ML20205Q738

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Partially Withheld Transcript of 841107 Technical Interview in Fort Worth,Tx.Pp 1-90
ML20205Q738
Person / Time
Site: Comanche Peak, 05000000
Issue date: 11/07/1984
From:
NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
To:
Shared Package
ML20204J134 List:
References
FOIA-85-59 NUDOCS 8606030044
Download: ML20205Q738 (92)


Text

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25 Taken by: Carmen Gooden, CSR, RPR November 7,1984 [ 4 1

1 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i 2 TECHNICAL REVIEW TEAM

            . .. 3 . . . .                                                                            l 4                                                .

5 TECHNICAL INTERVIEW l i k ' .- 6 . Wednesday, November 7, 1984 Fort Worth, Texas I 7 l s This interview was commenced at 4:00 p.m.  ! 9 i-PRESENT: l i. 10 MR. JOHN J. ZUDANS  ! Technical Review Team Staff 33 Nuclear Regulatory Commission l 12

                                  -Washington, D. C. 20555 13 MR. VINCE NOONAN                                                       ;

I- Technical Review Team Staff Nuclear Regulatory Commission 34 - Washington, D. C. 20555 15 ( MS. ANNETTE VIETTI g l Technical Review Team Staff g l Nuclear Regulatory Commission

                           '      washington, D. C. 20555
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        .                         MR. ROBERT PHILLEO                                          '

15 l Technical Review Team Staff Nuclear Regulatory Commission

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 . . ,                            MR. LAWRENCE SHAO Technical Review Team Staff j        21               Nuclear Regulatory Commission                         , , ,              ,

Washington, D. C. 20555 - - MR. JOSE CALVO I 23 Technical Review Team Staff l Nuclear Regulatory Commission j 24 Washington, D. C. 20555 25 l

                                                                                                  * ^ * " ' * * *

(- t 2 1 PRESENT: (Continued) 2 MR. RICHARD KEIMIG Technical Review " car Ctaff 3 Nuclear Regulatory Commission - Washington, D. C. 20555 ,

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3 i PROCEEDINGS 2 MR. NOONAN: We're here today to talk

                     .. 3                      to talk about the allegations at Comanche Peak.

4 For the record my name is Vince Noonan, and I'm also the i 5 Project Director for Comanche Peak: What we'll do here ' (' 6 today is basically try to address as many concerns as we 1 7 can talk about, and those we can't talk about we'll take t 8 back and see if we can get the proper answers for you.  : 9 i. What I'd basically like to do is' to get Larry Shao, who ' 10 is the Group Leader for the civil and mechanical areas, talk '

                                                                                                          )

a 11 basically about the civil stuf f. With that, Larry, do you , l 12 want to start? j l . 13 MR. SHAO: My name is Larry Shao. I'm the Deputy l l 14 Director, Divisicn of Engineering Technology, NRC, assigned-s 15 to Comanche Peak as a Civil / Structural and Mechanical /Fiping , 16 Group Leader.  ! i l l l 1; Altogether, in the civil area we have about 47 alle-i

                 .i*    IS      gations' and in the mechanical area we have 150 allegations, l
                 ;                                                                                        l
           ,            19      so altogether in the civil / mechanical area we have about 200             '
                 't j      20      allegations we're working on.        These allegations are related
       ,                                                                                                  l l
                 ?
                 '      21      to design, construction, testing and inspection of civil 22      structures and mechanical components.                                 '

l 23 When I was given the job, I tried to get experts on this , 24 team. The experts are in the piping area, component support ' 25 area, civil structure area, and the concrete area. One of i l

i I 4 1 ! my experts here is Bob Philleo.

                                                  ~

Bob is going to just talk 2 about construction. By way of a little background on Dob 3 Philleo, Bob used to be the Chief of Structures in the U. S.  ; 4 Corps of Engineers for about 40 years in charge of construc-( . 5 tion of mass structure in the United States. He was past

     ~~

6 president of the American Concrete Institute, and also past t 7 president of ASTM. J . S MR. PHILLEO: I was a director. 9 MR. SHAO: He was the director of ASTM, and he has 10 written many books related--as a matter of fact, one of the i-11 handbooks you cited is one he co-authored, so he can address 12 some of the concerns you have in the three areas you had. ,

             ,     13    One is on the concrete base mat cracking, one is on the con- i                      !

1 {' 14 crete cement tests and concrete strengths, and the other one 15 l also addresses the control of the designs. These three areas 16 we're going to address in more detail today. ' l l 17 Altogether, in my team we have about 17 people, six 1 l 18 working on the civil structure and 11 working on the mechani-19 cal piping, and they're all supposed to be experts in their ) 1 I { i 20 areas.  ! 4 - l

               ?   21           There's a letter you wrote to Ippolito about a month                          ,
               '                                                                     .--                     {

22 ago relating to concrete strength. Bob, why'do'n't you address 23 that letter, what your findings were, and maybe try to ' \ {

                                                                                                !             l 24 explain a little bit in general.        Bob was involved in the        i t

25 development of the concrete codes also, so he knows the l

s l E I background behind these codes. ) 2 MR. PHILLEO: The letter apparently was triggered by n

                                                                                                                               ~        ?

I I 3 some concerns on the Richmond anchors, but it got into the ) i l, 4 general discussion of concrete strengths, per se, and winter l N 5 protection. It was pointed out--Attachment D to that letter ' l 6 has all the meat--that there were 18--or 36 cylinders, just l \ 7 the standard moist-cured cylinders that are used for accept-i 8 ance of the concrete which failed to make the strength of l 4000 pounds per square inch which, in g eneral, was the design' { 9 l l I 10 strength for the project. I ij We went through and checked all the mixed designs and l l l 12 found without exception all those cylinders that f ailed to l I

         .              13   make 4000 were for a 2500 PSI mixed design.                                                So we have found l                        14   no place in our investigations where any of the standard t

15 cylinders on which acceptance of the concrete is based fell l 16 l below the design strength. There were, in fact, 36 of i I l these below 4000, but for those 2500 was the design strength. 37 t i 15 MR. SHAO: There are certain concrete differences;

           ;            19   for instance, only 2500 PSI.                                           These are concrete mainly i
           !            20   used for over-excavaticas where they've over-excavated the                                                    ,

i r ek and then tried to fill it up. These are not really l l' 21 k; . . . structure concrete. They are mainly filling concrete. 22 23 s was one of t.he % gs. We didn't know and couldn't tell-- 24 . i MR. SHAO: I

                        'S
                        '                                      I think Bob did quite a deep investigation                                  -

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l l 6 I and found out that most of the cylinders that were centioned l 2 ~ l' that failed-- l 3 MR. PHILLEO: I have a copy of Attachment D with all l 4 the. mixed designs indicated for every cylinder that was cited 5 there,9so if anybody wants to go into any degree of detail, -l l \ . 6 we can do that. As a broad-brush statement, none of the 7 cylinders cited in Attachment D and none in any of the work 8 that I have done failed to meet the design strengths. [ There 9 may be some because I did not look at all the cylinder i 10 strengths, but all those that were associated with allega- { i 11 tions plus a bunch that we picked at random where the alle- L 12 gations were not specific, we never found any where the . i

              ,   13       standard cured cylinders failed to meet the design strength,i l

14 MR. NOONAN: How many did you look at? i 15 MR. PHILLEO: We looked at three or four thousand, I , 2 16 guess. I'd have to go back and add them up. We looked at a ! i* j 1; bunch of them. - i j IS Now, the second half is how they deal with field-cured

                ;          cylinders.

19 There, there were quite a few field-cured

i
      ,         j 20       cylinders that did not meet the requirements.                It should i
        ..a                                                                                                        !              f j 21       be noted, however, that there is not a rigid requirement for l                                         l l                                                                            ..

j  ! 22 acceptance of concrete based on field-cured cylinders, but .

                                                                                                                .I 23       the job specification says--and what the ACI, American                                 '
                                                                                                                ~l 24       Concrete Institute, code that it's based on says--that if the 25       field-cured cylinders f ail to meet 85 percent of the l                                                        .

l 1

                                                            . . ~ . . ~ . ..

7 I I laboratory-cured cylinders at 28 days, the contractor shall t 2 improve the protection. So it doesn't reject the concrete: 3 it merely rejects the centractor's protection devices and l 4 requires that he improve them. However, it might also be I 5 pointed out that the requirements for the field-cured i f I

                         +                   6   cylinders that were invoked on this job were those for 7   structural concrete out of the ACI building code, and there 8   is indeed some--a fair amount of concrete in the plant for                         .

1 9 which that is a legitimate requirement. Anyplace where you l l l 10 have suspended concrete slabs and beams, that is the correct l 11 requirement to use because you want the strength to be 12 attained fairly early, because when you strip, the thing has I

                   ,                        13   no support under it and you want to be sure you have the                           ;

14 s treng th. 15 Is that the 4000 PSI? 16 MR. PHILLEO: Well, it's the requirement--85 percent of l i t- , the standard cure. The standard cure usually ran over 5000; l I 15 however, if it fails to meet that, it should exceed th'e 4000

                     ;                           ay 500 PSI.

19 I

                     !                      20          Now, it's also true in the ACI standard for cold weather
                '-:  .                            concreting that for concrete that doesn't have the support j

21 itself, like a slab and a beam, there are much more 'ienient 2, i 23 requirements which apply. And much of the concrete in the 24 plant would meet the categories that they define as the ,

                       ~

t 25 concrete not having support itself. They did not choose to , I . _ _ _ _ _ _ _____. __ _ _ _ _ _ . . f

8 1 invoke those more lenient requirements on the jcb. I can't I l 2 really criticize the engineer for doing that because it makes 4 3 the job complicated if he got two sets of requirements to .

                                                                                       !  1 4    adhere to, and the inspectors always have a big row of which              I
                                                                                          \

5 one applies. So they wrote the more stringent requirements I 6 into the specification. -SuMdBYfGIIf04'Orsd3cy;l;indegs _ __ _: mew 7 das & y Q Q g , p g g y,e3 _ 8 vee 8fidWENstTfl"fsM6C IFUfestpb=17.icati6h7 That is , because 9 they were low, the contractor should have been required to 10 improve the protection. Whether he did or not, I don't know. i 11 That's largely a matter for the Quality Control-Quality , I 1 12 Assurance people to wrestle with. The thing I was concerned ; j 13 with from the standpoint of safety of the project is to see  ! 14 whether those failures were in the suspended structural 15 concrete or in the more massive concrete for which the more 16 lenient requirements could have been applied. out of the 108 l l 17 there were only three that were in slabs or beams, and of i IS those three, two just barely failed to make the 4000; they 1 19 were right around 3900. One was down about 3500, so that i

        $ 20    was one for which there was some legitimate concern.         That
        } 21    was d'ealt with at some length on the job and was ultimately i                                                                  -

22 disposed of by making Schmidt rebound bammar tests on the 23 questionable concrete and comparing it with sound concrete, I l l 24 and it was found to be satisfactory.  ! t i 25 S the other 105 were in the more massive concrete that

                                                   *    .-     ..       .-         +

E-- - U l l 9 1 is not a suspended structure for which they could have, if I. 2 they had wanted to complicate the job, they could legitimately 3 have used more lenient requirements, in which case there  ; I 4 would have been no concern for those. 8 hS ECY5Tcor3c3d,e g 5 3tetLO:'.R.7mrEWaT4@f a1-lWreltoLmeFetStheYfeWFdrishfEiii2.t!1e

       \

6 g ut for a 105 out of 108 the specifications could have 7 been more lenient and there's no problem with safety. 8 But it was a procedural failure-- 9 MR. SHAO: It was a f1*S1Yt!T8MYrl. 10 MR. PHILLEO: It's 3t3QAg % t,tep p ot a safety. l g} MR. NOONAN: One thing that I'm tryinc to do in all of I f l 12 this is: We go through and we look at the technical reasons Now, we I 13 why it's either okay or not okay; we will do that. 14 might say that it's okay because we've done some tests or f l 15 l whatever, but we are going to try to identify--we'll call it 16 root causes--why it happened in the first place, and then i i i

              ;-        we'll turn that over to the proper group of people te look i   15 at.
                                                                                                 ]

l

           ;   19              MR. SHAO:  Also, we are looking at two things.      We're         j i                                                                                     l
           !  20         looking at certain FSAR specifications and procedures.       If 5             they violated this, we look at it further.      So the violation,

, 21 1 i .- 22 we can cite them, but safety impact you really'have to fix 23 them. You have to maybe modify or do something, so when we can see a potential they are violating and they are safety g ] 25 impact, we can--

10 Il MR. NOONAN: You could also have a violation with no - i 1 i 2 safety impact.  ! i 3 MR. SliAO : In that case we just cite them. l 4 MR. NOONAN: In your SER do you explain-- 5 MR. S*dAO : In SER we would differentiate them. There's i 6 a violation and a violation in safety impact. 7 MR. PHILLEO: Now, this letter thing leads naturally S into the third major point made in your letter, having to 9 do with the validity of the Schmidt rebound hammer for the  !' 10 application in which it was used. One of the interesting f t gg things--we'll probably discuss this in more detail with Mr. - I 12 Walsh--in saying it was not valid, he used one of my bcoks , 13 as a reason for citing it. i j4 Let me make one comment there. On the p. 15 Richmond insert answer, we were under severe time restraints 16 l to get it in. In fact, we were doing so under heavy protests i I to get it in. I don't know if you noticed in the letters

    .i  ;-

i I' i i: 15 ' that were sent, it took four mailings to get all the ~ attach

      ;        ments to the Board.      But during that time, I think that 39 20             ried to make clear in there that he hadn't had much l
     ]         time to really icok at this, and what he did look at bothered 21                                                                                           {

g him. That was basically what he was trying to say.~~He did , n t have time to thoroughly research ANI or ANSI or anything 23 l , else that might app-7 to ASTM. He didn' t have tirce to really j t J l look at it thoroughly. l 2a. 1

                                                                                                     \
                                                                                                     \

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11 I

                                ]              MR. PHILLEO:                He was correct in citing references that l

the Schmidt hammer should not be used as a substitute for

                                                                                                                                 ~

2 l 3 normal compression tests for accepting concrete. I am very

                                                                          . _ . . . . . . . . _                                  l 4     adament about that point, that we not throw out the moist-5     cured cylinders in the. laboratory which are the basic accept :

( ' 6 ance medium for concrete and subbtitute the rebound hammer; 7 but it is a very handy device for comparing concrete. That's 8 about all you can do. The manufacturer puts a calibration ' 9 ; curve right on the side of the instrument, and I wish he 10 would take them off because it leads to more trouble than f' gi iti's worth to the people that get a rebound number and lock f 12 on the side of the instrument and convert .it to compressive t 13 strength. It takes a great deal of carefully controlled l 14 laboratory work to get a calibration curve for a given set c.f La ' 33 l materials, but it is a good device for comparing two con-16 l cretes; so if you have a concrete that you're completely ' i I t i g- satisfied with, that is not in question, then you make a l. ig family of tests on that concrete, and then you 're in a *

                          ;           position to take concrete that is in question and if it's of 19 i
                          !    20     approximately the same age and moisture condition, you can
                       - g                                                                   <                                    i l
                          ;    g      test that.             If the questionable corcrete gives as high numbers                     '

i' .. 22 as the concrete you're confident in, then you have a reason-l 23 able basis for saying that the questionable concrete is no g longer in question. 25 MR. SHAO: I think is right when he says that l

12 i 1 if not used properly, the Schmidt harner test, that some of

                                             .                                                 I 2 -   the people just like Bob say just use a calibration curve and I

3 convert to the actual nurber. You can't do that. If you do I 4 it right, compare with same age and same roisture and then 5 compare with good concrete, something comparable you know the t 6 strength and you compare it, that could be very useful, too.

                                                                                          ~

7 This is one of the things I think that has concerned us a lot is that on DimteningsthaMsom@Deflije S 9 you be there and see what-the-Sam-Hill they dobathersth3n /

                                                                                                     /

10 hthWsiEeTeFp1846W1%keWatWCEo'NtTaWft). J

                                                                                                   /

11 MR. PHILLEO: There were some cases involving possible 12 freezing of concrete during cold weather where they used it 13 and only reported the nurbers, and that's fine; that's the way 14 it should be done. In some of the work cited in Attachment. t 15 D they were converting the compressive strength. I much 16 Prefer the first procedure, and all they report is the raw i I l i 17 data. Then you have a good basis for comparison without

                                                                                                        )

i 15 worrying about calibration figures that are probably incorrect.

       ;                      I think that's all I need to say about the general 19                                                                                     ,

i

 .     !         20     strength issue that was raised in your letter with the
       .                      .-                                                                t f         21     attachment deal, although we're willing to pursue it to what-i                                                                                                '

22 ever length you wish to pursue it. i 23 No, I think we can go into more detail when gets here. 24 25 MR. SHAO: The second issue is the concrete base mat. l upm e e e

1 ! 13 1 MR. PHILLEO: Okay. This is the cracks down at the l I 2 ; bottom in Unit One. 'There was a great big massive donut-shape 3 pour, and there are, in fact, cracks across the narrow part j 4 .of the donut just as the alleger said, and one would expect 5 to get them. Concrete always reduces in volume as it dries  ; a 6 out, and that's something you've always got to worry about. 7 That's why they put joints 'lilun that in concrete walls to get S the cracks in a groove where they can't be seen. That's 9 always a design problem to work around the fact that concrete 10 shrinks when it dries and massive placements also shrink l

                                                                                                                                                                 )

I 11 because of thermal contraction. They heat up when the cement - l l 12 dehydrates. 13 This placement was designed to go in two pieces where , 34 the construction joined across the middle. I think that wculd i have been the proper way to do it. Somewhere along the line, 15 16 by the time they got into construction, the contractor was i j  ;- given the option of doing it in two pieces or in one: and he I is chose the option to do it in one, which I guess nest con-g i

        ;             tractors would do.             It's a little cheaper to do it that way.

19 I So he did it in one. As I said, there was a rigid form on

  -     !    20 4                                                                                                                                                  .
        ;              the inside of the donuts; so when the concrete shrank the                                                                                 ]

21 cra k's right where the construction joints would have been. 22 i Essentially there is the same condition there as if they'd ) 23 ' done it in two, except if they'd done it in two pieces , 24 there would be a ni.cc straight joint across there. Instead,I 25 l

14 1 I there 's a jagged crack along there. Structurally the thing

                                             -                                             l 2        behaves the same.

3 We can go into a lot of structural discussion to shew l 4 that it's not particularly significant. One of the cracks 5 comes across a very thick beam where all reinforced bears i 6 have to crack. The only way the steel can take up the 7 tension is for the. concrete to crack. They're designed that 8 way. Usually we distribute the steel so we get a lot of very 9 fine cracks, but the total length of cracks, the total width' 10 of cracks, is going to be the same whether there's a pre-11 existing crack or not. Drobably the mostrcompelling answer 12 to this is that the critical design condition in there is 13 for a postulated accident inside .the containment where the , i 14 whole thing is subjected to internal pressure. So the steel { 15 !i in there is designed to take that accident condition, and 16 l when that happens all the steel goes into tension and the

         '         l
         '., 17 concrete cracks in so many places, the concrete just doesn't gg       figure at all in that most-severe condition; so the exfstence
     !   ;   gg        of a crack in that part of the containment is immaterial as i
         !   20         far as the most severe leading condition in that containment ,

i k l 21 9 88* Essentially, the thing--just the way it's~ designed, only 22 instead of having a nice, neat joint across there, there's 23 a jagged joint which has been repaired so that there--on top,. 24

   ~                                                                                           I 25        andthathasnostructuralsignificance;butit'sessentiallyl

15 1l in the design condition the way it sits there.  ! l 2 MR. NOONAli: Let me ask a question. The contractor was 3 allowed to pour the concrete in one piece? 4 MR. PHILLEO: Yes. 5 . MR. NOONAN: Is that a violation of procedures to do 6 that? 7 MR. PHILLEO: I doubt if you can cite it. It's just 8 merely a change in the design concept. The designers had 9 considered that as being done in two pieces. For that very l 10 reason I doubt that there's a piece of paper anywhere that gy says it must be done in two pieces. That was just the design 12 concept. I can't say for sure; I haven't searched every

 . 13    piece of paper that might be relevant.                                     ,

j4 MR. SHAO: For this particular allegation we tried to close out the original alleger. That was last week, and he 15 l 16 l was happy with our findings. He had no problem with that i I findinc. I don't know whether you know the name of the i ;- i 16 alleger or not, but we did close out with him last week. 19 The original alleger: I'm not sure if I f 'O know who the original alleger was.

   .               ....                                                                l NR. SHAO:       I have the name, but we can't say it.             -

21

                ,'f1R. NOONAN:         I would prefer not to say it, and ': hake sure we keep the confidentiality.             We met with him last        I 23 week and Dick Wessman from my staff was down here.

I MR. SHAO: On the phone. 2a. i

16 1 l 1 . MR. NOONAN: On the phone? Excuse me, this was one he l 2! did on the phone. If you need it, I'll ask Dick if that's 3 l 3 one of the CASE people. 4 Yes; all right. 5 MR. SHAO: The third issue is -the control room ceiling. ! 6  ; think the original alleger is I think hic 7 criginal allegation said that the fueling conduit, the dry-i S wall and the piping going in the area above the ceiling panel 9 in the control room are classified as n'on-cite and are  ! 10 supported only by wires tnd that these are either made for 11 or are the result of seismic event. This allegation was l l g2 i criginally attacked by Mr. Jose. He looked into it. He also 1 13 found some allegations is valid. He then turned it to my l 14 group and also I found it as valid. We even expanded the 15 investigation a little bit and went beyond what he said. We looked at the whole control room ceiling.  ! 16 i l i i g7 I don ' t know whether you're f amiliar with the regulation, I g 33 Regulation 129. There is Seismic Category One and non'-Scismic

   ;  19    Category One. gamic Category One is non-safety function. f ,.
   !  20    You,have to design.      The design should be in such a way it            I' i

j cannot fail. l 21 The nc.1-Category One can't fail, but our 22 regulation say when it f ail that there must be "done in such 23 a way that failure would not adversely affect the safety , g function of the safety-related components. j J l l 25 So in Comanche Peak for non-Seismic Category One, they ) l

  • j l

J

1 l_1_ l i . I - do a so-called Damage Interaction Study. When they do a

                                                                                                                  ~   l l

h 2 Damage S.udy, they look at physical geometry, do some analyses. 3 Then they reclassify the non-Scismic Category into two, one 4 called Ca'tegory Two and one non-Scismic. Non-Seismic is when I 5 it -fails, supposedly the geometry of the layout in such a way I 6 it will not affect the safety of the component; but Category i 7 Two are close to safety-related components so they have to i S perform in such a measure that Category Two cannot f ail. 9 So in the Control Room ceiling there are heating,. 10 ventilating and air conditioning. They were classified as I 11 Seismic Category one. We have no problem with that. 12 The safety-related conduits that are classified as Seismic 13 Category One we have no problem with, but there are non-  ! 14 safety conduits and lighting fixtures which they were . 15 classified as Seismic Category Two, and they're supposed to i 16 provide an analysis to show these seismic Category Two i l

             ^

l 17 components in such a way that failure would not affect the g g3 component; but they do not have very good analysis.- We'are

     ;             not happy with the analysis.

19 Instead of doing a good dynamic I  ; I 20 analysis, they do a lot of clone study analyses and then take

     ;                  y  ~
                                                  ~..                                     .

l' j 21 interaction effect into account. So we point out to them l . l 22 and they agree with our finding. I y3

       .                  Also, there are non-Seismic items such as sloping sus-l 24          pended drywall ceiling, acoustical ceiling and louvered                                   !

25 ceiling. They should be designed in such a way that their

                ==
                                                                                        =

18 1 I failure would not cause--adversely affect the function of i I safety or cause inju'y r to operators. We found out they 2.l - 3 didn't do a good job in this area either. So we wanted them l 4 to provide either analysis or modify their ceiling in such a 5 way they meet Regulation 129, and they are committed to do . 6 that. But because of this problem, we are looking at s 7 area. I say that we see this problem with 'the Control Room; 1 8 what about the rest of the plant? Is it possible the same 9 kind of problem occurs somewhere else in the plant? They i 10 submit a program plan--that was October the 18th--I was not 11 happy with ?.he program plan. They addressed concurrency , i 12 quite well, but they did not address the generic issue I 13 was asking for so I'm still waiting for that. l 14 MR. NOONAN: Where did you make the money in case your-- I 15 MR. SHAO: They were going to try to rip out some of 16 the d.m.ywalls. i i . g- MR. N00NA:;: The last time I went down there, out there l j 15 to the site, they had a lot of construction. They were*

         ;   19    taking out most of the ceiling and putting in aircraft 20    wiring and so forth.                         Are we going to go back and look at                   I
         ~
c. ...

21 that? f 22 MR. SHAO: This whole thing is--as I said; the first l 1 23 part, I'm not happy with that plan in this area. I'm not g happy with that Category Two analysis and also the generic 4 25 attachment. J l

                                                                                                                           \

19 j Cne of the things that concerns us is that 2 whenever they have to redo something like this, it seems likel 3 they always have a tendency to go out and either contract to

      ,;    have it done or start doing it themselves and just go ahead 5    and do it before the MRC even has a chance to look over what '

6 they're planning to do. 7 MR. SHAO: That would cost them money if they start to 8 do it and we tell them we don't agree. That's their probler. 9 If they're start enough, they talk to us first. 10 MR. NOONAN: 'They are in the process of redoing it. , i 3g When I was there, I was looking at it and I did talk tc them i n there. They've got the ceiling out.  ; 13 MR. SHAO: Yeah. I told them don't use judgment so they! I 14 say this thing fall down it wcn't hurt the people. It , i 15 j doesn't tap,e a lot to hurt people's eyes or nose and people 16 can't function, so ycu better modify the structure, rather  ! i l . g ;- than try to prove it. You see, their original judgcent is I ' i 15 I something very light can fall down, hit scccLedy en ti:e head 39 or eyes. I think-I said don' t do that to us because ncbody

   ! 20    can be sure about five rounds, ten pounds falling down; it              I
   .              "                                                                 l 21 may hurt somebody.                                                        .

MR. HOONAN: It seetts to me we ought to go' bdck to the g ite and check to see what they're doing. i g l MR. SHAO: Okay. i j 23 M That's one of th things that. bothers us. l .

                                                                                       ~

_-_. ~_ - 20 I of course, we have another concern which goes into the cost 1 l 2 aspect of this as well. In addition, I think it puts an i 3 additional unnecessary burden on the NRC tecause once they're, 4 started doing something and have already dcne some work on 5 it, it puts a pressure there .for them to go ahead and finish ! 6 doing it, 7 MR. SHAO Maybe you can bring it up to management, i 8 Vince. 9 MR. NOONAN: I will. I 10 MR. HUNNICUTT: Specifically, Un' t One will be held up i' , j; until they finish the main-- l 12 MR. NOONAN: Maybe you better, at this point in tire, 13 identify yourself. l 1 i g.g MR. HUMNICUTT2 I'm sorry. I'm Doyle Hunnicutt, Region , 0  ! 15 Four. l l MR. EANGA RT; I'm Dick Bangart, Region Four. i 16 I l ' g-MR. NOONAN: Dick is cne of the directors here for the l

  • l 16 miscellaneous areas on the TRT Teat.

1 j 39 1 recognit:c the name. s

                                         *MR. SHAO:                                I think that's all the issues I have today.                    i 20 4

u Th re is one issue on the heating and ventilating support. t 21

     !*                                                                                                                          "~

Dick, that's your area, right? 22 MR. NOONAN: We can go to that. Maybe at this point 23 ,

                  !                                                                                                                               i la tina--I'd like to ask you if there are other thinga that l

we need f_O know about? em. c o- ,

21 j There's a lot of stuff here. I think it

                                        .                                                               i 2           would probably be easier for me for y'all to go ahead and 3

for me t just start going through my stack. , a 4 MR. NOONAN: Maybe I'll have Dick start on the heating 5 and ventilating system. 6 MR. BANGART: The concern I was writing in regard to, 7 the HVAC-Supports was assigned to the Miscellaneous Team to 8 follow up on. There is a relatively extensive inspection 9 history related to the issue of the box and work done at the 10 cite and a lot of work that was done by the Utility themselves { I g3 in response to the concerns that were raised. We had two 12 people involved in the detail look at that issue. Mr. 13 Hunnicutt was one. Mr. Lee Ellershaw is a Reactor Inspector i 34 in our Region, but he was also previously an inspectcr in the la.

          , Vendor Program Eranch, so he has been involved in inspecting 1

16 IIVAC vendors for whoever is supplying the components. Mr. g ,_ Ellershaw is not available today so Mr. Hunnicutt is going to g summarize the details cf the investigation that we underteck.

 ;   39 MR. HUNNICUTT:      This allegation was where they had been s
 !  20 alleging that the HVAC had not been analyzed for seismic                                   '

s .  : loads and stated that all HVAC components and supports l

 }                                                                                                              )

s inside the containment were not properly considered in regard i to the treatment of missiles. In other words, some other 23 j movable object could penetrate through the HVAC. And that the 24 HVAC failure during the postulated accident would allow the 25 l. 9

                                                                                                               )

22 1 temperatures to rise to an unacceptable level inside the , 2 containment. We had previously inspected this on Report No, 3 445/831S and again on 6324 where we identified the violation 4 pertaining to the fabrication, installation and inspection 5 of the }NAC system components, i 6 i The licensee responded with corrective action and ' to other identified violations on June 28th of '83. This i 8 response also addressed analysis of the identified worst-9 l care conditicns being performed b Corporate Consulting and 10 Development Company, which had been the HVAC suppcrt design 3g enginecr. I g; During our other inspections we sampled the EVAC ducts 13 end supports in the Unit Cne cable shredding room and the  ; y Unit one containment air circulction and cooling system. The g NRC craff ebserved certain dimensional and welding discrepan.cies g l simi'.ar to those that we had previously identified in the two i j g- reports because nearly all the fabrication and installatien i 15 had been perferreed by bondsc.en p for to the identification

          ;  39          of the first vi.olation.          It appeared that the discrepancies 20 cWened by the NRC staff were very similar*-no worse, in ft g           cther wcrds--to those that hhd origf.nally been identified.
                                                                                             ~

We requested that TUC submit a discrapancy evaluation by 2 g their centractor, which was again related to Corporate Censulting and Develcpt.ent Company. We will es11 that CCL g in the future. e

} l 23 I I So our staff again made an inspection that included the j

                                                          ~
                                                                                                                    !         (

2 CCL report and according to the CCL, we found that all the . 3 pertinent HVAC supports were analyzed for seismic icading. . 4 The' NRC staf f also reviewed the CCL report entitled " Seismic i l 5 Qualification Report of Seismic Category one Duct Work and l 1

         -        6             Hangers for Comanche Peak Steam Electric Station."                       This s                                                                                ;

7 report is identified by CCL as llo. A-424-81-06. The latest 8 revision listed here is June 1, 1983. That's Revision Nc. 9 6. This CCL rcport included the engineering work sheets, 10 hanger data sheets and computer printcuts that referenced 1 11 and indicated the inputs and the analyses used to maie their l l 12 calculations. The NRC staf f also determined that the CCL-engineered j 13 i ja hangers were analyzed using two different methods. One is 15 the well-known hanger-based cede called Stardyne, S-t-a-r-d-16 y-n-e; and the hanger-based analysis censisted of two codes-  ! I i l i g- . hanger which is used to qualify your single duct transfers y n hangers using your finite element models and the FIASA, a

             ;     39 much mere complicated analysis technique, which can accom .odate multi-duct transfers and axial hangers.

( 20 ,

              .                        ..                                                                                 l j                           I 11 be happy to go into the Stardyne if anyone is 21 i

interested; otherwise, I'll just quickly say that it is 22 , 23 a program that can be used for complex arrays of multi-duct 24 hangers and for thermal expansion analyscs of duct systems l 25 simulating a load. . l

                *           *~+              ..                            ~ . .                    .

24 1 The CCL report--paper is not important, but there are 2 48 volumes of it; in other words, you have to do quite a bit , 3 of work to get through it--presents a seismic qualification l 4 documentation for all the Bahnson Company Seismic category 5 One +:VAC ducts and hange'rs installed at Comanche Peak. The 6 NRC staff determined from the CCL data that the EVAC ducts 7 and' hangers are structurally accurate to withstand the post-8 ulated seismic loadings hs CPSES. . 9 Further, on CCL's seismic qualification report it shcws 10 that the seismic-qualified HVAC duct work is classified as i 11 Seismic Category One. Also, safety-related equipment Londed i

        '12      in the duct work is seismic-qualified either by dynamic i

13 analysis or by shaker table testing using a full responsive l 34 spectra or by static analysis using one-and-a-half times the 15 peak of the floor response spectrum. , 16

            !             Due to the fact that all the corponents are analyzed l

[ to assure that they are structurally adequate to withstand f i g gg the postulated seismic loadings, there appears to Le no'need 19 for missile consideration with respect to the HVAC systems. 20 In pur report 8324 we indicated that the reactor containment  ;

                                                                    's
                     ~
      .                2                                                                                 i        l j  21      heat removal system did not rely on the HVAC system, but is 1

22 really c mposed of two separate containment spray'rAc'ircula , 23 tion trays, each of which has 100 percent capacity and, of 24 e urse, the containment spray has two functions. One is to 1 \ 25 rem ve the heat from the containment after postulated load, ( __ l

25 Il and the second, of course, is to wash entrained and suspended 2 material out of the atmosphere af ter postulated load. , i 3 The NRC staf f reviewed the FS AR and found that the 4 containment heat removal system was designed to assure that 5 the failure of any single active component, assuming the i 6 availability of either on-site or off-site pcwer exclusively, 7 did not prevent the system from accomplishing its design 8 safety function. 9 I'll be happy to answer any questions related to it. I 10 I have one question. I'm assuming from 11 what you said that the answer to this is yes, but just to bc l 12 sure and also I'm a little out of my element: In the con-l

 ,   13    tainment, the sides of the containment, where you have the' 14    HVAC system ducts going up the sides of the containment, p         .

I 15 l are those seismically--not seismically--laterally supported? l l 1 16 l MR. HUNNICUTT: Yes, ma'am. They are laterally supported l l j i 17 to where they can only move within the seismic requirerents.

                                                                                           .        I i

is These are large ducts. They transfer very large arounts of ( l 19 air. Roughly--let's see, the height of the containment is { , i i 20 252 feet, and I've forgotten the circulation capacity; but a e - j 21 the fans do continually circulate the air to keep from 22 stratifying. In other words, the bottom would'be at 80 23 degrees and the top at 190 or some other numbers, but they , l 24 _are seismically restrained to assure that under the postu-l 25 lated seismic conditions for the arca--I have forgotten the l D e4- ,%. e. ,m _ _ _ _ -_-___-e.

26

      ;   I     exact numoer--related to a seismic category .1G or .12.

2 One of our concerns there--I'd have to check 1 3 the transcripts to be absolutely certain a.cout this, but it l

     .          is my recollection in June of PBS hearings testimony was that 5          they were not laterally nupported, and that was one of the                                    l 6          things that was brought . up.                          This was during the hearings
                                                 . . . .      - - ~ . .-

7 on CAT Team fi _ndines.. -  : 8 MR. HUNNICUTT: As I understand it--I hope my information 9 is correct--they were laterally supported to withstand any I' 10 postulated seismic event for the maximum allowed or permitted g3 , by the FSAR as Mr. Shao pointed out, .12. 12 That's one thing--I'd have to check on that

                                                                                                                      )

13 to be certain. }

    } .1                    MR. NOONAN:               That was a June 30th--                                      ,   I There was a June 1983 hearlng.                I'm not 15 16           sure what the date was.                         I'd have to check.                                   {

i I MR. NCONAN: You say the NRC did a review? Whc was that? j - I was one; Mr. Ellershaw was the$ther: l 15 Ma. HUNNICUTT: )

59 and if you will permit me to go back a cecond, I will tell you Mr. Taylor was the third, and if .

20 who p e other people were. .' ~ c . 21 my mem ry doesn't fail me, those are the three principals. f l Now, we have had some input from a Mr. Cumings who"is the 2'2 current resident, and due to the fact there's a draft report q 23 ) l g under consideration right now. I don't recall but I know he j  ! and I had authorship on portions. I can' t remetr'oer the numbelr. l 25 l I

l 27 1 Now, on 8416, in my infinite wisdom and hurry, I just copied' 2 the three pages that related to it; and I do not know who the 3 author was on the 8416. It was issued on October the 4th-- l 4 of this year, of course--and I only have pages 12, 13 and 14. 5 I apologize for not having this entire package, but when you 6 are in a hurry--of course, I didn't take it out of the site. 7 I think that's ene we just got recently. 8 MR. HUNNICUTT: You would have just gotten it because 9 it was mailed--it left our office on October the 4th, and  ! l pages 12, 13 and 14--in fact, it would be paragraph 6--cover 10 33 a minor amount of your HVAC; and there's another ene coring 12 that really went through the CCL Phase 1, 2, 3 and 4 docu- , 13 ments that compared it to a licensee's evaluation. i y Specifically they had made a probability analysis that--I 15 l think it was 280 elements needed to be checked and CCL had 16 l done 285 so, in other words, they probably listed calculation's i l 6 g

g. between the licensee and CCL were certainly within the basic l

15 mathenatical realm. We hope to get that report issued short-

                ;      g9    ly. I won't make a stab at the number because I may be wrong.
                !      20          MR. NOONAN:         What concern was there?                                                          '

l l j MR. HUNNICUTT: Again, they neglected the use of the core spray system and containment spray, which each of the i 93 two systems is 100 percent available, and that is supposed I to reduce the temperature within a reasonable amount of time , 2a, f rom the highest postulated value to a reasonable value.

28 1 MR. NOONAN: But the concern would be that the tempera-2 ture gets too high and the equipment won't work? 3 MR. HUNNICUTT: That was our understanding of the l 4 allegation, yes. _ And.nrtym r;wasNauppofte spropH1y.

                                                                                                                   ~

5  ;

 . s                      :      .. ~ ..                      .. ,- _ m a m m, fg _ T= % 4: h= r-7 8                        MR. NOONAN:   I'd like to do one other thing, too.                         As    !

9 far as the equipment inside,'do we qualify the equipment for! 10 what we call the high energy line, which is the main steam i

                                                                                                                ~

11 line, or ALOCA people. I don't remember the exact tempera-12 tures, but I'll get them for you. Equipment is usually 13 qualifiedtowithinarangeofsomewherearound300 degrees.l 14 MR. HUNNICUTT: Let me correct that; it's 275. j l 15 I was kind of thinking 280. 16 MR. NOONAN: We don't tell you what the equipment is i I l 1 i 5 1; actually qualified for. We'll give you the upper value. ' l ls MR. HUNNICUTT: If I remember correctly, it was 50' PSI l - - ; as designed and 40-something as the maximum calculated and 19 i

   ! 20                  275 Fahrenheit would be the~ maximum temperature.

s j 21 MR. NOONAN: Do you have anything else on that one? 22 MR. BANGART: Do we have additional questions En this I 23 that might be jraised at some later. time? e uld have; I don't. 24 25 MR. NOONAN: With that, I' ~think I'll get Jose Calvo  !

                      *                       = hem m e e,me        %.               , , ,      g [          .
                                                                                               , + ,

29 1 start with the electrical. I 1 2 MR. CALVO': My nEme is Jose Calvo. My background: I l 3 work with the NRC for the last 12 years. I spent one year 4' with the International Atomic Energy Agency. I also worked 5 for Westinghouse in energy-related matters. I also worked I

 ,        6       for Bechtel Corporation and Louisiana Power.
                                    ~

7 Before, I think you had one allegation that I'm con-S cerned with. Before we get back to the allegations, I think 9 it's appropriate to tell you how we handled the allegations.. 10 As you know, the quality control inspectors were interviewed i 11 and a number of allegations came up as a result. Most of i 12 them were general in nature; some of them were specific. 13 What we did is some kind of way we correlated all these j 14 allegations. One allegatien was talking about terminal , 15 locks. We're talking about bat splices; we're talking about 16 cable installation. We put them into about nine categories. l 17 l And regardless of the allegation which has safety significance j lb , or no safety significance, we went beyond that point. We 7,

 ,      19      kind of bound the subject categories with our own sampling, l                                                                                                                                                 )

i 20 looking in areas where we felt there was a real concentration ~

 ,.4 j  21      of . cables and problems of terminal locks or bat splices so                                                              l a
     *                                                                                                                     ~

22 we can identify whether there was some kind of~ generic 23 implications as a result of this. 24 The allegation you brought up, I think, touches termin' al 25 locks, touches cable splicing, touches cable installation,

                                                                .                                                                                      l S

4 . .. f.-..-.-. ~ ~ = = . .

30 I and I think also it touches nonconformance reports with

                                                                        ~

2 regard to cable operation where the cable was installed. We l l 3 acknowledged the fact that this particular allegation, the 4 formation brought up by the alleger was--the concerns brought 5 .up by him, there was no safety-related matter but we say let's

       ..             6      see if the same problems are in the safety-related matters.

7 So maybe we can give him credit for th'ese things. I guess 8 what we did, we focused in that kind of direction. We did  ; 9 find some problems with bad boxes. I want to give credit i 10 to s I do to all the allegers who contributed to 11 force us to look into that area so we did find problems there~.i l 12 We also have problems with terminal locks. = We have l 13 problems with terminations as we indicated in previous  ; g4 meetings with the tJtility and in our letters summarizing i 15 ur conclusions. One thing we did in that case is we had 16 ~~"~---O----- -

                                                                                    ---P'-"N~~"" W '"~ N"W U N i
                                 ,-u        a      -
                                                     ----.ut_.                 .- ,

i 15 utWEEEEE ER5Ekk We went up there and we ascertained the quality

            ;               of the hardware. I was involved with a similar team who 39 1                                                                                                                                -
            !       20      was re.sponsible for assessing the quality of the hardware f'

1 g at the' similar plants, and i had some background on ' hod to 22 work' on this type of review. -- I

                                                                                                                                          -j       i g                'Now, thisiswhatIwedid.                                I'm looking-at specific                          i     f 1      I i

24 allegation 813 and I guess the alleger we used to call j I 25 **' * ~~ t 4,.. . _-. .. _-.--~~~.------- - - - -4 -

31 I ts. VIETTI: cesn't know what 813..is. That'.s our - 2 NRC number- , ' 3 MR. CALvo: ows Oklahoma. One of the allegations l 4 brought up has to do with the use of locks for some dif ferent i 5 size cables', 750,000 circular mill versus the 1,000 circular 6 , mill, but that one located in the circulating water syste'.t. . 7 That system normally is not safety--I mean, it is non-safety , 8 I related, so we did not concentrate on that because why waste i 9 our time about the non-safety related. Let's concen.trate on ' 10 similar problems with the safety-related, 11 Also, the other allegation he had was building locks-- i 12 I go back to Switch Gear Room Reactor One. I guess this I 13 allegation came on 1981, 1982. We went and checked this oct 14 ourselves and found out that that thing was involved with i 15 some black cable, but definition of black cable is non-safety 16 related so we don't bether with that one either. I 17 We did look into also unmachined panels,  :

                                                                                                           .ike panels--                           ;

j 16 Centrol Roor panels. Those also were associated with'b' lack .- 19 cables, also non-safety related, so we don't bother pursuing { l s-20 tha't one. No reason to spend our time. c { 2 1 21 There was another one that had to do with patching of 22 cables and with operation.; There was some nonconformance i 23 report. I think the nonconformance report was indicated as 24 in 1981. Thosc had been handl'ed in a manneri that was satis- ' 25 factory. Whether they 'were safety-related--they could or . t 9

                                .       . . . . .        - - . - . . .      . . . . . . . . . .                   . . . . - - - ~ * . ~ . ~ . . .      .. .

{; ~

                                                                                                       ,s'.     ,b +0             v.

32 1 they couldn't be construed as .non-safety related. We did i also look at nonconformance reports -in several areas to bound.k 2 3 all these allegations, so this contributed an input to the 4 other category for nonconformance reports. j 5 The only one that had some safety-related flavor was thei

l. 6 Switch Gear Room in Reactor Number One. There was some prob-7 l lem there in No. 10 terminal locks. So what we did, par- '

8 i tiicularly for the terminal locks, we went and we reviewed

                                                                                                                                        +a 9

l the safety-related areas and we looked up in the order of -I 10 about 16 safety-related panels and the control panels, j I. I 11 termination cabinets, rnotor control centers, 12 and syitch gear.! he inspected them for the proper size locks and relative to , 13 cable sizes and screw sizes. We look for tightness in the  ! 14 bars, ground wires. So we look at all these things that were 15 Presumably brought up in 1981. We find nothing wrong in this  ! 16 particular area. i he did find something wrong about the i splices and the excess bending in the terminal wires. [. 17 i* IS I The cther one in the cabic installation was a whole 19 category. i We went back to this with the other allegations

    ,    i              20                and we didn't find nothing out of the ordinary. We looked
   .. ' 4 I

21 into the cable tray. 22 , In summary, all the allegations with everybody contributal 23 ing to them, , wf h = m obl= ~ i.th ' thwe h I 24 25 A - -- -

                                                                  - " -      ="-+        h#*             "--M*
 ,                                                    .        ,y-.'..

yn, .

                                                                                                                   .jk,; h, .. : -- ----- .

i 33 I G64trorenooniReillriijWiMElddand that we passed to the i 2 Mechanical Group. . , 3 Now, we hac some other--that was the hardware allegation.

                                                                                                                          'l j                 4      We had also the OA-0C allegation and we look into the elec-5      trical NCR activities.                         We found no problems insofar as our 6      small input from the electrical standpoint.                          We are waiting 7      for the big cverall input that QA-QC must link--couple with I

l 8 ours. We also looked into procedures, and we identified ' 9 ' problems'and we identified corrections to those problems. 10 Again, also, that one is not complete because the overall 11 OA-QC programatic review got to couple with that one. The I 12 other one that we wrote, the electrical eewrn=pe.ccoawcra'rn1Mgy 13 su. ,.56=XITcTffonMMTink we find problems with the elec- I 14 trical qualification and training that we came out with some 15 procedures and some requirements and actions to be accom-l g plished. t I However, those gave me a chance ta look more broadly I l

              ! 17  l and the OA-QC found additional problems with the electrical i

i IS procedure. 19 I guess in essence that summarizes your particular i

              !        allegations, but I think the important part of it is that 20
      . -     J                 -
              ; 21     all of them contribute to making this categories.

t

              !                                                                                       Not any
              '                   5
                                                                                                    . .-                   i 22     single individual gets to take credit for this." Also, the                                          ;

{

                                                                                                                                    \

23 team also has found other things that were not covered by the 24 allegations..

                                                                                                                         .l MR. NOONAN:             You say the QA-QC; this is .the.--

25 e

                                              -e Ow n  ""M    W"
  • bem $4
                                                                                                  ,g,           p~   e       em ,

' 'j ~ve =

                                        ~
                                                                                                .        e _~,MEM_- _ _ _         _

i ~4 4 - _ i 1 MR. CALVO - Livermore; the group. , They are supposed 2 to couple all the disciplinary with the programatic one and 3 come up with--in some cases we already had concerns and we l 4 confront those concerns. Now, when those concerns get bigger 5 because they found something else,smechanical or coatings

      ~

6 or whatever it is, those have to be put together; and just i 7 because they found that everything is okay doesn't mean that

        ~

8 that subject is complete. It's okay from the standpoint what 9 the allegation may focus in, but when the others come-  ! l 10 together, maybe this whole thing will open up and caybe i-11 l focus on those areas, even in our area, but we don't know , I 12 that until we finish the work. i 13 MR. NOONAN: @ --- . _  ; Mrr=MarhaMvarmnrma.14-+ ham m

                       -=tferngs ?
                                                                                                                         --       p 14                                                                                               f        t , .>_ t s .,, e             ,

A - 15 "- Iaipn - - Ee_b2S_ con _ieggfisa m y -OL ,-Jul 3u2s N 16 ,

                             -^#"___""
                                                                        - J: - -- Helmm> As you know, when                                           !
f. 17 these NCR's become available and they all have the stigma i

j 15 that they are--they say it is complete as far as the electri-19 cal input, but these conclusions can be changed as a result ' i '

          !  20           of th5'overall programatic reviews.                                                                                         !
      -e                                                                                                                                              l
          }  21                   At this tir.e I say the Utility as well as-the intervenors
          !'                  ~

22 are at a disadvantage because you only know the r'esults and 23 the conclusions, especially on the electrical area. You . l 24 don't know how.we got to'those results and conclusions, which I 25 test, what method we used, how we bound the thing up, why

l - 35 I we picked this up, and where we picked it up. Knowing those i 2 things, you can say,- "I know how they go about- it. Now I can

 ..                     3  develop a plan; I can critique a certain astount, and I can 4  understand what the overall scope of the problem is."                                                You 5  have to have the whole picture to try to understand what we i 1

6 did was either good or not good. At this time it is very l 7 difficult to ascertain. l 8 When you come out with the final report,  !

                               ,~             j 9  will that be included in the report, how you did all this--                                                  i 10          MR. CALVO:     Yes,'it should be.                                     Then people can under-l 11  stand whether we did a good job or bad job.                                            By this time         '

l 12 all these people on the report that we saw say those by it-13 self don't mean nothing and there should be no basis for j 14 coming within the actual plan at this time. That is not fair I 15 to anybody to do that. 16 MR. NOONAN: On these reports we called them safety a* {. 37 evaluation. He were going to handle it. It's a charge from i i 15 what was being done be fore. We will have one of ry sta,ff

        .      ;       19  members in charge of the so-called safety evaluations, and                                                  -
              !        20  under her we 'will have- three consultants for various areas
     ,-J                      . . .             .

[! 21 we're talking about here. We'll have a consultant for the , cr- - 22 e atings on OA-OC. We'll have a consultant for the mechani j . l 23 cal and miscellaneous. areas.- We'll have another consultant l l 24 f r the civil and the electrical and testing areas. Their

  • l j b is to, after all this comes together, basically sit thereI
                                                                                                             ~

25 l I

                                                    ****** Nee *        *
  • eee- . em. . -ey e ....e,.y..
_* / 4 ..
                                                                                                                      *   * ,j.

36 I and look and see if we have a'ddressed the evaluation properly, 2 if there's something that we've missed. It's sor.ething like 3 a coordinator to look over the picture. We have three out-

                                                                                                    .l 4  side consultants to do this, sort of, for us, to give you an I

5 independent viewpoint before we finally put it out to the 6 public. t 7 MR. CALVO: Our effort was not encompassing to pinpoint ' i 8 what the root cause, but it was focusing at the problems; and 9 now when we established the actions that needed to be taken 10 by Comanche Peak Utility, then after they do that work, then l-11 the root cause is estab,lished. It doesn't make any differency 1 12 whether they reinspect the whole plant or take a sample, - 13 a representative, regardless of what the confidence level, l 14 what the acceptance or rejection. The only problem we nave 15 with the rejection is simple: whether that one is reflective 16 of thn_fg!_qTreyg-It r could very well be that you will say, a j 3- 'I have met the acceptance criteria and that n.eans that I have i gg a root cause probler. and I have to go further regardless of

    -   ;   39 whether you meet the criteria or not."                 They've got to under-i   20  stand,that.         It's not a part of whether you passed the test.                             ,
        ;           ;; . 9                                                                                      1 l
        }   21  It's because you found when you passed the test that you had
        '                                                                          ~

i to go forward. 22

          . 23                          That's been one of our big concerns from the beginning~'on all of this.            Nobody seer.ed to really be                 ?

24 25 addressing that before. 4 . 1 G

                                                * * * -      e      . ese m   4   e, A        g     5. / /-    -e

37 1l MR. CALVO: Now we know it's a concern, that it is a '

                  '2 l'

problem. How big that problem is we'll know after we do 3 further samplings. That's all I have to say. l 4 MR. NOONAN: These three coordinators, their job is also 5 to look for what they can tell--as best they can, look at 6 the root causes. Make sure you address these areas that l *  % h 7 we're worried about; why did they happen in the first place? 8 MR. CALVO: Do you have any questions?  ! i 9 On a lot of the electrical stuff, as you're! 10 aware,hillieGarde has been working with some of the 11 other allegers. She's much more knowledgable about that .. 12 and what they have to say.

           .      13                            MR. KEIMIG:     My name is Rick Keimig.                 I was the leader                        ;

14 of the group that was looking into the concerns in the test i 15 program area. By way of background, I have had in excess of 16 12 1/2 years with the NCR Region One Office in various

                                                      ~

i i 1- positions in the areas of construction, testing and operations. j IS There are three other members on my team: Ward Smith, who I

        .        19                     is sitting on my left, who has been assigned Resident                                                           l
            -!   20                     Inspector at Comanche Peak since January of this year; and 5   21                     there were two contract persons from the Idaho National
           . .i' 22                     Engineering Laboratory with experience in testing.' ~                                          _    e l

23 We looked into 19 specific concerns or allegations and '

. 4 , 24 put them into seven discrete topic areas. .AsJose' mentioned l before, the specific allegations we put into, topic areas
                                                                                                                                 ~

25 ., < i 4

                                                                * * * * ' =           *===     .e emm e   emo ..

a ., y s

38 1 because of their similarity. The concerns expressed in  ! l 2 CASE-Proposed Contention.26 were included in topic area 1, 3 3 and 4. I'll start off,with topic area 1 which is the 4 largest area and concerns eight of the items in Proposed , 5 Contention 26. - -  ! 6 - The first concern that was expressed in CASE-Proposed , 3 7 Contention 26 was that the applicant failed to conduct an e 8 adequate prefueling hot functional test program in that not l i 9 all components or modifications were installed with required i i 10 functional testing. TRT reviewed this particular concern l l 11 and found that the hot functional test was conducted with l 12 several minor components and equipment not having been g 13 installed at the time of the test, and also found that 14 rodifications remained to be completed after the test was l 15 completed. , 16 In addition, we also reviewed some of the inspection I 17 reports of inspections conducted at Ccmanche Peak' including i i 16 the construction Appraisal Team inspection and several others, 19 as I mentioned. The ones that we reviewed we looked spe-i

      !   20      cif'ically for any evidence in those inspection reports that i
      !   21      would give indication of any undocumented--I emphasize i                u                                                                     . . . . .

l 22 undocumented--components and equipment. We fohnd no 23 evidence of any of those inspection reports. Therefore, we. l 24 had confidence in the system that the applicant: was' using  ; for documenting-missing components and equipment. l 25

            '-~--       --       + -- -          -       - . .        . . . . .            .            .    '~.     ,;;
                                          ;,.      _                            >     '~

s , /bA "*

39 1 Our review found that all the equipment required .by the . I 2 hot functional test procedures was either installed .or was 1 3 documented as not'being installed on either a test efficiency! 4 report or a test procedure deviation. Both of these items , I-l 5 the test efficiency report and the test procedure deviation, i 1 l - 6 are the administrative mechanisms that the applicant uses l l 7 for discrepancies found either during the test or before the l 1 8 test. Approximately 95 percent of the test efficiency report's l 9 issued against the hot functional testing documented-' piping I 10 and equipment supports and restraints that were not installed i 11 prior to stant of the test. l 12 We reviewed specifically those applicable test ef ficiency 13 reports, and we also reviewed two test procedure ef fic.ency l 14 reports which had been generated by the conduct of the hot i 15 functional test. We found that the documentation of the . I 16 missine eculprent components was proper and that outstanding l . j 17 testing which remained because the components were not I i 1 i is installed at the tir.c of the test was tracked by the appli- 1 19 cant and his administrative tracking system.

  ..      i  20                ,ye also concluded that the applicant's decision to                                                      !
     .;w                     ,
21 proceed with the hot functional test despite the numerous x
          '                                                                                                                              j 22        ePi eces of missing equipment was a_ conscious decision, and it '

l

            .23        . appears to have been influenced by . the economic impact of                                                     , !

24 delaying the testing program. This:is not unusual.  ! 25 We also found that the. applicant at the -time that we l

                                            .p. **

g.,

40 1 did our review was planning a preoperational testing program.' t 2 i That is, they wanted to load fuel and then proceed with'the I I l l 3 tests which were not conducted prior to fuel load. - I guess 4 now this~is up in the air as to whether they will. complete 1 5 all the testing that was not previously done before fuel 1 6 load or whether they will finish some of it and have addi-7 tion'al remaining after fuel. S In any event, any testing that is deferred beyond fuel-9 ing will have to'get NRC approval. 10 MR. HUNNICUTT: The licensee has prepared to do many i 11 hot functional which will cover the items that ::r. Keimig . I 12 has mentioned. They lost a coolant pump that is being

           ,.      13                  replaced right now.            Between now and probably the weekend            ,

14 they will test'that, and their plan then is to go ahead and 15 complete the hot functional items that are covered here; and 3 16 then prepare at a later date to remove the head and prepare

              $    17                  for fuel loading.        The number of days is up in the air i    15                  because of the pump and, of course, it's the licensee's,
        . ;        19                  schedule.

I

              !    20                        .MR . NOONAN:    May I ask a question?        Pump motor burned
  .           j  #
                                                                                               ,                   l 3    21                  out?                                                                         ~

h' . . 22 MR. HUNNICUTT: Yes, sir. ' ' I 23 MR. NOONAN: Was that a de'fective pump motor? t 24 MR. HUNNICUTT: No, sir; a piece of foreign material

           ?

4 25 -was found. - l

                                                 ~

1 e P,

                                                                                                 - I
                                                                                                              .        o     ____

41 1 MR. NOONAN: In.the casing? In the motor? In the 1 2 pump casing?-- - l 3 MR. SMITH: In'the motor area.

        ~

4 MR. NOONAN: It wasn't what they were pumping? 5 MR. HUNNICUTT: N o ,v= = - W'Y'"*"="* - ='he> 6 outside. It_ car 2 @ i - --- w =wymene m as

                 ?
                            &MR. NOONAN:             Something that was picked up in the manu-
      ~

8 facturing process, you think, or do you have any idea? 9 I MR. HUNNICUTT: No, the pump has been used a number of 10 times. We have not finished our reviews nor has the licensee, t. 11 but the appearance is that they did not close it up soon i 12 enough after the last testing, and for one reason or another; 13 foreign material was introduced and sat there. The pump l 14 had been used a number of times by jogging it to remove air , 15 from the primary system, and they started to do a two-minute 16 test and about 15 seconds they saw a flash of light and 8 l , j 17 smoke and they shut it down and secured all the testing until i 15 they determined the problem. They do have a spare pump, and

    -       2 19     'the old one is being moved out, pump number three moved out i

i 20 and a new one is being put in. I e - l

                                                                                                        ~
            !   21                MR. SMITH:        We should point.out that this is an open-22      type motor that has areas you can look in an'd see the areas 23      where thi's foreign material was, so it's not normally closed l
                                                                                            ~

2( and sealed. It's accessible. a 25 MR. NOONAN:

                      .          ..N. u.. h.?n._        _

_ l

p .~ ,.~ .. ...: .. .., .,

                                                                                .      .~.

l t 42 1 MR. SMITH: Yes, i 2 MR. HUNNICUTT: You can't rule it out. It could also 3 have fallen and bounced once or twice.because from the . 4 operating floor down is a path of probably 40 feet, and there are two levels .on the steam generators and people can I 5 \ .

 ..                       6   work and drop something mid-level and above the steam gene-7   rators.

8 MR. NOONAN: Is that going to -be a report published-- - 1 9 MR. HUNNICUTT: They haven't finished their investi- l gation so I can't answer the question, sir. I 10 gg Say the plant had been operating and seme-12 thing like that happened, what would have been the impact 13 of it? They have .other pumps available-- l 14 MR. HUNNICUTT: The worst case would have been a locked. i 15 m tor in that pump. which would have stopped all flow f rom I 16 m ving through the immediate reactor scram and you had the i i g- other three pumps plus natural circulation for cooling, so I i 18 the postulated accident should not have caused any serious

   ,,;                   39   problem.

I

        !               20             MR. KEIMIG:       You have to be careful; it's the pump                              i s

a . . j 21 tor, not the pump.

        !'                          *; .                                                                   . - -           l
                                 .,    If.there are no further questions on the reactor coolant                                  l 22 23    Pump motor, I guess I'll summarize our findings with regard j
                                                                                                                          'l to that concern, and that is that we found that while some                                  y
                                                     ~

C mPonents and equipment ~were not installed during the 25 6

                                                   "$.2                                                             4' S.
                                                                                                                 ~ Ruhty.

1 43

1. initial hot functiona1 test program, they were documented 2  !.

g and were tracked to be included in the deferred operational ; 3 testing program. 4 The next concern expressed by 5 MR. h00 NAN: Could I interrupt you? When you went 6 through this process and looked at whether they had done 7 the documentation properly, tell us in a little more detail 8 i what that was. What did you do? 9 MR. KEIMIG: What we did was we reviewed pertinent i 10 start-up administrative procedures, NRC inspection reports, , 11 the preoperational test index, the system-subsystem turnover $

                                                                  .                                                I 12        index, and we reviewed. this documentation against the facility 13        safety analysis report or the final safety analysis report                           !

14 and the applicable NRC requirements and regulatory guide , 15 conducting preoperational test programs. We also reviewed 16 17 of 25 completed hot functional tests and interviewed ~i I

       $           17        cognizant personnel in the test program area.
                                                                                                        .         1 i           Ig                    MR. NOONAN:      Was that both supervisory and workers?
   . .'I 19                    MR. KEIMIG:      Yes. As I mentioned, we also looked at
       !           20        many of the test efficiency reports and test procedure                              i 5

h~ 21 deviations. 22 MR. NOONAN: When you say "we", that's TR5, "ight?- r 23 MR. KEIMIG: Yes. 24 MR. CALVO: All the things will be documcited; how we I 25 went about doing it. - e

                                    . . - . . . . .   ..--..._..~         .-   . u .'.                .
                                                                                                           ,m.                   -

44 I I I I MR. KEIt'IG : The next concern expressed in CASE-Proposed

                       - 2              contention 26.was that the applicant did not intend to                              I 3            check some components in~ the system until heat-up to hot -

4 scandby cr during power escalation. We reviewed that concern 5 by 'looking at the integra'te'd plant operating procedures-- 6 procedure, rather- " Plant Start-up From Cold Shutdown to Hot l l 7 Standby". As in the case for hot functional testing, this 8 procedure specifies that the plant be taken to normal l 9 operating pressure and temperature using reactor coolant l l 10 pumps as the heat source. The system preoperational testing i 11 that was not done prior to the--would not have been done 12 Prior to the fuel loading. At that time, again, this is  ; 13 somewhat complicated because of the change in the applicant's! 14 planning now because of the delay in the hearing process.  ; 15

                                '       We looked at the preoperational tests that we made and found i i

16 that none would be safety significant if done after fuel

               !                f
  • i 37 ; loading because of the nature of the testing and also because 1 ,

g 35 the fuel was new fuel and self-radiating and, therefore,  ;

            - 2          39             could not cause a r.adioactive release that would harm the                            I i                        public health safety.

i , 20 g M - -

               ;         21         -

Additionally, there are some tests tha.t can only be . t 1 . -- i

               '                                                                                     _ ,                      l g              done after fuel loading.. We reviewed those tests, or the                          .j        l
~

i q- plang for conducting those tests, and found that they were  : I I- ,,, consistent with the licensee ? s final safety analysis report i el 25 and also the Esgulatory Guide 1.68 which is'the NRC guide on' l

              ,-   - ,    _t;.        ---!          ,
                                                       '       . _.m y  14 Ms _.        m . . . ,m._ a              1*                l

45 I I 1 conducting preoperational testing. l 2 We also found tha't there were several hot functional , 1 3 test items that were scheduled to occur during the power-4 essential portion of the start-up testing. But those par-l 5 ticular items do require reactor power in order to conduct 6 the test, so in summarizing our findings on this concern, 1 7 would say that while we found that some of the tests were 8 going to be deferred until after fuel load, we found no. , 9 safety significance with that deferrment process, and that 10 the licensee again had tracked those tests and had done 11 evaluations and, as a matter of fact, has subreitted those i 12 evaluations to NRR for their approval; and if I'm not mis-13 taken, they did receive NRR approval to conduct those tests l 14 after fuel loading. r 15 MR. NOONAN: Do you have any questions on this one? 16 No. I have a feeling .ay have some. j 1- MR. NOONA'1 : We'll take a short break then. l 16 (A short recess was taken.) -

       - ;                           MR. NOONAN:             We'll go back on the record now.            Rick, 19 i                                                          .
         !   20           do you went to continue with--                                                                 '
           ,                                                                                                             i
         .                                                                                                               I 21 MR. KEIMIG:             Yes. The next concern that was expressed '
                                                                               .                   . . . .                t in CASE-Proposed Contention 26 was that the ap'licant--neith          p

. 23  ; I 24 25 ^"9 " "#U " " " _ :c .. '.

                                                                                                              . ,.?:
                                                                                                                              ~

4C 1  : cf the problets that.were encountered. The TRT reviewed, , 2 . as I' mentioned earlier, hot' functional terting related test 3 , efficiency reports and also the master data base and the 4 'l master data base was an integrated tracking system the appli-m c: t .

                                                                                             . g,.: .s.                          - 3 . . .

5" cant tihe's eit's a computef* ited'systbr, in any eveht'-that

                              .1            .u + i                                                        4                                   -

l g. 6- <. tra'dks ,eall sorts of different'4hings, but included amongst

                                       . ~. eV          .                   .

9L s' ...m

  • e . . . .

7 -thu.- re test efficiencies, equipment deficiencies,'thinos 6 p

                                               .                                          a                                         1       -

a

                                                                                           .e                                           .

l Il_. . 8 like that. As an example, there were 20 test efficiency , i 1 9 reports identifying missing hangers and supports associated 10 witn the therr.al expansion test. Each of these test ef fi-yy ciency reports was initiated by the Start-up Group and was 12 evaluated by the applicant's engineering organization for 13 its impact on the test results. The applicant performed 34 calculations and installed temporary supports and weichts l a_ during the conduct of the hot functional test sc that the installed supports which in normal operatien weuld interact i 3 1_ with the r.issing supports would not yield erroneous data. . 33 We alse.deterrined that the reasen that thcrc vac no

           ' w~
   .;                           l documentation in NRC inspection reports .indicatinghegion 39 2
      '             '                            s g+g wiedge of sissing.

t.V. g 20 ponents was because thg'gd.ssing

o. e 4 a C* *-m- % . . ki r.w ' *n -
                                                                                                                     " 'c.=   
                                                                                                                                    'g;

{ g components and equiptr.ent were documented and were being 3 oc

                                                                                                                                   . +=

trtekhd in accordance with the applicant's administrative i,

                      ,2
                                                                                                 .          . -                        g
                      .g               procedures.        Those administrative procedures are reviewed.                                              -

24 . prior to the Utility's initiation of preoperational testing , 1

                                                                                                                                                ~

y-  : prior to their initiation of the prerequisite test by the 9

                                                     ,g   ,,                                                    .*
                                                                                                                                                  ..     ** 1

47 1 ' NRC stcff to assure th,at they are adequate to track those That was done by Region 4 previously. I 2 types of things.  ; l

                 ~                                                                               t 3

With respect to keeping the. Atomic Safety and Licensing l 4 Board informed of matters that surfaced during the testing , 5 program, we did not find anything that we considered relevant l-6' to any of the issues that were then ;:esented before the t 7 Atomic bafety and Licensing Board. Therefore, there w6s no 9 8 need for any notifica. tion to the B.oard before eny of those 9 deficiencies that were identified during the testir? progra re.I i 10 I might add that the testing program is performed to

            ;j.         identify the deficiencies with the components and equipment,               '

12 j and probably that's the reascn the Board refused to ada.it 13 that particular contention since they're aware of the reason ! 14 l for conducting the testing prcgrar.. 15 Now, in the case of something coming up there in the , 16 testing program which would have been considered a scfety

       $     17          issue or an issue that could not have been resolved to the i     15 satisf action of the NRC, that then would havg been brought
       !     19          to the Board's attention, even though it was not a matter i

20 pending before it at the' time. That would have been the t g

- f
       ;     21 nly reason for Board notifict. tion.

l 22 MR. NOONAN: Did the TRT loch at the adminie:trative ,' Procedures at all? 23 ] MR. KEIMIG: Which administrative-- . 24 1 3 MR.'NOONAN: Are you talk,ing' bout the Adninistrative e e l

                                                                                                                                            =
                                                         . __s        .                        --

_ _ _ _ _ _ - - - - _ _ 49 prodedures set up by the app'l icant?

                                                                                   ~

2 MR. KEIMIGt \ i Yss. I . i 3 ME. NOONAN: Did TRT look--- i l 4 MR. KEIMJG: Yes. > 5 MR. CALVO: We looked et one time and you guys went i i 6 back and looked again. 7 MR. KEIMIG: Yes. When you csked me before what did we I S do to revi.ew this thing', that was the first thing we did was 9 1cok at the admin? strati.ve procedures. We also found it to 10 be sufficient .for the job intended to do. 11 MR UCONAS: Let na ask another qucstion. has that 12 always there as far as you could determine? Those pro- , 13 cedures were in placc; they weren't sud.denly fixed? I 14 MR. FEIM.1G : R Wel1' , during the testing pregiam, precedures 15 get revised as pzchlems are found with the p,tocedure, the way { t 16 it was written, Some cf these ptocedures have gen 22 through i j - I j p mary revisions, hopefully to irtprove the procedure, thougn i IS we did nct go bach to see enat each subsequent revision to

               ..                        O         a previous revision improved that revision.

i We did ga bagk j 20 in several cases to a previoAts revision because we couldn't 4 f: . j pg d - figure out how it waa done from t'te revisien that was in ( (

                 "                                    e.
                                                                                                                               .-                             l 22        place :at t!.e titae ithat we were looking at.it.                       In~other                .
                                                                                                                                                   !         )

J23 words, it hy have appeared phat it was not d6ne in accord ' j {

                                                                                                                                                   .          I 24        ance with the current. revision. to .that procedur9, so we had
                                                                                                                     -                                       {\

25 to go back to therrsvision that was in place when that l l 2 I e .n . b Jn ' "

                                                                                                                                    -?--
1 l

l  ! 49 1 particular evolution took place to see if it was done in  ! 2 accordance with the precedure that was in place at that tire. I i We found it to be okay.

                                                                                            ~

3 4 MR. NOONAN: From your standpoint, the revisions were 5 what you'd call the normal administrative-type revisions that

    ,          6    would occur?                                                           )

I 7 MR. KEIMIG: Yes. - 8 MR. SMITH: I might add that their administrative pre- I 9 cedures require them to retain each of the previous revisions l,- l 10 so it's not difficult for us to look at a given time frame -

                  '                                                                        I 11    and then go into the vault and pull the revision that was in           l l                                                                     I 12 '  effect at that time to see that they, in fact, complied with I.

13 that revision. In some cases, you could even see where it l 14 caused a problem and they made a revision to improve that; 15 so it's all there. 16 MR. KEIMIG: I don't want to leave the impression that  ! j 1-

                  ) we did that in the case of each one of these administrative         i 15 l pr cedures. We did not.                                          i l
        ,;    19          MR. CALVO:    We did challenge--we did look at the pro-
          !   20    cedures, in particular the post-construction inspection of          ,
          ;-             o                                                    ..,

l

          ;   21    electrical equipment and raceways, and I guess we did not i
                                                                          ...           i
              ,,    accept the revisions for the sake of the revisions.       We did ,'

23 a tually--it was a great deal of concerns'with these I

            '                                                                           i revisions, and the concern was whether the revision was put         j there to improve the procedure or whether the revision was 25
                                   .Me       ae, w   . a. ee d . e m e.

1%

10 ~ 1 put there to circuevcnt the problse, so we went baci. in 2 history and we went frow. Fevision 6 to Revision 1S and we 3 found these cases that was brought to our attentien that it 4 i was some justification for. Like I said before, these.prc-

                                                                                                          -     ; t-             a: +, 4                         .,

i

   .                                    5" l cedGret ehre just an inptst -to'this wfm.de' progiamstic review ti          + . -                                                                  s       .                          a 6 el    that shs going to be done by the OA-QC and how all these
                                                        .c                                                             sf ,      - e                         ,   c..
                                        -        thi$ 7 died together, or whEhhcr                                               we w'ere heing too as'riow s

t b- ,- .. ..

p. s .
                                                                                                                                                            -w **

3' in'our scope at this time', with the d9oUramatic rev[$w#saying, r..,. 9 "It appears that you might have to go and look deeper or J bro ade r . I don't kncv. Mine, I guess--an apprcach to 10 looking at procedures as an apprccch to looking at procedurce 33 12 I think indicates that those two had to be coordinated with

        ,                             j3          the overall QA-CC programatic review.

g MR. KEI?iIG: The next concern expressed by CASE-Eroposet Contention 26 was that there were nurerous problets identi-l a. fica during the ccnduct of the therral expansicn test and,

indeed, there were. It was alleged tha 60 perecnt of the
1_
         ;                                        test pcints in the therral expansion test itself failed the 15
   ,     ;                            jg          acceptance criteria, and also that the . traceability of'the
                                                      . es .                                            . , .

i ,,, , , ,0 megpgringdeviceswaslos,tg,ecausetheywerenot'1 bgg'edwith 3 .- ~ 4f.'s . , c

y. , p - , yy ,: - =. g:_. -::; -lx , , y ;, ,_ 3
         ,'                                       the data, and that the applicant's engineering organizaticn
W :r 21 .Ws  % '
                                  *               .haWL provided no justification for the usc-as-is determincticn 22            --

on piping which did not meet the acceptance criteria. -- 23 I The TRT, through discussions with applicant's personnel 1 24 . l and by reviewing the completed portions of the therr.a1 ) 2,, : i

                                                                                          ' ' ~ ~ '
                                                                                                                                                                                .)

51 I I expansion test,.no;p.A tha,tsbout.,4.cor.cg4+4;ps,;pMs j l 2 g f aiJgQMpggta,ppo,4:rdte;Qa The reascns for the failure l; I l f 3 were not totally ' unexpected in the course of doing this het 4 functional testing, either by the applicant or by us. There 5 were TDR's issued to document all test failures so that the

    ,-           6        applicant could provide corrective actions subsequent to that.

7 Additionally, about 12 percent of the monitoring locations S were not measured because of missing equipment. These were' 9 also doeurented. Seven percent of the monitoring locations 10 were invalidated b.ecause the equipment was removed subsequent 11 to the completion of the test. These were also documented. i 12 In total, about 50 percent of the monitoring locations

        .       13        still require measurements.                                    These measurements will be done--

l 14 so these additional measurements will be taken during subse . 15 quent hot functional testing that's to be conducted now, I 16 9uess, before fuel load. . j 1- The concern was also exnressed that ter nere:ures were I 18 taken and legged during the test but that the specific

           ;              measuring devicc could not be traced back to the locations 19 i
          $     20        that they were used at. 4ags_taffsfodridstna@e-completg ,                                        . . = . ,   ,

21 M Dl8" M W N % f'Ebs 9BjChng hatg rgeghXiM tyrrhoweyep y 22 gM_ & _ynyaggggggnqMRrgqgggspygggparAtappg2whicMggd 23 d @ N N "'" N WMid5 S N # The fault was in the. test pro-24 edure which had undergone a revision and the revision that  ; 25 wasusedduringthetesttheyrequiredthatfjheserial es j . . - . . . . . . u---._----- - . - . - - - _ _ - - . - _ _ _ - - - - _ l'

l 52 l 1 numbers of the measuring devices be recorded screwhere in . 2 a test procedure and not specifically on the data sheet on 3 which the engineers were going to record the temperatures. 1 4 But that loss of traceability of the calibration of the i 5 instruments, fortunately the tiest engineer did keep a 6 separate account of which instruments were used at what i 7 locations so they were able to go back and have included 8 that data in the completed test package. Ward, have you 9 verified that's been done? i 10 MR. SMITH: No. They have that data package pulled out to get it ready for the next hot functional where they're 11 f 12 going to do the balance of the support package.  !

 ,       13                 MR. KEIMIG:    We will be reviewing the entire procedure, !

14 not only what was done in the previous - HFT--that's hot 15 functional test--to verify that the logged data was incor-16 porated, but also to see that they did it in the het functicnal I l [ 17 test they're about to do new. I i 18 MR. NOONAN: Is that a procedural change because-awhy

    ;    19           did it happen?     Do you know?

I~ i 20 4 MR.-SMITH: They may have--let me back up.

                        - o                                                          Theadminis-(

21 trative procedure that controls the format procedures has ' 22

                      %      8bb', tl ere.,that-l         wereyawl'iYF1 A91t :ongthh,agej 23na   8 *M.54b Wd W "F'9 W B f . Y Y Q" $ W PA W W W W 2a       QT)$?M&%{M"R)h??23E%*?E*TNM0,d)f' aea 25 4 W         M M M M 5S.S $ M nd apparently when they made
                               .                           .e.....

53 1 the change they said, "Well, look, we've got a whcle bunch l 2 of temperature instruments here. Let's get it en a nice, 3 clean summary sheet. We'll put it in front of the test l 4 procedure." And that's what they did, and it's a nice clean 5 l summary sheet in front of the test' procedure that tells you  : 6 .w hat this calibration data is, what the serial nuther is, 7 and the instrument is. But as Mr. Keinig indicated, there's I

    .                                                                                    f S        no connection between that and the data sheets.           But this 9        ceparate leg provided that.          What they will do is incorporate 10        that leg in the data package so that you can make the con-11        nection anytir.e.

l 12 j Now, the significance of that is if for some reasch they 13 find out later that a temperature measuring instrument is cut. 14 cf calibration when they check it again, then you know where 15 you have to go to recheck. If you don't do that, what happens 16 is they end up doing the whole test over; so it's r. ore of an I 17 economic than a technical probler. 15 MR. KEIMIG: It's pore to their advantage. ~

 ;      19              MR. NCONAN:       You said they are correcting it, though?

I MR. KEIMIG: Yes. Rather than characterize the procedure

 !      20                                                                                        ,

j  ;; which tells you how to format a test procedure. having vaguc B* [ language in it, actually what it provided for was several ,. 23 options for recording the traceability for maintaining tha:

        ,4 I   traceability, but when you use core than one instruncnt, then
         ~

you have to record the instrument serial number on the data  ! l [

      -                    e  w s                                                            y e

54 1k sheet that you used to take the measurements with that I 2 instrument; . and by putting a whole bunch of them in front of l I l

                           -3'      the procedure, it just didn't cut it.                                           If you were only using I

4 one instrument for a test, that would then be all right to

                                                                                                                                     ~

l

 ,                          -5      do,' but if you use several of them; you can't do it.                                           Therein 6     was where the fault lice.

7 i We also reviewed a reprecentative sample of test 1 i 8 i efficiency reports including those specifically mentioned in ! 9 the CASE-Proposed Contentions which were DDR 853, 854, 855, 10 1033, 1034, 1035, 1112 and 1113, which identified questionable- l I 11 data or deficiencies during the thermal expansion test. We ' 12 could find no cases where the applicant's engineer had not . I 13 Providedback-updataorcalculationssupportingajustifica-f 14 tion for the use-as-is determination. I 15 l The next concern expresced by CASE-Proposed Contention , 16 26 was that the het functional test was c,cnducted without I l

         $                 17      consideration of accident conditions.                                          During our review of J

{ b the tect procedures , wc found that the applicant tested -

    .i                     19      safety syatems with consideration for accident conditions a
         !                 20      to, phc' extent that it Was; cessible by simuisting certain
                                            ,                                                                                                   j
 .       4
                                     <   .s.                                      ,

i s-21 Perameters such hs temperaturo, pressure, flow, etc., that 22 might.be encoantered during en anticipated accident or an 23 cmergency condition. Moreover, the NRC doesn't require an 24 APP l icant to test under actual accident conditions. What is. 25 ' required, however., is that the applicant include in his

                                                    --                                                                                         I c

4

                                               **        * * * -*    - + = - -             . m.              ...          .   ,
                                                                                                                                           , .        ..O..

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  • _ _ _ _ _ _ _ _ _ _ _ _ #*_T_* -
                        .           ..            ~ . .                   ..            . . . . .

55 l 1 application the principal--or how he intends to corrly with 2 the principal desien criteria for the proposed facility and 3 the principal design criteria contained in 10CFR50,~ Appendix 4 l A, and they established necessary design, fabrication, con-

              ,                                   6                             a. ;' ~~.i = . e 6 4.                                       .              3w               .

5'ls-strection testing, perforittarree r6qdtrernents for structure

                                           . s.       ,                                                e        .

6 syst'em' dbmponents important to bsafety. We found that the

                            %. . 4 6;-

C -

                                                                                                                                                            +g Cominbe Peak plant 'is desiijned and constructed witE systems
            %        >. 7 t.             4o ,                                       -                                                                      .s g.

Y ae i "8 and features needed to minimize the consequences ofS an

c. .  :- pg.-

9 accident. 10 The next concern expressed was that the applicant and 33 Region 4 staff were willing to accept the deficient test 12 result. Our review of the completed hot functional testing

        .             13             and other preoperational test documents indicated that with y               few exceptions--I'll get to those later--there were no E

15 deficient test results accepted by the applicant. The final in acceptance of the test results does net occur until after i

          !          17              the Joint Test Group reviews and approves those test results.
                                   .t c e m m M t.r g :- t.r - teey_g_cne_t                                                                                                                      c
                                                                                            ----         - . . -gyc_+pg 31g:s g g-g
      -   ;           ig '!           review and a                                                                                          st ob eIctives i '
             .                                                                                     There was one in eacli' case of
                                                                                       ,.                         . . :. ~-                     j. m . Q
          !          21        i      three procedures.                                          .
         !*                             -i s                                                         t.                                                     . - - -

22 MR. NOONAN: Rick, can you give an example of one of those? 23 ! ,

 '                            =

MR. KEIMIG: I sure can, if ycu want me to go into it. MR. NOONAN: Just one. 2a.

                                              ~ ~ " ~ '           -

56 i 1 MR. KEIMIG: Le,t me take the least' complicated one. - 2 I'lfhavesomeq'uestionsprobably,.but I 3 want to wait till gets here. 4 MR. KEIMIG: Okay. Test Procedure PT3405 entitled  ;

         -                                                                        .                                    .               l 5   " Steam Generator Narrow Range Level Verification" intended                                        !
          ',                    6   to d6monstrate at hot no-load conditions that the narrow 7   range level channel for each steam generator indicate properly l

8 at the upper and lower instrument panels and compare properly 9 I with each other for actual changes in steam generator water.

   -                                                                                                                                     l 10   level.             When this particular procedure was conducted, there ;

i. 11 were three level detectors that were found to be defective, s l 12 and temporary equipment was installed in their place in order Af ter the test was completed, the ) 13 to perform the test. ( 14 temporary equipment was removed and at some time thereafter,I . 15 the correct level detectors were received by the applicant 16 and then they were installed; however, the only testing they'

                        !       le   caid on the three newly-installed level detectors was cold i,      16   calibrations, so they did not meet the test objective which 19   was demonstrated hot no-load conditions that the narrow range
        .                k i     20     level channels:for the steam generators' indicate properly.
                                                                                            ~                           ~

f ..r. l k' 3* 21 They tracked one of them. That particular portion of the test x . will be included in the hot functional [ testing' that will be

                      ~

U 22 N'vn

      . m .i.                               .           .

e , W I. ' 23 conducted shortly. That's :one example.: As'I said, there , n - h,g. . 24 ~were two others, very similar type of thing i I.D ' 25 The' next ' concern expressed 'was - that th'e Atomic Safety 2 . t

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                     .. -                j:g-Sk+                           ,

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                                                                                    . , . . . = . ...

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                                                                                                         . .. ; 3 Q g g . g ; __

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i ( l 57 I and Licensing Board cannot rely on the NRC staff to monitor i 2 that program for any future inspections. When we did our 3 review--TRT did their review of the hot functional test, 4 Preoperationa1 test, taeuwA l

                                                                        ?mmme%t*&L Ma po.t,.y.et.,byung m

5 '

                                 **Masnection=rrf=*kMEjutWFt95fMTR5550 Tup orathe:acosspleg
    ,                      6                     ges. Therefore, it was not possible for them to 7       be tainted by this concern.                                                                           i As a matter of fact, they just 8       had not started their review yet.               Anything that one wanted i

9 to make out of that allegation or that concern was not ' 10 appropriate .at all. We did not find any lack of candor on 11 the part of the applicant or the Region 4 staff during our 12 review. l 13 MR. SMITH: I think, for the record, I need to point out 14 one thing. Mr. Keimig indicated that the applicant intends t.c 15 Perform this test on the steam generator detector during this ,. 16 next hot functional test. 4 .- r ~ . - --

                                                                                            - . .- -                 t.: t su1Ett2apsIt       1 j                  l
            '            37       is our contention that it must be donc and, hopefully,                                       it will j            18 be done, but it's not on the schedule right new.

That par-39 ticular problem was not an oversight by the Joint Test Group. 4. 20; They. consciously said this is the way we're going to retest

    '?                  21        this thing.- We're going to test it cold. Theirpositionwasl

[ ..

22. that we have tested 13 out of 16.so we've preted generically!
                                                                                ~                                                     I, that these things'     w ork, so they're still looking at it.

j3 i g They're still evalu.ating it, so the issue is not. closed one  : 25 way r the other at this point in time.

                  -   ~

A3 7 .. g._ ._ .

58 g MR. KEIMIG: The NRC staff is on record as telling the  ! 2 applicant that it i~s pot in compliance with the spir'it. and  ! l l 3 intent of. Regulatory Guide 1.68. 4 There is one question.I'll go ahead and ash 5 now. Wha" *ha"M^ -hMWan - > -WhenEthey= Molt]}eEtes.tsd , y 6 x _YMBam o se5t'e stqEare--be iTt qQd{eb,Ag4 o me o n e ,

                                                                                                    *"                                                             I 7                from NRC there?

[ ' 8 MR. KEIMIG: We do a sample inspection program of the

                                        ~

9 test program. We're not there for each and every test. i. l- . 10 We're not there 24 hours a day, but we do a sampling program l and then we review test results, again on a san:ple . basis: j gi 12 but I would say that the majority of the engineering safe-I 13 guard testing is reviewed by the staf f. 14 MR. IlU'INICUTT: To further clarify what tir. Keimig said, , i we c me in unann unced on all shif ts; it isn't just an eight 15 l to four. We have people there late at night and early in 16 I [  ;- the corning, and if it's a test that has problems or sig-gg nificance, we do have people for around-the-clock coverage. But normally this isn't necessary. We certainly do cover-  ;

       ,.                  39 a

j .2d what is necessary to assure ourselves and, of course, other ,

                                                .s. . . .
                   .      21 people that are interested that we do cover the test, the                                                                 .
3. -

proceEures, qualifications of peoplef etc., to assM e that. ! 22 t - .' they do meet the requirements. ' v . ,- $ - 23

  • i n ; q't,i MR. NOONAN: Do you have the benefit of 'their 'schedulesi~

24 i  ; ( f ..' i Not only { th'e schedul'e but

                                                                                                                                                     ~

[' ' MR. 'IIUNNICUTT': Yes, sir. 2a. .

                                                                                                                                    ~'

p * ' C e Y

p. . . . , - - . . . .
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59 I they're updated schedules daily. In other words, i' they sli'p

                                                                  ~

2 six hours, we know they slipped.six hours. Do you I

                                                                                                                      ~

3- MR. NOONAN: How often would you call in help? 4 have an idea? l 5 MR. HUNNICUTT: It's a' hard question. Specifically, we

                                                                                                                                   .I 6       have a senior resident and a. res dent on the operation site, '

7 and I have a construction resident who is qualified in opera-i 8 tions, but at another facility, and he is there, and myself,I t 9 if necessary. So we do have--without calling in other. help- ! L. m 10 we do have the entire Regional staf f in the event we need / 11 them. i D 12 . 7. guess my last question was triggered more 13 by the problem with the containment integrated leak rate test {. 14 MR. KEIMIG: That's coming. l 13 I guess that's one of the things that i 16 triggered that cuestion: What happened with that?

                        !                                                                                                             l
't                I-                 MR. KEIMIG:        Why don' t we pick up with that?                        The j                 18        concern expressed by CASE was that the leaks encountere'd' I                 19        during the containment integrated leak rate test were numerou,s t

and of such magnitude that it would have to be corrected and l 20 .4 - j 21 the test repeated before fuel loading. As a condiElon for i

'~~

22 perating license for a full power reactor such as Comanche h;d' 23' Peak, the licensee has to test--or the applican't; the . appli-- v cant has to meet the- leakage' test requirements set forth .in 24 l. Id 25 10cFR50,. Appendix J. Appendix d, of 10CFR50 requires . , e g D

          , Vg                                                .._...:,_,.  ' . . ;. d . _

A'ry';;hj. .4 b ..< N $ .' : . , ,,/y ;,y.; hj*l6; gip /[Q d .J.%: .

                                                                                                  '   " ~ ~ ~ ~ ~         '

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60 1 preoperational testing of the overall leak tightness of .the 2 Containment Building. l That establishes acceptance criteria 3 for the test, and this te' sting is conducted to assure that l 4 the total leakage through all designated penetrations and/or 5 building floors, if any, does not. exceed the value specified I

 .           6   in Appendix J or the applicant's proposed technical'specifi :

7 cation. The TRT reviewed the as-performed containment inte-l 8 grated leak rate test, and the resultant test data would i 9 determine that as alleged numerous leaks were detected during' 10 the first of three attempts to conduct the test. On each of jj the first two attempts when it was determined that the leak-12 age rate would exceed the maximum allowable leakage rate,

     ,      13   the licensee terminated the test and reduced the containment j 14   pressure to a safe level for personnel entering into the 15   e ntainment, and searched for, found and corrected the leaks.

i 16 Prior to the third attempt, test personnel identified i i

       .[

3- three containment electrical pe'etrations that had excessive a j 15 leakage rates. They isclated those three electrical pene-

        ;   39   trations prior to the third attempt at conducting the test, i

i 20 and then they performed the containment integrated leak rate ;' f g test. That third attempt was successful. The test was 22 observed by two NRC inspectors and those NRC in'spectors also 23 independently calculated the leak rate test. results. After

               , the completion of the test, the applica'nt performed individual 25   leak tests on the three pen,etrations that were isolat9d during 1.

A j, . . . . .

61 i i the integrated test and found that the--and then locked for 2 the cause of the excessive leakage.. They found 'it and it was l 3 in the penetiration--happened to be:in the seals; they hadn't I t

              ,......4              i been properly sealed--and penetrations were reassembled and c               -
                                                     ,                      . v., +; , +        s ,,, , , '                          ,,.
                            $ I -then again individually- leak tested. .> The results .o'f that
                                <-; .            At 4 v                                              ,,

6 leak sate test, after the problem was corrected for each cf

r. ,. " 4 w6eb ,. v.- .
                                                                                            .A (C r.. *                                           .

7 the*t$rde electrical penett 1t' ions, 'were then added to the 8 i ,.

                         ~

w . . .<c.=,,

 ~

t '- I overa'l l leak'$ge rate for th$ containment. E Tiiat w'as~ the gi. 9 result of the t'hird attempt. This addition was insignificant 10 and did not alter the significant figure in a previcus total 11 leakage rate. 12 Tne problem that I was referrin'y to was-- t 13 l does anybody have a copy of the TRT report here? I don't 11 rer..cui,er the exact wording , but-- 15 b'S . VIETTI: Which report are you talking about? The 16 18th of Septer-her letter to the applicant? 1; 'Yes. The part that I was referring to which j is concerned us is on page 14 where it says, "Though the leaks

-{
               -#'      '. ,i9 l were subsequently repaired,and *in21,1vidually tested with k                         saYh.ctoryresults, N' ,s(20     er- ('                               m -

y 9 cv e n c' - form the CIO with these pene i - -a

                                                                                               %'%C      f ds.& *.NC V i6,-;a4the 3             .21"                                                                        tions' 1solated." That i                                  @&                                       .

3 4. ..

                        .'22-kind of . thing that has 'always ' bothered us wheneverr anything                                    .
                                        '^ '

g c- r: er ' j.: -4

                         '23 'l           like that comes up because we're not always certain                                         - ~   n.--

at';thint

,;x; ., - '

like that would hav~e~ been: caught if there hadn't been this

                                                                                                           .                           ~

$ 2.~1 ,

   ..                                 i

?y. This is cne o'f our 25 .. . . higher levcl of review by -the TRT teac.

 ~

W l 1 9

  • 5 ._s-'#, ._.P._. ,
                                                           , , j/ * ]

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62 1 continuing concerns with this, that sometimes in the past - 2 .i* we don't k' now if NRC h'as looked at things ' closely enough. i I This is what triggered my concern about the other. 3 4 MR. KEIMIG. I understand. It concerned us also.

                               .S                    MR. NOONAN:             Do you think that from what you've done                                                 l
 .                              6           that this thing would have been caught?

7 MR. KEIMIG: It wasn't' a matter of catching it. The

z. -

8 applicant reported it in'their summary leak rate test report,

                          .-    9           in its amendment.                   It was there.                    We happened upon it before '

10 the Containment Systems Branch of NRR. got around to reviewing 11 the applicant's report. It would have been picked up. They' 12 were not trying to hide it, as evidenced by the fact that they .

        ,                      13          put it in their report.

Again, this is a matter of conductin,g 14 a preoperational test were the system not in the configuration 15 or very nearly in the configuration it would be in during 16 normal operation. That's what bothered us. i g- One of the things that bothers us is, if *

        ~

g gg I remember correctly, what came out in the paper when that

            }                  19          third test was performed was the applicant saying, "Yes, we've i

i ~ 20 Passed and everything is wonderful", and so forth; not even , \  ; - i f 21 mentioning anything being closed off. In other words, without any mention that th'ere still might be some problems "that .

                                                                                                                                               ~
                             .22
                            . 23           they had:to corre,ct. Shis is the sort of thing- .
                                                                                                                                                     . y            ,
  ,-                                               MR. KEIMIG:                                                                                               .l-
                             -24                                             The problem is not of any creat. sigitificance.v .                                              t
n. ,. , y. :. .

25 but I thi.nk. if they would, h, ave--I 'shouldn ' t be . speaking ' for ig .

                                                                                                                                                                            -     \
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63 1 the -Containment System Branch--if they had asked the containd 2 cent System Eranch'if they did do that, that is, isolated I 3 those three electrical penetrations, and then proceeded with*

  ,                                         4         the test, they would have probably been turned down..

I 5 MR. CALVO: Excuse me. When this was subnitted to the . 6 Containment System Branch, it was submitted in amendment to , t

                                                                                               ^

7- the pSAR? i 8 MR. KEIMIG: No. It was just in.the test summary report 9 that's required by Appendix J. i l 10 MR. CALVO: It's practice in the NRR to accumulate , i 11 these things that impact the FSAR. At some point in time you 12 write a supplemental safety evaluation report which covers l 13 all these amendments up to *. hat time. If you had not indi-14 cated other ise, that means that you accepted what they had i 15 done ;nd ycu assume they have no great significance that can ^ l 16 l be implied by that. If you feel that it's safety significant, s j 17 then you so indicate it in the supplemental safety evaluation

          .i                               18          report. It happens to us in the case of the splices.                    The
          ;                                19           applicant told that to the NRR and NRR has not done the                                  ~

1 g a 20 review up to that time. The TRT requested NRR, "Weneedthel

          .                                                                                                                                          l 5                                21           evaluation now so we can have a decision on this , matter."                              j f                                                                                                             '

g . 22 They say, "Well,.you precipitated our review. We're not 23

l. going to get into it until we have a couple of more acend- .

24 ments." They say, "This one has a bearing on what we're l " 1 25 doing", sotheydid.prepareasupplementalsafetyevaluationl-

      .                                                                    *m.. ese-
                                ' ' 'anw    =     ...w..    <    ,,m., ,.i.

64 I report. Most of the branches in the NRR work on that basis. 2 Whether this particular report was. to be considered as a j 3 supplement-to supplemental safety evaluation report,.that's 4 something that we can determine.  ! I l 5 ,

p. NOONAN: I'll find out on this kind of test what t

6 the CSP procedure is on looking at this test. Then I'll have l 7 to look at this transcript and let them come back with,a I 8 written reply. . 9 _ Okay. 10 MR. KEIMIG: They have aircady required that, and I j 11 intend to take action.  ; 1 12 MR. NOONAN: They have? l l l 13 MR. KEIMIG: Yes. 1 h 14 MR. NOONAN: I'll have a look at it. 15 MR.KEIMIG: When we surfaced this problem, I turned it I 16 over to NRR, by the way, Containment System Branch, because

          !        17      it was really out of our realm, TRT.              As Jose pointed out, g        33      it's not for us to evaluate those things.

19 MR. CALVO: Containment leak testing, leak rate testing,' g r.  ;

  ~

I  ;- 20 is part of the standard review plan, and I know is addressed'

                              -: y                                                           ,-

j 21 in the safety evaluation report. How much of the follow up

          ?                                                                            .    . ---                     \

22 they do after.that, I think Mr. Noonan is going.to determine. l

  ;-                              MR. NOONAN:

Annette, help me on that. .W hen we get 23 j b- back let's get sor e assistance to look at the record, to bring 24 l 25 the containment leakage tests and let them tell us.what.the ' f:. . .

                                         * ~~ tia-- W                       u -- .; Q.pg. . ,  ,     ,.       . . .

65 g procedure is, how they handle. it, any plants going through i 2 licensing--not Comanch,e Peak, but any plants. l-r 3 I might just mention agairi something that- i 4 first of all, 'we still think that there have been problems 5 in the past with Region 4 's handling of the allegations and e . v. < . - ~ l l e 6 so (orth, and that sometimes .they have not adequately investi,- l i 7 gated;.'but in addition .to that, I think a lot of the problem r , 8 with NRC and whistle-blowers and intervenors has been a lack, t 9 of communication, like what we're doing right now. I think

                                                                                                                                                .l 10    so many times that has been lacking.                                          I want to say again how I

11 much we appreciate all of you taking the time to come talk to, 12 us about this. I think this is a very important part of l 13 what should be going on and should have been going on all the 14 time, not just with this plant but probably with others as , 2 15 well. I think a lot of times it's been--a lot of NRC's s i i 16 problems as far as public perception has been due to lack cf i - g ;_ l communication a lot of times.  ; i IS l MR. KEIMIG: There was another problem that surfaced l 39 during our review of the containment leak rate test, and , 7

       '
  • i j 20 that was the applicant had committed to perform the test in 4

i l 21

                                   *   - rdance with 10CFRSO, App.endix J, which requires the 1                                                                                                                               l
                 '-                                                                                                                                      \

l 22 test to be performed in accordance with ANSI Standard, N45.4- l- _ 1972. While the applicant did perform a, test in accordance { 23 . 24' with-that standard, the data computation of the leak rate l

 "                                                                                                                                               I 25    te'st results were reported to us as having been performed                                                      -

l y' - .. ..

                                     .,           . I - . ..
                                             - 1 =-

5 ,:

                                                                                                                                   -l 2 nn!. . . .

l l

                                                                                                                         \

66 1 in accordance with a later Standard, ANSI 56.8, which is l i 2 not endorsed by the :RC. Now, because of the consistency i 3 of the data that was obtained during the test, the calcula-i 4 tional method probably---the calculational method by the [ 5 Standa'rd, Appendix J, requires the applicant to use as j

     -                      .                                                                                            t 6   opposed to the Stan'dard that the applicant did use--probably                                      I 7   doesn't make any difference.                        As a matter of fact, the
            -     8   Containment System Branch is also looking at that and has                                  :

9 come to that conclusion, but has asked the applicant to i 10 identify any other deviations from the ANSI N45.4-1972 i 1i Standard that they may have implemented during that test. I 12 MR. NOONAN: Let me interrupt. Why did they do it that la way? Why did they do that in the first place? C i 14 MR. KEIMIG: I don't know. 15 MR. NOONAN: " - - - "'WZGCJi$ga ;;.aMafinit%YtfWn~iGIRD , m --ca:-- _ g - -w 16 _-- Nr8 IDES %TOA@lD?!N.YC N[4 --' MQ g

        !       17  ,

MR. KEIMIG: What they should have done is amended the I i 18 FSAR. First, they should have gotten approval to do tne ' 19 calculations in accordance with the Star.dard. That wasn't i . l

              ' 20    done. They also should have amended the FSAR which was not l
        )       21    done, and they characterized that as being an. oversight.                                  I l

MR. NOONAN: The applicant did? ' 22 ) 23 MR. KEIMIG: Yes._ W they should not have elected to.

                                                                                              -- - n .c _ _ w g     us.g_the ANSI 56.8 method without our approval.

25 24R. NOONAN: Sounds like you basically I3 cd the problen , j l

s - 67

                                          '                                                                                             Why did 1            but it seems like the root cause is still there.                                                        i 2              it happen in the first p. lace?                                                                        !

i 3 1 MR. KEIMIG: We did conclude that the containment is 4 suf ficient to meet its designed function. 5 The next and last concern expressed by CASE-- 6 MR. NOONAN: Let me interrupt you. I guess we had  ; another member join us. We're on the record, so'if you 7' l. 8 wouldn't mind identifying.yourself so the reporter can pick , 9 it up. , 10 My name i MR. KEIMIG: The next and last concern expressed by  !

                                    }}

12 CASE was that unless ordered to do so by the Atomic Safety  ! l 13 and Licensing Board, the applicant will not conduct a test- , i i 14 ing program on Unit Two, but will rely instead on the results ? 15 of the Unit One ' testing program to support Unit Two opera-  ! 16 tions. The TRT reviewed the applicant'.s preoperational test , i f [ 17 ing program for Comanche Peak Unit Two as outlined in the  ! l

              ;                        g g l final safety analysis report and found it to be consistent
              ;                        19 with the !;RC Regulatory Guide 1.70 entitled " Standard Forr.at
              ;                                       and Contents of Safety Analysis Report for Nuclear Power g     ,

20 j .. 21 Plants", and also Regulatory Guide 1.68 entitled " Initial i 22 Test. Program for Water Cooled Nuclear Power Plants"_ . The , 23 8Pplicant is committed in FSAR .to meet both of these regula i i

   ).-                                 24-tory guides.

25

                                                             .The' FSAR Chapte'r 14.21 states that the purpose of the i

Lr s .. , . .....-. 17 . . . , . , , , , ,

                                                     ._..,.        . . . . . _ . . , . . -        ._      c ... ..               .       _ .. . . _ ,.

m

                                               ~           .-     -     . - . . . . . . .

66 I start-up progran for Comanche Peak steam electric station , 2 is to assure that the installed station structure syst' ems 1 3 and components will be subjected to tests to verify that the 4 Pl ant has been properly designed and constructed and is , 1 I 5 ready to operate in a manner that will not endanger public l 6 health and safety. That FSAR is applicable to both Unit One

7. and Unit Two. Therefore, that statement is applicable to l I

8 both Unit One and Unit Two. 9 We reviewed the preoperational test schedule and Figure, 10 14.2-4 which is the initial start-up test schedule. Both  ; 33 indicate that the schedule for conducting the preoperational. tests is applicable to both Unit One and Two. We also I 12 I 13 reviewed the Unit Two acceptance test preoperational testing j4 dated July 18, 1984.. This document provided an index of 15 acceptance tests and preoperational tests including test 16 numbers, revision numbers and procedure titles, and were ,

        .i l     projected in Unit Two testing program.                     We compared the i        17 gg          Unit Two test index with Regulatory Guide 1.68 and with the ;
         ;         39          Unit one index and found them to be consistent.                       Only systeras 20 which are shared by Units one and Two and were fully tested l        21 duSing Unit One testing progpam were not scheduled to be                               l retested during the Unit Two preoperational test program.                              ;

i I can 9 1 ve Y u s me examP l es of systems--waste gas, system l 23 control room,. heating and ventilation system, telephone and I i 2a, radio system, and so forth--and the basis for not testing l

                                                              -                                                                                 69 1:      them again forl Unit Two-is that they were tested satis-i 2-       factorily during the ' Unit one testing program, and when the '

3 Unit Two testing program is undertaken, those systems will  ; 4 iae in operation. - 5 So we concluded that that concern was without basis. 6 overall, we concluded that there was no information , that surfaced during our ' review of those concerns that would 8 preclude the ASLP from making a decision pursuant to i 9 10CFR50. 57A. We did find sone potential violations, but 10 nothing of any safety significance or with any generic gg implications subject, again, to a review of the findings of 12 the OA team. y 13 MR. NOONAN: Based on what he's found out, they haven'tl ' d 14 found anything of safety significance. ? p._ ' -- . -

                                                                -n-g              n ._a % =; =_m & y guy.e y g m y .                                       .
                                  '1EFm
               ~
                                                   " -   '~'          '                         -"

16 -- - 37 I might also mention that a lot of the gg things that I think you mentioned were allegaticas in there.

    ,' -                    39 I'm not sure if you were working from a summary, or were you ,

w rking from our actual pleadings that we sent in with all a 20 .

  • the attachtr.ents?

8 21

  • We're working from the proposed contentions. l MR. KEIMIG:

22 . , y I think I characterized them as' concerns. They were not

 .                         ..                                                                                                                            [
  . .a
 ~ ~ ' -'                             .really' allegations, but because they were technical. concerns 24
                                                                                                            .                                            l
                                      . expressed by you and the. Board refused to consider .them, we 25                                                               -                                                          t 1

4e

                                                 ,-          --r,-----                                   .           ,_.          ,,

jf "' *' \ ,htr . , . ... ,

70

              'l      took them as being legitimate concerns and did review them.

2 I just wanted to.be clear that all those 3 were' based on the documents that we received f rom the appli-

              -4      cant.

5 MR. SMITH: Can I ask.a question? You spoke earlier i 6 about communication. 'I was thinking of that'as I was read-7 ing the area about Unit Two testing. Did you actually e

      -        8      receive information that led you to believe that they are 9      not going to test the systems in Unit Two?                             Did we under-10      stand that properly?

11 I'm not sure. That's one of the things that l 12 I need to go back and look at, our original contention. One  ; 13 of the things that I personally was concerned about was that, 14 . they would use it as the basis--since they're asking for = l i l 15 an operating license for both units--that they would use that l 1 16 as a basis for saying go ahead and give us a license for

      'I                                                                                                                      .

j l Unit Two also. In other words, they used the test for Unit i

        -     15 !. One whereas they actually hadn't done tests for Unit Two.
    .,U       19      'Ihat's one of the things that I was concerned about.                                       I don't I                                                                                               -
        !     20      remember the exact wording of what was said.                                That's one of
       .4                                                                                                                      l the things that irar.ediately comes to mind that I remember.                                                      l 21 2

g MR. KEIMIG: That's the' way I thought that yo6 'had con ! I strued that. . 6 Also,;you n'ed e to remember, too, that what 2a. we were asking for primarily in this contenti.on was tliat we' !' g

                            .7

71 1 b wanted discovery abou't these matters; and I think at some  ! i 2 point in there we mentioned that we weren't certain. how l t 3 much or the extent of the problems that there might Le, and I 4 we wanted a discovery to try to find that out. In effect,

   .                5    what y'all are doing ;is doing some of the discovery on it                     i 6    now. I'm awfully glad to find out some of these things, and 7     like I said, we'll probably have a few nore questions later. '                     l 1
8 Within the context of the hearing, it's a little bit 9 different from when you're asking for discovery about a I l

10 contention. It's a little bit different, in other words, l ii from making an allegation like "I went in the field and I i i 12 saw something wrong and this is what it was."

         ,        13             MS. VIETTI:     We went through the various documents,                 j 14     hearing transcripts, depositions, Office of Investigation 15      reports, old inspection reports that were written by the e

16 Region, trying to get a comprehensive list of technical i i g- concerns, some of which were allegations, sore of ther had l  ;

         .-}*     jS   i  come out of'other areas that were concerns, and that's how l
  ,.i             19     we grouped them and gave them to the people in the TRT to i                                                                                                  ,
I 20 investigate. But that's how some of them get all inter-  !

j A c:e j 21 twined--they're used to using the word " allegation", but l

            !                                                                               ~~~

that's not necessarily the case. - - 22 f 23 We were 1 king strictly at their doc,uments l ,

 ')-                      when we developed thhse concerns.             That was the . basis for 24                                                                                     9 25 the contentions.

a

                                             - * ' - ~ *
  .                                                        ~~ s-                          ..    .          .

I e + .p e,

) 72.

                               }                MR. NOONAN:    Juanita, 'if it 's okay with you, I'd like                 !

n 2 to take a break at this pointi in time. l 1 3 I (A short recess was taken.) 4 MR. NOONAN: M?rk Walsh has joined *this group and we'll;

l. 5 bas'cally talk to any of the concerns that he might want to !

6 address--have us address to him, but I want to know first: i 7 Do you want to go through this first or do--

        ~

8  : Why don't we go ahead and start with these 9 and I'll try to work t.hese in as we go. Then if I've got  ! g.) anything right at the end-- 3g MR. NOONAN: ' we have people here iror. the civil 12 and mechanical area and we also have--in fact, I talked about I '

  .                          13         the HVAC--we have electrical and prestart testing area.                  In !

14 l order that maybe I could let some of these people go horta, 15 l would you want to talk about the 'HVAC firs t or--it'n your i 16 option, whatever you want to do.

           .I                       l j               3-                              Well, the HVAC.           It vr.s written in a report
         -i                  jg         with the control room and I pretty much forgot about it until
       .l                    39         the TRT came along.
  -                                                               Just looking, the ceiling in the control
             .1                               -
            !               20          room I had forgotten about because of the same report.                 It l

21 was the investigation by . The HVAC p oblem is 22 when he went to investigate it, Am%3E2EtiisagadulutAOp 23 He looked at the HVAC within the ,. Q-: - 24 ntrol room. The HVAC within the control room was seisricall'y a-r qualified just looking at it.

                         . 25
                                                                                                                              \

4 i c' .' .A

                                                                                                            ; y;  , , .

73 y i 1 R. SIIAO : It was also sitting on top of the slab. 2 There was bracing. Okay. It scened'to b'e 3 , race 6. in the- three principal directions. It was t;.e i 4 , Containment Building that.I saw one particular line duct, E -- S,l 14 ps/maybe thirty'.fsef Jodi$tinbidg.up the side of bie q..,1 g l-6 congu: ment that did not contajn any vertical restraint excei.t e -{ t cr .e Et G..

 ~

7 the. duct' itself, mPzdinsuci#.eegydorhontalmregraintag.,

                 ,_                                    w s. J                                  &            >                           .~          .

8 'e'n t r

                                                                        ?_12        ance4Igi'a#LdigectiogpstfgehercoJLteingen$r.g There          -

9 was sorce restraints that would be radially--of the contain-ment--to hold it from falling in, but nothing from going side-ways or vertically except the duct itself. 12 There was other areas that I saw that were similar within ( 13 the containment. Offhand, I can't remember exactly where. g They don ' t stick out. l a_ l-1R. ShAO: So he's concerned mainly sideways restraints. I would think--I did not see rnany sideways

                                ,.,               restraints throughout the building. The containrent was a concern of mine while I was there because Bahnsen was h.

yr .-  !

   .           v 19 l -supposedly finished, and I can understand if they're not done l
      .!      h             -

i witfil&-the Safeguards Building that the seismic restraints a g . 20 4e g j " ~ niig M no't k$N Ep yet; bu M h h b- ffajf_ w y b_g

               ~
                            . 22                      eW KQBhware appp_osp,dAygo[egnAdhere*wamasaqeke_~sltrAJnttsy                           _

y. u. 23 The problem may still be within the safeguards Buildinc.,or - c

                                           ,      the Auxiliary Euilding excluding control roor:i.

1:R. !iOONA!i: .Okay. Dick?

                                                                                                                  .=**

3

     % 43 NGE%4thM%)s4g g%% e'"593 % % % IS*    =MN                       "'

4 74 1 MR. BANGART: We summarized the work that we did and I  ! 2 think that we did und'erstand the concern when ue finally  ! l 3 looked at this allegation as part of the TF.T. Indeed, 4 Eahnson problems were well known, have been for sece t'ime, I and there's been a great deal of both inspection on' the part i 5

    ,-                          6         of Region and also TRT, and effort on the part of the Utility, 7         andlthey hired a consultant to do an analysis of the supports'
                                                                        ~

6 and conductors associated with the containment or the venti \

                          . 9         lation system inside containment.                 Indeed, there were dis-10         crepancies identified in the fabrication and construction of it         the INAC systen.       The engineering analyses that were conducted i

12 by CCL which is--we previously put the title of the company , f

            ,                  13         in the record, I believe--but the bottom line is that the 14 ,       engineering analysis supported the accuracy of this system.

l B 15 Is this the same company that did the i 16 original analysis?  ! l l

              .j               g; MR. BANGART:    Yes, it is; Corpcrate Consulting and

{ IS Development. They expanded it through a four-phase evaluation

               ;               39         that--I have forgotten the date that the four phases came i
               !               20         out--but they did this statist.ical analysis of the worst                                               ;

\ *.  ; .- j That report has not been issued yet, and I hesitate l 21 cases. t 22 to give you the numbers'because it's too easy to co'nfuse  ! t 23 ven with that 24  ; 25 4 one, therc Vas still something 'ovei- 98 percent probability  !

                                                         ..                                 t.

M .~. v.: ..w

                        .we +:.c .s: .-u-                         .          ,

w .n.w . mm .w ,.m .

75 a

                 }   of meeting the requirertents.                                                                    -

y l - l 2 PR. NOONAN: Did they go back and do that analysis , 3 given that there were some deficiencies? l 4 MR. BANGART: Yes, tney'did. . 5 NR. NO~ONAN: And they recognised those dc#iciencies and' 6 they went back and did the analysis? 7 MR. HUNNICUTT: The four. worst pipe hangers are listed i

      ~

8 in the report that I've got in draf t form, and no way do I

  • 1 9 rene:ter the nurlers.

10 MR. NOONAN : N 8 N b m cri$ ng Y Y b h 9 11 '3GE - ' UIEINNN' CI*##DUdE1*#ESI?d 1 12 MR. SHAO: Did they do an original at.;1ysis?  ; 64 2 13 MR. HUNNICUTT: They did a supplemental if I remember l 34 correctly. 15 MR. SHAO: Why did they do a supple ^m ental? i 16 MR. HUNNICUTT: I can't answer that questien. I ccr. ' t i j ;7 know. Evidently they did the original analysis. In June , i 15 f '93 I think they finished one and the next one was latpr, s, 39 if my mecory serves me correctly. O i s 20 MR. CALVO: This report has not ye*. been made available

      .                     v
        ,                                                                                                               l to the NRC, therefore.

21 i .. .. MR. SHAO: Th se are seismic category one structures, l 22 right? 'Ibey should have original calculation. 23 p 1 MR. HUNNICUTT: They probablp do. l 24 25 ) If the original calculations were all right,

                                                                                                                                            \

k c t

1 M - 1

              ; l        why did they have te; do another cne?                                                                                                                        l          l 1

s 2 MR. 3A11GART: Because of the problems found, l l 3 , JGP " CNN-J N W d'K$ W U:RCF2thec;Zi;t'.It-irsgrm*Sd-in3 MM 4 K0WMDWi% it was necessary to do a re-eva$.uation 5 o to deternd11re what worst case wan; with what vae fc and, and , 6 the wor,st case that I recall being found was cne su; cort i 7 related to it that had two welds I::issing or underrire!!--I  !  ;

      -      8   '       can 't semember right offhand--but t.here was a problem with this one specific cno and thrce other ones that were warst
9) ,

i 10 case. As I say, part of it Va can c.nly go so far with the draf t report before we start getti.ng en the lird that we're 33 l n t supposed tp he on, specifically, releasir.g draft inferra' l 12 13 tion. Ac I say, the repcrt is getting near fir.al review. , s  ! 34 My concern, though, wcs root so cuch f.f a. ) was p rn , was just total 1aci. of support ' 15 **' - .-= , * --- u mW _ _ _ . m . sjei nck - nL.cnq> nenri ng ' # "hn -gngp, ort on - i-- -m

                                                                                                                                                   . a par ticular iuct

_. _ , - ~

        ;                wn q ,,.LL.the3pduct_went thro _uch _do ficienc.ies ,f rorn                                                                          .C9_ OCg-I
        . 1                                                          __.__ - -- ---- -                                             _ - -

i i g gg _does not _tcll_ the! _they__ne_ed a supp_cr_t 2 ,_ _m;. . _ 1 l

        ;                           MR. B A!iGART :                 That point was rain d by                                                                              earlicr.

( ,_ 39

  • cemitted at thht point in time to go back and look at 20 l  ;
   f:                    the %e~si ned and' installed'sVpports ar,i vet back to 'you to                                                                                                 l confitm whether or not these supports that you? r.e cc:icorneri 22                -                                                                                                                                                  -

h l 23 hbout perhopr. may not be there or, indeed, are or are-no!. i le- 1 l the2a. If they are not in any r,ense thcru, we'll find out  ; j 24 ' l

               ,           why they are not there.

22 l < 9

                                      *6 "

e oeos.or . * * , 4

77 That was the concern. l 3 And the're's another aspect of this that  ! 2 . 3 we're concerned about in the overall context of this whcle l and that is when things were - { 4 thing and any of these issues, done and if they were done because the Utility noticed them 5 i and did something about them, or if they were done because

 ~

6 7 they were brought to their attention by us or by somebody else,"and whether or not they would have been caught'if theyI

                 .3 9

hadn't been brought to their attention by some other means. l , In therwords,whethertheywouldhaveactuallybeencaughtl 10-There's l g by their own OA-QC program in normal operations. When they did another thing that we'd like to find out: i  : 12 13 what as far as if the supports are there now, when they put i y them there and why they put them there, that sort of thing. I MR. ENiGART: EnFey%gWf _-f e e ding,.,,thes cQp.db - - y 15 _

                                                                                                                     ~

ie ,

       .                                                                                                                            I r       s MR. SHAO:              Why g d,,_they redo _thei_r a,nJ1 ysis?

I j g7 MR. MOONAN: We tock some action on this and I'll repeat g i that we said we would go back to see if the supports are g9 i cre. May e ck codd also check and see when they were  ; 20 - - , put ih there, have they been there all'the time, were they

         !          21                                                                                                                 '
         #                      added, when, what time?

22 MS. ELLIS: If they were there all the time, we've got l 23 J  %. _ _ _ _ _ s, a pgtm.c.uc,.,xould_like to show you. s .

                     ,,4 MR. NOONN4 : Also,f Larry's concern is why did they go 23 i

e

            ^                     --                          -

r-- 7.;

78 Did they do it because-- I 1 back and redo the analysis? 2 MR. hUNNICUTT: As I recall, it was because of the  ; 3 identified problem. 4 MR. BANGART: That's.a fact.- 'We know that . Concerns i l l 5 vith'Bahnson have been well know,+as'I mentioned, for some i 6 time, and there has been sepa ate action taken_on the part , 1 1 7 of the NRC to deal with Eahnson as a vendor who's doing i e 8 work at the power plant,dable,dJo_de_Mcicat,yor]t4n,their l 9 part, and what was delin_quent_ in_th_eir_oyggap at 10 allowed them to have--so that's been a two-pronged effort, _

                                                                                                                  ~n, i

1 11 I know, in regard to the Bahnson Company. , I i I Will information about that be included in,  ; . 12 I 13 the report also? j l 14 MR. BANGART: That's not in our report. I believe j g  : 15 that's being handled through the vendor program people d l

                                                                                              ">mmnenemutsp                     ,i                 l
                                                                                   -                                            *~~.                '

16 i- l located in 1:ashington. i 1; l'R. NOONAN : Is that Elvis? , {-.

     $                   1, "R. DANGART:               Garrizet.

j 13 U 10 . MR. NOONAN; Is that report available? . [f k hg 20 , MR. BANGART: I don't.,know if there's been a report  : 1; n s . - y .. . i issued. I know there has been correspondence between the . 21 - l Director and Victor Young and the Bahnson Cor.pany. I've ' .t

                  ,,,                                                                                                             l'L 1 st track of exactly the sequence of evNnts that occurred.                                         I) 23 g

I know that Dahnson has been inspected by the other program ^ l branch. Where matters have evolved to at this point in timet 25

                                           "*          " * * ' -  ***e o ne ,    e              ,

ii

                                               . - - -                               . . . ~ . . . - .           .

79 i I I I can't tell you.  !

                                                                          ~

2 MR. NOCNAN: Annette, maybe you~could make--let's check l 1 3 with the I&L people back in Washington anc find out wherc 4 that is and if we can releaue it, if there's anything that

               <       5         can be made public at this time.                                      .

l

                           )

6

                                                            ,_'s That another n_g x-~n=     aspect      ~ o_f the c:
                                                                                                                           , applicant's
                                                                                                                             ~ ~ ~cn- ~    y     ,

QA-QC program that we're interested in. How is it that they ' p g 7.m mgr rm..n ~__ - =_sanamnsassaazsa 8 had a vendor and did not know the status of their work?  ;  ! i 9 MR. BANGART: That'sanothermatterthatweareinvolved'%. )

                                                                                                                                                 ,      ./

10 in just at this very mo;r.cnt. We specti g. g g i IPM k S.dE."M M M Il'J 22 1IS. "nt's_veyd_of gug ge g gcr II f . 12 Tha_t o - inspection was conducted late this summer, _ag tha t _ ~- -- ---

                                                                                                                                                 ,  g        ,,

13 report is in final stages of preparation. 8

                                                                                                                                                   -4 y                   MR. NCON;O;;                     just stcpped out of the room.

lh Let's I, 15 go off the record for a minute until he gets back. t 16 (A brief recess was had.) i I g-l MR. NCONAN: I'rt oing to co back on the record for a l g3 r:inute while is out of the room. Maybe

          ;                      would like to talk about ser.e things that she brought with
3. , ,19  !

i ' i 20 her. l 21

                                                         \ There's on'e that has to do with tlie                                                               .

j-

                    , , ,        electrical information, and what I've brought with'Fi is                                                       !                    !

e a 6 ' 23 Nonconforrnance Report E-81-00088 dated 3-25-81. This we 1 24 rec ived op discovery--I don't knos exactly when; it would Y, 25 have been in the time frar"e of March to about, rr.aybe, April ' 1 p

i l l 80 1 or so of '82--and at that time this was still oge,n I  ! m_s four safety-rclated Class 1E meters (2 diesel

                                                                           ~

2 s i S  ! 3 generator watt n.eters, 2 diesel generator var n.cters)were 4 retr.oved from the _instalked r-nin_ cont n1,boarkwfTnout' pro- _ - - l 5 cedure, were sent off site for modification to an unapproved

                                                                                              %w                                                                           i
  ,'                   6       facility, and were reinstalled in the control board without            - - -

y -~% .

      .e
                                                                                                                                                               ' I #.

7 procedure. l 8 DCA 9714, Revision 1, was prepared / approved following  ;

                     -  9       the work clearing sirilar modification of Unit Two instrune:r-,l I

10 tation. The quality status of the four instrunents in the l 11 control board for Unit One is indeterminate as a result of l l 12 the work performed on the safety-related instrument / board , t 13 as stated above. 14 This is one that I've been concerned about for'scte  ! I time, and I'd like very much to know what happened. Also, I 15 16 I=L'"*'" 14k _am_gg t,o know how all of this cot done outside -recedure.l g3=3mmYgggmer~a--

              .;                                                   p,
              .j         17 It appears that they did all of it outside procedure, took i

1S it to the unapproved f acility, brought it bach and reinstalled l

                $        19 it outside of procedure, and then set up a procedure whereby ,i 7                                                                                                                                                                '

20 theycoulddothesamethingforUbtTwo. I think clearly 4 & ,- ., . l 21 there' areg,oc.e_duralg.;i,ogQpgs involved, and one of the h r

                                                                                                 *% sump g

22 things that I'm concerned about, too, is whether there were r 23 also safety implications with it. MR. NOONA'4: Did you read down to--what point? , 24 I read all of it there. 25

                                                                                                                                                                        ~

I 81 __ f l itR . NOONAN: Did you read this (Indicating)? l f

                                                                                 ~

2 No.  ; I 3 MR. NOONAS: For the record I'd like to go ahead and , f 4 refer to-the following: It's referenced document Gibson 5 Hill Specification 2323-MS-605, c'r.!1 DECDS-1700, Revision 1,1 < It was dated March 6 paragraph 3.2A, reported by John Lowry. C. -[ 7 25, 1981, It had a QE review approval signed by Mr. B.

      ~

8 Scott dated March 30, 1981, and it says, " Action Addressee

                                                                                                             " Electrical Engineering                           4*.

L. Popplewell", P-o-p-p-1-e-w-e-1-1, 9 i l' 10 Department." MR. CALVO: Ke'll look intQ jt. 11 . ' xdwa 6S M C,. l l ^There is one other deal that has to do with j 12 - , l

        ,.                    13 electrical very quickly, because I couldn't find the documenti to bring it with me.

There was an audit done by the appli-14 can't and it's one of the exhibits that we were going to . 15 I'm

            ~

16 introduce into evidence, but I don't think we ever did.

              '                       I    not sure if it was accepted into evidence or not.                                             It might i                j-have been when we had a bunch of things accepted at one tir-e.

IS l s 2 19 It had to do with--I don't remember the details--it had to do' i with having the wire which was supposed to be used--it was

               !               20
  • J .

21 backgraded or whatever youj call g ,g g g e l r much smal-le:. We didn't have any electrical 22 amewsusae sM;-si zed wire.w;spg g p from . 23 experts at the time I came across this, but just . I

                                            ~ general knowledge of some of our members and some of the                                                          1
                                 ,y it appeared               I pc ple that looked at this particular document,                                                                     i, 25                                                        ,

ma __ __ __ _ _

82 Il .to us that this could be a problem with using the s: caller 2 wire and could also possibly cause fires and this sort of  ! I l 3 thing because of the use of the smaller wire. I'll try my 4 best to find that. If not, probably I' can identify it- by , I 5 our exhibit number, and maybe the NRC can find their copy; i 6 but hopefully we'll find it for you. That's one that I  ;

                                                                 .                                                             i 7      just happened to think about when we were talking about ser:c '
 -                                                                                                                             l 8      of this stuff here.

9 MR. CALVO: The significance of that--I guess we had l l 10 to know what kind of circuit the thing is used with. Again, i 11 we got to establish up to what point that wire--what kind of' l I 12 current it carries, what is the significance of having one 13 smaller sized than it's supposed to be. 1 14 I'll try to find that. , l l 15 MR. CALVO: Keep in mind some of these things, you pick , them up from the preoperational testing. You keep in mind I 16 E i j  ;- l that this plant, Comanche Feak, it was the circuit required i j IS for safety. According to technical specifications you are l 19 constantly checking the circuit electrically so it is very

    'b-

[ 20 iCPortant to relate this to.the circuit and find out what i ,,. b * -~ 7~

        ;       21 kind of system is involved.              Then the significance will be
                                                                                               ~    ~

22 established. 23 MR. NOONAN: Is it okay to have Jose call you the first f g of next week?  ! Yes, that will be fine. 25 j 3 1

                                                                                                        ~~-
                                                   .                     ..       ..         '.                    V S3            )!.

1 MS. VIETTI: I know that Gary Mozeno, the lawyer en this' N l' i 1 2 case, keeps fairly good files,' so if somehow we can comuni l J l l 1 3 cate and direct him to a particular document, ne r.ay very 1 4 well have it in his files. 5 I know where it is on our list of exhibits. ! i

               .6      If he's got them in order by exhibit number, which is what                         I f

I 7 I'm hoping, he'll be able to find it very quickly.. l

 -              8            MR. NOONAN:      I think we'll go back now to the stuff that                                     l
             . 9                    had.

i

           . 10            MR. CALVO:    Let me ask a question.                  Do you have any more' 11      electrical ones?

12 I think that's all the electrical stuff that , 13 I have. j 14 MR. BANGART: Any more liVAC-related items? f l l 15 No. 16 MR. BANGART: If there are any other matters, Doyle and ] ' 2 i g- I are Arlington Regicn 4-based. If there is anything you

   .'i          33 i   wish to bring up--
     ;          19                         There are some items with the liner.                    I        -
     !         20       don't know which group would be--                                                    ,            .

J

  • 21
                            -MR. BANGART:       We were also a part of the TRT and we                                ]}
                                                                                              ~'

i didn't address that particular issue. i 22 MR. NOONAN: Which liner is that? 23 24 The--liner plat,e_of the containment. ( MS. VIETTI: Is it the walls in the spin-filled coil

               . a.                                                                                     g i                                                              A                 r        m               W                  ,

e f, w  :. h b

\ f) l l 84 I liner? l 2 No, the- containment liner. 3 i'R. NOONAN : When we get to that, I think that will coce 4 under Larry's area. . 5 .MS. VIETTI: Why don't :you go into it a little bit l , , 6 further and rnaybe we can identify it. ' 7 MR. NOONAN: Let's go c'ff the record for a minute. I 8 (A discussion was held off the record.) 9 MR. NOONAN: We're back on the record right now, and 10 we've decided that Dick Bangart and Mr. Hunnicutt can go gj ahead and leave' this reeting and the rest of us will stay l 12 here. l e l

 ,            13                                 I think what I'll basically do is we'll start with the
              }4   concrete area.                                    We have the people to address concrete.              Let's I

15 go, ahead and talk about.that. I 16 MR. SHAO: Let me introduce Bob. He is one of our TRT ! I'

    !         17   r.cmbe rs .                               He's retired from the U.              S. Corps of Engineers.       !

[ I i IS- He used to be Chief of Structures at the U. S. Corps of

    ;              Engineers in charge of these construction. He's now in 39 i

20 Massive Structures, and he was a past president of American  ; 5

 ]

i 21 Concrete Institute and he also was past director of ASTM.  ; I think he is co-author of one of the handbooks you lientione g . [, l 23 With that introduction, he's working on a couple of j g concrete areas that you have ' concerns with, r.aybe. f

                                                                                                                               ;                  (

25 This is the same stuff that you probably .

                                                                                                                                               ~

_g _u -

85 1 already have. This is the Richmond insert stuff. Do'you l l 2 have a copy of that? - 1 3 MR. PHILLEO: Yes, we read that. l 4 So you've got that. Why don't you go ahead ,

                                                            /    .                                                                     ,

5 and kind of go through what you told me earlier for Mark's j

 ".                             6    benefit, and as you go through if I have more questions, 7    I'll holler.
   ~

l 8 MR. PHILLEO: That insert thing apparently got you 9 concerned about strengths of concrete in general. In fact, i 10 I think somebody threw you a curve in saying that all the i

                               ;;    concrete was designed for 4000 PSI and the actual strength                                        !

t 12 was 4500 to 5000. ,

       ,                       13                                    That was the applicant.                                           j I

34 ,MR . PHILLEO: Yes, I sensed that. Because, for instance, i 15 y u went through the records and picked out 36 lai,cratory-16 cured standard cylinders that were below 4000. So we went  ! 3 I

                               ;_    back and looked at all the mixed designs for all cylinders f

I I 33 that you cited and found that without exception those 36 39 that you pulled out were for a 2500 PSI mixed design. Even

 /       j

[- l 20 the applicant--and I might--there are some things that even 8

     ~

[ f 21 Regib'n 4 hadn't stumbled on--but, in fact, all those lower  ! l i* strength ones were designed for 2500, so that prett9 well g eliminates that, that there was any unacceptable concrete as judged by the standard acceptance tests. , 4

Before we go further on that, there were t .
             ~ . . ~                       .....,,,._,,.-..........
                                                                             . . . ,       s.      . ......     . . .    .   ,
                                                                                                                                               }

86 l 1 a couple on page--do you have a copy of our Attachment D? 2 MR. PHILLEO: Att'achment D? Right. 3 There were a' couple specifically on that, 4 on page--I guess it starts on page 2, through page 4, where I' 5 it's talking about the concrete pbur for the Reactor No. 2

  .'                 6      cavity wall.                  That one in particular was a dUncern.                              It --+uu
         .                     .w_                                                                                                     ,

7 didn' t appear thqtithat' nneJ" pWe't3 55f'lfted m m _- _ _ g ,_ 8 MR. PHILLEO: Yes. There's a question of what needs l 9 retesting. I guess according to the specifications you could 10 interpret that there would have to be some evidence someday gj that the field concrete did acquire a strength of 83 percent of the standard cured cylinders. I think the specifications 12 13 are a little vague on that as, in fact, are the ACI's, the 14 ACI Code f rom which they were taken. 15 As I mentioned, the ACI Code is a building code and + l 16 concentrates on building elements, which is norral bear and i  ! I I i 37 column and slab construction, and so it has very conservative i IS requirements for strength that has to be attained by field , 1

   '-      ;          j9      cylinders because it's geared towards fast-track construction i
    ,      [          20 where..they're stripping early and the concrete has to 7, ,

e 21 support itself, and if you back off at all on those early h i i strength requirements, you have collapses as you do, inceec, 22 i 23 g t in some cases. l A substantial amount of the concrete in the project is i 24 l f that sort, but a larger,part is not. They chose to make 25

                                                            "***"*********e        ,,      _ , ,     , , , ,

87 I i 1 all the concrete meet that one rigorous spec, I think, pri- l 2 ) marily because it's easier to build and inspect if you don't] 3 have to decide which concrete meets which class. 4 I have with me the ACI Cold Weather Standard which 5 gives recorrcendations for different types of construction,  : i 6 and those recommendations for non-fl.exural members are that- ,i 7 in a climate where they're going to eventually get enough I l 8 heat from the environment to attain full strength where ( l

                '9           they're not loaded in early age normally requires protection ,                        .                 \

1 l 10 for three days and then they just assume that eventually the l j 11 heat will--get the heat from the climate and reach full t l 12 strength. So it would have been permissible for much of the con- f 13  ! I l 14 crete to be judged that way, just to protect it against l l and - 15 freezing until it's strong enough to withstand freezing, l t 16 i just let it wait until spring and su:rner and pick up the i i l

i. 17 strength before it needs it. I
                                                                                                                                     )

j . 15 They did not do that for, I think, understandable 19 reaspys s y per,e ig g g g e ,ogc n e e, ,i 20 cyginde r s,th a t,yo u.,cJtedg.ha t.,.did,.notyc3.pgge cents of the specification. - i 21 mans:mesensev - l t You said some of those mixes were 2500-pound 22 mixes. The mix was designed for 2500.. Was the analysis 23. where that concrete was used, did they assume 4000 or 2500? 24 MR. SliAO : This 2500 PS,I mix is mainly out of those 25 i

                                                                                                                                ~

88 l 1 so-called filling concrete. It is not structure concrete. - 2 So what they do is excavation, rock and everything-- 3 Like mud mat? l 4 SHAO: Mud-mat, yes. It's not structure. 5 So essentially it was non-safety related.

                                   - J                                                                                                           t
  ,             6          MR. PHILLEO:     That would'be a good guess.                                         I'm not                          .

i 7 prepared to say that on the record because you can design

       -                                                                                                                                         I 8  perfectly good structural concrete out of 2500 PSI concretc.

9 I really am not in a position to say for sure that there's 10 no safety-related concrete. f 11 MR. SHAO: It may be safety related, but the thing is , i l 12 mainly the filling concrete is not.really structured. Mainly, 13 ' supposedly they excavate too much the rock and they fill up l l 14 with concrete and so on. i-15 ocumen g g ggcjived,,J he fec,uiremeg ! t 16 r yas. gm r g p ~ l l 17 MR. SHAO: But these are actually 2500 PSI. l j 16 MR. PHILLEO: I've identified the mixed number on every

      ..;                                                                                                                                          I 19   cylinder cited in Attachment D, and every one of those with                                                                    !

t l *

   ,-    i . 20   the double asterisk, the d,ouble asterisk indicating the
         ;               m                              ...

E 21 standard cure, has a mix number starting with a three. The . code is that if they start with a three, it's jus't 2500 PSI. l 22 g

     ^

23 If it starts with a one or a two, it's 4000. I have this [ piece of paper documenting all that. f 24 25  : ! Could we got a copy of r. hat? i

89 I MR. NOONAN: We're going to put this into our safety l I 1 2 report, and I'm trying to get this out within the next week. '

                                                            '                                                                                l         l 3           l'm going to say that tongue-in-check a little r,it.

4 he don't want to push you on it.

 ,                             5                            MR. NOONAN:         You're not pushing me.

i They used the--like the Swiss hammer or

                                                      ~

6 7 Schmidt hammer--on the 2500-pound mix. I'm concerned with t., .

         ~

8 them using a Swiss hammer on a 2500-pound mix, design mix,  ! 3,

                            '9 and quali fying at 4000-pound mix ori something that--they' re 10            not ecuivalent and they're testing--

l'  ! 11 MR. Fl!ILLEO: I would certainly be concerned about th a t ,' t 12 too. I have no evidence that they did. The concrete that 13 was most at issue was the 4000-pound concrete and as near as 14 I can figure out from the records, they always compared a 15 questionat,le 4000-pouno concrete with a confirrec 4000-pound I 16 concrete. There's very little of the 2500 PSI concrete that

           .I                                                                                                                                   .

l i - ; I can run down. I've never seen any involved in the Schmidt

               .A                 ...        .

h , hammer tr. sting. [

             ;                                                MR. NOONAN:         llave we answered that for you, Mark, or                       j
 ,,,,                          19 2

l3 M J C) think there's something else we want to go back and f 20

  • p.

l do for you? l 21 22 - 2500 is new information to me. 'I have been - 23 going through the documents, and they were testing apparently 1 4000 or 2500. 24 MR. PilILLEO It seems to me the applicant was pretty  !. 25 l

                                                .a 90 l                                 1          vague on this point, too.                                    Just to start running through 2           your document here, we'just turned the crank on getting the                                                                                                 }

3 printout of all the mixes and identified each one. It just 4 turned out that all 36 ' cylinders that failed 4000 in the )'[ 5 standard cured cylinders were 2TOO p'ound mixes. We didn't 6 expec,t that. That's just the way it turned out.

     .                          7                                        There's several aspects of this that bothered S           us.       Part of them have to do with what you're talking about I     4
                           9              and partmofm                                                                                  tui;RhhrA*        I think                                   ;
                                                                                                                                                                                                      ,         l 10            it's pretty self-explanatory what our concerns were about the                                                                                                       1 11           ma-dQ@t because I think there's obviously some real prob ,l l

12 g.s here-because they commi_tteilo_coahead _ and _ test ay of' 13 (these; obviously, they did not do that. j 14 It appears that some of the tests did not have every-l 15 ? thing that they should have had contained in the documenta-16 . tion along with the test.  ! I l.

        ,                                                                                                                                                                                           }
       '!                     17 l Another thing that bothered me was that some of the
        ,i                    15            information attached to the nonconformance report which,
                                                                                                                                                                                                      '#MW.
    .,'                       19            as I understand it, are supposed to be complete documents.

I  ! i 5; i 20 Supposedly what we got on discovery of these nonconformance

c. .

g .( reports were the complete documents. l 21 If they were, some of l i V f 22 the information simply was not clear in here. I'll get into, 23 that in a minute. It has to do with the cracks in the base

                                           . mat again.        This one in particular, this Reactor No. 2 24                                                                                                                                                                   g 25             cavity wall, was one that I yas really concerned about. This' k  s
                . _ _      .                       ._.... -..    . . - . ~ . . . . . .                      . . . . .                                                                                       ...
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