell 23 , C. R. Hooton M. R. McBay 24 Anthony Vega
. R. E. Camp I
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, PRESENT:
Richard Wessman 2
J. C. Goubert .
S. Treby '
3 i Vincent Noonart ;
, R. E. Camp
- 4 Billie Garde ,
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MR. DENTCM: I am Harold Denton. I am Director 2
of the Office of Nuclear Reactor Regulation. This is a meet-3 l
4 ing today between the NRC Staff and the management of the 5
Comanche Peak project. ;
I wanted to be here to see part of 'your presenta- l 6
tion, and also wanted to introduce Vince Noonann who replaces 7
Tom Ippolito as the Program Manager for our Technical Review Team.
Maybe many of you know Vince from his previous jobs in the Commission, but he's a volunteer for this opper-tunity to finish the effort that Tom ' tarted.
We also have here today Bob Martin who recently became effective as a Regional Administrator of Region It' .
He's responsible for directing the field inspection activi-15 ties and coordinating with the program manager and to com-16
! plete our technical view of this project.
I We have a memo from the Executive Director of 18 f* Operations that -appoints this -- of this position, and they -
j 19 y are available in the back of the room for anyone who wants a j M g copy.
l 21 i The Mechanical Review Team stays in place as it 22 was under Tom, the team leader such as Larry Shahl and the 23 staff.under the team leader are all the same as they were.
24 We're still going ahead without Tom's benefit 25
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. 4 1 but with Vince stepping in, and we'll put full-time effort 2 on this project until it's completed.
3 The purpose of this meeting is to go over your 4 response to the letter that Darrell Eisenhut sent you regard-5 ing the first findings from the Technical Review team. This 6
is not intended today to be a decision-making meeting, but 7
will allow you an opportunity to present your program to us.
g Before I turn the meeting over to Darrell, it g might be good to go around the room and introduce who is 10 here so that we all know each other.
MR. HUNTER: I am Dorlan Hunter. I am in Region 33 IV,Pr jects Branch 2. I will end up as it is set now with 12 the Comanche Peak project for Operations -- for startuo.and 13 operations.
34 MR.HEISFFMAN: ~ I am Bob Ecisf fman representing the Office of Inspection and Endorsement.
I MR. KEIMIG: Rick Keimig, Technical Review Team.
g 17 MR. SHAO: Larry Shao, Technical Review Team.
g 18 MR. CALVO: Jose Calvo, Technical Review Team.
i 19 lg MR..NOONON: My name is Vice Noonan. I am with 20 4 the iroject Director for Comanche Peak.
j 21 l MR. EISENHUT: Darrell Eisenhut, Director of 22 Licensing.
23 MR. MARTIN: Bob Martin.
24 MR. REDDING: I am Jack Redding. I am the 25 T
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' ., representative here for Texas Utilities Electric Ccmpany.
2 MR. BECK: John Beck, TUGCO, Manager of Licensing.
3 MR. CLEMENTS: Bill Clenents, Vice President, 4
Nuclear Operations, TUGCO.
5 MR. SPENCE: I am Mike Spence. I am President of 6 TUGCO. .
7 MR. FIKAR: I am Lou Fiker. I am Executive Vice 8 President of TUGCO.
9 MR. GEORGE: I am Joel George. I am Vice Presi-10 dent of TUGCO and the General Manager of the Ccmanche Peak 11 Project. ,.
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12 MR. BANGART: Dick Bangart, Region IV.
13 MR. GEIBERT: John Geibert, TERA Corporation and 14 working on this project with Texas Utilities.
15 MR. REYNOLDS: Nick Reynolds, counsel to TUGCO.
i 16 MR. MERRITT: John Merritt, Assistant Vice General
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- 17 Manager in charge of Engineering and Construction and start-I 18 up.
h j 19 MR. HOOTON: Randy Hooton, Civil Structural Lead-i l 20 er f r the Comanche Peak Response Team.
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21 MR. MC BAY: Mike May, Construction Manager.
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- MR. P0PPLEWELL: Larry Popplewell, Electrical 22 "9 ""#i"9 C#***
23 VEGA: Tony Vega. I am Site Insurance Manager 24 25 at Comanche Peak.
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1 MR. CA.MP : Dick Camp, Startup Manager, Comanche
', 1 2 Peak.
3 AUDIENCE MEMBER: Oscar -- of the Technical Review 4 Team.
5 MR. BOOTH: Jack Booth, Dallas Times Herald.
8 MR. JOHNSON: Al Johnson, TRT.
7 MR. SMITH: War.d Smith, Technical Review Team.
3 MR. KOPECK: John Kopeck, OPA. ,
g MR. WEISSMAN: Dick Weissman, Technical Review to Te am .
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'4R . SCINTO: Joe Ccinto, NRC staff member, i : ;
12 MR. T.EBY: S. Treby, ELD j 13 MR. POSLUSNY: C. Poslusny, TP.T.
34 MR. YOUNGBLOOD: Joe Youngblood --
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MR. HOFMAYER: Technical Review team.
MS. TANG: R. C. Tang, TRT.
MR. VIETTI: Annette Vietti, Technical Review Team fa 20 f MR. HUTCHINSON: I am Ron Hutchinson with --
, 21
- MR. DENTON: I am going to turn over to Darrell 22 l -
Eisenhut any other introductory comments, and then we'll 23 turn the program over to --
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MR. EISENHUT: Thanks, Harold. Two items I 25
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' The Jhave mentioned before we go into your nresentation.
2 first is when we had our meeting in connection with our let-3 terof September 18 we went through in some detail explaining what we saw the' technical issues to really be, that is the 5
scope of the problem, in its technical arena.
. 6 When we asked for a program plan by our September 7 18 letter which you've replied to, one of the focuses and 8 oneof the things that I have said we're going to be looking 9 for is how are you going to manage and how are you going to 10 handle the review of those items, just not to review them 11 from a technical standpoint but the s,,econd aspect of it ,is 12 rather to look at it from why should we have confidence this 13 time around, any issues that may have slipped through the 14 cracks, this time won't slip through the cracks.
15 Not to belabor it, but let me use an example 16 with my staff scme time ago. If an element of the staff has 17 had endless problems that have been falling through the j 18 cracks, let's say, and then got identified that these nrob-g to lems have to be resolved, I am not sure I'd go back to the
! 20 same person in charge and ask them to exclain why the problem d happened in the first time or explain and evaluate what the 21 ie 22 bounds of the problems are. .
23 The point I am making is that while today we are 24 1 king at the issues and we'll be looking at your pregram 25 plan from a technical standpoint, that is how you are
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,, resolving the technical issues, chere is clearly a second 2 perhaps more fundamental issue that we're looking at, and it 3 was mentioned in our September 18 letter, through asking i
4 for an indentification of the cause, how you are going to 5 identify it.
6 We'f1-he looking to the process you use so to 7 speak in resolving these issues and regaining the confidence 8 that it is now thoroughly done and lastly, in identifying 9 the root cause.
10 I just wanted to point that out as a key issue I
11 before we go into it. As Mr. Denton said, we are keeping a 12 transcript. I ask everyone as they speak to identify them-13 selves. I do intend that as soon as the transcript is avail-14 able, I will serve it on all parties in the proceeding by 15 board notification so everyone will be getting it at the same 16 time when it's available.
17 With that I'll turn it over to Mr. Spence. I do j is understand that you have a presentation that you'd like to g tg go through today. I requested the meeting as a vehicle to l.
a 20 facilitate discussion on this program plan to give us a good d understanding of what it is and give the staff an opportunity 21 i
22 to ask you questions, drill you so to speak as we go through 23 each piece of the elements.
, 24 . With that, Mr. Spence, I'll turn it over.
25 MR. SPENCE: Darrell, thank you very much.
9
! Ladies, gentlemen, good morning.
2 You have-met our staff. We'll introduce each of 3 the speakers again as they make their specific issue presenta-4 tions. TUGCO appreciates the opportunity to have this meet-ing'wi'.h you and your staff, Darrell, to review our plan to 5
s respond to the Technical Review Team issues that are being 7 presented and will be presented subsequently, to recieve 8 your questions, and any comments regarding our response plan 9 and to provide to you today, to the extent that we can, in I
to the format we've got set here, our :larifications and any j 11 answers that we may have t,o your specific questions.
12 Our overall objective for today's meeting is to 13 reach agreement, hopefully with you and the staff on the 14 specific issues, items and action plans that we've submitted 15 in my letter to you of, I think it's October 8.
16 I want to emphasize at the outset our continuing t
37, first priority emphasis that TUGCO places on the satisfactory 18 resol. tion and closure of all the issues coming out of the-g 19 TRT, both those we have now and those that we may get in fa the future as the team completes its investigation.
20 d You have a copy of our agenda for today, I 21 I
r 2i believe. Our agenda has been designed to cover with you in some detail our program plan, overall, and the specific 23 issue, action plans, addressing those issues already identi-24 3 fied.
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' John Merritt will expand on that in a few minutes 2 with his presentation. Before I turn the program over to 3 John, I want to emphasize a couple of general aspects concern-4 ing our program plan.
5 First, I want to emphasize is this. I've assigned 8 our most senior nuclear management and most knowledgeable 7 members of our nuclear staff to this Comanche Peak response 8 team.
9 That should be taken as an indication of the 10 importance, the high level of importance that I and my com-11 pany place on this matter.
12 I want to -- before we get into our presentation, 13 briefly outline some of the speci5ic responsibilities that 14 I have assigned to TUGCo personnel in connection with this 15 plan and also some of the significant roles that personnel is outside of the TUGC0 organization will be played in the 17 carrying out of this response plan.
l 18 As a key component of the plan, I have establish- <
- 1e ed a senior review team which would report directly to me.
20 It's accountable to me. Serving on that team are Mr. Fikar 21 as Chairman of the Senior Review Team; Mr. Cle.r.ents, Vice i
' Chairman; Mr. George and John Beck, all of TUGCO.
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- In addition to our TUGC0 management personnel I 23 24 have also engaged services of Mr. John Bear who is anager 25 of Nuclear Safety and Licensing for Tera Corporation, to be
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! 1I a full-time member of our Senior Review Team te bring an b
2 additional perspective to that effort.
3 The Senior Review Team has the primary responsibil-f 4 ity for seeing that the action plan is comprehensive and 5 fully responsive to the expressed concerns and for the
! e responsibility for approving the plan.
The Senior Review Team will also be responsible 7
l 8 for review and approval of all results of the Issues Specific 9 Action Team Leaders.
10 A second aspect that I want to emphasize is that ti we have also established a special evaluation team in the 12 QA/QC area of our response plan, which will consist entirely 13 of personnel outside the TUCGO organization.
14 This Committee will be responsible for the review 15 of.all instances where we are unable to verify the qualifi-Is cations of our QA/QC personnel in the issue that was iden-j 37 tified.
In addition to that we are also using outside is i
y gg personnel, personnel outside the TUGC0 nuclear organization to review, revise, as necessary, and to monitor our QA/QC d inspector training program, 21 i 22 Tony Vega, in his specific issue presentation will e mment further on the roles of these outside person-23
"'I' 24 Beyond that we intend to seek additional outside 26
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12 1 assistance as we carry out our response plan where the need 2 arises or should additional issues that are brought to us j 3 from the investigations of the Technical Review Team indicate l
4 that the use of such outside pe'rspective would be beneficial a and appropriate to our effort.
g With that John Merritt, our Program Manager for y the Comanche Peak response team will begin our presentation.
l 3 ME. MERRITT: Has everyone got a copy of the agend<t g or the program? Jack, if you will help pass that around, to please.
33 Good morning ladies and gentlemen. My name is 12 John Merritt as I've indicated to you earlier. Shortly l
13 after we raceived the TRT questions in September. Mike 34 Spence appointed me as Project Manager of the Comanche Peak Resp nse Team which is the complement of the TRT at Ccmanche 15 g Peak.
- This morning briefly I will have my organi::ation, 97 directors, talking to you on the specific items. Mr. Larry i '
Popplewell will be discussing the electrical. Randy Hooton will be discussing the civil structural in conjunction with l la 20 f Mr. Mike McBay.
21 i Mr. Vega will be addressing the QC as it pertains 22 to the electrical issues, and Mr. Camp will be addressing the startup issues.
MR. DENTON: Could you tell me what ycur previous
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,. role was?
2 MR. MERRITT: Previously - if you speak up.
3 MR. DENTON: Fhat was your previous assignments 4 on this project?
5 MR. MERRITT: Okay. I arrived at Comanche Peak e in June of 1977 as Construction Manager. From there I tacved 7 into Manager of Engineering and Construction in '81.
s In late '82 I was responsible for the Startup g program and then in late '83 I assumed the role of Engineer-10 ing Construction and Startup.
33 I have had rough 1y ten years with the company as 12 we've performed work on fossil fire plants prior to that.
13 This morning I intend to provide a brief overview 34
'of the program plan that is before you gentlemen, hitting n the highlights, as we see'it, with the program plan, it-15 self.
I will be addressing initially the first two fun-37 damental functions,that being the formation of the organiza-l ,
tion and organizational structure as well as the personnel g 19 qualifications required to be a member of the CPR team.
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f MR. EISENHUT John, let me ask you a question 21 pondering your answer to Harold's question. Under your 22 previous responsibilities as manager of construction, etc.
-- did QA report to you?
MR. MERRITT No, sir.
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.,, MR. EISENHUT: So you say that it was -- when you 2
say construction you really mean construction?
3 MR. ME?.RITT: I mean construction.
4 MR. EISENHUT: Like in the field of --
5 MR. MERRITT: The field, construction, the build-8 ing, and in particular at Comanche Peak, Brown & Root --
7 general contractor -- Brown & Root reporting to me. The 8 QA/QC program reports ultimately to Mr. Dave Chapman and 9 Mr. Bill Clements, Tony Vega performing the role of the site 10 QC manager.
- 11 MR. EISENHUT
- ,And then the next question was 12 at what point in the company did construction and QA rescen-
] 13 sibility come together and go with the last five years, 14 eight years, whatever the plans of construction -- where is did the two come together.
, 18 MR. MERRITT Came all the way to the present.
s 17 MR. EISENHUT: Came all the way to the present?
l is MR. 5?ENCE. QA reports up through -- to the 8
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Clements tree of our organization chart, construction up h to f 20 through to -- the two don't come together till --
l d It has been that way, I guess, for ever.
21 I 22 MR. MERRITT In setting up the organizational i structare, we were impressed with the TRT structure and 23 fcrmulated our structure, basically along the same line as 24 i
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the TRT. Af ter agreeing on the organization structure wit!h
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,the senior review committee. then we established the require-2 ments for the individual budget review team leaders.
3 Basically these requirements entail lengthy and 4 detailed experience in the field in which they are represent-8 ing or on the CPRT: managenent experience so that they have e the capabilicy of working across the organizational fronts 7 at Comanche Peak in pursuing problems, demonstrated abilitv 8 to make decisions, hard decisions as well as managers that !
9 are f amiliar Nith the Ccmatche Peak crogram and what is re-1 to quired in that program, !
11 On completion 9,f selection of the program team 12 leads, then we address the issue of rJointing or deterrininD [
13 the issue coordinators. The fundamental criteria with tne !
- f 34 issue coordinators was detailed and lenothy ext
- erience in ;
18 the area in which they are working, independence to the )
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,, maximum possible extent from the issue in question in which ,
I I jy they are working, as well as training and familiarity with 9,
the procedures at Comanche Peak under which they will be I
working. 'f y 3, fa , At this time I would like to highlight some cf the f key items on the summary of the program process.
MR. SHAO: I have a $aneral question. To what 22 extent do you intend to use technical censult f.ron each i discibline?
MR. MERRITT: Frcm the standpoint of toeh71041 6
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, , counsel --
2 MR. SHAO: Consultants from outside -- technical 3 experts in the disciplines.
4 MR. MERRITT: As necessary in reviewing the items 5 of coure -- Gibson Hijl is our primary AE. at Comanche Peak.
6 We have Westinghouse on the site with technical people that t 7 we will be calling upcn in those particular cases.
8 Also in the testing program we have Westinghcuse 9 personnel infused into that operation. In several specific l
to areas we will be using Ebasco in seme of the technical 11 issues which is also on the job site., ,
12 MR. SHAO: Are these people originally involved 13 in the project or are you going to use somebody not original-14 ly involved in the project?
15 MR. MERRITT: Some are and some are not. Sore 16 have been involved in the process but by-and-large we are 1
g 17 attempting to use people that were not intimately invcived is in the particular question'in fact.
i 1 19 MR. NOONON: As these people present the details 20 of the program they'll point out the outside consultants d they'll be using.
21 I 22 MR. SHAO: But so far I don't see any means yet.
23 MR. NOONON: Thay'11 point them out in their 24 presentation.
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! 25 MR. MERRITT: As far as detailed personnel and i
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' ,.the companies that are represented, let me do reference to 2 this.
3 In the detailed program plan found in your book, 4 there are the names of the primary people and the companies 5 if they are other than Texas utilities.
6 Found in the appendix of the program plan is what is called the Cummary of the Program Process. Once we 7
8 had set up an organizational structure we then attempted to 9 highlight the major areas or points along the implementa-10 tion process that we needed to pay particular attention to.
11 At this point in time I would say all plans have 12 moved to Item 7 which is implementation of action plans.
13 Those will be discussed in further detail by each one of 14 the plan presentors.
16 Continuing on with the summary of the program 16 process, we put early on in the program the identification 17 ' as much as possible of the rcot cause in particular generic l
It implicaticns.
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- to We did this from the standpoint of alerting all i
10 of our canagers to keep a very sharp eye or keep atuned l
21 to the fact of identifying the root cause so that we ceuld i
22 validata or substantiate eur assumptions that we had used 23 in developing the action plan, ar.d where those assumption 24 were inappropriate, then we could modify the action plan 26 accordingly.
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18 1 Also, from the standpoint of identifying the gen-2 eric implications, if the action plan needed to be expanded 3 we could move to the expansion of that actio'n plan as rapidly 4 as possible.
5 MR. NOONAN: I wonder if I could briefly comment 6 on that. Going through suppor'ts here in the last few days, 7 it seems to me that it would cause some generic implications 8 -- not really well defined in all areas. Maybe as you go 9 through this presentation you could tell us where these 10 things are identified.
It We could not - ,our own staff could not identify 12 them f or every section.
13 MR. MERRITT: At this point in time when we 14 submitted or when we submitted the plan, all of the root 15 causes or generic implications had not been identified. It is was basically the program per se.
37 As we are moving forward we are attempting to gg identify those and modify the programs accordingly. New I
- is will address that at this point with item number 11.
f After we have submitted the program and I believe 20 that was about a week-and-a-half or ten days ago, we have 21 t
. r gg already identified some of our assumptions are in the action 23 plan to have changed and as such, we're already in the 24 process of revising those action plans accogdingly which 25 will also include mcdifications to the root cause or generic
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' ' 19 1 implications. We will be submitting those revisions to you 2 in the immediate near future as they are identified today.
3 Some of the few members will be discussing those 4 with you. Finally, the summary of the program process con-5 cludes with the. final submittal of the report to the NRC.
As I've indicated before the entire process is 8
7 identified in the appendix to the plan.
MR. SHAO: To what extent do you intend to provide 3
g any independent verification in certain areas?
10 MR. MERRITT: In c.ertain areas and again it goes 33 back to the individual program process, itself, the indi-12 vidual team members will be identifying where they are using 13 what I would call out' side entities or entities other than 34 those found on the job site on a plan-by-plan basis.
15 Each plan has -- its . unique unto itself and will have certain outside participation as we feel like it is 16 37 being necessary.
gg MR. SHAO: But you -- on every area -- you have
- 3, different criteria.
MR. MERRITT: We have certain criteria, that is a
3 i correct, that aru being reviewed and implemented by the 21 i
t individual program or team managers, that is correct, if I 22 nderstand your question.
23 MR. SHAO: My thinking is if not every area you 24 25 an -- y u have to do independent verification, but certain 1
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. 20 1 areas you have to do it.
2 MR. MERRITT: That is correct.
3 A MR. SHAO: In order to conduct the program you 4 have to have criteria. Certain areas -- if you have present problems you have to do independent verification. Certain 5
g areas you do not have to do independent verification.
MR. MERRITT: As we move through the program 7
8 process we will be identifying that criteria, yes.
MR. SHAO: So that has not been identified yet?
g 10 MR. MERRITT: At the time of submittal of the j,
plan, it had not been identified, no, sir.
MR. DENTON: I think what Larry is getting at is 12 13 the most effective way to put some of these things to bed 94 would be direct physical measurement verification, say as 15 pp sed to paper surge, and if the question is over configu--
rati n r material bigness, go back and measure it or --
16 is that your intent?
37 MR. MERRITT: In each one of the program managers j 18 we'll be addressing that. We do have in certain cases and f I will be talking on that in a minute -- the aspects of 20 i
d the program which, in many cases, move beyond just a review 21 3
- of paperwork.
22 Yes, sir, we are going back into the field, and I am going to talk on that in just a minute, but that then will break down on an individual plan basis on specifically 1
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what will be done. Some cases, a paper review. Some cases, 2 additional inspection, some cases additional engineering and 3 some cases, rework, but I'll talk on that in just.a minute 4 if that is the question you're asking.
5 MR. DENTON: Let me ask another policy question.
6 This review is somewhat unique in that we've got adjudicatory 7 proceedings running along that is considering many of the
. 8 same issues, and many of the people that the PEPCO review 9 team has interviewed have also appeared before the Board.
10 Both in close camera sessions and in open ses-11 sions, did your review team be made aware of the information 12 that has also been brought out before the Board on these 13 same issues, or are you restricting it just to the letter 14 from Eisenhut, for example, because many of these may have 15 had its genesis in people who appeared before the Board and 16 then ultimately we talked to them and did the review.
37 How are you assuring that you've got the full --
iig the scope of the concern, and what I am really asking is dc your team members -- are your team members aware of what is i .
19
! go going on in the legal proceedings?
d MR. SPENCE: Harold, let me answer that one in 21 2
1 two parts. Our senior review team identified -- we've got 2
the overall policy direction and approval responsibility 23
. coming from the Response Team.
3 They're keeping themselves very currently aware 25
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of all of the issues in test'imony beford them on related 2 matters. And through their involvement in the ASLB process,
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3 knowledge of issues and ' testimony -- make sure that the 4 individual ef forts on these specific action plans and the 5 management of those are also aware of the parallel nat.ure 6 of the issues between TRT and ASLB issues.
7 A second comment I'd make on that is that the a point you raise is indicative of the reason for it and the 9 benefit of having people who have fcmiliar knowledge from to their experience over site, involved in the addressing of the-si resolution of these issues so that they'll have a complete 12 awareness not only of the particular physical attributes of -l 13 the issue raised by.the CRT but also the peripheral issues 14 that ahe being litigaEad in connection with that same mat-15 ter, perhaps at the ASLB.
MR. DENTON: It does,siem uniqie in that regard 10 a
in that the issues are closely intertwined in some cases 17 h
10 with what's being under actual adjudication. ,
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gg MR. EISENHUT: Harold, if I could follow up on g
that, it is n'ot necessarily clear that if the senior review 20 team which -- if you'd look at it from a senior management 21 r standpoint, may very well not be as attuned to the signifi-cance f what they hear in the detailed testimony of the 23 ,
hearing as the riviewer doing the worY. yo ld be.
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While 1 clearly respect -- there are the pros and 3
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cons going one way or the other, at the same time it would 2 seem that there may well be a benefit to having people in 3 charge of resolving an' issue familiar with the detailed testi-4 mony in the hearing and not just the testimony of the hear-5 ing, but CAT reports, routine inspection reports, so that 6 everything that exists on a particular issue, it would seem 7 to be -- you know, I've given you an analogy.
s If Harold Denton or Darrel Eisenhut lead a detail-g ed inspection report on cable splices in the back of a cabi-10 net in a control room, things can clearly go past us, but {
it if a detailed reviewer who really understands what the 12 standards are, what the codes are, what the construction 13 practice is, different things may completely leap out of him 14 than would leap out of us.
15 MR. SPENCE: I guess a good example of our organi-16 zational structure addressing what you've said is Tony Baker' s
- 37 role. Tony is very active in the Comanche Peak response is team effort as a pregram leader, and I think you're' familiar I
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g 3, with the roles that he has played also on parallel issues fa g before the ASLB.
d There is an example of a direct linkup between the
. 21 i: two parallel activities at a level of our response team or-22 ganization well below the senior review team unit.
I think that is what you are --
MR. EISENHUT: Right.
e i
'I e
' . 24 I MR. DENTON: We envision our effort to be suffi-2l cient to resolve this issue if it's also before the Board, l
3 and, therefore, we intend to stay current with whatever is 4 going on before the Board issues, and that might color our 5 evaluation of your activities, and I think it would behcove 6 all of us to keep in touch as there are these two proceedings, 7 one in record and one off record that have to be closely a tied together where there's mutual issues before the two, 9 and that we not attempt to resolve the technical . issue and 4 10 forget about some new aspect or twist that has been brcught 11 up in the other proceeding. .
l 12 MR. EISENHUT: There's one other twist to that, 13 too, and that is a number of the pieces of information have 14 come up in the hearing through either confidential sources 15 or through being heard in camera sessions. Certainly the tis utilities counsel was present at those meetings and certain-s 17 ly there are agreements that have been signed protecting the I: 18 information.
5 j ig Is there any length for the technical information i
that is taken care of in the hea. ring process in closed ses-20 l
sion? Counsel, better listen to this thing.
f 21 -
l
! Is there any link whereby the technical merits 22 that come up can get back to the management so that the 23 24 management -- whoever is responsible for evaluating this thing hears the information?-
25 i
l l
m
e 25 1 I nean there is a distinct possibility that in a 2 closed session of a hearing is where the vital critical 3 technical pieces of information come up, but you could have ali 4 program that is moving along at full speed that just doesn' t 5 have the benefit of that at all.
6 Is there any -- have you folks taken any steps of 7 at least some senior management whatever disclosures -- what-a ever the appropriate language is, to get that information se g that there's at least a link in its connection with the 10 program? ,
y MR. SPENCE: The answer is yes, and I --
1 . .
12 MR. EISENHUT: Can you elaborate a little hit 13
- ?
g MR. SPENCE: I think the term is protective oreer.
16 MR. EISENHUT: Right.
3
- g MR. SPENCE
- Darrell, I believe the only in camera technical testimony before the ASLB has been the witness 2 F testimony.
I. MR. EISENHUT: All right. Is that the only one?
j 20 J MR. SPENCE: That's the only one that I know of 21 i and it's the only one my counsel knows of, too.
22 I use that as just a general description of the 23 famil? of issues. In that particular case a number of our 24 key senior management people including Mr. Clements who has
er -
- i 26 I
,, the overall responsibility for startup and QA to senior 2 management level, was a party to a protection agreement .
3 which allowed him to be privy to that testimony as was Mr.
4 Vega and, I believe, in that particular case, Mr. Chapman..
5 7s that right?
6 There may have been others but I know those are 7 our three most senior QA managers, and they were all allowed 8 by that protective order to access to that in camera testi-9 mony.
10 MR. DENTON: We've had a number of key counsel 11 come into this meeting since we began. Stuart Treb'y, naybe
~^
12 you should identify yourself and anyone else that icinec: us 13 after we went around the room.
14 MR. TREBY: Well, I think'I did indicate earlier but n'y name is Stuart Treby. I am the assistant to the 15 16 hearing counsel for the NRC staff and have been involved in
- 37 the proceedings that are placed before the hearing board.
I 18 MR. COMER: (Inaudible statement from the flocr.)
C MR. CRISTENBERRY: I am chief hearing counsel.
j 19 a
. I MR CARDEN: Tom Carden, also with (inaudible 20 3
d statement from floor.)
21 3
E MR. DENTON: Thank you. We're going to attempt 1 22 )
on our side to stay closely attuned.to what is happening l 23 before the Board, what the issues are that are similar.
24 l Would vou hazard a guess as to the extent of 25
, - - w =
. . e.
.- 27 1
,,any tie between your program and issues that are before the 2 Board?
3 MR. SPENCE: I don't know -- I am not sure what 4 kind of answer you want.
5 MR. DENTON : Characterization -- half these 6 things also pending before the Board? How would you --
7 MR. SPENCE: I have attempted in my own mind tc a
sort them out into those -- into that kind of relationship.
9 Counsel reminds me that the Board has taken the position that to they intend to 1cok into the TRT issues and all the TRT issues and that we don't necessarily agree that that is orce 33 l ,
er, but we do realize that where there are ccmmen issues l 12 in both TRT and before the Board, that that may be required 13 3,
that we haven' t yet attempted to sort out the-issue that g you've gi ven us thus far into a relationship that are direct-ly or in some way tied to issues currently before -- speci-fic issues currently before the Board.
f g he can do that.
18 MR. DENTON: I don't need any better characteriza-g I. tion. I just wanted to make the point that there is a broad g M 4 intertie in your orogram as well as ours that should take 21 i 22 account of all the information that bears on these issues when we go to resolve them.
23 I1R . SPENCE: That is a point well taken, sir.
24 MR. MERRITT: Mr. Denton, to get back to one of 25
4 ., .- --
27-A l Again within
.;your earlier questions under types of activity.
2 each action plan the action plan will be structured around 3 the needs of that plan to address certain additional work 4
activities or programmatic types of things.
5 For instance, if the program plan deems it neces-6 ary, we will perform additional documentation review. As 7 necessary we will perform reinspection. As necessary we 8 will perform additional engineering calculation. If required 9 we will perform additional testing.
to In some cases if it seems the most prudent thing 11 to do in order to resolve ,the issues,,we may even have some 12 construction rework, but each one of those will be addressed 13 in the individual action plan, itself.
14 Briefly in wrapping up the last two items there 15 is a couple of the plans that are approached en a phase 16 review process, phased from the standpoint that at the end
= 17 of one or more phases we will consider where we stand with j 18 information in hand and from there make a decision on the j to implementation of the next phase.
i I
! 20 That also will ultimately be reflected in the l
f 21 schedules that we are presently developing for this effert.
I E
22 MR. DENTON: Do you have any schedule you care 23 to share with us assuming you kick off the program in the 24 near. future?
25 MR. MERRITT: From the information we have at hand l
l
+ . . - , - . . _ - _ y
, , . * ,3 - , , -e
.. i 28 1
.,and it is still being reviewed as I've told you. We have 2 presented to you the overall action plans and we are into 3 the implementation phase of it. We are basically seeing 4 the conclusion of the first TRT report, the issues in the 5 first TRT report coming to a conclusion anywhere from the 6 middle to the latter part of December depending upon each 7 individual action plan per se.
8 MR. FIKAR: Let me interrupt one minute. Harold, 9 that also depends on what input we get from you all so it to is kind of -- we've got to be working in that -- after this 11 session we'll probably have some bett,er idea and then whyn 12 we get the issues and mechanicals we'll have a little more.
13 Right now it is kind of --
14 MR. DENTON: I think the intent of the tech review 15 . team is to provide you with a letter on all of the remaining 16 activities before the end of November. Is that the --
h 17 MR. EISENHUT: That's what we understood.
2
- 18 MR. SPENCE: The divisional schedule is November 1 .
3 '
j 19 Is that up in the air --
MR. EISENHUT: Up in the air pretty much. Well, 20 d
21 it is not really up in the air with the change of management.
ir It's up in in the air, I think, more with the recognition 22 23 fthe detailed process of where we are. Our commtiment is as soon as we identify a block of issues, we'll get those 24 to you.
25
O ,
P e- k 29 1
We've said the last issue of'our schedule is the 2 QA/QC issues and our target for those would be the latter 3 part of November with that particular set. That is what it 4 looks like to me.
5 MR. SPENCE: In the interim we would have to 6 receive whatever issues that can fall out of the other.
7 MR. EISENHUT: As they completed we would be --
8 as we identify areas where we believe additional work on 9 your part is necessary, we would be getting those to you as 10 they come along certainly just as we did in the September --
11 MR. DENTON: Could maybe ance or you or the 12 individual specialty leaders bring us up to date as to what you've done at the site since the last meeting? Are' there 13 14 any more site reviews going on or are they essentially ccm-15 pleted?
MR. CALVO: In the electrical group everything 16 17 iscompleced.
MR. NOONAN: Let me address it very quickly. I
- 18
!* /
j 19 have not yet sat down with all the team leaders and address-ed that particular aspect. We'll do that later this af ter-20 i noon and by Monday I'll have a handle on that.
. 21 I If the team leaders, themselves, want to answer that, go ahead and do it.
MR. CALVO: As far as the electrical instrumenta-tion, all the in~spection on site has been completed, and :
25 l
l 1
~
i l
. 30 i
1
.,,we are in the process of finalizing the supplement safey 2 issues reported -- they probably can be available to every-3 body in a week or week-an'd-a-half.
4 MR. DENTON: I thought sinde we were on schedule 5 it might be good if you knew where we were going in areas
. 6 that remain to be transmitted. ,
7 MR. SHAO: See, in the structure area we are 8 -- uth permission we give out the letters. In the mechanic 9 area we finish all the site work, and I don't know what the 10 open issue is.
11 Essentially we,',re done. - -
12 MR. SPENCE: Larry, that was in the mechanical 13 area?
14 MR. SHAO: Mechanical area, yes. See, I am in 15 charge of civil mechanics.
16 MR. EISENHUT: We should put a qualifier on that a
17 though s> no one jumps to too hasty of a conclusion. While f
- 18 the work that we originally laid out on the site is clearly 3
- gg done, I mean we've gone through the process and most areas i
with eight to' ten weeks on the site, we may very well have additional followup activities as we continue to evaluate 21 i issues with the ledgers, as we see your responses to i,ssues so there may very well be additional work going back to 23 the site.
24 The initial round of -- as we laid it out on the 25
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-T,
~ ~ ~ ~ "
31 I site, I wrapped up, I think, last week.
2 MR. MR. CALVO: I think that hopefully we have 3 finished, for instance, in the electrical discipline, there 4 are some prograi.matic aspects of the electrical issues that 5 have to-be coordinated with the QA/QC that -- so that when 6
they look at the overall programmatic impact of the issue, 7 they.migh.t have to go back to us and they have to do some-a thing else.
g That is reflected in the -- to indicate that be-10 fore this work needs to be done i- this area. The integrated 3,
approach has not yet been properly coordinated with all of the disciplines at this time.
12 MR. SPENCE: A question for Larry or Darrell, 13 34 either ene. If your initial site work is not completed in the camp area -- does that indicate -- should I take that 15 to mean that whatever issues you may have identified that 18 3
g would not require action by us will be forthcoming shortly on that?
' MR. EISENHUT: I would expect those issues to be
}
I. identified in the near future, but it is a matter of writing j 20
- f. down, you know --
21 MR. 5HAO: That is the one thing we should talk 22 about is whether we should -- the ledgers, the --
23 MR. NOONAN: The one thing I am doing r'ight now 24
-- I want to make sure in its process that all. cencern s 25
-, s,_ --
t .-_ . ......._~ i 1 identified by any neople that have given us concern, I want 1
2 to make sure that those concerns have been adequately addressf- J 3 ed and that we originally contacted the people that made thes e 4 concerns and show them what our resolutions are.
5 I am looking at that right now, and I have a 6
schedule on my desk and I'll have something on that probably 7 by Monday.
8 MR. SPEMCE: Darrell, you mentioned the peSpens-g bility or maybe the likelihood of followup by these function-10 al teams. After they complete their initial thrust on --
would that be aimed at looking furth r into issues they had 33 ,,
already been addressing or are you indicating there may be 12
- *****? -
~
13
- MR. EISENHUT: Well, it could be some of bcth 34 but I think, Jose, you've got to remember the process, and Jose pointed out pretty clearly. If you evaluate , let's I say five big technical areas, you find problems in the elec-g 17 trical. You may find electrical problems, questions, them-
$ selves,and you evaluate those individually,'but then there
- 19 i a is the more generic implications of what does this mean to g
4 the overall arena of QA/QC and that is why we have the 21
{
l . last group is QA/QC and all of the first pieces have an input 22.
to that. -
23
~
What you see and what it tells you -- may send you 24 back to do some more work. We are going to continue to 25
.- -- w-- 7
. .. ... . . .. 4
's
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1 , --other discussions we have had with the p Jedgers -- we are 2 going to continue to be looking at the process.
3 Remember though that TRT by design, when we laid 4 it out -- it was an overall evaluation. It wasn ' t to evalu-5 ate a hearing issue or a particular allegation or a particular 6
technical question. It was to go over and reverify the over-7 all competence of an area.
8 It encompassed all of the other things. We tried g to do that by design so when we 're looking at it, I mean you jo could come forth and tell us if you'd concluded the root 11 cause to a problem was wha.t.ever, and that could well dri}'e 12 us back to look some more.
13 I think it is largely -- we're going to have to 14 see the rest of the results coming out of the individual three or four groups. We're going to have to look at your programs, see t,he work and the results you're coming up with
{ and factor it all together.
g We're going to -- as I said, continue to have i
- discussions with the ledgers. We want to make sure we follow-
} ,,
I. up to the best we can to understand everyone's concern as j M f
. 21 thoroughly as we can.
! MR. DENTON: My comment just restricted to the initial scope as it might seem, not as a piece unfolding --
MK. EISENHUT: Right.
MR. DENTON: -- new information -- I thought it M
j -
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34 I would be useful to get out on the table where the effort as 2 conceived to be necessary by Tom months ago -- not what 3 likely still occurred.
MR. SHAO: I'd like to make a point. Even though 4
5 the mechanical area is ready to talk to you, the mechanical and QA/QC are very closely related. I don't think it's a 6
7 good idea to have a meeting on mechanical and later on QA/QC g that are all overlapping, g They're very closely related, so our problem is 10 QA/QC also, so I think we should. talk to the QA/QC people before we go ahead with the meeting.
33 MR. SPENCE: Well, in our September 18 meeting 12 we had several statistical numbers that were used concerning 13 g
the number of allegations in these various functional areas.
I recall it was in the 500 range total and the first Septem-g ber 18 report addressed maybe 20' percent of those, 16 MR. DENTON: Well, let's keap going so at least f g you understand where the team members stood in the various disciplines as --
fg MR. KEIMIS: In a testing program area of the 20 f onsite work that's been completed and finalizing the SSER, p 21
! 22 we have the same problems --
MR. FIKAR: What about codings?
23 MR. KEIMIG: Yes, codings on --
24 M -
4 i
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I MR. WEISSMAN: Well, let me comment for both 2' the petroleums and the QA activities because we didn't ask 3 those who were familiar to be present today on the subject of their discussion. --
-~ ' ~~
5 Again, both the codings and the QA groups have 6 finished,their onsite work, and they are in the process of 7 finalizing their SSER evaluation. The last of those obvious-8 ly is QA -- again, I think that with respect to the codings 9 variance, we're prepared to share information with the to members and hopefully QA will fall out very shortly at that 11 point as well. ... ,
12 MR. EISENHUT: Well, I don't want to take too 1:3 much time right now though to specific schedules and specific 14 items. The point Harold was making was the original sched-15 ules of where we --
16 MR. DENTON: Let's see if_Ne can get a summariza-e
- 17 tion of the various groups How about QA?
E
- 18 MR. EISENHUT
- Well, that was -- Dick was speaking i .
- ig of QA.
i 20 MR. BANGART: Region IV had some subset of miscel-2i lane us allegations sent to us for completion and then we're i:
22 also -- completed all the field work and have all the right 23 ups finalized for management review of section one at this point in time.
24 25 MR. DENTON: I think our intent is once an area
-. i
- o m.. 36 I
1 feels they can productively come to some conclusions in an 2 area, that will be transmitted to you without waiting any 3 particular date so just as soon as a group feels that they 4 have coherently reviewed an area, that will be subjrict to l 5 a meeting.
6 I think though that we are projecting -- this may 7 take as long as the end of November to complete all of the 8 tasks that are now invented.
9 I mention it because it ties into what your to schedules are, and how your programs can proceed. Do you 11 want to come back now to what you're doing on the origi.].al?
12 MR. SPECE: Before we get off that general sub-13 ject, back to the question I was in the process of phrasing 14 a moment ago.
15 The current effort by each of the functional 16 groups in their particular status of completion at the time 5 17 is based on, as I understand it, the issues that Mr.
- 18 Eppolito and the technical review team have had in their 3
3 '
- ig possession during the process, during July, August and Sep-i j 3 tomber.
I guess my concerns go to the question of as the f 21 ir electrical, for example, completes their work on the issues 22 before them, how do you -- what is your strategy and how 4 23 24 do you plan to handle late-minute, last-minute allegations that may come back into a group that is already complete 25
\
i .
m
~ ' 37 1 that would keep this from becoming a never-ending process?
2 MR. DENTON: I think we apply the same approach 3 we've done at other plants such as the Diablo Canyon plant.
4 They have to be looked at but we would take that site and 5 look at them.
6 MR. EISENHUT: I don',t know if you're familiar 7 with -- that's the same approach we used at Diablo -- I 8 think Diablo Calloway was the last one.
9 MR. CALVO: You certainly have the benefit of 10 how the contents of our safety reports have. Now when this 11 is ready it will be made available to you and to the public, 12 and I think you will determine how we have bound present 13 and future allegations, how we have done our sampling over 14 the significance of it.
15 When new allegations come up we will forward 16 copies -- the investigation being done,and these -- vell, said -- well, we have done this before and it looks like 17
- 18 it's within the ballpark of what we have done.
- ig Now once you understand that, I think if you can 1
i tune up the action plan, okay, that is something that you're j g 7,
$ missing in the action plans. You don't know -- you know 21 I the results but you don' t know why -- what was the basis of 22 the results, what part you took from there and that is a 23 part you were missing. There were so many questions not 24 nly fr m y but'also from the public. !
25 l
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8
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38 1 Why did you come up to this one. I think that 2 would be the key one, and we're hoping that we can,give this 3 to you today because I think it will answer all kinds of 4 questions.
5 MR. DENTON: We have procosed the Commission to 6 follow the Diablo Canyon practice and all practice with re-7 gard to late allegations and it's spelled out in, I think,'
8 SR22 on Diablo Canyon -- the process we go throach. We g look at them all and then the criteria about which we use in to decide whether it is one that will prevent an action j, or not or --
l 12 MR. SPENCE: In fact, that would -- last-minute 13 allegations after we have provided action plans that are 34 satisfactory to resolve the issues already identified --
15 w uld from that point on, any last-minute allegations if I 16 am hearing what you're saying would be aimed at balancing g safety implicationc of those late allegations against the 1 2
- ,, information that is already provided and the need to complete the review.
- l. MR. DENTON: Well, I wouldn't say balancing. I g 20 f 21 am trying to decide if the safety implications raised new g
l significant issues that have not been previously considered.
22 I think that is really the heart of the approach is that if 23 it is an allegation in an area that has been looked at hard, 24 )
and we have some basis for judging it, then we're comfortable l 25 1 l
-- 39 1
,,, making a judgment. If it raises an issue in an area where 2 there's really no inspection history, no technical review 3 and we don't know how to proceed on it, then we may have to 4 pause until that area can be looked into.
5 I think that is an issue we'll cross when we get 6 there. Hopefully, we'll know all of the allegations long 7 before we get to the end of this process.
8 MR. MERRITT: In conclusion with my portion of the g presentation I would briefly reference the fact that we 10 will be doing sampling on certain of those activities where i3 we believe sampling is justified, and I am talking abcut frcm 12 the standpoint of the activities referenced earlier on addi-13 tional record review, additional inspection, additional cal-34 culation, et cetera.
l 15 The sampling techniques wo will be using will 16 meet the requirements under mil-standard 105D, and we will be 1
37 using that and we'll briefly touch on that in one or two of 18 our discussions _heEthis morning._ _._ .-
y
/ % ,
a MR. WESSMAN: John)wil] your presentors clarify
~
b %..
ig for your standboint and' -perhaps a lesser sample than what 20 f 21 we have requested in our September 18 letter?
g
! MR. MERRITT: Yes, sir, we will be touching on that also in the presentation this morning.
Let me begin the detailed programmatic discussion l 24 !
1 here with again when we made introduction most of our people l
~
l l
4
1 are setting over in the corner here, and they gave the:
2 job titles but I would like to briefly go through and if you 3 will hold your hand up.
4 Larry Popplewell is responsible for the electrical 5 instrumentation effort. Tony Vega is responsible for the 6 QA/QC effort. Randy Hooten is responsible for civil struc-7 tural and will be assisted on a couple of items by Mr. McBay 8 and finally Mr. Camp will address the testing area.
9 With your concurrence we would propose to go to throughthe discussion this morning in the sequence as out-33 lined on the screen here.,,If you had preferred any other ,,
12 sequence, we will entertain that also.
13 MR. DENTON: I'll have to leave before 11:15 so i4 if you wanted to -- I'll stay for the most important part ,
.\ and if you think you've got it that way that is fine.
- (i 15 Ip "i - ,,
. FIKAR Well, do you have any particular --
', f ./
- 37 you would like to make sure you hear, Harold? 1.*e can rearrange
- \ these.
sg 3
{ ~ _ . ._ -_' ,
gg MR. DENTON: Let me ask -- Darrell, do you think --
j 20 MR. FIKAR: We're just using the order the way g
f they were in the letter, but if Harold wants to hear about i
i the ceiling and not about electrical, we can --
MR. EISENEUT: Can I make a suggestion? We can talk about the QA/QC area first since that clearly is going to be a vital piece in my mind, and if I could ask you -- one I
. i .
- . - - , , - w ---- - - - , , . ,- -
, - - , - ,-- m - -w
d S b e. .. -- ,_
. s 41 1 of the things I would like for you to discuss is how you l ,
2 chose those people, what the qualifications were, how you are 3 sure they were not invcived before to the point where -- and 4 certainly I don't know most of these individuals so I am not 5 particularly picking on these people, -but how do you know a they weren't involved before and how do you know they were 7 not part of the problem to start with?
8 MR. FIKAR: We'll address that.
9 MR. L'ISENSUT: That is the key thing that you have I
i N.10 to build in in the front end of the program.
i 11 MR. FIKAR: That will come out in the presen c-12 tion. ,
I 13 MR. EISENHUT: Good. Good.- l 14 MR. MERRITT: Why don't we start with Tony.
15 After Tony is there any preforance from there?
16 All right.
17 MR, VEGA: Ladies and gentleman, good morning.
18 MR. CLEMENTS: Tony, before you get started, may-I be Mr. Eisenhut would like me to address why I thought that j 19 i
1 20 Tony was a good man'to have for this issue team leader.
21 Tony has only been the the QA manager at the site r
. r since March --
22 MR. VEGA: March 16. ,
23 MR. CLEMENTS: March 16 and so although he's 24 d
familiar with the OA/CC program of TUGCO and has been 25 q
.-t.,.
...- i 42 j 1
involved only as -- responsible for the audit teams that 2 went down, I felt that he wa,s independent enough of the ,
3- efforts over the past ten years that made him available to I 4 act as the issue team leader.
So he really had two qualifications. One, he is 5 t 6
very familiar with what has been going on at the site from 7
an -- over from an auditing viewpoint and at the same time ;
8 he knows our QA program and'he was not involved over the j g nine years in previous positions.
MR. EISENHUT: Let me ask you, where you were in-g
, g volved -- where you were before the nine years or during j i
this nine years -- where were you in the organization, I 12 g guess, and what is your background?
MR. VEGA: As far as background I /e a degree 9
in electrical engineering. I am a registr . professional ,
15 i engineer in the State of Texas. I have a background of I
=
fire plant design, primarily power. systems, supervisory and 17 1 '
control systems.
18 i ;
I came to Quality Assurance in 1973. At that l I 19 i 3 l i time I started in the Quality Assurance organization as a j M staff member in the staff -- manager -- was involved in I f
. 21 formulating the PSAR, the initial program of procedures.
22 Subsequent to that I became involved in the audit ,
i 23 function of the architect engineer, the vendors, site ac -
24 tivities, testinc and operations. That is primarily my '
25
. 't.,.;.__.
43 1
.,, background prior to coming to Comanche.
2 MR. DENTON: Has TUGCO encouraged you to partici-e 3 pate in the various professional activities and quality 4 assurance and quality control?
5 MR. VEGA: As far as participation in the industry?
6 MR. DENTON: I know there are various standards 7 and professional societies." To what extent have you been 8 involvedin -- there's been a seemingly -- a change in the 9 way the agency approaches quality assurance over the time 10 that you've been involved from 1973 to today.
11 Are you -- do.yo.u particicate in the various 12 standard organizations that -- I've forgotten their name, 13 but --
14 MR. VEGA: The NSC standards --
15 MR. DENTON: -- the NSC standards for quality 16 assurance and quality control programs?
- 37 MR. VEGA
- Yes., We have been active through
- gg several industry organizations. In my previous position, as l '
- 3, a matter of fact, I was involved in reviewing proposed stan-g dards, commenting on them. We are active members of the
$ Edison Electric Institute UA Committee.
21
! We meet twice a year and, of course, communicate a lot more often on the types of problems that are being identified in the industry, the sclutions. We do everything we can to stay abreast of not only the regulations or n - e e
.~.
d e*-
- em. #
....r.....,.
44 1
changes, but also the things that are happening at other 2 plants with the primary interest of precluding them on cur 3 project.
4 MR. CLE.MENTS: We're also a member cf JCHA, 5 the Joint Utility Management Audit that goes around, within s the utility industry, audit other management groups -- other 7 utility management groups so I think that is a big help to s us, Darrell, also.
g MR. VEGA: We're also members of the ASBC criani-i 10 23 tion. We send representatives to meetings and then they J
33 come back and share what_wa_s discussed with the rest of the 12 organization.
13 MR. DENTON: Has your existing program been audit-34 ed by IMPO in their -- they have a pilot program to lock at construction adecuately. Have you participated in 15 16 activities --
t MR. CLEMENTS: We've had the original self-audit 37
- . l 1
and sent back the results of th.at audit into -- they're due 18 f
to make their first info audit of our construction. I believe,
}.
3, l in March or April of '85 g 20 ,
f MR. SPENCE: Let me clarify that. He said self-21 l
! audit -- self-initiated audit --
22 1 MR. CLEMENTS: Yes, that is it.
23 ,
. 1 MR. SPENCE: -- using info criteria. Actually j 24 l l
we had a consulting -- they conducted the audit. We didn't , ;
25 l i l
1 I
+ ..
h j I
., audit oursc1ves bet we initiated it under the infc progra ,
2 MR. VEGA; I would like to d.iscuss with you item 101 on the subject of QC inspector qualifications. The 3
item, the TRD as a result of their assessment concluded that 5l there was three -- that there were scme concerns in the area 6 of QC inspector qLalifications as follows:
]
7 There was a lack of supportive documentation
/
8 regarding personnel guni.tfications and the training and 9 cortification files for t.he electrical QC inspectors. There 10 was a lack cf documentation for assuring that the requirer 6ng I
11 for electrical QC ins.pector certificaticas were being met.
l q t In expressing thcae concerns, the TRT identified 13 five specific examples. Based on the observation the TRT l
14 proposed certain actions as follows: that eich team shc91d ;
t v
i '
jg i review all electrical QC inspector training, qualification, 16 cert:.fication and rscertification files against pre Ject re-17
, quirement, and if EUEC prcvide informatien in such a form is that it could be clearly demonstrated that each inspector
- I gg had met all of the requirements that apoly to their certifi-fs , cation .
d The tnt also specified that if an inspector did 21
, i2 not meet the requirements that TUEC should review the reccrds g
to deter nine the adequacy of the inscection and assess the 23 inpact on the safety of the nroject.
3l In addition to having made the cenment specific
. 25
, . = q . , .. _.
. . ; 46 1
., to the electrical QC discipline, the TRT expressed a state-2 ment that-the identified deficiencies has generic implica-3 tions through other construction QC disciplines.
4 Prior to going into the discussion of the action 5 plan I would like to cover some of the pertinent background 6 in the area of inspector QC training.
7 First of all, Comanche Peak was docketed without 8 a commitment to regulatory guide 1.58 and ANSI N45.2.6.
8 Accordingly, our initial training progress addressed the ap-10 plicable requirements of 10C, part 50, appendix B.
)
11 Our commitment.to ANSI N45.2.6 and regulatory 12 guide 15Awas made in 1981. Accordingly, we changed our 13 procedures to address those particular items specifically.
14 It would be appropriate to point out that the ASME inspectors 1
15 at Comanche Feak are cisrtified under a totally separate pro-i ts ' gram.
1 g 17 This program is in compliance with the require-ments of the ASME and they have the -- the records have been g 18
- I ,
j 19 A reviewed independently by the ASME authorized nuclear inspec,- '
[ 20 tor that is provided by the Hartford Steam Boiler Insurance f 21 Agency.
i MR. DENTON: Let me understand something there.
22 23 Do you have your own ASME code stamp within TUGCO?
24 MR. VEGA: No, sir.
26l MR. DENTON: So you are talking about something i
i r---,, n , ~ p , , . , . , - - . - , - -----~n.m- .- <y , -..,,y
e . 2. t -. . . ,. - - ... \ ~
- 4 47 1
else then? You are -- your program has not been audited 2 by the ASME and you are not the holder then of 0. -- what is ,
3 itcalled -- instamp but -- "-
4 MR. VEGA: But Braun a nd Root has been.
5 This is a Braun and Roct program. Braun and Root a has a stamp and the ASME has audited this program and it 7 is continuously overseen on a day-to-day basis by the 11 8 AN'Is that are residents on site.
9 MR. DENTON: So TUGCO, itself, is not the possess-10 or of instamp technicians --
11 MR. VEGA: Thatlis correct.
. 12 MR. DENTON: Some utilities have -- do you plan l
13 to--
14 MR. FIKAR: We plan to get one, Harold. We just l
~
15 haven't had a chance.
'~~
16 MR. DENTON: I see, s
!* 37 MR. CLEMENTS: At this particular time we're~not .
j 18 working on toward getting one. I want to make that.--
g 3, before we make nuclear units -- if ever.
a -
l MR VEGA: I would like to point out a very im-20 a
d portant point relevant to our inspector certification pro-21 t
3 gram. It is standard practice in the industry to certify 22 inspe t rs to disciplines, electrical, mechanical, civil, 23 INC. ;
1 Our program is a very conservative program hnd 25 l
-,,w ,--n , ---,.sw..-mm o~, e-q , -- , ,-- -.- , - ,,
. , .., _ - . i 48 1 unique in that we certify our inspectors with specific in-2 structions and specific procedures. This is a very important p 3 .-point because before we certify an inspectof we make sure 4 that he passes an examination and OGT and classroom training, 5 on that specific instruction so that we certify level I 6
to a specific instruction.
7 This makes our program a very conservative program.
8 Of course, we generate a lot of paperwork, a lot of paperwork, g but we find that it serves our purposes quite well.
10 We reviewed the specific examples cited by the ij NRC, TRT and our review indicates that the specific examples 12 cited by the TRT did meet the project requirements.
13 MR. CALVO: -- requirements -- did you conclude 34 that whatever the TRT found out was not correct?
MR. VEGA: We found out that in some cases the 15 documentation that was cited as not being there was there.
16
- g In other cases we determined that the item identified had
-- was not a requirement, and I can go into some details.
g 18 The details are included in the writeup.
I. MR. CALVO: I know but these usually tended to j 20
~f
- 21 be trend -- you have all the -- indicative that whatever
! the TRTs did it was not correct. Let me say something here.
22 Keep in mind when we requested your records, drawings, that is wha t we -- we acted upon the experimentation given by 24 the representatives of your company, and only based on their 25
w . -
. a. 4 j
. =
l
. 4 ~ . _ ,
49 1 experimentation will we reach'our cone'lusion.
2 Now with the attempt to come to a conclusion it 4 1
3 cannot be. cased on instrumentation that used to be at TRT.
4 It may be based on some other instrumentation that you may 5
have for a special occasion but not -- give it to one, then 6
you give it to all. .
7 MR. CLEMENTS: Let me address that and I want to 8
-- the"TRT, of course, came on site as an independent inves-tigative organization. It was to our mutual advantage to g-10 maintain that independence obviously, but We believe that this 3,
sort of stiffled communications to a certain extent in that we at times were not aware of what specifically an inspector
/ 12 -
/
/ ~was icoking for or whether or not he had found what he w as 73 (l / *4 g looking for.
Now the specific training record, and let me just give you an example. The 33 inspectors, electrical inspec-I tors that are on site collectively hold 770 certifications
- 17
. by instruction and by procedure, y 18
- We were not aw'are that having made those records j 19 i available to the inspector, that the inspector had not found j 20 4 the high school diploma or whatever records were being looked 21
{
j at. When we received the report this was the first opportun-22 ity that w e had on specifics, what exactly did you not find.
23 During the course of normal inspection an inspec-24
- tor will come up to us and will ask us for a record -- say, 25
.g
.. e
.~..
50 I I haven't been able to find this, but they
,.,I need this.
2 talk to us about specific reports, specific cables, specific 3 splices, and then we can produce those records.
4 MR. EISENHUT: What you keep doing is you're making 5 an assertion with which we disagree at the moment and if we've 6 got demonstrable evidence to back it up and we'll reconsider 7 it, but why don' t we just pass the slide by saying we don' t 8 agree.
9 The letter we sent to the utilities said that to we spent "x" number of weeks on site and we asked fcr the 11 records of the inspector qualifications and they couldn't be 12 produced so we gave you a question and said we couldn't find 13 them and they couldn't be produced in the time that we were 14 on the site so -- and that's all we said.
15 Therefore, the question is -- this - our issue 16 when we discussed it in this room back in September was that s
- 37 you either (a) find the record or (b) go back and requal.ify
- 18 the people. However, I have to say that I agree with Jose c ,
g $g a little bit. We're just a little bit skeptical if we've een n n es e r ree m n s and have asked this 20 d question over and over to a number of people and didn't get l 21
- i I the record.
Now here in the last three or four weeks you find'the records so I just wanted to make sure that we all understand where we are. Is that the reason for the skepticj s:
=-
l w w =v
i 51 1
.--it is something we're going to have to evaluate and it is 2
obviously^-- you came to a different conclusion than we did 3
so we're going to have to go take a hard look.
4 MR. DENTON: We're not saying you may nut be 5
right. I am saying you're making an assertion which we 6
don't agree based on the information we have.
7 -
MR. FIKAR: What you had at the time of --
8 knocking the efforts of the TRT that says now that we knew 9
, what they're doing -- if somebody had asked me this ques - l 10 tion I think I could show him the records. That's all. 1
17- .~. .
MR. CALVO: Focus to the foint of an independ'ent 12 assessment of 'all functions. I think that is --
13 MR. FIKAR: That is the whole --
14 MR. DENTON: I see you have a program to address 15 -
these issues, and maybe we ought to move past backgrou..d l 16 l 3
and see what you are doing about them. Maybe it would clar-
= 17 8
ify it.
- 18
! MR. VEGA: Okay. In order to satisfy ourselves ,
j 19 a we recognize again that the TRT reached this conclusion 20 3
based on what was presented and certainly we want to satisfy i
~ 21 j ourselves and address the concerns that have been expressed.
t f ~~~~ Accordingly, TUEC is conducting an expanded review
[ ,[I of the OC inspector certification records against the prcject 24
,M p s ,,
requirement and will assure that the training reccrds are
)l*N *'<* n Qg
. compiled in a format that clearly and concisely demonstrates oh a t a i(} h gl /
- . a
. . 52
, ,.that each inspector meet the requirements.
. 2 The scope of this review would include all the 3
electrical QC inspectors who have ever worked on site, and 4
f all other QC inspectors that are currently working at Comanche 1
5 Peak with the exception of the ASME inspectors that we 6 talked about -- talked about their program earlier. .
I 7 MR. DENTON: Can you give me a feel of how big f
8 a population that is?
9 MR. VEGA: The total --
10 MR. DENTOM: How many electrical QC inspectors k 11 have ever worked at the site? ~
\ : ;
I j 12 MR. VEGA: The total number -- there are 33 elec-13 trical inspectors on site at the present time. The histori-14 cal electricals are 86. The other disciplines excluding 15 ASME are 75.
16 The action plan is basically structured in three E, 17 phases. Phase I will be conducted by personnel that are y 8 independent from the site organization. These personnel are s
- s certified auditors. They're based in Dallas. They report i
20 to the corporate manager quality assurance.
l f 21 MR. DENTON: What is a certified auditor?
I E
22 MR. VEGA: They are auditors that are certified i
23 in accordance with ANSI N45.2.23. Our procedure is based
)
24 on that particular standard.
25 This team will review all documentation available .
9
s e,
- - 53 1
, ,for those inspectors and they will evaluate that documenta- I 2 tion using a checklist with-predetermined attributes that l 3 will generate a summary form that will either clearly indi-4 cate that all requirements have been met or identify those 5 areas where the certification records cannot be verified.
6 That will be handled in Phase II. In Phase II --
7 MR. DENTON: Wait a minute. Going down the item 8 -- do you think there's a difference between our audit and 9 your conclusions and is there a difference over what the 10 qualifications ought to be or is it a difference in what 11 the qualifications of indjviduals actually were? .-
l 12 MR. FIKAR: I think some of the examples that were 13 cited were in some cases documentation that was either not
- 14 reviewed or not made available by us -- in the package,
{* 15 could not specifically identify. In some cases I can cite i 16 the item on the vision test, for example.
t 1 17 Our requirement is to have a vision test that is
\ -
18 appropriate to circumstances. This particular person had E
j 19 failed the Ishihara test which is a standard dock test, but a
there is no commitment in the program to use that specific 20 d test.
21 iE' What was done in that particular case -- the 22 electrical level III who was also the electrical lead inspec-23 tor at the site at that time formulated a vision test.
24 Now the inspector was being certified to an instruction.
25 i
9 -
w
. . 54 1
The only color discrimination that he needed to 2 have was to be able to tell the colors of the information and 3 the jacket. That was the only color discrimination that 4 was needed under the specific instructions to which he was 5 being certified at that time.
6 He took a colored' pencil and showed the colors 7 that we use on site. The p~erson was able to discriminate 8 that. On that basis he passed that particular attribute.
9 Now that item was also reviewed. The test was also reviewed to by the site QC supe. visor and the training coordinator, and 11 they all endorred that item at that time._
12 It is things like that -- there is some element 13 of interpre.tation. The standards that we are addressing 14 is 45.2.6 and Reg Guide 158. As is the case with a lot of 15 standards, the requirements are general, and there is room 16 for a lot of interpretation.
We believe that that is the case. We believe 17
}
- 18 that we are concise in what we say we are going to do and a ,
s
- ig what we say is recommended and we are basing our conclusions i
20 n those particular statemenets and provisions.
,5 E MR. DENTON: I want to be sure we have a common 21 E
22 understandingofwhet{.erwewerediscussingwhatqualifica-tions should be or whether we're talking about individuals 23 and maybe you could -- l 3
MR. CALVO: Also they are disagreeing with our 25 l
l
'
- 55 1
,, -- they're going to implement our action with our inspection.
2 MR. DENTON: So you agree with their standars l 3 for --
4 MR. CALVO: Yes, because if it is agreement with 5 our finders -- consulted in disagreement with our action 6
to the utility, then I guess we're going to have to resolve 7 the difference.
8 The idea with our recommendations to go to the 9
-- to all the QA/QC and getting it to all the other disci-10 lines except ASME and go through all the records and compare 11 them to type of requirements -- find something that is wrcng 12 with it, and go back and determine what an individual has 33 done. so it is' irrelevant whether we can reconcile the end g result. They're going to do what we ask them to do and I am pleased for that.
15 -- , _ _
MR. VEG A: Yes, and we're going beyond that. We 16
- are also going to review the records of the current mechani-37
- 18 cal, structural INC so we are going beyond what the TRT --
C MR. CALVO: Instead of -- give you my current y 3, d
- argument because we talked to the individual who had trouble j 20 d
with the colors and he brought some things to our attention
. 21 i
- as part of the interview and without bringing that one into 22 23 the table I don't think there is need to it -- the fact that they are going to do it -- asked to do, I think it will be all right.
25 1
i i
j
.L.. _. . . . . . . .
56 1 MR. CLEMENTS: Well, the SRT looked at it after 2 talking to Mr. Mega -- the fact that --
like Mr. Eisenhut 3 said, if you came there and looked at those records and it 4 wasn't immediately obvious to you when you looked at those 5 records, that we need to do something to make it more clear 6 and concise so that the records are better so our records 7 henceforth, whether you were to come in and look at it will 8 be more clear and more concise and lined up in a better man-9 ner.
10 MR. CALVO: I agree, but when we went there for We asked for 11 the first time only one mir.ute of my time.
12 the records. There were no records --
13 MR. CLEMENTS : I understand.
MR. CALVO: That is the follow on -- we're going 14 15 to make a conclusion based on the records and I said this 16 is the latest and that is what we did.
- I am not arguing with that. As I MR. CLEMENTS:
5 17 e
say, I agree with you.
- 18 MR. CALVO: Yes, but were you -- for public g gg
"**"* * "#" ~~
20 d MR. DENTON: I think that we --
g 21 (Simultaneous conversation) r 22 MR. DENTON: Let me ask, Jose-- did that person implYthathedidnothaveadequatecolorvisionforthe job he was asked to do?
=4
_y _ , - , ,m --
. .~. . .. .. .
l
--- -. . . l 56 I
1 MR. CLEMENTS: Well, the SRT looked at it after l
, l 2 talking to Mr. Mega -- the fact that - ,like Mr. Eisenhut 3 said, if you came there and looked at those records and it 4 wasn' t immediately obvious to you when' you looked at those
\
5 records, that we need to do somethin to make it more clear
\
6 and concise so that the records are better so our records 7
\
henceforth, whether you were to co e in and look at it will s be more clear and
\ ore concise an lined up in a better man-9 ner.
10 MR. CALVO I agree, ut when we went there for 11 the first' time only o e mir.ute f my time. We asked for 12 the records. There we no re ords --
13 MR. CLEMENTS: I u derstand.
14 MR. CALVO: Th t 's the follow on -- we're gcing 15 to make a conclusion based n the records and I said this 16 is the latest and that is at we did.
3 17 MR. CLEMENTS: I m not arguing with that. As I
- 18 say, I agree with you.
g jg MR. CALVO: es, bu were you -- for public
' *****"" *** ~~
20 d MR. DENTON: I think hat we --
/
I (Simultan'eous convers tion) 22
, MR. DENTON: Let me as , Josc-- did that person g
imply that he did.not have adequat color vision for the job he was asked to do?
\,
I
, ., MR. CALVO: When we talked to him he saic 2 was given by the professional doctor -- he said that 3 chart that we showed him was kind of glarey. Couldn't 4 distinguish the colors in there so I was just wondering if 5 -- well, you know, sometimes those cables, determinations in 6 the control room and sometimes they also color glarey.
7 MR. DENTON: I mean did he think that he was net 8 adequate in this area to the job he was assigned?
9 MR. CALVO: He was very, very nervous.
10 MR. DENTON: But you think that he had adequate 11 construction? ,,
12 MR. VEGA: Yes, sir, and the reason being is that 13 the issue -- it is a bunch of dots and that is --
14 MR. IiEISHMAN: Let me follow your question for 15 just a second. I am Bob Heishman with'IE.
16 Mr. Vega, if you recall during the time that we t
- 37 discussed this issue a bit or it was discussed with members
- 18 of the CAT team in the hearing, I believe, and during the time g jg the CAT team was there, there was also some questions in re-20 gard to -- N45.2.6 of whether or not the program that Coman -
d 21 che Peak had and N4516 were exactly the same and there was I
r a great deal of discussion.
23 My concern now is that we don'_t_ _want to go ahead g
24 and do all of these actions again if we're not together in terms of what the requirements are which is what I think 25 I
I
=
4
~ . .- A 8 , . _ _
2- . ' 58 1 1
1
,. Harold was looking for and so I was satisfied at the end of
, 2 the hearing and the end of the count inspection that we !
3 do have agreement as to what those recuirements are. How-4 ever, sitting here today and listening to this discussion, 5 it raises that same question to me again in that the NRC 6 people went in and made a finding and TUGCO people came be-7 hind and said that is not a good finding because there are 8 some things that are different.
g My concern is that as we oc through and do all to this action olan and we don't know what the yardstick is l
l ti that we're measuring from, we're wasting our time. It may 12 be thatit is appropriate --
13 Oi.ay, I hope it is. That is why I raised the 34 question.
MR. CLEMENTS: I don't think there's any disagree-15 16
"" * **" "# *E*"Y * ^ E# 9##* "" **
- I expects the inspectors to be qualified to, certified to.
g 17 MR. HEISHMAN: That is the only question I am raising.
- j. MR. CLEMENTS: There's absolutely none.
g 20 I
- f. MR. HEISHMAN: Okay.
21
! MR. DENTON: It is good to pick out a case and zoom in on it so that we understand what you're doing. Now 23 let's take something as simple as what -- in order to get in 24 this program does the person have to have a high school 25 t
59 1
,. degree or equivalent diploma, and does your record review
- 2 -- include looking at those kinds of things?
3 MR. VEGA: Okay, let me address that one specifi-4 cally because that is one of the ones that was also in ques-5 tion.
8 Both the ICM 45.2.6 standard and the regulatory 7 guide have statements that are cited verbatim in not only
)
8 our response but also in our procedure. Botn standards have g recommended education and experience levels, but do provide to for demonstrating via examination that the proficiency that it would have been cbtained by that experience and that educa-12 tion have been obtained otherwise.
j, Our program, we believe, is a lot more conserva-u/ 34 tive in that it requires by examination.that the proficiency
. C'[
j4f be demonstrated not only in the context of the procedure and
~
15 16 the instruction but in the implementation beyond the job
- training.
y s l
18 MR. CALVO: I am trying to recall where we find 3, that particular -- I was briefly -- going on all these dif-ls ferent categories. I remember I was discussing the 4:00 d briefing. I remember directly indicated for this particular
. 21
! individual -- was made to the high school that he had attend-ed, however, no response was received from his high school 24 There was no indication whether there was acproval' and piece of paper was in the file indicating that he had a l
=
. . e s
=e g 60 1 high school background. That is the record, and we say, well y
2 let's go back again and we discussed 'it because it was part ci 3 the latest in NRC standard and indicated that you have to 4 have -- should have a high school diploma, okay.
5 So I know we discussed that subject. The record 6 was reviewed, and there was no indication there whatsoever 7 of a high school diploma or a high school equivalent. It a was recorded that a call was made to the high school and 9 that was it. There was no record of any call back or anything to like that.
11 That was the team found at that time based on the 12 information provided to us by you people.
13 MR. DENTON: What did you do in that case?
14 MR. VEGA: In that particular case -- let me
-- when I received the report I asked for the files, the 15 16 particular files and then not only in the QA/QC but the i~
tems, the irs as it were that were cited, the specific irs.
i "g 37 I can address that as a separate issue, but when 18 g ,,
I talked to the training coordinator, he advised me that
~.
there was a GED. I did not really go into -- and I asked l g I
him. I said how long has it been here? He said, well it d 7, ir was here. I said, did you know that they were looking for 22 ,
that?
73 He indicates to me that he was not aware that there was a deficiencv there. -
The GED was from -- now this 25 t
., _ . . - - . - - , - ,--.-,-e e. - - ,
'o ,
1
- .~~ '
l 1
is the information that we had for the specific instance 2 from Cleveland High School, and then he tells me that it had 3 been there.
- 4 He was not aware that the team member was not 5 entirely satisfied with the contents of that folder in that 6 there was no communication. I am sure there was communicatict 7 between the TRC member and you as a team leader, but there 8 was no communication between the TRT member and the utility g fror.. the standpoint of telling us you have a deficiency here.
to The first time we heard of,that was when we it received the report, and at that time then we said, okay, 12 what specific person are they talking about. We got that 13 information. We went to the file and the information was
! there.
94 15 MR. CALVO: All we can do is review what is in 16 the files and we were told to also ?elay this information of 37 ours. We looked at that -- that particular record was not 3,
there.
I. ,
j 3, MR. EISENHUT: Now I think it is important tc e
l look at this generically because remember, we told you in.
I d our letter, we gave you five specific examples. We said we
. 21 i weren't trying to go through and list all of the problems 22 we found because we didn't do 100% on it.
We certainly cave you five examoles for you to 24 look at this. As Harolcl said -- to give some real 25 i
- m.
- . ' h.. . , . _ . . . . . . _ . - . . _ .
62 1
,, understanding of what the issues were, so now the thing that i
2 I think when we look at your program of how you review all ;
3 documentation, we will be going back and looking at how did 4 you handle these five. How did you find -- handle the other 5 problems we looked at.
6 Did you look behind the invoice so to speak.
7 Did you really look and say did somebcdy go through and a check every piece of it or did you just rely on someone g else's judgment, that, yes, I've' checked it and it's all 10 right.
^
i, The degree to which you look at it is also gcing 12 to be an issue.
13 MR. VEGA: Certainly and we concur and we intend 14 to do that very thing, and we're not doing it r.ot only with 15 the inspectors that were suggested but we have gone beyond 16 that and we intend to do that very thing,
,7 MR. DENTON: What would be the product of Phase I?
MR. VEGA: The product of Phase I would be a sum-mary sheet that would show an inspector the requirement that lg a applied to his certification clearly indicating that either f 21 he met them or there.was a question, a particular item g
! could not be verified.
22 That particular item would then be referred for I
evaluation under Phase II.
- 24 MR. DENTON: Tell me a bit about the effort in 25
, _ . _ . . . - , . ~
' 63 i
1
.,doing this. Is it one person or --
2 MR. VECA: No. There have been anywhere from i
3 five to eight people, and I have been dealing primarily '
4 with the team leader so I don't know exactly how many people 5 were involved each dav, but it has been -- the resources k a have been allocated and they have worked continuously -- \ \
7 well, they've included work on weekends and they have been 8 working till late in the day every day. I, I
9 It has been a very significant effort by a whole f to team during the period of about three weeks.
/ -
l -
11 MR. DENTON: peJ1, will the data be together this s
s~
12 time so that if we ask about it, we can go down and pick cut j i
13 somebody's name? I i 14 MP. VEGA: Yes, sir.
15 MR. DENTON: Say we want to see why you think 18 he's qualified and then you'd have in a folder or something all of the data which you relied?
l 17 1
11B MR. */EGA: Yes, l I. '
I gg MR. MARTIN: Tony, there was one answer to this g
1 related series of questions that you gave a few minutes ago, 20 a
d 21 Y u did point out that ANSE N45.2.6 addresses formal educa- l
' 1 j tion basically that the applicant or the candidate should 22 , ;
have high school diploma or equivalences.
23
- However, you said that in your view because of 24 7,
the TUGCO program of certifying inspectors to ccccific 4
e W
e
., ,. 64
' ,, instructions and procedures and that they must demonstrate 2 thrcugh exarlination proficiency in the procedure and its 3 implementation and ycu said some other word which led me to 4 believe " chat perhaps that certification process by procedure 5l instruction and its implementation in your mind precludes 6 the recommended educational level or pregludes the need for 7 the reccmmenued eduent.ional level in ANSI M45.2.6, therefore, 8l in your program -- now I am extrapolating.
f I am presuming from what. I thcught you said and 9i I
to let me come in w!.tn a presunption ard tell me if I am ticht 11 or wrong that since ygu usa such a nro6edure, yov would not 12 as part of the revigw of t.he qualifications gf en inspector Le cog;crisd if he did not have a high school dipioma or .
isl o 14 a C110 because of this preceeding.
15
' you don't c6ncern yourself if there is such kn 16
! absence in ,the file as lonry as the individual has always l t 17 done work for which he has been certified with regard te f l is the specific instruction and implementation.
gg MR. VE.GA: Let me rephrase that slightly. '70 g
have defined what is a requirement and what is a recommends-f 3 .
d tion, and we are treating each one of those accordingly.
21 t*
r If the requirements have been met and that is the require-g ments r OJT, the requirements for classroom training and 23 the requirements for examination have been ret, then that 3
g inspector certification is considered acceptable. ,
- . t- .. .
. ,s 65 1 However, we're going and looking at the recommend-2 ed experience and education. If the recomended experience ;
3 and education have not been met, then that is made note of, 4 and we are going and we're doing -- if there is no verifica-5 tion for the high school ciploma of a person, we're actively 6
going ut and getting it.
7 We -- it is not that we're not concerned. We are 8 addressing it.
9 MR. MARTIll: I am trying to make it as uncencerned.
to What I a'm trying to understand is in the context of an 3,
action plan and in the context of the way you cortify your inspect rs, supp se the guy does not nave a high school 12 diplorra or a GED, does not meet the recommended educational 13 requirements of the ANSI N45.2.6 but he does meet the certi-I fication process, is there an action you are going to take with regard to the work that that individual did er are you 16 .
I going to say that was a perfectly certified inspector and g 17 7 .I don't have to go and icek at his work, and with 4 or 500 it. I, '
g I presume inspectors on the job, you have some likelihood of' g 15 i ,
20 hitting that condition. '
l f MR. VEGA: We would classify that inspector ;
21 l certification as acceptable.
22
/ MR. MARTIN: I am'just trying to make sure I a
( 23 understand that we don't rearrange the issuo at another ,
24 i '
point and come back and raise the issue and --
25 ;
i
~ - -
.,,I . . . . _ . . . . _ . . .
,. ,* 66 I MR. PIKAR: I think you characterized it precisely 2 the way we --
3 MR. BANGART: Tony, your schedule calls for Phase 4 I to be completed by, I think, today, and can you identify 5 any 1~ndividuals who, in your own mind are going to have tc e be referred to a Phase II kind of review?
7 . MR. VEGA: Yes.
s MR. EISENHUT: Out of roughly 200 what kind of 9 numbers are you talking about?
70 MR. VEGA: Let me answer that by presenting things. '
it in perspective by way of documentation that we have.
2' 12 We have 194 inspectors who collectively hold 13 1,629 certifications. Each one of those certifications we 34 are looking at five pieces of information, indoctrication ,
15 and training, general technical training, formal training in 16 each instruction, on t.5edob training and exa.W.ation recods,.
i That is 8,150 attributes that have been looked j
37 ,
,, at. Out of those we have had 252 questions. This is some-I thing that -- something was not defined.
} 3, la There is a question and if this is not perfectly !
20 f 21 clear that all requirements have been met, it is being sent to Phase II. It is a very, very conservative approach. Alt 22
'the decision-making is done under Phase II. '
This is an absolutely worst case condition.
MR. CALVO: I think you have got to be aware that t
I l
l E
I g
67 f ~~ this .is just only one input to the overall programmatic QA/QC' 2 electrical inspection -- in training, and that -- most com-3 mon in QA/QC finish this test, and you've got to show -- you 4 know, you've got to be conscious of the fact that all --
5 look into this and make a recommendation from the QA/QC e because it's looking at the -- this -- our findings, conclu-7 sions, recommendations, how ACI indicates that this could a be considered at the input of QA/QC program --
9 MR. VEGA: By the way, the numbers that I have to cited are not only for the electrical but they're for the 3,
other disciplines and'then' historical'so this is the total 12 picture.
i .
33 MR. EISENHUT I understood that, that roughly g that is how you get the 8,000, but now if Phase II is really 3,
the place you're putting the emphasis, can you characterize who the special evaluation team is?
16 I MR. VEGA: Yes. The --
g 17 I MR. DENTON: Can I go back to Phase I? I am ,
i still slower on Phase I here. The Commission sent out a bulletin back in the 1981 time frame asking people what they l, 20 ,
f 21 were doing with regard to meeting the requirements and the recommended sections of the ANSI standard and so forth cc 22 that when you do Phase I and -- are you checking to be sure that the requirements that you think are requirements were
- 24 i the ones actually committed to on the record? I N
l 1
e
_. . .i
'.. , t-68 1
,, MR. VEGA: Yes, sir. The action taken to generate 2
}. the predetermined attributes were exactly that. Due to the i
l 3
procedures that have been used and they've been going back 4
j and taking the historical procedures -- those procedures i
5 that were used at that time were they, indeed, in accordance i
8 with the requirements of the standards -- that was part of 7 the evaluation --
1 8 MR. DENTON: The requirements -- under you permit-
't 9 ted to on the record to the agency?
10 MR. VEGA: Oh, yes. We -- well, let me make sure 11 that I understand your ques. tion. You are asking me whether i 12 we have made sure that the commitments that are addressed I l 13 in our program or in our procedures and instructions are 14 consistent with those in the FASR in our quality insurance j 15 program.
lJ 18 The answer to that question is yes.
i !
ty MR. DENTON: So Bob's question then about how you i'
- is are handling requirement versus recommendations could be l I
- ; ,, discussed somewhere in correspondence, and we probably have s
20 come to agreement on how to handle that in the deep dark past
- d 21 a mewhere.
! ,, That is what you are following.
23 MR. EISENHUT: Harold, I think it is important to 24 n te that the project requirements --
. DENTON: About 1981.
f 25 I
i i
I
. ' . . _ - . 4
.. i 69 ,
! 1 MR. EISENHUT: About 1981 so -- ,
! 2 MR. DENTON: I just wanted to make a point that i I
i 3 you are meeting then whatever you t old the agency you'd be {
4 meeting in those time frames.
5 MR. VEGA: Yes, sir.
4 MR. DENTON: That is what you're starting Phase I 7 with.
8 MR. EISENHUT: Absolutely.
9 MR. DENTCN: And there may be differences then, to depending on the time frame. Is that what I .kear?
l 11 MR. EISENHUT: The requirements do change in 17?l,
s : .
l> l 12 and at that point we're using the agenda procedures that l l
l
- 13 apply and address -- those are commitments.
14 MR. EISENHUT: Harold, I have a question on Phase -
15 I, too. I forgot. You mentioned something a while.aco that 16 in the answer to a question -- you commented to the effect !
where you weren't sure of the details because the review 37 l 18 team leader was doing sdch and such.
l .
j to Who is the review team leader in this area?
j ,,
Is there a -- you mentioned about having issue coordinators, a
f ,,
about having review team leaders -- they had been assigned ;
. as issue coordinators in some cases and in this case, is there an issue coordinator? Is there a review team leader?
,3 Are you both or are you one?
MR. VEGA: Okay. I am both for -4 and what that !
i i
~
- . 't., , ._ ._ i
' . ' 70 1
refers to is preparation of the plan, the action items, 2
f I.am both.
~;
for submittal to the senior review te.a i .
3 Now that is separate from this particular group I 4 that is doing Phase I. Do we understand that?
5 MR. EISENHUT: I have another question. Is there 6 a review team leader for this issue?
7 MR. VEGA: Yes. I am both.
1 i e MR. EISENHUT: Okay. All right. This is one of 9 those cases that --
10 MR. VEGAS, Had I assigned that to somebody else 11 to work on it, formulate and -'
12 MR.' CLEME:TS: Darrell, the head of the audit 13 group, auditing, does not report to Tony. He repcrts to l i
14 David Chapman ar.d David Chapman reports to me, David Chapman 15 being the QA manager.
16 The guy who is leading up this TCGCO Audit Group j7 does not report to Tony.
ig MR. EISENHUT: The reason the question was asked ,
! s of Harold of how many people are in the audit group or how i .
19 l g big an effort is this TUGCO Audit Group.and the same ques-a d tion I was going to ask about the special evaluation team *s 21 i
- I was concerned about how big are they, how did they inter- l
- 22 act, how do they -- under whose supervision are they and how
,3 1 do they work under the issue coordinator or -- I
! 24 I MR. CLEMENTS: The TUGC0 Audit Group is working t
l
. 2... _ _ - _ _ _ _ . . . . _ .
71 q
1 separately. They are just a group that I brought in with ;
2 the cencurrence of cur chairman of the SPT to completely go 3 through the records and see what the condition of them were I
e and what they can verify a.nd what they -- what has to be 5 referred to Phase II.
l 4 Those people are external to Tony's organizaticn.
7 They report to David Chapman in Dallas and David reports to 1 . m..
3 MR. EISENEUT Okay. Is it fair to say that that i
to job is more non-decision -7.., king but rather what I'll loosely is call administratively going through the files and compiling 1
l 12 the data no that they've got a certain --
i 33 MR. CLEMENTS: He says up thers that they have a i
i4 checklist With predetermined attributen, and if they can !
l .,
15 verify those attributes are theirs, fine. If they can't they is are referred to the St.T. l, I
y ME. SPnMCO: The judgmental aspects of it ec a j 18 in Phase II under another --
I :
g jg MR. EISENHUT So Phase I is really collecting f 3, data and putting it in binz --
i f MR. CLEMENTS: That's right. Making sure that 31
- the record is better to look at. That is what I was refer -
22
- ring to a while ago.
- M3. DENTOh!
- Let's go to Phase II.
24
. H P. . EI?r.NitCT: The question on the flocr is what 5 e j
1 .
8
,e .*
72
- r 1 is Phase II and what is the Special Evaluation Team.
2 HR. VEGA: As far as Phase II is concerned, answer- -
3 ing your question first before I get into it, the Special 4 Evaluation Team is a team that is comprised of people outside 5 of Texas Utilities Electric Company.
g These are consultants that will be writing the 7 procedures and will be in essence resoonsib le for administer -
e ing the items that are defined under Phase II.
g Just to repeat what I said earlier, ,any questions to that are generated out of Phase I, any instance where a
,, record is not verified in Phase I wil'1 be referred to Phase 1
12 II. They will use specific evaluation criteria and the
,3 basis that they use for their decision will be documented.
34 MR. CALVor Also on Phase II will be root cause
, if aopropriate -- also will be developed on Phase II.
MR. VEGA: That will be addressed in Phase III I frem the standpoint that quality engineering and we'll take 1-7 g
4 . the items that, where qualifications cannot be demonstrated, 5 g
is they will review the record to determine the safety -f he i g. Is project and they will then answer the question why did it f
20 J
happen.
21 MR. CALVO: On Phase II -- you fourd something 22 i
with P.hase I -- would it not be a possibility of Phase II 23 l -- one is the group cost, whether to do some work because 24 something went wrong with Phase 1. If everything is okay you 26 i .
l - . .
e
~
.* 73 I
.,, don't need to have Phase II or Phase III.
2 MR. VEGA: That is correct.
3 MR. CALVO: Because if you look on Phase I to 4 Phase II you must have some root cuase there on Phase Il to
's be evaluated.
8 MR. CLEMENTS: We would ask the SET to make their 7 determination of what caused the problem.
8 MR. EISENHUT: Yes, I just second Jose's --
9 think it's necessary because those are the people that he's 10 laid out the problem for who are really going to be looking 11 at the questions that come,out, the gyestignable areas 12 coming up with using specific evaluation criteria.
13 I think that would be the group that you would 14 certainly want to make a call at least in the first instance.<
15 Phase II appears to be -- now, given whatever you've got, /
16 going out and looking at whether or not the plan is safe or 17 not.
g 13 MR. CLEMENTS: Yes. We would ask the SET to take i
- to a look at those reasons, why they happened.
l.
a 20 MR. EISENHUT: And then I would expect that when
$ you -- perhaps I am getting ahead a little, but whenever you 21 a
i 22 send us your response to 101, an integral piece would be whether the special evaluation -- what the special evaluation
'23 ]
24 team concluded. ]
25 MR. CLEMENTS: Yes, sir.
l l
)
. . . % am 4 .
% 's. ,*
y 1
MR. EISENHUT: Good.
2 MR.,NOONAN: One other question. On the Special 3 Evaluation Team, it is still not clear to me who those 4 pecple ares You said consultants? What does that mean?
5 MR. CLEMENTS: Well, we've selected two of the a people for the team and rooting for a third person. I think 7 I havs him in mind. We have two people that meet the require +
a ments in the action plan, Mr. Noonan, and I have forgotten 9 one of their names.
to The third person we're looking at is a man who si has been in quality assura,n.ce for 30 some years and we're 12 still talking to him to see if he's going to be available.
13 Th7t is -- those kind of pecple, external to our 14 company. None of the three of them have ever worked in any 15 consulting job with our company until now.
16 MR. DENTON: It is time to take a short break.
37 (Off tne record.)
18 MR. EISENHUT: Administrative items first.
g 3, Over the break we discussed it, and I think we s
l ,, came to the conclusion that it would be best to go ahead 5
d g and break at about 1:00 which was our previously planned time I
r 22 so recognizing the hour, we just ought to press on through to where we are at 1:00.
! From a logistics standpoint I think we ought to 2"
,< ~
l go ahead and continue through to finish the QA/QC area.
N 25
, - - w_ .~
i a
71
- s. ,. ,
1 Perhaps the second arek we ought to continue through would 2 be the electrical area following going on to the other areas 3 in whatever order you have it.
4 I asked that each individual identify himself, 5 particularly those people from the audience if anyone speaks, e
to identify themselves for the court reporter, and with that t 7 why don't I press on if that's agreeable to everyone.
8 MR. VEGA: Okay, for the record, Tony Vega again g continuing on QA/OC with Item 1B2. i As a resulf of the TRT assessment, the NRC iden-10 tified a lack of certain guidelines in our testing and cer-tification procedures for electrical QC inspectors. The 12 %
13 action that was specified by the NEC was that TUEC develop a y testing program for electrical QC inspectors that provides Ese recommended guidelines to assure that suitable profiency
, ~ . _ _ . _
is achieved and maintained.
I By way of background, the current procedures allow g 17
- for the engineers to develop tests appropriate to soecific 1
circumstances, and we recognize that additional guidelines ,
j 19 l l
would reduce potential for inconsistencies.
f, 20 Accordingly, DUEC intends to trace the following f 21 l actions: relevant procedures will be reviewed and appropriate!
ly revised to provide more definitive guidelines including i 23 those recommended and will point out that these procedures 24 ,
pertain to the training and certification of all inspectors, 25 l
l O
s
.. ,* 76 1 .not only the electrical inspectors so we are anplying a gen-2 eric solution, and certification testa currently in use will 3 be reviewed and appropriately revised to reflect more defini-4 tive guidelines again consistent with the recommendations.
5 This is a rather short item. This is all I have.
MR. CLEMENTS: You didn't point out Tony the 6
7 outside support.
ftR. VEGA: Yes. Thank you. I would like to 8
g point out that we have acquired the services of an indepen-10 dent contractor to come in and look at our training program, y our procedures and to help us to imorove our program, to
~'
12 give us comments so that again we can upgrade it and have
- e the best possible program that we can have.
13 Are there any questions? Gentlemen, thank you.
j,
!!R. !!FP.DITC : Thank you, Tony.
15 arry, if y u w uld please go ahead.
16 I MR. POPPLEWELL: My name is Larry Popplewell. I I " .
am the team leader for the electrical and instrumentation I ,
First issue involve heat shrinkable cable insulation group.
g Y sleeves.
[ M j MR. EISENHUT: Before you go on maybe I could
. 21 ,
! ask the same question I asked Mr. Vega earlier. Can you characterize your background, your involvement or your non-23 involvement in this carticular area and associated prob' lens l 24 previously?
l l
- i. ,.
77 1 MR. POPPLEMELL: Okay, I ar. at the cresent time 2 the engineering manager for the construction engineering 3 group. Previous to that which started in 1979 I was the 4 project electrical engineer. Recently I assumed the role cf 5 the engineering manager August 1.
6
- Prior to that I was in our Dallas office involved 7
in fossil plant design and construction activities. My a
educational background is that I am a degreed electrical g engineer. I am a registered professional engineer in the 10 State of Texas and I have a master's degree in Business Ad-ministration.
=' :
MR. EISENEUT: How long have vou been with the 12 company?
13 MR. POPPLEE7 ELL: Been with the ccmpany 13 vears.
34 As far as my involvement with regard to these issues being the project electrical engineer, I have been involved =cre I or less in all of them at one time or another.
g 17 MR. EISENHUT: Let me ask you a quasi-philosophi-cal question. Were there anything in the findings of the j 19
! TRT that surprised you?
20 l
4 MR. POPPLEWELL: No.
21 l
! MR. FIKAR: I was going to answer that, too. '
n .
We're not really surprised of the findings. We can under-23 stand how you got to them.
24
.MR. POPPLEWELL: As each group, Mr. Calvo's team 25
78 I .; members would either speak to me or others in my organization 2 we discussed their questions and tried to formulate an opin-3 ion s to what the issues were so we were not surprised.
4 MR. EISENHUT: I am sorry. That last thing has 5 raised more questions than the previous answer because --
6 were you not surprised just because of the continuing dia -
7 logue the staff obviously was working there at the same spct 8 or -- really the question I was asking was more on the lines 9 of were you surprised that these issues came up after at 10 least, in your mind I would have expected you would have 11 thought there would really,)e no sign,ificant issues that we 12 would be identifying that would be broughtbup this late in 13 the project.
14 It wasn't really'more the surprise of a few renths 15 ago versus now. That really wasn't what my question was.
16 MR. POPPLEWELL: I am never surprised of the s
17 issues that come forth -- because there are questions to be
- 18 asked and questions to be answered.
s j 19 The NRC stated and it's recounted for you in our plan that there was confusion existing as to when witnessing 20 21 f the installation of the shrinkable sleeves was to be docu-3 I mented. They cited some examples of that.
22 Our action was to -- requested by the NRC was to 23 c
clarify our procedures, perform or have the inspectors try 3
and assure that the sleeves were installed where they were i
1 l
+ -
. . - . . . . l i' ,* 79 1
required.
2 We also did some of our own looking and we deter- l 3 mined that the inspection reports do not consistently indi-4 cate when witnessing is required, witnessing of installations .
~
5 A possible u'ncertainly exists as to when documentation is 6 required; however, we agreed that there was no instances ob '
7 served where the sleeves were required and were not addressec a by the inspection reports. In order to keep this possible g uncertainty at a low level and nonexistent, we are going te ja revise the installation procedure, revise the inspection 3,
procedure'~that follows, train and certify the inspectors -
12 to the appropriate procedures and initiate an inspection
. :- ..s.
sampling program to assure that the sleeves are properly 13 34 installed.
' .. A 0: The only question that I had was 15 with the sampling system. Maybe we can discuss it because 3,
I I have the same generic concerns of the sampling system.
You could use the mill -- I don't know which revision you have. The one that I am looking at is 1962.
- 19 i By looking at it and trying to understand how j 20 f you would accomplish this, the concern that I have that is
. 21
! not quite clear from that standard is what you put in the 22 extra claim and maybe would like to request that you would 23 include this in the amendment to the action plans -- indicate 24 how many of the number of inspection reports that you are 25
- , , ,--,- .- w,- -w ,.-4y- -, -m-p -., ~ --s y,.-y e-
.. - - . . . ' ~
OV j going to look at pnd'bascd on'that numbar of inspsetion re-p rts that you are going to look at, indicate what is the 2
selection, what is the randon sampling that you're going to 3
use and which equiement associated with inspection reports 4
and what have you selected.
5 I also want to indicate what is the probability of success to achieve a 95 competence -- 95/5 and you indi-cated. Also I'd like to know what is an acceptable quality level to achieve 90 percent -- 95 percent competence and new the other one -- what is the inspector sample site if a normal inspection failed to be 95 percent competence level.
11 ..
It really worries me.
12 The Comanche Peak has two redundant train , ckay, 13 and if you go back to the safetyness of the claim, we costu -
14 late an accident, concurrent with the outside power, assuming 15 a single failure, and I am going to assume that failure of a 16 8 diesel, so I am going to disable one train.
g 17 Now I am only --
'he other train, and I am just g 18
- wondering if using the samoling system you -- rejection is j 19 y acceptable criteria that you could use in -- give you a 2 20 g rejection of approximately when you exceeded 22 bad reports.
l 21 The question is which equipment do you select so l
22 you can make -- do you select a diesel and you concentrated 23 with it -- of 21 -- what is the significance of those 21 24 projections. All I need is one more termination with the 25 disel that is remaining ther2 and completely lost the capabil -
e , , ,-, p
81 1 ity so I think the selection equipmsnt that you're going to 2 use for the -- see we didn't select the equipment which, 3 upon their failure, under accident conditions -- would be 4 lost to outside power -- have to greater contribute to a -
5 In this case I would like to concentrate your 6
random sampling if you can and the diesels and the batteries, 7
those pieces of equipment or inspections that have been a
greated contributed to the plan -- to lose the intent to g function in the middle of the action and concurrent w.ith the lost outside power.
10 That has got to come up in the report because 33 . . . ,
otherwise you could be concentrating on 500 with emergency lighting that have no -- except the consequences. That --
g the report is missing not only in this action but in all the other. action clans.
C 15 MR. POPPLEWELL: That's correct because we did
. 16
! not get formulating --
g 17 MR. CALVO: And this is standard -- that is y 18 I; 19 not explained here very well either, and also you must go i to the applicability of the standard to -- where you have j 20 J a nuclear power plant. Talking about pieces of equipment in
- 21 j here -- missles, and not only can lay that to focusing.
I wish you'd consider those comments and address 23 them and go over the basis for why you want to use the 24 central system.
25
U
- :. 82 1 MR. EISENHUT: Lou, did you got all that down?
2 MR. FIKAR: Yes.
, 3 MR. EISENHUT: Good point.
4 On several occasions you had mentioned that the 5 program plan at the time was being developed and certain a things weren't available and things have evolved since then.
7 One thing I guess I'll ask you at the end of the meeting 8 would be to consider revising or updating or amending the g program plan, prior to our appreval, obviously to adopt our 10 comments and to update it to o.ner information that you have.
99 MR. FIKAR: Yes. Me intend to.
12 MR. POPPLEEELL: That is all I've got for this 13 one.
14 MR. CALVO: One more -- I guess you don' t have to 15 give the answer, just for the record. I went through this i
16 in here ~~ and it had to do with action 4B -- you didn't 3
j 37 mention the fact that -- I look at you -- construction
- 18 inspection procedure - QI, OP-11.3-40. It was not addressed in your action plan.
I. You can provide the reasons for one -- that was j 20 d not used in here in these acti'on plans.
. 21 3
i MR. POPPLEi?2LL: Next issue concerns inspection 22 reports on butt splices. NRC found a lack of documentation on butt splices --
24 MR. CLEMENTS: Speak up a little bit.
- 4
83 1 MR. POPPLEUELL: NRC found a lack of documsntation 2 on butt splice inspections. They cited several soecific 3 examples of this. They requested that to ensure that the 4 required inspections have been performed and documented tc 5 verify that the butt splices are identified on drawings and 6 to verify that butt splices are identified within appropriate 7 panels.
8 We took a look at this particular issue and re-g viewed additional inspection reports and I agree with the to statements that have been previously made that inspection i,
reports or documents may exist that may not have been asked 12 for because they may not have been known to be asked for.
13 Our inspection reports on cables, for example, y concern cable pulling -- exists with cable:, any activities involving cables such as termination, want to lead her in, any' repair that exists, any splicing *. hat exists, any re-
- termination that exists, all have their respective inspec-tion reports.
- 18 I am not sure what Mr. Calvo's groues reviewed.
i 19 1 1
- i. When we looked at the inspection reports involving the l 20 l
4 butt splices we found that the butt splices had been wit-l 21
! nessed and had been documented on inspection reports that 22 occurred during the time that the butt solices were made.
23 Some inspection reports that were documented in 24 your letter of September 18 were inspection reports post-25
~
r
- - . - - - - - - - e w - --i ----r - & - - - - g ,--me- - - -
- ** 84
., ,.. j 1
. verification - post-instruction verification inspections, 2 etc. so that attcibute was not either witnesses or was not 3 verified.
4 We did, however, find that those documents did 5 exist. "ased on the f act that there is a disagreement between 6 our findings and the findings for the TRT, we're going to 7 institute an inspection Drogram to assure ourselves and 8 you, too, that this is just a misunderstanding of where docu-g mentation might exist, and we're going to review some in-10 spection recorts and some cables and'do some insnection there .
~
33 MR. EISENHUT: Nell, let me ask you a basic aues-12 tion. You said you found that inspection reports did exist.
13 MR. POPPL" SELL- Yes, sir?
34 They were in.the file. Were not lost.
15 PR. EISFNHUT: All right. They were in the file 16 where you would expect -- I mean all the inspection reports s
- 37 on cables to be?
- 18 MR. POPPLEWELL: Yes, sir.
,, MR. EISENEUT: I mean you didn' t have to --- all a
i right.
l 20 f
. 21 MR. CALVO: The problem.is that when we get 3
i the inspection, the random sample inspection report, if they are reports that we've had reviewed -- indicated that it was an onl'y report -- deference to something else -- then we 25
-- never found the reference and we assume that - the
~
i 85
\
i T inspection reports -- .
'.i 2 HR. POPPLEWELL: That's correct. That would not i 3 be referenced because the inspection process would not 4 necessarily reference previous inspections. Let's say we 5 have a -- maybe Mr. Vega can explain the process a little l
6 bit better than I.
7 MR. VEGA: Yes. Let me tell you what we did a when we found out exactly what we were talking about. Brought '
e the specific inspection reports and then pulled out the 10 cable nuncers. Knowing how things are filed at the site, 11 we asked for all the inspection reports for all the cables 12 that were listed on the inspection reports.
13 We initiated this action about 11:00 in the morn-14 ing and by af ter lunch, by 1:00 we had a stack of inspection 15 reports that covered all inspections that had been done on 16 all the cables and as Larry mentioned, some dealt with the j 37 pulling of the cables and subsequently the termination of 2
- is the cable and then the splicing during the Three-Mile Island i g ig modifications that were done which is when some of these i l l splices -- when the splices were done and then the irs for l 20 l
d the construction, verification.
. 21 I
- Again it is just knowing how things are filed and 22 how to call them.
23 MR. CALVO: Again, we did ask these same ques- .
24 1
'tions you asked when we were there. All the inspection 25
+ . . . ** . ,
- 86 f th2m then 1 ,. reports -- after we colected the random numbar o 2 we went back and said, let's find out if there was anything 3 else that had been done after this particular inspection re-4 port that we had done.
They said, no, that was it. There's.nothing else.
5 6
S when you're saying -- you .know, the capability to retrieve j 7
things independently -- some kind of way it appears that we are -- appears that we have some problems on that. Supposed-8 g ly you're finding the right thing and we're finding the 10 wr ng thing but independently we have requested -- maybe g
same request you made and we're finding reports that we
=: : \
f und some deficiencies with so it still -- something in 2
,) there problematic as f ar as the capability to retrive records i
and independently assess whether those records had been carried through and the deficiencies properly implemented or corrected.
16 3
- MR. : My understanding -- this was j
17
- presented in the Review Team -- was that you guys may have
- 18 asked for the last section of the report. Didn't ask were
- 19 I. there any inspections. performed after that and the answer j 20
- f. was no. As both Larry and Tony indicated, there are a 21 i variety of inspections that were done-during various time 22 frames associated with cables and questions, and were these 23 inspections documented -- inspection reports prior to the 24 final one -- whichever one was in the final evolution.
25
s s- ., a 87 In other words the inapaction reports are done on 1
an evolutionary basis.
2 MR. C ALVO : Yes, but you don't care about the 3
past. You care about what you had and what you h ve done 4
sometime in the future, and that question was asked and the 5
information provided to us is -- that information that we used to get to old findings.
7 You've got something else in there that you do not provide it -- it appears that this is the second phase that we had the same kind of a oroblem.
~
The information 10 some kind-of way was there and'some kind of way was not 11
. made available to the TFT.
12 You can leave it at that.
13 Then the action that you take -- I have no objec-14 tion with your action for that Phase I.
15 MR. NOONAN: Before you go I'd like to ask a 16
! question on this and maybe Mr. Vega is the one to answer it, g 17 Were these files used by the QA people prior to the TRT g 18 8 coming in? s i 19 ;
j . MR. VEGA: No. We did not -- we did not know j 20 ,
g what records were asked. I did not talk to the people that 1 l 21 TRT members talked to. I don't know how exactly the ques-l 22 tions were raised.
23 MR. NOONAN: I am not talking about that.
24 MR. VEGA: Prior to the TRT --
25 l
i I
- ,s .
- ,. a.
gg 1 MR. NOONAN: Have the QA -- reviewed by QA organi-2 zations?
3 MR. VEGA: Normal QAs are reviewed but not any-4 thing post to -- TRT was coming. Is that what you mean?
5 MR. NOONAN: I am talking about normal QA reviews.
6 MR. VEGA: Yes, sure.
7 MR. NOONAN: It had already been done prior to the 8 TRT?
9 MR. VEGA: Yes, that had been done but not 10 because TRT was --
11 .dR. NOONJR : Right.
12 ER. EISENHUT: Well, I guess that goes back to 13 something we talked about earlier. There will be people 14 obviously going back to the site doing some additional --
15 this was the point I made' earlier when I said that we kept 16 emphasizing in previous discussions that the first iteration that discussions had been done -- so then I would say that 17
- h. ,
- 18 the next time the people go down to the site and look at
- ig things, we want to make very sure that the staff -- if you
' l 20 have got to twist the question a little bit -- I am going j d
21 to request you folks' help, in helping us ask the right ques-
- = .
I tion.
22 MR. FIKAR: We'd be glad to.
23 M2. CALVO: Keep in mind that in some cases g
ue could not have done that because we are trying to protect 25 9
,* 89 l
l 1 .the --
2 MR. FIKAR: I know.
3 MR. EISENHUT: We appreciate that.
4 I think that is the key right there.
I 5 MR. CALVO: But again you should have a subtle e record -- independent and can be verified.
7 I don' t want to go around the world to determine l
a whether you have done something in the inspection report.
9 When I want to have the cable there I'd like to know what to else can be done with that cable, not only what this report 33 was -- yoO are going to t e future -- the satellite inspec-
= :
12 tions you're going around with.
33 We asked for that information and we didn't get 34 that information. Maybe we're asking for too many -- trying to protect the source. That could very well be the. case.
15 MR. VEGA: These inspections had been done prior 16 s
and so if you asked for anything from here on now you would 5 17
- 18 n t get them. You would have to have said let me see the j 3, inspection records for everything that has an inspected on a
ig that cable during the history of the cable.
20 MR. CALVO: We also do that. Anywav, I do not d
. 21 E agree with 12 additional cables. What did you base this when became 12. Why not 300? Why not 1,000?
23 If we have a problem or not -- the record that 24 I reviewed and the record that you reviewed -- they're 25
- - , -- , - e --
- . *' .. 90 I different.
MR. FIKAR: Well, you asked why. Me proceed 2 :
3 differently and if we have a disagreement we find out now. !
4 MR. CALVO: That's correct.
MR. FIKAR: But you asked why. We found there ,
5 6
was nothing wrong with the six cables you gave u's and the 7 other six is 12. We said,sokay, we'll review them again 8
and we'll just take 12 more random. We'll go cut and get g some cables and look at them. ,
That was the reasoning the FST decided on and .
10 it is as -simple as that. You'say, well, take another 12 r -:- _
and then look at it -- exactly that. -
MR. CALVO: Because my office and the people ;
that you've been -- going now to 12 I think you should use the same sampling techniques that you use for the ,
15
-- what you did before for the shrinkable sleeves , you 16 I should also use it -- ,
j 17 I MR. GOUBERT: I want to make a point frcm the 18 i
0 SRT's psrspective. Let's use this. If you can shoti ,
j 19 i objective evidence that there are inspection reports for j M J
all of the cables in question -- evider.cc in the file, l y 21 j then if we're in a position where there's no questicn with -
. 22 p ,.
respect to those cables, we're going beyond that -- 12 23 more cables. 7 24
. MR. CALVO: You can use that. argument for anythir g 25 ,
4
$=
- - - - -' y
,f 91 I
_; you've doae in here and if you found something wrong with 2 TRT, we're going to show it to vou that the -- documentatier 3 we looked at is the wrong - for all practical purnoses vou 4 accomplished your action and you have nothing else to do.
5 MR. GOUBERT: All I am saying we were doing is --
6 MR. CALVO: Based on your system of record, and 7 were there -- we requested the right kind of information. and 8 we didn't get it -- three months later that information in 9 some kind of way was misplaced and we didn't ask for the to right kind of things -- all of a sudden it's in your reccrd.
11 That's ou'r finding.
12 MR. FIKAR: Jose, you characterize that rather 13 differently than uhat we see it. How if you had come to us 14 and asked us specifically what you wanted, we would have 15 found exactly what Tony found. It is unfortunate that didn't 16 happen. Part of that is our fault and part of it is the j
] 37 independent's problem.
2
- 18 vie need to get you to go look again at all these 3, records and then if you still feel that way we can pursue a
ig 20 but if you're still seeing your position and not accepting d g that perhaps unfortunately we weren't able to furnish you
- 3 E what you wanted and we tried. We just didn't get it to you.
22 g We need to have another pass at that. That is what our team felt. Well, in this particular ir. stance we didn't find anything but we'll look at another 12. Now if ye a i
7
-me w c .
.. 92
' , -don' t agree to th'at we may have to do more.
2 MR. BECK: Let me just say something. Apparently 3 what is needed is -- the most common thing I've heard through--
4 out the last few days is that we come up to -- whether this 5 number is 12 or 1200 -- to me it doesn't matter as long as 6 there's fcundation. If it doesn't appear clear to the staff 7 then there is no basis for this number.
8 MR. CLEMENTS: Our problem was was what they said, e We felt like -- a lot of times in order to pick the cource 10 of the allegation of whatever it was that the right ques-
~
11 tions were'n't asked of our s,taff, and that is not our fault.
12 MR. CALVC: Let me give you the significance.
13 MR. BECK: The staff comes in -- doing on it --
i 34 they have to go under certain constraints. Have to protect 15 the identity of the person they're dealing with. That is 16 uppermost in their ninds. Files should be auditable. Should a
j 97 be ir a form of -- l i
18 MR. CLEMENTS: I agree. We need to know what
,, files they're looking for. If they're dancing around the a
ig 20 subject at hand, then maybe we don't produce the right d . records.
21 \
- i. l r MR. CALVO: Let me give you the importance of i 22 l l
this particular issue. Butt splices, according to require- !
23 .
ments are properly discouraged and in some cases they aave been prohibited. night af ter a guy won -- butt splices shoulc.
=. - . ._
.c ., e -
93 1
should not be F11 owed in cable --
2 MR. POPPLEWELL: We don't disagree with all of 3 that.
4 MR. CALVO: I am getting to the significance.
5 In ' amendment 44 to the FSAR you provide her with information a relevant to butt splices, and you say well, look, my commit-7 ments before -- I am trying to have some exception to those 8 canmitments. I am not going to comply with these require-g ments, with this criteria as part of your FSAR.
10 Then you -- right in amendment 44 across and you 33 say, I'd Iike to do somebody's splices because problems are 12 happening with manufacturers, things have to be changed l around, and you say, okay, we're going to look at.it and 13 )
34 based on that. guideline we're going to find out whether it 3, is acceptable -- based on this limited amount, okay?
o g ng by with these butt splices -- we 16
{ g feel that we're giving you exceptions on a commitment, and 1
,, we figured out that it was based only on limit so that they I
i
}. felt that the butt splices was a very significant deviation I. from figures of your requirement -- say we want to concentrate j 20 l f 21 on this effort so that is why we picked this up.
g l Some allegations to that effect -- you have not 22 done this kind of work, so based on that we had; to be care-23 l ful whht we selected and we did this.
24 ;
Let me ma'ke one statement to MR. POPPLEWELL:
25 s
,- -' l l
,. .t 94 There are approximately 8 cabico i
1 . clarify. butt splicca in 2 these cabinets, and I understood that the TRT locked at &
3 number of cables and butt splices in them.
4 Using a factor of five or maybe ten splices per 5 cable -- I am talking about wire per cable, we're talking about the TRT looking at a minimum of 120 splices. We are 6 ,
7 going to look at an extra 120. I believe that that issue is 8 greater than what we would find by most standards even though g we didn't --
MR. CALVO: It is not good enough.
10 3,
' Why don't we look at 100 percent of the butt 12 splices because I am only accepting the design on the basis 13 that you've only got a limited amount of them -- want to know how many you have. That is our position on 1B2 and also on 34 the next one that we're going to talk about -- butt splices.
I am s rry. We took a position and we say -- we 16 think it's dif ferent from that and we are belahoring our j 7
- g own report. I am s?.ying consistent with the verifying all of the butu splicas on Phase II, maybe you can factor into C
l.
that how many inspection reports that you can look at consis-g 20 f tent with witnessing how those butt splices were done.
. 21
! As a matter of fact when you get to next one you 22 are going to find out that you are doing what I am asking ,
you to do because the next item that you have you say that 24 you are going to have to do that to verify ccmpatibility of 25 t
+
95 1
,,,the butt splices. You are again saying here -- when you go 2 to the other one you're going to find out that you truly --
3 you are going to follow our recommendations. .
4 Why don't we put this in abeyance for a while and 5 get to the other.one and see how we are.
6 MR. POPpLEWELL: The next one is lA3 and has to 7 do with the qualification of butt splices. TRT found the 8 lack of splice qualification requirements and ?. hey found a 9 lack of -- in the procedures of the operability -- verifica-to tion of operability in the circuits in which splices occur.
11 We were asked ,--
t_o, develop procedures to assure-12 qualifications to service conditions which the splices were 13 installed and to make sure that the splices are not located 14 adjacent to each other.
15 Our installation procedures do not address the 16 operability of circuits, but our startup program does and r
i: 17 we rely on that. Installation procedures do not address
- 18 qualification of butt splices in formulating our amendment 44 C /
j 19 which you wrote the SER to, we looked at the mild environ-ment conditions in which the splices were found, that they 20 d were the same construction as the total and I believe these 21 3
I r are spelled out in the FSAR mmendment.
22 We installed,them in the applications per the FSAR
- requirements. New criteria was offered to us in the SER
, which was to stagger the butt splices. Our action plan is I
, ~
. *
- 96 1
. to preclude any misunderstanding. We will include a continu-2 ity check in the construction installation procedures.
3 We will supply or develop the qualification docu-4 mentation by contacting the appropriate vendors, get an 5 appropriate qualification document, and we will perform the 6 inspections necessary to ensure that the splices are appro-7 pr4ately staggered. That will publicly answer your concern a from the previous one.
g MR. CALVO: That's right, so if you're going to 10 do it in here you're killing two birds with one stone and 33 we'll be -- .,,
12 MR. POPPLEWELL: Right.
13 MR. CALVO: So what I am saying -- I cuess my 34 comment is that this particular action plan, Item I..t. 3 15 and Section 4A, the action plan -- you can coordinate that 16 ne with Phase II in item I.A.2.
, ; g Also bandles containing splices in Section 44MB f this item 1.A.3, also you can coordinate that one with 18 I '
, Phase II of Item 1.A.2, so whether you would object or not fg -
20 to do that, look like you also accomplished anything here.
f 21 What I am asking is to take that Phase II of the 3
! previous one and coordinate that one with Phase I in determin -
ing, based on the effort in here -- how many inspection re-ports you are going to have to witness it because it ties 24 .
l back to the butt splices .
l 25 i
p y_p-,. ,--. . . --- _..--,r ,y - - .r p ,-w ----e.- m-w-.--m --.,.+ %-- -g->w- -e+ 'c w -
t * --u
, ,e
- 97 1
MR. POPPLEWELL: So you're asking us to modify 2 our plan to --
3 'MR. CALVO: Yes, because we know where the busy 4 ones were and you didn't want to do 100 percent, but you have 5 to do 100 percent anyway in here.
6 MR. POPPLEWELL: Okay.
7 MR. CALVO: Now the other question that I had 8 with this particular plan -- you indicated that you have done
__ s these tests as part of your installation. I believe --
10 MR. POPPLEWELL: Part of the startup program, yes, 11 sir. - , -
12 MR. CALVO: B'ut I guess if you dif this test I'd 13 like to, I guess, indicate how the test was accomplished as 14 relates to the butt splices. Also what were the exceptions 15 in rejection criteria or accepting or rejecting butt splices.
16 Can you tell me how any one -- that it cannet work .
- 37 You say that you have done it before.
MR. POPPLEWEIL: I don't believe that our startup 18 I i c
3, procedure addresses butt splice installation or usace specifi -
!. cally. The circuit continuity check, however, is addressed.
g 20 d I believe Mr. Camp can maybe speak to that issue.
. 21 3
I There is a program --
22 MR. CAMP: We do not address any testing of butt splices in the testing program As Larry said all that we addressed is continuity of circuits and comparability of
~* "*
- 98 1 butt splices.
2 PR. CALVO: I understand that but there has got to l 3 be some kind of way in the record to -- that you had dcne 4 this -- some kind of way with everything -- you have all 5 these splices that you tested in tests from which one you 6 had rejected and what action you had taken to correct it and ,
7 you also will follow then and determine what the roof calls a
for and get that and -- then what else you can tell about g splices.
jo' If there's something about butt splices -- because
~
33 we accept the ones you had based on the whole entity and
.s. -
12 based on the limited amount of -- that is the basis of our 13 technical evaluation.
You encounter the action -- to challenge that 34 action, but you've got to come up with the justification of
-- to ' allow us a true test, whatever is included to prove I the adequacy of it, and all we want to know is that you have 17 2
tested them. Tell us what you did and tell us how many you
- 18
[; 19 have found wrong with it and what was your rejection material i and what was your corrective action.
j 20 4 MR. POPPLEWELL:- That needs to be outlined in our .
l 21
- ' action.
22 MR. POPPLEWELL: That needs to be outlined in our 23 action.
24 The next issue addresses agreement or disagreement 25
- ** 99
... s ,
- 1 l
1 when drawings of field terminations. NRC found physical loca*
2 tions of selected cable terminations did not agree with the i
3 drawing. He were requested to inspect all safety relating 4 terminations i. the cable spread room and control room cabi-5 nets and verify that the locations are depicted on the draw-6 ings.
7 We reviewed the selected Cables that were given 8 to us in the letter and reviewed the design changes and g temper:ry modifications from the startup program and found to that we have no safety -- no adverse safety significance in 11 this agreement between cable terminations and drawings.
12 MR. EISENHUT: When we met on the issue that we 13 laid out, I remember we specifically said we gave you select-g ed examples of that that we thought we involved. We had a lot more where we thcught there were problems. We had review-ed a large number. In fact there was one train of thought I that would say, enumerate all the concerns we have.
g 17 Another train of thought which prevailed 's -- I
[ 18 don't want to tell you an example of every problem I have got 2
I. because if I did those I was afraid of what you were goinc j 20 ,
J A to do. If I told you -- I have identified 43 problems, and ;
y 21 l you would have evaluated 43 and said, yes, there is no problem in those 43.
23 j
The issue that we were trying to get to was not l 24 ;
the -- go out and -- the 'TC certainly didn' t want to carry l 2$ '
I i
., .,e 100 1 , the burden and say we've identified the problem, but rather 4 j
.- l 2 we wanted to say -- to give you -- here are some examples
- 3 of the kind of disagreement between drawings and actual 4 field installation that we found.
5 We recognize that some of those may have essential +
ly no safety significance. However, it is indicative of 6
a bigger problem. It is indicative of a problem that based 7
8 on our audit of the drawings and the field installation they g
were different so we asked for a program to verify and to 10 rereview what was out there.
33
~ To come back and tell us that the ones that we gave you had no adverse safety significance, we probably could have come to that conclusion ourselves. That is really not the issue. The issue was that we found, we came to the conclusion on this item an'd on a number of other items that 15 there is clearly a difference between what you had in your
! -- what you were supposed to have in your plant and what ycu j 17 I had as dictated what was supposed to be by the drawings.
18 y '
What we were looking for was a orogram to verify j 19 i that the plant was built in conformance with the drawings and j 20 4
4 the application, etc.
j 21 j That is why Jose's issue was -- it sounds like 22 you fell into the trap or it certainly reads like ycu fell .
23 into the trap which we were trying to avoid getting into 24 by saying that we've identified all of the problems we found.
25 9
+
101 1 Heck, I told the staff save all the biggies for 2 later. Now I mean what does that do to the program, I don't 3 know because frankly I was relying on you to come back and 4 not try to punch holes in the particular examples that we 5 listed, but rather really try and look at it in a broader 6 context of what the problem might be.
7 I think that is -- Jose did -- that is the kind 8 of --
g MR. CALVO: Yes. The action that you take is --
to it is contrary to what your findings are.
11 MR. FIKAR: Maybe we're dwelling too much on find-12 ings and the actions are --
13 MP. CALVC: Yes, agree, but the records show that g we. make the TRT look silly and that is the -- I know that is not the purpose, but you have given the backgrounds in lere.
I can argue and say well, if everything that you followed I made no sense, what do vou gain -- go back and do all these g 17 I action plans. I mean you go through'all these and found g 18 nothing wrong with it, you can acticn plan -- that is the j 19
' ~
{ second one we asked you to do, okay?
g 20 g
MR. GOUBERT: The reason is this though. The 21 l reason it doesn't go exactly to what Darrell had said -- the SRT recognized that you did do some of the program and they 23 recognized that you may have found some things that were 24 by potential, discrepancies.
l i
I
l e .'
' 102 l 1 We want'to look at those individually to get some 2 flavor to how these discrepancies may have occurred.' Now 3 even though we found some ways that perhaps justifies that 4 there is no safety significance associated with these particu-5 lar examples,the bottom line is there were some examples of 6 discrepancies.
7 The standard we want to apply is in that there are a some discrepancies, that the reasons behind them -- let's go 9 look at a large enough sample of them and see if we find 10 that there is any situation where we're running into safety 11 significant problems. '- -
12 MR. CALVO: Agree.
13 11R. GOUBERT: That is why we didn't -- if we were 14 taking a position as a program -- that if we could refute 15 your example, we weren't going t6 go any further and you'd 16 have cause to be concerned.
MR. CALVO: Yes, but you see --
h 17 2
- 18 MR. EISENHUT: Jose, just a second.
I g tg MR. CALVO: Something else -- if ability for i
retrieving your records there -- it is not there, okay.
,! 20 d If it was an independent assessment is what you had -- who-21
, a E ever made that independent assessment -- it was getting 22 wr ng records, see?
23 Something wrong with the capability to perform 24 an independent evaluation on what you have out there. That 25
- ** 103 1
1 is what concerns me the most. If wa do somathing' wrong that 2 is good, but -- if it's one time, but it's consistent -- if 3 we do something wrong, well, I said, we're working on 4 Comanche Peak and maybe we don't follow their -- I don't 5 know.
6 (Laughter.)
7 MR. EISENHUT: Jose, let me make a comment here 8 to try and help. You see I think John made a key point.
9 Nowhere in~this report or in your presentation do you matter 10 of fact state that the discrepancies indeed are valid.
11 Rather, it comes off as arguing -- being argumen-
12 tative that well, these are nothing -- there's no adverse i 13 safety significance. The discrepancies exist and I think if 14 you -- if on each of these items if you clearly acknowledge 15 there are discrepancies.
There are physical differences out there. Now 16 t
h 17 it is tiet o the processes that are at work. You are l 2 1 18 supposed to have a process where you engineer the thing, a .
c '
- ig design the thing and go out with drawings and construct it i
j in accordance with that application.
20 d Clearly, it didn't work on some examples. There l
, 21 )
i r
22 are discre~pancies.
It is not so much to us in the first in-23 cidence that, well, never mind these examples because there are n safety significance. You come back with a program 24 25 clearly right where were intended to go in the first place, b
="nw =, e
4 .* 104 1
,,that you must have a program to verify how many are out there 2 and how many discrepancies are there, is it videspread, is it 3 limited, what is the nature of them and then you have to do 4 a safety evaluation.
5 That logic is what doesn't appear on either the 6 slides and it certainly doesn't appear in the writeup and 7 I think that is the item the staff is reacting to, that 8 first you have to identify what the problem is and what the 9 cause of the problem was.
10 Then you can argue as to whether or not this is 11 a major problem or not a major problem.
I think that is the a
12 thrust as I see it. I don't think it is productive to 13 continue to debate it but as long as -- but I think that is 14 a key point.
15 That is the message the staff had when they 16 ree.d the report. That is the message they see when they
! 17 read the slides. I-by design in the September 18 letter 2
g 18 limited the examples that were given in the letter to be j is only a fewexamples because I was really afraid that if'we said we reviewed "x' tumber and we identified these problems; i
20 l
21 Thrr4 . o rays a tendency on anybody's part to i
22 go and evaluate those examples and say, but by the way there are no-big problems. We're certainly -- get a limited 23 s ample' . It is incumbent upon you to convince us that, in 24 25 fact, you have done a thorough encugh of a review..to identify )
I T- w
0
- ** i
. i 105 l 1
I all discrepancies or to at least be able to identify it well 2 enough to have enough conscience.
3 Jose has a statistical item in mind, what he's 4 looking for, and you have a program laid out. It is the 5 background and findings that we take issue with in a number 6 of these cases more than we do the actual actions. !
7 Is that fair to say, Jose?
8 MR. VEGA: Let me address the comment on record --
9 MR. CLEMENTS: No, we kicked that around. I to don't think we hnve to --
~
11 MR. SPENCE:,
I think Tony means to say this 12 though. I think it's important.
13 Just anticipating what I think you're fixing to 14 say.
15 (Laughter.)
16 MR. VEGA: One of the things that we found in
- 17 going through some of the examples that were given to us and
- 18 again we don't know how many examples you have, but that is i 19 all we had to go on.
E We went through and our system is not simple.
20 d I don't know whether, yes, when you compare a drawing to a 21 a ,
a r physical item, that isn't the complete story. There are 22 e mp nent modification cards. There are DCAs, and there are l 23 also modifications, temporary modification authorizations that also are perfectly acceptable methods of changing what 25
-m'y y m- . n-
l r; . 106 1 is in the field and unless you get the complete story you !
l 2 haven't had -- you don' t have the complete picture against j 3 which to go and measure the physical configuration out in 4 the field.
5 Now Larry may be -- we have changed our approach, 6 tea. We hod some specifics as to what we had found and why 7 it is that it was no safety implication.
8 We also wanted to answer the same question that g you had in your mind and that is do we have a situation 30 out there where unauthorized design changes are being made, 33 and, therefore, what is out there in the field is not repre-12 sentative of what engineering has approved, and I-believe 13 that three of the five examples were covered by temporary 14 m dification.
15 Larry, help me there if I -, there was one in-
' " ' 9 ' * '#
- 16 g lead was blue or black and it was shown on mistake on the drawing. If you go to the compenent modification card that E ,
} ,
authorized that change, the color'of the conductor is con-
- sistent with what is in the field.
4 On the print item there was a connection, a two-l 21 i lead connection to a dry contact that had no polarity re-22 .
quirements. It was a duly cabled -- the leads were changed, so I want to make sure that I address the comment a'cout 24 record retrievability because I believe it, to a certain 25 Se
1 cxtent, it's unfair to us because we don't know 2 have deficient in your record because you canne 3 not want to compromise ycur information.
N 4 That doesn't mean that the records are ....
5 That means that we cannot communicate freely and, therefore, 6 in some cases, the TRT may not have looked at the right 7 paper. You know, it isn't a lack of record retrievability.
8 MR. CALVO: But again it goes back to -- when g I requested the drawings, asked to give me all the drawings 10 that dealt with this particular piece of equipment and this 33 is the latest drawings available for UTRT. We used those 12 drawings as being the latest piece of information, DCAs, CMCs, and based on that we concluded t.kat in the cases that 33 g we had inspected, that the equipment, the hardware did not g match the drawings.
Now if you say that the system is so complex and I it is not simple enough and -- I am just wondering also 3 17 e
- whether or not you people -- any trouble looking at these g 18 drawings and trying to make some changes.
- ~ ~
. 1 i [
-' MR. VEGA: Well, again we are proficient and i 20 ,
work with these systems day in and day out. Again, if you
! asked for a drawing and the CMCs and DCA -- that is what the 22 people gave you, i
,2( .
MR. C [VO: But the people who brought these alle- l 24 I gations to our attention are people that you think they are 25 j l
i 1
-a . . .
108 1 . proficient in stoing. .
o 2 MR. VEGA: I have no way of knowing whether they 3 are proficient or not in that area.
4 MR. EISENHUT: Well, let's see. Tony, I think 5 your credibility in my mind went up by one notch when you 6 acknowledged that it is a very, very complex system. That is 7 why I think we take a lot of weight of what you come back-8 with when we say we think we've identified some potential g problems.
10 If you come back and acknowledge and tell us that 11 they're either right or not right, that they're either all 12 pr blems or not problems to start with, regardless of what i 13 y ur safety significance are -- it certainly would help.
g You certainly know where all the drawings are.
You contend that there's this card and that card and this 15 '
modification . It is a very comolex system. We recognize I that, and that -- but that complex system tells you that there g 17 I is no place that you can go in this plan, I don't believe,
- 18 I i
[
.; 19 and find one single final design drawing for a given piece of I system.
g 20 g You have to get the rest of the pieces that go j 21 l with them. That is part of the frustration, I think, that 22 I am sure our staff here felt. I would be surprised if your 23 inspectors didn't feel it. I would be surprised if our re--
24 gional inspectors didn't feel it.
25
""= n
- , ,'*.,, '109 l 1 Somehow we have got to cet to the bottom line 2 really -- were there or were there not discrepancies between 3 the two and that ought to be the first situation you try to )
4 address. I think you have a program here and I'd like to 5 go on to -- do we buy the action plan or don't we buy the a action plan.
7 MR. GEORGE : I'd like to make one point on the a complicated system.' The reason the system is complicated 9 is to accommodate modifications to systems. It started out 10 in '72 and with a log with all of the issues obtained dcwn 11 the pike with TMI -- all of the new regs, Comanche has em -
12 braced all of those, so that dictated a complicated system.
13 Ultimately the system will be simplified and all 14 change paper will be posted to drawings, Darrell, and you 15 will be able to take one drawing and deal with that system.
16 Two will be completed without the use of change pacer large-
- 37 ly because we know what is coming out of us so the system
- 18 is complicated by necessity for us to complete the plan.
a c ,
4 jg MR. EISENHUT: So what you are asking your inspec-J tor to do first is inspect it with no final design -- in one -
place, (a), and then you are asking the NRC inspector to I verify it, that this -- with no final design in one place, 1 4 22 i that'the system is all right, and that is a very difficult thing to do. That is a complicated process.
Different utilities have handled that in different 25 1
- ,L *'-, s 110 l 1
, ways but one approach would be we could say well we can't 2 finish our inscection until you produce the final design.
3 They were asking for -- they asked for another 4 plan -- what is the final design or inspection reports for 5 a systewm, and it is imeumbent upon the utilities to bring 6 forth whatever information we need to make that decision.
7 MR. GEORGE: We agree with that.
8 MR. EISENHUT: I think that is where we are.
g MR. GEORGE: And we were lacking in anything you to didn't get.
33 MR. EISENHUT: I don't know how we got -
I mean 12 we may have gotten here by a dozen dif ferent ways and --
13 productively we've got to get one with --
14 MR. CALVO: That was the oricinal request - - we said that you must inspect all the terminations because one 15 16 f the things, one of the complexities -- I think when ycu f g get out with SER, you are going to have some of the flavor
- 18 of what -- system to make that conclusive,-but I guess if i '
you concentrate on the action plan and we can reneat to the I. action plan, we'll accomplish -- to solving difference be-20 l
- f. 21 tween the actual equipment and the actual -- and the drawing.
i MR. HUNTER: Darrell, this is Dorland" Hunter 22 -
speaking. To sort of go along with what Darrell is savinc.
23 We're'having the same problem in Region IV, but here is what 24 we have to see when we go out and look at a drawina. It has 25
.. /
_m ..- _ _ - 7.# _. _ ~,
7 - y ,,y,. ,. y -
... ,. . 111 1 to.ba shown on that CPR, that control drEwing.
2 I don't care if you have 50 or 70 control drawings or one set of control drawings. It'has to say on that draw-3 4 ing this drawing is not accurate without consideration of 5 these activities.
That is what you have got to shoot for. In the 6
7 end that is where you are going so when you look at these a
programs look at that because that is what we're going to g require you to have in the control room.
If it is temporary mods you may have to note those ,
10 If it is ongoing design changes, you'll note those. If it
- is completed design change you'll wa'it for drafting and'will
~
12 redline y ur drawings.
13 You'll have to have a program that meets criteria g
six that says the drawing is at the location to be used and it is accurate without question. If we find problems ar.d 16 we have, then -- but we want you guys to get that flavor.
That is what we're looking for.
~
MR. CALVO: To go back to the action plan, I /
- $ 19 can give you our comments on it kind of quickly. Again, j 20 j a
f we issue a request for you to do an -- overwhelming verifica-
. 21 3
i tion of all these terminations against the drawing.
22 We're willing to accept what you propose but 23 under certain conditions. Again, we're using this mil 24 standard again and I am -- I'd like to be sure -- what I 25
s 112 1
.had said before. I'd.like to ba cure that tha cample -- it l
2 is a random sample, and I want to know what the pieces of to 3 equipment you had selected in the random sample -- I want 4 know how they sample, with respect to how many terminations 5' do you have and whether the rejection and the acceptability l
6 superior, and I guess the root cause if you find some kind l 1
7 of a problem and also for what are the criteria for you to i 8 go to the expanded sample in case you found some kind of a i e problem.
to I think that will amplify our sentiments, okay.
Keep in mind that those systems are very ec.;tiguous to a --
33 -
12 that is the one where the random sample should be concentrated 13 if you can.
Now also another thing I'd like to know so that 34 We Can resolve these drawing problems -- I'd like to know the drawings that you use, for the terminations to be simple.
I 17 I'd like to be identified with the revisions and all the
- information -- so the reason we got an appointment with ti:e
- 18 I; -- so everybody else will know what'to independently evalu-19 I ate after you finish.
j 20 okay. Also, again we've had a comment that you f
. 21 i
are going to -- potential problematic QA/QC concern about 22 the drawings the some kind of way to -- complicate feedback 23 in here later, but we don't know if we want to know that 24
-- how the QA/QC things work. .
25
113 l l
I Also, the acceptable conditions that are stated 2 in Section 4AA and 4B -- when you are talking about inter -
3 change -- collections to a terminal point, electrically l 4 common to that as specified.
5 From the standpoint of compatibility we agree with 6 you. From the standpoint of making future changes, and you 7 are making a lot as indicated with these drawings -- put 8 in their log and their collection -- th'ey are not showing 9 that in the drawing and that is the way. When you are going 10 to make another change, you may make a mistake in there so 11 I think we don't accept th,a.t "A" as a basis for acceptability 12 when you go to this comparison.
13 Plan B -- when you say they interchange police
, 14 to terminations -- they collect contacts -- all of the 15 devices that have no polarity requirement -- that alsc is 16 important. If I can collect the relay backwards and then 3
have them put that in the drawing, when I collect that, it h 17
- 18 is supposed to be closely or -- I also have some problem g gg in support of making changes so we will not accept that as a
acceptability as part of your criteria.
] 20 d Now insofar as the last one, we accepted that one 21 E n the basis that the use of cable conductors or size larger 22 23 than specified, that is okay as long as we can assure that 24 ag d connection can be made.
I am saying only -- you can save it for later, only 25
114 1
,.you have got some arguments why you feel that "A" and "B" 2 should be considered as part of ygur acceotance material.
3 We feel that it should not be -- I think it still goes back 1
4 to the question that the drawings doesn't check with the 5 actual equipment and when you made changes, it is important 6 where those -- the polarity of changes on simple compatibility 7 is important to know whether things are in the drawings.
8 MR. SPENCE: Perhaps a more efficient way to l g detect that is -- or to respond to it is to take under ad-10 visement here and --
33 HR. CALVO: Okav.
=
! MR. SPENCE: Our team leader get back with your 12 i
13 team and they can talk about it right away.
MR. CALVO: Very well.
34 MR. EISENHUT: It has become obvious to me on.a 15 number of these details that what Ne're going to have to do 16
- -- there are important details. What we're going to have to 37 do is continue a dialogue and the detail of the items, each
- 18
! of the items with the appropriate team people.
- 1
- MP. CALVO: That's mv comment.
' - j j M MR. POPPLEWELL: The next item concerns perform-d g
21
! ance -- vendor-installed terminal lugs. The NRC found that certain nonconformance supports concerning vendor lugs 23 be improperly closed. They wish to have those nonconfor..anc e !
reports reevaluated and redispositioned -- excuse me -- thev l
. .. , 1 b .. .
115 i l
l I
- ,wish that the reevaluation and redisposition of all NCR as i 2 related to vendor lugs be reworked.
3 Our action is that we will disposition nonconfor-4 mance regarding the bent lugs and they will be -- we will 5 review those and there will be new ---
6 The background is there for clarification and is 7 in no way meant to be a --
8 (Laughter.)
9 MR. CALVO: I am not going to let you win that 10 one.
11 (Laughter . ). _ _ ,
12 MR. CALVO: Not on that one. I think that your 13 action plan should consider all -- twisted in excess of 60 14 degrees. That is to the dispositicn.
15 MR. POPPLEWELL: That's correct.
16 MR. CALVO: All of them.
17 MR. POPPLEUELL: That's correct. That is what
- 18 we' re saying.
j 19 MR. CALVO: I guess it would be hard for you to 20 know -- the NCR form is that the lugs are determined and d
21 then meaning too that -- do not force the equipment to this ir 22 problem -- wouid also be included in the action plan. That 23 was the -- from the actual specifics of the concern. If 24 we can get the SER out to you before you give us the actual 25 plan back to us, then we will pick up those things in there.
f*
~.
116 1
MR. POPPLEWELL: The next issue has to do with 2 separation criteria for flexible conduits and flexible con-3 duit as found in the main control boards, associated with 4 safety-laid cables. The action required by -- specified by 5 the NRC will reinspect the panels, containing the safety 6 laid cables and correcting violations or provide analysis 7 showing the flexible conduit is an acceptable barrier.
8 MR. CALVO: Again, just for the record, regulatory g guide 175 which involves extra policing ~~ 288 -- 1974 --
10 allows you -- in those cases where you have alraady allowed it for separation of material,,-- you must do analysis -- demon-12 strate the adequacy of different size -- the installation of 13 that.
9 That analysis includes testing so I am sure when 15 y u consider analysis to all in accordance with the require-16 ments, you must consider accepting -- demonstrate the accep-j- tability of that particular conduit as a barrier.
37 J
While you are doing that testing, consider the 18
! acceptability of redundant flexible conduits in contact with 3,
I. each other because we did find our -- those things to be in
! 20 i .
d contact with each other.
- 21
! The only point I make is -- as long as the standard allows you to get around this, but the acceptability of the installation -- the testing -- through analysis --
that analysis includes testing so I an .sure -- I r emind you
.m- - - -- -
y a y ,-w,s -,, -, -
. .- *'se !
1
,when you come out with that. action plan that ircludes analy-2 sis be sure that you acceptance is associated with testing. !
3 MR. POPPLEWELL: Our action plan does include --
4 MR. CALVO: Yes, infers that.
5 MR. POPPLEWELL: Any questions?
e The second issue concerning separation is similar 7 and we're talking about flexible conduits to cable and free 8 air which were described by the report.
I g The action that was specified was again similar to -- that we should inspect and correct or provide analysis 1 33 demonstrating the adequacy of the flexible conduit as a 12 barrier, taking.into account testing.
13 fir. CALVO: In connection with the -- your action 34 plan, you also may want to consider again the flexible conduit and the cables in' contact with each other as part 15 f y ur knowledge. It also -- because if your analysis 16 demonstrates that the flexible conduit is an acceptable 37 barrier then your specifications, your drawings, your pro-I cedures and documents shall be corrected accordingly as I -- because as it stands right now he says that it is not !
j 20 I f 21 allowed.
! You've got to correct them to indicate now that 22
-- don't follow those things because it is not in accordance with t'he -- you include in the action plan, at least you 24 ,
have got an understanding of what you're going to do if the O
9
. . - . . , . ~ - . . , . . , ~ , - , - - - , - - -- - - ,. , - , ~ , . ~ . -
118 1 . analysis proves to be satisfactory. On the other hand if 2 the analysis proves satisfactory, then you have got to pro-3 vide for separation criteria, but in this case it would be 4 as much as five inches between the conduit and the cables --
5 six inches.
6 (Inaudible question from the audience.)
7 MR. HUNTER: This is a figure and realizes and a you might not want to ever repeat these, but you're going g to use the Guide 175 in the future. In other words --
to MR. CALVO: No, no.
11 MR. HUNTER: ou do it now, right, and then --
12 and satisfy that and then for major construction activities, 33 modifications in the future and all your -- you'll not have 14 this problem.
15 MR. CALVO: But it is their action.
16 MR. HUNTER: Oh , I see.
- g MR. CALVO
- The requirements allows them to analy-sis with the separation requirements and the standards are S
c ,
not met.
9 I. MR. POPPLEWELL: The next issue concerns conduit j 20 f
. 21 cable tray separation in the plant as opposed to bringing it i inside the control panel. An analysis substantiating 22 separation criteria between conduit and cable trays was ]
not submitted with NRC.
24 i The requested action was to submit the analysis .
25 i
- 1
_ - . . - . . , . _ . _ s _ _ . _ . ,
1
119 1
We understood that this had to do with the standard review 2 plan and was not asked for at that time. We will provide the 3 analysis to confirm that the installation is adequate and 4 acceptable.
MR. CALVO: If the FSAR also -- you want to address 5
-- if the FSAR -- as it states -- as it exists today -- does 6
7 it say anything there that you're meeting this physical a
separation by analysis instead of by physical -- by the spacial separation. The FSAR should indicate that analysis was used to satisfy the separation requirement.
Based on our cursory review of the FSAR, that 11 ,
aspect was not there, and had it been there, most probabIy would have asked you for your analysis.
I want to be sure that also the FSAR is amended 14 to reflect that fact.
15 MR. POPPLEWELL: We will submit the appropriate 16
! documents for your review.
= 17 --
The last item that I have is barrier removal in-g 18 3 side the main control board. The action specified by the '
i 19 y NRC was to replace the barrier and to assure that the redun-
! M
) dant field wiring cables found in the area of the barrier
. 21 meets a minimum separation criteria.
l 22 The barrier has been removed. Was removed for 23 purposes of installation or maintenance in the board. The 24 barrier will b e replaced and the cables will be reworked.
25 4 *
' ' ' ~
1 MR. EISENHUT: From a purely logistics sta o
2 itis clear that what we're going to have to do is sei 3 forum for teams to continue the dialogue, I believe, on the 4 rest of these issues because we're basically able today to 5 provide you a lot of feedback on the program plan as to a what.our reaction is and comments are.
? I know we're going to be breaking up we said about a 1:00. I do want to plan to give the representative, the e intervenors an opportunity to comment today so I would 10 figure maybe the next 15 minutes to -- it's your choic.e to 33 best weigh to figure out how to use that.
12 We can embark on another area to historic, to 13 where we go. I think what I would suggest and I mentioned it 34 to Vince Noonan is either here or in Texas next week pick up 15 a meeting to continue to go through the program plan.
I think the best way to do it from the technical 16 review team is item-by-item-by item because obviously they 1-j 17
- 3g are familiar and you folks are familiar with the details.
3 3 ,
g 3, I'll leave that to you for your review.
MR. SPENCE: I think that would be an official way f3 gg d to proceed from here. Whether we do it in Texas or here --
21 ir MR. EISENHUT: Depends a lot on the logistics of 22 .
~
~~
23 -
MR. SHAO: Next meeting will be in Texas. '
MR. EISENHUT: But I don't think that decision 4
4:
,- .,.* 121 1 .has to be made right now. Then it would be whatever particu-2 lar area principally would fall down. How many more items, 3 Jose, in your area?
4 MR. CALVO: It's one more but I can defer that one 5 to Larry Shao -- analysis of electrical supports.
MR. EISENHUT: Because I was going to say if we 6
7 can get through at least your item --
g MR. CALVO: That one we can postpone until later.
MR. SHAO: That one essentially belongs to me.
9 10 MR. CALVO: So we're finished.
QA/QC electrical inspectors -- ,
MR. EISENHUT: So there are two subgroups that are 12 ,
13 left -- Larry, your subgroup and the timing subgroup. l g MR. SPENCE: Let me get some input from my senior review team and see how we can best use the next 15 minutes.
15 1
We've got one issue --
I MR. EISENHUT: Why don't we do this then.
17 4
[
We will 90 ahead and make arrangements to -- I wculd like to, I think, from a logistics standpoint -- I'd like the staff
} ,
to work out -- we'll work out with you a schedule whereby l 20 :
a i I
f we can continue the meeting' starting -- proceeding to' the 21
! issues next week sometime, I'd prefer, because I t.hink there
' is some need to get on to make sure that if there's any 23 feedback into the program plan, it is at an early time.
24 MR. SPENCE: Would it be appropriate to suggest l 25 ,
4 4
4 1 .that Mr. Noonon and Mr. Fikar get in touch with e :
2 say on Monday or early next week and arrange a t 3 schedule --
1 4 MR. EISENHUT: That would be fine.
5 MR. SPENCE: So we will know who to bring or who 6 to -- how many to accommodate as the case may be.
7 MR. EISENHUT: Fine. I think that's gcod.
P 8
Let 's see . - Are there any other staf f comments ,
i i
g general or on the areas we've covered? Appreciate you 2
to scovering them a little bit haphazardly by we're going, but :
if there's no other -- I wanted to give the representatires ,
33 12 of the intervencrs today an opportunity to have any comments, i3 constructive feedback, suggestions-cr whatnot, preferably 4
gl not whatnet, but Billie Carde is here and ne's representing both case and -- I'll give you an opportunity if you'd like 15 o co ent.
j 16 s
MS. GARDE: Well,.I called you all together today.
j 17 I didn't take the time as we were going through the. items '
E to make a very detailed list so I am going to be giving you
{ 3, fg 20 basically some general comments.
f My biggest concern based on the presentation made ,
g 21
- ! by the utilities today is a lack of the independence of the personnel chosen in the senior review team and various issue leaders, which I.think is a direct conflict of the type of program you want to undertake to give both the NRC, the i
r D
4 r- .-,a- _ __ _- . .< _ n., w ,- - , . ,
.s
- , . 123
' ublic a lot of assurance in your res-e,.intervenors and the 2
ponse to the CRT.
3 I think it is very inappropriate to choose the same i 4
personnel who have been in charge of these areas for basical-ly the life of the construction, and in some cases, frankly 8 are the direct targets of allegations made in the context 7 of harassment and intimidation hearings as being the cause of 8 the problem.
8' Whether or not that issue is decided in favor of
'O intervenor er in favor of applicants, the idea of spending 11 the time te do the effort that you are doing now and spend-12 ing that kind of money -- seems to me that a more prudent 13 approach would be to pick people from within TUGCO or outside 14 of TUGCO from an independent consultant who have unquestion-15 able-credentials.
16 I think particularly in the area of protective I
g 17 coatings where we didn't talk about at all today, the choice f.
18 that you've made is considerably sensitive to the realities j
19 of the licensing proceedings.
20 Second, I think that the methodology presented 4
21 in dealing with these things in a piecemeal approach falls i
22 far short of the type of program that is going to be neces-23 sary to put to bed the concept that your plant has not 24
' suffered from a major quality assurance breakdown.
l 25 l I, tco, was hardened by Mr. Vega's public
a
'. . 124
. 1 rccognition that tho project docum:ntation is incrcdibly 2 complex and often confusing. That is the thing that we have a heard from, whistle blowers from pecple on the staff and .
4 people as an argument and a defense for the situation and .
5 confusion that both project personnel find as well as the 6
NRC.
7 I think that recognition of the problem is a big a
step in the right direction, but it is not -- it's only a g beginning and until you can have a final piece of paper that says this is what this table tray should be, this is what 10 p the electrical system should be, it is somewhat imprudent to -
expect the TRT to be expending a lot of time and 2
money and then you all come back with a set of documents that says and this is the real story.
My concern is that everybody is wasting a lot of time and an awful lot of money at a point when that is not
! appropriate. I don't think based on the evidence that the g 17 I TRT found that it is a good idea to draw the line and say i is this is the full magnitude of the problem.
g 19 i I think if no other lesson at all was learned from
! 20
) Zimmer, it is that you don't draw a line, stop looking at the j 21 l problems and evaluate it at that point. You have to look 22 at the full scope of the problem.
23 Now I have a comment which I want to direct spe-24 cifically to the NRC, and that, I think, is contained in my 25 1
., .,1 -
125 1 letter Mr. Eisenhut, to you, of the last week of September, 2 and that is that my concern about the TRT's effort is that 3 it's continuing to take a piecemeal approach to which the 4 utility isresoonding with a piecemeal response as opposed to 5 getting an independent picture of the plant.
6 The errorts tax =.; by region three at Midland in 7 the diesel generator building inspection revealed things that a no whistle blowers, no workers, no intervenors and no NRC g inspection had previously identified at the Midland facility.
I 10 My concern is that you're going to spend an awful ;
3, lot of time tracking allegations and that has to be done 12 but that at the end of the tracking of all the allegations, 13 you are still not going to have the answers to the questions g -- is this plant completely safe.
I think the electrical area is one that demonstrates those kinds of things.
I My biggest concern at this point is that since g 17 I there has not been an ef fort to deal with the documentation
. 18 i .
problem, first, and the documentation provides the basis for I what both the applicant and the NRC have got to determine j N 4 to make determinations of what is correct and incorrect,
- 21
!' that the situation, whether it is a month from now or six 22 weeks from now or two months from now is going to be the same ,
23 They're going to find things, and you're going to produce CMCsoor DCAs or revised drawings, and you're never 25 4
- - - _ - - . - ..c . _ _ - , y _
', 'l' -
126 I
, going to have a final story.
2 I don't think that that is in anyone's interest.
3 The second comment on Mr. Eisenhut's point was 4 that a basis that has to be approached in each area which is 5 described as a deficiency is the criteria and the acceptabil-6 ity of the criteria that has been accepted by the NRC, that 7 is. acceptable industry standards before you go forward to 8 evaluate any specific example.
4 9 The separation cables is a good one. If you don't to know what is the criteria for separation, what is acceptable, 11 it is going to be pretty dififcult for everybody to decide j 12 that if, what you have in place, is, in fact, acceptable.
13 I worked with Mr. Beck quite a bit on the Midland 14 project and so I know -- at least on one case firsthand 15 that you do have the expertise and the talent among your 1e staff to design the kind of program that even meets inter-
< 17 venors ' criticisms, and I certainly don't think that you -
18 can design a program that meets all of our criticisms but
- f. <
i 19 I do think that you can have one that is acceptable to work l.
a 20 with,
$ I think thr* has been developed at other plants, 21 i
E 22 and that is possible and I think that is the kind of thing 23 that you should expend your effort on as opposed to having l l
1 24 a real -- frankly, as I see it -- kneejerk session where 25 they find problems and you say they're not problems, and they say they are a problem, and we all sit here in these 1
. _ . . . . , , c. - - - , . - -.w, -.. - m . - - , , _
127 V
1
, hot rooms for a long period of time and not get anywhere.
2 Thank you, Mr. Eisenhut.
3 MR. EISENHUT: Miss Gard , I will -- we are, in 4 fact, evaluating the program plan, and, in fact , if you or >
5 the intervenors would choose to submit any comments to me ;
6 in writing, any more comments other than what you've given 7 today, you can do that, entertain such ccmments, but I will 8 need those comments on the program plan no later than the 9 ene of next week.
10 MISS GARDE: I think we followed the same method-11 ology we did in Midland, and we'll submit a program review
(
12 of the documents we received today.
13 MR. EISENHUT: Okay. The -- and as I said the 14 schedule for that though is by the end of next week. I'd 15 appreciate what I can get.
MR. CALVO: Excuse me. To be fair, the intervenors 16 a
17 spoken to utilities and the fact that we had to approach f.
18 it -- a piecemeal approach in the electrical -- it's very
~ :
- Ig hard to say that at this tima because I -- nobody had defini-g tive -- what we had done -- safety evaluation reports.
I think when you see it you'll know that we had ,
fa 21 r
22 been all encohpassing and I think that that will be the 23 appropriate time when the safety evaluation report comes
(
l 24 down -- are at issue, then you will make that determination.
l 25 It cannot be made today based on the information that is 4
- - - - -v - ,---.-,sv,,+,,e-,- -+---m.e=~ w - - - - ---- "y---s -
- .. *
- e .. 128
' .available to everyon3.
2 MR. EISENHUT: That's right. As one or two last 3 comments I want to ask Bob Martin who as we mentioned in the 4 beginning is -- took over this week as regional administra-5 tor in Region IV and Vince Noonan, if you folks have any 6 comments, observations that you'd like to make?
This is Bob Martin. The only comment 7 MR. MARTIN:
e I would hope to make is that you gentlemen avail yourselves 9 of the documentation from the EDO which further clarifies to the working relationship which will exist between Mr. Ne nan ti and myself, and I am sure I am speaking for Vince but I am 12 certainly speaking for myself, I certainly expect the Region 13 IV staff to be working very closely with the TRT so that 34 in information which is exchanged between the utility and 15 Region IV, you can be well aware of the fact that the TRT and the NRR staff will be fully informed as we will be.
16 t
on the workings of the TRT and that relationship so that j
37 while program implementation might call for documents to i ccme from different places, you will not be dealing with /
g 3, two different organizations I can assure you.
i We'll be dealing with one organization as we 7,
ie return somewhat to the more, if you will, normal mode, of the regional responsibilities and the NRR licensing and OELD hearing responsibilities as we somewhat establish more towards the classical relationship between those
~
~ . . .
-e
'ee 129 1 organizations during the course of the project of your type. i 2 Therefore, I just. wanted to doubly assure you that 3 that c1cse working relationship will c'ontinue even thwough -I 4 am now starting to assume a fraction of the respcnsibilities 5 that had been held by the TRT previously.
8 That is all I have.
7 MR. NOONAN: I think I endorse what Bob said. We g will cooperate with each other. I will talk to Bob on a g very frequent basis. e I do plan to come down to Texas v'ry l shortly and come to the site and visit the site. I have 10 33 asked my staff to continue on what they're doing to maintain ur schedule commitments and while I am trying now to read 12 all this stuff and become familiar with everything.
13 As I get familiar I will be talking with the 14 pe ple, appropriate people, and like I said I'll be coming 15 down to Texas very shortly, g MR. SPENCE: I'll just close from our side by saying that we appreciate again the opportunity to meet with t
you and arrange for the meetings between the specific TRT I teams and --
20 l
d MR. EISENHUT: Very good.
21 ir MR. SPENCE: We acknowledge the comments and the 22 clarifications that we got today and we'll certainly factor those'in to our continuing view of our action plans -- any 24 revisions that are necessary.'We'll take those into account 25 e
130 1
and get those to you.
MR. EISENHUT: Very good. I appreciate everyones' 2
3' efforts today, coming to the meeting, and going through this 4 in somewhat of a warm room.
g So thanks, and we'll continue at a later time.
(Whereupon, the meeting was concluded at 6
12: 44 p.m.)
7 a
9 to II ..
12 13 14 16 16 17 l
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g 19 i, = .
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t 22 23
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e se CERTIFICATE OF PROCEEDINGS: 1 I l This is to certify that the attached proceedings, l 2
l l 3
IN THE ETTER OF: i 1
, TUEC MEETING WITH NRC STAFF 5 1 DATE: OCTOBER 19, 1984 PLACE: BETHESDA, MARYLAND 7
8' were held as herein appears and that this is the original 9
transcript for the file of the commission.
10 11 12 13 t 14 15 16 REPORTER: STEPHEN A. CAIN I
SIGNED d ( M, . b .
TRANSCRIBER: NEAL R. GROSS SIGNED: h/Ihrcu 20 21' 22 23 24 25 ,
PAEE STATI REPORTING INC.
cowt me,eetene e e:;x::::=
0.C. Aree 141-1901 e Belt.& Annep. 149-4136
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TUEC MEETING WITH NRC STAFF OCTOBER 19, 1984 AGENDA '
INTRODUCTORY REMARKS M. D. SPENCE CPRT PROGRAM OVERVIEW J. T. MERRITT ISSUE-SPECIFIC ACTION PLAN L. M. POPPLEWELL PRESENTATIONS --
C.- R. Il00 TON -
M. R. MCEAY A. VEGA Y R. E. CAMP
SUMMARY
J. T. MERRITT CLOSING REMARKS M. D. SPENCE
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- -a PROGRAM OVERVIEW CPRT ORGANIZATION PERSONNEL QUALIFICATIONS
SUMMARY
OF PROGRAt1 PROCESS
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TYPES OF ACTIVITIES
+
PHASED REVIEWS SAMPLING TECHNIQUES O
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COMANCHE PEAK RESPONSE TEAM ..
(C P RT)
TUSCO PRESIDENT E SPENCE SENIOR REVIEW TEAM
- L. F. FlK AR ,
4 S.R. CL EMENTS J. SECK J. A. GEORGE J.C GUIBERT PR ARAM M ANAGER CPRT AT. ME RRITT. Jr.
I I I -
1 I I I ELECTRICAL / CIVIL /STRUCT. PROTECTIVE COATING MECHANICAL GA#GC TESTul6 PROGRAMS 1
BNSTR. LE ADER LEADER LEADER L E AD~8t LEADER LEADER L.u POPPLEWELL C.R. HOOTON -
R.E TOLSON C KMOEHLM AN A.VEGA - R.E. CA MP --
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E.c.. E.d. B.e.
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_ 'WI.V0GELSANG MR.M*0AY A. VEGA _ S. FRANKS
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0 8 JONES u WAfDsER _ A.LANCASTER
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S P. MAR flNOVICH D PATANKAR G&K I.m .I.e. R E. CAMP I kl.1 b 2,1 m 3 - E.d
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SUMMARY
OF PROGRAM PROCESS
- 1. RECEIPT OF NRC-TRT REQUEST FOR ADDITIONAL INFORMATION.
- 2. PRELIMINARY REVIEW OF ISSUE BY CPRT PROGRAM MANAGER, SENIOR REVIEW IEAM AND APPROPRIATE REVIEW IEAM LEADER.
- 3. ASSIGNMENT OF ISSUE CO0RDINATOR.
- 4. OBTAIN ADDITIONAL, CLARIFYING INFORMATION FROM NRC-TRT TO ENSURE FULL UNDERSTANDING OF THE CONCERN (IF NECESSARY).
- 5. DEVELOP ACTION PLAN TO RESOLVE CONCERN USING GUIDANCE EROVIDED IN ATTACHMENT 2.
- 6. ACTION PLAN APPROVED BY APPROPRIATE REVIEW IEAM LEADER, PROGRAM MANAGER AND SENIOR REVIEW IEAM.
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- 7. IMPLEMENT ACTION PLAN.
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- 8. IDENTIFY ROOT CAUSE AND POTENTIAL GENERIC IMPLICATIONS. ,
- 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).
- 11. REVISED ACTION PLAN APPROVED BY APPROPRIATE REVIEW IEAM LEADER, PROGRAM MANAGER AND SENIOR REVIEW TEAM (IF APPLICABLE).
- 12. IMPLEMENT REVISED ACTION PLAN (IF APPLICABLE). l
- 13. DEVELOP ACTION PLAN RESutTS REPORT USING GUIDANCE i PROVIDED IN ATTACHMENT 3.
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- 14. ACTION PLAN RESULTS REPORT APPROVED BY APPROFRIATE 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 FtEVENT REOCCURRENCE 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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INTRODUCTION OF SPEAKERS ,
ELECTRICAL / INSTRUMENTATION LEADER L. M. POPPLEWELL QA/QC LEADER -
A. VEGA ISSUE I.D.1, I.D.2 COORDINATOR CIVIL / STRUCTURAL LEADER ...
C. R. HOOT 0N ISSUE Ic, IID COORDINATOR M. R. MCBAY TESTING PROGRAMS LEADER R. E. CAMP d
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ITEM I.A.1 HEAT SHRINKABLE CABLE. IMSIILATION e DESCRIPTION OF NRC ISSUE CONFUSION AS TO WHEN THE WITNESSING OF INSTALLATION OF HEAT SHRINKABLE SLEEVES WAS TO BE DOCUMENTED
, ACTION SPECIFIED BY NRC CLARIFICATION OF PROCEDURAL REQUIREMENTS ADDITIONAL INSPECTOR TRAINING ASSUl:ANCE THAT SLEEVES ARE INSTALLED WHERE REQUIRED I.
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ITEM I.A.1 ,
BACKGROUND 9 IRS DO NOT CONSISTENTLY INDICATE WITNESSING.0F 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 l
l TUEC ACTION ,
REVISE INSTALLATION PROCEDURE REVISE INSPECTION PROCEDURE TRAIN AND CERTIFY INSPECTORS i INITIATE INSPECTION SAMPLING PROGRAM TO ASS'URE SLEEVES ARE PROPERLY INSTALLED i
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ITEM I.A.2 INSPECTION REPORTS ON BUTT SPLICES . I1
- 1 DESCRIPTION OF NRC ISSUE t LACK OF DOCUMENTATION OF BUTT SPLICE INSPECTIONS
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SEVERAL SPECIFIC EXAMPLES CITED i
ACTION SPECIFIED BY NRC 8SSURE THAT REQUIRED INSPECTIONS HAVE BEEN PERFORMED AND DOCUMENTED VERIFY THAT BUTT SPLICES ARE IDENTIFIED ON DRAWINGS VERIFY THAT BUTT SPLICES ARE IDENTIFIED WITHIN THE APPROPRIATE PANELS -
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ITEM I.A.2 /
i, BACKGROUND
) ADDITIONAL INSPECTION REPORTS REVIEWED dEQUIRED INSPECTIONS WERE DOCUMENTED TUEC ACTION PHASE 1 REVIEW ALL INSPECTION REPORTS FOR THE 12 CABLES REVIEWED BY TRT REVIEW 12 ADDITIONAL CABLES
- IF DOCUMENTATION EXISTS, CLOSE REPORT i
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ITEM 1.A.2 TUEC ACTION (CONTINUED) ,
PHASE II - FURTHER REVIEW IF PHASE I DOES NGT CLOSE ISSUE REVIEW DRAWINGS AND DESIGN CHANGES SHOWING SPLICES INSPECT TO ASSURE THAT ALL BUTT SPLICES ARE PROPERLY INSTALLED IN APPROPRIATE PANELS l
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ITEM I.A.3 BUTT SPLICE QUALIFICATION ,
DESCRIPTION OF NRC ISSUE LACK OF SPLICE QUALIFICATION REQUIREMENTS VERIFICATION OF OPERABILITY OF CIRCUITS IN WHICH SPLICES OCCUR ACTION SPECIFIED BY NRC DEVELOP PROCEDURES TO ASSURE QUALIFICATI N TO SERVICE CONDITIONS
- l ASSURE THAT SPLICES ARE NOT LOCATED ADJACENT TO EACH OTHER i ,
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ITEM 1.A.3 -[
BACKGROUND
- f INSTALLATION PROCEDURES DO NOT ADDRESS OPERABILITY OF CIRCUITS WITH SPLICES
! - START-UP AND TEST PROGRAM ADDRESSES CIRCUIT OPERABILITY I INSTALLATION PROCEDURES DO NOT ADDRESS QUALIFICATION OF SPLICES FOR
, SERVICE CONDITIONS 3
- MILD ENVIRONMENT CONDITIONS
- SAME CONSTRUCTION AS TERMINAL LUGS
- LOW POWER APPLICATIONS AS PER FSAR NEW CRITERIA IN SER FOR FSAR AMENDMENT 44
- REQUIREMENT TO STAGGER SPLICES ,
j TUEC ACTION
- CONTINUITY CHECK TO BE ADDED TO CONSTRUCTION INSTALLATION PROCEDURE t
QUALIFICATION DOCUMENTATION WILL BE DEVELOPED INSPECTIONS WILL BE PERFORMED TO ASSURE SPLICES ARE APPROPRIATELY STAGGERED l
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ITEM I.A.4 l
AGREEMENT BETWEEN DRAWINGS AND FIELD TERMINATIONS DESCRIPTION OF NRC ISSlJE
- PHYSICAL LOCATION OF SELECTED CABLE TERMINATIONS DID NOT AGREE WITH DRAWINGS
- ACTION SPECIFIED BY NRC INSPECT ALL SAFETY-RELATED TERMINATIONS IN CABLE SPREAD ROOM CABINETS IN CONTROL ROOM CABINETS I '
VERIFY LOCATIONS ARE ACCURATELY DEPICTED ON THE DRAWINGS
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ITEM I.A.4 BACKGROUND ,
NRC SELECTED CABLES REVIEWED DESIGN CHANGES REVIEWED
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TEMPORARY MODIFICATIONS REVIEWED FINDING '
ISSUES HAVE NO ADVERSE SAFETY SIGNIFICANCE TUEC ACTION i
CONDUCT SAMPLE INSPECTION OF 500 SAFETY-RELATED TERMINATIONS REVIEW DRAWINGS FOR ACCURATE INCORPORATION OF DESIGN CHANGES RECONCILE DIFFERENCES, IF ANY, BETWEEN INSPECTION AND DRAWING REVIEW
- EXPAND $ AMPLE AS NECESSARY IF ACCEPTANCE CRITERIA IS NOT ACHIEVED i
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1 ITEM I.A.5 NCR'S ON VENDOR-INSTALLED AMP TERMINAL LUGS DESCRIPTION OF NRC ISSUE ,
4 NONCONFORMANCE REPORTS CONCERNING VENDOR LUGS IMPROPERLY CLOSED ACTION 3PECIFIED BY NRC .
REEVALUATE AND REDISPOSITION ALL NCR'S RE' LATED TO VENDOR LUGS e
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ITEM !.A,5 BACKGROUND EQUIPMENT INVOLVED FROM 2 VENDORS GE III 600LD-BROWN BOVERI LUG VENDOR CONTACTED IN 1981 AND IN APRIL 1984 l.UG VENDOR GAVE SPECIFIC CRITERIA NONCONFORMANCES DISPOSITIONED USING VENDOR CRITERIA TUEC ACTION ALL D15 POSITIONED NONCONFORMANCES REGARD 1HG BENT LUGS WILL BE REEVALUATED i
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ITEM I.B.1 FLEXIBLE TO FLEXIBLE CONDUIT SEPARATION .
DESCRIPTION OF NRC ISSUE MINIMUM SEPARATION REQUIREMENTS NOT MET MAIN CONTROL BOARDS SAFETY-RELATED CA'BLES WITHIN FLEXIBLE CONDUITS ACTION SPECIFIED BY NRC ,
REINSPECT ALL PANELS'CONTAINING REDUNDANT SAFETY-RELATED CABLES AND CORRECT ANY VIOLATIONS OR -
PROVIDE ANALYSIS SHOWING THAT THE FLEXIBLE CONDUIT IS ACCEPTABLE AS A EARRIER s
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- s BACKGROUND l Sw1TCH MODULES ON THE MAIN CONTROL BOARD REQUIRE SLACK IN TliE CABLES -
FOR.
REMOVAL / REPLACEMENT REMOVAL FOR TESTING i I
REMOVAL FOR ADJUSTMENT
... FLEXfBLE METAL CONDUITS USED TO PROVI.DE APPROPRIATE SEPARATION SUFFICIENT DOCUMENTATION DOES NOT EXIST QUALIFYING THE FLEXIBLE CONDUIT AS A BARRIER ,
TUEC ACTION i
- PROVIDE SUFFICIENT DOCUMENTATION, INCLUDING ANALYSES, NECESSARY TO i l QUALIFY 1HE FLEXIBLE CONDUIT AS A BARRIER 4
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ITEM !.B 2 .-
FLEXIBLE CONDUIT TO CABLE SEPARATION DESCRIPTION OF NRC. ISSUE .
MINIMUM SEPARATION CRITERIA NOT MET IN MAIN CONTROL PANEL BETWEEN SAFETY-RELATED CABLES AND SAFETY-RELATED CABLES WITHIN FLEXIBLE CONDUIT t SAFETY-RELATED CABLES WITHIN FLEXIBLE CONDUITS AND NON-SAFETY-RELATED CABLES *
/
SAFETY-RELATED CABLES AND NON-SAFETY-RELATED CABLES 4
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ITEM I.B.2 -
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i ACiFONSPECIFIEDBYNRC ,
REINSPECT ALL PANELS CONTAINING SEPARATE CABLES AND CABLES WITHIN FLEXIBLE CONDUIT AND. CORRECT ANY VIOLATIONS OR t
PROVIDE' ANALYSIS' DEMONSTRATING THE ADEQUACY dF THE FLEXIBLE CONDUIT AS A BARRIER l .
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ITEM I.B.2 '
BACKGROUND .
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ISSUE CONCERNS CABLE IN FREE AIR TO FLEXIBLE CONDUIT SEPARATION TUEC ACTION i'
- PR0vtDE ANALYSIS TO CONFIRM THAT INSTALLATION IS ADEQUATE AND
] ACCEPTABLE l i
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ITEM I.B.3 CONDUIT TO CABLE TRAY SEPARATION -
DESCRIPTION OF CONCERN ANALYSIS SUBSTANTIATING SEPARATION BETWEEN CONDUIT AND CABLE TRAYS IIAS NOT BEEN SUBMITTED TO NRC ACTION SPECIFIED BY NRC SUBMIT ANALYSIS ,
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ITEM I.B.3 ,.
! BACKGROUND -
ITERIA BASED ON-IEEE 384-1974 AND REG. GUIDE 1.75 gARA:'I
! DOCUMENTS EXIST WITHIN GIBBS & HILL SUBSTANTIATING THE SEPARATION CRITERIA
- CRITERIA WERE NOT SUBMITTED FOR NRC REVIEW i
- TUEC ACTION .
I SUBMIT GIBBS & HILL DOCUMENTS
! SUBMIT SANDIA REPORT l .
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ITEM I.B.4 4
BARRIER REMOVAL 1'
DESCRIPTION OF NRC ISSUE 1
- CERTAIN BARRIER MATERIAL IN MAIN CONTROL BOARD HAD BEEN R'EMOVED ACTION SPECIFIED BY NRC REPLACE THE BARRIER MATERIAL i
ASSURE THAT REDUNDANT FIELD' WIRING NEETS MINfMUM SEPARATION CRITERIA i
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BACKGROUND
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VENDOR-SUPPLIED BARRIER MATERIAL HAD BEEN REMOVED i i
TUEC ACTION.
I REPLACE BARRIER MATERIAL REWORK CABLES TO RESOLVE SEPARATION.CR!TERIA DEVIATIONS l-r 4
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i ITEM 1.C ,
c ELECTRICAL CONDulT SUPPORTS l
DESCRIPTION OF NRC ISSUE I
NON-SAFETY-RELATEQ CONDUITS OF ALL SIZES WERE OBSERVED IN SELECTED SEISMIC CATEGORY l 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. 6UIDE 1.29 AND FSAR SECTION 3.7B.2.8 IS REQUIRED WHICH DEFINES THAT NON-SEISMIC ITEMS SHOULD BE DESIGNED
. SUCH THAT THEIR FAILURE WILL NOT ADVERSELY AFFECT THE FUNCTION OF SAFETY-RELATED COMPONENTS ,
_ _ _ _ _ _ _ _ _ - _ _ _ _ _ - - _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ , _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ . _ _ _ _ _m ____ __+ . m . _ a_ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -
O ITEM I.C ACTION SPECIFIED BY NRC PROVIDE THE RESULTS OF SEISMIC ANALYSIS WHICH DEMONSTRATE THAT i ALL NON-SAFETY-RE. LATED CONDUITS AND THEIR SUPPORT SYSTEMS, SATISFY THE PROVISIONS OF REG. GUIDE 1.29 AND FSAR SECTION 3.7.B.2.8.
VERIFY THAT.NON-SAFETY-RELATED CONDUITS LESS THAN OR EQUAL TO 2 INCHES IN DIAMETER, NOTINSTALLED IN ACCORDANCE WITH THE REQUIRE- .
MENTS OF REG. GUIDE 1.29, SATISFY APPLICABLE DESIGN REQUIREMENTS.
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ITEM I.C c
BACKGROUND SEISMIC SUPPORT WAS PROVIDED FOR NON-SAFETY-RELATED CONDUIT GREATER THAN 2 INCHES IN DIAMETER FOR AREAS OF CATEGORY I STRUCTURES WHICH CONT /INED SAFETY-RELATED EQUIPMENT ,
IN AREAS OF CATEGORY I STRUCTURES WHICH CONTAINED LIMITED QUANTITIES OF SAFETY-RELATED SYSTEMS, ALL NON-SAFETY-RELATED CONDUlT, GREATER 0 THAN 2 INCHES IN DIAMETER, WAS NON-SEISMICALLY SUPPORTED AND WAS EVALUATED BY THE DAMAGE STUDY 6ROUP AND SEISMIC RESTRAINT PROVIDED IF IT WAS DETERMINED THAT THEIR FAILURE WOULD BE DETRIMENTAL TO 1 SAFETY-RELATED SYSTEMS 4
, NON-SAFETY-RELATED CONDUIT 2 INCHES OR LESS IN DIAMETER WAS NOT INCLUDED IN OUR SEISMIC SUPPORT PROGRAM OR DAMAGE STUDY EVALUATION BECAUSE'0F THE FOLLOWING:
SMALL MASS LIMITED SPANS BETWEEN SUPPORTS TYPICAL SUPPORT DESIGN INTERVENING MEMBERS INTERACTION CRITERIA 4
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ITEM I.c ,.
TUEC ACTION PLAN -l PROVIDE
SUMMARY
DOCUMENT WHICH DELINEATES'THE PHILOSOPHY AND i IMPLEMENTATION OF THE UAMAGE bTUDY EVALUATION OF NON-SAFETY-RELATED f CONDUIT
- EBQVIDE SEIjMIC ANALYSIS WHICH VERIFIES THE STABILITY DURING AN 55; 0F THE 4 INCH AND UNDER DIAMETER CONDUIT WITH THE PRESENT SUPPORT SYSTEM i
FIELD VERIFICATION THROUGH A SAMPLING PROGRAM OF THE INSTALLED CONDUIT SYSTEM TO VERIFY AS-BUILT CONFORMANCE TO ANALYTICAL ASSUMPTIONS 6
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ITEM 1.D,1 .
OC INSPECTOR QUAllFICATIONS -
DESCRIPTION OF NRC ISSUE LACK OF SUPPORTIVE DOCUMENTATION REGARDING PERSONNEL QUALIFICATIONS l 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 i
i 5 SPECIFIC EXAMPLES CITED i
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ITEM 1 D,1 -
DC INSPECTOR QUAllFICATIONS ,
ACTION SPECIFIED BY NRC 3, l
- TUEC SHALL REVIEW ALL ELECTRICAL QC INSPECTOR TRAINING, QUALIFICATIONS, I
CERTIFICATION AND RECERTIFICATION FILES AGAINST THE PROJECT REQUIREMENTS i
TUEC SHALL PROVIDE INFORMATION IN A FORM THAT CLEARLY SHOWS THAT THE
! REQUIREMENTS HAVE BEEN MET BY EACH ELECTRICAL QC INSPECTOR I
1
- IF AN INSPECTOR DOES NOT MEET REQUIREMENTS, TUEC GHALL REVIEW THE .
j RECORDS TO DETERMINE ADEQUACY OF INSPECTIONS AND ASSESS IMPACT ON THE SAFETY OF THE PROJECT -
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ITEM I.D.1 -
ADDITIONAL NRC COMMENTS .-
IDENTIFIED DEFICIENCIES HAVE GENERIC IMPLICATIONS TO OTHER CONSTRUCTION i DISCIPLINES
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ITEM 1.D.1 .
. BACKGROUND
CPSES PROJECT REQUIREMENT REVISED IN 1981 TO REFLECT SUBSEQUENT COMMIT-i MENT TO ANSI Nf15.2.6 AND REGULATORY 6UIDE 1.58 i
CPSES ASME INSPECTORS CERTIFIED UNDER A SEPARATE PROGRAM INDEPENDENTLY :
- REVIEWED BY ASME-AUTHORIZED NUCLEAR INSPECTOR (AND.
CPSES QC INSPECTOR CERTIFICATION PROCESS REFLECTS A MORE CONSERVATIVE APPROACH THAN THE COMMON PRACTICE IN THE NUCLEAR INDUSTRY TUEC REV!EW OF SPECIFIC EXAMPLES CITED BY NRC-TRT INDICATES THAT SUBJECT INSPECTORS MET PROJECT REQUIREMENTS j ,
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ITEM I.D.1 ,
TUEC ACTION TUEC IS CONDUCTING AN EXPANDED REVIEW OF QC INSPECTOR CERTIFICATION RECORDS AGAINST PROJECT REQUIREMENTS AND WILL ASSURE THAT TRAINING / CERTIFICATION FILES ARE COMPILED IN A FORMAT THAT CLEARLY AND CONCISELY DEMONSTRATES THAT PROJECT REQUIREMENTS ARE MET SCOPE OF REVIEW WILL INCLUDE ALL ELECTRICAL QC INSPECTORS WHO HAVE EVER WORKED AT CPSES AND ALL OTHER QC INSPECTORS (EXCEPT ASME INSPECTORS)
CURRENTLY WORKING AT CPSES ,
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ITEM l.D.1 -
TUEC ACTION (CONTINUED) l PHASE ONE REVIEW OF ALL AVAILABLE DOCUMENTATION CHECKLIST WITH PREDETERMINED ATTRIBUTES CERTIFICATION
SUMMARY
FORM i 1
I PERFORMED BY TUGC0 AUDIT GROUP (TAG)
PHASE IWO EVALUATE CERTIFICATION RECORDS NOT VERIFIED IN PHASE ONE l
SPECIFIC EVALUATION CRITERIA ,
, BASES FOR DECISIONS DOCUMENTED PERFORMED BY SPECIAL EVALUATION TEAM t
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PHASE THREE .
- IF INSPECTORS ARE FOUND WHOSE QUALIFICATIONS CANNOT BE DEMONSTRATED, REVIEW OF INSPECTION RECORDS WILL BE PERFORMED TO DETERMINE IMPACT ON SAFETY OF THE PROJECT PERFORMED BY TUGC0 QUALITY ENGINEERING l
ITEM I.D,2 -
GUIDELINES FOR ADMINISTRATION OF QC INSPECTOR TESTS ..
NRC DESCRIPTION OF ISSUE .
LACK OF GUIDELINES AND PROCEDURAL REQUIREMENTS'FOR TESTING AND CERTIFYING
! ELECTRICAL OC INSPECTORS 4
ACTION SPECIFIED BY llRC TUEC SHALL DEVELOP A TESTING PROGRAM FOR ELE,CTRICAL QC INSPECTORS WHICH 4
PROVIDES ADEQUATE ADMINISTRATIVE GUIDELINES,: PROCEDURAL REQUIREMENTS AND TEST FLEXIBILITY TO ASSURE THAT SUITABLE PROFICIENCY IS ACHIEVED l
' AND MAINTAINED I
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i ITEMi.D.2 .-
e BACKGROUND J
i CURRENT PROCEDURES ALLOW QE PERSONNEL TO DEVELOP TESTS APPROPRIATE TO THE SPECIFIC CIRCUMSTANCES ADDITIONAL GUIDELINES WOULD REDUCE POTENTIAL FOR INCONSISTENCIES i
J j 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 APPROPRIAT REVISED TO REFLECT MORE DEFINITIVE GUIDELINES i
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ITEM NUMBER II.A REINFORCING STEEL IN REACTOR CAVITY .
DESCRIPTION OF ISSUE IDENTIFIED BY NRC .
A PORTION OF THE REINFORCING STEEL WAS OMITTED IN A REACTOR CAVITY CONCRETE WALL PLACEMENT BETWEEN EL. 812'-0" AND EL. 819'-0 1/2" ACTION SPECIFIED BY NRC TUEC SHALL PROVIDE AN ANALYSIS VERIFYING THE ADEQUACY OF THE AS-BUILT CONDITION i
j THE ANALYSIS SHALL CONSIDER ALL REQUIRED LOAD COMBINATIONS i
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ITEM NUMBER II.A .
BACKGROUND
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INVESTIGATED DOCUMENTED OCCURRENCE OF REINFORCING STEEL OMITTED FROM A UNIT #1 REACTOR CAVITY CONCRETE PLACEMENT.
REINFORCEMENT, INSTALLED PER REVISION 2.
REVISION 3 ISSUED AFTER CONCRETE PLACEMENT ADDING REINFORCEMENT.
REINFORCEMENT ADDED AS A PRECAUTION AGAINST CRACKING OF CONCRETE WHICH +
MIGHT OCCUR IN THE VICINITY OF THE NEUTRON DETECTOR TUsES SHOULD A LOSS ,
OF COOLANT ACCIDENT OCCUR.
BROWN &ROOTISSUEDNONCONFORMANCEREPORT:CP-77-6.
GInsS & HILL EVALUATION INDICATED OMISSION DID NOT IMPAIR INTEGRITY OF THE STRUCTURE.
REVISION 4 ISSUED TO PLACE A PORTION OF THE REINFORCEMENT IN THE NEXT CONCRETE PLACEMENT. ,
TRT REQUESTED DOCUMENTATION OF ANALYSIS PERFORMED SUPPORTING GIBBS & HILL CONCLUSION.
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ITEM NUMBER II.A i
! /
TUEC ACTION PLAN i
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AN ANALYSIS OF "AS-built" REACTOR WALL WILL BE PERFORMED. AN
!' ANALYSIS WILL BE PERFORMED TO DETERMINE WHETHER THE STRUCTURAL INTEGRITY OF WALL IS COMPROMISED.
GIBBS & HILL WILL PERFORM THE ANALYSIS AND DESIGN REVIEW THE CALCULATIONS.
AN EXTERNAL ORGANIZATION WILL PERFORM ADDITIONAL DESIGN REVIEW OF CALCULATIONS.
EXPANDED REVIEW OF ALL INSTANCES OF REBAR OMISSIONS WILL BE i PERFORMED TO CONFIRM THAT IN EVERY SUCH CASE PROPER ENGINEERING EVALUATION AND DOCUMENTATION DOES EXIST.
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ITEM II.B -
CONCRETE COMPRESSIVL s..,2NGTH NRC DESCRIPTION OF ISSUE i .- ALLEGATION OF FALSIFICATION OF CONCRETE COMPRESSIVE STRENGTH TEST RESilLTS COULD NOT BE PROVEN VALID OR' INVALID ,
e ~
CONCRETE STRENGTH LOWER THAN THAT SPECIFIED IN THE DESIGN MAY REDUCE THE LOAD RESISTING CAPACITY OF STRUCTURES l-l ACTION SPECIF'IED BY NRC .
TUEC SHOULD DETERMINE AREAS WHERE CONCRETE WAS PLACED BETWEEN JANUARY 1976 AND FEBRUARY 1977 AND PROVIDE A PROGRAM TO' ASSURE ACCEPTABLE CONCRETE STRENGTH .
TEST PROGRAM TO INCLUDE RANDOM SC-HMIor HAMMER TEST ON CONCRETE I IN AREAS WHERE SAFETY IS CRITICAL ,
ADDITIONAL SCHMIDT HAMMER TEST ON CONCRETE NOT WITHIN THIS SPECIFIED TIME FRAME COMPARISON OF THE TEST RESULTS TO DETERMINE IF ANY SIGNIFICANT VARIANCE IN STRENGTH OCCURS I
ITEM II.B ,
BACKGROUND .-
l ALLEDGED FALSIFICATION OF COMPRESSIVE STRENGTH TEST NRC REGION IV INVESTIGATED OTHER ALLEGATIONS AIR CONTENT
=
SLUMP DEFICIENT AGGREGATE GRADING
. i I
CONCRETE IN THE MIXER TOO LONG PREPONDERANCE OF EVIDENCE SUGGESTS FALSIFICATION DID NOT OCCUR 4 i MATTER CANNOT BE RESOLVED BASED ON PRIOR COMPRESSIVE STRENGTH ,
TESTS IF LYJBT EXISTS DUE TO FALSIFICATION NEED CONFIRMATORY EVIDENCE ON TEST RESULTS j i
i 1
ITEM II.s l-TUEC ACTION PLAN l
ScHMIDT (REBOUND) UAMMER IEST, A NON-DESTRUCTIVE TEST, WILL BE PERFORMED AS REQUESTED BY TRT 327 PLACEMENTS IN CATEGORY I - SAFETY-RELATED STRUCTURES DURING TIME FRAME IN QUESTION 50 TESTS TO BE PERFORMED 50 TESTS OUTSIDE TIME FRAME IN QUESTION STATISTICAL ANALYSIS TO DETERMINE IF A SIGNIFICANT VARIANCE EXISTS BETWEEN THE TWO DATA SETS i t t
._______'___,_m_ _ _ ~ _ _ _ _ _ . . _ _ _ . . . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _
ITEM II.C '.
HAINTENANCE OF AIR GAP BETWEEN CONCRETE STRUCTURES l NRC DESCRIPTION OF ISSUE
) . ADEQUACY OF THE AIR GAP COULD NOT BE DETERMINED SINCE:
AVAILABLE DOCUMENTATION DID NOT PROVIDE LOCATION OR EXTENT OF REMIANING DEBRIS.
ADDITIONAL SITE FIELD INVESTIGATIONS WERE NOT DOCUMENTED ON
! PERMANENT RECORDS.
PERMANENT INSTALLATION OF ELASTIC JOINT FILLER HAD NOT BEEN SHOWN
- TO BE CONSISTENT WITH SEISMIC ANALYSIS ASSW1PTIONS AND DYNAMIC MODELS USED TO ANALYZE THE BUILDINGS.
l j ACTION SPECIFIED BY NRC ;
i -
! PERFORM INSPECTION OF THE AS-BUILT CONDITION TO CONF 1RM THAT ADEQUATE 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 j RESPONSE.OR DYNAMIC RESPONSE CHARACTERISTICS OF THE CATEGORY I STRUCTURES, COMPONENTS AND PIPING WHEN COMPARED WITH THE RESULTS OF THE ORIGINAL I
ANALYSES.
I ~
ITEM II.C r.'.
l
\ BACKGROUND SEPARATION BETWEEN CATEGORY I STRUCTURES IS REQUIRED IN THE FSAR TO PREVENT UNACCEPTABLE SEISMIC INTERACTION DURING AN SSE
~!
ELASTIC JOINT FILLER " ROT 0 FOAM" USED UNTIL OCTOBER 1977
~AFTER REMOVAL - OTHER FORMING TECHNIQUES USED CONCRETE PRE-PLACEMENT INSPECTIONS DOCUMENTED AIR GAP WAS PER DESIGN REQUIREMENTS ,
4 POST CONSTRUCTION INSPECTIONS DID NOT DOCUMENT CLEANLINESS i
0F THE AIR GAP i
W i .
p .
- ITEM II.C -
I TUEC ACTION PLAN
! QC INSPECTION OF AIR GAP BETWEEN CATEGORY I STRUCTURES AND CATEGORY I j AND NON-CATEGORY I STRUCTURES WILL BE REPERFORMED AND DOCUMENTED 4
f i ANY DEBRIS ENCOUNTERED MAY BE REMOVED AFTER DOCUMENTATION BY QC j-
, ENGINEERING EVALUATION OF DOCUMENTED INSPECTIONS FOR IMPACT ON SEISMIC AND DYNAMIC RESPONSES l
! IF APPROPRIATE, FURTHER ENGINEERING ACTIONS'WILL BE DETERMINED FOR EVALUATION OF IMPACT ON COMPONENTS AND PIPING '
REMOVE ANY DEBRIS WHICH SIGNIFICANTLY AFFECTS THE ORIGINAL DESIGN ,
CALCULATIONS REVIEW PROJECT PROCEDURES FOR ESTABLISHMENT *0F REQUIREMENTS FOR MAINTENANCE OF ADEQUATE SEPARATION CONDITIONS -
- EVALUATE NEED FOR FSAR UPDATE BASED ON AS-BUILT CONDITIONS j
i i
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i 4
. . - _m_ _ _ _ _ --m-___-m_ _ _ - _ _ _ , _ _ _ . - _ _______ _ __ . - - _ _ ___ _ __
ITEM ll,E
, REBAR IN FilEL 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 HANDLTNG BUILDING MAY HAVE
! OCCURRED.
i l LOSS OF THE REBAR MAY REDUCE THE LOAD RESISTING CAPACITY OF THE i- CONCRETE FLOOR SLAB,
- ACT!0N SPECIFIED BY NRC .
i
- TUEC SHALL PROVIDE 'fNFORMATION TO DEMONSTRATE THAT ONLY #18 REBAR IN IST LAYER WAS CUT, I
6
~
- OR 3
- ^
PROVIDE DESIGN CALCULATIONS TO DEMON 3TRATE THAT STRUCTURAL INTEGRITY
~
IS MAINTAINED EVEN IF #18 REBARS IN BOTH IST *AND 3RD LAYERS WERE CUT.
4 4
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.-. . . __ _- . ._ . .- . . . _ .. ~ _
o ITEM 11.E TUEC ACTION PLAN
, DESIGN CALCULATIONS WILL BE PERFORMED TO . DETERMINE ST20CTURAL ADEQUACY OF SLAB EVEN IF 1-#18 IN IST AND 3R'D LAYER IS CUT. <
A REVIEW OF THE PROGRAM 3 CONTROLLING REBAR CUTTING WILT. BE PERFORMED.
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.g ITEM II.D '
%A SEISMIC DESIGN OF CONTROL ROOM CEILING ELEMENTS NRC DESCRIPTION OF ISSUE REVIEW OF THE CONTROL ROOM CEILING REVEALED THAT ARCHITECTURAL INSTALL 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 SEISMIC ITEMS SHOULD BE DESIGNED IN SUCH A WAY THAT THEIR FAILURE WOULD NOT ADVERSELY AFFECT THE FUNCTIONS FOR SAFETY-RELATED COMPONENTS OR CAU INJURY TO OPERATORS.
REVIEW OF CALCULATIONS FOR SEISMICALLY RkSTRAINED LIGHTING FIXTURES AN 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.
s 4
s
_____ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ __, _ _ _ _ _ __ __ _ _ _ _ - _ _ _ _ . . _ _ m - ______ _._______ - _____ _ _ _ _ _
i
- i i ITEM II.D ;;
! ACTION SPECIFIED BY NRC PROVIDE RESULTS OF SEISMIC ANALYSIS WHICH DEMONSTRATES THAT THE MON- -
SEISMIC ITEMS IN THE CONTROL ROOM (OTHER THAN THE SLOP'ING SUSPENDED DRYWALL CEILING) SATISFY THE PROVISIONS OF REG. GUIDE 1.29 AND FSAR SECTION 3.7B.2.8. .
PROVIDE AN EVALUATION OF SEISMIC DESIGN ADEQUACY OF SUPPORT SYSTEM FOR LIGHTING FIXTURES AND DRYWALL CEILING WHICH ACCOUNTS FOR PERTINENT -
FLOOR RESPC;4SE CHARACTERISTICS.
i PROVIDE' VERIFICATION THAT ITEMS NOT INSTALLED IN ACCORDANCE WITH THE j REQUIREMENTS OF REG. 6UIDE 1.29 SATISFY APPLICABLE DESIGN REQUIREMENTS.
I i - PROVIDE RESULT $ OF AN ANALYSIS THAT JUSTIFY ADEQUACY OF THE NON-SAFETY l CONDUlT WHOSE DIAMETER IS 2 INCHES OR LESS. ,f i
PROVIDE RESULTS OF AN ANALYSIS WHICH DE,MONSTRATES THE FOREGOING PROBLEMS 3
i ARE NOT APPLICABLE TO OTHER CATEGORY ll AND NON-SEISMIC STRUCTURES, j i SYSTEMS AND COMPONENTS ELSEWHERE IN THE PLANT.
i i
I i
d ITEMkl.D ~/
BACKGROUND DESIGN PHILOSOPHY WAS TO SE!SMICALLY RESTRAIN ALL MEMBERS WITH LARGE MASS.
ARCHITECTURAL FEATURES WITH SMALL MAGGES, IF LOCALIZED FAILURE OCCURRED, WOULD NOT BE ADVERSE TO THE OCCUPANTS OF THE CONTROL
- j. -
ROOM.
WITH THIS PHILOSOPHY, ENGINEERING ADYISED THE DAMAGE STUDY 6ROUP THAT THE DESIGN WAS IN COMPLIANCE WITH THE INTENT OF REs. GutDE 1.29 AND NO FURTHER REVIEW WAS REQUIRED.
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' ITEM II.d SEISMIC DESIGN OF CONT!!OL CEILING ELEMENTS y
/
Nffges mmsm m-ues a m.mmm .. . . .,
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-_.__ __-_ - __ - _-- _ __ -_ _ _ _ _ . - . . . . . . -, N __ _-- _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ - _ _ _ _ _ _ _ _ _ _ _
~
. t j ITEM II.D ..
l '! -
- TUEC ACTION i
l FOR THE MOST DIRECT AND TIMELY RESOLUTION, ACTIONS WILL BE TAKEN TO PRECLUDE ANY ITEM FROM FALLING.
SEISMIC ANALYSIS WILL BE PROVIDED WHICH' DEMONSTRATES COMPLIANCE WITH
- REG. 6UIDE 1.29 AND FSAR SECTION 3.7B.2.8.
- HORIZONTAL SEISMIC RESTRAINTS WILL BE INSTALLED TO PREVENT INTERACTION .
BETWEEN CEILING SYSTEMS.
ItE DRYWALL CEILING WILL BE REPLACED TO EXPEDITE RESOLUTION IN LIEU OF VERIFICATION TESTING.
I '
PERFORM EVALUATION ON INDIVIDUAL COMPONENTS OF ACOUSTICAL AND LOUVERED CEILINGS AND FROVIDE POSITIVE ATTACHMENT IF FAILURE IS A CONCERN.
VERIFICATION WILL BE PERFORMED BY QUALITY CONTROL ON ALL APPLICABLE DESIGN REQUIREMENTS.
- PROVIDE
SUMMARY
DOCUMENT WHICH DELINEATES THE PHILOSOPHY AND IMPL,EMENTATION
, CF THE DAMAGE STUDY EVALUATIONS MADE ,THROUGHOUT THE . PLANT WHERE POTENTI AL 4
INTERACT 10NS EXISTED.
PERFORM A REVIEW OF ARCHITECTURAL SPECIFICATIONS AND DRAWINGS TO CONFIRM THAT ARCHITECTURAL FEATURES HAVE BEEN APPROPRIATELY EVALUATED IN OUR ,
PRESENT DAMAGE STUDY PROGRAM.
1 L
j .
- HOT FUNCTIONAL TESTING DATA PACKAGES ISSUE III.A.1 ,
DESCRiPTIONOFCONCERN
- IN REVIEWING TEST DATA PACKAGES, THE TRT FOUND THAT CERTAIN TEST OBJECTIVES WERE NOT MET FOR AT ,
LEAST THREE PREOPERATIONAL HOT FUNCTIONAL IESTS
- ACTIONS SPECIFIED BY NRC REVIEW ALL COMPLETE PREOPERATIONAL IEST DATA PACKAGES TO ENSURE THERE ARE NO OTHER INSTANCES WHERE TEST OBJECTIVES WERE NOT MET, OR PREREQUISITE CONDITIONS WERE NOT SATISFIED. THE THREE ITEMS IDENTIFIED BY l THE TRT SHALL BE INCLUDED, ALONG WITH APPROPRIATE JUS.TIFICATION, IN THE TEST DEFERRAL PACKAGES PRE- l i
SENTED TO THE NRC 1
i
~
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. 1 HOT FUNCTIONAL TESTING DATA PACKAGES l ISSUE III.A.1
. 1 DESCRIPTION OF CONCERN IEST DEFICIENCY 1CP-PT-55-05 A LEVEL DETECTOR APPEARED TO
" PRESSURIZER BE OUT OF 'CALIBRATI0N'DURING l
LEVEL CONTROL" THE TEST AND WAS REPLACED AFTER
~
THE TiST. THE AFPROVED 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-55-0; " PRESSURIZER LEVEL CONTROL" PRESSURIZER LEVEL CONTROL MAINTAIN LEVEL IN MANUAL AND AUTOMATIC MODE
r '.?
HOT FUNCTIONAL TESTING DATA PACKAGES ISSUE Ill.A'.1 TUEC ACTION PLAN REVIEW EACH TEST IDENTIFIED BY TRT CONCERN
- REVIEW THE SEVEN REMAINING HOT FUNCTIONAL PRE ,
OPERATIONAL IESTS NEED FOR RETESTS TO MEET TEST OBJECTIVES WILL CONSTITUT5 A REJECT - - -
ONE REJECT WILL REQUIRE SAMPLE REVIEW OF REMAINING 136 IF REVIEW OF FIRST SAMPLE OF 20 REVEALS ONE REJECT, REVIEW ADDITIONAL SAMPLE OF 20 l
REVIEW OF SECOND SAMPLE REVEALS ONE REJECT, ALL REMAINING APPROVED TESTS WILL BE REVIEWED l
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JTG APPROVAL OF TEST DATA ISSUE lil.A.2 DESCRIPTION OF CONCERN TO COMPLETE THE PREOPERATIONAL IESTS PROPOSED FOR DEFERRAL AFTER FUEL LOAD, THE JTG, OR SIMILARLY QUALIFIED GROUP, MUST APPROVE THE TEST RESULTS _
PRIOR TO PROCEEDING TO INITIAL CRITICALITY. IHE TRT DID NOT FIND ANY DOCUMENT PROVIDING THAT TUEC IS COMMITTED TO DO THIS ACTIONS SPECIFIED BY NRC 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 SPECIFICATIONS i
,e
" ,P i
l 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 SPECIFIED BY NRC EVALUATE THE REQUIRED PLANT CONDITIONS FOR DEFER-RED PREOPERATIONAL IESTS AGAINST THE PROPOSED TECHNICAL SPECIFICATION REQUIREMENTS AND OBTAIN NRC APPROVAL WHERE DEVIATIONS FROM THE IECHNICAL SPECIFICATIONS ARE NECESSARY 9
4 r --- .
.v TRACEABILITY OF TEST EQUIPMENT 1 ISSUE III.A.4 l l
l l
DESCRIPTION OF CONCERN l
1 1
TEST DATA FOR IHERMAL EXPANSION IEST DID NOT ,
PROVIDE FOR TRACEABILITY OF TEMPERATURE MEASURING INSTRUMENTS IN THE MANNER.SPECIFIED BY STARTUP PROCEDURE -7 ACTIONS SPECIFIED BY NRC INCORPORATE THE NECESSARY INFORMATION INTO TEST DATA PACKAGE ESTABLISH CONTROLS TO ASSURE APPROPRIATE TRACE-ABILITY DURING FUTURE TESTING
~
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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 SPECIFIED BY NRC-IDENTIFY AND-JUSTIFY ANY OTHER DIFFERENCES AS A RESULT OF APPLYING ANSI /ANS 56.8 IN LIEU OF ANSI N45.4-1972 .
(REQUIRED ACT' ION CLARIFIED BY NRC LETTER DATED AUGUST 27, 1984) .
- / -
o
q e' PREREQUISITE TESTING ISSUE III.C DESCRIPTION OF CONCERN INITIAL CONDITIONS FOR PREREQUISITE IESTS VERIFIED BY CRAFT PERSONNEL ACTIVITY IMPROPERLY AUTHOR ZED BY STERTUP MANAGEMENT MEMORANDUM ,
ACTIONS SPECIFI-ED BY NRC RESCIND MEMORANDUM ASSURE NO OTHER MEMORANDUM ISSUED IN CONFLICT WITH APPROVED PROCEDURES iW '
~
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l _
PRECPERATIONAL TESTING ISSUE III.D DESCRIPTION OF CONCERN CURRENT DESIGN INFORMATION NOT PROVIDED TO TEST ENGINEERS ON A ROUTINE, CONTROLLED BASIS ACTIONS SPECIFIED BY NRC ESTABLISH MEASURES TO PROVIDE GREATER ASSURANCE THAT TEST ENGINEERS ARE PROVIDED WITH CURRENT CONTROLLED DESIGN INFORMATION e
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~
, . O LIVE R G. C A N N O N Q S O N. I N C. zxhide # 2 DEPARTI.TJMT.L CO1?HESPONDENCE DATE N embe r 4,1983 i
SU O J E C T _._ Meet ng TUSI - Dallas lleadt;uart ers - Wedne:: day 11/3/33 - RE: C0:fM4CllE l EAR COAT {,
7g File cc: JJNorris, RATrallo FRONI k!m#Eh =-
Joe George, Vice Presid..nt - TUSI
. Dave Chapean, Corporate QA Manager - TUCO John Merritt, Jr., Assistant Project General Manager - TUSI Billy R. C1.m.!nts, Vice President-Operations -
TUC0 Tcny Vega, QA L nager to Chapman - TUG 3 R. B. Roth & J. J. Norris - O'. B. Chnnon & Son, Inc.
- 1. Session st arted at 3:00 p.n. and t.as prir.cipally on clients reaction to August 8, l33 Joe I.ipinny trip report.
. In general, with only a thret' day uit.c visit in July, 19S3, certain of the positions taken by Joe and stated as ' factual', would have taken weeks of close examination and evaluations according to the clients peopic.
RiiR apologized again for the lack of secur~ity at OBC, in that an in housc.
2.
m mo ' leaked out' and had caused our client such consternation and new additioaal expe:.ure to inteiscnors.
- 3. In nauwer tc iW.P upecific qu.astions, liilly Cls u:ents said that site Q. C.
reports directly to him, also, contrary' to Lipinsky tnemo, site QA Man.iger, Tolson, r. port s t o h hs .:nd not t.o Production. Davc Chupaan readily con-fitued this. Further, Teu1ron is a TUC0 nan and not Erown & Root.
- 4. Joe George is Vice President and has complete charge of C. Peak. lic cmphasized th ic r.cown & Roor, currently ace essen'islly labor Brokers cod he is calling the shots. !!cace, a's sugge:.ted by Li iinskyl nemo, whether Brown & Root t+ould be receptive to, or responsive to a Cannon andit and/or the findings therenf is a m.ite point with TUSI.
- 5. JJ:; orris rai. sed pa at of writing NCR's, or the lack thereof, and Cler... uts and D..ve Chapr:an vspo:"I d t hat ucthing in 10CFR50 requires "NCR". TUco clected to have 'u.c:at i:: factory reports ' as their mechanism for identi fying construction ur cip:i .n.
l nt deficiencies.
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tt.IVlut p. C ANNON r, SON, INC.- -
11ecting TUSI - Dallas !!cadquarters Page 2 ,
- 6. GRoth aded further who has responsibilitics for ;;i ncratin.c, QCP's, QAP's ..nd QIP's and Ch.apesan answered , TUGO, threu;;h Toul uon's gr oup.
Jack mided th.it he was pre:;ent, when JJI.ipinsky a t with Teuleen .md Toulson's ri :: ark aboue 'not his concern' rol.it ed t o* the Plant Lice nsing-Procedure and not to .iJLipinkys's voicing his via w of the ign.ili ty of work and inspection at the site.
- 7. KURoth sucscst ed that to further addencs C.innon and TUST concerns on the Class I coatings, and recognizing its been three in-2nths or bett er since C.mnon inade any actual site inspt:ctions, that C5nnon set up a Taskforce Group, to visit the site ASAP and take shatever tiine is required to corac up with a realistic overview of the coatings ef fort,
- c. pecially since the retr'o . fit program was effected areund the fi rst of Septiaber.
- 8. All ..;;reiad - we were thanked for coming to Dallas' on short notice and the m.eting adjourned.
- 9. MRoth to set up the Taskforce Group, to co: .cnce site visit Nover.ber 9, 1983.
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R. B. Roth Is 1
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OLIVER B. CANNO' N Q SON. INC. gxs13t ,4 e
DEPARTMENTAL CORRESPONDENCE DATE November 28, 1983
^
s.4301 - Coatings Overview Task Group Repork .
. ... ort B. Roth
.;ph A. Trallo
Background:
Cannon Personnel Concerned:
Robert B. Hoth - President and Chief Executive Officer Ralph A. Trallo - Vice President Nuclear Services ~
i John J. Norria - Vice President and Project Account Ma, nager John J. Lipinsky - Corporate Quality Assurance Director M. Keith Michels - Corporate Quality Assurance Lead Auditor On November 4,1983 a Cannon Task Group consisting of the writer, J. J.
Norris, J. J. Lipinsky, and,M. Keith Michels was established to perform follow-up cvaluation of items previously addressed within the scope 1
. provided under our Consulting Services Contract
- with this client.
(_ This follow-up was to be in accordance with guidelines set forth in i
" departmental correspondence from Robert B. Roth to the writer
- and the principle purpose detailed was to evaluate the nuclear coatings retrofit program at Comanche Peak. Ke'y areas included:
Material Storage and Control Painter mechanic qualification / documentation Working relationship between Production / Inspection Status and adequacy of documo'ntation/ traceability '
Implementation of coatings retrofit effort, see " Painting Hinutes of Hecti6g", pages 1 to 4, dated 3/15/83, as prepared '
by R. M. Kissinger, Project Civil Engineer 5 Compliaitee of Nuclear coatings to Proje,:t Specifications requirements Overview ns to adequacy of current safety-related coatin$s in pince, as per proper Industry practice, etc.
t
- TUGO. Purchase ' Order..No. CPF-15245
- Departmental correspon1cnce 'R.
F0lA-85-59 B. Roth to- R. A. Trallo, 11 78-83 1 .
- a-- .
1 $
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OLIVlitt D. CANNON Q SON. INC. .
- H-8301 - Costings: Overview Task Group Report * '
TO: Robert B. Roth ,
. November 28, 1983 .
Page Two .
~
ZZ. Preliminary Preparation: ,
_ \
~
The writer discussed the operation and purpose of the Cannon Task Group )
i with the other participants. A point of departure schedule was i
. established in accordance with Robert B. Roth's memo guidelines, and preliminary checklists were prepared to facilitate orderly progression and review.3* The intent was to have OBC QA Services (LipinslEy and Michels) and J. J. Norris (Account Manager) onsite for whatever time was i
required to complete the necessary reviews. R. A. Trallo was to visit l the site to perform an overall evaluation as to the effectiveness of the Cannon Task Group activities. Commencement dates for site activities were: November 9, 1983, J. J. Norris, J. J. Lipinsky and H. Keith Michels onsite to begin proliminary reviews; November 10, 1983 the writer onsite to insure effective implementation of the Canron Task Group actitities.
( . -
III. Task Group Activities:
o On November 8,1983 I called John Herr'itt to advise him that Oliver B. -
Cannon personnel would be onsite November 9, 1983, and requested that he have available the folllowing information for review:
Organizational chart with names and titles of individuals and positions filled Copy of current revision of the QA Program -
Complete cooperation with various onsite ,
i departments, orGanir,ations and individuals j List of n0Na of all inspection personnel and icvel of certification .
List of nanes and positions 'of production personnel (foremen and above)
( ,
List of cortified painters nnd systems for which the painters are qualified -
3*
"JJL nnd MC1 Co nanclie Peak ' Trip Plan" (4 Pages) .
-4e ,
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OLIVER IL CANNON r, SON. INC.
i H-8301 - Qoatings Overview Task Group Roport T0: Robe ~rt B. Roth
< November 28, 1963 .
Page Three
- ( .
III. Task Group Activities: (continued) i l
Liason or interface person for quality assurance, quality j control, production, and other departments in order to expedite l and aid in the performance of this review
~
Mr. Morritt requested that any reviews conducted by OBC sere to be performed on a joint basts (ie. QA and Accout Management).
4 Cannon personnel were onsite the morning of November 9,1983 At that time J. J. Lipinsky gave a copy of the preliminary review checklist3 .
to John Herritt. J. J. Norris and John Merritt discussed the checklist
, and Mr. Merritt requested a*" kick off" meeting prior to any. formal reviews or implementation of Cannon Task Group activities.
C It became evident that the scope of the Cannon Task Group activities I
wnich had been previously outlined
- were not' coincident with that perceived by TUGO. Mr. Merritt requested a review meeting to discuss the concerns of the "Lipinsky Memo" and based on the outcome of that meeting TUGO would re-define the scope of the Cannon Task Group activities. The review meeting was held commencing Thursday, AM, November 10, 1983, with John Merritt chairing.
Mr. Ron Tolson, Con-,;ruction QA Supervisor, started .the discussion. In essence the *Lipinsky Memo"
- was used as an agenda, and each memo paragraph, or statement, was discussed and clarified. The meeting was recorded and the transcript has been distributed for comment. It became evident that ccrtain statements in the trip memo were incorrectly stated or misinterpreted. This was principally due to the organizational structure at Comanche Peak. (ie. A management team consisting of individual's employed by different or6anizations.) '
2.
3
- Departmental correcpondence it. B. Roth to R. A. Tralln,11-4-83 JJL and Mxa comanche c.uk Trip Plan" (4 Pages) )
- 4. - Trip Report -(JJL to !!uit) 8-3-83 .
. l 5.' . " Lip'insky',Hemo Heeting on November 10 and November 11, 1983"
. .. l
- ,1
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'ol,JVI;R 11. CANNON r, SON. INC. '
H-8301 - Costings Overview Task Group' Report TO: Robert B. Roth November -28, 1983 U-Page Four .
h .
Mr. Tolson explained the operational
- roles of the individuals involved on the Comanche Peak Team, along with their proper titles, responsibilities, and. lines of reporting. '
Concerns raised in the *Lipinsky Memo"
- were for the most part, based on observations and discussions between Joe Lipinsky and site .
personnel.
At face value this "information," would be the cause for raising concerns regarding the site coating activity. Throughout the course of the November 10 aceting, it was evident that Site QA 1
Management at Comanche Peak was not interested in further audits, or program reviews, since they have been subject to numerous outside and internal reviews and audits in.the past several years. These constant
, n a'd sometimes redundant reviews, compounded by the apparent personnel matters,rosulted in short or clipped responses, which could readily be misinter'preted.
~P.-- .
(
Regarding areas of coatings material handling, personnel qualifications, non-conformances, and quality responsibility, Mr. Tolson discussed the current procedures and controls in effect at Comanche Peak. This detailed information not readily. availa'ble to Joe Lipinsky during his site visit of July 26, 27, 28th, 1983, and on uhich visit he based his August 8, 1983 trip report to Robert B. Roth.
i i
Comanche Peak Management stated that they do not feel they have a problem in the areas of concern, as raised in the "Lipinsky Memo."4
- A detailed indepth audit was not agreed to. However, a review of-specific items could be scheduled, or program " paper" be made available for review, at Cannon's request.
After consideration the , Cannon Tank Group decided thnt a limited review was unwarranted, since it would not provide sufficient support to a statistical extrapolation as to the entire coatings programs' effectiveness.
( -
Detailed discussion and information is provided in the notes of the November 10 and November 11 meetings. (Roterence footnote 5.)
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- Trip R'eport (JJL-to RBR) 8-8-83 W ...3
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- QI.WE!!,13. CAN NON C, S ON. INC.
1 H-8301 - Coatings Overview Task '"Group Report g TO: Robert B. Roth -
2 November 28, 1983 ,
Page Five
IV. Conclusion:
The Cannon Task Group df.d not perform the total overview function as originally scoped by Robert B. Roth. This was due to the request of our client to explore and review the "Lipinsky Memo"
- in further detail, paragraph by paragraph. .
s The site meetings of November 10 and 11,1983 resulted in the following:
The concerns raised in the Lipinsky Memo"
- were based on i
limited information and observations which were neither investigated nor discussed in sufficient. detail, during his site visit, to either allay or to confirm.
(, Comanche Peak Site Management adequately detailed the programs and controls in place, which would relieve or allay the
. concerns raised in the "Lipinsky Memo."
- Cannon has no basis to confirm that these programs and controls are in place and are being effectively implemented. Confirmation could only be provided by a detailed audit. Such an audit could be redundant and certainly time consumins'. Further, TUGO has neither requested same, nor is it required by the referenced Purchase of Services Agreement.
Based on the information provided by the Comanche Peak Site Organization .
~
we can assume that our ' concerns i are unfounded, however, affirmation could only be finalized by further effort.
t 1
L ~ Ralph A. Trallo l
RAT:jr 4 - Trip Report (JJL to HBR) 8-8-83 l _
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- "2
. OLIVER B. CANNON Q SON. INC. -
l DEPARTMENTAL CORRESPONDENCE DATE- November 4. 1983 '
SUBJECT Jnb 118301-Coatinn Overview Task Crouo'. Cannon to TUST' ( omncine Peak "yg _ R.
A. Trallo. J. J. Norris. 3. 3. 1ininsky. M. Michele ee? APMe. Aree M le ygong _ R. B. Roth -
1.
As a follow-up to our Consulting Services Contract over the past sunsner, for this client, I am assigning this Cannon Task Force to perform a Nuc1 car Coatings overview at the Comanchc Peak Nuclear Plant, Glen Rose,being constructed by Texas Utilitics Services, Inc. at Texas
- 2. Task Force to be:
R. A. Trallo J. J. Norris - Vice President - Nuclear Services
- Vice President !!ouston Operations J. J. Lipinsky - Corporate QA/QC K. Michcis - Lead Corporate Auditor 3.
Site effort to commence, Wednesday morning, November 9,1983. Jack, C Joe and i*cith to report on Wednesday.
till 1.ater in the week. Ralph may not be abic There is no established time limit. I suspect to schedule
,, from three to 'five days may be necessary, buc the best judgment of our seniot swnagers involved will so ascertain. Ralph is designated as Task Force Leader.
- 4. Principal purpose is to evaluate the Nuclear Coatings Retrofit Program that has been in effect over the last 3 to 4 months.Key areas would include:
Material Storage and Control Painter mechanic qualification / documentation
^
Working relationship between Production / Inspection Status and adequacy of documentation / traceability -
Implementation of coatings retrofit effort. see " Painting Hinutes of Hecting", pages 1 to 4, dated 8/15/83, as prepared by R. M. Kissinger, Project Civil Engineer u
Compliance quirements. of N^ clear coatings to Project Specifications re-(. -
Overview as to adequ.acy oi current sa'fety-rcisted coatings in place, as per proper Industry practice, etc.
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01,lVER D. C AN NON 4 S ON. TNC.
Tor R. A. Trallo, J. J. Norri's, J. J. Lipinsky .K. Michels November 4,1983
,' Re: Job H8301 - Task Group Page 2
- 5. Separate individual and objective reports are due to Task Leader and his composite report shall be submitted to my office within five working days after site assignment. 1 j
Ralph is further charged with the security of the reports / observations i
l given to him and his composite report shall be directed to me, and no other copies issued or distributed.
- 6. I shall then communicate the results of our effort to TUSI. -
l
- 7. All costs and expenses involved shall be submitted in separate expense envelopes, with appropriate receipts and clearly marked with Job #H8301.
- 8. Any questions or clarifications to the above shall be addressed to my i attention.
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mcmo revec 5 Page i of 4 JJL & WH CO. WOE RIAK TRIP' MID: Organizational ch.trt with n.vnes and titics of individuals and positions filled Copy of current revision of the QA Program Complete cooperation with various on site departments, organizations and individuals, ,
. List of names of all inspection personnel and level of certification .
. List of names and positlocs of production personnel (foremen and above)
List of certified painters and systems for which the painters are qualified, -
. Require liason or interface person for quality assurance, p% >> quality control, production, and other departments in order "
to expedite and aid in the performance of this review C
OAY #1 Revic'w QA Program in gencIal
.~.
Revicw QC Procedures and how those piecedurcs related to the QA Program .
Go 'over QC Procedure nin6ering sequence Review site organization and responsibilities (both individual and company)
Review Retrofit program (why implemented, still on-gning-why? why nut?, what has been accomplished to datc)
Tour Site (containt.cnt, paint shop, werchouse, calibration lab, etc.)
NOTE: Dadae 301 as tima allous t
9 6
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1 Psiya 2 ef 4 I
- a. 1 DAY #2 Non-Confirming CondLtlons Review existing NCR's Review preentfure for unsatisfactory reports to determine adequacy .
Review procedure for NCR to determlnc adequacy I l
Review logs for NCR and unsatisfactory report !
Revicw status tag procedure and logs .
Revicw NCR and/or unsatisfactory coordinator status -
Procedure and Spc.cification Revision Control ,*
Review system and procedure for changes to specification and procedurcs -
Revicw controls - assure th'at only most current revisions of specification and procedurcs are utilized Examine nn site situation to determine sequence of work
( activities g DAY # 3&4 Material Storage Review procurement docunents Review rccciving procedures and records Revicw personnel qualifications 'for receivin0 personnel Review product certification Examine reject and hold areas (review tagging procedures and logs)
Examine facilities (take reprencntative batches and determine if procedure followed) i
, Review warchcosing records
. \
Exa'ninc facilities and check calibration of recording therinographs (exxninc certific:ites of compliance for instron"nts, calibration recorch for instrum.:nts, perr,cnn?1 for individuals p.:rtoriaing calibrat. inns)
Deter:nine place war:: 1 tri r.irca.bility r.: of inatcrial frnin receiving to in (alco Quing i..ickw.ird::uarchauning recarris Irnn in place w.i:4)and daily reports
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- Pagc 3 cf A DAY #5 ,
Personnal Qualificaticns ,
. \
Painter Qualifications -
Revicw indoctrineition and training program Observe (if possib?.c) class room session and field qualifications
- Revicw documentation on personnel qualifications Inspector Qualificaticns '
Revicw indoctrination and, train'ing program'
- Review personnel qualifi~ cation with regard to level of certification Review documentation on personnel qualifications Auditor Qualific'tions a
Review personnel qualifications for auditors
( Audits Review documentation on personnel qualifications A
Review audits of the coating operation DAY M Calibration .
Review calibration Icgs Review certificates of compliance for test instruments l Review traceability of instruments to NOS l
Review training and qualification of calibration personnel
/
Revicw tjocumentation of personnel qualifications
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Page 4 of 4
. DAY #7 4'8 Daily Inspection Reports -
Review adenjacy of daily in:ocction ecoorts (coInpared to
- information reoJircu by A
- ssI)
Determine traceataility of records for representative arcas and/or itens DAY #9 410 Wrap up and tie together items that were examined earlier.
NOTE:
The above schedule is tentative in nature and is not meant to be all inclusive. Arcas or questions raised'during the -
review will be pursued until a r'ceponse is'provided.
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DEPARTMENTAL CORRESPONDENCE .
'DATE October 2B_ 1991 SJECT Texas. Ittilit ies Services - Letter dated October 27, 1953 R. B. Roth OM_ J. Liefnskv
- 1. In addition to the individuals identified in the subject trip
- report, the writer set with a number of the coating quality control inspectors. -
These individuals were: 1.ane t t e Adams Dave Ambrose Gary Corrigan
.3oc Deshanbo (sp?) -
Margaret Lucke Evert Houser-Casandra Owen Note: The writer u,et other inspectors but cannot recall the individual names. " ~
The writer discussed job status, project conditions, work activitics and other miscellaneous items with the above individuals. The writer
-has either empicyed or worked with the above listed individuals on one or more nuclear projects.
- 2. As stated repcatedly by the writer, a thorough review /aud,it would be required to provide specifics on the six itetns listed by p. N. Chapmt However, the following explanstion is provided for each item as listec by D. N. Chap =mn. '
A. Material Storage - the writer observed that the coating material is mixed, and set on pick up pallets outside Containment. None of the caterial had tags attached (status or mix information), and there is no apparent control on how long mixed material sits on the pallets.
B. Workmanship - at the time of the writer's visit the applicator qualification program was being administcred by production persont with no insp'ection or senitoring of the* qualification process (beir during or after) by quality control. Itiis information was provide to the writer by Mark Wells of site engineering and quality contre Vith regard to the quality of the work, the writer observed numerc areas of in place work which by appearance was less than the quals of work put in place by Cannon on nuclear and non-nuclear project:
cae 215 F0lA-85-59
To- p'*
3' ." B. Roth
- _exas ut;3; 3 s
V """I'*8 fftter Da QedO/27/g3
. - October 26, 19 Additionally, *
.t by engineeri' individus1s n g and/or productithe writer was informed o on that
.any good as p(ainters.34 out of 451
- a low percentage individuals) empl of th C. oyed as painters werc the report format utilized oCompliance with A :
n ments site. - the writer only briefly examin' Also, ANSI has requirements or apincluded on,the inspecticH fall of the requir at there are forms to be compl eted), plicator qualification (s report.
D. manuf acturers' instructions , to new+ a few.unterial storage, tagging E.
"Possibly" coating integrity ,
possible document deficienci sec Item E and P on page 4 -
p, Morale probicas - based oc coes see Item C above f
ebc writer concluded thatpersonnel, v includingonthose vere not satisited with their the ins job s.
~pection personnel onuals e l the .{projec,t To the writer's knowledge ;
3.
H. Williams are no longer, J. Deshanbo, E 1 on the project . site Houser, C. Owen and As indicated in the subject that as of Octobs: 31, 1983 problema ' preliminary assessment by J in areas of material stortrip report, uben the write t '
e painter qualification and l d ments . J. Lipinsky,'that Comanche Peak ha possible coatingaintegrit age..wcrkmanship octrination). not satisf (quality of s a dand
,nnt ob or concern". The items y', he tk. Tolson)ying
- work and opinion, withof coating integrity'Tand th t with ANS1, require-a indicate'd, replied '"Thet 's "That is not his job orquality reisted matters and the Ris possibie debatabic) exceptiondea to believe t bst conrrn". . Tolson, er least id the writer cerned with quality.1:. Tolson was indicatirc thTherciore, the writer statewoul 4
C. Brandt at he (R. Tolson) w. e inclined advised as not con-
' Car.non employct them (C. s (insBrandtand R. Toison mentioned 7 5
and R. Tolson. ftiller specifically when the that wi pectors) were or)areapproximately employed nine o former r ter The writer was referring t n the projcet'.
6.
7 See item 28 abrve. ' o issues raised in iteme.2 abov In t he writer's opinion at result the aceting of July 28and ,
1983apparently in the opinio n luspectorsof this a get and foremen together together.was(see planned page 2) this was the situatiof tho on. As -
based on follow-up conversati However,this to bring was the Quality Control ons with the site pe rs' c.ane later~canec11ed, t
i .
, To: R. R. Roth .
Ke: Texas Util.itics services -
October 28, 15
. Letter dated 10/27/83 Page 3
- 8. Apparently, the air compressors or air supply lines were not providii clean (water and oil f ree) af r, and up to half the shif t, approximac i five hours, was utilized to make the air quality acceptable.
1 l
- 9. Zimmer has probicma related to coatinge se a result of placing more cephasis on production then they (Zimmer) did on quality. It is the
+
writer's opinion that this appears 'o be a hang-up at Comanche Peak.
' 10. The writer based this statement on conversations with inspection ste; in what appeared to be poor instructions in the procedurer (though t -
writer cannot rceall specifics), coupled with the number of changes the specifications (nost of which catered toward ' relieving requirenc i on areas or items where requirements could not,be satisfied.
- The implications of the writer's statement is that somewhere down' tt ;
road, another set of eyes any or may not concur with ny assessacnt.
- 11. See Item 2 above. 1
- 12. As a result of the teetings at tended by the writer, the site managen pecple (R. Tolson) declined the of fer of Cannon to perform an in-dep .
audit raised.that would have either confirmed or satisfied the concerns I !
- 13. The writer based this on conversstions with site inspection personne -
t and the apparently disintercsted attitude of R. Tolson, when advised of potential coating quality problems.
- 14. See Trem 2F above.
15.
The writer is unable to recall the names of inspeerion personnel enc uhile in the field. However, two of the topics frequently discussed the quality of work and where employment possibilit'ies may currently
- 16. There is an honest internal disagreement in the manner in which ANSI quirements impact the cost of a project and the quality of the work.
- 17. See 1 ten 12 above.
- 18. The writer based this observation on previous work experience, and suggests that the coating manufacturer be contacted to confirm same.
Note: Power gEinding on isolated areas of one square foot or less abould not be a problem. .
- 19. Again, the writer based this observation on previous work experience and suSEcsts that the coating manufacturer be contacted. However, o l'henolinc $305 (one year or acre, with veld fume accumulation) may n '
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'Re: Texas Utilities Services October 28, 198.
Letter dated 10/27/63 Page 4
- 19. - continued be adequately cleaned and provide sufficient intercoat adhesion by solvent wiping.
- 20. The writer's spcciality is Quality Assurance / Quality Control, as,the.!
terms deal with coatings and the writer's offer of an in-depth audit ,
(in order to confirm or allay quality concerns) was repeatedly rejce Also see Items 3 and 12. *
- 21. Based on the writer's observations on site.and my past Nuclear' site experience, the work observed in place appears que'stionable with reg to quality. (Again, an in-depth audit / review may resolve this issuc Also, any attempt by Cannon or any quell.fied professional applicat.:r gsalvage "in place work", may not be practical or realistic. Certain isolated areas mey prove acceptable and pc rhaps complete roorns niay b.
okay. However, realistically and from a cost /cifcetive viewpoint.
" rework" is more logical considering production effort and the atten' docua.entation. .
- 22. Gee Iten 21 above.
Additionally, the retrofit program tr.sy well resolve the writer 's con, but I have not reviewed the adequacy or results of the ret rofit prog' Realir.ing that the writer is not.familier with the results of the re "
program I cannot conswent one way or the other on the acceptability i retrofit program.
The writer distributed the trip report to R.
- 23. B. koth and J. J. Norri or around August 8, 1983.
- 24. .The writer did discuss the subject matter ir my trip ' report with P..I Field Coatinge Quality Control Supervisor. on. subsequent trips to th '
project site.
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. l C A S E (CITIZENS ASSN. FOR SOUND ENERGY)
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214/9h6-9hk6
- l August 14, 1984 Ceary S. Mizuno, Esq.
Office of Executive legal Director U. S. Nuclear Regulstory Coc:missico Maryland National Bank Bldg. - Room 10105 .
7735 Old Georgetown Road Bethesda, Maryland 20814 ,
Dear Geary:
Subject:
In the Matter of Texas Utilities Electric Co., et al.
Comanche Peak Steam Electric Station, Units 1 and 2 Docket Nos. 50-445 and 50-446 Infornation Fronised ' oy CASE Regarding Applicants' Motion for Summary Disposition Regarding Gans You will recall that during the 6/6/84 Applicants / Staff / CASE telephone conference call, you had asked us to supply you with infors tion when we could about any instances of which CASE was aware where a pipe support which had been classified as class two was reclassified as class one. (See 6/6/84 conference call Tr. 88-91; see also discussion on paigD, Item 10, of attachment to CASE's 8/13/84 letter. to William A. Horin,
Subject:
Open Discovery Items for Motions for Summary Disposition.)
Now that we have been allowed to present the ANI documents to the Board, we are able to supply you with that information. This was the instance when CASE asked "When a pipe support that was classified as class two is reclassified as class one, is its stiffness also considered?" Applicants stated that they were not aware of any such reclassifications. However, is discussed in our 8/13/84 letter to Bill Horin, Applicants, LT.cluding their attorneys, have been aware of this information at least since our'6/30/84 letter, under subject of Documents Obtained by CASE in Rate Hearings'Which Are Also Relevant and Material for Operating License Hearings, and our 6/30/84 Request to Applicants for Admissions, to which were attached a summary of each ANI document as well as a copy of each such document.
e information is contained i -
(see attachment to CA .- ons negar ing .
Documents . As discussed therein, the ANI identified several instances where NCR's were written to upgrade supports from Class 2 to Class 1. It appears from the ANI document that the specific items identified were struts for supports (it is not clear from the document whether or not these were for pipe supports), and this is what led to our question.
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It slse appears that the only concern which was addressed was regarding preferation and dispositioning of NCR's and that neither the ANI nor the Applicact.s addrctssed whether or not the stiffness was also considered when the supports are upgraded. As stated previously, it is not clear from the kNI document tdtether or n'ot these are pipe supports. However, we believe that i:hls is still a question which needs to be addressed.
Sincerely, CASE (Citizens Association for Sound Energy)
)AA ^' A rs.) Juanita Ellis President ec: Bervice List 4
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