ML20211B084
| ML20211B084 | |
| Person / Time | |
|---|---|
| Site: | Byron, Seabrook, 05000000 |
| Issue date: | 08/05/1986 |
| From: | COMPUTER INTERFERENCE ELIMINATION, INC., NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20211B057 | List: |
| References | |
| NUDOCS 8610170124 | |
| Download: ML20211B084 (200) | |
Text
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BYRON UNIT I AS-BUILT DRAWING 3
REVIEW AT CIE, INC.
8:25 a.m.
Tuesday, August 5, 1986 2129 - 152nd Avenue N..E.
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Redmond, Washington ORIG.NAL Debra-Rossoff Dean Moburg & Associates Court Reporter 1610 Pacific Building seattle, Washington 622-3110
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1 IN ATTENDANCE 2
REPRESENTING CIE, INC.:
Schuyler Mitchell 3
Scott Nicholson 4
REPRESENTING U.S. NUCLEAR Duane Danielson REGULATORY COMMISSION:
Isa Yin 5
7 MR. DANIELSON:
Today is Tuesday, August 8
the 5th, 1986, at 8:25 Pacific Daylight time.
9 Members of the U.S. Nuclear Regulatory 10 Commission's Region III of fice, located at 799 Roosevelt 11 Road, Glen Ellyn, Illinois, are meeting with 12 representatives of Computerized Interference Elimination,
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13 Incorporated, at 2129 - 152nd Avenue Northeast, Redmond, 14 Washington, to discuss problems which they perceive to 15 exist at the Commonwealth Edison Company's Byron Station 16 Unit I.
17 These problems relate to errors on the safety 18 related piping and support as-built drawings.
These 19 errors could affect inspections conducted to satisfy 20 requirements set forth in IE Bulletin 79-14 and could 21 possibly impact the stress analysis and the ASME code l
22 required design report.
23 As agreed, this meeting is being transcribed.
24 Now, we will put on the record the persons 25 present during this meeting.
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
3 1
Please give your name, title, organisation and 2
a brief summary of your experience.
3 My name is Duane Danielson.
I'm a section 4
chief in the engineering branch in Region III.
I have a 5
bachelor of science degree in mechanical engineering and 6
I'm a registered professional engineer in the state of 7
California and in Georgia.
4.
8 I have about 29 years of experience in, nuclear
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9 experience.
Fourteen years have been with the Atomic i
10 Energy Commission and the Nuclear Regulatory Commission, 11 both in Regions II in Atlanta, Georgia, and Region III in 12 Gle'n Ellyn, Illinois.
I 13 Prior to that I was with Mare Island Naval 14 Shipyard for about five years.
There I was involved in 15 the naval reactors nuclear submarine, new construction 16 and overhaul programs.
17 Prior to that, I was with General Electric in 18 San Jose, California.
There I was involved in the design 19 of their commercial nuclear power plants for about one 20 and a half years.
As o.(s" 21 Then prior to that, I was with Arrow-Jet.
22 General Nucleonics in San Ramon, California, and there I 23 was involved in the design of their commercial reactors 24 and military reactors and their space program reactors.
25 Isa, why don't you go ahead.
'_1 DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
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4
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1 MR. YIN:
My name is Isa Yin.
My position
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2 with NRC Region III right now is senior mechanical 3
engineer.
I graduated from college with a BS degree in 4
mechanical engineering and I have about 20 years nuclear 5
piping experience.
6 I worked for Parsons, Bechtel, General 7
Electric. and right now I'm with the Commission.
8 MR. GAVULA:
My name is Jim Gavula.
My 9
current position is reactor inspector, mechanical, in 10 Region III.
11 I have a bachelor of science in mechanical 12 engineering.
I've got approximately ten years of i
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13 experience, five of which is in the nuclear field.
The 14 other five are in mechanical design.
15 MR. MITCHELL:
My name is 16 Schuyler Mitchell.
I'm president of Computerized 17 Interference Elimination for the past 17 years.
My firm 18 under my direction has worked in the marine industry for 19 Bremerton Naval Shipyard, Lockheed and several naval 20 architectural firms.
21 We work for the Atomic Energy Commission, 22 Richland, Washington, through Vitual Engineering.
We 23 have worked on plants for the Tennessee Valley Authority.
24 The plants are Sequoia and Watts Bar.
25 We've worked on Duke Power power plants at b
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
5
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s.
1 Catawba.
We've worked on Public Service, electric and
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2 gas, Power Plant Salem, Unit II, Boke Creek.
3 We've worked on Seabrook Nuclear Power Plant, 4
Unit I.
We've worked on La Salle Nuclear Power Plant, 5
Unit I, Byron Unit I, Byron Unit II, Braidwood Unit I, 6
Braidwood Unit II, Trojan Nuclear Power Plant, Faso-flex l
7 test facility for the United. States government.
We've 8
worked on Banford II and Hanford Units I and IV and San 9
Of rey Unit III.
10 Our firm's job was to take the drawings 11 designed by the engineers of the large AE firms, Bechtel, 12 the utilities themselves, their internal design agencies, 13 and find discrepancies in the mechanical systems such as
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14 piping and piping supports.
15 My education is that I have a bachelor of 16 science degree in business administration.
17 MR. NICHOLSON:
My name is l
I 18 Scott Nicholson, General Manager, Computerized 19 Interference Elimination, since the inception in 1970.
20 As Mr. Mitchell stated, I've been involved in j
21 all the work in all of these plants.
My background is 22 electrical engineering.
23 MR. DANIELSON:
Now, we would appreciate i
24 it if the representatives from CIE would provide us the 25 following information:
w' DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON 1
I
I 6
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l l
- x. -
l' One, a brief statement of your company's 2
background, which you might have covered a little bit 3
therer two, a statement on how your interference 4
detection system works; and three, the background 5
describing the extent of your review of the Byron Unit I i
i 6
as-built program.
7 Then af ter that, we will get into your specific 8
concerns.
9 MR. MITCHELL:
As I pointed out in my 10 earlier remarks, CIE has worked on many nuclear power 11 plants.
12 As you can see, gentlemen, we are an extremely 13 small firm, but we have developed a computer program 14 initially in the marine industry to take the piping 15 systems, mechanical and electrical systems, all the steel 16 and structure, and build a numeric model.
17 This numeric model tells us whether the systems 18 will physically fit in that area and physically work as 19 far as their design for space.
20 We were brought into the Atomic Energy 21 Commission over in Richland, Washington by Vitual 22 Engineering, who had heard about us through Control Data 23 Corporation.
We worked on a sodium plant after we had 24 trained Vitual Engineering to work with us.
f 25 Basically, what we do for the nuclear field, f.
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
I and I think we should get into that right now...
2 MR. DAMIELSON:
Excuse me just a minute.
3 MR. MITCHELL:
Go ahead.
4 MR. DANIELSON:
So that there are no 5
problems here with proprietary information, _if during any 6
of our discussions here you feel something is 7
proprietary, would you, please, make that clear on the 8
record so that we don't disclose it?
9 MR. MITCHELL:
I don't think there will be 10 anything, but if somehow we come up with that, we will be 11 happy to do that.
12 Anyway, basically, from our work with Vitual 13 Engineering, we met with representatives of the 14 Washington Public Power Supply System and they asked us 15 to train their design agent, Burns & Roe, in the 16 utilization of our computer program for the detection of 17 physical interferences.
18 Now, what I mean by that is that the procedures 19 utilized in the past to make sure everything would fit 20 into an area was a composite drawing.
It's just a l
j 21 drawing that everybody draws on, and they can see what is 22 in the area.
23 The problem was that that procedure was not 24 working, because as the drawings were going out into the 25 field, interferences were happening, interferences with l
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w DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON i
8 1
piping systems, say, hitting a vent duct or a support not 2
attaching properly to an embedment plate, problems with 3
the drawings.
4 These problems are extremely expensive in the 5
construction cycle, as you can imagine.
Considering a 1
6 number in the area of 15,000 to 20,000 on a nuclear power 7
plant, it can be quite expensive and time delaying.
8 So we were asked by WPPSS to train Burns & Roe 9
to use our program on Banford Unit II.
It's our 10 understanding they used the program and found some 4,000 11 interferences.
12 Now, I don't know how we are going to do this 13 with a blackboard, but the system is quite easy.
We take 14 an area of the nuclear power plant.
We have a system go 15 in and, let's say, out of an area.
16 We do nothing more than set up an arbitrary 17 origin point, which is located so many feet in the "X" 18 and "Y" direction.
We'll say that is "X" and that 19 direction is "Y,"
and, of course, the elevation.
20 We do nothing more than describe the beginning 21 point of the system and the ending point of a system, the 22 "X," "Y," a nd " E " c o o r d in a t e s,
"X-1," "X-2," "Y-1,"
23 "Y-2,"
"E-1,"
"E-2."
24 The computer builds the two together.
We give 25 the outside diameter of the system.
We now hold that DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
9 i
i space.
We take all our systems and input it similarly.
2 Now, there are different techniques that we 3
use, such as blocking methods and centerline methods, but 4
.those basic methods -- we're able. to describe virtually 5
everything in a nuclear power plant no matter how complex 6
it is and we're able to input that data quite quickly.
I 7
hope today to show you, gentlemen, how easy it is.
8 Now, our job is to do nothing more than take 9
all the data in a given area, build this numeric model, 10 and let our clients know when two systems occupy the same 11 spot.
12 We are not an engineering firm and we do not f
13 practice engineering.
We simply provide a service.
14 Engineers take a look at the data and determine whether 15 it is a problem or not and make any adjustments.
I 16 It's been our past history that approximately 17 90 percent of the items we present to the AE turned out i
18 to be interferences and required engineering or field 19 change notices issued.
l 20 There is a study which we will get into later 21 on that points out how accurate this system is.
This 22 study was requested by Commonwealth Edison.
23 Are there any questions?
24 NR. DANIELSON:
No.
l 25 NR. YIN:
No questions.
l r,
s l
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
10 4 '
1 MR. MITCBELL:
It's a f airly easy 2
procedure.
As I've said earlier, we have done this for 3
many nuclear power plants, Burns & Roe, AE firms.
We've 4
done it for Bechtel Corporation, Sargent & Lundy.
These J
5 are the type of firms that we've worked with on their 6
drawings.
7 So we have a pretty good experience in this 8
field.
In fact, we consider ourselves the expert because 9
we've had so many years in it and we haven't found 10 anybody that can compete with us as far as answering the 11 questions we can.
12 You understand, gentlemen, that when we get the 13 drawings, the AE firms have done their best.
They've 14 used whatever procedures they have.
They've used 15 composite drawings or models that cost up to $10 million.
16 Still, our firm can come in and find errors.
i 17 This is what we have done for Byron and l
18 Braidwood power plants.
l 19 Because of our work with Byron, Braidwood and 20 other utilities, sometimes we are brought into a project 21 not at the conception stage, but later on after many of 22 the systems are already completed in the design cycle, 23 such as the structure, such as the piping.
24 In some instances, we're brought in where the 25 systems are already installed, and supposedly we have
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DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
f 11 1
drawings with all the~ field change notices and 2
engineering change notices that reflect what that system 3
should look like out in the field or the actual 4
configuration.
We have found in many instances very 5
large discrepancies.
6 We have found these early in our cycle of the 7
nuclear industry and we brought this to the attention of 8
the NRC.
In fact, we have had several meetings back in 9
Washington, D.C. with the NRC concerning the problem of 10 as-built drawings.
4 11 MR. DANIELSON:
Can you give me some dates 12 when you think these meetings might have taken place?
13 MR. MITCHELL:
Yes.
I think the most 14 important meeting happened with Mr. Victor Stello.
That 15 meeting happened on February the 3rd, 1981, where i
16 Mr. Nicholson and myself went to the NRC, pointed out 17 that we had a tool to detect the type of problems, as-18 built problems, that the drawings did not reflect the 19 configuration of the draw'ings, and we could point these 20 out to the NRC.
21 The reason we went to the NRC, we were quite 4
22 familiar with Bulletin 79-14, where by accident, the NRC 23 happened to just stumble onto the f act that some of the i
24 drawings did not reflect the actual configuration.
l 25 We received an extensive letter back from I ('
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DEAN MOBURG & ASSOCIATES - SEASTLE, WASHINGTON t
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12 1
Mr. stello dated March the 17th, 1981, which a copy of 2
you can have, of course, where we made an unsolicited l
3 proposal to demonstrate it to the United States l
4 government how the system worked and h6V^1E could work to 5
save the government some time and money in their own
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6 analysis of as-built drawings.
7 The answer back f rom the NRC was that they 8
didn't feel it was proper for us to impose this 9
requirement on the utilities.
10 But they did point out in their letter, and I 11 would like to quote it, "On February the 3rd, 1981, 12 during our meeting with you and your associate, you 13 expressed your concern that the verification by some 14 licensees of the as-built configuration of safety-related 15 piping systems had not been performed with sufficient 16 precision to meet the intent of the bulletin.
17 "If you do have specific information indicating 18 that specific licensees have been deficient in responding 19 to Bulletin 79-14, that information could be helpful to 20 us in protecting the health and safety of the public.
21 "For that reason, we request that you identify 22 those licensees whose performance, in your view, has been 23 deficient, and that you describe the nature of those 24 deficiencies to the extent of your knowledge."
25 We were surprised to get this letter from the
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DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
I 13
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1 NRC, because in our meeting with Victor Stello we found f
2 that the NRC was not of interest at all, but we kept this 3
letter in mind.
f 4
Mr. Nicholson and I had great discussions on 5
Bulletin 79-14 and what type of information would be 6
accepted by the NRC if we were to come forward as 7
requested in this letter.
8 We felt, and I think have been proven right, 9
that the only information that would be acceptable to the 10 NRC was the as-built for-record drawings on a nuclear i
11 power plant that was in operation.
12 Anything prior to that the utility or the AE 13 could consider preliminary, and, therefore, the NRC had 14 no jurisdiction, in our opinion, of a problem existing, 15 and this has -- I think as we go along through this 16 meeting -- will prove to be the case.
17 We were quite surprised to see the utility give 18 us the for-record drawings on an operational nuclear 19 power plant, because Mr. Nicholson and myself knew that 20 once that happened, there was not a nuclear power plant i
21 in the United States that could, in our opinion, put up i
22 with the scrutiny that our procedure would put these 23 drawings through.
24 MR. DANIELSON:
Did you respond formally 25 to Mr. Stello?
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DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
14 2
1 MR. MITCBELL:
When?
2 MR. DANIELSON:
Providing any of the 3
information that was requested in there, any specifics.
4 MR. MITCBELL:
Yes, we did.
But again in 5
our discussions we felt that the power plants that we l
6 were working on were simply preliminary, and, therefore, 7
the utilities could say that these drawings are not 8
completed.
In fact, the utilities had done so.
9 Commonwealth would be a good example of what we 10 are talking about, saying, "These drawings are 11 preliminary and we are working on them.
They have not 12 been finalized."
13 Mr. Nicholson and I said, therefore, to make a 14 presentation to the NRC that would be acceptable, we 15 would have to wait and have for-record as-built drawings 16 on an operational nuclear power plant that the NRC had 17 accepted.
l 18 MR. NICHOLSON:
Well, we also, during the l
j 19 meeting with Victor Stello, offered to give him 20 interferences in existence on the Fase-flhx test facility 21 in Banford, Washington, of wuich we had numerous ones, 22 because we had done the project itself for 89 and one 23 other.
He declined.
24 MR. MITCHELL:
We felt these interferences 25 would show that there would have to be extensive work l
r DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
15 r'"
I done on the as-built drawings and that this would be an 2
area that the NRC could take a look'at.
3 Again, since the drawings were not finalized, 4
we felt that this wouldn't.be a good case.
Victor Stello, if I remember -- what were his 5
6 exact words to you?
7 MR. NICBOLSON:
Exactly, Mr. Victor Stello 8
stated to me at the time I was of fering him these 9
interferences to look at, "You're not going to dump that 10 on my desk."
That's a quote, unquote.
11 MR. MITCHELL:.So our position was that --
12 lik'e I say, we were a little surprised to get this letter
(
13 f rom Mr. Stello.
14 But we've always kept it and kept it in mind, 15 because at that meeting Mr. Stello. also gave us a copy of 16 CFR-21 saying, "If you know anything about nuclear power 17 plants that have a safety problem, it's your job to bring 18 it forward."
i 19 MR. DANIELSON:
Have you reported anything 20 under Part 217
]
21 MR. MITCHELL:
This meeting, in our 22 opinion, is under 21.
23 MR. DANIELSON:
Well, this ' meeting, as f ar 24 as Region III is concerned, is to put on the record your 25 concerns relative to Byron Unit I as-built drawings, as I DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
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1 mentioned in the beginning.
2 MR. MITCHELL:
Yes, that's right.
Our 3
position, since we received a copy of this, and our 4
understanding of this letter, is that we are required by 5
law to report this.
6 If we weren't required by law to, we'think it l
l 7
would be a moot case of even bringing this to the l
l 8
attention of the NRC.
l 9
MR. DANIELSON:
Well, you mentioned that 10 we were basically only interested in operating plants.
11
.That's not.true.
I don't mean to be argumentative.
12 We're interested in any deficient conditions, l'
13 particularly the significant ones that could have an 14 impact on the safety of a nuclear power plant whether 15 it's in construction or whether it's in operation.
16 MR. MITCHELL:
Yes.
I understand that.
17 Now, as I pointed out earlier, we had found 18 problems with systems that supposedly were finalized 19 drawings and we notified the utility involved.
20 specifically, we notified Commonwealth Edison 21 that they had this problem, Mr. Byron Lee, who was the, 22 I believe, vice-president at that time.
23 We pointed out that we had found some problems 24 on the La Salle nuclear power plant and the Byron power 25 plant, and that we thought that because we were doing DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
17 1
interference analysis, we could also for them take some 2
of these problems that were slipping through their 3
procedures for as-built checking.
4 Mr. Lee called his staf f together and he was 5
assured that there was no problem, and he wrote up a 6
letter stating that he had no problem with the as-built 7
drawings, that he was assured by his staff that these 8
drawings would be okay when they finally were turned over 9
to the plant to operations..This was in 1981.
10 MR. DANIELSON:
Bow long have you been 11 dealing with Commonwealth Edison?
12 MR. MITCHELL:
1975 was our first contact.
I 13 MR. DANIELSON:
And that was with which 14 client?
15 MR. MITCHELL:
With Mr. Ludwig Glischer on 16 the La Salle nuclear power plant and Art Klineran and 17 Wayne Steedy.
18 Some of the people in the field of Commonwealth 19 Edison did not think it necessary for an interference l
20 analysis.
21 We did one interference analysis on Braidwood 3
22 Unit II, a relatively small area, a small area of the j
23 containment section and a small area of the penetration 24 area, about 700,000 or 800,000 cubic feet on Braidwood 25 Unit II.
We found over a thousand interference notices.
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DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON I
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i 18
- :s.
1 This, of course, is extremely costly to a 2
utility to come back and redesign these supports and 3
piping systems that have interferences, but there were 4
people at Commonwealth that felt that the procedures they 5
had established for building nuclear power plants were 6
adequate and that our system would not help them at all.
7 Because there were discussions in this area, 8
the chairman of the board and the president of the 9
corporation, Jim O' Conner, it's our understanding, 10 recommended that there be a study done'by an independent Al 11 reviewer.
That reviewer was -Newv Tech Engineering Company 12 in Chicago, Illinois.
~
13 They came to our offices and reviewed our 14 procedures that we utilized.
15 MR. DANIELSON:
This was in what year?
16 MR. MITCHELL:
This would be about 1983.
17 They reviewed our procedures on Braidwood.
18 They then took 400 to 500 of the notices with us, went out 4
19 in the field and reviewed them, and wrote a report.
20 That report was highly critical of the in-house 21 procedures and did say that CIE's procedures would detect 22 interferences and save the utility a tremendous amount of 23 money.
hv 24 Because of the -New Tech report, Commonwealth 25 Edison gave 'us a contract in a similar area on Byron DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON s-.-
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Unit II.
2 On January the 3rd,1984 we had a meeting in 3
the field, and at that meeting it was agreed that we were 4
to receive the as-built drawings.
5 This was the first time that we on any project 6
with Commonwealth had drawings that were supposedly, in 7
our understanding, as-built and so marked on the 8
drawings.
9 Within 30 days of receipt of those drawings' we 10 notified Commonwealth Edison that we had found extensive 11 discrepancies on their as-built drawings.
12 They flew one of their people out to our b
13 offices in February of 1984, Mr. Burt Annis, and he 14 looked at the results we were coming up with.
15 He then pointed out that these drawings were in 16 error and that this was not a procedure or an acceptable 17 finding, as far as he was concerned, on drawings that 18 were supposedly as-built.
19 We were asked to document a bunch of these 20 drawings and submit it to Commonwealth, to 21 Mr. Burt Annis, where Hunter Corporation, it was our 22 understanding, doing the as-built check, would review 23 these discrepancies and let us know what the results 24 were.
25 I think at this time what we would like to do DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
20 1
is to show you what we found on Byron Unit II, which will 2
then lead us into Byron Unit I.
3 I have made several copies of these drawings.
4 I've had them blueprinted.
I have the originals'out 5
there if you would like to look at them, but I believe 6
you understand the procedures used by Commonwealth 7
Edison, what the drawings mean.
8 MR. DANIELSON:
Yes.
9 MR. MITCBELL:
I would just like to show 10 you the types of problems that we were coming up with.
11 MR. YIN:
Before we go into specifics, let j
12 me ask a few questions, if I may.
I' 13 MR. MITCHELL:
Sure.
1
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14 MR. YIN:
When you talk about 15 interference, are we talking about actually deviation 16 from design or actual physical interference?
I just want 17 to know the terms.
18 The reason I ask the question is, during 19 construction, design stage, you may find interference.
20 Now you're talking about as-built.
21 The plan is already built.
The system is 22 already in place.
There can no longer be any 23 interferences, okay?
I 24 So is the question of the design as-built f
25 drawing incorrect, the drawing control problem that you DEAN MOBURG & ASSOCIATES - SEATTLE, WASBINGTON
.,-_...-_--.-_.-w
1 21 1
allege to, or is it an inadequate review f rom the AEs 2
that such a deviation from design is either acceptable or 3
unacceptable?
4 so we want to get the issues clearly 5
delineated, identified, before we go into the specifics.
6 MR. MITCHELL:
Our position is that the 7
drawings we have have errors on them, but I think you 8
brought up a good point.
Before we get started getting l
9 into the technical aspect, let's lay the ground rules.
f 10 First of all, it is our understanding under IE l
11 Bulletin 79-14, Revision 1, and I am going to read a few 12 things f rom this, because I think it is important that it 13 gets in the record, according to Bulletin 79-14, as we f
14 interpret it, the NRC had come up with a couple of j
15 problems and were trying to resolve those problems.
i i
16 During the resolution of these concerns that 17 I'm now quoting -
" Inspection by IE and by the licensees l
18 of the as-built configuration of several piping systems 19 revealed a number of nonconformances to the design 20 documents, which could potentially affect the validity of 4
21 the seismic analysis.
Because, apparently, significant j
22 nonconformance to design documents have occurred in a 23 number of plants, this issue is generic.
24 "The staf f," NRC, "has determined where design l
25 specifications and drawings are used to obtain input
\\
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON i
\\
22 1
information for seismic analysis of safety-related piping 2
systems that it is essential for these documents to
~
3 reflect the as-built configurations."
4 So it is our understanding that this document 4
5 requires the utilities' AEs to set up some type of as-6 built checking system; is that correct?
7 MR. YIN:
That is absolutely correct.
8 MR. MITCHELL:
Sargent-Lundy, therefore, 9
following Bulletin 79-14, has set up Project Instruction 10 Number PIBB-26.
11 In that they say, "The purpose of this 12 procedure is to identify the field installation data 13 which is to be submitted to Sargent-Lundy to verify the j
14 as-built condition.
1 15 "The piping isometric drawing shall be marked 16 to show appropriate dimensions for pipe routing, pipe l
17 support locations, and special information required for
'l 18 each pipe class.
19 "The dimensional information shall be in j
20 sufficient detail to eliminate ambiguity to the i
21 information submitted.
22 "The installed conditions are not espected to 23 be in perfect agreement with the Sargent-Lundy single 4
24 line drawings; however, the measured for-record 25 information is required to be in agreement with installed f
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON i
- ~. -. - - _ _ _ _ _
23
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1 piping configurations.
2
" class
'D' piping in seismic Category 1 3
buildings will have a field walk-down to ensure the
]
4 installed hanger locations are consistent with design j
]
5 drawings.
6
" Dimensional Tolerances.
Dimensions are to be 7
recorded to the following accuracy:
linear dimensions, 8
plus or minus 1 inch for a length of sero to 9.9 feet; 4
9 angular measurements, plus or minus 5 degrees for elbows, i
10 bends and relative pipe leg orientations."
i 11 Would that be a correct procedure?
12 MR. YIN:
That's correct.
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13 MR. MITCHELL:
Just for some information, 14 if we could I
15 MR. YIN:
Let me just point out, deviation 16 f rom design is nothing new to anybody, and deviation is i
17 perfectly acceptable as long as evaluated by the AE 18 whether it is Class I, Class II or Class III piping.
19 Class I, of course, you have a formal stress i
20 report, and even in Class I, if you can accept the 21 deviation as you made the notice, make an evaluation in 22 the back of the report in the appendix, whatever the 23 format they choose to use is considered acceptable by the 24 code.
25 Classes II and III have lesser stringent 6
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON i
I
s 24
('
I control, but they'still have to document the findings and 2
evaluate it with -- either based on control engineering 3
judgment, let me put it this way, or by some simple calculation or extensive calculation to accept such.
4 5
deviation.
6 It's acceptable not only to the code, but also 7-toitbe Commission'.
~
'O MR. NICHOLSON:
We agree with everything 9
you have said.
10
-MR. YIN:
So I guess the issue here that 11 we have is,.are there any deviations?
t We are not talking 12 about interference, because we are talking about -- Byron
'lir Unit I is alfeady constructed, so there sho'uldn't be any 14 interference.
~ 15 So[are~there any design deviations, that is, 16 not identified by Hunter or by another group I think is 17 Nuclear 18 MR. MITCHELL:
NPS?
19 MR. YIN:
Yes, NPS.
Nuclear Power 20 Systems; is that correct?
21 MR. MITCHELL:
Yes.
22 MR. YIN:
Their failure to identify those 23 deviations which they're supposed to do, and those are, I 24 think, the key that we come here today.
25 Am I correct?
l
{'
1 I
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
i 25 1
MR. MICBOLSOM:
Correct.
2 MR. MITCBELL:
That's correct.
l 3
MR. MICBOLSON:
And that is what we plan 4
to show you, those deviations which have gone undetected l
l 5
by the parties that be charged with finding these.
6 Mk. YIN:
Okay.
7 MR. MITCHELL:
To do the as-built check 8
and the analysis you have two separate items, but they 9
are interrelated.
10 First is the as-built walk-down, and that is 11 where a person physically goes out and measures the 12 length of a pipe or the location of a support, the angles 13 or bends on those piping systems, and this is normally 14 done by surveyors or engineers or people under their 15 instructions.
16 Before you can do a seismic analysis, you have 17 to.do a walk-down.
This walk-down...
18 MR. NICBOLSON:
I will correct that by 19 saying a final stress analysis, not a preliminary stress 20 analysis, which is done on the
'M" drawings or the 21 originally engineered drawings.
We're talking about 22 final stress.
23 MR. MITCHELL:
The requirement is to 24 measure this, as the actual configuration is out in the 25 plant, and that is to be done before the final analysis i
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
26 5
1 is to take place, because what we are doing is, we are 2
comparing the actual configurations with the other 3
analyses.
4 It's fine for these two to be different.
In 5
fact, they say so in their thing.
What they want to do, 6
though, is to compare them to see if these deviations are 7
greater than allowed by their seismic analysis program.
8 So, therefore, they have set up requirements 9
that say, 'You will measure this plus or minus 1 inch."
10 So you will see a figure such as 4 foot 3-7/8 inches.
(
11 They have measured it to that type of accuracy.
12 MR. NICBOLSON:
And to identify that f
13 dimension they will have boxed it in.
14 MR. MITCHELL:
They'll box that dimension 15 in.
16 Now, what they do is they compare that with '
17 what they have here, but what we were coming up with, 18 this was 24 feet 4-3/8 inches boxed in, something 19 completely different.
We knew it had to be 4 feet, but 20 it was 24 feet.
21 M R.
YIN:
You're talking about 10 feet of 22 m difference?
I mean, is this a...
23 MR. MITCHELL:
I'm talking about 20 feet 24 of difference.
25 MR. YIN:
Yes.
I mean 20 feet of DEAN MOBURG & ASSOCIATES - SEATTLE, WASBINGTON
27 I
difference.
2 MR. HMITCBELL:
That's right.
I'm saying 3
that the figure that we're looking at now over here says 4
24 feet rather than 4 feet.
5 MR. YIN:
Is this by actual. measurement or 6
is it by calculation?
For instance, if you have an angle 7
deviation based on computer calculation, if you draw an 8
arc and you measure the end of the arc, it may be a 9
tremendous amount of difference, but the angle itself may 10 be having some...
11 MR. MITCHELL:
Plus or minus five degrees?
12 MR. YIN:
Yes.
(
13 MR. MITCHELL:
Well, I think we're going 14 to show you, gentlemen, that this is the actual -- what 15 is known as the chain dimension as measured.
It has 16 nothing to do with the angle that you're worried about.
17 MR. YIN:
Before we get into this area, 18 the actual measurements of those dimensions at Byron I 19 were initially done by the Hunter QC people and 20 subsequently reviewed and verified by NPS.
21 Now, NPS does not go out to measure the actual 22 dimension ~unless those dimensions are questionable or 23 missing on the drawing.
24 MR. MITCHELL:
Yes.
Absolutely.
25 MR. YIN:
That was the process that I was DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
I 28 1
aware of.
2 So can you maybe tell me a little bit about --
3 before we get into the details -- what are the problem 4
areas?
Somebody may be missing something, according to 5
you.
6 MR. MITCHELL:
Well, as Mr. Nicholson was 7
explaining earlier, what we found is that the review 8
process, whatever that review process is done by the 9
Bunter QC people or done by NPS, didn't work.
10 Now, to show you that, we have to get into the 11 technical part, okay?
12 MR. YIN:
Yes.
13 M R.
MITCHELL:
Our position is that 14 whatever their procedure is in-house', it didn't work, and 15 we were finding things, dropping-through the slot that 16 shouldn't have.
17 I've had long discussions with the Hunter QC 18 people, Mr. Ken Jagma, as to what was going on.
19 Mr. Jagma pointed out that once we had a drawing that had 20 a box around it, unless someone pointed out a problem to 21 him, that box was never changed.
22 MR. NICBOLSON:
Which is what you said.
23 MR. YIN:
I'm just kind of curious.
Would 24 a major problem occur because of lack of QC, or is the 25 problem associated with NPS not doing the job they were DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
-., _ _ _. -. ~ _ _ _ _ _... _. _.
29 I
supposed to do?
2 MR. MITCBELL:
We can't answer that 3
question, really, because all we're getting -- we don't 4
know what their procedures are.
We were never able to 5
get into how they were doing it or what they were doing, 6
only that there were problems coming out of whatever 7
system they could set up.
8 MR. NICBOLSON:
It would be-speculation.on 9
our part to surmise where the problem or the breakdown 10 occurred to create the errors that we have been finding.
11 MR. YIN:
Let me put it the other way.
Is 12 any other other party involved that could contribute to J
13 the problems that you allege have happened?
Are you 14 aware of any other parties other than Hunter QC and NPS 15 that are doing some work in this as-built measurement and 16 verification work?
17 MR. MITCBELL:
Commonwealth Edison, is my 18 understanding, had the final say on it.
In fact, I think 19 they're quite specific in the Sargent & Lundy document 20 that it was Commonwealth's problem to furnish the correct 21 data.
22 So somewhere Commonwealth Edison's staff was 23 involved in it.
How or to what degree, we don't know.
24 So Commonwealth was involved.
NPS was 25 involved.
Hunter was involved.
Where or what people l'
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
r:#._.2
~
-.m I
l 30 1
exactly, other than Mr. Een Jagna that I know at 2
Bunter -- I've had many, many discussions with him -- I 3
don't know.
4 MR. YIN:
All right.
5 MR. MITCHELL:
But you mentioned NPS.
I 6
have a copy of NPS's walk-down procedure Number 3.0.9, 7
and that procedure tells how, first, a group of people 1
8 will get the documentation ready.
9 That includes the isometric drawing, the field 10 change notices, ECNs, all pipe supports, anchor, sleeve 11 detail, embedment place.
They will get all that data put 12 together and that will be handed out to a walk-down 13 group, another group.
~
I'4 It-is their job, the walk-down group, to go out 15 and to do the measurements, wherever they are, however 16 they do it or whatever they do.
17 That then comes back to a reviewer and the 18 reviewer will review the work performed by the package 19 preparer and walk-down personnel, making sure that the 20 information provided is complete and concise.
21 The reviewer will also ensure that the as-built 22 information is properly transferred to the original 23 piping isometric, pipe impairing, a revised blue-line 24 copy with a field walk-down copy.
25 The final review.
The final reviewer performs DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON f
7
31 4
1 a cursory review of the as-built package for 2
completeness, accuracy.
This review is performed by 3
appropriate team leader.
4 So-these are the procedures, then.
They have 5
set up a reviewing of a system, and, yet, Mr. Nicholson 6
and I on a completely different subject, interferences --
7 we're not interested in two systems that are installed.
8 They're built, right?
9 We're paid for finding a support that hasn't 10 been installed on a pipe and making sure it will fit in 11 there without physically interfering with the system that 12 is already installed or a future system.
(~
13 Now, what happened was, once we reported the 14 as-built drawing problems to Commonwealth Edison, all of 15 a sudden we stopped getting drawings.
We couldn't get 16 our contract.
We couldn't get the drawings thit were 17 under contract to be sent to us.
~
~
18 MR. NICHOLSON:
Again, this is on Byron 19 Unit II.
20 MR. MITCHELL:
Byron Unit II.
21 We couldn't get the documents.
There were long 22 discussions, telephone discussions and meetings with-23 Commonwealth saying, "What is going on?
You're paying us 24 to do a job, and you won't send us the documentation."
25 MR. DANIELSON:
What time frame is this?
s.
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
32 s.
1 MR. MITCHELL:
About three or four months 2
into the contract.
3 MR. DANIELSON:
And that was again...
4 MR. MITCHELL:
April, May of 1984.
5 MR. DANIELSON:
Okay.
Thank you.
6 M R. MITCHELL:
We were so concerned that 7
we asked for a meeting with Cordell Leed, who was the 8
vice president of Engineering, and the meeting was in 9
June of 1984.
10 So it was agreed there would be another meeting 11 to address the as-built problem and to make sure that we 12 got the documents that were contracted to do our job.
They were spending hard tax dollars out there, 13 14 the rate payers, and we weren't able to do our work, and, 15~
yet, we were begging for the drawings and we couldn't get 16 them.
17 So we had a meeting in August with 18 Mr. Brent Shelton and with Mr. Burt Annis, and it was 19 agreed that we would get all the documents that we were 20 supposed to get, as well as the f act that we would do --
21 we would go through the as-built drawings on Byron 22 Unit II in our area and correct those numerous problems 23 with them.
24 "Not only that, but we suggest that you take a 25 look at other plants, such as Byron Unit I, Braidwood l
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON i
33 1
Unit I, Braidwood Unit II," because we believed that the 2
same problems existed.
3 And we said, "More importantly, we need the 4
supports.
We believe the as-built supports have gross
~5 discrepancies in them."
We were not allowed to have the 6
as-built supports.
7 MR. YIN:
Can I bring you back to the 8
issue involved?
9 MR. MITCHELL:
Yes.
10 MR. YIN:
Construction we are not planning 11 to discuss right now.
They had the prerogative to change 12 the. design at the job.
They are of a preliminary nature, I
13 so we don't have any concern at this point.
14 But the specific issue involved is Byron 15 Unit I.
That was already installed and in operation.
It 16 deviated f rom-design.
We want to know how much it
~
17 deviated from design, whether there is any safety impact 18 in safe operation of the systems.
That is the key point 19 here.
20 MR. MITCHELL:
Why don't we move along, l
l 21 then.
22 M R. YIN:
Let me also mention one thing.
23 You are getting those drawings from the AEs.
24 MR. MITCHELL:
No.
We're getting them 1
25 from the field.
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
34 1
MR. YIN:
From the field?
2 MR. MITCHELL: - Yes.
3 MR. YIN:
And you didn't walk-down the 4
system yourself, right?
5 MR. MITCHELL:
Absolutely not.
6 MR. YIN:
You're using the AE's drawings 7
or the 8
MR. MITCHELL:
No.
Hunter.
9 MR. YIN:
The Hunter drawing.
10 Now, if we can establish saying that -- excuse 1
11 my expression -- you got some undesirable drawing to 12 start out with and you input it in your computer, would 13 that be normally to say the garbage in, garbage out?
14 MR. MITCHELL:
Well, I see the point 15 you're driving at.
The point is, yes, garbage in and 16 garbage out.
The point was there was a tremendous amount 17 of garbage.
In other words, there were so many mistakes 18 made on the drawings.
19 MR. YIN:
Are we talking about a document 20 control problem or a safety issue involved?
21 MR. MITCHELL:
I think you're going to i
22 have to, again -- I believe it's safety, but I think
\\
23 we're going to have to show it to you.
You're going to 24 make the determination once I show you the-documents, all i
25 right?
l DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
,,,,.,,,,-n
,,.__,,.,,,,.,,.,,n,,,,_,..,,,,,,-n-,,-_,.
.,-..,-m
..-.-n,
35
~ MR. YIN:
Okay.
1 2
MR. MITCHELL:
So that is what I would 3
like to do.
I would like to get to the technical end of 4
it.
Afterwards, we can answer all of your questions.
5 MR. MICBOLSON:
It's helpful to work up to j
6 this point, this question you keep bringing up, by 7
reviewing Byron Unit II.
8 MR. MITCHELL:
Because I think Byron 9
Unit II is going to pin it down and I think we can go 10 through it rather quickly.
l 11 But this is the procedure.
I do have a copy of 12 the -procedures f rom NPS.
They're NPS H-1000 sheets and 13 it tells you how to walk-down and mark up the drawings.
14 Now, here isswhat we were finding on Byron 15 Unit II as we started.
The Drawing Number CC-21 -- and 16 this information has been passed. onto Commonwealth.
All 17 the stuff on Byron Unit II, of course, has been passed on 18 and corrected.
19 MR. DANIELSON:
And corrected?
20 MR. MITCHELL:
Oh, yes, and corrected.
21 MR. YIN:
CC-21.
What system are we 22 talking about?
23 M R.
MITCHELL:
Component cooler.
It's a 24 Class "C"
system.
25 What we are showing you are just typical DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
36 I
problems.
2 MR. YIN:
Class "%" is -Commonwealth 3
Edison's designation and-is equivalent to ASME Code 4
Class III; is that correct?
5 MR. MITCHELL:
Yes, I believe so.
6 I think what we are going to show you is that 7
the errors cover all different classes.
It's not just 8
related to one class, but I believe it covers all 9
classes, but these were the first ones we were running 10 into, because they were in the penetration area and 11 that's the area we started in.
12 Basically, gentlemen, Scott and I debated on 13 how to show you these things.
You have a location point 14 here, which is, a requirement on an NPS drawing, and that 15 point is by a surveyor.
16 Our understanding is that location point is 17 used to help close the loop and check the chain 18 dimensions to make sure they're correct.
They go from one location point to another location point.
19 J
20 MR. NICHOLSON:
And, also, in the stress 21 analysis it's utilized to get the relationship or the 22 loading points to the structural members.
23 The steel beams have a location within the 24 plant.
The pipe has a location within the plant.
We 25 join the two via a snubber, and to get that relationship l
l DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
_ _ _ _ _. _. ~.,,
37 s'
I between these two systems, we must work from these 2
monuments.
3 MR. YIN:
Okay.
4 MR. MITCHELL:
Now, if we were to start at 5
4 feet -- I'm 'sorry -- 3 feet 5-7/8 east of "M," we know 6
exactly where that is located.
We're going to attach to 7
a system CC-20.
~
8 We're going to come out here and -- we're 9
working in one just one direction, only one direction.
10 Let's just call it the "Y" direction, for lack of a 11 better term.
12 We're going to start here at that location
({
13 point and we're going to come out here 6 feet 6-1/4 14 inches.
15 As you can see there, gentlemen, it is boxed 16 in.
That's a chain dimens1on.
It has nothing to do with
~
17 angles.
The next chain dimension is 35 feet 1-1/4 18 inches.
19 If I use those two dimensions, I should be able 20 to come up with 5 foot 6 east of "Q."
My problem is, 21 gentlemen, I'm 7 feet off.
That would be the type of 22 error that we would find.
23 I brought a calculator if anybody wants to run 24 the figures.
25 MR. YIN:
What size.of pipe is this?
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
,.--nc---, -, - - -
w,--
38 1
1 MR. MITCHELL:
Oh, I don't know.
It's 3 l
2 or 4 inch.
3 MR. NICHOLSON:
It's 3 inch.
4 MR. GAVULA:
It gets down to how the 5
markers were determined as far as...
6 MR. NICHOLSON:
16-inch pipe.
There it is 7
right there.
8 MR. MITCHELL:
Okay.
16-inch pipe.
P 9
E R.
OA'!OLA; Yes.
That makes sense.
10 Component cooling carries a lot of water.
11 MR. MITCBELL:
Now, you had a...
12 M R.
GAVULA:
Well, you've got to realize
("
13 that these points in space in the piping analysis --
14 these are not necessarily what is' input into the piping 15 analysis.
It will go through the piping system with-16 these.
17 MR. MITCHELL:
You're right.
18 MR. GAVULA:
So what you're showing is i
19 that there is a discrepancy between your basic dimensions 20 here, but that is not necessarily reflected.
l 21 MR. NICHOLSON:
Are we?
Or are we showing l
22 you a discrepancy in these two dimensions?
l l
23 MR. MITCHELL:
Let me point out that the t
24 location points you're looking at are correct.
25 MR. GAVULA:
Okay.
Then it's either that DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON i
l
_ _ _ _ _ _ _ _.. _ _ -. _ _ _ _ _ _ _ _ _ _ _ _ _ _.. _ _ _ _ ~. _ _ _ _ _., _..
39 t
I these are incorrect or these are correct.
2 MR. MITCBELL:
That's right.
Very good.
3 MR. GAVULA:
So it's a matter of going 4
into the piping analysis and seeing whether those 5
dimensions were used in the piping analysis or whe4ber, 6
in fact, there was a discrepancy just in the".~..
7 MR. MITCBELL:
You're missing two points.
8 Number one, it is a requirement to have as-built 9
drawings.
New Reg. 800 says you will have as-built 10 drawings.
11 MR. GAVULA:
When you go out'into the s
12 plant, though, whether this location is, in fact, 6 feet 13 1 south of 19 14 MR. MITCHELL:
As far as the analysis is 15 concerned, you're correct.
16 MR. GAVULA:
Okay.
17 MR. MITCHELL:
But as far as the walk-down 18 is concerned, you must show the actual configuration of 19 that system, and we keep missing the two points.
20 Commonwealth does that quite nicely.
21 Our contention right off the start is that the l
l 22 as-built drawings do not reflect the actual 23 configuration.
24 MR. YIN:
Right.
You're absolutely right.
l 25 We're not trying to defend our position or the agency l
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON l
i 8
.. _ _.. _ ~. _ _, _. _ _. _.,.. _,., _ _. _,... _ _., _ _.. _. _ _. _...., _ _. _ _ _ _ _ _ _.,... _ _ _
..,_.7m_,._,_______m
40 1
1 position.
We come here to gather information.
So we 2
bring it back for our own evaluation.
3 MR. MITCHELL:
Right.
4 So our position was, we said, " Hey, there is-a j
5 discrepancy there, gentlemen."
I'm just using it for my 6
own interference analysis, but these are the as-built 7
drawings.
They're boxed in.
And the drawings so state 6
that they're as-built.
9 When we contacted Hunter Corporation and 10 Commonwealth Edison through Burt Annis, we said, " Hey, 11 can you have these type of discrepancies?"
12 And they said, " Hey, we're within 1 inch on our
^
13 measurements up to 10 feet.
We're within plus or minus 14 5 degrees on our angles.
We can't have these 15 discrepancies."
16 I said, "Well, we've got them.
We sent them to 17 you.
You're looking at them."
18 He said, " Hey, something is broken down in the 19 system.
Any help you can give me, I appreciate it, but 20 if somebody doesn't say there is something wrong with I
21 that, if that drawing goes through our office and out and 22 no one catches it, that'= the vey it stays in the 23 drawing."
24 So that's the type of problem we're looking 25 at.
We're saying, " Hey, gee whis."
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
.--..-e.--.,__m,,..,~~e..-.-,w_..ms.. - - =,.,,,. _ _. - - -
---.._,.--._-.___,_.--w,-,,m.y-
41 1
' MR. YIN:
To summarise CC-21, as you 2
mentioned, at least one directional measurement, all 3
those that were measured together, you found something 4
like a 7-foot discrepancy?
5 MR. MITCHELL:
A 7-foot discrepancy.
6 Now, what is a discrepancy?
Simple.
Is it 7
just, say, we drew an arrowhead to the wrong place, or is
~
8 the measurement incorrect?
Of course, we would have no 9
way of knowing.
10 We simply say if we follow the drawing, which.
11 is our requirement, to take the "X,"
"Y,"
"Z" coordinates 12 along and follow it like it's shown here on this
('
13 document, we found a problem.
14 MR. GAVULA:
Were there any. othe'r-problems
~
15
_other than...
16 MR. MITCHELL:
Just on that one 17 particular.
18 MR. GAVULA:
Just that one dimension?
19 MR. MITCHELL:
Yes.
20 MR. NICHOLSON:
You should show him where 21 it is.
22 MR. YIN:
Excuse me.
Is this the latest 23 drawing?
Is there a possibility they have revised this 24 or you have?
25 MR. MITCHELL:
Surely it's been revised.
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
42
~
It's been revised a hundred times.
I mean, we've told 1
2 them that these problems existed.
3 MR. NICHOLSON:
Remember.
This is 4
Byron II.
5 MR. MITCHELL:
Byron II.
6 MR. YIN:
I'm sorry.
I thought it was 7
Byron I.
8 MR. MITCHELL:
Byron.II.
9 MR. NICHOLSON:
This has been corrected.
10 M R.
MITCBELL:
We're just showing you the 11 type.of problems that were coming on that brought us --
12 and we'll get to Byron I, okay?
('
13 I just want to show you the type of problems we 14 were getting and,their answers, what their answers are.
15 MR. DANIELSON:
What you're saying is, you 16 know the problems on Byron Unit II have been resolved.
17 You don't know that the potential problems you're 18 identifying for Byron Unit I have been resolved.
19 MR. MITCHELL:
Yes.
But on Byron Unit II, 20 only a small area and only certain systems.
21 For example, the small bore piping, I can't say 22 that for in our area that we worked on, because we never 23 received all the small bore piping.
24 MR. NICHOLSON:
Likewise with small bore 25 supports.
c DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
43 1
MR. MITCHELL:
Well, any of the supports 2'
we can't.
3 But here is another example of what we would 4
look at.
The drawing number is SI-34.
5 MR. YIN:
Again, this is Byron II?
6 MR. MITCHELL:
Byron II.
7 You can see we come out of a sleeve here.
We
.l 8
have an as-built elevation of 386, 11-1/2 inches.
I'm 9
going to come up here 2 foot 6.
I'm going to come up 10 here 2 foot 8.
11 So if you add those together, they certainly 12 don't come up to 418.
That's just a problem we were 13 looking at.
(~'
14 What is the correct answer, gentlemen?
15 MR. YIN:
What kind of a deviation are we 16 talking about?
17 MR. MITCHELL:
The deviation is about 18 20 feet.
19 MR. YIN:
Would it be a drafting error?
20 MR. MITCHELL:
I have no idea.
I mean, we 21 turned it over to them.
It could be a drafting error, a 22 checker error.
Who knows?
Whatever the problem is...
23 MR. NICHOLSON:
Someone would have to go 24 out to the field, dete'rmine if these are indeed correct 25 dimensions, 2 foot _8, and 2 foot 6 inches.
Is this 4
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
44 1
indeed a correct elevation which has been verified here, 2
and is this, in fact, the correct elevation?
3 MR. MITCHELL:
We have no way of knowing.
4 MR. DANIELSON:
These drawings were 5
presented to you as being as-built drawings?
6 MR. MITCHELL:
Absolutely.
When they were
~
7 given to us, they were the as-built drawings within their 8
specifications.
No one but no one knew there were any 9
mistakes on them.
10 M R.
NICHOLSON:
If you look at the 11 revision column, you will see that it has gone through 12 three steps of yielding 100 percent as-built.
13 M R.
MITCHELL:
On several drawings, not 14 this particular one.
15 Now, what happens once we notify them?
I 16 brought a copy of our notification.
This is what a 17 notification would look like.
18 It simply says, " Signer assisting drawing error 19 notice."
And we said, " Hey, SI-34, Revision 1, we've got l
20 these discrepancies," and we sent them a piece of paper.
21 It has nothing to do with interferences, right?
22 "Here's ' your discrepancy," and we sent them a 23 copy of it.
This is the before one.
Bere it says 24 "be f o re."
This is what we found.and we wrote it up and 25 this is the result.
Here are the results.
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
45 1
They come back and say, "Oh, yes.
That 2
dimension was incorrect."
For who knows what reason?
3 Cnecker error?
Drafting error?
I don't know.
4 But if you will notice down here, gentlemen, do 5
you see that movement' there, that location point?
That 6
is the strangest move I've ever seen.
7 We not only said, " Hey, this system doesn't 8
work here, but if we run the whole doggone thing, it 9
doesn't run.
You're certainly out of tolerances with 10 1 inch to 9 feet."
11 MR. NICHOLSON:
You should also say here 12 that this dimension 2 foot 8 inches was changed to r{
13 28 feet 9 inches per our notification that there was an 14 error.
15 M R.
MITCHELL:
We said, " Hey, there's a 16 problem."
So these are the type of problems we were 17 stumbling on.
18 The next drawing is CC-53.
19 MR. YIN:
Again, this is Byron Unit II?
20 MR. MITCHELL:
All of them are Byron i
l 21 Unit II.
22 I pointed out that this location point was 23 drastically moved.
I've never seen a location here.
24 I've always seen them on elbows.
25 MR. YI A:
This drawing is not for us to DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
46-I keep, is it?
2 MR. MITCHELL:
It's yours.
3 MR. YIN:
It's ours?
4 MR. MITCHELL:
Sure.
5 MR. DANIELSON:
I would like to keep one 6
set of these drawings, this set right here.
7 MR. MITCHELL:
Whatever you want to do.
8 That's why we made these, is for your -- to take with 9
you.
10 Now, they've answered these.
I mean, they've 11 got the solutions to these.
But these are the type of 12 problems we find.
Here is another example on CC-53.
13 Our job, gentlemen, is making sure everything 14 attaches and works and does what it is supposed to do.
15 I will point you down to this location point 16 down here.
You see an elevation of 400 feet 4-1/4 inches 17 and you add 16 f eet 7.
18 If you add those two together, it comes up to 19 an elevation just below 417, actually 416,11-3/4, okay?
20 Who cares?
So we start working this thing up for our 21 interference analysis program.
22 Lo and behold, we can't attach to this system 23 here.
It's an RF system.
We say, "We're missing it."
I 24 sean, we're missing it by 10 feet or so.
How come we're 25 missing it by 10 feet?
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON I
..___,__.,.,-._....__,._.,,,,.,__,-.m.
., _ _. -, _ -.. - _ - _ _. _.... -,...,,,, - - _,.... -....., _.... ~... _ _. _,
47 1
So we go get RF-8, okay?
Here is RF-8, and 2
it's got "as-built" all over the place on it, right?
And 3
here are the as-built. dimensions and here's where I want 4
to tie in.
This is where I want to tie in here.
There 5
it is.
6 I even have the valves.
I have the valve 7
vendor drawings.
I have everything.
8 So I'm saying, " Gee, I'm getting some stuf f 9
working here, but, by golly, I can't get it. to tie into 10 that system.
Something is wrong in Denmark."
11 So here is the answer.
First of all, the 12 elevation, is it correct, 412?
Not only that, but the
(
13 dimension from here to here is not 16 feet.
It's 4 foot 14 6.
Now it works,.okay?
15 Not only that, when we were trying to tie this 16 one in, we were a foot off.
This pipe comes through 17 here, ties into CC-16 and then goes through the missile 18 barrier wall.
l l
19 We kept missing it by a foot, so these two 20 dimensions were completely off.
Now, these were the l
21 problems we were finding.
22 MR. YIN:
It just seems to me you are l
23 doing essentially similar things as what NPS is supposed 1
l 24 to do.
l 25 M R. MITCHELL:
It seemed that way to us.
l l
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
48 1
I mean, that's exactly.
We had a technique.
We have a 2
lachnique that sort of caught all the things that were 3
slipping through the holes.
4 MR. NICHOLSON:
Except we are out here in 5
Seattle 2,000 some miles away f rom a plant site.
NPS is 6
right there in the field measuring these dimensions.
7 MR. MITCHELL:
With a vast staff, a crew 8
c ' trained people who review these things and go through 9
inem.
10 What we are trying to get at, gentlemen, is a 11 trend here.
It isn't just a few drawings.
It's a lot of 12 drawings, 50 percent, we believe, of all the drawings we
(
13 get no matter what their classification, and we will show 14 you that as we go through here.
I think you'll see a 15 tremendous trend here.
16 M R.
DANIELSON:
On Unit II, how many 17 specific examples of interference or errors did you 18 identify and how many did they end up correcting?
19 MR. MITCHELL:
~Well, basically, I don't 20 know the exact number.
There was a lot of them, but f rom 21 this report -- Hunter issued a report f rom the first 22 batch.
23 Within the first 30 days-of our work Hunter 24 issued a review of the as-built errors that we submitted 25 and they had some 34 line items that they looked at.
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
49 1
Well, 34 line items of a large bore penetration was that 2
virtually every system had a problem.
3 That resolution of discrepant drawings 4
transmitted to Bunter Engineering, and this report is 5
what we received in a special meeting called to address 6
this problem at the field.
7 Bere are some of their answers.
I believe you 8
have a copy of this.
If you don't, I will make sure you 9
do have a copy of it.
10 Some of the answers are:
correction of 11 drafting error,. correction of drafting error, correction 12 of drafting error, reemphasis of location dimension, 13 correction of a combination of errors, correction of 14' checker errors, correction of drafting error, correction 15 of transposition error, correction of drafting error, 16 correction of conflicting information, update of as-built 17 location, correction of math error, update of as-built 18 information, correction of as-built information.
19 As you go through the document, you can see, 20 gentlemen, that these were just errors, okay?
And Bunter 21 verified that these errors were made, that somehow in the 22
. Bunter system these errors slipped out.
23 NPS missed it.
Hunter missed it.
Commonwealth 24 missed it.
25 These are the same type of errors we reported t
t DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
50 1
on La Salle in~ 1981, that we were told -- according to 2
Mr. Lee, he was assured that these types of errors would 3
not happen in the drawings.
4 Now, I can show you some others.
Do you 5
remember the RF-87 6
MR. YIN:
RF-8 ties into CC-537 7
MR. MITCHELL:
That's right.
It happens 8
to be correct here.
9 You will notice we have three location points.
10 You would assume with three location points that I 11 shouldn't have a problem in there.
Anyway, I wouldn't 12 think I would have.
13 But if I use that information that is provided 14 to me on that, using Location Point A here to Location 15 Point B, the true length between the points is 8 foot 16 8-1/16.
It's not 5 foot 8-3/16 as shown.
A discrepancy 17 of 2 f eet 11-7/8.
j 18 Going f rom Location B to Location C, which is 19 just from here to here, there is a discrepancy of 2 foot 20 1.
Going from this point to here there is a discrepancy 21 of I foot 6-5/16 inches.
22 This drawing, this whole revision, was done --
23 Revision 1 -- was the as-built information.
l 24 MR. YIN:
Now, again, as far as as-built 25 is concerned, you have gone through at least two stages.
r DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
51
(
1 First, Bunter QC will mark the as-built and then NPS will nAc
.2 hev4L as-built.
3 MR. MITCHELL:
Yes.
4 MR. YIN:
Maybe another stage, CECO's 5
personnel may have looked at it.
So as far as as-built, 6
it could be the preliminary as-built, intermediate as-f nAL built or pr.l:::y as-built.
7 8
MR. MITCHELL:
Absolutely.
9 MR. YIN:
We don't.really know where we 10 are.
11 MR. MITCHELL:
Let's take a look at that.
12 In "the line we received from Commonwealth Edison, they 13 said -- in fact, I have a letter.
14 MR. NICHOLSON:
First of all, some of the 15 drawings are marked 100 percent as-built.-
The 16 intermediate stage you reference, I believe, is the 17 70 percent as-built, and then you have a preliminary as-18 built.
19 MR. YIN:
That's correct.
20 MR. NICHOLSON:
On the revision column.
I 4
21 mean, the notes made on the drawing indicate that.
22 MR. MITCHELL:
See, our discussions *ith 23 Hunter and NPS were that these were the final drawings as l
24 far as the information on them was concerned.
The 4
25 reviews had all taken place.
l I
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON l
9 52 1
Some of them have supports.
Some of them 2
don't.
But once the dimension was put down, that was it 3
as far as once it got out into our hands, because these 4
drawings mostly -- all the as-built information was done 5
in 1983.
6 So here we were working in '84.
So they had 7
gone through all their cycles.
We knew it.
8 But Commonwealth used the same delineation.-
i 9
They said, " Bey, these are all preliminary.
Until we 10 turn that plant on, these are not the final for-record 11
. drawings."
12 MR. YIN:
There is a point of no return, I b
13 would say.
Probably you can say prior to turn over for 14 testing start-up, before operation.
So that stage is t
15 probably what we can call final, final.
16 Anything before that, an engineer does have 17 some prerogative to play with it.
18 MR. MITCHELL:
You bet.
And that's 19 exactly what we said.
We said, "If we came to the NRC 20 and we showed you these documents, you would come up with 21 the same conclusion."
22 And that's why we never did anything earlier, 23 because we never had the documents, we felt, in the right 24 stage that you would take a look at, but this is the type 25 of information we were finding.
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
53
?
l 1
Our' point -- I'm using Byron Unit II -- is l
2 don't -- this procedure of as-built drawings has gone 3
through many, many stages, and Byron Unit II represents 4
the best that they've come up to to this date.
5 If they've got these errors at this stage with 6
the technique and the people they have, something is 7
wrong.
8 MR. NICBOLSON:
The procedures don't get 9
worse as they progress.
They supposedly get better, 10 because they incorporate errors on earlier plans and into i
11 new procedures.
12
~
MR. MITCHELL:
But this wasn't happening, 13 and we found these problems on Byron Unit -- or Braidwood 14 Unit II when we were playing around with the interference 15 program.
l 16 MR. YIN:
Let's go off the record.
17 (Off the record.)
18 MR. DANIELSON:
We can go back on the 19 record nov.
I would like to reflect that Mr. Mitchell, 20 Mr. Nicholson, Mr. Gavula, Mr. Yin and Mr. Danielson are 21 present.
22 I just looked at my recor ts here and we don't 23
'have a copy of that document tant yau referred to as far 24 as Byron Unit II.
l 25 May we have that?
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
54 l
s 1
MR. MITCHELL:
You bet.
I thought I sent 2
you one.
I will get you a copy.
That's no probles at 3
all.
f 4
We were just talking about Drawing CC-53 where l
5 we showed -- that changed the dimen'sions quite 6
drastically, in our opinion, from what the original 7
drawing was.
I 8
I can go on and show you more, but they're 4
9 basically similar.
SX-19.
l 10 Now, on SX-19, what we have is a 20-inch pipe.
11 we just want to go from one sleeve to another sleeve 12 straight up.
We'll go from this sleeve here up to this 13 sleeve.
14 I have the structural drawing to show you.
I l
15 want to go through this sleeve and this sleeve, okay?
16 MR. YIN:
Are we still on Byron Unit II?
l 17 MR. MITCHELL:
Byron Unit II.
I think 18 this will be the last one on Byron Unit II as far as this 19 is concerned.
20 But what happened was, we could not get through 21 those two sleeves based on the as-built information that 22 is shown on the drawing, and that information is...
23 MR. YIN:
Now, you're showing us SX-197 24 MR. MITCHELL:
SX-19.
25 MR. YIN:
S-683 and S-6767 r
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
55
~
1 MR. MITCBELL:
Yes.
2 We were just trying nothing more than to get 3
from one sleeve to another sleeve to do our thing, and 4
all this information is as-built.
You see the as-built 5
information as shown.
6 MR. NICBOLSON:
I might point out that 7
with your computer program, when certain things do not 8
occur in the program, we.become suspicious in that we 9
should see on our printout pipe its wall and also its 10 sleeve.
11 Now,-if that pipe calls out against the wall, 12 that's an interference, and there is no sleeve call-out, 13 also, then we have to say', " Wait a minute.
Something is 14 wrong," and start looking around for the sleeve, because 1
15 we know it takes a sleeve to penetrate a four-foot-thick 16 concrete wall, something of that nature.
17 So you may refer to something as an 18 interference where a pipe will hit the wall, but in 19 reality, that's an okay situation as long as the sleeve 20 is in place.
21 In this case, the sleeve was not there, so we 22 started searching the steel drawing and the concrete
)
23 drawings.
Where is the missing sleeve?
And we found the 24 sleeve.
25 MR. MITCBELL:
But we found that the as-DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
56 1
built information shows the pipe going in one direction, 2
when, in reality, after they received our notice, they 3
corrected it and made it go in the other direction, 4
almost a foot discrepancy on a 20-inch pipe.
5 They have corrected this one here and this one 6
down here.
7 MR. NICHOLSON:
And then it lined up 8
beautifully with the sleeves and we were happy.
9 MR. MITCBELL:
Gentlemen, what I have just 10 shown you here on Byron Unit II is nothing more than the 11 problems we were coming up with after what we had been 12 told were the drawings, the finalized drawings, as far as 13 dimensions were concerned.
14 It's quite true, as I pointed out earlier, from 15 a technical standpoint, someone could say these were just 16 preliminary and they had a chance of going through and 17 correcting these errors and checking these errors.
I buy 18 that.
19 Somebody stamps " preliminary" on it.
In fact, 20 they developed a stamp just for us that said 21
" preliminary" on it.
22 So we knew that.
We said, " Bey, we know what 23 the game is.
We understand what is going on.
We found a 24 breakdown in your system.
We have a tool that can help 25 you.
You guys seem to think that you don't have a DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
'--.a w.,
y
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---w-.v,i-,-
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57 1
problem and you're in the preliminary stage of this 2
plant.
You haven't turned it on."
3 What can I say?
I certainly can't go to the 4
NRC, because the NRC will say, " Hey, these are 5
preliminary."
6 MR. NICHOLSON:
Or Commonwealth will tell 7
the NRC that these are preliminary, and rightfully so.
8 They have every opportunity to update or change any 9
drawing prior to the time which you referred to as 10 loading 5 percent or bringing it up to a certain 11 inspection point where they...
12 MR. MITCHELL:
So these were as-built 13 problems, had nothing to do with seismic analysis.
I 14 mean, we could visualize what could be going on here, but 15 we really -- we had no evidence that this information was 16 not correct.
It was caught-in the analytical stages.
17 Their system was good, except the as-built 18 walk-down did not meet Bulletin 79-14 as far as showing 19 the actual configuration.
20 There are two separate problems we're looking 21 at, the as-built drawings shown in the actual 22 configuration, which this drawing does not do for one 23 reason or another, and that data then being transmitted to 24 the analytical model, where another problem is created.
25 MR. NICHOLSON:
I might add at this stage, DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON n.,,
_..,_,,.,.,,_,.._,_.._n
l 58 1
at the same time we started detecting these problems in 2
what we felt were as-built drawings, we also tried to do 3
some research on what constitutes an acceptable 4
deviation, what tolerances are. allowable by the 5
regulations that the NRC comes up with.
6 We, first of all, found that Commonwealth 7
Edison itself had a document, which we have here and have 8
.showed you, that states that so many inches are allowable 9
in a measurement of 10 foot, 20 foot, 30 foot, and so on.
10 Also, the SME people, the Society of Mechanical 11 Engineers, are trying to put together a package or have 12 put together a package which they are trying to get 13 accepted by the NRC, I believe, to make this a uniform 14 situation throughout the industry.
15 We have found that all of these requirements, 16 deviations allowable, they're all quite similar.
You 17 don't find one person saying, "I can be 5 feet off on 18 this seasurement," and the next guy saying, "No.
That's 19 1 inch."
l 20 They're all within an inch or so of one 21 another, within a couple of degrees of one another.
l 22 So although you won't find any real written 23 document in NRC regulations concerning actual, acceptable 24 deviations, the NRC, I believe, at this date says, 25
" Deviations are not allowed.
We want it as it really l
l l
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
59 1
is."
2 Even though, tongue and cheek, we know that 3
it's not going to be perfect, there is some acceptable 4
allowance that we will give.
5 MR. YIN:
It's not our concern, quite 6
frankly, what the deviation acceptance criteria should 7
be.
The architect engineers, the licensee who was 8
responsible for the system design, based on the essential 9
nature of the system, can, rightfully so, assess the 10 amount of tolerance.
11 Also, the deviation from the tolerance ~is not 12 really that important, in our mind, as long as it's been 13 evaluated by the responsible engineer.
14 So I think the issue we're talking about is 15 engineers, if the design engineer was aware of that 16 deviation or not.
17 MR. NICBOLSON:
Right.
Irregardless of l
18 what size of deviation.
19 MR. YIN:
That's right.
Now, if the 20 design engineer is located at the site, perhaps we'll 21 have less of a problem than a design engineer located a j
l 22 few hundred miles away from the site, because the design 23 engineer at the site can actually see the physical 24 configuration and make an assessment right on the spot.
25 Recent trend is to assign more engineers to the DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON 4
I
4 60 1
site just to take care of those deviations, because, as 2-you can see, in the drafting there has been a problem.
3 We were aware there is a problem.
The as-built condition 4
is a problem, and we are aware of the problem.
5 The whole idea of the 79-14 is to say, " Bey, we 6
do have a problem.
Go back and take a look at it."
7 That's the whole idea of the issuance of the 79-14.
8 MR. NICBOLSON:
And identify those points 9
on the drawing which have a deviation which no one is 10 aware of so that we can assess it.
11 MR. YIN:
I'm not trying to minimize what 12 you're trying to say.
We want to get as much information 0
13 as we can have today, or, if necessary, even tomorrow.
14 We will bring those documents back and verify 15 the accuracy of what they have done and also verify the 16 program to assess the adequacy of the program.
17 MR. MITCHELL:
Yes.
Well, you can see the 18 problem we were having from the interference standpoint.
19 It was screwing up our program, because garbage in...
20 MR. YIN:
Garbage out.
21 MR. MITCHELL:
Garbage out, right.
22 But more importantly, we just happened to 23 stumble onto what they call an analytical model.
This 24 is the analytical model on FC-22.
25 Now, we technically weren't supposed to get DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
61 1
these document's, but we just happened to get a couple of 2
them in the mail for one reason or another.
3 Here is a typical drawing, FC-22, and you can 4
see up here all as-built data will be in a box as shown.
5 You can see all this as-built data is in a box, okay?
6 MR. YIN:
Yes.
7 MR. MITCHELL:
Now, everybody that I know 8
of as a layman who takes a look at this drawing and if 9
they were told that this is within 1 inch, plus or minus 10 5 degrees on the angle, and a surveyor had gone out and 11 marked these spots and measured these dimensions...
1 12 MR. YIN:
This is Byron Unit I?
13 MR. MITCHELL:
Byron Unit II again.
14 Now we get into the analytical part, why we 15 were worried about the analysis.
16 MR. DANIELSON:
Did we identify this is 17 iso FC-22?
18 MR. MITCHELL:
Yes.
l 19 When we started working the drawing, we had a j
20 dimension of 26 feet 9-1/4 inches, and we said, " Gee, 21 that won't work.
This is a mistake."
22 They come back and change the dimension.
They 23 said, "You're right.
It's not 26.
It's 25."
They 24 changed it a foot.
25 But then we happened upon this analytical DEAN MOBURG & ASSOCIATES - SEATTT.E, WASHINGTON
_,_y.,.-
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.,i m,,,,-,___,__-._w--_m.-_,_-
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62
(~
I model, and this analytical model says that this isometric 2
was developed using as-built dimensions and 3
configurations from Bunter iso FC-22, 3-A, and lo and 4
behold, they got the 26 feet, not the 25 feet.
5 In other words, gentlemen, what we found and 6
what we believe was happening was that these drawings i
7 were being taken and utilized in the analytical models 8
and this would be going through to the other things, 9
because no one believed that there were any mistakes on 10 these drawings.
11 To the best of my knowledge, the NRC certainly 12 didn't believe there were any mistakes on these drawings 13 that they were getting.
14 MR. YIN:
This is dated'19 -- the latest, 15 this is 1980; is that correct?
16 MR. MITCHELL:
I think we have
'84.
17 MR. YIN:
That's updating the piping as-18 built drawing.
That's for this iso drawing FC-22, and 19 that the analytical model drawing 20 MR. MITCBELL:
Is off of 3-A.
21 MR. YIN:
3-A.
That.is dated January 8, 22
'837 23 MR. NICHOLSON:
Yes.
24 MR. MITCBELL:
So we are saying, " Bey, 25 this information isn't changed unless someone finds a i
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
63 1
flaw in it.
2 MR. YIN:
But 3-B corrected the dimension, 3
as you mentioned earlier.
4 MR. MITCBELL:
Because we + ld them there 5
was a problem with it.
6 MR. YIN:
But it is a possibility that 7
this analytical model drawing will be changed?
8 MR. MITCBELL:
Oh, yes.
Now it will be 9
changed.
It is changed on Unit II, because that's our 10 job.
We told them there was a problem.
11 So I'll show you another one that shows you --
12 go ahead.
(
13 MR. GAVULA:
So Rev. 3-A for the Hunter 14 isometric matches the Rev. 3-A information on the...
15 MR. MITCBELL:
On the analytical model.
16 MR. GAVULA:
So what we haven't verified 17 and what we need to verify is that that 3-B was picked 18 up.
19 MR. MITCBELL:
I'm sure it was.
20 MR. YIN:
Mr. Mitchell is saying that if 21 they don't identify the deviation, then the designer wf.11 22 not be able to pick it up in the analytical as-built i
23 drawing.
The.15hbhwewanttoshow 24 MR. NICBOLSON:
25 is an as-built drawing and an analytical model, direct N
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
l
- 64
(-
I relationship here.
This model picks its dimensions up 2
from the isometric as-built for-record drawings.
3 MR. YIM:
That shouldn't be a surprise to i
4 anybody, I hope.
5 MR. MITCHELL:
It isn't a surprise, but 6
it's wrong.
7 MR. YIN:
So the basic issue is whether or 8
not the knowledge was transmitted to the~ engineer so the 9
engineer can make the adequate assessment?
10 MR. MITCHELL:
That is the bottom line.
11 MR. YIN:
So we come back to the same 12 point again?
13 MR. MITCHELL:
That's right.
14 Now, we take a look at -- I will have to pull 15 this up.
Now, we're just looking at PW-9.
These are all 16 l
Class "D" pipings, but they're the only ones that we had 17 the analytical models on, okay?
I'm quite familiar with 18 this one, because I found the error.
19 On Revision 3, they put the as-built l
20 information on this document.
Ka-have a dimension of 21 22 feet 9-5/8 inches.
You can see on the revision that l
22 that is now 32 feet 9-1/2 inches.
i 23 MR. DANIELSON:
And that is Revision...
24 MR. MICHOLSON:
3-B.
25 MR. MITCHELL:
The analytical model on
(
1 l
t DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON w-,,----.--,,,,w_,
ww-,-,n.
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e,e-m w_-m-m.n-,,-,---a-,,,,
I 65
\\
i l
1 this one is now taken from PW-9, 3-A.
You can see that 2
the dimension had been changed.
i-3 In other words, we notified them that there was 4
a problem.
They had come in and changed it because of 5
our notification.
6 That's what we're saying.
We're saying, " Hey, 7
none of these things are getting picked up, to the best j
8 of our knowledge."
9 MR. NICHOLSON:
And when they are picked 10 up, they do make the corrections.
11 MR. MITCHELL:
They make the corrections.
12 MR. NICBOLSON:
So follow it through to 13 the logical end, reanalyze for stress, whatever other 14 programs are-required.
When they know there is an error, 15 they correct the error.
16 MR. MITCHELL:
But, as you can see, we i
17 have looked on a bunch of errors on drawings.
We're on i
18 Byron Unit II.
19 We were concerned that the as-built drawing 20 walk-down program did not meet Bulletin 79-14 as shown 21 in the configuration and that that information may get 22 transmitted into the analytical models that are used for 23 seismic analysis and other programs.
24 These documents led us to believe that, okay?
l l
25 MR. YIN:
Let me right now maybe interject t
l DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON i
66
?
i.
I another thought and see how we can respond to the 2
thought.
3 Supposing the licensee or the AEs that -- I 4
know there's a lot of problems, the deviations and the 5
drafting, but so what.
All the deviations identified so 6
far have not caused any' hardware change and the deviation 7
is of such a minor nature, not the way you're talking
~.
8 about, 20-feet difference, 7-feet difference.
9 What they have measured and found out may be 10 3 inches, 4 inches, at the most.
Most of them, 11 90 percent or so, may be less than 1 inch.
12 So based on that, they evaluate that based on 13 other information they have.
They have high confidence l
14 the the system will operate safely.
15 MR. MITCHELL:
That is exactly the...
16 MR. YIN:
The confidence level met another 17 bulletin, for instance, 79-02, say 95 percent i
18 successful, an evaluation of less than 5 percent of any i
W j
19 problem eJ failures.
4 20 Will you buy that argument?
21 MR. MITCHELL:
Absolutely not.
I have 22 another nuclear power plant I plan to show you that can't i
i 23 meet that.
I 24 See, gentlemen, what we found out is that, l
25 basically, they did not have a tool to tell them what it
-(~
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON i
l l
67 f"
v 1
should be.
There was no way of finding out.
No one 2
checked it.
3 They also were lying to each other, if I can 4
use that term " lying."
It's the wrong word, but what I 5
sean by that is the AE is not going to go to the utility 6
and tell them there are mistakes on the drawings, that 7
they are not as accurate as they should be, and I don't 8
believe utilities go to the NRC and say the same thing.
9 Whether it's deliberate or nondeliberate, I 10 just have never seen anybody do it.
11 And, yet, here is a firm out here in Redmond, f
12 Washington with people who are certainly unqualified to
(~
13 take these documents and find these type of errors in 14 them.
Something is wrong.
Something is drastically 15 wrong with the system.
16 I can take the laymen and show them these i
17 things and they get a little upset at what we show them, i
18 because they believed that the NRC was doing its job, 19 that the NRC actually set up a procedure to go out and 20 measure what these people were doing.
l 21 You actually physically go measure some of 22 these areas.
You look at their procedures.
You see what 23 they're doing.
Yet, no one has ever come across this.
24 No one knows the 20 feet or 7 feet or anything.
25 MR. DANIELSON:
This is a very small l (
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON l
i e
68 1
sample.
i
)
2 MR. MITCHELL:
Very small, absolutely.
l 3
MR. DANIELSON:
And we have identified j
4 errors.
5 M R.
MITCHELL:
I'm sure you have, but I 6
think the concern is -- I think you people do that l
7 because you were concerned, that you wanted the as-built 8
program to be correct.
9 MR. DANIELSON:
Absolutely.
10 MR. MITCHELL:
But you didn't have a tool.
11 They didn't have a tool.
We just happen to have a tool.
12 I can take the entire containment area of Byron l
13 Unit I and within 90 days go through every system in 14 there, every small bore piping, every small bore support, 15 every large bore piping, every large bore support, every 16 hanger on the ventilation system or on the cable trace, f
17 and I can tell you where the errors are within 90 days.
i 18 I contractually do that all the time.
19 These are the type of errors we were finding.
l 20 We got fought by the highest people at Commonwealth 21 Edison, and their answer was exactly what you said.
22
" Hey, we're satisfied.
I'm assured," Mr. Lee 23 says.
Cordell Lee.
Jim O' Conner.
"My people have 1
24 assured me."
25 In fact, you have a copy from commonwealth DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
69 Y
1 Edison of Mr. Brent Shelton's answer to CIE.
Well, now, 1
2 we've got mistakes, but who cares.
3 MR. MICHOLSON:
Or they are acceptable 4
mistakes.
5 MR. MITCHELL:
Or they are acceptable 6
mistakes to the NRC, okay?
7 MR. YIN:
Okay.
]
'8 MR. MITCHELL:
So this was what got us off 9
on Byron Unit II and led to. Byron Unit I.
10 I was quite satisfied in my mind -- I know 11 Mr. Nicholson was, too -- that they weren't catching 12 these mistakes.
They didn't cat.ch them on any of the
(
13 previous units and they're not catching them on any of 14 their future units.
15 That was because we had discussions with the I
16 people in the field and we had the documents and we've 17 seen what happened once we spotted the errors.
They were 18 corrected.
19 MR. YIN:
We come here with absolutely an 20 open mind and we are not going to be biased for you or 21 for anybody.
22 MR. MITCHELL:
That's right.
We 23 understand.
24 MR. YIN:
We are here to obtain data.
So 25 we go back to another study of the whole thing.
t
- g...
s.
{
DEAN MOBURG & ASSOCIATES - SEATTLE, NASHINGTON
70 b.
1 MR. MITCBELL:
That's right.
2 Now, there is no advantage in this to CIE.
I 3
sean, it's not my -- we don't see any monetary advantage 4
to it.
The reason we are doing this is because we think 5
it's -- we have to by law.
6 MR. NICBOLSON:
And we are concerned for 7
any potential ramifications that these errors could 8
create in existing plants across the nation, because we 9
have seen errors of the magnitude which leads me 10 personally--- and I'm sure Schuyler -- to believe that it 11 has got to affect something.
1 I
12 Now, be it the seismic analysis, the beam
(
13 loading, the wall loading, a critical system separation 14 analysis, jet impingements, we don't know what study will 15 be directly affected, but a layman can pretty well 16 surmise that something will be affected when a dimension 17 of 2 feet all of a sudden in reality turns out to be 18 20 feet, an 18-foot discrepancy.
19 Logic just dictates to me that that has got to 20 throw sand in the gears.
21 MR. YIN:
Your point is well-taken in the 22 area of design versus as-built during a construction 23 stage, and you have provided us a number of examples on 24 Byron Unit II.
25 MR. NICHOLSON:
Not the key examples.
We
(
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON l
71 s
I understand Byron I is, of course, the bottom line plant 2
here, because it's in operation.
3 MR. YIN:
Now, as you already know, 4
Byron II could have gone to a large number of 5
improvements or changes.
So what you gave us may have 6
already been corrected.
In many cases you knew for sure 7
it is already changed on the drawing.
8 MR. NICHOLSON:
That's correct.. Because 9
we gave the problem in writing to Commonwealth Edison and 10 we awaited their answer.
In fact, we did receive the 11 answer and it said, "Here is the correction."
~
12 We verified that correction in that it was 13 proper, it did work.
The correction was satisfactory to 14 us.
15 MR. YIN:
Now, the next step is that 16 you're going to show us Byron I, the specific deviations, 17 right?
18 MR. MITCHELL Yes.
19 To lead up to that, we, frankly, told 20 Commonwealth Edison that their drawings, in our opinion, 21 did not meet their own specifications and we certainly 22 thought the NRC specification for showing the actual 23 configuration as it was supposed to be.
24 I felt that under the rules that I had, CFR-21, that I had to report this to the NRC and to -- I also 25 DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
__-,,,,m.
72 t'
I felt that this should be reported to the stockholders of 2
Commonwealth Edison and to the state of Illinois, because i
3 I felt these were such drastic and gross deviations that i
4 they were unacceptable.
5 Their corporate attorney, Mr. Earlan Delsey, 6
suggested in a letter to us that maybe we could put this 7
matter to rest once and for all, that, really, the people 8
at Commonwealth felt there was no problem, that they were 9
quite satisfied they were within the rules and 10 regulations of the NRC and their own specifications, and 11 "maybe we could put it to rest once and for all."
12 So I took that and I called Jim O' Conner, who
- ,I 13 is the president of Commonwealth Edison, and I suggested 14 that they take Quadrant Number 4 in Byron Unit I and give 15 us all the drawings in that area, all the piping, all the 16 supports, all the structure, everything in that area, and 17 we would at no charge do our thing, looking for 18 discrepancies on their for-record drawings.
19 These discrepancies we were looking for were as-built dimensional problems.
20 21 MR. NICHOLSON:
The reason we wanted 22 Byron I is because our experience on Byron II, we would 23 give them an error and they would come back and say, 24 "Well, this is preliminary."
25 In our minds, we felt this was the 100-percent
(
i DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON I
I 73
(?
1 as-built for-record drawing which would not be changed 2
unless someone indicated a problem.
3 When we started finding the problems, they 4
said, " Wait.
These are now preliminary as-built 5
drawings," which we previously said was their 6
prerogative, because the plant wasn't to the licensing 7
. stage yet.
8 So to prove our point, we said, "Ah-ha.
If we 9
can get our hands on Unit I drawings, a plant in 10 operation, they're going to have a pretty hard time 11 coming back to us when we find a problem, if we find a 12 problem, saying that these are preliminary as-builts and, I (
13 therefore, the errors are acceptable."
That was our sole 14 point in attacking Unit I.
15 Also, when we were doing our work on Unit 16 Number II, as you know, some of these drawings are split.
17 They say, "This drawing is for Unit I and Unit II."
They 18 may be a mirror image.
They may be just drawn in that 19 they represent both plants.
20 Doing our work on Unit Number II we came across 21 some of these drawings which were identified as being i
22 utilised for Unit I, also, and we were finding errors.
23 Not staying within our boundary, just 24 curiosity, we tended to look across the line, the l
25 separation between the two plants, and say, "What is i/
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
74
,a I
going on in Unit I?"
2 After we did that a few times, we started 3
finding errors in Unit I, gross errors in Unit I.
This 4
was during our work on Plant Number II.
5 We went to Jim O' Conner.
We said, " Bey, Jim, e
6 we're finding errors on Unit I."
7
" Don't want to hear that.
You're assigned to 8
Unit-Number II.
You will confine your efforts within the j
i 9
contracted spaces and you will not cross that line."
10 On occasion we sent problems to Commonwealth 11 Edison identifying errors which happened outside of our 12 contracted area.
The response back was, "These 13 interferences, these errors, are outside of your 14 contract."
15 MR. MITCHELL:
" Don't talk about it."
16 MR. NICHOLSON:
" Don't tell us.
Do not j
17 report any errors outside of your contracted area," even j
18 though our work would sometimes lead us'outside of that 19' parameter.
20 As long as we identify an error, we say, "Well, 21 shoot, we might as well send it to the client and let him i
22 make the correction."
1 23 MR. MITCHELL:
Makes sense to me.
24 MR. NICHOLSON:
They did not want to see j
i 25 any more errors than we were going to send them or i
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
75 t
1 contractually' vere required to send them.
m 2
In fact, he would have been quite happy had we 3
not sent any errors to him.
4 MR. MITCBELL:
"Just take the check."
l 5
That was our impression.
6 Mr. Delsey, as I said, sent us this letter 7
saying that maybe we can do something.
Jim O' Conner and 8
I agreed on the telephone that we could do something.
9 I was then asked to come back and make a 10 presentation to Tom Mayman and Brent Shelton and some.
11 people concerning what our suggestion was.
12 So we went back to Chicago, made a 13 presentation.
This was in -- oh, I don't know -- April 14 of '85, somewhere in there.
15 We sat down and said, " Hey, you give us all the 16 drawings in this area and we'll do'our thing and we won't 17 charge you for it."
4 18 We estimate our costs, internal costs, if we do 19 everything, what we would charge a client would be about 1
20
$125,000.-
21 "We're going to do it for nothing.
We're that i
22 sincere about it.
We know there's problems in it and 23 we'll do it for nothing, no charge to you."
24 So the first thing out of the meeting was, "For 25 goodness sake, all we want to see is five errors, no DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON j
76 1
more than five errors.
That's it.
We know there's 2
problems on these drawings.
We understand there's 3
problems on these drawings.
Don't show us any more than 4
five errors.
From that we can ascertain everything."
5 We said, " Fine.
No more than five errors."
6 MR. NICHOLSON:
It seemed funny to us that 7
a demonstration being done at no cost to a utility, that 8
they would limit the number of reports that we could 9
submit.
Suppose we found a hundred.
10 They were very concise.
"We only want to see 11 five."
12 MR. GAVULA:
What was the intent of 13 limiting it to five, do you know?
14 MR. NICHOLSON:
Because Mr. Able, the
~ station nuclear engineering manager that takes over after 15 16 the plant is in existence, he says, "I haven't got time 17 to go out in the field and verify 100, 200 problems."
18 MR. MITCHELL:
Even if they're correct.
19 MR. GAVULA:
Was the intent that if you 20 could find five, that that would indicate that thera is a 21 problem?
22 MR. MITCHELL:
They said that from the 23 five they could ascertain if there was a problem or not.
24 MR. YIN:
Did they say the worst case or I
25 simply just the ones that were average?
l l
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
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77 1
MR. MITCHELL
'Just pick five that you 2
want to send."
We had a choice of picking them.
3 MR. NICHOLSON:
What we felt were 4
representative of the various problems encountered.
5 MR. YIN:
Could it be logically assumed 6
that you are going to present the five worst cases?
i 7
MR. MITCHELL:
No and yes.
I'm almost 8
going to have to show them to you and show you the 9
problems we went into before I can answer that question.
10 MR. NICHOLSON:
There are other 11 restrictions.
12 MR. MITCHELL:
So what happened was they t
13 asked us to produce the agreement, which we did.
We 14 wrote up the agreement, which you can have a copy of if 15 you want.
i 16 It simply said, "We're only going to produce 17 fiv.e.
You're going to send us the drawings and there is 18 going to be no charge to you people.
If we don't find j
19 anything, we're going to keep our mouths shut."
That
(
20 seems fair.
21 "If we find something, then you're going to j
22 admit it and you're going to give us credit for it and 23 you're going to solve the problems, not necessarily using 24 us, but these problems are going to'be solved."
l 25 We got a letter from Mr. Brent Shelton that 3
l
\\
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON i
I
4 78
~
I said, " Wait a minute.
We don't want to do this.
We 2
don't want to send you all these drawings, because there 3
would be 1,700 of them."
4 We said, "Yes, we know.
That sounds about 5
right."
6 MR. DANIELSON:
That's to cover 7
Quadrant 47 8
MR. MITCHELL:
Yes.
9 I said, "Yes.
Give or take a few hundred," I 10 said, "that's about right."
11 He says, "Why don't you pick a different power 12 plant, a different-area, a different power plant?"
l
'7 13 I said, " Wait a minute.
This whole thing is to 14 talk about drawings on a power plant that is 15 operational," and he suggested Byron Unit II.
16 I said, "My God, if I haven't proved it with 17 these, what the heck is another study going to do?"
So I e
l 18
- said, "No.
I will take just 60 drawings."
He had a i
19 number of 60 drawings on his letter.
I said, "I'll take 20 those 60 and I'll produce 5 out of the 60."
21 Now, I've limited myself from the 1,700 I can j
22 play with down to 60, or tbout what, 3 percent?
I'm still going to produce the five.
23 24 Then he comes back and he says -- and he called 25 Mr. Nicholson about the lo:stion points.
I$
l DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON l
I 79 1
1'll let you tell them what he wanted on the 2
location.
3 N R. NICHOLSON:
Well, because a number of 4
the problems we reported on Byron Unit II dealt with 5
these monument points, location points on the drawings 6
being in error, he felt that this demonstration should l-7 not address anything having to do with monuments.
f 8
His words were, "These monuments are not 9
important to the pipe stress analysis."
10 I agree with that statement, the pipe stress 11 analysis, and that he would hire a person to erase all 12 location points on the drawings if necessary.
13 so I agreed that we would not report anything 14 of the five notices we were contracted to report having 15 to do with any location point or monument point.
16 so that further restricts a person when you're 17 dealing with these drawings in that you're not being able 18 to use these locater points.
19 But a couple of things with his statements 20 didn't ring true with me.
Number one, he says locater 21 points are not important on the drawing.
22 I disagree with that statement for the reason 23 that I gave previously in that I believe you have to 24 merge a pipe drawing to a steel drawing when you're doing
/
25 loading studies.
The two have to be interrelated, number i
DEAN NOBURG & ASSOCIATE 8 - SEATTLE, WASHINGTON
80 i
l
.1 one.
2 Mumber two, the locater points are on the i
3 drawing.
Any information on a final as-built for-record 4~
drawing, I believe, should be correct.
5 If anything is represented on a final drawing, 6
you give this to a lay person or any other person and 7
say "here's the drawing" in an emergency, and they look j
8-at the drawing, they assume everything on t.he drawing l
9 that they're looking at is correct.
10 There is no note on the drawing that says to 11 disregard all locater points or monument points.
So his l
l 12 statement that says those are not important I knew was I
13 baloney, but I was not in a position to argue with'him, 14 because we wanted to do the proof, our study, on Byron 15 Unit I.
i 16 We wanted to get our hands on existing as-built 17 drawings.
That was our primary intent.
We knew we could 18 find problems.
19 So I agreed.
I said, "Okay.
We won't use the 20 monument points," and we didn't.
21 MR. MITCHELL:
So we're restricted with 22 the number of drawings we can have, what we can utilize 23 from the drawings, and the number of problems we found.
24 MR. MICHOLSON:
One other thing I will 25 add, he is right that the locater points are drastically 0
(W j
l DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
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1 in error.
Our experience on Byron Unit II as well as 2
Byron Unit I shows us that in excess of 50 percent of 3
them are incorrect.
4 And I'm not talking a half inch, an inch or a 5
foot.
I'm talking many feet in a number of cases, and 6
we'll show you.
7 MR. YIN:
Those location points are quite 8
important during construction.
9 MR. MICHOLSON:
Yes.
Very important 10 during construction.
11 MR. YIN:
It shouldn't be that much of a 12 deviation.
13 F.R. MITCBELL:
This is what killed us, 14 because we agreed they're very imp ~ortant during 15 construction.
16 We would get a location point on a pipe.
- See, 17 what we're going to tie this into, gentlemen, maybe the i
18 as-built drawings weren't walked out properly.
The 19 containment wall, sleeve, the pipe comes out of the 20 sleeve, turns.
The location point is right here.
21 This location point, if I use it, says I'm 22 7 feet away from that wall, but if I use the dimensions, I
23 the chain dimension, it says I'm only 5 feet away from 24 that wall, okay?
A surveyor has gone out and done this.
1 25 I'm worried.
We've seen~them come back and DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
82 i
I change these things, but we've never seen them come back l
l 2
and change those things.
3 MR. GAVULA:
It's a lot easier to measure l
4 the piping than it is to...
5 MR. MITCHELL:
You would think so, that's 6
right.
But what if this is correct?
7 MR. GAVULA:
Well, okay.
That's something 8
that needs to be determined.
l 9
MR. MITCHELL:
That's the thing that has 10 to be determined.
11 MR. GAVULA:
The surveying, they're going 12 off,' like you said, the pins in the plant, and it may be 13 difficult to get exact readings trying to triangulate 14 exactly where you are.
15 MR. MITCHELL:
That's what they're trying 16 to do.
17 MR. GAVULA:
As opposed to -- you can lay 18 a measure on a piece of pipe.
l 19 MR. MITCBELL:
Sure can.
But then you 20 say, "What are these people doing the job for?"
21 MR. GAVULA:
Then they have problems with 22 their locaters.
23 MR. MITCHELL:
That's right.
But maybe 24 they're correct.
25 And you would think a person that is doing this l
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
83 1
and had been i'n the field for many years doing this knows 2
exactly what they're doing, and.one of the items you 3
would check if you were the surveyor is what is going on.
4 MR. GAVULA:
Do you know if they were 5
reconfirming locater points?
6 MR. MITCBELL:
They certainly were, yes.
7 I've got one right here.
I think we've got the one here 8
where it moved 2 foot 6 that I showed you a minute ago.
9 You bet.
They were changing just like that.
10 MR. NICHOLSON:
If they knew about.
11 MR. MITCHELL:
If they knew about.
12 MR. GAVULA:
They were changing locater 13 points?
14 MR. MITCBELL:
You bet.
15 MR. GAVULA:
Do you know if they were 16 changing it based on -- even if they were changed on the 17 piping information, or if they went back and actually 18 resurveyed the...
19 MR. MITCHELL:
Now, that I don't know.
20 MR. GAVULA:
Okay.
You just know that 21 they changed them?
22 MR. MITCEELL:
Right.
23 See?
Right there.
24 MR. GAVULA:
Ok'ay.
25 MR. NICBOLSON:
It was on the elbow.
Now i
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
+
=-...
i 84
\\
1 it's down 2 foot 6.
2
'MR. MITCBELL:
Strangest place in the 3
world to put a locater point.
4 MR. YIN:
The drawing we're looking at is 5
SI-34.
)
6 MR. MITCBELL:
Revision I-A.
7 MR. NICBOLSON:
So if they knew there was 8
an error on a locater point, they would naturally change 9
it.
10 MR. MITCHELL:
The guys'in the field 11 wanted any information that they could get.
They could 12 care less where it came from.
"If you found an error, 13 great.
Let's solve the problem."
14 Our problem came from middle management and top 15 management.
16 MR. NICBOLSON:
At Commonwealth Edison.
17 MR. MITCBELL:
So we got ready to do this 18 study and they sent us the 160 drawings.
19 We sent you copies of the results of that 20 study; is that correct?
21 MR. DANIELSON:
Yes.
22 MR. YIN:
I'm not too sure what you're 23 referring to.
24 MR. MITCBELL:
You haven't seen them?
25 MR. DANIELSON:
I believe he's seen it.
n DEAN MOBURG & ASSOCIATES - SEATTLE, WASBINGTON
85 C
1 Let's see.
I'believe this is the letter.
2 MR. YIN:
Why don't we read it into the 3
record.
4 MR. DANIELSON:
Yes.
It's a letter from 5
Mr. Mitchell to Jay Barrison, dated July 9, 1986.
6 MR. YIN:
Yes.
We have seen that.
7 MR. MITCBELL:
And you reviewed them?
~
8 MR. YIN:
Briefly.
Not in great detail.
9 MR. MITCBELL:
I think along with that 10 package we sent was a letter from Brent Shelton, June the 11 30th, 1986.
12 MR. YIN:
It was quoted in the letter, I
~
13 believer is that correct?
14 MR. DANIELSON:
Let me make doubly sure 15 here.
16 Yes.
17 MR. MITCHELL:
Now, what happened, what 18 transpired, is we quickly went through these drawings and 19 we found five errors.
We found more than five errors, 20 but they only asked us to document five.
21 As Mr. Nicholson pointed out, these were.just 22 representative of what we were finding.
Wr.re they the worst cases or 24 not?
25 MR. MITCHELL:
No, I don't think so, but r
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
l 86
, ('
I then I don't know what you consider to be the worst case.
2 They were ones that fit our criteria, that we didn't base 3
it on a location point, that we could track down.
4 In other words, of the 60 drawings, we couldn't 5
use all the drawings, because we couldn't verify many of 6
the problems we discovered.
7 We know there are more problems out there that 8
are grosser than what we showed, but without more 9
documentation such as the supports or the steel 10 MR. YIN:
Let me ask this.
Did you stop 11 when you got the first five?
12 MR. MITCHELL:
Well, we stopped when we 13 got the 14 MR. NICBOLSON:
Roughly 60.
15 MR. YIN:
So out of 60 deviations you 16 picked 5 to report?
17 MR. MITCHELL:
That we could document.
18 MR. YIN:
The others 19 MR. MITCBELL:
We felt that without more 20 information we couldn't document them, and I will show 21 you what we're talking about.
You're going to have to 22 see it to see why we say these are more representative 23 than the worst case scenario.
24 With more information, I'm quite sure that we 25 could show worse cases than what we have presented.
e l
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON l
87
~
1 MR. MICBOLSON:
See, our problem is we 2
had to -- in documenting these five, sending them to 3
Commonwealth, there could not be a shadow of a doubt cast 4
on our five notices, because it would detract from our 5
credibility.
6 So we had to be able to prove beyond the shadow 7
of a doubt that these five were in existence and that no i
~
8 way could Brent Shelton or his people undermine them by 9
saying, ' Bey, you used the wrong support drawing or not 10 the latest revision," or something was wrong with it.
11 So the five that we sent, we knew he couldn't 12 get out of.
13 MR. GAVULA:
Were there more than five 14 that you could document?
15 MR. MITCHELL:
Yes, there are.
We'll show 16 you some of those.
17 MR. GAVULA:
Bow many could you document 18 versus how many you think -- you said you had about 60.
19 MR. MITCHELL:
Oh, I think about another 20 ten or so that we could document, but you would have to 21 see the problem, again, to see what we were up against 22 and what we were trying to accomplish.
J 23 MR. NICHOLSON:
If we could get our hands 24 on the drawings that we need to document the remaining 50 25 some, then we could do so quite easily and there would be DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
I 88
\\
1 no question about it, but we would require some supports 2
for these piping systems.
3 MR. MITCHELL:
Steel.
4 MR. MICHOLSON:
Some steel.
5 Supports, when you work these drawings, it can 6
pin down pipe location very quickly, because we know the 7
support must go over and attach to an embedment plate or 8
up to -- attach to a piece of steel.
i 9
MR. MITCHELL:
And we know where that has 1
10 to take place.
i 11 MR. NICHOLSON:
So that can move your pipe 12 over or up.
13 MR. MITCHELL:
Commonwealth would never j
14 give us the as-built supports.
That's one of the 15 problems we think really is out there that is hidden, is 16 that the as-built supports -- because there's more 17 dimensions on those and more information taken from an 18 as-built standpoint.
19 We requested to do the as-built supports, and i
20 they would not send them to us on Byron Unit II.
- Again, 21 we felt that was the same reason on Byron Unit I.
22 If we got our hands on the supports, we 23 definitely could find problems, but we figured just with i
24 the few drawings we were able to work with, we can find
'25 five.
It didn't take an expert going through those
(_,
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
89
[
I documents to find errors.
2 MR. YIN:
Let me ask your from the 3
60 drawings that you received, they represent how many 4
different systems?
5 MR. MITCHELL:
They probably represent 6
seven systems.
7 MR. YIN:
Seven different systems?
8 MR. NICBOLSON:
Seven or eight.
They're 9
interconnecting.
Like the safety injection system will 10 go from SI-l to SI-2 to SI-3, SI-4.
11 MR. YIN:
Based on your estimate, how many 12 feet of pipe?
I'*
13 MR.-MITCHELL:
Well, that's not -- I have 14 no idea.
I can show you one contract on as-built that we 15 only used 300 feet of pipe and we found 15 errors.
16 Here we probably have several thousand feet of 17 pipe, but a lot of it outside of our area.
18 MR. YIN:
How many dimensions can you 19 estimate?
20 MR..MITC2 ELL:
I really don't know.
For 21 large bore pipe, it would be 3, 6, 20-inch pipe.
22 MR. YIN:
What I as trying to get to is, 23 we can identify the.footag~e of piping that you evaluate, 24 and the number of dimensions that you verified, perhaps 25 we can get some perspective on the amount of deficiency (3
DEAN MOBURG & ASSOCIATES - SEATTLE, WASBINGTON
90 t
1 percentage-wis'e.
I 2
MR._MITCBELL:
I think that's a wrong way 3
to look at it.
I certainly do.
4 MR. YIN:
Otherwise, how can you identify l
5 or evaluate the significance of the findings?-
I i
6 MR. NICHOLSON:
There is another.way to 7
look at that problem.
Suppose there are a hundred l
8 dimensions on this drawing which we're looking at now, 9
SX-19.
l 10 Of those 100 dimensions, 1 is in error, but 11 that error, instead of.being 2 foot, which it actually 12 is, states it's 20 feet, giving us an 18-foot error.
13 That constitutes 1 percent of the drawing being in error, 14 correct?
15 MR. YIN:
Yes.
16 MR. NICHOLSON:
But the magnitude of that 17 error is significant in that it easily could affect
[
18 seismic analysis.
That's what we're getting to.
Your way of looking at the problem is a good 19 20 way in a number of instances.
It's a_way to draw 21 conclusions, for sure, but.in other regards, it's a poor way and will not work, especially as I just stated.
22 It's one error on the drawing, but is it a 23 24 potentially significant error?
25 MR. YIN:
The concern, without looking at DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
91 i
1 any specifics, is another one, that you have a 2
significant deviation, say, of 20 feet.
Then, of course, 3
the analysis is going to go wild.
4 MR. NICBOLSON:
Right.
5 MR. YIN:
On the other hand, I would also 6
have to imagine that it's probably a drafting error and 7
may not affect the stress analysis, because if you have 8
an excess of 20 feet, then you may have a weight 9
supporting problem, or, rather, you may have sag too 10 much.
The sagging is a problem due to that weight.
11 It would be almost impossible not being 12 idehtified by somebody walking down the line.
13 MR. MITCHELL:
You say it's impossible?
14 MR. YIN:
Yes.
That's what I said.
15 If you have an existence of 20 feet, then it 16 will be probably impossible, not absolute, that most 17 likely people will pick up the discrepancy.
18-MR. MITCHELL:
Most, but not all?
19 MR. YIN:
Yes.
20 MR. N1CBOLSON:
That may be true, but, 21 again, remember, we are talking about a two-part problem 22 here, as-built condition as being one criteria, and 23 seismic analysis as being one other criteria.
24 The two are interrelated, but they also stand 25 alone as being two separate studies and requirements.
p DEAN MOBURG & ASSOCIATES - SEATTLE, WASBINGTON e
92 kb 1
MR. YIN:
Right.
We are trying to obtain 2
the actual information so we can go back and...
3 MR. NICBOLSON:
I believe what you're 4
saying, out in the field if I see a pipe that's running 5
20 feet unsupported, obviously I recognise that to be a 6
. problem if I see a two-foot sag in the thing.
Anybody is 7
going to notice that in the field, I would think.
8 MR. YIN:
So we don't know how many feet 9
of pipe you analyzed.-
We don't know how many dimensions 10 you verified, but, nonetheless, we know there were 11 60 drawings.
12 We can get some information after we get back 13 to.our office and we can ask that to other people.
14 MR. MITCHELL:
Sure.
I'm sure
~
i 15 Commonwealth will be happy to give you a large figure.
16 MR. NICBOLSON:
The main thing here, I 17 think, is to take each error on a stand-alone basis and 18
-analyze that error, the impact of the error and the 19 significance of the error, and then draw your conclusions 20 or run the analysis, or whatever.
21 MR. YIN:
By reading the transmittal 22 letter you forwarded to us, CECO did just that, right?
wt 23 They evaluated and they found these to be no problem?
24 MR. NICBOLSON:
We don't know.
25 MR. MITCHELL:
Basically, we received a DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
~
93
,i 1
telephone call from Commonwealth Edison that said there 2
were no problems on these drawings.
3 We wrote a letter back to Jim O' Conner stating 4
that we didn't believe that anybody could come to that 5
conclusion.
6 MR. NICBOLSON:
They also told us they 7
contacted the NRC on these various things, also.
~
8 MR. MITCHELL:
So they spent two weeks to 9
draft a letter to us..
They read me the letter over the 10 telephone and then we received it a little while later.
i 11 We didn't receive it right away.
We received the letter 12 a little while later.
~
13 But from the telephone conversations, 14 Mr. Nicholson and I both agreed that under the 15 circumstances, we felt that we had to notify the NRC.
16 We notified the director.of enforcement, who 17 used to be Victor Stello.
Because we received a letter 18 from Victor Stello's office, we notified that office.
19 We felt that was the proper procedure.
20 The reason we contacted Region III was because 21 in the discussions with Brent Shelton concerning these 22 five, he pointed out to me that he had personally 23 contacted the NRC, a representative of the NRC, and that 24 the NRC agreed with his findings.
25 MR. DANIELSON:
The specific dates and the DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
94 rv.
I specific instances that he is referring to I'm not sure 2
of.
3 MR. MITCHELL:
Well, I recekved a 4
telephone call from Mr. Barrison and he did'say that that 5
did take place, that a telephone call was received from 6
Mr. Brent Shelton and that it was, in their opinion, a 7
brief general discussion and nothing was meant of it 8
other than that they might be getting a telephone call 9
from me.
10 But the letter we received leads me to believe 11 that someone at the NRC has agreed with Commonwealth 12 Edison and its procedures, and that's why we contacted 13 Region III ourselves, to find out what was going on, 14 simply to find out who the person was so we could talk 15 with him and show him what we did and how we did it.
16 MR. DANIELSON:
As we mentioned earlier, l
17 we conducted our as-built effort review of Byron Unit I, 18 Isa did, Mr. Yin, and after much extensive effort and 19 several violations, Isa was satisfied, based on his 20 sample, that what was out there was acceptable.
21 Maybe that is what Mr. Shelton is talking of.
22 I'm not sure.
23 MR. MITCHELL:
I have no idea.
24 MR. MICHOLSON:
We asked Mr. Shelton, "Who 25 did you talk to?" and he wouldn't tell us.
i~.
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON 4
-e
,e,
-,er-
95 1
MR. YIN:
This is not important.
We are 2
not bere to defend what we have done.
We have not come 3
here to defend the licensees' program.
4 MR. DANIELSON:
Absolutely.
5 MR. MITCHELL:
We agree.
I don't think
~
6 it's irrelevant, but I see where you're coming from.
7 MR. YIN:
We would like to get as much 8
information as possible to go back to reevaluate what we 9
have done previously.
10 MR. MITCBELL:
I think this letter of June 11 the 30th, though, shows the intent of the licensee and 12 its procedures.
13 In that letter he says, "We do not believe that 14 these notices present any regulatory or safety concerns.
15 Applicable NRC regulations require that we have a 16 systematic program to demonstrate and document the inputs 17 to. seismic analysis performed for our power plants.
18 "As in every aspect of the nuclear regulation, 19 we strive for perfection in our documentation.
20 Recognizing the inherent limitations of any system, 21 however, the documentation program contemplates the l
22 possibility of errors and provides for them through a l
23 system of design margins and safeguards.
24 "In simpler terms, we would expect that in 25 making thousands of drawings, the data taker or draftsman t
i DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
2 96 s
1 will err occasionally.
2 "Both the regulators,' I believe that's the 3
MRC, "and our system contemplate the possibility of that 4
sort of error and provide compensating safeguards."
5 Our question in contacting Region III was, can 6
you tell us what those design margins are and safeguards 7
are that he's talking about?
8 MR. YIN:
I think he's talking in very 9
general terms.
As you know and everybody else knows --
i 10 maybe I shouldn't assume that -- there is no such thing 11 as an established safety margin, per se.
12 I guess a different system has a different 13 designed stress and has specific designed safety margins.
14 So it's very hard to say what is the fixed number.
15 So we're not trying to come here to debate how 16 safe is safe.
Of course, it's got to be safe; otherwise, e M-.xh_
17 it shouldn't be
- rn, right?
18 And we want to find out what information you 19 can provide us so we can go back to verify whether or not 20 the system is safe on a specific case-by-case basis.
21 We will exceed that.
We will look at the whole 22 thing.
23 MR. MITCBELL:
Our question is, say, maybe 24 we're bringing you people here and you shouldn't be here.
25 Maybe we've made a-mistake.
l
\\
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON i
-._,_..-,,._,_--..,,------,,-..-----.-,.-----,n...-
97 1
We want to say, "Is there a system.of design 2
margin safeguards that we don't have bere?"
Because we 3
understand 79-14.
That's cut and concrete.
We 4
understand Sargent-Lundy's as-built. walk-down program, i
5 okay?
And that says you will do something.
So that 6
information can be fit into other programs.
7 Are there any other margins or safeguards that 8
we've missed?
I 9
MR. YIN:
Margina of safeguards on a 10 system basis is this.
The deviation should be properly, 11 identified and evaluated by the responsible AEs.
~
12 MR. MITCHELL:
Absolutely.
13 MR. YIN:
And when he satisfies himself or 14 herself, then that is the end of it.
15 MR. MITCBELL:
That's right.
In other 16 words, if he has come in there or she's come in there and 17 looked at 18 MR. YIN:
So the basic issue here is not 19 the safety margin we're talking about.
It's whether or l
20 not the AE has knowledge of the deviation that you people 21 may identify using your own system.
22 MR. NICBOLSON:
We agree with that 23 statement and we'll live with that statement.
24 MR. MITCHELL:
Now, if he does that, then 25 he has come back and he has updated his documents to w
DEAN MOBURG E ASSOCIATES - SEATTLE, WASHINGTON i
1
98 1
reflect those) is that correct?
Under the way of doing 2
the work 3
MR. YIN:
According to the existing 4
system, they should upgrade the drawings.
5 M R.
MITCHELL:
In other words, five years 6
f rom now, if I pick up a document and I find an error on 7
it, that shouldn't be there, correct?
Because it was 8
evaluated and had gone through the system.
9 M R. YIN:
Based on the strictest 10 interpretation of the procedure, that should be done.
11 (Off the record.)
12 MR. DANIELSON:
We will go b,ack on th'e r
13 record now.
Messrs. Mitchell, Nicholson, Gavula, Yin and 14 Danielson are present.
15 MR. MITCHELL:
As I pointed out, we had a 16 question, but the NRC's-problem is just to look at what 17 we present and to evaluate it.
18 We were just concerned with, had the NRC 19 changed plans or knew of some documents that we didn't 20 know about, and that if they did, we would like to see 21 them so we could figure out maybe if we were on the right 22 track or we weren't, because this letter led us to 23 believe that there was something that we had not found.
24 Also, it was said in the letter, "We continue 25 to be confident that our program complies with applicable e
7 DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
99 1
NRC requirements.
For your information, however, we have 2
advised the NRC of our discussions with you and of the 3
notices which you have sent us."
4 So we felt that there were discussions between 5
Commonwealth and the NRC that brought forth these 6
margins, and they took a look at these five notices and 7
had made a determination already prior to this letter we 8
received or any conversation that the NRC had said there 9
was no problem.
10 MR. DANIELSON:
You made an assumption 11 it was not valid?
12 M R.
MITCHELL:
That's what I understand, 13 that it did not take place.
14 MR. DANIELSON:
It did not take place.
We 15 were aware of these particular. problems.
They told us of 16 them.
17 MR. MITCHELL:
Yes.
But they didn't show 18 you.
1 19 MR. DANIELSON:
They didn't show them to t
20 us.
21 MR. MITCHELL:
So I can take a look at l
22 this letter f rom my own mind and simply say, " Hey, the 23 NRC's position is that they are now taking a look at it J
24 and we are now going to...
25 MR. YIN:
No, no.
Let me clarify this a en.
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
-__-..., =,,.
-..*----.-,._e,------,-------.,----w,v-
,,,,.-..,1,,,y,-,w
~ - -
,,w.w----._~
l 100 (T
1 little bit.
For the specific allegation you brought 1
2 forth we have no procedure yet, but as far as the overall 3
79-14, the implementation by the licensee, Region III i
4 reviewed-it and accepted it.
5 Now, it's not -- they're saying that based on 6
the limited samples and the system, we could have been in 7
. error in some cases, in some areas, but as far as we're 8
concerned up to this moment, we have to stick to our 9
position that we accepted their program and they have met 10 the 79-14 requirement.
11 MR. MITCHELL:
Absolutely.
12 My question is, did you talk to Brent Shelton 13 about these?
14 MR. YIN:
I have not talked to him about 15 them.
16 MR. MITCHELL:
I agree with everything 17 you're saying.
Up until the moment that we are meeting 18 here, the NRC'1s position is that the licensee is in 19 compliance and he's doing his job and there is no 20 problem, unless we see it from this meeting.
21 MR. YIN:
That's correct.
l 22 M R. MITCHELL:
But according to this l
23 letter I received f rom them, -it was my impression from 24 the letter, and correctly so, that the NRC had reviewed i
25 the five notices and had discussion...
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON l
i l
l
101 1
MR. YIN:
That is, I think, a 2
misinterpretation.
3 MR. MITCHELL:
My misinterpretation, or 4
the letter is incorrect?
5 MR. YIN:
I guess your misinterpretation 6
of the letter, because we have not reviewed that and 7
we have no formal procedure on the whole thing.
8 If the letter is describing that we have 9
accepted their program as it was presented in your letter 10 to us, I think that's a false statement, but 11 MR. MITCHELL:
That's all I'm trying to 12 ascertain.
4 Is this sentence incorrect:
"For your 13 14 information, however, we have advised the NRC of our 15 discussions with you and of the notices which you have 16 sent us"?
17 MR. YIN:
But we haven't said we have 18 accepted that position.
19 MR. DANIELSON:
We were advised of the 20 five notices, but we have not reviewed to assure whether 21 there is or is not a technical problem associated with 22 these five notices.
23 MR. MITCHELL:
That's fair.
That was why 24 we contacted you personally.
We went the most direct 25 route, because that's where Victor Stello's group was.
J (s
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
102 1'
~
1 We contacted you just to find out what the heck this 2
letter meant.
3 As I pointed out earlier, we received the 4
60 drawings, and we used what we could of those drawings 5
and, parts of them, and we produced five what we call 6
error notices, if you will.
7 What we would like to do is couple the 8
discussion on those error notices with the answer from 9
Commonwealth Edison, because I think that it's fair that 10 we bring their stuff in.
11 The first error notice they're talking about is 12 our Error Notice 1 on Drawing SI-4, Revision 10 Alpha.
13 On that drawing, on our notice, we point out that if we 14 use the dimensions as shown on the drawing, we have a 15 10-inch pipe which we cannot attach to the accumulator 16 tank and we're about 5 or 6 feet from attachment.
17 MR. YIN:
This is Notice Number 18 MR. MITCHELL:
Number 1.
19 I guess the best way to do it is to read their 20 answer and then go into discussion.
How do you want to 4
21 do it?
22 MR. YIN:
I think the best way is for you 23 to summarize the problem and then present Commonwealth 24 Edison's response.
25 MR. NICHOLSON:
I personally worked on DEAN'MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
..~---.-- -..- - -- --.---
l
.103
('
\\
i I
this drawing, so I'm acquainted with what was going on j
2 here.
I could not use the locater points, as we 3
previously discussed, so I picked up at a point 4
penetrating the missile barrier wall.
5 I was confident that the sleeve going through 6
the missile barrier wall was indeed correct within an 4
7 acceptable error margin of, lets' say, 2 or 3 inches.
~
8 MR. GAVULA:
How did you determine that?
9 MR. NICHOLSON:
I went to the missile 10 barrier wall and the penetration schedule to see what the 11 location was, and working from this coordinate point, the 12 center point of the penetration, and following this line, 13 this 10-inch line -- I believe it's Class I and II --
14 working up the various coordinates, I knew that I had to 15 get to the accumulator tank.
16 I was also confident, although not positive, 17 that the accumulator was where the basic location 18 drawing, the architectural drawing, showed it to be.
19 In other words, in my mind, I was confident the 1
20 accumulator tank is not 5 feet different than the t
21 architectural drawing represents for this plant.
So I am 22 trying to close now between penetration, sleeve and 23 accumulator tank.
24 MR. GAVULA:
So your two points are 25 something given on -- the first point on another drawing
)
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
104 i
I and the second point you actually referenced the location 2
of the tank on this drawing?
3 MR. NICHOLSON:
That's correct.
I backed 4
up the location of the accumolator on other drawings, 5
because there is more than one connection to that tank.
6 So after I made three or four checks on the 7
accumulator, I was confident that the accumulator is 8
where it's supposed to be.
Nobody will' argue that, I'm 9
sure.
10 MR. YIN:
The penetration should be 11 accurate.
The heavy equipment location should be 12 accurate.
13 MR. NICHOLSON:
Should be accurate, give 14 or take an inch, two or three.
15 Also, I'm trying to find errors on this drawing 16 in a short distance.
If I find a 3-inch error over a 17 500-foot distance, no one is going to be too concerned.
l 18 So my intent on working this drawing is to find the 19 greatest magnitude error I can in the shortest span.
20 So from this point to the accumulator tank I 21 find it 5 feet 3-1/2 inches off.
22 MR. YIN:
That is because of the angle?
23 MR. NICHOLSON:
Well, immediately, I don't 24 know.
So I reverify the sleeve.
I reverify the tank.
25 I'm satisfied that's correct, and I know that somehow
(
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
,.. - ~,
105
(#
.1 between these"two points there is something wrong, or.I 2
an interpreting something incorrectly and doing the math 3
incorrectly.
4 So I reverify my dimensions, my angles, and, lo 5
and behold, I find, " Gee, whiz.
This thing would have 6
worked had this angle of 33 degrees been represented 7
correctly up here on -- where it continues on the drawing 8
from Point A."
I just reversed that and I say, " Gee,
~
9 that's kind of funny."
i 10 I still don't know if that's the correct 11 solution to this problem, but being in the game for a 12 number of years, you can make some guesses, generally
(
13 correct. guesses, and you say, " Gee, if I just slip that 14 over, it's going'to work."
15 Now, there is still a little 3-inch error 16 between these two points and the' center of this which I 17 can't account for.
I've got the magnitude of it, 5 feet, 18 but the 3-inch error I can't account for.
19 Now, that could occur here on this sleeve.
So 20 I reexamine the sleeve, because not always does a pipe 21 penetrate the sleeve exactly dead center.
22 And for this reason they do a gap study to 23 determine'what is the distance from the pipe in the 24 northeast, south and west azimuth, the distance from the 25 pipe to the sleeve.
I haven't seen any gap studies on
(~
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON i
_ _ - _ - _ _... _... _,, - -. _. -, _ _ _,.. _, _ ~ _..
106 1
Commonwealth Edison, so I don't know.
2 MR. MITCHELL:
Do they have gap studies?
3 It calls for it, but I have never seen any.
4 MR. YIN:
The gap measurement is a part of 5
the requirement of 79-14.
6 MR. NICHOLSON:
Anyway, the first thing I 7
do is investigate the sleeve.
I say, "Well, they call 8
that a 16-inch pipe sleeve, and I realize that I'm 9
working with a 10-inch pipe."
So I've got 3 inches all 10 the way around that pipe, and that could account for my 11 3 inches.
12 So I go back to the sleeve schedule.
I look up 13 the sleeve to verify that it is a 16-inch.
Lo and 14 behold, I find out that's not a 16-inch sleeve.
That's 15 an 18-inch sleeve.
16 I even have more room than I thought I had.
17 The drawing represents it as 16, but, in fact, it's an 18 18, and I'll bet the sleeve schedule is more correct than 19 this.
20 So I say, "Well, that can account for it."
I'm 21 not penetrating the sleeve properly.
I don't have the 22 gap study, which I would generally request, or the gap 23 measurements for that particular' sleeve.
24 But I'm confident I an exactly 5 foot out just 25 based on this.
In fact, a distance of 2.62 feet times 2,
{
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON D
107
('
\\4 1
because I'm going to swap that over here.
2 MR. YIN:
The 18-inch pipe sleeve you show 3
on the civil drawings.
The 16-inch pipe sleeve is shown 4
on the piping isometric drawings.
5 MR. NICHOLSON:
I didn't report that to be 6
an error, because I considered that to be an 7
insignificant drafting error.
8 It's not correct, but I was looking for 9
something bigger than, " Hey, you misrepresented your 10 sleeve by 2 inches."
I was looking for a 5-foot error, 11 which I found.
12 Lo and behold, we get the answer back from
~
13 Commonwealth Edison.
14 Well, before I get to their answer, I see on 15 the drawing "RFA-3114" -- and I don't have RFA-3114 nor 16 do I even know what it means, RFA.
I assume, I guess, 17 it',s " revised field adjustment," or something.
I've i
18 never seen RFA before.
I've seen ECNs and everything, 19 but not RFA, but I know it's got something to do with 20 this.
21 I read it and it says, " Installation cut in two 22 levels only."
It doesn't make any sense to me, so I have i
l 23 to ignore it and concentrate on these angles.
I 24 MR. MITCHELL:
The reason we ignored it is 25 that that is taken care of in Revision -- I believe
(
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON i
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108 1
Revision 2 way back in 1979, and we know that all field 2
change notices and ECNs should be incorporated into this 1
3 document at this time.
4 This should reflect that, plus the fact that 5
this had been walked down, an as-built check.
So we 6
believe that this is the actual installation as shown on 7
the drawing.
8 This is what I'm talking about.
Five years or 9
ten years from now, we wo'uld assume that this is what the 10 document shows, that this is the correct as-built walk-11 down document.
12 so, therefore, Scott says, " Hey, we notify the 13 utility.that this seems to be a discrepa.ncy on the as-14 built drawing."
15 Now, if it is a discrepancy and it has gone 16 through the analytical model, does the analytical model i
17 represent this or does it represent something else?
That l
18 is the question.
If the analytical model represents this 19 like we believe it does, then there is a problem.
20 Now, you say that an engineer can look at this 21 and he can see that there is no problem.- We also believe 1
22 their system is supposed to come back and check this and 23 correct it.
It has not done that.
l 24 MR. NICHOLSON:
The other thing that 25 worried me in this particular one is the fact that we do f.
I DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON A
109 I
have a hanger ~ support, which we didn't have our hands on, 2
but we know it's in existence, right here, this SI-03041.
3 And it is on this particular segment of-the pipe, which 4
changes location.
5 So without that support, I don't know if the 6
support is, in fact, over here or where it should be or 7
on this segment as represented on the drawing.
8 What happened to this stress analysis?
Which 9
position did the stress analysis assume this pipe to be 10 in?
As a lay person, I assume the stress analysis was 11 done as the drawing indicated it to be.
That may be an 12 incorrect assumption.
13 MR. GAVULA:
That has to be verified.
14 MR. MITCHELL:
Now, this is the answer 15 from Brent Shelton on isometric SI-04.
16 "Our isometric drawings were originally 17 prepared by Southwest Fabricating.
These initial 18 Southwest drawings were copied and reproduced to form the 19 basis for the present as-built drawings.
The drawings 20 were then changed or annotated as necessary to reflect the 21 final configurations.
22 "With respect to Spool SI-4-8, this spool was 23 fabricated as shown on the isometric and as described in
(
24 your notice."
In other words, I understand that we l
25 showed it like the drawing showed it.
l DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
110 1
"When preparing to install this spool in the 2
field, we determined that it would not fit.
The solution 3
is shown on our attached Sketch A."
In other words, they 1
4 just rotated it.
5 "The spool was field cut and rotated 30 degrees 6
north of the east-west centerline from its original 7
position.
This field cut and rotation allowed closure 8
with the tank.
9 "Although the isometric is not pictorially 10 correct, the note discussing.this field cut is on the as-11 built drawing supplied to you.
12 "The piping analysis from a stress point of 13 view works in either location since it was a rotation as 14 identified on the final drawing."
15 Now, I would like to address that.
16 The pipe comes down.
It has 33 degrees.
It's 17 incorrect.
The movement of this pipe should be back to 18 66 degrees.
We have plus or minus 5 degrees acceptable, 19 63 degrees out -- it turns to 61.
20 I know of no seismic analysis program that will 21 allow a deviation more than plus or minus 10 degrees.
So 22 I am worried.
23 The idea that you can just rotate it, that's 24 fine and dandy, but you must come back, and the idea is
(_
to check the as-installed configuration with the 25 DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
111 1
1 analytical mod'el on the tolerances and make sure that 2
they're correct.
If there is a discrepancy, why is there 3
a discrepancy?
4 The discrepancy on this drawing is to update 5
this drawing to reflect the discrepancy.
This should 6
have been caught.
It wasn't caught.
7 MR. NICHOLSON:
And, of course, the 8
loading for that hanger, you can't simply rotate that 9
segment of pipe around 360 degrees and expect your 10 loading not to change, based on where does a hanger 11 attach to something when you're finally done rotating it.
12 MR. GAVULA:
Well, within limits.
You
. ('
13 have to realize that from a stress analysis point of i
14 view.you can do things with rotations that are 15 acceptable.
16 MR. MITCHELL:
That is correct.
You are 17 allowed to rotate it, but you also have some...
18 MR. GAVULA:
I agree that the' 19 documentation should be there, but fro a a stress analysis 20 point of view, and that's bottom line, where you have to 21 get back into, does the stress analysis that is existing 22 still represent what 1
23 MR. NICHOLSON:
Was originally approved.
24 MR. GAVULA:
Yes.
Is the stress analysis 25 still bounding?
1 DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
,n,,n_..__
112 1
With the seismic category you can in some cases 2
swap directions back and forth like they have done and i
3 you will get exactly the same stress.
4 From an analytical point of view...
5 MR. YIN:
We're not trying to defend i
6 anybody.
7 MR. MITCHELL:
No.
I'm learning 8
something.
Go ahead.
9 MR. NICHOLSON:
We're trying to get an 10 understanding here ourselves.
11 MR. YIN:
The issue is clear.
First of 12 all, you're saying that they're violating their own 13 procedure, a maximum of 5 degrees.
We want to go back 14 and verify that.
15 Secondly, we want to verify that once the 16
. stress isometric, not the as-built isometric 17 MR. MITCHELL:
The stress.
18 MR. YIN:
Once the stress isometric 19 reflects the as-built condition.
These two things we're 20 going to promise that we're going to do.
21 MR. MITCHELL:
So that was number one.
In 22 other words, they said, "Yes, you're right as far as 23 pictorially, but there is no stress problem."
Again, we 24 can't answer that without your bailiwick.
25 So the next drawing is CC-46.
\\.-
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
113 t
1 MR. NICHOLSON:
We were confident on that 2
one, though, that we reported a problem that showed a 3
violation of 79-14.
4 MR. MITCHELL:
The next one is CC-46 5
isometric, Revision 7-P.
6 I think you guys are satisfied now that the 7
information we used is only the information on the 8
drawing.
We don't make up anything.
f 9
MR. GAVULA:
I don't think there is any
(
10 doubt about that.
11 MR. MITCHELL:
So on this particular 12 drawing we know that we can't use the location point.
We 13 do know where this is and we do know where this is and g
14 we're quite satisfied that we can run it within some 15 degree.
16 MR. YIN:
Excuse me.
As far as the 17 equipment location, we probably can, more or less, assure 18 that's the right location, but the other end you just
-19 pointed to on Drawing D-56 -- or actually, CC-46...
20 MR. MITCHELL:
I think it's CC-40.
21 MR. YIN:
That is the connection, I mean, 22 the branch line, connecting into another system.
I'm not 23 too sure you can say that's the fixed location.
24 MR. MITCHELL:
You're right.
Also, we l
25 used the sleeve on the missile barrier wall.
l
~rL DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
l 114 v
1 "MR. YIN:
Okay.
The sleeve.
I can buy 1
2 that.
3 MR. MITCHELL:
But it just happens to work 4
out that everything works out fine.
5 Now, what we did is we started at a point and 6
we went down here 11 feet or 13 feet, and we came up here 7
and we used the angles, okay?
8 Now, inside containment you have to use the 9
Engles to show your leg orientation, and we used those 10 angles.
11 We come down here and we drop down and we use 12 another angle, and then we came over here and we used i
13 another angle, and we did the whole thing.
14 Scott, you take it from there.
15 MR. NICHOLSON:
Well, we can see that the 16 offset here is 22 degrees 32 minutes in a horizontal 17 direction off of the azimuth line.
In this case it's the
~
18 east-west coordinate.
19 We can see that these two legs, two lines, are 20 supposed to be parallel, just general isometric drawing 21
. principles.
This is vertical, this piece here.
We also 22 see that we have a verifying angle of 22 degrees 23 32 minutes off of the same east-west azimuth.
24 Now, we get to a peculiar situation.
This leg 25 going through this miasile barrier wall says 22 degrees DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
-w-
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115
_.(
32 minutes offlof the north-south azimuth, okay?
1 So if a person were to use standard isometric 2
drawing procedures and the angles as indicated here, he 3
would say you have 22 degrees plus 90 degrees plus 4
another 22 degrees for a grand total of 135 degrees.
5 Now, that rings bells to me right-off, because 6
It's it's now no longer a standard elbow of 90 degrees.
7 a specially cut and welded elbow, but that's okay.
8 That's common in nuclear power plant construction.
9 so I continue to go through it with my 10 coordinate system to penetrate the missile barrier wall.
11 All-of a sudden, I can't get a penetration here, because 12 the angle on this leg is not perpendicular to the missile 13 14 barrier wall.
I searched for the error, and you can see the 15 16 error yourself right.now.
17 MR. GAVULA:
Yes.
18 MR. NICHOLSON:
Instead of this angle of it 22 degrees 32 minutes being on this side of the pipe, 19 should be on the other side of the pipe, a simple error.
20 And, yet, when a person utilizes a drawing, you 21 must do what the drawing tells you to do.
If it says to 22 23 make this segment 4 foot long, you have to make it 24 4 feet.
You're not privileged to say, "No.
I'm going to 25 ignore that 4 feet.
I'm going to make it 3 foot 6."
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
116 1
The"same thing app 1'ies to angles.
If it says 2
22 degrees from the north-sound asinuth, I have to follow 3
that.
4 MR. MITCBELL:
So we did.
So, naturally, 5
we came up with a problem and we would pictorially show 6
it.
We would say, " Hey, there is a problem."
7 The answer from the field was, "The piping in 8
question is installed as shown on the isometric drawing."
9 Be is saying that the piping is installed as shown on 10' this drawing.
11 MR. GAVULA:
Well, it shows it's going 12
_through that sleeve.
13 MR. MITCBELL:
"The piping in question is 14 installed as shown on-the isometric drawing."
It doesn't 15 say anything about that sleeve.
It-says that if I follow 16 the dimensions on here, that's how it is installed.
17 MR. YIN:
We understand that.
18 MR. MITCBELL:
"The angle of 22 degrees
)
19 30 minutes is shown three times on this drawing."
Three 20 times.
Well, let's take a look at that.
J l
21 One, two, three, and there is a fourth one.-
22 MR. NICHOLSON:
"How do you come up with 23 three when we come up with four?"
That's okay.
24 MR. MITCHELL:
The only purpose of this 25 angle is to describe the skew of the wall and associated f
s_
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON i
117 I
piping from the north-south centerline.
2 MR. NICBOLSON:
It has nothing to do with
-3 the wall.
These angles on this pipe have nothing to do 4
at all whatsoever with this wall.
5
- MR. GAVULA:
Okay.
Continue.
6 MR. MITCBELL:
"Any one of the three 7
angles would have been sufficient to show the skew.
The 8
angles in question are not as-built angles since they are 9
not boxed in and are similar to locater points."
10 In other words, if they're locater points, then 11 we can't use them.
12 MR. GAVULA:
Okay.
13 MR. MITCHELL:
I would like to point out 14 that on Commonwealth Edison as-built drawings they do not 15 box in the angles, and if you would like to look at a few 16 of the drawings, I would-be happy to go through them.
17 Those angles are supposed to be boxed in based on 4
18 Sargent-Lundy's specifications and their own 19 specifications.
20 MR. YIN:
As you can demonstrate on the 21 drawing, they were not boxed in?
22 MR. MITCHELL:
That's right.
They.were 23 not boxed in on any drawings.
24 MR. GAVULA:
They may have other errors 25 there.
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
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118 1
MR. NICHOLSON:
We don't know if they're 2
verified or not.
3 MR. MITCHELL:
In_other words, they're 4
unverified to me.
I don't know what the heck he's doing.
5 The specs say they'll go in and verify these things, and 6
they're not on any of their drawings.
They do it on 7
bends, but you have to use them.
They're certainly used 8
in the seismic analysis.
9 "While'we acknowledge that the one angle you 10 pointed out is discrepant -
" well, we didn't point out 11 any.
We just said it was wrong.
"You tell us what is 12 wrong with it."
13 "While we acknowledge that the one angle you 14 pointed out is discrepant with respect to the other two-15 angles and should have been shown on the opposite side of 16 the pipe, one must selectively ignore the other two 17 angles and the practice of not dimensioning 90-degree 18 elbows to reach the configuration shown in the notice."
19
'What are you talking about?"
There is a 20 90-degree angle.
21 MR. GAVULA:
If you look at the standard 22 practice -- you would have to go and look at the other 23 drawings, but they typically will show -- put the 24 parallelogram on there to show angles that are not 25 90 degrees, and I think that's what they're referencing.
1 DEAN MOBURG & ASSOCIATES -_ SEATTLE, WASHINGTON t
I
119 1
' MR. MITCHELL:
I have no idea.
All I'm 2'
saying is that I used -- or Mr. Micholson or 3
Roger Elkerson, one of our employees -- used all the 4
angles that are shown on there and it didn't work.
5 Piping stress analysis results would be 6
acceptable if either configuration were used.
I can't i
7 answer that.
Again, you're allowed plus or minus i
~
8 5 degrees, and I'm way over that one.
9 MR. NICBOLSON:
Is that a "no" for the 10 record?
11 MR. GAVULA:
You would have to go in and 12 look at the stress analysis, and that's basically what
~
13 you have to do, is match -- if there is a discrepancy 14 between some dimensions here, you need to go back into 15 the stress analysis and verify what the stress analysis 16 used versus what the as-built is.
17 If there is a drafting error, then the drafting 18 error needs to be corrected.
19 MR. MITCHELL:
No problem at all.
20 Scott, do you have CC-427 21 MR. YIN:
Again, just for the record, we 22 are not going to tell you all we are going to do.
23 MR. MITCHELL:
No, no.
We understand 24 that.
Anything you want off the record, as far as I'm 25 concerned, can be taken off the record.
(~
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
]
120 1
" MR. YIN:
Mo, no.
It's_not going to 2
change the record.
We're just saying that most likely we 3
will go that route, but we will reserve our options to go 4
over, more or less, what we talk about.
5 MR. MITCHELL:
Absolutely.
6 I would like to read the answer, first, on this 7
one here._
The isometric drawing is CC-42, Revision 15-C.
8 "This isometric does not appear to be valid to 9
us.
There-is closure of the.as-built dimensions.
10 Apparently, CIE scaled and angled from the cardinal.
11 points as opposed to the isometric drafting practice of 12 assuming angles not shown to be 90 degrees.
13 "If our assumption or understanding of this 14 item is incorrect, we would need further information or i
15 explanation from CIE."
i 16 We show this line could not attach to CC-43.
17
' Missed it by about 5 or 6 feet.
And we drew it a special 18 way, okay?
We drew it in course to our understanding of 19 isometric procedures.
20 Our understanding of isometric procedures is 21 that if an angle is not shown, then the pipe, the 22 continuation piping, is on the cardinal line.
23 Maybe we might have to show you what we are 24 talking about.
25 MR. GAVULA:
Please do.
(-
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON I
121 I
1
' ' MR. MITCHELL:
We think we can clearly 2
demonstrate this.
3 We've got a pipe system that comes out here and 4
it's got a bend in it, all right?
If there is no angle 1
5 shown there, we assume it to be 90 degrees if it's on an 6
isometric drawing.
7 MR. YIN:
That's correct.
8 MR. MITChELL:
So if an angle is not 9
shown, it is on the cardinal lines, whatever they are.
10 MR. YIN:
Yes.
11 MR. NICHOLSON:
Either the north-south 12 line or the east-west line.
/
13 MR. GAVULA:
You've got to watch out, t
14 though, because if the line isn't parallel to the 15 cardinal lines, then you have got to figure that they may 16 have used the standard fitting.
So you have to really 17 watch your interpretation of that.
4 18 MR. MITCHELL:
But it's shown.
19 MR. NICHOLSON:
Parallel.
20 MR. YIN:
If it's offset, then you show it 21 at an angle.
22 MR. MITCHELL:
You can have a standard 23 fitting here, okay?
If it's a standard fitting, there 24 will be an angle shown, and I'll show that on every one 25 of these drawings.
That is the rule, 33 degrees, and DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
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't 122 r,
I that's a standard elbow, and I can show you that.
2 See, these are all standard elbows, 45 degree, 3
but it's still shown, because it's not a cardinal line.
4 Right there, 90-degree elbows, but they're not on a 5
cardinal line.
6 If an angle is not shown, then it is assumed to
~
7 be 90 degrees on the cardinal line.
8 MR. YIN:
What he is saying is correct.
9 MR. NICHOLSON:
That's why, with that in 10
- mind, we simply do exactly what this area of the drawing 11 tells us to do.
12 You can see that this line here is parallel to 13 the north-south cardinal line.
l 14 MR. MITCHELL:
Do you want those angles?
i 15 MR. NICHOLSON:'
Yes.
16 MR. YIN:
Well, from the look of it, I 17 think what you're saying is correct.
Bere you show a 18 16 degrees and 30
- end: : minute offset, and then here 19 it's right on the cardinal line.
20 MR. NICHOLSON:
You pointed to the 21 16 degrees 30 minutes, which is a problem in itself, in 22 that we know if we have a straight line and another line
{
23 intersecting that line, you have 180 degrees total.
24 But this 170 degrees, which is verified here 25 for the bend between the two pipes...
f DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
123
~
1 NR. GAVULA:
So they did verify that 2
angle?
3 MR. NICBOLSON:
Yes.
It's bozed in as 4
170 degrees.
5 Then they also have this unverified 16 degrees 6
30 minutes.
If you add the two together, you come up
^
7 with 186 degrees.
That is a problem in itself, which we 8
didn't report because it's so close to the 5-degree 9
tolerance.
10 MR. YIN:
Yes.
That meets.the 5-degree 11 acceptance deviation.
So you, more or less, verify the w.
12 intent, the design intent.
(~
13 MR. MITCHELL:
Yes, but we didn't worry 14 about that.
15 MR. YIN:
That's not the issue.
16 MR. NICHOLSON:
The issue is, this is on 17 the cardinal line.
This is a vertical segment.
This leg I
18 here is also on the cardinal line, the east-west.
19 MR. YIN:
It has kind of crowded the 1
20 joint.
21 MR. MITCHELL:
Yes.
It's very crowded.
j 22 MR. NICHOLSON:
And then we have a 23 vertical drop.
24 Now, you can see this in better perspective, 25 because I put it back on the normal mechanical drawing 2
(*
1 i
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON i
l
,_..,_,,n,___,,,_
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124
/
I configuration.
2 MR. GAVULA:
Gave it a plan view.
3 MR. NICHOLSON:
Gave it a plan vie ~w, 4
right.
5 so you can see that we're coming up here on 4
6 this angle of 24 degrees 43 minutes, which is there.
7 It's hard to see.
8 Do you see this little arrow here?
9 MR. MITCHELL:
This arrow right here with 10 this line here.
11 MR..GAVULA:
Okay.
12 MR. NICHOLSON:
So I have an offset at l
I~
13 24 degrees 43 minutes.
You come up vertical and drop due 14 east, which is this leg here.
15 MR. MITCHELL:
Why don't you go ahead and 16 show him how that works.with those things.
17 MR. NICHOLSON:
As you can see, we are, in 18 fact, roughly parallel within general drafting scales, 19 five points of this one and this is parallel there.
20 MR. GAVULA:
Show me that one.
21 MR. NICHOLSON:
We can see our 24 degrees i
22 43 minutes off the...
23 MR. GAVULA:
So that's what that other 24 dimension line is?
f 25 MR. NICHOLSON:
Yes.
, (
i DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
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125
~
e 1
We have a vertical drop and then we_have 2
33 degrees off the horizontal through a 90-degree elbow.
3 Number one, we went from this line, which is on 4
the axis.
All of a sudden, we're off the axis.
We're 5
33 degrees off the axis.
i 6
And if we do that, we pull this entire leg here 7
out of whack with joining up with the existing.
8 MR. MITCHELL:
So we write up a -
go 9
ahead.
10 MR. GAVULA:
Go through that again.
I'm 11 still 12 MR. MITCHELL:
He said that if we go by-13 and follow the isometric rules of drafting, doing what 14 we've done, instead of attaching here at CC-43 like I 15 want to, attaching here, by moving this system, by 4
16 following all of the dimensions available, I don't 17 attach.
l 18 MR. NICHOLSON:
We should have a 33-degree 19 angle on this leg of pipe, over like that, which is this 20 leg here.
That's just drawn on the axis.
21 MR. MITCHELL:
And the reason we know what l
22 that should be, number one, we've got the "M" drawings 23 for Unit II, and these drawings are supposed to be mirror 2'4 image.
You've heard that term, " mirror image."
25 We went out and looked at that and we said, i
l DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON l
l i
. _. _ - - - - - -.. _... _ -. _ _ -. _ - - - _ _. ~. _. _ _ _ _. -. _ -. - _. _ _ _. _ _ _.. _ _ -.. - _ - - _ _ _. - _. -.,
i
126 1
" Hey, you put'33 degrees on that sucker and it will 2
work."
3 MR. NICBOLSON:
See, if you put an angle 4
on this leg, 33 degrees, in other words, take this leg 5
and swing it like this, hold everything here constant, i
6 you will line up perfectly.
i 7
MR. GAVULA:
Okay.
8 MR. NICHOLSON:
But what did we do?
We 9
followed exactly the way it's drawn and exactly the way 10 it's dimensioned.
So not only is this drawn incorrectly, 11 it's also dimensioned incorrectly.
12 MR. GAVULA:
Did you get back to them?
'13 MR. MITCHELL:
We pointed this out to 14 them.
We physically sat in front of Brent Shelton and we 15 said, " Brent, do you understand what's going on here?"
16 The answer is, "I don't think it's a problem, 17 because I verified everything."
I 18 Let's take a look at his answer.
19 MR. NICBOLSON:
Maybe you had better read 20 it first.
21 MR. MITCHELL:
I already read it.
22 These are the cardinal lines.
What he says is, 23
" Hey, I've got a pipe coming up here like this, and I'm 24 24 degrees off that cardinal line."
25 Now, if you understand how to do isometric 4
g-DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
127
[ ~.
1 drawings, you'know the isometric drafting practice of 2
assuming angles not shown to be 90 degrees.
So he's 3
saying if it's not'shown, I come down here 90 degrees.
4 That is a 90-degree angle there.
The 5
dimension, this is north.
This is west.
This is south 6
and this is east.
This is zero.
This is 90 degrees and 7
this is 180.
8 The distance from north to here is 24 degrees.
9 The distance from here to' east is 66 degrees, right?
10 Well, if I subtract 66 from 90, what does that make this 11 angle here?
24.
\\
I 12 What does that do to that angle up here?
If 13 this is 24, this is 24, this angle is 24, not 33 as shown i
i 14 on the drawing.
15 So using Mr. Shelton's procedure, I have to 16 subtract 24 from 33.
I come up with a 9-degree error, t
17 even using his method.
I'm still outside my tolerance.
I 18 My point is -- and Mr. Nicholson's point -- the 19 drawing is incorrect.
Was this data set into the 20 analytical model?
You're going to take a look at that.
21 MR. YIN:
Even if you -- according to your 22 drawing, using 24 degrees, you still have not mentioned 23 this line here.
Is this drawing 24 MR. NICHOLSON:
These are correct.
l 25 33 degrees.
f a
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON l
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128 1
MR. MITCBELL:
24 is not correct.
2 MR. MICBOL80N:
33 degrees.
3 MR. MITCHELL:
24 won't work.
4 MR. YIN:
So this is a correct dimension 5
and the 24 is wrong?
6 MR. MITCBELL:
No.
24 is correct, also.
7 He doesn't have a dimension right here on this line.
8 MR. GAVULA:
He doesn't orient that.
9 MR. MITCHELL:
Be is off 33 degrees.
10 MR. NICHOLSON:
This leg is drawn like q
11 this.
12 MR. GAVULA:
It should be perpendicular to 13 this.
14 MR. NICHOLSON:
It should have an angle 15 here, 33 degrees.
16 MR. MITCHELL:
So our question is, even 17 after we explained that to them, they didn't understand 18 it.
They've got access to the best analytical minds in 19 this country, and all the money in the world and they 20 still couldn't figure that out, even after it was 21 explained to them.
22 On CC-37 -- have you got that one, scott?
23 MR. MICHOLSON:
Any. questions on this?
24 MR. GAVULA:
No.
25 MR. MITCHELL:
What we were trying to show i
(..
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
129
(-
1 on this partidular drawing was that there were just a lot 2
of errors on it, little errors.
No big deal.
Just a 3
bunch of errors.
4 One of the errors we show is that they have an 5
as-built dimension of 38 feet to a support.
If we use up 6
the chain dimensions from support to support, we get 7
33 degrees, or just a discrepancy of 5 feet.
8 MR. NICHOLSON:
33 feet.
9 MR. MITCHELL:
Bere it says 38 feet.
10 MR. NICBOLSON:
You said " degrees."
11 MR. MITCHELL:
I'm sorry.
12 So it's an error.
Now, we say, " Gee, whiz,
~
13 over here, guys, we have a dimension of 5 feet here, but 14 if I add up the chain dimensions, I find just the 15 opposite."
I find the overall dimension correct, but 16 these little chain dimensions are incorrect.
No big j
17 deal.
18 I come in and I say, "I have a chain dimension 19 of 11 feet 3 and -- I believe it's 1/4 inches -- versus a 4
20 chain dimension of 12 feet and 1/2 inches,'so one of them 21 is incorrect," and I draw a sketch of it.
22 I say, "One shows 11 feet, and this shows i
23 12 feet.
No big deal.
Just a discrepancy."
There's a 24 lot of discrepancies on this drawing.
That's why I show 25 it to you.
f.
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
-. -\\
130 k$
1 The answer from these people is,'*This not' ice) 3
?.,e..: : a u 2
shows the dimension from the centerline of the main pipe 3
to the location of a 3/4-inch test line.
It has 10 feet 4
1-1/8 inches.
This dimension is apparently discrepant 5
and should be 9 feet 3-3/4."
So he's saying that this 6
little line -- this number here is wrong.
7 "This dimension is information, location, for 8
the 3/4-inch test line and was not used in the piping 9
analysis.
10 "The overall length, 11 feet 3-3/4, was used in 11 the piping analysis, but the analysis results are 12 acceptable using either overall length, as such i
13 discrepancy has no engineering significance."
14 What I point out is, " Bey, I don't know from a 15 seismic whether it does or not, but I do know if you use 16 this dimension here, none of my supports are going to 17 work," and I explained that to him and be still got it 18 wrong.
19 The problem is, the two little chain dimensions 20 are correct.
This is wrong, and here is your 12 feet 21 that shows what your design was, okay?
These two match 22 the design.
This overall length doesn't.
23 "My goodness, you people are so confused."
24 Even when they're sitting down with the documents in 25 front of them and we have explained it, they still get DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
f 131
{
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the wrong answer.
..e 2
MR. GAVULA:
At this point we don't know' l
3 which one is correct.
..e 4
MR. MITCBELL:
I do.
- 1' '
r
._ A
.e 5
MR. GAVULA:
There is an error and we need l
6 to go back and verify it.
7 MR. MITCBELL:
Yes.
I mean, I know what 8
it is.
9 MR. NICHOLSON:
Well, we don't know proof 10 positive, but we do know 12 foot 1-7/8 works.
It gives 11 us a closed loop versus the verified 11 foot 3-3/4 inch, 12 which does not work.
Also, the 12 foot 1-7/8 does 13 coincide with the two verified intermediate dimensions l
l i
14 here.
15 MR. YIN:
What you are pointing out is a 16 drafting discrepancy.
17 MR. MITCHELL:
Sure.
That's all.
18 MR. GAVULA:
But at this point you have I
19 not verified which one is correct.
20 MR. NICHOLSON:
We can't, other than 21 through mathematical check.
I would have to go out in
?2 the field, get out my tape measure and physically measure 23 to be 100-percent positive.
24 MR. YIN:
What system is this?
25 MR. NICHOLSON:
Component cooling.
i DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
132
~
1
" MR. MITCBBLL:
The last.one before lunch'..
Again,' we were trying to 'show simply a - >*q;;.f.
.; % r;gpgny p py q :
k
~~
2 is Number 5.
3 representative sample of what we were finding." ~
4 Now, this is a Class "D"
line, and as I read 5
earlier in the specs, they want to check the hanger...
6 MR. YIN:
Excuse me a minute.
I thought 7
on CC-37 you pointed out three-different problems, right?
8 MR. MITCHELL:
Yes, I did.
9 MR. YIN:
Maybe I wasn't paying attention.
10 MR. MITCHELL:
I didn't bring them all 11 out.
We didn't look at all of them.
12 MR. YIN:
Okay.
So you just worked up 13 one.
14 MR. MITCHELL:
Number 4, not 4-A or 4-B.
15 We were just trying to show that this was a...
16 MR. DANIELSON:
Drafting errors.
17 MR. MITCHELL:
Yes.
18 MR. YIN:
Okay.
Fine.
Thank you.
19 MR. NICHOLSON:
We would be happy to pull 20 them out, if you want.
21 MR. YIN:
No.
That's fine.
22 MR. MITCHELL:
Now, I was mentioning 23 Class "D" lines.
Sargent-Lundy has said that they want 24 to check the hanger locations of Class "D" lines inside 25 containment.
They want to walk down to those lines..
,f is DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON I
~. -
133 C'
That's what their specification says.
so We say, "Well
?
1 we'll show them one of those.' "M;l'%n,' ajkri:xymgqW,5%k Dc.:, r.4
=A,
7 2
3 Now, here's what we've got here.
We have a
.e.
-4 dimension from the ceiling, an as-built verified 5
dimension to a line, and we know that these lines are 6
typically a 3-foot-3 separation from each, and I have'an 7
as-built dimension from the top line to a support.
8 So what we're looking at is, is that support 9
located where it says it is?
Will it attach to steel?
i 10 If we use the as-built dimensions as shown on this 11 drawing, what happens is, I.take one of these lines and l
12 set it right into a bunch of steel.
The support goes way r
13 above the floor it's supposed to, okay?
14 Therefore, there is a discrepancy, all as-built 15 information.
So I would think that this is something 16 someone would want to know about.
17 The answer from the field is, 'This notice 18 shows 3 foot 2-3/4 dimension line to the leader IN006AD,"
19 that's to this line right here, "as opposed to the leader 20 from line W004JD."
That's this right here.
21 "While the location of this arrowhead is not i
22 shown properly," he is saying it should be shown up to
]
23 here, "it does not cause any engineering confusion, 24 because all the elevations of the floor and various 1
25 branch lines are shown."
!C DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON l
i
~ -....., -... - --..-, _
134 (h
~
Uny'4rified dimensions..m p w.gwe're.,x u. m y[s.i s.
First told we3 1
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2 have to use verified.
Now he's saying we do'n't have to 3
use verified information.
+3ca.: n n.
4 "Again in this case, the remaining information mustbecollectively1]gnoredhoreachtheconclusion
~
~
~
5 6
offered in the notice."
7 NR. NICBOLSON:
You can see where the 8
problem comes here.
I have a grating, and he says, "Come 9
down 3 feet and then typically go up 3 feet from here to 10 here."
You put this leg right back into the grating, 11 because 3 feet and your typical 3 feet here are.the same.
12 So if you remove this arrowhead from this leg 13 and move it up to this leader right here, it will work, 14 but he states that this does not cause any engineering i
15 confusion, because all these are given, these elevations.
16 I disagree with that statement.
It did cause 17 confusion in that this is a verified dimension, boxed in, 18 and these elevations are not.
19 MR. MITCBELL:
And they're specifically to 20 come.in and verify the locations of this information, not 1
21 use unverified information to go back and check against.
22 NR. YIN:
I think your concern is well i
23 understood.
24 You mentioned earlier that you have some 25 discrepancies identified but not able to put down in
\\
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
135 f,:.
o I
writing.
Can you show us an example of what we are. stivt<
pypw.3,
- - %7
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2 talking about?
f 3
MR. MITCHELL:
Yes.
Could we do that 4
after lunch?
5 MR. YIM:
Yes.
6 MR. MITCHELL:
Can we go off the record?
7 (Lunch recess.)
8 MR. DANIELSON:
Again, we have 9
Messrs. Mitchell, Micholson, Gavula, Yin and Danielson 10 present.
11 MR. MITCHELL:
We just got finished 12 discussing the five notices that we sent to Commonwealth f
13 Edison, and we think those clearly show that there are
+
14 some problems on the drawings, but we said there are more 15 problems that we have found in our letter.
16 We would just like to show you some of those so 17 you,can take a look at them and make your own 18 determination of what we have.
j 19 They're not in any particular order or i
20 particular problems, but they do cover all j
21 classifications, and I think it will show you why we need 22 more information before we can pin some of these problems 1
23 down.
i i
24 MR. DANIELSON:
We want you to show us all i
25 that you feel is applicable to what we're doing.
, (
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON t
,w.-,,,-r-- - -, -,, --.,- - w-_
,---,a,-+--we-w-,,-wm-vv-%,-
- ,erew,==er--+
136 l-
MR. MITCBELLk$ggG::s ~%w:eYeAi? W 1
, T.i,9*fti J
i 2
certainly close enough.
F'
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~
3 The first one is off of the WO-1 drawing.
4 Because we have a tool that we can spot where errors are at, we fee 1 with all the ob u' mentation we could tell you
~
5 4
6 exactly what is wrong with these drawings.
7 First of all, on WO-1, we know if we use 8
location point to location point, we're way off.
It just 9
doesn't work.
You could say that is caused by the angles i
10 or the chain dimensions and their tolerances.
11 We believe that we found one chain dimension i
12 that is incorrect by approximately a foot, and that chain
/
13 dimension is over by Column Line F.
With the support, 14 which we don't have, we think we could pin it down.
15 We think this dimension here is wrong.
It's 16 shown about 18 feet and the as-built dimension shows 17 17 feet.
We definitely think, though, that that chain 18 dimension is incorrect.
If not, then some other place, 19 and with the supports we would be able to pin it down j
20 exactly.
21 So here would be a good case where we really 22 don't have enough information, but we certainly believe 23 that the drawing is incorrect.
24 MR. GAVULA:
The basis for that is using i
25 what information?
(
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON l
137 (b'
'" NR. NICBOLSON:
We're utilising thim,sy;'n, 1
locater point, starting fr%%y;ym;;:~rg:a'n; 'om this point,' running through
' vfN +;,
~
2 3
the verified as-built dimensions given in the boxes.
l s.
s 4
Utilizing the 17 feet throws'you way off when 5
you get to this point,'buIt if'yo'u utilise these 6
unverified original design dimensions, which total 7
18 feet, roughly, it works perfectly and ties into the 8
next system.
9 so we suspect, " Gee, there is a foot there, and 10 if we just altered this 17 foot to 18 feet, we come out 11 just fine.'
12 MR. MITCHELL:
Give us the supports and we 13 would be able to see it, because we know where the
{~
14 structure is, and when they're attaching the supports to 1
15 the structure, they have to be precise.
16 You can't be off a little.
The' support won't 17 attach properly.
We think that would help us pin down 18 where the error is at for sure.
19 MR. GAVULA:
Did you have sufficient 20 information as far as the other system tie-in, whether 21 there was a discrepancy there?
You said it tied into...
t 22 MR. NICBOL80N:
We were satisfied that 23 this WOO 4 line, WO-42, was correct, where the error is, 24 in fact, on this drawing that we're looking at.
l 25 MR. GAVULA:
So with the as-built DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
138
. (I I
dimensions demonstrated now, you cannot tie into the
.._,,n-
.c,.9 ; se,uqy,yg..
- 7. j
- g.p-2 additional one, but if you'use the modified -- what you 3
think'is correct, then it should tie into it?
l l
4 MR. MITCBELL:
That's correct.
5 MR. YIN:
If you use the design dimension, 6
you can make it work?
7 MR. NICROLSON:
Yes.
Within tolerance, 8
give or take an inch, which is close enough for anybody.
9 But you can see what happens when you do have 10 an error on a drawing of this nature.
Let's say you're 1
11 working in the other direction.
If you change any one of I
l 12 these by 1 foot, by the time you get to the end doing a l
l
{}-
13 loop closure, you can really throw this point way, way 14 out.
15 For instance, if you're off 1 degree here, 16 1 degree here, it's insignificant, but by the time you 17 carry that 1 degree over to here through 100 or 200 feet, 18 it becomes quite significant.
19 That's why we allow plus or minus the 20 5 degrees.
If changing any one of these angles by 21, 5 degrees will make it close over here, I'm sure we would 22 go ahead and do it.
23 But in this case we couldn't do it, because we 24 weren't talking angles here.
We're talking a chain 25 dimension, which comes under a different category of
]
(-
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON 1
139 r
1 1 inch per 10.f e e t.*; i f ;-[ j g g O r % h s,.; b,N +..
2;st.
a 4.
2 NR. YIN:
Okay.
Anything else on this 3
WO-17 4
RR. MITCBELL:
No.
There could be more.
~
5 We just don't have enough information to pin this thing 6
down.
This one just stands out and hits us in the head.
7 MR. YIM:
Okay.
We will verify this.
8 MR. MITCBELL:
The next one is the 9
essential service water, SX-36.
It's a similar problem, 10 that we can't make a loop closure that looks good to us.
11 MR. YIN:
Bere you're using the location 12 point?
13 MR. MITCHELL:
Yes.
In this particular 14 case we're using the location point to tie into SX-73.
15 We do.have some of the "M" drawings on Unit II, 16 and these are supposed to be mirror images.
So we have 17 gone back and looked at those drawings on Unit II, but 18 these are the as-built for Unit I.
19 We believe the discrepancy on this particular 20 drawing lies down here, right here.
When we were off, we 21 were almost a foot off on this one, too.
This shows 22 19-7, and it's over 20 feet, and when we corrected it, it 23 seemed to work.
24 MR. DANIELSON:
Was this a resolution that 25 might have been used on Unit II, then, the rc= son for you
^
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DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
_~
140 h
I to suspect this?
_~
.ac y 2
MR. MITCBELL:
Yes.
4 3.
MR. DANIELSON:
Is.that true on the other 4
one, also?
5 MR. MITCBELL:
Not really on that one.
]
6 Now, on this one here it looked like it had been handled 7
that way.
8 But again, without the supports and some more 9
information and not being allowed to use the location 10 points we felt that we couldn't present this to them.
We l
11 didn't have enough information to back it up.
j 12 "How do you prove that that is where the error l C 13 is at?"
Well, I don't have any.
14 MR. NICHOLSON:
We can't just make a 15 blanket statement that this drawing is wrong to 16 Commonwealth Edison.
We have to be more specific when we 17' give them an error, and say, "And'right down here, 18 specifically, the 15 degrees should be 20 degrees," or 19 something of that nature.
20 MR. MITCHELL:
The next covers two 21 drawings, RY-5, Class A, and RC-9, Class A.
i 22 What we have here, on RY-5 we'have a dimension 23 of 28 feet 2-3/8 off the centerline containment building.
24 We come back 4 feet 4 to the edge of the valve.
That 25 gives us approximately 22 feet from the centerline of the i~h DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
141 i
- g. '
.l containment hiilloing. ;
- ,.
- . i. c w
s
,L
-r 2
When we tried to' tie it in with the continuing 3
line, RC-9, we were given a dimension of 1 foot 2 back to 4
the edge of the pipe.
That gave us about 21 feet.
l 5
When we Icoked down at the block, it had 16-7, 6
and we were sitting around 20 feet, 21 feet.
So we were 7
off about 7 feet or so.
~
8 MR. MICBOLSON:
Do you want to go through f
9 that?
10 MR. MITCHELL:
Go ahead.
11 MR. NICHOLSON:
Of course, naturally, the 12 north arrow on these drawings are 90 degrees of being the
~
13 same.
So you have to take that into consideration.
14 But what Schuyler is saying is that this valve 15 from R-ll, which is your centerline of your containment, 16 23 feet 8 inches up to the flange of that valve, we're 17 try.ing to get back to this elbow on the adjoining system, 18 which is this point here.
19 When we do that and we go through the I
20 dimensions given, the verified dimensions, coming back,.
21 you have to consider that this is a 4-inch pipe and long 22 radius elbow; which is 6 inches to the weld point, here.
23 And the fact they gave us a verified 1 foot 24 2 inches to the valve, and~then they have the verified 25 monument point of being 15 11-5/8 north of the
?
U DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON t
1
~
142 N,.
I centerline, it just doesn't compute.
5.<
2
~
NR. YIN:
What is the discrepancy?
3 MR. NICHOLSON:
About 7 feet.
You can r,ee 4
that 23-8 less 1 foot 2 would be 22-6.
So this 5
dimension, 15 11-5/8 inches, should read 22 feet 6 inches 6
north of the centerline.
So that is a 7-feet-and-some-7 inch discrepancy.
8 MR. MITCHELL:
The next is on RY-3.
9 Do you have a question on that?
Go ahead.
10 MR. DANIELSON:
No.
I'm just trying to 11 catch up here.
12 MR. MITCHELL:
No rush.
13 MR. DANIELSON:
Okay.
14 MR. MITCHELL:
The next one is RY-3.
On 15 RY-3 here, what we found here was, we found a dimension 16 that we felt was incorrect, and there was no way of 17 checking it out, because they did not put the angles on 18 the drawing to use.
19 In other words, you can't feed the information 20 in without the angles, and there are no angles shown on 21 the' drawing.
22 We think there is an error of about 6 inches on 23 a 2-foot-6 leg, but without those angles we are unable to 24 vterify it.
25 MR. NICHOLSON:
I worked this drawing from DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
143 C
1 this COI -- of Drawing RY-2, which was correct...so,..
2 picking it up at this connection point in th'e "Y,"
I 3
worked it around here and found that these two verified 4
lengths would not be long enough together, added 5
together, to join this monument and this elbow if you did 6
it in a straight line, let alone put angles in here.
7 And, yet, they indicate that there are some 8
angles here, but they don't give me the elbow or the 9
angles.
They use a 45-degree elbow cut to suit.
So 1 10 didn't really know.
It obviously has to be less than 11 45 degrees in here if you're going to take a 45-degree 12 angle and cut it.
r -
13 But I could-verify using all their dimensions, 14 verified dimensions, that these two dimensions of 2 foot 15 0-1/2, and 20-1/4 inches,.added together, were 16 insufficient to join the monument point with this 17 45-degree elbow.
18 I suspect that this 2 foot 6 inches should, in 19 fact, be verified as somewhat close to 2 foot 6-7/16 20 inches, where they said it's only 2 foot 0-1/2.
21 So if I went out to the field, I would 22 personally feel that I would find this 2 foot 23 0-1/2 inches to be incorrect.
Just a guess.
24 MR. MITCHELL:
The next drawing is RC-7, 25 reactor coolant, Class A.
(.
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
l 144 Nu 1
On Chis particular one we know where the tadk;'3 -
. m.; <3 w 2
is at -- I'm sorry -- where the line is'at, but've'ra
~
3 given a dimension...
4 MR. YIN:
Bow do.you know where the line 5
is?
6 MR. MITCBELL:
Because we have the 7
arrangement drawing.
We're satisfied that this is where 8
it belongs.
9 MR. YIN:
Okay.
10 MR. NICBOLSON:
Again, we verified that 11 based on the architectural drawings, the manufacturer's 12 drawing of that tank and the fact that that fittings are
(~
13 where the manufacturer said they were on the tank.
14 MR. MITCHELL:
When we looked at the as-15 built dimension of this particular point, this line 16 should have been way over here on the other side.
17 MR. NICHOLSON:
As you can see, it says 18 29 feet 5 inches to center of containment.
This 19 dimension here going further away from containment is 20
.28 feet 10-7/8, which is less, based on standard l
21 isometric drawing procedures.
You can see that.
22 MR. YIN:
Yes.
I 23 MR. NICBOLSON:
Which tends to mislead a l
24 person, except that we know that the tank is properly i
25 dimensioned here, because we verified the tank location L.-
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
145 h
I with the founaation, the architectural drawings, the.eds 7
2 manufacturer's prints.
3 These are some of the ambiguities which are 4'
referred to in the specifications.
5 MR. MITCBELL:
The next is CC-44.
This 6
gets to one of those problems we already talked about.
7 We show this location point here.
Let me get 8
the right one.
This location point right here.
9 If we use this location point based on the 10 sleeve, it's 3 feet out.
In other words, there is a 11 discrepancy of 3 feet between what is shown here and what 12 the actual chain dimensions are, and, therefore, we think 13 there is a discrepancy on that one of some 3 feet.
14 MR. YIN:
These are really just the 15 obvious mistakes.
It actually shows on the drawing two 16 different dimensions;-is that. correct?
Is that what you 17 pointed to?
18 MR. MITCHELL:
No.
He's got a dimension 19 of 76 feet here.
20 MR. YIN:
Right.
21 MR. MITCHELL:
It can't be 76 feet.
It 22 has got to be 73 feet.
23 MR. YIN:
How do you know?
24 MR. MITCHELL:
Well, because we know where 25 the sleeve is here, and if we move it to the 76, it shows DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
I 146 h
I all the dimensions...
~ ' ":-
' S i-z.
2 MR. NICBOLSON:
We know the inside of the 3
containment wall is a 70-feet radius, okay?
4 MR. YIN:
Okay.
5 MR. NICBOLSON:
And we know the thickness 6
of the wall.
We also know the length of the sleeve.
7 MR. YIN:
Okay.
~
8 MR. NICBOLSON:
We have on as-built 9
dimension here of 2 feet off of the end of the sleeve.
10 MR. YIN:
So it just doesn't add up?
11 MR. NICHOLSON:
If you do the 12 triangulation or the trig involving this 23 feet 1 east
(
13 of centerline and 76 3-1/8 north of centerline, you come 14 out with a different radius.
15 MR. GAVULA:
So the locater point is...
16 MR. NICHOLSON:
Incorrect.
17 MR. MITCHELL:
What we are pointing out, I 18 believe, are the easier errors we can show you without 19 doing a lot of work and a lot of calculations, which 20 would have to be done.
21 MR. NICHOLSON:
Some of these errors, to 22 show another person or an outside person, you have to get 23 your calculator and go through numerous trig problems, 24 which is quite lengthy, but can be done if we get to a 25 point of having to make every error that we know of G
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
147 1
obvious to an'ou'tside person.
7.
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MR. DANIELSON:
Let me ask again, are a 3
great deal, if not all of these that you're identifying 4
here on Unit I, aisilar to or the same items that you 5
identified on Unit II?
6 MR. MITCHELL:
No..They are different i
7 than Unit II.
They're similar in the fact that they're 8
the same type of errors,. chain dimension errors, location 9
dimension errors, that-type of thing, but they are 10 different than the~ones we found on Unit II.
11 In other words, they're not the same spot or 12 the same drawing.
13 MR. DANIELSON:
All right.
14 MR. NICHOLSON:
They're not mirror-image 15 errors.
16 MR. DANIELSON:
That's what I was going to I
17 ask, yes.
18 MR. MITCHELL:
The next one consists of
)
l 19 two, SI-12 and SI-15.
Again, it's a quite 20 straightforward error, we think.
21 What we have is we have.a dimension from this 22 sleeve.
This is an as-built dimension on Revision ll-G 23 of SI-12.
We're given an overall dimension of 13 feet 24 here.
25 MR. YIN:
Before we go too far, are you k
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
148 J
1 going to let ds keep all the drawings?'
n WF /"F99fg Fl
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f w,w i
Ny '
2 MR. MITCBELL:
No.
These are ours.
We 3
want to keep them.
4 MR. YIN:
Is it possible t;o make a zerox 5
copy of the localized area and mark it in yellow so we 6
will be able to...
7 MR. MITCHELL:
Well, we looked at that.
8 We can try.
They don't really come out that good in a 9
xerox, bec._se it's blue, but we can go ahead and try.
10 MR. YIN:
Yes.
Why don't we do that.
11 MR. NICBOLSON:
Can't you just ask 12 Commonwealth for a revision on the...
13 MR. YIN:
We certainly will, but we want 14 to have a specific area to recreate.
I don't want to i
15 mislead anybody.
16 MR. MITCHELL:
I have no problem with 17 that.
I think I tried to do that when I sent the five 18 notices to you.
I tried to zerox.
19 MR. YIN:
The blue is not the best thing 20 to put on the zerox machine.
1 21 MR. MITCHELL:
Again, we're looking at a l
22 13-foot dimension here.
When we go and utilize the l
23 dimensions that are given on the other drawing, SI-15, 24 the chain dimensions to the valve, and continue on, we 25 find a discrepancy of over a foot just in a small -- just
(
I DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
149 k6' I
between the ttio drawings.
1
~
2 The next one is'rW-13.
As I start 'through this 3
sleeve, I have an elevation of 380 feet.
I continue 4
around here and try to bring it in, tie it into this-
~~
I'm 10 feet off.'
~
j 6
MR. GAVULA:
In what direction?
7 MR. MITCHELL:
In the elevation.
i 8
MR. YIN:
Is that approximately 10 feet 9
off, or is it 10 feet plus?
10 MR. MITCBELL:
10 feet.
11 MR. YIN:
Exactly 10 feet?
12 MR. MITCHELL:
Well, not exactly.
It's 10
('.
13 plus a little.-
I'm sorry.
I would have to go back and t
14 redo the cales.
15 MR. NICBOLSDN:
We can do it, if you would 16 like.
17 MR. MITCHELL:
Would you like me to do it?
18 Let's go ahead and do it.
19 What do you have?
20 MR. NICHOLSON:
389.83.
21 MR..MITCHELL:
This shows 380, versus 389.
22 MR. GAVULA:
What do you get when you take 23 your elevation?
j 24 MR. NICBOLSON:
406.
25 I've got that.
Now what do you want to do?
l.
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
150 1
MR. MITCHELL:
SubtractLthis'aumbErliight:
4
-?N QNM3@Wb:.?/CC9;/[.9 2
here.
+... g s..
r 3
MR. MICBOLSOM:
25.84.
l.;
4 MR. MITCHELL:
Feet difference?
5 MR. NICBOLSON:
Yes.
There is almost 6
14 feet of it right there, so take that off.
7 MR. YIM:
How many?
I wasn't paying 8
MR. MITCHELL:
We were just subtracting 9
this number from this number, and the difference was 10 24 feet.
11 MR. YIN:
This is the horizontal 12 dimensions.
13 MR. GAVULA:
So it's basically a 14 discrepancy between the 380 elevation indicated versus 15 the 406 elevation indicated?
16 MR. MITCHELL:
Yes.
It's off 9 feet.
17 MR. GAVULA:
Were you able to go back and 18 verify this is a nozzle location on the steam generator?
19 Were you able to go back and verify whether the...
20 MR. MITCHELL:
We're satisfied that that 21 dimension is good.
l 22 MR. GAVULA:
How about this location, the 23 elevation of the...
24 MR. MITCHELL:
The sleeve is 10 feet off.
25 MR. GAVULA:
The sleeve location is DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON i
151 g-QC
-~.
10 feet off rhletive to the structural"drawddfs?MfjMjit@:-
1
~
. w : w x,.-a3 ~ y:6 g yp.:y.._ c m $. ;, -
2 MR. MITCBELL:
Relative to this diaension 3
here.
4 MR. GAVDLA:
So that the sleeve is in the 5
proper location relative to that?
6 MR. MITCBELL:
The sleeve is in the right 7
location.
I'm not sure what...
8 MR. GAVULA:
So if this elevation was 9
changed 10 MR. MITCHELL:
It could work.
11 MR. GAVULA:
Then that would match up with 12 that?
\\
~
13 MR. MITCHELL:
Well, it would be changed 14 to'whatever it is, yes.
15 The next one is CC-37.
We looked at this one 16 prior in one of our five notices.
The thing that caught 17 our attention is-that we have an elevation of -- we know 18 that this pipe is at 4-17 and we're looking at a 19 dimension dropping below the pipe of 4-19.
20 We don't have a CC-39.
I'm sure that there is 21 some -- there is a discrepancy here, but they just don't 22
.show the tie-in properly, but we are given a location 23 point and it's drawn downward from it.
So there is just 24 a discrepancy there.
25 I think, gentlemen, this shows you that we DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
152 1
could go on and on with this thing,'but with'out thoac-
~
fjr n 49% (~-Mg 2
proper information, we can't really document it exactly.
3-There are a lot of errors on these drawings, a 4
lot of errors.
There are chain dimension errors, 5
location errors.
They're caused by a checker making a 6
mistake or a rereviewer not catching something.
There 7
are just many reasons for these errors.
8 We just don't think that drawings that reflect 9
nuclear safety drawings should have these type of. errors 10 on them, especially the numbers that we keep coming up 11 with.
12 I believe we have shown you a trend from Byron
~
13 Unit II back into Byron Unit I.
I think that when you 14 review the safety part of it that you will feel that some 15 of this information could affect the analysis.
I believe 16 that.
17 That's why we've gone through the effort and 18' time and the trouble, we think, to bring these to your 19 attention.
20 We have these type of errors in other nuclear 21 power plants.
We just finished a study on the Seabrook 22 nuclear power plant.
Again, this power plant can be 23 considered to be in the preliminary stage, because it's 24 not in operation.
We believe these drawings -- and if 25 you would like to look at them, we would be happy to show i.
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON l
1
._-.-_-.-.....-..___..___,,....-...m._
. -, _ _ _ _, _ _. _.. ~. _., _ _ -.. _,..... -, _.... _, _. -. _. -.... - - - _ - _.
153
.(
1 them to you. "
g g.
~
2 MR. NICBOLSON:
They do have fuel on-site 3
pending approval to load.
4
_ MR. DANIELSON:
Let me ask a question.
5 Are you finished with Byron Unit I?
6 MR. MITCBELL:
No.
7 MR. DANIELSON:
I mean finished as far as 8
the information you're giving us.
9 MR. MITCBELL:
Yes.
At this tihe I can't 10 see any additional reason to just give you more data of 11 the same stuff.
Technically, I think we have done our 12 end of it.
13 We have shown you the information.
We think 14 there is plenty of information to make a decision on.
We 15 think it certainly is going to be different than -- we 16 can't buy Commonwealth's explanation for the five we've 17 bee.n'given.
We think those answers are unsatisfactory.
18 My interpretation of Commonwealth's letter to 19 me from. Mr. Brent Shelton is that you expect errors like 20 this, the NRC expects it, they expect it.
They don't 21 mind looking at them, and it doesn't affect anything.
22 I just totally disagree with that based on the 23 specifications.
24 MR. NICBOLSON:
And of these five notices, 25 if we can answer the existence of these five errors that k.
l DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
154 h
r I
we're dwelling on, we still'have the'aumerous problems as
, A i.x 4.._ -:+ c,...
- yzjay r8:, >
2 we encountered on Byron I, which we related a few just 3-now to you.
4 Given.a little more documentation, in the 5
17 years of experience we have in doing this very thing, 6
we could identify exactly and pinpoint and prove that the 7
errors do indeed exist, and we're relatively confident 8
that when we say they exist in this dimension or that 9
dimension, that is where you will find the error.
10 Again, how it developed, we have no idea.
11 Maybe it was a mismeasurement in the field.
Maybe the 12 recorder writing down the dimension wrote the wrong
/]
13 thing.
Maybe when it got transcribed from one document 14 to another document, there was an error.
15 But what we're trying to show is the trend, 16 that the errors exist, and that the best engineering 17 minds in the country, the best checkers in the country,
+
18 probably the best NRC region in the country, failed to 19 find these errors that lay people back here on the West 20 Coast can find quite. easily.
21 send drawings and I will personally look at the j
22 drawings and show you errors.
I don't care what plants 23 you want~to talk about in this country, be it Sedra, be 24 it your Byrons, your Braidwoods, your TVAs, because we 25 have found the errors in all the plants and they are DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
155
($h I
just like we'ke shown you her~e'.f ? -
2 MR. DANIELSON:
You found the errors?
You 3
mentioned finding the errors.
4 What do you perceive needs to be done?
5 MR. MITCBELL:
Well, we looked at this.
6 Our initial presentation to the NRC back in 1981 was that 7
there should be a tool which everybody can rely on to 8
quickly go through these drawings and see that they 9
actually -- everything ties together.
10 It's a fairly easy tool to do.
We have one, 11 and you can develop your own or use somebody else's.
I T
12 don t care.
13 But our tool quickly goes through and says, 14
" Hey, all these numbers work" or "they don't work."
15 We're able to pinpoint where the errors are at so people 16 can look at them and ascertain if that's right or wrong.
17 Commonwealth will admit that we've never, ever l
18 disputed that something was wrong on the drawing.
It's 19 the impact or the importance of it, not that we were l
l 20 wrong in our analysis, but just the importance of it.
l 21 So our recommendation is that the NRC should 22 have in its back pocket a tool in which you can take a 23 relatively small portion of the plant, but critical, and 24 check some of the drawings out, including all the 25 supports and the piping systems.
I think that would give f
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON 1
---,---_._,.-,n-
,-,n-,,,..,,,,_.__,--,c,--.--,,,..,_-.,
156 LL 1
you a better' handle on the procedure'you have today.
egay
..g a w. _. -
2 After you do your normal walk-down and you 3
-check the small area, as you say, and you find violations 4
on those, I take it, no one expects you to check them 5
again.
No one expects you to find anything.
6 I think that before the plant turns 7
operational, you should take one more small check, and j
8 this would be a tool to use, or require the utilities to 9
somehow show you that these drawings are in the proper 10 conditions, as-built conditions, the seismic analysis 11 condition.
I don't know what type of information you 12 need for that.
~
13 MR. YIN:
Okay.
We'll follow up on it.
14 As I said, we need to have some xerox copies to highlight i
l 15 the discrepancies before we leave you.
16 MR. MITCHELL:
We will drop some in the 17 mail to you.
18 MR. YIN:
Can we do it before we depart 19 from here?
20 MR. MITCBELL:
We can certainly try.
No 21 problem at all.
22 MR. NICBOLSON:
Is there anything that 23 we've shown you that surprises you, or do you expect 24 these types of errors that you have seen today?
25 MR. GAVULA:
Well, at this point we need r
w/
DEAN MOBURG & ASSOCIATES - SEASTLE, WASHINGTON
_. - ___,_ -.,. -. -... -. - - - _.. - -. _ - ~..... - - _... _
157 l
c w' 1
to get b3ck into the > analytical aspect.
Like you said, 2
you can go in on any plant and find the discrepancies, 3
and the bottom line is, how significant are these 4
discrepancies?
That is what needs to be addressed at 5
this point.
6 MR. NICb9LSON:
You're addressing it from 7
the analytical viewpoint, correct?
8 MR. DANIELSON:
As far as. interferences 9
are concerned, and so forth, if it's an as-built plant',
i 10 like you talk about Byron Unit I, I mean, you know...
11 MR. NICHOLSON:
There is no interference 12 out in the field.
13 MR. DANIELSON:
So, really, isn't the end 14 problem or the end question, does the analysis -- is it 15 compatible with the as-installed condition in the field?
16 MR. NICHOLSON:
That's one of the 17 questions.
But the other question, again, is 79-14, do 18 we have drawings which represent the plant as 19 constructed?
There are two facets.
They interrelate, 20 but there are two separate questions and two separate 21 requirements.-
22 MR. YIN:
To answer your question, it is 23 not a surprise, because recent follow-up on some C.
24 operation plants, for instance, like Dresdgn, we do l
25 identify that the walk-down inspection for the 79-14 l
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
1 158 ks I
bulletin was not that adequate, and additional work was 2
done.
3 MR. DANIELSON:
At least in some areas.
4 MR. YIN:
Right.
5 So what you present to us is truly not a 6
surprise, but the detail surprised me somewhat, and we 7
would follow up on it.
8 MR. MITCHELL:
Well, I scratch my head at 9
that as a layman.
You said you went through Dreadin and 10 you found that the walk-down had some problems with it.
11 MR. YIN:
Right.
12 MR. MITCHELL:
That problem doesn't 13 surprise me, because we claim that there isn't a walk-14 down done under 79-14 that works.
It's just a claim.
15 But what bothers me is that someone didn't say, i
16 "If the walk-down on the Dreadin didn't work, why didn't 17 we check La Salle and Byron to see what happened there?"
18 MR. YIN:
Because the 79-14, although --
19 let me put it this way.
20 Although the original design was done by 21 Sargent-Lundy, at the time frame when we issued 79-14, 22 the'effect to the industry -- quite a great deal of 23 impact.
So.in most cases, the original AEs, at least in 24 Region III, were unable to follow up on it.
25 As a result, a licensee had to farm out the DEAN MOBURG & ASSOCIt.TES - SEATTLE, WASHINGTON l
(5 159 work to different Ass, consultants, such as Impelh 'NaNI ~
~
1
~
2
{ech, and various organizations.
Not only that, the 3
walk-down and the evaluation quite frequently are not 4
done by the same organisation.
5 So there was no reason for us to believe it is 6
a generic problem, because it is very hard to say if
~
7 Organization A had missed something, we will 8
automatically think Organization B will also have the 9
same problem.
That is basically"why we have come up to os:M.n the p1:tive of not 10 really checking everybody.
11 The second reason that we didn't really go f'-
12 after the responsible organiation was the fact that 13 during the AEs' evaluation they were like you, would 14 identify a lot of discrepancies, and they actually went 15 to the. locations to verify themselves.
16 Much of the evaluation was done right at the 17 site.
Maybe documentation was not that grood, but at 18 least the evaluation was pretty comprehensive.
So that 19 is another reason we didn't feel it was something of 20 emergency or urgency in nature.
21 As you know, in the
[L restraining areasf, 22 jet impingement criteria has changed.
The arbitrary 23 intermediate breaker has changed.
There is talk about
)%
24 seismicggg; ;; irr: overdesigned,;;he damping value we use
(-
25 in seismic analysis 'as way too conservative, and DEAN NOBURG & ASSOCIATES - SEATTLE, WASHINGTON 1
i er i
l l
160 kh' 1
there is talk about relax in that area.
2
'There is a great deal of discussion between the C.Je 3
onnission and the oo-committees, various committees, to j
4 talk about that issue.
Of course, we have not come-up i
5 with any conclusion as to which way to go.
6 For instance, we have to remove some 7
conservatism in the piping system.
For instance, you 8
can -- as a result, you may be able to save a large 9
number of snubbers or restraints, but your price to pay 10 will be a large amount of defections in the design 11 seismic conditions.
12 In the intermediary, you can think that this r~
13 pipe may hit the structure, they may bump into each 14 other, and the very thing you people working on, the 15 interference problem, is going to be a major issue.
16 So you gain some.
You lose some.
Where are we 17 going to draw the line?
We haven't come to that point 18 yet.
19 MR. NICBOLSON:
What about when an 20 incident is reported, and it happens to be a particularly-21
. bad incident?
Isn't the first thing that any engineer 22 using prudence would do is to grab the drawing and expect 23 that drawing to represent the condition out in the field 24 and he looks at the drawing and he is confident that the 25 drawing is correct and he starts making decisions based DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
161 6
~
1 on that information on the drawing?
j o,
e v
_s
'2 Because a lot ofthese areas are hot currently 3
if the plant is in operation.
We don't have time to suit 4
up and send a man out there, which it may be too-hot to 5
do that.
6 MR. YIN:
Your concern is a. relevant one, i
7 but, on the other hand, prior to 79-14, the bulletin, 8
came out on the street, the documentation was even less 9
of a condition as what we see today.
10 MR. NICBOLSON:
I'm not disputing that 11 we're getting better.
I believe we are getting better.
~
12 MR. YIN:
We are getting a lot better, and 13 many nuclear power plants are in safe operation and never 14 reported any problems as a result of poor drafting and 15 poor documentation control.
16 So we have to examine ourself.
Are we talking 17 about a document control problem, or are we talking about 18 a safety problem?
i 19 I can certainly confer with you just from the 20 preliminary look that there is a look of some kind of 21 discrepancy between design, as I mentioned, and the 22 boxing as-built walk-down verification, but as far as a "m**dv&c i
23 meekomp safety concern, I don't see it yet.
24 MR. NICHOLSON:
And there is no way you could until you examine what happened on the seismic.
We 25
(,
i DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
162
,c,n~g.g 1
understand that.
- s.
w 2
MR'. YIN:
So what we need to do nowis to i
3 bring back all the information you presented today and 4
put two and two together and see where it leads us to, i
5 and we certainly owe you an answer whichever way it i l 6
lands.
7 MR. DANIELSON:
Isa talks about evaluating 8
what you have don'e.
That's fine.
We're going to do it.
9 But I would be interested in getting one more 10 thing here, and that is, you mentioned that there were 11 other plants that you had concerns with.
12 MR. MITCHELL:
Yes.
c' 13 MR. DANIELSON:
These are the plants.
Are 14 they in Region III, or do you know?
15 MR. MITCBELL:
Yes.
Clinton Power Plant.
16 MR. DANIELSON:
Do you have specific 17 concerns that you can give us relative to...
18 MR. MITCHELL:
I don't have the.as-built 19 drawings to give you, and that's why I can't give it to 20 you.
21 MR. DANIELSON:
What is your basis for 22 saying that Clinton...
23 MR. MITCBELL:
Because we did an 24 interference analysis on Clinton and we looked at some of 25 the structural plans and some of the large bore pipings
(
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
163 r'G.
I that were insEalled.
~
~
2 Although they didn't say "as-built," the 3
drawings. supposedly were up to date, and we felt that 4
there were mistakes on those drawings.
That's in 5
Region III.
6 We have the same concerns on Tennessee valley 7
Authority.
~
8 MR. DANIELSON:
You're taking the words 9
out of my mouth.
I am very deliberately leading up to 10 that.
11 MR. MITCHELL:
Go ahead.
12 MR. DANIELSON:
What I would like you to
['
13 do for the record is tell us the plants that you have l
14 concern with, summarize your concern, and then we can i
15 make this information available to the other regions so 16 they can do the necessary reviews.
17 MR. MITCHELL:
Okay.
Again, our problem 18 is making unsubstantiated claims, if you will, without 19 the documentation to back it, all right?
20 MR. DANIELSON:
I understand.
21 MR. MITCHELL:
I do have Seabrook Nuclear 22 Power Plant, maybe a quick little story, if I might, 23 because I want to answer your question.
I think it's 24 important.
We're talking about the industry.
25 We had done an interference analysis on t
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
~164 b
I seabrook Nuclear Power Plant and we found a tremendous 2
amount of interferences, extremely bad interferences 3
which would cost a tremendous amount of money to 4
straighten up.
5 We made out warnings known to the top i
6 management of the utility.
We also pointed out the 7
problem that they were going to have with the as-built 8
drawings.
9 They told us, "Thank you very much, but 10 goodbye.
We don't need your service.
We are satisfied 11 with the procedures we have in-house."
12 We then learned about a presentation going to 13 be made by UENC at a Philadelphia ASME meeting in 14 December of 1984.
At that meeting they were going to 15 discuss the as-built problems that UENC had found on 16 the drawings.
17 Mr. Nicholson and I attended that meeting in 18 Philadelphia.
In that meeting they pointed out -- and we 19 have the documents to show -- that they found a lot of 20 as-built drawing errors which they considered paper 21 problems.
22 MR. DANIELSON:
Do you know if the NRC was 23 present during that meeting?
24 MR. MITCBELL:
No, they were not present.
25 In our discussions with the gentlemen who made L
I DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
165 h
1 the presentation, we were satisfied in our own minds that 2
there were more errors on the drawings.
It just 3
simply -- we were satisfied from the discussions.
4 We contacted Mr. Ed Brown, who i_s the president 5
of Seabrook Corporation for constructing the plant, and I 6
pointed out to Ed that it was my belief that his as-built 7
drawings had errors similar to-the ones we've seen today.
1 8
Mr. Brown invited us up to his office to sit 9
with DENC and his as-built people and look at their 10 drawings.
Within five minutes Mr. Nicholson pointed out 11 what he considered errors on their drawings.
l 12 Because of.that, we offered at no expense to l (
13 the utility to do exactly what we've shown you here, a 14 demonstration.
15 It required the president of Public Service of 16 New Hampshire to get us the drawings.
There was a lot of 17 reluctance, but there was our claim verbally that the 18 drawings did not reflect the plant as constructed.
19 MR. NICBOLSON:
I sat in the meeting with 20 Mr. Brown and looked at the drawings and in a couple 21 minutes I said, "Well, there is an error right there and 22 there is an error right there."
Be's got his two 23 engineers in the room and they have no explanation.
24 I said, "What about the loop closure?
How do 25 you close the loop between the two points?"
C DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
166 1
Their statement "as, "We don't havelto_closei;;.
'.pthw :.s.si.#ig That's unimportant for seismic," which'u a c??.
e u-2 the loop.
in a ^
3 sense is true.
You can take a segment of pipe,and I
4 suspend it in air and run a seismic analysis and show a l
5 hanger here and a hanger here, and you know that pipe is l
6 going to be supported.
l 7
MR. MITCBELL:
But then when we looked at 8
their seismic analysis program, we found it was based on 1
9 those location points.
I f
10 So we received a package from Seabrook and we 11 took 300 lineal feet and we fcund severcl major, in our 12 opinion, discrepancies.
}
13 They immediately sent three people out here.
I 14 One was an ex-NRC employee.
At that meeting we started 15 to show them what we had, the errors on their as-built 16 valk-downs.
17 First, they said that they were within their J
18 tolerances, and then when we brought out their 19 specifications and showed them their specifications were 20 outside of tolerances, they then said, "Well, you're 21 right.
We don't understand what the problems are here.
22 We will go back in the field and walk them down, like you 23 suggest, or look at them."
24 The next thing we received wee a letter from 25 them saying, "We don't want you to nahe a presentation to s.
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
167 h
1 our -
" or a verbal telephone call sayinh, 'We don'$ NS
-...,.w,. vy :
.yyg.p;;
2 want you to make a presentation out here.
You will be'
[~ _,,
3 getting a letter."
4 And the letter said, "Thank you for the 5
demonstration.
We don't need any more examples.
Send 6
the drawings back."
If you would like to look at the 7
drawings here, I can show you the discrepancy that we're 8
talking about.
9 MR. DANIELSON:
Again, do.you have a 10 package put together for Seab' rook similar to what you 11 offered us for Byron I?
~
12 MR. MITCHELL:
Yes and no.
I believe b
13 before we would want to disseminate that particular 14 package, we would want to sit down and discuss with 15 whoever is looking at it what we have and how we obtained 16 it.
I think it requires that type of thing.
17 Now, whether we go back to Region I and do that 18 or they send somebody out, it makes no difference to me.
19 MR. DANIELSON:
Would you be willing to 20 put this package together and discuss it with Region I?
21 MR. MITCHELL:
Certainly.
No qualms at 22 all.
23 But to continue on with your question, there 24 are other plants that we sincerely believe have a 25 problem, but we don't have the documentation, per se, DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
168 kh
. " 1~ ' '~.~ ~.
I that says "as-built" on it.
(
2 There is no question in my mind and I don't 3
think in Mr. Nicholson's that this is...
4 MR. NICHOLSON:
I know we can tear TVA 5
apart.
6 MR. DANIELSON:
Which units?
7 MR. MITCHELL:
Sequoia,-Watts Bar.
8 MR. NICHOLSON:
What is the other one?
9 MR. MITCHELL:
Well, Belefonte, but we've 10 never looked at Belefonte.
11 MR. NICHOLSON:
Sequoia for sure.
I 12 looked at that one in depth.
That was the worst one I've 13 ever run across.
14 MR. DANIELSON:
But you have no specifics?
15 MR. MITCHELL:
No.
Just from our -- we 16 worked on that in 1981, and because of that, we went to 17 Victor Stello, but he said that we had to have the final 18 as-built documents that you're looking at here.
i 19 without those documents the NRC was not 20 interested.
So we said, "Okay.
We can't do it, then."
21 That is why you were not contacted earlier on seabrook j
22 and that is why you were not contacted on Byron Unit II.
23 MR. NICHOLSON:
Or-WPPSS Unit I.
24 MR. MITCHELL:
Or II.
1 e
- t..
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
169
(-
1 MR. MITCBELL:
I think it's.sanford y 2
Unit II.
~
N x
3 MR. MICBOLSON:
We're-hoping we can set a 4
precedent in your region.
~ '
5 MR. MITCBELL's I think what has to be done 6
here on these drawings is', the entire quadrant should be 7
looked at.
That includes everything in that quadrant, 8
okay?
That's all the supports, everything, all the small 9
bore piping.
10 I mean, I can show you the same problems on the 11 small bore piping that are nuclear safety related, that 12 are walk-down, that have gone supposedly through the f
/~'
13 seismic analysis.
14 So I certainly think that we have only been 15 able to scratch the tip of the iceberg with the 16 information we have here for you, and I think that was a 17 del.iberate effort by Commonwealth Edison not to let us 18-have the documents.
19 MR. NICHOLSON:
If you can get the 20 documents which we would be required to have for 21 Tennessee Valley Authority, Seabrook, and more on these, 22 we'll show you more problems.
Some more documents, some 23 more problems.
24 There is a limit to my generosity, though, in 25 being willing to help the NRC do its own job.
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
170 kb
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~
1 MR. YIN:
We cann'bt speak to the NRC's',
p-<
-...,.. g a..,,
.4,,,
2 policy.
We cannot speak for other regions.
3 So the primary reason for us to come here is to 4
resolve the issues that you brought up against Byron 5
Unit I.
6 MR. NICBOLSON:
And we're willing to help 7
you do that if need be, if it's required.
8 MR. DANIELSON:
For Seabrook, would you 9
have some specifics that you could give us?
10 MR. MITCHELL:
Certainly.
11 MR. DANIELSON:
Now?
12 MR. MITCBELL:
Yes.
4 13 MR. DANIELSON:
Recognizing that this 14
. isn't a total listing of what you're speaking of, could 15 you give us some specifics now?
16 MR. MITCBELL:
Yes.
We would have to go 17 outdoors and look at the drawings.
18 Do you want it officially on the record?
19 MR. DANIELSON:
Yes.
20 MR. MITCHELL:
Well, why don't we take a 21 break here.
Give me a few minutes to pull some things 22 together and let's take a look at them.
23 MR. DANIELSON:
Let's go off the record.
24 (Off the record.)
25 MR. DANIELSON:
Again, we have
(.
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1 Messrs. Mitchell, Michols6n', Gavula, Yin ~and Daniel n
2 present.
- .
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With regards to seabrook _ihe information that 1
4~
you are going to give us now, is this based, as far as 5
you know, on preliminary as-built drawings, or is it 6
based on final as-built drawings?
7 MR. MITC8 ELL:
The definition by Public 8
Service of New Hampshire says that this information is 9
preliminary, that these are not the final as-built i
10 drawings.
11 MR. NICHOLSON: ~We understood the drawings 12 which they sent us to be finalized as-built drawings when 13 we received them in that the sole purpose of the 14 demonstration was to show Mr.. Brown that he did indeed 15 have errors in his finalized as-built drawings.
16 When we found those errors, we were given the 17 same reason that Commonwealth Edison gave us for those 18 errors being in existence, that these are preliminary as-19 built drawings.
20 It's a play on words until the plant actually 21 is approved by the NRC and is operation at that point in 22 time, it's my understanding, and we do not any longer 23 have preliminary drawings.
They can't be.
24 MR. DANIELSON:
What time frame did this 25 take place in?
q)
DEAN MODURG & ASSOCIATES - SEATTLE, WASHINGTON
172 1
- NR. NITCBELL - We're' talking about -- we 2&i;4)W@$-4W -
~l w : % b :.
2 were notified that~there would be'a December 10, 1985 3
meeting in Philadelphia by the Philadelphia ASME section, 4
where at that meeting United Engi sering Constructors i
5 would present a paper dealing with nuclear piping i
6 as-designed /as-built data reconciliation at the Seabrook 7
nuclear power station.
~
8 At that meeting Mr. Rigamonti presented a 9-paper, and he went into the reconciliation problems and 10 the as-built problems on the Seabrook power plant and he 11 pointed out the problems they had with the 12 as-constructed /as-built data.
13 And he said when looking at the as-built 14 drawings, that the calculated support locations from the i
15 piping and support data, that this data showed 16 discrepancies with the field data.
17 They considered it a paper problem or a 18 tolerance accumulative effect, but whatever the problem 19 was, they had to go back and redo their as-built check.
20 So we had discussions with him after the 21 meeting about these drawings, and it was pointed out by 22 Mr. Rigamonti that now the Seabrook drawings were within 23 their specifications, which I have a copy of, which are j
24 quite similar to those by Seabrook, that they had a plus 25 or minus 1-inch discrepancy on their -- or tolerance on k
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON i
-m...__..._. _., _ - _ _. _,
173 (b
1 their chain dimensions.
..n gg 2
NR. DANIELSON:
You said similar to 3
Seabrook..You meant similar to Byron 17 4
MR. MITCHELL:,Yes.
I'm sorry.
To 5
Byron I.
6 We had a meeting set up with~Mr. Ed Brown, who 7
was, I believe, the president of the Seabrook 8
Corporation.
It's a. separate corporation from the 9
utilities.
It's like...
10 MR. NICHOLSON:
Be's president of Yankee 11 Atomic.
12 MR. MITCHELL:
It's sort of a construction 13 arm of all the utilities.
14 We had a meeting set up with him
-- I believe 15 it was December the lith -- where at that meeting we were 16 going to discuss his as-built problems, where he had his 17 people present.
18 At that meeting we told him he had problems 19 with the drawings fast looking at them and that we felt 20 that it would be fairly simple for us to take an area of i
21 bis power plant and site containment and to demonstrate i
22 these errors.
We recommended an area that we had worked i
23 before, because we knew what the drawing numbers were.
24 Mr. Brown was very reluctant to do it.
So we 25 called the president of the corporation and said, " Hey,
(
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON 4
- ~. _
174 v
I we believe you have as-built drawing problems and for no 2
cost we will show you what those problems are."
]
3 so they agreed finally and sent us the j
drawings.
That's what we're going to take a look at this 4
5 afternoon, some of them.
I am not prepared to show you
~
6 all of them, but I am prepared to show you some of them.
7 MR. NICBOLSON:
Mr. Brown's original 8
statement was, "I do not need another audit of my 9
drawings," even though there was no charge.
We were 10 there to prove a point to him.
11 l
In prior meetings with Mr. Brown he had said, 12 "I like what I see.
I like your program.
If I had any
'(
13 money, I would do that."
In subsequent meetings he said,
'~
14 "When I get the money, I will do this."
4 15 When he got the money, it dawned on him that, 16 gee whir, what if he did have problems with his as-built 17 drawings, which he considered at that point in time to be 18 as-built?
19 It finally dawned on him, "What happens if you 20 guys take my drawings and find errors in them?
At this l
21 stage of the game, I can't afford to have errors."
22 It seems prudent to me.
No one in their right l
23 mind would go through another audit that wasn't being 24 forced upon them by someone.
Who needs that kind of j
25 grief, especially in light of the fact that Seabrook has l
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
175 G
1 gone through dany, many problems, much more so than Byron
" ' ~ '
2 ever thought of.
3 MR. GAVULA:
Do you think he felt that 4
there was, in fact, a significant safety problem?
5 NR. NICBOLSON:
I believe that he really 6
didn't know one way or another, but he did not want to 7
take the chance that we would find something, because 8
that would set him back, obviously, and time is money 9
back there and they wanted to get that thing licensed as 10 soon as possible.
11 Right now they're having a problem with the 12 state in the evacuation procedures that is slowing them
~
13 up.
He certainly doesn't need another as-built problem.
i 14 But I believe that he really doesn't know if he
~15 does or doesn't, but he says, "Why chance it?
Why do I 16 need this audit?
If you guys do find something, I have 17 problems."
So that's why he was very reluctant to give 18 us any drawings.
19 MR. MITCHELL:
And he is certainly 20 reluctant now that he ever had given us a drawing, just 21 as Commonwealth is.
I'm very surprised that they gave us 22 the drawing.
I wouldn't have.
23 MR. DANIELSON:
Realizing that we're not 24 going to get all of your examples, why don't you go ahead 25 and give to us the examples you have.
! (,
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON-
l 176 65 t
1
.c j
- NR. MITCBELLa~ What Mr. Rigamonti pointed 2
out was thSt when he did the first as-built check, there 3
were some problems.
As we understand it, the contractor 4
who installed the drawings did an as-built verification.
5
'For some reason, those dimensions didn't work 6
too well.
So another one was authorized.
7 Now, outside containment was the responsibility 8
of UENC.
Inside containment was the responsibility of 9
Westinghouse, because I guess Westinghouse built the 10 system.
11 So what you are looking at here is the 12 as-constructed drawing up to a point where Westinghouse
([
13 took over.
14 Scott, why don't you just tell them something 15 about what we're looking at here while I get the 16 Westinghouse drawing.
, 17 MR. NICBOLSON:
Well, very simply, we're 18 penetrating the containment 19 MR. DANIELSON:
Which drawing do we have 20 Lere, now?
21 MR. GAVULA:
9763-F-800160-542.01, Rev. A.
j 22 MR. DANIELSON:
And it pertains to what 23 system?
24 MR. GAVULA:
RH system.
25 MR. NICHOLSON:
I have a problem with that n:
G DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
f 177 bi 1
Rev. A.
I'm not sure, because there's lots of rows. on 2
here.
3 MR. GAVULA:
They go up to Rev. 17, but 4
then they've "X'ed" that out and come back.
I don't know 5
what the procedure is.
6 MR. MITCHELL:
So this part of the system
~
7 was checked by UENC.
8
'This is a Westinghouse drawing.
They're a 9
little different, but the dimensions you see down here 10 are the as-built walk-down dimensions.
11 MR. DANIELSON:
Again, what drawing are we 12 ref' erring to here?
13 MR. MITCHELL:
This would be System 14 Line 13.
The last two digits tell you your number, 13.
15 Now, what this shows is, you have a 16 penetration, Penetration Number X-13.
17 MR. DANIELSON:
There is no other 18 identifying number, is there?
19 MR. MITCHELL:
That's right.
This is the 20 actual walk-down document.
This is the actual drawing.
21 MR. GAVULA:
You can go back to their PEDS i
22 program, probably.
We'll have to see if they can trace 23 it through with this information.
24 MR. MITCHELL:
There are two of then I'm 25 looking for.
Let me get one more.
There are several
(
~
l DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
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178
($;
I sheets that g6 together.
2 Okay.
Bere we're talking about 3
MR. DANIELSON:
That first drawing we 4
spoke of from Westinghouse dealt with Line Numbers 13, J
j 5
14, 160, 180, 182 and 2707 6
MR. MITCHELL:
Yes.
l 7
MR. DANIELSON:
The one that Mr. Mitchell 8
is talking of now is 9
MR. MITCHELL:
Is 160.
I'm sorry.
- 160, 10 not 13.
You see that "160" right there.
11 MR. DANIELSON:
Okay.
It says Line 12 Numbers 058.1607 j
13 MR. MITCHELL:
"58" is a line number.
j 14 "160" is a line number.
"138" is a line number.
They l
15 have them all together.
It's really confusing.
16 So what we had, we had the as-constructed over 17 here.
What we wanted was the as-constructed in this area 18 that we had initially worked on for our interference 19 study way back when.
j 20 Now, what we have is we have a sleeve here.
21 They call it penetration -- or, actually, Anchor Point 22 X-13, and that, of course, is what they're talking about i
23 right there.
i j
24 Now, this is the actual walk-down document we 25 have that is supposed to be verified against this, and
(;.
1 DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON r
I
179 g
1 then your anaiysis.
If there is any discrepancy, you 2
check your analysis.
This is the reconciliation of the 3
two drawings.
4 Now, when we first looked at thi's drawing, we 5
couldn't figure heads or tails out of it either, because 6
we couldn't figure out where to start at.
7 So we called them up and we said, "Can you 8
explain what this little drawing over here by 9
Penetration X-13 is and how you mean to start the 10 dimensioning from that anchor point?"
11 And they said, "If you take the sleeve drawing 12 SX-l3, which we'll send you a copy of, we will show you 13 how we came up with the dimensions that you're looking 14 for."
15 Now, this is quite intriguing.
What they seid 16 is to come out to where you actually start dimensioning 17 on your pipe.
You take the sleeve, and from the wall, 18 the outside containment wall, you will see a measurement.
19 In this particular case it's 2 foot 10-1/2.
And then you 20 will come down and see another measurement, 17 inches, to 21 what we call the flued head.
22 Now, to find out where to start inside the 23 containment, you take this beginning point at the flued 24 head.
You add 17 inches out.
You come back 2 foot 25 10-1/2 inches.
V.
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
180 0
1 You come back 4 feet 7-1/2 inches'and whatever 2
dimension is shown from the inside of the containment 3
wall to the edge, and you will see that that works out 4
close to 6 foot 11-1/2.
5 So what we did is we did that, and it didn't l
6 seem to work.
We said, "My goodness."
Okay.
Now we 7
understand where they started from.
8 They also said that all measurements are from 9
weld points.
So in this particular case we have the 10 anchor point.
This point right here that matches into 11 the sleeve would be the start point.
That is the weld 12 point and that is what the drawings called for.
13 So what we did is we took the dimensions 14 starting at this anchor point and we came out here 2 foot l
15
. 9-1/2 and we came down here 24 feet and we did all the 16 dimensions as shown on this drawing, okay?
17' MR. GAVULA:
This is in your program?
18 MR. MITCHELL:
This is in our program.
19 Just took it and put it in.
20 Now, we said, "Let's take a look at the results 21 of using these walk-down dimensions compared to this j
22 drawing here and see if the supports and everything 23 work."
That's what I want to show you right now, the 24 results of that.
25 I'm showing him Seabrook As-Constructed
(.
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON i
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l 181 b
1 Discrepancy Number 53-D.
-3 v.
.N -
s'
.s 1,..
2 MR. GAVULA:
Is that your designation?
3 MR. MITCHELL:
That's our designation.
4 Let's see if we can all get the same idea.
5 Bere we have the wall.
This is the wall right here.
We 6
have the dimension of 1 foot 4-3/4.. That's to this point 7
right here, as it was explained to us by Westinghouse 4
B personnel.
9 We checked with them four different timen to 10 make sure that we were starting at the same spot, the 11 correct spot, doing it correctly, and that their 12 tolerances were plus or minus 1 inch for the as-built 13 walk-down.
14 You see you're given a dimension of 2 foot 15 9-1/2.
You're given a dimension of 24 feet 3-7/8, this 16 point here.
You're given a dimension of 11 foot 3-1/2, c
17 boxed in.
The dimensions I'm giving you are boxed in.
18 In all the dimensions we simply followed this line 19 around, and that's what the drawing shows.
20 Does everybody see that, see where I got the 21 dimension?
22 The results of using those. figures would be 23 this.
We have a support here.
24 MR. DANIELSOEs Again, what drawing are L
25 you referring to?
s.
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON 1
182 1
MR. MITCBELL:
This would be 53-D,-
~
2 Sheet 2.
3 We have two supports located right bere, right 1
4 next to each other.
Where this support should be right 5
here is back to this as-designed spot.
In other words, 6
it should be right back in here rather than right here.
j 7
MR. GAVULA:
How far is that?
8 MR. MITCHELL:
A foot maybe.
9 MR. MICBOLSON:
It's over a foot.
In one l
10 direction it's 1.3 feet and the other direction is about 11 a half a foot.
That isn't the real point here.
The 12 distance is the fact that here is what the support looks 13 like.
The support is intended to weld up to this piece 14 of steel and this piece of steel here.
15 In reality, based on the Westinghouse 16 documentation, the support is essentially hanging out in 17 mid air.
Well, we know it's not that way in the field.
18 We know what it looks like in the field in that the 19 hanger is probably over here and welded properly to the 20 support.
21 MR. DANIELSON:
Do we have a support 22 number for that particular support?
23 MR. MITCBELL:
Yes.
He's got it written 24 on here, Scott.
25 MR. MICHOLSON:
Yes.
It's on this drawing
~
d DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON i
183
(:
1 here.
y ;.,-
~
2 MR. MITCBELL:
You're right.
Bdhe it is.
3 160-RM6 and 165.
Now, we have those supports.
4 MR. DANIELSON:
That was 160-SG5.
5 MR. MITCHELL:
Okay.
SG5.
We physically 6
have those supports here, the as-constructed.
7 MR. GAVULA:
So the discrepancy comes between the piping configuration for the walk-down versus 8
^
9 the pipe support location from the pipe support drawing?
10 MR. MITCHELL:
The as-built walk-down, 11 okay?
All these dimensions are as-built, even the 12 lochtion.
The supports are located within 1 inch of the i
~
13 dimensions shown on this document, too.
14 We're saying, "If that's true, you aren't going 15 to hit your steel.
If we attach the support to the pipe 16 as you show, then we're not going to hit the steel."
17 so bells should be ringing.
There is a 18 dimension wrong.
There is something wrong, and that's-19 what we show.
20 MR. GAVULA:
Where did the information for 21 the steel come from?
22 MR. MITCHELL:
We had that already, 23 because we had done this area before.
l 24 So that's one of the questions.
First, bells 25 started ringing, because they asked us over the
.~
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
184 Nb I
telephone, "Are you guys finding anything?"
74?[f E-
~
2 "Well, sure.
This is off.
This is off."
3 "It's not the as-built information, gentlemen.
4 It's the unverified information you're using, such as a 5
sleeve or such as the steel."
That's the first thing 6
that cane'out of their mouths.
7 "You're using unverified information.
If you i
8 say there is something wrong with this drawing not going 9
through a sleeve properly, it is the unverified,4geeve or I
10 the unverified structure."
11 In other words, they're saying, " Hey, this is 12 not here.
It's over here."
13 To that, gentlemen, I said, "I believe the 14 unverified information more than I believe your as-built 15 information, and that's why I'm here, to prove it to 16 you."
17' MR. GAVULA:
What was your basis for that 18 statement?
19 MR. MITCHELL:
Because I knew that the 20 doggone steel was correct, because you can't -- these i
21 areas are so tight and so critical and so congested that 22 that steel, which is as-built, because those drawings 23 have to be -- those are safety related items.
Structure 24 is safety related inside containment.
If they're moved 25 or changed, they have to have a change on them, also.
(_
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON t
185 1
We simply in the past have found the structure y,y :... -
2 correct, the sleeves correct, the piping wrong.
3 MR. GAVULA Again, it's an assumption 4
based on your past experience?
5 MR. MITCHELLi That is correct.
In other 6
words,~none of the other systems would line up.
We would 7
have physical problems all over the place if this system 8
was like it was shown.
9 In other words, I'm jamming that support into 10 other systems.
I have a composite of the area, 1
11 gentlemen, so I know what is going in that area from my 12 work'on the interference analysis program.
So I know
^
13 exactly what is in there.
14 So we said, " Hey, here is what the drawing 15 shows, and if you use it as the drawing shows, these are i
i 16 the type of problems you will have."
17 We could have done the same thing with 18 Commonwealth had we had the supports, which we never 19 could get, the as-built supports.
20 Bere is another problem if we use that 21 dimension.
I'm showing Discrepac..y 53-C now.
"If we are 22 to believe these dimensions you show in this drawing, we 4
23 tie into the line here, we'll throw another system off.
i 24 It doesn't meet.
These systems don't meet if 25 we use the as-built information.
i DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
186 1
s.
104 1
.MR. DANIELSON:
Off of which. drawing? t*;f,y,-
m.. w p.
.,. ]
.mg. :-
This would be ' of f of --~ ~6*;'
2 MR. MITCHELL:
i 3
what is this line number here, Scott?
4 MR. MICROLSON:
180.
~
5 MR. MITCHELL:
180, okay.
Somewhere in l
6 here.
Bere we are.
Right here.
This line represented
~
7 right here is this line right here.'
8 So if I use the information as shown on this 9
drawing right here, I can't tie in properly.
I'm way out 10 of whack, and my supports don't work over here.
11 MR. GAVULA:
Were you able to identify 12 what seemed to be the problem?
'[
13 MR. MITCHELL:
Yes.
We knew what the 14 problem was.
There are two problems on the one drawing.
I 15 One of them, a dimension by the penetration is incorrect.
j 16 MR. DANIELSON:
Which dimension is that?
17 MR. MITCHELL:
The 2 foot 9-1/2.
It's 18 incorrect by about 5 or 6 inches.
19 The other discrepancy was that this dimension 20 of 24 feet should be 25 feet 8 to have it all work out.
f 21 MR. MICHOLSON:
They forgot the elbow.
1 22 MR. MITCHELL:
We estimated that they 23 forgot the radius bend on the elbow.
t 24 MR. NICHOLSON:
This dimension, this l
25 arrowhead, should actually be going to this weld on the r
Es>
4 DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
--w---
+ -, - - -,, -
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I 187 1
! bd I
long radius elbow, and it's -- what si'se line~is that?
i 2
MR. MITCBELL:
It's a good size.
You've 4
3 got it written down there.
4 MR. NICBOLSON:
A 12-inch line.
5 So the 18 inches that were out just happens to 6
be the radius of the elbow.
So if you add this 18 inches f
7 to this 24 foot 3 that they have, you come up just 8
exactly almost, 25 8-1/4..
Works great.
t 9
We have no qualms about that, the fact that 10 MR. MITCHELL:
Where the problem is at.
11 MR. NICHOLSON:
Or how it occurred.
It's i
j 12 a very simple drafting error again.
)'
13 But their answers are what we have qualms with.
14 MR. MITCHELL:
So what happened is they 15 flew out three people to see us.
One of them was
]
18 Mr. Steve Sadosky.
17 We were told that at the beginning of this, we 18 would do our thing and come back and make a presentation 19 to Mr. Ed Brown and his staff to see what we had done, j
20 That was the agreement, at no charge to them.
i 21 But they wanted to fly Mr. Sadosky out and a i
i 22 couple of other people out to see what we were finding, 23 because we said we had found some stuff.
24 So they flew some people out here.
I believe 25 it was in February, the middle part of February of 1986.
(
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON i
.---n.
---n------
4 188 1
These three gentlemen told us that we were using 2
unverified information, and, therefore, that i whohthe 3
discrepancies were, that there could not be any problem 4
with these.
'5 When we showed them what the discrepancies 6
were, they then came back and said they're within 7
tolerance.
" Gee, we can move a system 6 inches or the 8
diameter of the pipe and that will correct all these 9
problems."
10 We then gave them the walk-down specifications, 11 which are quite similar to Byron's, and all of a sudden, 12 things started to happen.
~
i 13 First of all, they said, "Yes.
We don't 14 understand why you've got these problems based on the 15 information you now have, but we're going to go back to 16 the field and find out what happened."
I 17 The answer to the story we got is in this i
18 letter.
That is the answer.
19 MR. NICHOLSON:
Of course, on the l
20 telephone Mr. Sadosky said, "You can't take on 21 Westinghouse."
Maybe he's right.
We didn't get a 22 contract.
23 MR. DANIELSON:
Is this copy for us?
t 24 MR. MITCHELL:
If you want it.
I don't 25 know whether you want it or not.
(
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON nm i
189 C.
m 1
NR. NICROL805:
'This was the first time'in meu n
2 17 years we've ever been loaned drawings, number one, and 3
the reason they wanted them back so bad is because they 4
were as-built drawings.
They didn't want us. going 5
anywhere outside of our office or their office with those 6
drawings.
This is my opinion.
7 MR. MITCHELL:
We did get some answers
~
8 back.
We were told, first of all, "Sorry, gentlemen.
9 You weren't using the latest as-built information."
10 If you'll notice, this particular drawing has 11 one signature on it, right there, and for this drawing to i
12 be ' finalized, it had to have two signatures.
I 13
- so, Mr. Mitchell, we just found that 14 yesterday.
Dimensional error.
And by the way, 15 Mr. Mitchell, we went out and we measured from the wall 16 to the edge of that line there and that is exactly l
17 39 inches.
If you look at the as-constructed dimension, l
18 you add these dimensions up, I foot 9, and 1 foot 6, you l
19 come out to 39 inches.
i 20 "Your problem, Mr. Mitchell, you don't i
21 understand how we do our work and that is why you have 22 these errors.
You have presented erroneous information i.
23 to us."
And we said, "Okay."
24 I'm given a dimension of 1 foot 4.
i 25 MR. DANIELSON:
This is referring to which l
\\
DEAN NOBURG & ASSOCIATES - SEATTLE, WASHINGTON I
i
Q?,
190 I
drawing?
4 fC j
'[f' 2
MR. MITCBELL:
This is referring to the 3
verified as-built sleeve drawing.
4 They said, "It's very simple why you guys made 5
a mistake.
Bere is the sleeve.
Bere is the wall.
That 6
dimension is 1 foot 4-3/4.
What happens, what you don't 7
understand, Mr. Mitchell, is that there is only one weld i
8 there, not two as you're shown.
9 "That weld is simply up against that elbow 10 right there, and that's 18 inches.
That's a long radius 11 bent elbow, which is 18 inches on a 12-inch pipe.
12 "Mr. Mitchell, we went out and measured this 13 distance and it's 39 inches, just like the drawing i
14 shows."
15 Sounds good to me.
I'm not going to argue with 16 them.
But, gentlemen, I have a verified as-built sleeve.
17 I know this dimension is 18 inches, and if I add these.
18 two up, I certainly don't come up to 39, 3 foot 3.
I 19 come up to 2 foot 10.
l 20 I said, " Bey, I don't care what the true 1
21 dimension is, guys.
You ought to get the drawings to at 22 least reflect it within your specifications."
23 They don't know about this yet.
We weren't 24 allowed to go make a presentation to them.
" Don't tell
{
25 us what our problems are."
(
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON-l l
191 b.*
4
~
1 You asked about how many feet. ~ We worked only
$w,-jifS4(g<(& '
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si 2
300 feet.
.?;;;..
3 So there are other problems with this.
If you 4
were to take this system -- and I should,actually get the 5
system I want.
This is the one right here.
6 If you are able to take another system, which 7
is 013, it has two signatures on it now, doesn't it?
It j
8 should be a finalized drawing,~according to them now.
9 If you use this drawing and follow it all 10 around, I can't get these supports to work.
11 MR. DANIELSON:
What support numbers are t
12 these?
~
13 MR. MITCHELL:
I'm talking about this 14 support here, 13-G.
15 MR. DANIELSON:
SG-77 s
16 MR. MITCHELL:
Yes.
And where are the l
17 other ones?
There is another one in here.
This support 18 here.
Depending on which way I go, I can't get these j
19 supports to work.
20 This is what it looks like.
If I use the i
21 Westinghouse walk-down drawing -- I believe that's a i
22 solid line here -- this is what the system does.
If I 23 use the piping vendor's verified as-built dimensions, I'm 24 way over here.
25 I don't care which one I use.
I can't get s
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
192 h
1 eitheroneofthese'totdi'intothehotlegthatthey're j
.a..
2 supposed to.
3 MR. GAVULA:
Bow far off is the deviation?
4 MR. MITCBELL:
It depends on which one 5
you're looking at.
One is about 5 feet.
The other is 6
about 10 inches, somewhere in there.
7 MR. GAVULA:
Bow about the support S
location?
9 MR. MITCHELL:
The supports won't work.
10 MR. GAVULA:
What do you mean by " won't 11 work"?
l 12 MR. MITCHELL:
In other words, I can't l
13 attach them to the steel.
14 MR. GAVULA:
The location specified on the 15 support drawings
-16 MR. NICBOLSON:
If we attach to the pipe 17 the way the support shows, we can't attach to the steel.
18 If we attach to the steel, we can't attach to the pipe,
)
19 based on the length of the support and the dimensions l
20 given for the support.
21 MR. DANIELSON:
The drawing we are looking
[
22 at when we are talking about these two different lengths i
23 of piping is Drawing 53-F.
i 24 MR. GAVULA:
This is a CIE document, also?
25 MR. MITCBELL:
Yes.
s
'N DEAM MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
193
(..
1 MR. NICBOLaous And we made these drawings 2
simply to present the problems to their personnel.
I 3
don't recall where the error is on this one.
4 MR. MITCBELL:
I know there is an error in 5
here.
You would have to take a look at the bulletin, but i
6 there is an error here and there is an error, I believe, 7
in here.
8 Again, all we said was, " Guys, someone should 9
be able to take these drawings and take a quick look at 10 them and be able to come up within your tolerances, with 11 no problems such as we're finding here."
12 They said, "These are preliminary drawings.
13 We're not doing an audit.
You're not checking us out.
14 Get out of here.
You're not allowed to come back and 15 make a presentation to the chairman of the board.
You're 16 not allowed to make one to the president.' We don't want 17 to see any more that you guys have got.
We don't have a 18 problem.
Send the drawings back."
19 Again, why we didn't notify the NRC was very 20 simple, gentlemen.
Preliminary, right?
I can't hang my 21 hat on that one, can I?
If this plant was operational, 22 though, I could.
23 MR. NICHOLSON:
It's funny that Yankee 24 Atomic and Seabrook are going in for an operational 25 license prior to February the 26th of '86 or prior to the
(
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
194 h
I 1
January time that we did this demonstration.
2 They're not getting the license.
Therefore, 3
all drawings were still preliminary, but they certainly 4
were indicating to the NRC that the drawings were ready 5
to be approved.
6 MR. MITCBELL:
I have a question just 7
generally.
I'm speaking off the top of my head.
8 If I was a utility, why wouldn't I use every
)
9 procedure possible to make sure my drawings were within 10 the specifications that I agreed to?
11 MR. DANIELSON:
I think they do as best 12 they can.
13 MR. MITCHELL:
That is exactly the answer 14 that was given by Commonwealth.
"We do the best we can, 1
15 but no system is perfect."
1 16 But when somebody can come in and find these l
17 type of problems instantaneously, then don't you think 18 it's time to relook at the situation, or am I wrong?
19 MR. GAVULA:
I think it depends on the l
20 significance of the deviations.
What you have pointed 21 out at this point are documentation errors.
Again, you 22 have to go back and look at the stress analysis before 23 you can come up with the significance of these 24 deviations.
25 MR. MITCHELL:
Again, you're bringing it l
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON-l
r l
195 kh intooneprobbenwhenthey'retwoseparateproblems.
1 2
MR. GAVULA:
Well, isn't, though, the as-3 built drawing -- what do you do with the as-built 4
drawing?
5 MR. MITCBELL:
For one thing, you're 6
required to have it.
7 MR. NICHOLSON:
What do you do with it, 8
not what do we do with it.
9 MR. GAVULA:
The as-built drawing gives 10 you a basis for verifying that your stress analysis is, 11 in fact, correct.
12 The as-built drawing in and of itself I don't 13 know really has that much function.
You've got to refer 14 back to the-stress analysis to compare what you've got in 15 the field..
16 MR. MITCBELL:
New Reg. 800 says you will 17 have as-built. drawings.-
18 MR. YIN:
We are not trying to debate the 19 use of the as-built here.
Definitely if the CECO 20 procedure required to maintain the as-built and they have 21 defined the accuracy of the as-builts, they are 22 committed,-in other words, in accordance with that 23 procedure or requirement.
24 Anything that deviated from the procedure 25 specifications is considered to be a violation, a DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
_. _ _. ~
l 196 h
noncompliance [ We certainly will look 'into that.
I 2
MR. MITCBELL Okay.
So we showed you I
3 what we could.
j 4
We can't bring in the stuff on Tennessee valley 5
Authority, because it's not even as good as this, because 6
we don't have -- we weren't assured that the drawings we l
7 were working on, TVA or Duke Power or Clinton or Trojan i
8 or San Ofrey Unit III, were in the as-built condition.
9 But we have found, in our minds, enough 10 discrepancies that back in 1981 we thought that the NRC 11 should take a look at it ard they said, "No.
We need 12 better information than you have."
That is why it has 13 taken this long to present that type of documentation.
14 MR. DANIELSON:
If representatives from 15 Region I were to come out here, would you have more 16 examples?
17 MR. MITCBELL:
Yes.
We would put a 18 package together for them to take a look at.
Be happy 19 to.
20 MR. NICBOLSON:
As I said, I'm happy to do 21 further analysis.
If you are able to obtain as-built 22 documentation on any plant, I will be more than happy to 23 show you some more. problems to further substantiate my 24 position here.
25 MR. GAVULA:
Do you think you can find
(_.-
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
t 197 1
1 1
this on any plant?
2 MR. MITCBELL:
Any plant.
3 MR. MICBOLSON:
I can find it on any 4
plant.
It's not an "if."
5 MR. MITCBELL:
In fact, you can find it 6
easier on the older plants, because it was humanly 7
impossible to walk down the older plants.
You can't get l
8 into the areas.
9 The reason I say that, Mr. Nicholson and I have 10 done ship board walk-downs, and you know how difficult a 11, ship can be, and a nuclear power plant in some of these 1
12 areas is far more difficult.
13 You can't even see the area.
You've got 40, 14 50, 60 feet from the floor to the ceiling just crammed of 15 piping systems.
You can't even.get scaffolding up there 16 to do the measurements.
i 17 So this idea of taking 300 people and turn them 18 loose in a power plant to go out with binoculars and look 19 at them was ridiculous.
l j
20 You bet your Dreadin nuclear power plant as-l 21 built drawings have got problems with them.
It would be 22 easy to find, but what bothers me is that we're finding l
23 them on power plants that are under construction today 24 that have procedures set up to go through and check these 25 out.
' (.
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
().'
1 That is what bothers me, is that the techniques 2
today don't work.
They didn't work in 1980.
They don't 3
work in 1986, and if we let this go on, they won't work 4
in 1990.
5 so, gentlemen, I think we can wrap this up 6
somewhat, if you like.
I would like to make some closing 7
statements.
8 Mr. Nicholson and I have been in this game 3
17 years and we have brought this, as we said, to top 10 management in many utilities and the NRC and to you 11 gentlemen today.
12 We don't know you people from Adam, but we have 13 had people before come in that we didn't know sit down 14 and tell us certain things, and we found out they didn't 15 transpire.
A good example is the people from Public 16 Service of New Hampshire on the Seabrook demonstration.
~~~"
17 If you're not aware of it, we want to make you 18 aware of it.
We have contacted the State of Illinois, 19 their nuclear safety department.
We think they have a 20 right to know.
21 MR. DANIELSON:
We are aware of that.
22 MR. MITCBELL:
We also have contacted our 8
23 senator, Senator Evans, and his staff is aware of what we 24 have here, and they said they would -- if we asked, would
(;-.
at least ask for an investigation.
We're quite familiar 25 DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON l
d
.....__.______,,..-._,,,,..._.._,_.______,m___,.
({t withGAOandwethinktheydoagoodjobofinvestigatinh^
I
~
2 work.
3 We don't know what NRC is going to do.
We 4
assume, we make the assumption today, that you.are going 5
in and do an adequate job and come back with the facts as 6
they are, and you're not going to try to make it good for 7
CIE or for Commonwealth Edison.
"We believe that.
8 I just want to let people know that if I have i
9 any inclination, any inclination, that this thing is 10 being done improperly or what I think or interpret i
11 improperly, I'm going to ask for an investigation by the 12 GAO.
I just want that straight out.
13 I don't know the middle management people in 14 NRC, but I have heard some comments already that I'm not 15 satisfied with.
16 I'm certainly unsatisfied with the letter I 17 received from Commonwealth which leads me to believe that 18 somebody from the NRC has had some discussions, and I 19 just didn't like the results of that.
20 MR. DANIELSON:
You can rest assured that 21 we will investigate this and be assured that there are no 22 significant issues out there that remain to be dealt 23 with.
24 MR. MITCHELL:
It's also our understanding 25 that we will receive a copy of the transcript.
(.
DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON i
l
i 200 (h?
1 9 "" $ ~"^ 'c'. ~..:qhN>n t -}' ".
1 MR. DAMIELSOM:
Yes.' "..
2 Debra, with regards to the transcript, please, 3
only the original, and mail that to U.S. Nuclear b
4 Regulatory Commission, Region III, P. O. Box 2027, Glen 5
Ellyn, Illinois, 60138-0227, and please make it to my 6
attention.
7 I have three rather common statements we like
~
8 to end a discussion like this with.
9 Do you have any further information you would 10 like to add for the record?
11 MR. MITCHELL:
Mot at this time.
12 MR. DANIELSON:
Do you feel we have 13 adequately covered your concerns here?
14 MR. MITCHELL:
You have listened to our i
15 presentation.
16 MR. DANIELSON:
Have you given this
]
i 17 information to us freely and voluntarily?
18 MR. MITCHELL:
Yes.
19 MR. DANIELSON:
And, to the best of your 20 knowledge, none of the information is proprietary?
21 MR. MITCHELL:
That's correct.
22 MR. DANIELSON:
We're off the record now.
23 (Proceedings terminated at 24 3: 80 p.m.)
25
.N DEAN MOBURG & ASSOCIATES - SEATTLE, WASHINGTON
-