ML20211B428
| ML20211B428 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 10/10/1986 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| CON-#486-1215 OL, NUDOCS 8610170230 | |
| Download: ML20211B428 (120) | |
Text
c OR GINAL UN11ED STATES rs NUCLEAR REGULATORY COMMISSION IN THE MATTER OF:
DOCKET NO:
50-456 OL 50-457 OL COMMONWEALTH EDISON COMPANY (Braidwood Station, Units 1 and 2)
LOCATION:
CHICAGO, ILLINOIS PAGES: 14354 - 14471 DATE:
FRIDAY, OCTOBER 10, 1986
- 78. 0 /} chb, ZbeAdv S-ryic e j.7efer
// / / - // 9 Acs-reosaat aegaareas,1xc.
O Official Reporters 444 North CapitolStreet l Washington, D.C. 20001 8610170230 861010 PDR ADOCK 0500 6
{
(202)347-3700 NATIOMv!DE COVERACE
14354 1
2 UNITED STATES OF AMERICA 3
NUCLEAR R EGULATORY COMMISSION 4
BEFORE.nlE ATOMIC SAFETY AND LICENSING BOARD 5
__________________x 6
In the Matter of:
7
- Docket No. 50-456 COMMOUWEALTH EDISON COMPANY 50-457 8
(Braidwood Sta tion, Units 1 9
and 2)
__________________x 10 11 Page: 14,354 - 14471 s
12 United States District Cour t House 13 Courtroom 1919 Chicago, Illinois 60604 14 Friday, October 10, 1986 15 16 The hearing in the above-entitled matter reconvened 17 a t 8:00 A.
ft.
18 B EFO RE:
19 J UDG E HERB ERT G ROSSMAN, Chairman 20 Atomic Safety and Licensing Board U.
S.
Nuclear Regulatory Commission 21 Washington, D.
C.
22 J UDG E RIC[l ARD F.
COLE, !!cm be r,
Atomic Safety and Licensing Board 23 U.
S.
Nuclear Regulatory Commission Washington, D.
C.
24 425 J UDG E A.
DIXON CALLIH AM, Member, Atomic Safety and Licensing Board U.
S. Nuclear Regulatory Commission Sonntag Repor ting Service, Ltd.
G enev a, Illinois 60134 (312) 232-0262
14355 1
Washington, D.
C.
2 APPEARANCES:
3 On behalf of the Applicant:
4 MI CH A EL I.
MILLER, E SQ.
PHILIP P.
STEPTOE, III, ESQ.
5 Isham, Lincoln & Beale Three First National Plaza 6
Chicago, Illinois 60602 7
On behalf of the Nuclear Regulatory 8
Commission Staff:
9 GRD30RY ALAN B ERRY, ESQ.
ELAINE I.
CH AN, E SQ.
10 U.
S.
Nuclear Regulatory Commisalon 7335 Old Georgetown Road 11 Bethesda, Ma ry land 20014
')
12 On behalf of the Intervenor:
13 ROB ERT G UILD, ES2 14 15 16 17 18 19 20 21 22 23 24 25 Sonntaq Repo r ti ng Service, Ltd.
Geneva, Illinois 60134 j
(312) 232-0262 i
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EXIIIBIT INDEX MARKED RECE IV ED 2
Intervenor's Exh'ibit No. 162 14417 14471 3
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TESTIMONY OF 2
TilOMAS B.
TH ORS ELL KENN ETH TIlOMAS KOSTALL 3
CROSS EXAMINATION 4
(Con tin ued)
BY MR. GUILD:
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JUDGE GROSSMAN:
We're back in session.
2 This is the 73rd day of hearing.
3 We concluded yesterday's session with Mr. Guild's 4
cross examination of the panel.
5 Mr. G uild, could you please continue.
6 MR. GUILD:
Thank you, Mr. Chairman.
7 Good morning, gen tleme n.
8 BY MR. GUILD:
9 Q
Let's turn to the document that's been received as 10 Intervenors' 161, Sargent & Lundy procedures for 11 evaluation of BCAP CSR discrepancies.
{
12 You have that document before you, gen tlemen ?
13 A
(WITNESS KOSTAL)
Yes, sir.
14 0
Now, the first section of that document, Obj ectives 1.1, 15 A,
"To verify" -- and I'm taking that language -- that 16 term f rom the preceding paragraph -
" A, No programma tic 17 design significant problems exist in the construction of 18 the Braidwood Station which have not been identified and 19 addressed."
20 It's clear that Sargent & Lundy had already taken a 21 position on that question, in par t, prior to undertaking 22 its role in BCAP?
23 A
(WITNESS KOSTAL)
That's not correct.
24 What this is is just a redefinition of the Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 l
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objectives of the BCAP program which are defined in the 2
BCAP document.
3 Q
Well, that may or may not be what it is, but that's not 4
exactly what my question was, Mr. Kostal.
5 Let me s ee if I can be a little clearer.
6 Sargent & Lundy, because it had a continuing 7
responsibility as we discussed yesterday, had certainly 8
taken a position that, up to the point when the BCAP 9
program began, there were no programmatic design 10 significant discrepancies that had not been addressed or i
11 identified, in whole or in part?
You had taken that 12 position, hadn' t you ?
13 A
(WITNESS KOSTAL)
We have not taken either position.
14 What we've -- what our position has been is we will 15 assess anything -- or any discrepancy that arises at the 16 Braidwood Station, and we will determine whether or not, 17 through that assessment, the element can carry its 18 design loads, and make a recanmenda tion, if it can't 19 ca r ry its design load, as a corrective action.
20 0
Well, sir, it is clear, though, that to the extent tha t 21 discrepancies were ref erred to you, to the extent that 22 questions werc referred to you for interpretation of 23 your design specifications, to the extent that 24 throughout the process Sargent & Lundy, during the Sonntaq R epo r ti nq Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14360 1
course of its normal duties from Day 1 with the 2
Braidwood proj ect, looked at structures, systems and 3
components, you had already concluded that there were no 4
programmatic design significant discrepancies at the 5
time you undertook your BCAP responsibilities?
6 A
(WITNESS KOSTAL)
At the time we undertook the BCAP 7
res pon sibili tic s, all the corrective actions required 8
for NCR's, up to that point in time, had been addressed.
9 There were no outstanding corrective actions which would 10 lead us to believe that there was -- there was any 11 significant problems at the site.
12 0
Indeed.
All right, sir.
13 You had already taken that position.
14 B,
Obj ective B of BCAP, "On site contractor's 15 procedures governing ongoing safety-related construction 16 and quality assurance activities addressed all 17 applicable design and regulatory requirements."
18 To the extent that Sargent & Lundy, through the 19 procesa you described yesterday, had already reviewed 20 contractor procedures that had been sent to you by 21 Commonwealth Edison Company or the contractors 22 themselves, you had already taken the position that 23 represents objective 2, that no design significant 424 programmatic problems existed with those procedures?
Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
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{
l A
(WITNESS KOSTAL)
Well, Objective 2 has nothing to do 2
with design significance.
Obj ective 3 does.
3 Q
All righ t.
You are absolutely right.
I misstated that.
4 You had already taken the position reflected in 5
Obj ective D, and tha t is, that the site procedures met 6
all applicable design and. regulatory requirements to the 7
extent you reviewed them?
8 A
(WITNESS KOSTAL)
To the extent of the procedures we 9
r evi ew ed, they met the requirements that were imposed in 10 our specifica tions.
11 Q
All righ t, si r.
12 A
(UITNESS KOSTAL)
Whether those problems met all the 13 other quality objectives, we assume tha t those 14 procedur es were reviewed for those quality obj ectives as 15 part of Commonwealth Edison's scope of work.
16 Q
All right sir.
17 So to the extent -- let me agree that you reviewed 18 those procedures, the ones submitted to you, again, to 19 detetnine that they met applicable design requirements.
20 I'm breaking down tha t last phrase, " design and 21 regulatory requirements," focusing on design 22 r eq ui r ement s.
23 You did that, didn' t you?
424 A
(WITNESS K0STAL)
Yes, sir.
Sonntag Repot ting Service, Ltd.
Gencva, 3111nois 60134 (312' 232-0262
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Q You had already done that and made up your mind on that 2
question --
3 A
(WITNESS KOSTAL)
That's correct.
4 0
-- when you undertook your BCAP responsibilities ?
5 And to the extent, on Item C, that Sargent & Lundy 6
had any responsibility for reviewing or advising on 7
ongoing corrective action programs, significant 8
corrective actions for past construction problems, you 9
had already reached the determination, before you 10 undertook your BCAP responsibilities, tha t *.ho se 11 significant corrective actions would be a iequately 12 implemented and documented?
13 A
(WITNESS KOSTAL)
That's correct.
14 0
All right, si r.
15 So with that understanding, Sargent & Lundy then 16 has a defined role in DCAP, and that document sets 17 f or th, in pa r t, what that role is.
18 Let's look at the next page, please, sir, under 19
" Methods of Analysis, 1.2."
20 Phase I, I take it, reflects the engineering 21 evaluation of the observations that are referred to on a 22 case-by-case basis ?
23 A
(WITNESS KOSTAL)
That's correct.
24 Q
All righ t.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
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Now, Phase II I'm a little less clear about.
I can 2
read what it states there, but can you tell me -- well, 3
first of all, did.you do Phase II?
4 A
(WITNESS KOSTAL)
Yes, sir.
5 0
All right.
6 "It will consist of a trending review of all 7
observations in a population to determine if 8
programmatic construction discrepancies exist. "
9 Now, I'm a little unclear about this, this trending 10 business.
11 Did you trend all of the observations or did you s
12 only trend the design significant observations which, of 13 course, there were none of as you concluded?
14 A
(WITNESS KOSTAL)
We trended the observations that were 15 notable.
16 0
You trended the notable observations.
All right, sir.
17 Now, that trending of notable observations, is that 18 reflected in some report or document?
19 A
(WITNESS KOSTAL)
It's reflected in documents we 20 prepa red f or BCAP, which were provided to DCAP, on our 21 scope of work.
22 Q
Maybe I be tter be clear.
23 What is that scope of work?
24
/
(WITNESS KOSTAL)
Our scope of work was to review, as Sonntag Repor ting S e rvi ce, Ltd.
G enev a, Illinois 60134 (312) 232-0262
14364 1
defined here, each of the discrepancies that were sent 2
to us in observations and to determine whether or not 3
those discrepancies were design significant.
4 We were then to review the results of that 5
evaluation to determine if there were any trends which 6
we believe were programmatic and which we felt required 7
then f urther evaluation.on the par t of Commonwealth 8
Edison for future corrective action.
9 (In di ca ting. )
i 10 0
I see.
m 11 Well, perhaps this has slipped through my efforts 12 at rather -- a rather speedy attempt to understand what 13 BCAP consisted of, but I hadn't run into those 14 documents.
15 They certainly were made available.
I j ust hadn' t 15 seen them.
17 What was the problem of that trending review?
Did 18 you recommend any f urther action, Mr. Kostal ?
19 A
(WITNESS KOSTAL)
Yes, sir; and that's defined in the 20 BCAP repor t, the results of the trending review.
21 There were follow-on corrective -- corrective 22 actions.
23 For example, the missing clamps.
We found --
424 Q
Cond ui t.
Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
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1 A
(WITNESS KOSTAL)
Missing conduit clamps.
Excuse me, 2
sir.
3 We found what we believe to be a concern relative 4
to missing conduit clamps.
5 There was a walkdown program initiated to determine 6
the presence of missing conduit clamps throughout the 7
plant.
8 0
Okay.
9 J UDG E GROSSMAN:
Excuse me.
10 These are the straps that you are talking about, 11 the wall straps that are --
s 12 A
(WITNESS KOSTAL)
No.
These are the straps that attach 13 a conduit to a vertical member that's supported, let's 14 say, of f of a ceiling.
15 It's a Unistrut member where there's a little C 16 clamp which was drawn in the picture yesterday.
17 Rather than attached to a wall, it's attached to a 18 vertically supported cantilever Unistrut section.
19 J UDG E G ROSSMAN :
I'm sorry.
I interrupted 20 your answer and you were telling f urther what had --
21 A
(WITNESS KOSTAL)
In addition, we recommended that 22 stif feners attached to structural steel members be 23 reviewed.
24 We found, in the process of reviewing for hangers Sonntag Repor ting Se rvice, Ltd.
G eneva, Illinois 60134 (312) 232-0262
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associated with supporting junction boxes, which are 4
2 then supported off the structural steel, there is a 3
requirement that stif feners be installed in certain 4
instances, and we found missing stiffeners in this 5
program, and felt that that was a trend that required 6
f ur th er r ev iew, and there's a walkdown that was done to 7
r eview for stif feners.
8 BY MR. GUILD:
9 Q
All righ t, sir.
10 Now, it sounds that, indeed, these two subj ects are 11 mentioned in one of your gentlemen's testimony.
12 Mr. Thorsell, I believe you point to both these 13 programa ?
14 A
(WITNESS THORSELL)
Yes, sir.
15 Q
All right, si r.
We'll return to those in a moment.
16 Now, you understand those two walkdown programs' 17 recommendations for f urther corrective action are the 18 product of Sargent & Lundy's Phase II trending review of 19 your observa tions ?
20 A
(WITNESS KOSTAL)
Right.
21 Q
All righ t, si r.
22 A
(WITNESS KOSTAL)
And the others are defined in the 23 BCAP final report, 24 Q
So I sec.
Perhaps I could direct my attention to what j
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Geneva, Illinois 60134 (312) 232-0262 t
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those are and I'll return to those at a later point.
2 But what other products were there of Sargent &
3 Lundy's Phase II trending review by way of 4
recommenda tions ?
5 A
(WITNESS KOSTAL)
These were in our populations outside 6
of electrical area.
7 Q
That's okay.
Then I'll search the repor t.
8 Those are the two areas, the stiffeners and the 9
conduit straps -- conduit clamps for which Sargent &
10 Lundy's trending review supported a recommendation for m
11 further corrective action in the electrical area?
12 A
(WITNESS U10RS ELL)
Perhaps could I clarify that?
13 It wasn' t limited to just the conduit straps.
It 14 was a r eview of the attachment of conduits to support.
15 There was one discrepancy in which a conduit was 16 attached to a different support, and so it was a 17 combination of whether the clamp was present, properly 18 attaching th a conduits _to the suppor t, and whether the 19 conduit was attached to the proper support.
20 Q
All right, si r.
21 Conduit attachments and the stiffeners for the 22 j unction box -- on junction box mounting supports, those 23 two subj ects?
24 A
(WITNESS T110RSELL)
Actually, it's more general than Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14368 1
j unction box mounting.
2 The discrepancies were identified for junction box 3
mounting.
The program -- the corrective action was to
-4 address equipment in general.
5 Q
Eq uipmen t.
All right, si r.
6 We'll return to that later, then.
7 Now, turn to the next page, if you would, 8
ge ntlem en, pl e ase, in Intervenors' 161, under " Sample 9
Selection."
10 Now, a t 2. 2.1, there is the identification of the 11 element of the samples denoted, highly-stressed 12 elements, more highly-stressed items, and Sargent &
13 Lundy provided BCAP Task Force a list of more 14 highly-stressed items within the electrical population, 15 and those were limited to cable pan hangers; correct?
16 A
(WITNESS KOSTAL)
We provided -- yes, we provided the 17 list for cable pan hangers.
18 We also provided a list for conduits, which were --
19 and we also provided a list of certain equipment.
20 0
Well, sir, I thought I understood -- and perhaps it was 21 my mishearing -- that stress, in effect, was only a 22 significant consideration for cable pan hangers in the 23 electrical popula tion and tha t, indeed, it was only in 424 the cable pan hanger population that BCAP resorted to Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
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1 the more highly-stressed sampling technique?
2 A
(WITNESS KOSTAL)
That's correct.
3 These other lists were provided for use in their 4
engineering j udgment por tion of the sample, 5
It just provided a -- these were not to the same 6
level of stress that the conduit -- that the cable pan 7
hangers were, but they represented the most highly 8
stressed, even though they were stressed to a much 9
lesser e xtent than this popula tion, so by definition, 10 this is the highly-stressed population of cable pan 11 hangers.
12 (Indica ting. )
13 If I could give you a characterization.
In this l
14 procedure, highly stressed is defined as an item which 15 is equal to an interaction value or a margin of 20 16 percent, not to exceed 20 percent, meaning if the 17 item -- the item design still had a margin of safety of 18 20 percent, that was the cutof f for highly stressed.
19 In the popula tion of conduit hangers, a 20 highly-stressed element would be -- the list that we 21 gave them would have a cutof f value of 50 percent, 22 approximately, 4 0 to 5 0 pe rce nt, so there's a 23 significant additional margin in each of the conduit 24 hangers.
Sonntag Repo r ti ng Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
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Q Then how about for junction boxes:
2 What was the margin?
3 A
(WI TNES S KOSTAL)
There was no list given for junction 4
bo xe s.
5 0
I'm sorry.
Did you say equipment?
6 I think I misheard you.
7 A
(WITNESS KOSTAL)
Eq ui pm ent.
We gave them a list of 8
equipment that was safety-related equipment that was in 9
elevations of the plant where the seismic levels are 10 higher, and, therefore, subject to higher stresses, not 11 necessarily -- not necessarily high stress as we' re 12 defining it here.
13 Well, it is, in fact, defined here; but it is just 14 the highest-stressed elements that we have, the 15 highest-stressed equipment that we have, even though 16 they are not considered highly stressed by this 17 definition.
18 Q
Did you quantify the interaction coefficients for the 19 equipment that comprised the list of more stressed 20 it ems ?
21 A
(WITNESS KOSTAL)
No.
There -- that was based on
(
22 judgment, providing them the list of equipment that was 23 in higher elevations of the plant that had, obviously, 4
24 the higher seismic levels.
(
Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
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Q All right, si r.
While it may be obvious to you, it 2
isn' t obvious to me.
3 The higher up in the plant you get in a seismic 4
event, the more subject the item is to seismic loading; 5
is that a --
6 A
(WITNESS KOSTAL)
Right.
correct understanding?
7 0
8 So you tend to 1cok at -- one major element of 9
stress on any component is the stress that is associated 10 with the projected influences under seismic loadings.
11 You tend to have more of those loadings at higher 12 eleva tions in the plant?
13 A
(WITNESS KOSTAL)
Correct.
14 Q
That applies to any kind of component?
15 A
(WITNESS KOSTAL)
Any component.
16 Q
All right, si r.
17 It also applies -- when you are talking about cable 18 pan hangers, for e xample, the ones that are the more 19 highly-stressed items, all other things being equal --
20 by that I mean, identical cable pan hangers -- would be 21 subj ect to greater stresses at higher elevations in the
,22 plant?
23 A
(WITNESS KOSTAL)
Yes, everything else being equal, 24 they would be.
Sonntag Repor ting _ Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
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-l Q
All right, sir.
2 Well, let's talk a moment about this point.
3 The interaction coefficient that is referred to in 4
2.2.1, highly-stressed elements, a portion of your 5
procedure, Intervenors' 161, is it, in effect, th e 6
reciprocal of the safety margin value that is calculated 7
when you make your design significance evaluation?
8 A
(WITNESS KOSTAL)
Yes, sir.
9 Q
Now, just so we're clear:
10 That value -- the computation of that value is 11 described at Section 3.3, entitled " Design Margin,"
4 N
12 fur ther in this exhibit?
13 A
(WITt1ESS KOSTAL)
In 3.3, the second paragraph, it just 14 indicates that the interaction -- that the interaction 15 coefficient cannot exceed 1, meaning 1 is equal to a 16 safety margin of 1.
17 Q
All righ t, si r.
18 The definition is given, though, of design margin 19 in the preceding paragraph, and I quote, "The design 20 margin is a measure of the excess capacity remaining in 21 the component, determined as the ratio of the design 22 basis allowable stress to the actual as-built stress. "
23 A
(WITNESS KOSTAL)
But tha t's not what an interaction 24 coefficient is.
Sonntag R epo r tinq Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
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An interaction coefficient is the state of stress 2
that exists in the member as compared to the allowable 3
stress for the member calculated.
4 This is nothing but a definition defining the --
5 I'm sorry.
I stand corrected.
You are right.
6 Q
All right, sir.
7 What I want to understand, though, is you used the 8
term design margin.when you make calculations for design 9
significance.
We're going to turn to that later.
10 But that design margin is identified as MS?
11 A
(WITNESS KOSTAL)
SM.
12 Q
The other way around, you are right.
13 SM?
14 A
Safe ty --
15 Q
S sub M or SM?
16 A
(WITNESS KOSTAL)
It's j ust written SM, saf ety margin.
17 Q
Safety margin.
All right cir.
18 Safety reargin is expressed as a value.
19 And for all cases where you -- af ter you have 20 performed your calculations, refined your calculations, 21 tha t value e xceeded 1, 1.03, 1.9, 2, 3,
4, et cetera, 22 that value reflects the remaining safety margin in the 23 as-built condition of the item?
h 24 A
(WITNESS KOSTAL)
That's correct.
Sonntag Repor ting Se rvice, Ltd.
G enev a, Illinois 60134 (312) 232-0262
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Q All right.
2 Now, hoe does that value, the SM, compare to the 3
value for the interaction coefficient?
Are those 4
reciprocals?
5 A
(WITNESS KOSTAL)
That's correct.
You perform your 6
analysis, and the resultant analysis is an interaction 7
coefficient.
You get the reciprocal of the interaction 8
coefficient, and that tells you what the remaining 9
design margin is.
10 So in the calculations, you will always see the 11 interaction coefficient value first and the safe ty 12 margin second.
13 (In dica ting. )
14 Q
Fine.
All righ t, sir.
15 So when you -- in the more highly-stressed items 16 analysis or identi f ica tion, you are essentially 17 expressing the safety margin that exists in the item if 18 as built to design specifications?
19 A
(WITNESS KOSTAL)
Tha t's correct.
20 Q
Now, let's talk about how that safety margin in the 21 as-designed conditions varies for these populations.
22 Let's tal,k about, first, cable pan hanger 23 popula tion.
424 That was the area where, indeed, you f ound items Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14375 1
that met your definition of highly stressed, and that 2
was that their safety margin -- there were items whose 3
safety margin was 20 percent or less?
?
4 A
(WITNESS KOSTAL)
The definition of highly stressed is 5
where there is a -- it exceeds the allowable stress 6
anywhere between 0 and 20 percent.
7 0
All right, sir.
8 Now, how many cable pan hangers, in their as -- in 9
their as-designed condition, met that definition of 10 exceeding their safety margin by less than 20 -- 20 11 percent or less?
12 A
(WITNESS KOSTAL)
I'd like to -- I have to briefly 13 explain a hanger and what we defined as high-level 14 stresses in the hanger.
15 A cable pan hanger is made up of various 16 components.
There are member elements, which are 17 vertical and horizontal, and there are connections.
18 Each of those elements is individually designed.
Each 19 of those elements has to maintain total allowable, 20 therefore, they have to have an interaction value less 21 than 1 or they have to have some safety margin.
22 In defining a highly-stressed hanger, you define 23 the most critical element in the hanger as being highly 24 stressed.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
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1 What we defined -- what we did in providing the 2
definition of highly stressed that exceeded an 3
interaction
.8, we reviewed all the hangers and all the 4
individual elements within the hangers to look at those 5
elements where they exceeded an interaction of
.8, and 6
in that case, we had approximately -- I don' t know the 7
exact number, but it's in the range of a thousand to 8
1,500 hangers defined as being highly stressed, which is 9
the definition of an interaction exceeding
.8.
10 Q
Or a safety margin of less than 20 percent?
11 A
(WITNESS KOSTAL)
Or a safety margin of less than 20 12 percent.
13 Q
All righ t, si r.
(
14 Now, again, to help break this out for a lawyer who 15 doesn' t --- who is, at best, a folk engineer trying to 16 understand this stuff, if we' re talking about the area 17 of the plant where there are cable pan hangers that is 18 the first cut for looking to identify more 19 highly-stressed items -- again, we're talking about the 20 higher elevations in the plant -- and where would those 21 elevations be, Mr. Kostal, a t the Braidwood Sta tion ?
22 A
(WITNESS KOSTAL)
Well, let me -- to answer your 23 question, we did not make a first cut on cable pan 424 hangers.
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Geneva, Illinois 60134 l
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We have an individual computer run on every single 2
' cable pan hanger, and we reviewed the computer runs to 3
determine the interaction values, not where they were 4
located in the plant but the whole population of all the 5
hangers which are individually analyzed.
j 6
Q All right, sir.
7 Well, I thought you told me the other day that, in 8
effect, you knew where you were going to find them and 9
that you made a search of the records based on the 10 elevations because of the phenomenon that you just 11 described to me, and that is, the seismic stresses being
~
12 greater higher up in the plant.
13 A
(WITNESS KOSTAL)
What I defined to you the other day 14 was if all things were equal, you would find them in the 15 upper elevations in the plant.
16 Given that all things are not equal, the only place 17 you can find them is through the individual analysis of 18 the given hangers.
19 Q
All right, sir 20 Well, bear with me for a moment in understanding 21 your explanation now.
22 Assuming all things were equal, assuming we have a 1
23 series of identical hangers that are in dif ferent 24 elevations in the plant, what's the elevation at the Sonntaq Reporting Se rv i ce, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14378 1
Braidwood Station that would be subject to the greatest 2
stresses because of ' the seismic phenomenon that you have 3
iden tified ?
4 A
(WITNESS KOSTAL)
Again, let -me recharacterize.
5 If we designed every element to meet the code --
6 the computer program optimizes design of the given 7
hanger and connections such that it takes into account 8
the different variables that exist at each elevation, so 9
if everything was equal, we would have the same state of 10 stress in~ every single hanger, the same interaction 11 value irrespective of elevation.
~'
12 Q
That wasn' t my question, though.
13 Please do correct me if I'm just misstating 14 som e thing, because I don' t want the record to be in 15 error.
16 Let's assume we have the same identical hanger --
17 all right -- the same details, the same hanger, the same 18 configuration, but it is installed at different 19 eleva tions in the plant -- all right -- so it doesn't 20 take into account the different seismic forces at 21 various elevations.
Bear with me in my assumption now.
22 Where would the elevation be that was subj ect to 23 the greatest seismic stress?
24 A
(WITNESS KOSTAL)
Given your assumption that the member Sonntag Reporting Se rvi ce, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14379 1
sizes are the same, all the dead loads are the same, the 2
geometry is the same, and with those assumptions, the 3
highest elevation in the plant is where the highest 4
seismic response sector exists, which is at the 5
elevation of the roof, which is in the 460, 470 range.
6 Q
All right.
7 A
(WITNESS KOSTAL)
That's in the auxiliary building.
8 If you go in the containment building, it would be 9
up at the dome -- it would be up higher in the 10 containment near the polar plane, 11 (Indica ting. )
~
12 Q
All right.
13 Now, I appreciate your bearing with me.
Now let's 14 return to what your analysis identified as the more 15 highly-stressed items-in the cable pan hanger 16 popula tion.
17 Were any of those more highly-stressed items of 18 1,000 to 1,500, with the safety margin of less than 20 19 percent -- were any of them in elevations 460 to 470 of 20 the aux building or at the top of the containment near 21 the polar plane?
22 A
(WITNESS KOSTAL)
I did not review that data base to 23 determine that.
24 Q
All right.
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You don't know the answer to that question?
2 A
(WITNESS KOSTAL)
I can' t say effectually.
3 I would presume there are some.
4 Q
All right.
5 Mr. Thorsell, do you know ?
6 A
( WITN ESS TH ORSELL)
No, sir, I do not.
7 MR. GUILD:
Mr. Chairman, perhaps I can solve 8
this problem more in detail off the record, and I'll 9
certainly try; but during discussions in the proceeding 10 of this hearing, I talked with Mr. Kostal and counsel 11 about this question of more highly stressed cable pan 12 hanger samples.
13 I am interested in pursuing this matter.
I don' t 14 want to waste hearing time to do so.
15 I understood there was an outstanding request there 16 be some description of what that population was; and 17 perhaps if I can simply get a commitment f rom counsel --
18 we can discuss that matter of f the record -- then I'll 19 pursue it.
20 MR. STEPTOE:
We'll certainly commit to 21 discussing it off the record, Judge Grossman; but that 22 was the one request that Mr. Guild made during the 23 course of informal discovery that we declined to comply h
24 with.
Sonntag Reporting Service, Ltd.
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He wanted essentially a written response to an 2
inf ormal interroga tory, and we just decided that that 3
wasn' t appropriate.
4 We had given an oral explanation I believe that was 5
adequate.
6 I don't really see the relevance of this line of 7
inq ui ry.
8 Now, if Mr. Guild wants to know -- for example --
9 if he wants to have a list, the list that Sargent &
10 Lundy gave to BCAP, that's fine, but I think that the 11 minutia of how that list was-generated, the computer 12 program that generated it, it doesn' t seem particularly 13' relevant to the issues of QC Inspector harassment.
14 MR. GUILD:
W ell, to the extent this rebuttal 15 case has any relevance at all, Mr. Chairman -- and I 16 f rankly can think of some arguments to the contrary --
17 but it really is Edison's rebuttal, I wo uld say -- I 18 would suggest that if they are going to rely on this 19 case for rebuttal or case in chief, whatever you want to 20 call it, that they are obligated to defend it.
21 Now, with that understanding -- I really didn' t 22 know we had a -- we are at loggerheads at this point, 23 but I would, the n, r equest through the Chair that 24 Applicant be directed to produce the list of more Sonntaq Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14382 1
highly-stressed items that were identified in each of 2
the electrical populations.
3 If it's not a meaningf ul document. in the sense tha t 4
I guess I j ust get a list of numbers that don' t mean 5
a ny thing, it will simply call for another round of 6
requests for explanation.
7 So I would suggest, Mr.-Chairman, that it might be 8
appropriate that Applicant produce that list and 9
accompany it with some explanation so that the list is 10 intelligible.
11 JUDG E GROSSMAN:
Well, I don't understand, 12 Mr. Steptoe, what you are objecting to, because Mr.
13 Guild is not now asking for a written explanation, which 14 is apparently what you objected to.
15 MR. STEPTOE:
I thought he was, Judge 16 Grossman.
17 We have no problem with providing lists.
18 JUDGE GROSSMAN:
I understand -- well, th e 19 list you are not obj ecting to.
20 It was having a written explanation.
21 MR. STEPTOE:
That's correct.
22 JUDGE GROSSMAN:
Okay.
Now, I understand 23 he's asking for the lists and an oral explanation off 24 the record to save us hearing time; is that correct, Mr.
Sonntag Reporting Service, Ltd.
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Guild?
2 MR. GUILD:
Yes, that would suit me.
3 JUDGE GROSSMAN:
You would have no objection 4
to that?
5 MR. STEPTOE-No.
6 JUDGE GROSSMAN:
Did you wish that right now, 7
Mr. Guild?
8 MR. GUILD:
No, sir.
That would be fine if 9
we can simply have that made available at Applicant's 10 convenience, 11 MR. STEPTOE:
S ur e.
s
~'-
12 JUDG E COLE:
Sometime before the end of the 13 hearing.
14 MR. STEPTOE:
I don' t know whether I've go t 15 the records in the room.
16 MR. GUILD:
If he has them in the room, that 17 would be fine, Judge, but I ass umed they didn' t.
18 I'm not trying to be unreasonable in the matter.
19 JUDGE GROSSMAN:
I just wanted to know if you 20 wanted a recess to do it now.
21 But you are not thinking of doing it immediately?
22 MR. GUILD:
No, sir.
23 JUDGE GROSSMAN:
So I understand there's no 24 disagreement.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
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There will be the list produced, and/or lists, and 2
inf ormal explanations, and we'll go on to another.
3 subject now then.
4 BY MR. GUILD:
5 Q
Just to round this point out, Mr. Kostal, how many items 6
were in the more highly stressed identified 7
subpopulation of conduits --
8 A
(WITNESS KOSTAL)
I don' t know.
9 0
-- or, I guess, conduit hangers?
10 Is that what they were, conduit hangers?
11 A
(WITNESS KOSTAL)
Yes.
~
12 Q
And how many items were there in the subpopulation more-
~13 highly-stressed pieces of safety-related equipment?
14 A
(WITNESS KOSTAL)
.Around.20.
15 Q
How many of those items -- the more highly-stressed 16 equipment items, how many of them were BCAP CSR sample 17 it em s ?
18 A
(WITNESS KOSTAL)
I don' t know those statistics.
19 Q
Do you know if any are?
20 A
(WITNESS KOSTAL)
I could find out.
I j ust don' t have 21 it with me.
22 Q
All right, sir.
23 How many of the conduit hangers, the more 424 highly-stressed conduit hanger items, made the CSR Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14385 1
sample list?
2 A
(WITNESS KOSTAL)
I ' don' t know that, either.
3 o
with respect to cable pan hangers, you know it was sent 4
over, and I think the record reflects what the selection 5
was.
6 A
(WITNESS KOSTAL) 68.
7 0
68.
All righ t, si r.
8 Now, would you tell me what stress means as you use 9
the term in your -- in the Sargent & Lundy procedure for 10 evaluation of BCAP discrepancies?
11 A
(WITNESS KOSTAL)
Stress is a unit of measure.
It
~
12 basically defines the -- for example, in steel, it's a 13 unit of measure defining kips per square inch.
14 Q
What's a kip?
15 A
(WITNESS KOSTAL)
That's a thousand pounds.
16 Q
All right.
17 A
(WITNESS KOSTAL)
And you take that unit of measure, 18 stress, and you compare it with a unit of measure of 19 allowable stress, which is also defined in the code as 20 kips per square inch.
21 (Indica ting. )
22 Q
For steel?
23 A
(WITNESS KOSTAL)
For steel, f
24
-0 All righ t.
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W ell, let's talk about what's stress in the other 2
relevant applications for purposes of evaluating the 3
significance of electrical observations.
4 A
(WITNESS KOSTAL)
All the electrical observations are 5
steel.
They have the same definition.
6 0
All right, sir.
Th a t' s h el pf ul.
7 JUDGE GROSSMAN:
I'm sorry.
8 The same what?
9 A
(WITNESS KOSTAL)
They have the same definition.
Th ey 10 are steel components.
11 They are different types of steel, but they are 12 steel components.
13 BY MR. GUILD:
14 Q
If we were talking about, by contrast, concrete 15 e xpansion anchors, we would be talking about stress as 16 it applied to the loadings on concrete?
17 A
(WITNESS KOSTAL)
Tha t's correct.
18 Q
And that would be different?
19 A
(WITNESS KOSTAL)
Tha t's correct.
20 0
Well, how abo ut --
21 A
(WlTNESS KOSTAL)
Well, stress would be the same.
It's 22 j ust the unit of meas ur e --
23 Q
Unit of measure.
24 A
(WITNESS KOSTAL)
It's a different element, so you would Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
F 14387
\\
l have a dif ferent allowable.
2 Q
All right, sir.
3 Well, how about cables:
4 They are not steel, are they ?
5 A
(WITNESS THORS ELL)
Stress is not a factor in the 6
evaluation of cable discrepancies for BCAP.
7 Q
I'm sorry, Mr. Thors ell.
8 Have you finished?
9 A
(WITNESS THORS ELL)
Fo r B CA P.
10 Q
Fo r B CA P.
11 Well, stress is a value -- well, stress is an 12 aspect of design specifications relative to cables, is 13 it not?
14 A
(WITNESS THORSELL)
No, sir.
15 Q
Well, sir, you have specifications for maximum pulling 16 tension on cables, don' t you?
17 A
(WI TNESS THORS ELL)
No, sir.
18 Specifications define the functional requirements 19 of the cable.
20 I'm speaking in terms of specifications that 21 Sargent & Lundy prepares for procurement of cable to be 22 used in construction of the plant.
23 Now, the cable manuf acturer will provide an 24 allowable pulling tension, which is a factor that enters Sonntaq Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262 i
~
14388 1
into the installation of the cable, and that allowable 2
pulling tension is based on the properties of the copper
{
3 conductor as well as the properties of the insulation.
4 But stress in the context of code allowable 5
stresses or calculated stresses doesn't enter 'into the 6
design or installation of cable per se.
7 There are other types of stresses associated with 8
ca bl e, such as voltage stresses and voltage stresses on 9
the dielectric material that is used for cable 10 insula tion, but that's a totally different subj ect than
)
11 the type of stress that Mr. Kostal was speaking about.
12 Q
Well, I really don' t want to limit the discussion to the 13 type of stress that Mr. Kostal happened to have been 14 speaking of.
15 The f act of the matter is stress is a f actor in the 16 design specifications as they relate to materials other 17 than steel in the electrical population, and, in this 18 case, cable.
19 Whether you considered them or not in BCAP is maybe 20 the issue, but i t --
21 A
(WITNESS THORSELL)
Well, let me see if I can clarify it 22 for you.
23 In the case of structures or cable pan hangers, h
24 Sargent & Lundy is the designer of those components, and Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14389 1
Sargent & Lundy. takes into account the stresses in the 2
materials used to design those components so that we can 3
assure that the stresses to which those components are 4
subj ected are within the allowable material stresses.
5 In the case of cable, Sargent & Lundy is not the 6
designer of cable.
The cable is designed by a cable 7
manufacturer.
8 Q
Well, let me interrupt you, Mr. Thorsell, to see if we 9
can cut this short.
10 The fact of the matter is Sargent & Lundy was the 11 source of considera tion.
Whether BCAP considered them 12 or not, you j ust identified two aspects in which stress 13 has a bearing on the design of cable.
14 The first was pulling tension, and there are limit 15 specifica tions identified by the manuf acturer, and the 16 second is stress f rom the electrical standpoint, voltage 17 stress ?
18 A
(WITN ESS THORS ELL)
Right; which is also a f actor that 19 is within the realm of the cable manuf acturer.
20 Q
All right, sir.
21 And there's a f urther consideration to stress on 22 cable, and they have to do with parameters involving 23 minimum bending and training radius specifications?
h 24 A
(WI TN ESS THORS ELL)
That relates to stress on the Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14390 1
dielectric.
2 Q
All right, sir.
We'll return to that subj ect in a 3
minute.
4 Now that we've gone a little bit beyond steel, are 5
there any other materials, aside from steel and aside 6
f rom cables, where stress is a consideration in 7
establishing the design criteria within the electrical 8
popula tion?
9 A
(WITNESS THORSELL)
There are various materials that 10 will be used in the manuf acture of equipment, and these 11 materials could be subj ected either to physical stresses 12 or various types of voltage stresses.
13 However, those were not within the realm of BCAP, 14 because the role of the electrical installa tion 15 contractor is merely to mount equipment and make 16 connections to equipment, so any of the internals of the 17 equipment that may be subj ected to various types of 18 stresses would be within the realm of the equipment 19 manufacturer.
20 Q
And generally speaking, BCAP did not look at 21 vendor-supplied components or work ?
22 A
(WITNESS THORSELL)
Correct, in general.
23 Q
Can you give me a specific example of non-steel 24 materials that would be -- where there are stress Sonntaq Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
r 14391
/
1 considerations in electrical equipment?
2 A
(WITNESS THORSELL)
The terminal blocks in a piece of 3
equipment are made cf a dielectric material that has to 4
provide insulation between the various terminals.
5 Q
Is it a plastic?
6 A
( WITN ESS TH ORSELL)
Yes.
7 There's a terminal block on the table.
I 8
0 We had a chance to-look at it the other day with 9
Mr. --
10 A
( WITN ESS TH ORS ELL)
Yes, sir.
11 Q
-- Woz niak ?
j 12 A
(WITNESS THORSELL)
Yes, sir.
13 Q
Black plastic?
14 A
(WITNESS THORSELL)
Yes.
15 Q
All right, sir.
16 Do any other materials come to mind in equipment?
17 A
(WITNESS TUORS ELL)
Others -- ther e's numerous 18 components that go into various pieces of equipment that 19 would be subjected to various types of physical forces 20 as well as electric force.
21 MR. STEPTOE:
Excuse me, Mr. Thorsell.
22 Can you keep your voice up?
I'm having a hard time 23 hearing you.
h 24 A
(WITNESS THORSELL)
Okay.
Do you want me to repeat Sonntaq Repor ting Se rvi ce, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14392 1
tha t ?
2 MR.-STEPTOE:
No.
3 A
(WI TN ESS THORS ELL)
Okay.
4 MR. STEPTOE:
I didn' t mean to interrupt.
5 I'm sorry.
6 MR. GUILD:
That's helpf ul.
7 BY MR. GUILD:
8 Q
There are numerous other materials.
9 And what are those, sir ?
10 A
(WITNESS THORSELL)
I don't think I could begin to list 11 them; that there's numerous materials that go into a
~
12 motor, for example, or into a circuit breaker or a 13 switch gear or an assembly, and various types of metals, 14 pl astics.
It's a rather extensive list.
15 0
All right, sir.
l 16 J UDG E G ROSSMAN :
Okay, Mr. Guild.
17 I don't think it's worth pursuing.
I don't think 18 that involves this case.
19 BY MR. GUILD:
20 Q
The f act of the matter is --
21 MR. GUILD:
I agree, Mr. Ch airma n.
22 BY MR. GUILD:
23 Q
The f act of the matter is, Mr. Thorsell, stresses on h
24 those materials were' simply not evaluated by Sargeant Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14393 1
Lundy when they did their design significance evaluation 2
of BCAP discrepancies?
3 A
(WITNESS THORSELL)
BCAP discrepancies did not af fect 4
those materials, either, 5
Q The answer to my question is no?
6 A
(WITNESS THORSELL)
No, we did not do an evaluation of 7
those.
8 Q
Now --
9 J UDG E G ROSSMAN :
By the way, in your 10 summarization, you said cable and steel, and I believe 11 Mr. Kostal also mentioned the concrete for the straps.
12 Now, were there any other materials to which the 13 cable supports or conduit supports were attached other 14 than either steel or concrete?
15 A
(WITNESS KOSTAL)
No, si r.
16 BY MR. GUILD:
17 Q
Now, Mr. Kostal and Mr. Thorsell, please, let's return 18 to 3.0 of the Sargent & Lundy procedure, Intervenors 19 Exhibit 161, 20 Evaluations are categorized into. four levels of 21 capacity reduction, and tha t's X, Y,
Z and D.
22 Now, those categorizations, the X, Y and Z 23 ca te goriza tion s, are based on the computation of a 24 capacity reduction f actor, the R value; is that correct?
Sonntaq Repor ting Se rv i ce, Ltd.
Geneva, Illinois 60134 (312) 232-0262
~
z 14394 1
A (WITNESS KOSTAL)
Not X.
2 Q
For X you don' t make that calculation?
3 A
(WITNESS KOSTAL)
Correct.
4 Q
For X, you judge, on the basis of your engineering 5
judgment, that it is consistent with design r equirements 6
and, therefore, no R need be calculated?
7 A
(WITNESS KOSTAL)
Correct.
8 0
All right, sir.
Understood.
9 Y and Z, then, you make an R value calculation.
10 R is calculated pursuant to Section 3.2.
Th at 11 follows two pages later in the procedure.
"R equals
~
12 governing properties of as-built component," numerator; 13
" governing proper ties of as-designed component,"
14 de nomina tor, to calculate the ratio and get your R 15 value; correct?
16 A
(WITNESS KOSTAL)
Correct.
17 Q
Now, you were helpf ul, Mr. Kostal, the other day in 18 giving me some examples of how you make this calculation 19 in the structural area.
20 Perhaps you could do a repeat performance for the 21 Board and par ;:les.
22 Let's take the case of a weldment where there's an 23 underlength condition identified in the field by a BCAP h
24 obs e rva tion.
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Perhaps, if I could ask you to illustrate the point 2
on the chart, it might be helpf ul.
3 A
(WITNESS KOSTAL)
If I could make a suggestion.
4 Q
Yes.
5 A
(WITNESS KOSTAL)
As part of the procedure, that you 6
only attached the first f ew pages, there is a page that 7
gives you an explanation as well as an example in this 8
pro cedur e.
9 It may save a lot of time; but I'd be happy to go 10 through --
11 Q_
Well, why don' t you show it to me.
I didn' t mean to
' ~ ~ '
12 leave anything out that would be helpf ul, and that's 13 probably something that would be.
14 A
(WITNESS KOSTAL)
It's the example I presented to you 15 last Thursday.
16 Q
Yes, it is.
17 Perhaps --
18 MR. GUILD:
Counsel, I have no obj ection to 19 including that as part of this exhibit or marking it as 20 a separate exhibit, but perhaps I simply deleted it to 21 save paper.
22 If the witness could still summarize that process 23 on the easel, I'd appreciate it.
h 24 A
(WITNESS KOSTAL)
In essence, if we have a weld --
Sonntaq Reporting Service, Ltd.
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14396 1
le t 's s ay w e ' r e 'h av ing a -- f or e xam pl e, this is an 2
embedded plate and we' re attaching what I would call a 3
cantilever piece of tube steel, of which there would be 4
a load applied, so there is going to be a weld here.
5 (Indica ting. )
6 MR. GUILD:
Could you keep your voice up, Mr.
7 Kostal, so we can hear.
8 A
I'm sorry.
9 If I draw a cross section, what we' re going to be 10 looking at is this embedded plate and this piece of tube 11 steel and this fillet weld.
12 (In dica ting. )
13 If you look down at that fillet weld, it has a 14 certain length, a certain size.
15 In this case, we'll define this as 10 inches and 16 we'll define this as 1 inch, so it's a 1 inch fillet 17 wel d.
18 (Indica ting. )
19 Now, let's assume we have a defect somewhere in 20 that weld or some type of discrepancy where we lose a 21 portion of that which is equal to 2 inches by a 22 hal f-inch.
So the as-built area is equal to 9 inches.
23 We lost 1 inch out of 10 inches.
24 (Indi ca ting. )
Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14397 1
The as built is 10 inches.
R value is as built 2
over as designed, which is 9 over 10, eq ual to. 9.
3 (Indica ting. )
4 BY MR. GUILD:
5 Q
All righ t, sir.
6 In what category, then, would that defect, the 7
defect where there was a 1 square inch reduction in the 8
effective area of a 10 square inch fillet weld, be on 9
the basis of the R value calculation?
10 A
(WITNESS KOSTAL)
In that particular example, we would 11 classify that as a Y.
It's not less than
.9.
~'~
12 Q
All right.
13 And in that case, since its R is not less than
.9, 14 that discrepant condition would receive no f urther 15 detailed engineering calculation for design 16 significan ce ?
17 A
(WITNESS KOSTAL)
That's correct.
18 Q
All righ t, sir.
19 If, by contrast, the reduction in the area of that 20 weldment were 20 percent, was a 2 square inch reduction 21 as opposed to 1 square inch, it would have an R value of 22
.80, it would f all in the category of a Z and would be 23 required to receive a detailed engineering calculation 24 for design significance?
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14398 J
f 1
A (WITNESS KOSTAL)
Yes, sir.
2 Q
Now, if the defect were a size discrepancy for a 3
structural member, in particular a structural member 4
smaller in area than -- smaller in length, let's say, 5
than as specified in the design specifications, would 6
the calculation of R value be similar?
7 Would you make a calculation of as-designed ~ area 8
for that member, the plate, and compare that to the 9
as-built, as-found, area for that plate ?
10 A
(WITNESS KOSTAL)
Yes, sir, 11 Q
And you calculate an R value.
~
12 On the basis of that calculation, you either 13 determine that a further detailed calculation was 14 required for design significance or not depending on the 15 amount of reduction in the capacity?
16 A
(WITNESS KOSTAL)
Yes, sir.
17 JUDGE GROSSMAN:
Excuse me.
18 I take it when Dr. Kaushal told me that all of the 19 defects were evaluated for design significance, what he 20 didn' t tell me was that automatically anything in 21 Category Y was considered not design significant; is 22 that so?
23 A
(WITNESS KOSTAL)
That's correct.
24 Category Y is a category where it has an R value Sonntag Repor ting Service, Ltd.
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14399 l
1 that exceeds.9; and our logic is defined, actually, as 2
to why we don' t believe we have to continue the 3
evaluation f urther -- is defined and clarified, in terms 4
of the ph'ilosophy of why we don't believe that, on Page 5
12 of Exhibit 161 under Item 3 startin'g with the last 6
paragraph, and the philosophy in that these components 7
have design margins in them, they have material -- we 8
use -- for example, we use material strengths as 9
specified in the code where the actual material 10 strengths exceed the code allowables by generally 20 11 per cen t.
We know that our methods of analysis have 12 conservatisms built into them, so taking into account 13 all the various conservatisms that we applied to our 14 design, plus the -conservatisms that exist in the 15.
selection of materials compared to what the code 16 requires compared to what you actually get, it's our 17 belief that values less than 10 percent can easily be 18 accounted for if you did an exact analysis..
19 JUDGE GROSSMAN:
I understood the 20 explanation; but that went a little further than my 21 question.
22 Thank you.
23 A
(WITNESS KOSTAL)
Oh, I'm sorry.
24 BY MR. GUILD:
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Q The per tinent language appears at Page 13, in fact, Mr.
2 Kostal, of your procedure, quote, "When the capacity of 3
an item is reduced by less than 10 percent, it becomes 4
apparent that the minor effect to the design margin may 5
easily be offset by applying any of the calculation 6
refinements available.
Therefore, engineering j udgment 7
that an item remains within design allowables may be 8
applied to any item that retains at least 90 percent of 9
its section."
10 A
(WITNESS KOSTAL)
That's correct.
11 Q
All righ t, sir.
~'
12 And, in fact, it's not simply a discretionary 13 proposition; engineering judgment, in fact, is and was 14 applied to all such items such that no further 15 calculations were made?
16 A
(WITNESS KOSTAL)
That's correct.
17 JUDGE GROSSMAN:
Excuse me.
One further 18 cla rifica tion.
19 We were talking about a particular weld.
20 Were they welds that were categorized as Category 21 X,
Y or Z or were they entire components which might 22 include a considerable number of welds?
23 A
(WITNESS KOSTAL)
We do not perform -- unless a weld is 24 by itself, we perform an analysis based on what we would Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14401 1
call a stress plane or a transfer plane with loadings 2
from one section to another section.
3 In that analysis, you consider all the welds that 4
are made at that plane, you consider all the 5
discrepancies that are found in all those welds 6
simultaneously and you perform one analysis, including 7
all the discrepancies in that analysis.
8 So to answer your question, multiple discrepancies 9
on multiple welds are accounted for -in the analysis.
10 (Indi ca ting. )
11 JUDGE GROSSMAN:
Okay.
I believe I
-J r
12 understand what you are saying now.
13 BY.MR. GUILD:
'14 Q
All right, sir.
15 But that's not the case for welds that don' t 16 appea r, though defective, at the same transfer plane, 17 although the same item?
18 For those you do independent R value calculations 19 limited only to the defects that happen at a common 20 transfer point?
21 A
(WITNESS KOSTAL)
No, that's not a correct statement.
22 If we had -- in f act, when we go through 23 Calculation 104, I will show you examples where all the 24 defects are considered on that stress plane.
.~
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14402 1
0 That's not the question.
2 I think your testimony is you considered multiple 3
defects on a common stress plane for calculation of an R 4
value?
5 A
(WITNESS KOSTAL)
That's correct.
6 Q
All right, si r.
7 But if the defects on an item occur on different 8
stress planes, those have to be calculated 9
independently, and independent R Values are calculated 10 for each stress plane where a defect occurs?
11 A
(WITNESS KOSTAL)
All right, that's correct.
12 Q
All righ t, si r.
13 That. point, in fact, is made at 3.1 of your 14 procedure, which is entitled, " Stress Transfer Plane,"
15 and specified that the stress transfer plane is the unit 16 of evaluation?
17 A
(WITNESS KOSTAL)
Correct.
18 Q
"The stress transfer plane is defined" -- and I'm 19 reading -
"as the load carrying mechanism for all 20 normal and sheer stresses occurring at the discrepant 21 loca tion. "
22 Again, stress transfer plane is defined with 23 reference to the discrepant location?
24 A
(WITNESS KOSTAL)
That's correct.
Sonntag Reporting Se rvi ce, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14403 1
We would not --
2 Q
Th e --
3 A
(WITNESS KOSTAL)
We would not perform an analysis other 4
than at the point where you have a discrepancy.
S Q
All righ t, sir.
6 Now, if there were multiple discrepancies and they 7
occur at different transfer planes, you have to do 8
multiple analyses --
9 A
(WITNESS KOSTAL)
Tha t's correct.
10 0
-- independently ?
11 A
(WI TN ESS KOSTAL)
Tha t's correct.
12
'O Now, let's turn to the last page of your procedure, Mr.
13 Kostal, " Dis crepancy Reports. "
14 Look at Item 2, please.
In particular, the 15 f ollowing :
" Root cases and programmatic characteristics 16 of an observation shall only," with the emphasis in the 17 original -
"be addressed on Part 4" -- I take it that 18 is Part 4 of the observation form -
"if, 1,
the root 19 cause or prgrammatic characteristics occurred as a 20 result of a deficiency in S&L specifications, drawings, 21 et cetera ; and, 2,
the observa tion is design 22 significant.
The root cause is the engineer's judgment 23 as to the underlying cause of the discrepancy.
Whether 24 this cause appears to be programmatic or not should also Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14404 1
be indicated.
Additional pages may be attached."
2 Well, I take it you find no cases where you made 3
any analysis of root cause pursuant -to that provision of 4
your procedure?
5 A
(WITN ESS KOSTAL)
Tha t's correct.
6 Q
All right, sir.
7 Let me ask you this:
8 Did you find any instances where the first 9
condition of that provision was met, and tha t was, " Th e 10 root cause or programmatic characteristics occured as a m
11 result of a deficiency in S & L specifications, 12 drawings, et cetera," whether or not they were with 13 reference to a design significant discrepancy?
14 A
(WITNESS KOSTAL)
Not to my knowledge.
15 Q
W ell, did you look?
16 A-(WITNESS KOSTAL)
Sure.
17 Q
Did you document an evaluation of observations for that 18 condition?
19 A
(WITNESS KOSTAL)
It didn' t require to document it so 20 because there were none.
21 Q
I take it you did not?
22 A
(WITNESS KOSTAL)
No.
23 Q
Mr. Thorsell, do you have anything to add to that 24 answer?
Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
i 14405 1.
A (WITNESS THORS ELL)
No, si r.
I 2
Q Well, you are sort of asking Sargent & Lundy to perform
(
3 a critique of its own work when you are asking for an 4
evaluation by your engineers of the condition of root 5
cause or programmatic characteristics resulting from a 6
Sargent & Lundy deficiency, aren' t you?
7 A
(WITNESS KOSTAL)
Tha t's correct.
It's part of our QA 8
program.
9 J UDG E G ROSSMAN :
Why don' t we take a 10 10-minute break.
- ~
11 MR. GUILD:
Fine, Mr. Chairman.
12 (W H ER EU PON, a recess was had, after which 13 the hearing was resumed as follows:)
14 JUDGE GROSSMAN:
Con tin ue, Mr. G uild.
15 BY MR. GUILD:
16 Q
Mr. Kostal, now, to recap a moment, then, having gone 17 through Intervenors' Exhibit 161 with respect to the 18 calculation of capacity reduction f actors, de signations 19 of X, Y's and Z's, if I can ask you to help me correlate 20 that categorization to the data that appears on 21 Intervenors' Exhibit 141, anv tha t's your print-out of 22 the CSR da ta base, the column of notable discrepancies
'23 there for R observations evaluated by Sargent & Lundy 24 for which a capacity reduction f actor value of less than Sonntaq Reporting Se rvi ce, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14406 1
.90 was derived.
2 A
(WITNESS KOSTAL)
That's correct.
3 Q
The insignificant category represents a count of all 4
other observations comprising observations in the X's 5
and Y categories ?
6 A
(WITNESS KOSTAL)
That's correct.
7 Q
In clu ding, among thase, observations for which Sargent &
8 Lundy made no calculation, but simply reached an 9
engineering judgment that the observation or discrepant 10 condition was insignificant?
That's the X category?
11 A
(WI TNESS KOSTAL)
The X category, yes, si r.
12 Q
Now, Mr. Thorsell, Mr. Kostal has been responding to 13 q ue s tion s, as I understand, in the structur al area, 14 relating to welding and structural components.
15 You have responsibility for talking about all other 16 electrical areas.
17 It's true that you didn' t compute R values for all 18 other electrical discrepancies that were non-structural?
19 A
(WITNESS THORSELL)
That's true.
20 Q
There wer e, of course, as there were in the structural 21 welding a rea, X discrepancies, discrepancies that, on 22 the basis of engineering judgment, you determined to be 23 insignificant without any calculations at all?
24 A
(WI TN ESS THORS ELL)
For each one of the X-category Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
n-14407
~
1 evalua tion s, there was a documented evaluation of 2
engineering judgment that was prepared and reviewed.
3 That meets the same requirements as an engineering 4
calcula tion.
It's j ust that it does not carry with it a 5
calculation number and does not contain numerical values 6
nece ssa rily.
7 Q
It's a documented judgment?
8 A
(WITN ESS THORS ELL)
Correct.
9 Q
Maybe a narrative or a summary of that engineering 10 judgment?
11 A
(WITN ESS THORS ELL)
Yes, sir.
12-Q All right, sir.
13 Now, how about for the Y ca tegory of discrepancies 14 in the non-structural non-welding area?
15 It's true that, for the non-structural non-welding 16 area, ther e wer e Y's. tha t -- there were non-notable 17 categorizations made without calculations?
18 A
(WITNES S THORS ELL)
Again, those were documented 19 engineering judgments that may be of a narrative nature 20 ra ther than a numerical nature.
21 Q
All right, sir.
22 Can you tell me, Mr. Thorsell, in how many 23 instances discrepancies in the non-structural h
24 non-welding area were evaluated as insignificant without Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14408 1
an engineering calculation?
2 A
(WITNESS TEIORSELL)
No, sir, I can' t.
I would have to 3
go back and check.
4 Q-All right, sir.
5 Well, let's look at one.
6 I've handed you a document that you were kind 7
enough to make available to me in preparation, and 8
counsel made copies.
I appreciate it.
It's an 9
observation for Cable 130 Observation 02.
10 (Indica ting. )
m 11 Now, apparently it's not the complete 12 observa tion -- oh, maybe it is.
Page 3 of 3 is the 13 second page in the package, Page 1 of 3 follows, Page 2 14 of 3 follows that, and then there's a letter attachment.
15 A
(WI TNESS T110RS ELL)
Yes, sir.
16 Q
Now, sir, I want to turn to Dr. Kaushal's Attachment 4.
17 Now, I'm looking there for Cable Observa tion 130.
I'm 18 trying to determine whether or not this was the subject 19 of any r evision.
20 Do you know whether this item was revised or not, 21 Mr. Thorsell ?
22 A
(WITNESS THORSELL)
The observation -- whether the 23 observa tion was r evised ?
24 0
Whether the da ta on Dr. Kaushal's Attachment 4 for this Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14409 1
particular observation was revised.
2 I've simply mislaid my --
3 A
(WITN ESS THORS ELL)
I don' t have a co py of Dr. Kau sh al's 4.
5 My understanding of the -- well, I don' t know 6
whether this was the subject of a revision or not.
7 MR. GUILD:
Counsel informs me that it 8
apparently was not.
9 I certainly would like to be corrected if I'm 10 referring to unrevised data.
11 BY MR. GUILD:
12 Q
But let me look at the copy that I have; and this 13 par ticular observation -- well, the description is, "All 14 three conductors of cable," et cetera, n um be r, "have a 15 trained radius of three inches inside the high voltage 16 terminal box RC/FC f an," a number, "per drawing numbe r. "
17 The minimum training radius for that number is 12.9 18 inches or for a numbered cable it is 3.2 inches.
19 Now, these are bend radius violations, 20 discrepancies, are they not?
21 A
(WITNESS TilORS ELL)
Yes, sir.
22 Q
All right.
23 Now, are those categorized as pull or term 24 attributes in Dr. Kaushal's Attachment 4 ?
Sonntag Repor ting Service, Ltd.
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r 1,
14410 1
A (WITNESS TUORS ELL)
I don't know how he would have 2
categorized that.
3 Q
Well --
4 A
(WITNESS THORSELL)
I suspect --
5 Q
Yes, sir.
{
6 A
( WITN ESS TH ORS ELL)
If the bend radius violation occurs 7
right before the termination of the cable, I suspect 8
that bend radius was considered a pull categorization by 9
Dr. Kaush al, but --
10 0
Well, sir, we have three entries for Cable 130 in Dr.
11 Kaushal's Attachment 4.
These are Line Items 268, 269 12 and 270.
13 The first two of them are termination inspections 14 by N.
K., and they reflect 18 inspection points in the 15 first case, 3 discrepancy points; 18 inspection points 16 and 0 discrepancy points in the second case; and then a 17 pull inspection with 45 inspection points and 4 18 discrepancy points by J.
T.
R.
19 Now, do you know which discrepancies reflected on 20 Dr. Kaushal's Attachment 4 are the subject of 21 Observations Cable 130-02?
22 A
(WI TN ESS THORS ELL)
No, si r, I do not.
23 J UDG E G ROSSMAN :
Excuse me.
24 Didn' t we have testimony tnat they didn't consider Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
r:
p: -
14411-
.N
-t
~
- 1
.any pull viola tions discrepancies?
2 MR. GUILD:
Mr. Chairman, as I understand it, 3
since. pulling radius, bend radius, is not a recreateable.
4 attribute, it cannot be: inspected in CSR, but if the 5
final training of the cable (n: cable and conductors 6
violated the minimum training radius, -that was an 7
observable ' condition, and that's what's reflected in 8
this observation.
9 JUDGE GROSSMAN:
Well, tha t's ~ my 10 understanding.
'~
11 So no pull radius violations were determined; isn' t 12 that your understanding of what was testified?
1 i
13 MR. GUILD:
I'm somewhat in the ~ dark about 14 exactly how they would categorize this, Mr. Chairman.
15 That's the point of the question, in part.-
.16 A-(WITNESS THORS ELL)
I didn't do the. categoriza tion, and i
17 I'm not aware of which one of these ' relates.
18
. BY MR. GUILD:
19 Q
All right, sir, all right, sir.
20 Let's turn, for a moment, to Mr. Kostal's 2
21 pr in t-out, Intervenors' Exhibit 141, and look, again, at i
22 Cable 130.
4;
-23 A
(WITNESS THORSELL)
Yes, sir.
j,
24 Q
Okay.
t
).
Sonntaq Reporting Service, Ltd.
Geneva, Illinois 60134-(312) 232-0262
4
--14412
.v:
1 For Cable 130, we have~ 4 insignificant 2.
. discrepancies in the CF/PL -- that's. configura' tion.
3
. pull - 'so we have 4 pull ' discrepancy points and '3 4
termination discrepancy points.
5 Do you see that, sir ?
6 A
(WITNESS M10RSELL)
Yes, sir.
7 Q
All'right.
8 For a total of.7 insignificant discrepancies for.-
9 which an-R capacity reduction.value of 1.0 is assigned; 10 correct?
11 A
(WITNESS HIORSELL)
Yes, sir.
G 12-Q And those 7 insignificant pull and term discrepancies 13 are associated with Observations 2, 3 and 4 for this
.14 particular CSR item?
-15 A
(WITNESS HIORSELL)
Yes, sir.
16
-Q ~
And we have Observation 2?
17 A
(WITNESS HIORSELL)
Correct.
i 18 0
All righ t, sir.
L 19 There's a total of 7 discrepancy points notable for 20 that particular CSR item; correct?
-21 A
(WITNESS THORSELL)
Yes, sir.
-22 0
All right, sir.
l.
23 Now, you did not, in fact, calculate an R value for 24--
this particular -- for these particular discrepancies, i
Sonntag Reporting Service, Ltd.
l-Geneva, Illinois 60134 l-(312) 232-0262
14413 1
did you?
2 A
(WITNESS THORSELL)
An R value was determined by 3
engineering judgment.
4 Q
The number that's shown, the 1.0, seems to suggest that 5
it's a numeric product of some calculation.
6 It is not, is it?
7 A
(WITN ESS T110RS ELL)
It is not a product of a numeric 8
calcula tion.
The number 1.0 indicates that there was no 9
reduction in capacity.
10 Q
All right, sir.
1 11 And I take it that in the non-welding 12 non-structural area, simila rly, there would be other 13 numeric expressions of capacity reduction values in Mr.
14 Kostal's tabulation, Intervenors' Exhibit 144, which are 15 also the product of engineering judgment and not numeric 16 calcula tions ?
17 A
(WITNESS TilORSELL)
Yes, sir, there are other values of 18 1 which appear there.
19 Q
All right, sir.
20 And I take it that you simply -- if you didn' t do a 21 calculation, you didn't assign any other value but 17 22 A
(WITNESS TilORSELL)
No, sir, that's not true.
23 If I have no capacity reduction, I assign a value 24 of 1, and there's no need to do a calculation.
Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
m 14414 1
Q W ell, what I mean to say is it also -- the converse of 2
that proposition is also true, and that is, the fact 3
3 that there are no listings of.98 or.95 or.91 or.90 4
for the non-structural non-welding discrepancies, does 5
not suggest that you -- does not suggest that such 1
6 capacity reductions wouldn' t be found if you had 7
performed calculations?
8 A
(WITNESS THORSELL)
No, sir.
9 0
You just didn't do the calculations?
10 A
(WITNESS THORSELL)
If I had a five percent capacity 11 reduction, I would have computed a five percent capacity 4
12 reduction 13 Q
Did you make any calculations, sir?
14 A
(WITNESS THORS ELL)
Of capacity reduction ?
15 Q
For your non-structural non-welding.
16 A
(WITNESS THORS ELL)
Ye s, sir.
17 Q
Did you make any in the cable area?
18 A
(WITNESS THORS ELL)
No, si r.
19 Q
So if there's l's in the cable area, the 1 indicates 20 that you have done an engineering assessment and 21 represented that assessment by the numeric value 1, 22 right, but the absence of values between.90 and 1 does 23 not suggest that there aren' t values.90 to 1; j ust the 24 f act that you didn' t make the calcula tions --
Sonntag Repor ting Service, Ltd.
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14415 1
A (WITNESS THORS ELL)
No, si r.
2 0
-- you simply reached a judgment?
3 A
(WI TN ESS THORS ELL)
It suggests there are no values 4
be tw een.9 and. l.
5 0
I beg your pardon ?
6 A
(WITNESS THORSELL)
It states that there are no values 7
be tween.9 and
.1.
8 Q
All right, sir.
9 But you didn' t make calculations for the assignment 10 of non-welding non-structural ~ insignificant attributes 11 where --
12 A
(WITNESS THORSELL)
I did not make calculations where 13 there was no capacity reduction.
14 Q
or where that capacity reduction f actor was deemed to be 15 insignificant on the basis of engineering judgment?
16 A
(WITNESS THORSELL)
No; where there was no capacity 17 reduction.
18 0
Well, sir, as I read your procedure, your procedure 19 covers both cacec that I have proposed to you, and that 20 is, that the one where you say there is no capacity 21 reduction and also the one where you deem, by 22 engineering j udgment, that that reduction is 23 insignificant but don' t make a calcula tion.
24 A
(WITNESS TIIORSELL)
Which procedure are you referring Sonntaq Repor ting Se rv i ce, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14416 1
to?
2 Q
The procedure that's in evidence I just discussed with 3
Mr. Kostal, and tha t's your --
4
_A (WITNESS 'IHORSELL)
That is a structural procedure used 5
by Mr. Kostal for preparation of structural 6
calcula tions.
7 Q
I stand corrected.
You are absolutely right.
8 Does your procedur e, which I don' t have a co py of, 9
for non-structural non-welding also allow you to assign 10 items to the insignificant category on the basis not of 11 calculations but engineering j udgment?
12 A
(WITNESS TilORS ELL)
I don't have a procedure in the 13 electrical area that corresponds to Mr. Kostal's 14 procedure in the structural area.
15 I would have to review the general proj ect 16 instruction to be able to answer that question 17 accurately.
18 Q
All right, sir.
Tha t's h elpf ul.
19 And I asked you -- again, to give you credit for 20 having been forthright with me when we talked.
{
21 You said that, when you spoke, you didn't have a 22 procedure analogous to Mr. Kostal's.
23 I asked you for one and you said you didn't have 24 one?
Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-026:'.
u
14417 1
A (WITNESS TilORS ELL)
Tha t's true.
2 0
All right, sir.
3 Let's look at this observation, then.
4 MR. GUILD:
Mr. Chairman, I'd ask that this 5
this document be marked as Intervenors 162, please.
6 (The document was thereupon marked 7
Intervenor's Exhibit No. 162 for 8
identification as of October 10, 1986.)
9 BY MR. GUILD:
10 Q
Now, I'm going to ask for some help in understanding, 11 Mr. Thorsell, what the nature of the as-found condition 12 was here.
13 The reference to conductors is for the, I'll call 14 them, wires, the wires that appear within the cable 15 jacket for a larger cable that is bound together binding 16 three conductors?
17 That's a folk engineering description, I 18 understand, 19 A
(WITNESS TH ORSELL)
Would it be easier, Mr. Guild, if I 20 used the exhibit that was previously used and make some 21 ske tches --
22 0
It would be very helpf ul, Mr. Thorsell.
l 23 A
(WITNESS TIl0RS ELL)
-- and try and characterize the 24 nature of this discrepancy, and then you can ask Sonntaq Repor ting Se rvi ce, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14418 1
questions with that background?
2 0
That would be very helpf ul, Mr. Thorsell.
I appreciate 3
i t.
4 A
(WITNESS THORSELL)
What I have attempted to sketch here 5
is the motor termination box that's mounted on the side 6
of the RC/FC f an, and what this is is a -- essentially a 7
sheet metal enclosure, and caming out the back of the 8
sheet metal enclosure f rom the motor itself are what we 9
refer to as pigtails, which are three single-conductor 10 cables for attaching the power cable that supplies power 11 to the motor.
12 The way this connection is made is by putting a 13 compression lug on each of the three pigtails, putting a 14 compression lug on each of the three conductors of the 15 power cable that feeds it, and then making a connection 16 of one of the conductors in the power cable to one of 17 the pigtails, the second power cable conductor to the 18 second pigtail and the third power cable conductor to 19 the third pigtail.
20 (Indi ca ting. )
21 The power conductor in this par ticular case is not 22 unlike this cable.
It's a three-conductor cable with an 23 overall jacket on it.
h 24 (Indi ca ting. )
Sonntag Repor ting Se rvice, Ltd.
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14419 1
Q
. By "this cable, " Mr. Thorsell, just so the record will 2
be clear, you are referring to an earlier. demonstrative 3
exhibit, the one that looks like a trident mounted on a 4
board?
5 A
( WITN ESS TH ORS ELL)
Yes, sir.
6 Q
Tha t was th e -- I believe it's the 5,000-volt cable --
7 A
(WITNESS THORSELL)
Yes.
8 Q
-- power cable ?
9 A
( WITN ESS THORS ELL)
Correct.
10 visually this power cable that is the subject of 11 this discrepancy appears very similar to this.
12 The dif ference is that this is a larger cable.
13 Each of the conductors is larger.
14 0
Which is the larger cable, si r --
15 A
(WITNESS THORSELL)
The --
16 0
-- th e su bj e ct of th e dis cr e pan cy ?
17 A
(WITNESS THORSELL) 2he subj ect of the discrepancy is a 18 larger cable.
19 And this cable is a 600-volt cable rather than a 20 5,000-volt cable.
Okay.
21 (Indi ca ting. )
22 0
By "this cable," you mean to say the cable, the subject 23 of the discrepancy, is a 600-volt?
24 A
(WITN ESS THORS ELL)
Correct.
Sonntaq R epor ting Service, Ltd.
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b 14420 t
1 Now, in the description of the observation, ther e 2
are two minimum training radiuses referred to.
3 The first training radius, of 12.9 inches, is the 4
minimum training radius of the total cable, which would 5
be the fat part of this exhibit.
6 (Indi ca ting. )
7 Okay.
The second training radius that's listed is 8
a training radius for a single conductor cable of the 9
same conductor size as the cable that is the subject of 10 the discrepancy.
11 Q
Can you translate the cable size that's the subject of 12 the discrepancy, Mr. Thorsell, into a gauge number ?
13 A
( WITN ESS TH ORSELL)
This is a 500 MCM cable.
14 JUDGE GROSSMAN:
You don' t use AWG 15 designations for that?
16 A
(WITN ESS THORS ELL)
No.
It's larger than AWG.
17 5,000-MCM refers to --
18 BY MR. GUILD:
19 Q
500?
20 A
(WITN ESS THORS ELL)
Or 500 MCM refers to 500,000 21 circular mill cross section of the conductor.
22 Q
What's the diameter expressed in inches of cable itself, 23 the discrepancy cable ?
24 A
(WITNESS TUORSELL)
Okay.
The cable itself has an Sonntag Reporting Se rv i ce, Ltd.
G e nev a, Illinois 60134 (312) 232-0262
14421 1
outside -- or the individual conductor of the cable that 2
is the subj ect of _ this observation has an outside 3
diameter of 1.072 inches.
4 Q
You are referring to -- you are deriving that number 5
f r om th e ev al ua tion por tion of th e doc umen t ?
6 A
(WITNESS THORSELL)
Yes, sir.
7 Q
Now, that is a measured value or is that a specified 8
value, if you know ?
9 A
(WITNESS THORSELL)
That is data provided by the cable 10 man uf actur e r.
11 Q
All right, sir.
12 Now, what's the outside diameter of the entire 13 cable itself with the jacket, if you know?
14 A
(WITNESS THORSELL)
I don' t have that inf ormation.
15 I would expect it to be on the order of 2-1/2 --
16 between 2-1/2 and 3 inches.
17 Q
All right, sir.
18 What's the piece of equipment that's the subj ect of 19 this discrepancy?
What is an RC/FC fan?
20 A
(WITNESS TBORSELL)
That is a reactor containment f an 21 cooler.
22 0
What safety-related f uaction does that f an perf orm?
23 A
(WI TN ESS THORS ELL)
It's part of the cooling system for 24 the containment structure.
Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14422 1
Q All right, sir.
2 Now, where were the measurements of the training 3
radius violations made, if you know?
4 A
(WITNESS THORSELL)
Okay.
I've drawn this sketch with 5
the conductors disconnected.
6 The way the connection is made, the conductor of 7
the power cable comes up, the pigtail comes up, and 8
there is a bolting of the lugs in a back-to-back 9
configuration, and the violation of bend radius is the 10-bending of the conductor of the power cable as it's
~
11 turned up to make this back-to-back bolted connection, 12 and that radius is measured as the -- as the inside 13 radius of this bend.
14 (Indi ca ting. )
15 Q
All right, sir.
16 Now, this particular power cable was terminated to 17 the pigtails from the fan motor in the observed 18 condition?
19 A
(WI TN ESS THORS ELL)
Yes, si r.
20 Q
All right.
21 Do the lugs simply -- are they simply supported by 22 the weight of the pigtail and the power cable conductor 23 inside the equipment?
24 A
(WITNESS THORS ELL)
Yes, si r.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262 g
14423 1
Q They are not mounted to any sort of structural member or 2
terminal block?
3 A
(WITNESS THORSELL)
No, sir.
This type of connection is 4
used for motors, so that any motor vibration is 5
accounted for, and it provides isolation f rom any 6
structure so that you don't create any wear as a result 7
of the motor vibration.
8 Q
All right, si r.
9 I take it there is some taping or sealing of the 10 lugs af ter they are bolted together?
11 A
(WITNESS THORSELL)
Yes, sir.
12 0
And they were found in that condition ?
13 A
(WITN ESS TH ORSELL)
Yes, sir.
14 Q
All righ t, si r.
15 Now, then, the measurement of the training radius 16 made by the CSR inspector and determined to be 17 discrepant was the training radius specified as an 10 inspection attribute in the CSR inspection checklist?
19 A
(WITNESS THORSELL)
Yes, sir.
20 Q
Was the training radius specified by Sargent & Lundy in 21 a component-specific design specification?
22 A
(WI TN ESS THORS ELL)
The training radiuses are shown on 23 an electrical installation drawing f or each cable type.
h24 There is a tabulation of the characteristics of that Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14424 1
cable, which include minimum pulling radius, minimum 2
training radius, maximum pulling tension, factors that 3
are used in equations that are also provided for 4
calculating maximum pulling tension as well as other 5
cable information.
6 Q
All right, sir.
7 Was that training radius acceptance criterion the 8
same as was applicable to the L.
K.
Comstock pull or 9
termination inspection for that connection, for that 10 cable ?
}
11-A (WITNESS 'HIORSELL)
Yes, sir.
x 12 Q
It was.
All right, si r.
13 Now, looking again a t the --
14 MR. GUILD:
Mr. Chairman, perhaps counsel 15 would agree that we should treat this illustration 16 simila rly and --
17 MR. STEPTOE:
Ye s, Bob.
18 Could we have that one marked as Applicant's 19 Exhibit 147 and the previous one as Applicant's Exhibit 20 146, and we'll treat them in the same way as we were 21 doing.
That is, we will accept the obligation of 22 providing manageable copies.
23 JUDG E GROSSMAN:
That's fine.
24 MR. GUILD:
I'm sorry.
Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134
[
(312) 232-0262
i 14425 1
146 was what?
2 MR. STEPTOE:
Mr. Kostal's sketch.
3 MR. GUILD:
Of th e --
4 J UDG E COLE:
That's the weld.
5 MR. GUILD:
Of the weld.
6 MR. STEPTOE:
Of the weld.
7 JUDGE COLE:
The as built and as-designed 8
exampl e.
9 MR. STEPTOE:
Bob, before we leave this, 10 there's something I just don't understand about the 11 drawing.
12 What is holding the lugs up in the air there?
13 A
(WI TNESS THORS ELL)
Just the cable.
The way this --
14 this is --
15 MR. STEPTOE:
I don' t get the representation.
16 I mean, I would think gravity would make the lugs 17 fall down the way you've got it drawn.
18 JUDGE GROSSMAN :
Tha t's hard to do with 19 one-inch conductors.
20 A
(WITNESS THORS ELL)
Yes.
If you come and feel the 21 stiffness --
22 MR. STEPTOE:
Okay.
23 A
(WITNESS TH ORS ELL)
-- of the example here, and consider 24 the cable being larger than this example shown on the Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134
]
(312) 232-0262
14426 1
board, the cable is relatively stif f.
It will not f all 2
down.
f 3
MR. STEPTOE:
Thank you.
4 I'm sorry for the interruption.
5 JUDG E GROSSMAN:
Those are a little more than 6
one inch thick conductors?
7 A
(WITNESS THORSELL)
Right.
8 BY MR. GUILD:
9 Q
All right, sir.
10 Now, if you would return to the document marked m
11 intervenors' 162, on Page 2 of 3 of the observation
\\
/
12 record, there appears an evaluation by the Task Force; a 13 determina tion tha t this, indeed, was a valid 14 discrepancy; correct?
15 A
(WITNESS THORS ELL)
Yes, sir.
16 Q
Now, the statement reads, " Cable IVP004 violates the 17 minimum training radius at Equipment IVP0" -- maybe 18 that's l?
19 A
(WITNESS THORS ELL)
OlCA.
20 Q
A, thank you.
21 "This observation is valid.
Note that the 22 violation applies to the individual conductors without 23 the overall jacket."
24 Now, I take it tha t tha t was -- tha t's an Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14427 1
appropriate interpretation that minimum training radius 2
does apply, indeed, to the conductors as well as to the 3
overall cable ?
4 A
(WITNESS THORSELL)
Almost right.
5 Q
Why don' t you clarify it.
6 A
( WITN ESS TH ORSELL)
It does apply to the individual 7
conductors.
8 Violation of minimum training radius to the overall
(
9 cable isn't applicable in this situation because the 10 overall cable isn' t bent.
11 0
Yes.
12 There is no training radius violation for the 13 overall cable here ?
14 A
(WITNESS MiORSELL)
Correct.
15 0
But there are training radius requirements that are 16 applicable to the overall cable that aren't called into 17 question by this observation; correct?
18 A
(WITNESS MIORSELL)
Yes, sir.
19 0
.And in this case, the training radius specifica tions are 20 appropriately applied to the individual conductors 21 within the cablei 22 A
(WITNESS THORSELL)
Yes, sir.
23 0
Understood.
24 Now, I take it that Eargent & Lundy has no quarrel Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
1 14428 1
with the validity determination made by the BCAP Task 2
Force for this observation?
3 A
(WITN ESS THORS ELL)
No, si r.
4 Q
All right.
5 Now, the preceding page, then, Page 2 -- two pages 6
pr e ce ding, the second page of the document, Par t 4, this
'7 is Sargent & Lundy's evaluation of the discrepancy, and 8
you prepared this evaluation?
9 A
(WITNESS THORSELL)
Yes, sir.
10 Q
All righ t, sir.
11 Does Box 24 indicate your concurrence that this is, 12 indeed, a valid observa tion?
13 A
(WITNESS.THORSELL)
Box 24 indicates that the 14 evaluation -- that the discrepancy was determined to be 15 valid by BCAP.
16 Q
All righ t, sir.
17 I mean, I take it you checked Box 24?
18 A
(WITN ESS THORS ELL)
Right; but Box 24 merely repeats 19 what's in Box 17, 20 Q
All righ t.
21 Does that reflect any further evaluation of the 22 question of validity by Sargent & Lundy ?
23 A
(WITNESS THORSELL)
In this case, no.
24 0
Well, how would we know if it did or not?
Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134
]
(312) 232-0262
14429 1
If you checked Box -- if you check the valid box, 2
does that always indicate that you are simply 3
transferring the data from the BCAP's determina tion, or 4
in some cases, does that indicate that you made an-5 independent evaluation and concurred in their 6
conclusion?
7 A
( WITN ESS TB ORSELL)
In the very initial stages of the 8
BCAP program, the checking of valid or invalid in Box 24 9
waa a Sargent & Lundy recommenda tion.f or validity or 10 invalidity to the BCAP CSR engineers.
11 That process was revised, and the checking of these 12 boxes for validity or invalidity in Section 24 merely 13 represented an indication of what was in Box 17.
14 Q
W ell --
~
15 A
( WITN ESS TBORSELL)
There was -- theke was no -- there 16 was no evaluation of validity or invalidity indicated by 17 the X in this box.
18 Q
All righ t, sir.
19 Well, you completed that Box 24 and signed the 20 preparation Box 27 June 17, 1985.
21 That wasn' t the early days of BCAP program, was it?
22 A
(WI TN ESS THORS ELL)
No, si r.
23 0
It had been going for a year?
24 A
(WITNESS THORS ELL)
But what I said was, in the early Sonntaq Repor tino Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
v 14430 1
day s, the checking of valid and invalid represented a 2
r ecommenda tion.
3 Sargent & Lundy stopped making that recommendation 4
as a result of a finding that was made by the NRC, and 5
some conf usion over who was validating and invalidating 6
observations, and subsequent to that, the checking of 7
the box merely was a repetition of what had been 8
determined by BCAP.
9 Q
Well, sir, I'm af raid -- I thought I had this clear, but 10 I'm afraid this raises some further question on this j
11 point.
12 I understood that, at the point where this matter 13 was clarified, they simply changed, by r evision, th e 14 BCAP observation form and deleted the box Sargent &
15 Lundy made any designation whatsoever of validity?
16 A
(WITNESS THORSELL)
This is an old form.
17 Q
l see.
18 So you just happened to use an old revision of the 19 form?
20 A
(WITNESS THORSELL)
Old form, new process.
21 Q
So your check of the box was essentially a 22 meaningless --
23 A
(WI TNESS THORS ELL)
Yes.
24 0
-- step?
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
I 14431
]
1 I understand.
All right, sir.
2 Now, are those your words that appear in the 3
evaluation portion?
4 A
(WITNESS THORSELL)
Yes, they are.
5 0
All right, sir.
6 There is no visible wrinkling of the jackets and no 7
apparent physical distor tion.
8 Now, I take it that's your conclusion?
9 A
(WI TN ESS THORS ELL)
Yes, si r.
10 Q
Well, I don' t see any observation of the condition of I
i 11 the jacket whatsoever made by the CSR inspector in this L) 12 doc um ent.
13 A
(WITNESS TBORSELL)
That's true.
14 Q
I take it that you went out and looked at the cable in 15 question?
16 A
(WITNESS THORSELL)
That's correct.
17 Q
You didn't ask the CSR inspector to go out and inspect 18 the condition of the cable and report on whether or not 19 there was visible wrinkling of the jacket or a physical 20 distortion of the conductor?
21 A
(WITN ESS THORS ELL)
No, si r.
22 Q
The conductor OD is 1.072.
23 Now, I take it that the CSR inspector didn't derive
,s.
/
N i
24 that measurement of the conductor diameter?
N,_ /
Sonntaq Reporting Se rvi ce, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14432 1
A (WI TNESS THORS ELL)
As I stated before, tha t 's 2
information that was provided by the manuf acturer in the 3
manufacturer's data.
4 Q
All righ t, sir.
5 J UDG E G ROSSMAN :
That was not the observed 6
condi tion, I understand, Mr. Guild.
That was the 7
specification for the cable -- for the conductor in the 8
ca bl e.
9 MR. GUILD:
Understood.
10 BY MR. GUILD:
11 Q
Let's look at the observation description, though.
~
12 There are values that are stated for the training 13 radius, minimum training radius specifications.
14 The first value, I.take it, is for the cable as a 15 whole, and that's the 12.9 inches?
16 A
(WITNESS THORS ELL)
That is correct.
17 Q
And the 3.2 inches is stated as the specification for 18 minimum training radius with respect to 01506 cable?
19 A
(WITNESS THORSELL)
Yes, sir.
20 0
Wha t is 015 06 ?
21 A
(WITNESS THORSELL)
That is a single-conductor ~ 5 00-MCM 22 cable.
23 Q
All right, sir.
h 24 That is a specific reference to the conductor of Sonntaq Repor ting Se rvi ce, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14433 l
1 the diameter that was the subject of this discrepancy?
2 A
(WITNESS TH ORSELL)
No, sir.
3 The construction of a multi-conductor cable 4
consists of insulation and j acket over the copper 5
conductor for each of the conductors, and then on the 6
overall jacket over the entire assembly of conductors 7
for the cable.
8 In the case of a single-conductor cable, the jacket 9
over the insulation is thicker than the jacket over the 10 insulation of the individual conductors of a g
11 multi-conductor cable.
12 In other words, if I have a three-conductor cable 13 and I take off the outer jacket, the individual 14 single-conductor cables that are lef t are smaller in 15 diameter than h single-conductor cable of the same size 16 that was purchased as a single-conductor cable.
17 (In dica ting. )
18 The reason for that-is that the jacket is there to 19 provide physical protection of the cable.
The jacket is 20 a much tougher, more resilient material than the cable 21 ins ula tion.
22 In the case of a multi-conductor cable, the bulk of 23 the protection is being provided by the overall jacket, g
24 so the j acket on the individual conductors is made f
Sonntaq Repor ting Se rvi ce, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14434 1
thinner.
In the case of a single-conductor cable, tha t 2
outer j acket is thicker.
3 (Indi ca ting. )
4 Q
All right, sir.
5 So you --
6 A
(WITNESS THORSELL)
So tne number of 3.2 inches written 7
up in this observation does not apply to the cable in 8
question.
9 (In di ca ting. )
10 Q
So it's not a valid observation?
11 A
(WITNESS THORS ELL)
No.
'~
12 The observation indicates that the training radius 13 was violated; and what the inspector used for com'parison 14 purposes to make that determination was the allowable 15 training radius of a single-conductor cable, which is 16 greater than the allowable training radius of the 17 individual conductors.
18 In other words, if he had passed this test --
19 Q
But it was not an appropriate test?
It was not a valid 20 observation, Mr. Thorsell; is that your position?
21 A
(WITN ESS THORS ELL)
No, sir.
22 0
Well, the inspector used the wrong specification.
23 1sn't that a basis for determining an observation h
24 invalid in the first place?
The inspector still Sonntaq Repor ting Se rv i ce, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14435 1
identified a bending radius violation?
2 A
(WITNESS THORSELL)
No.
It truly was a violation of 3
criteria that he had available to him.
4 Q
Yes, but he used the wrong criteria.
5 Tha t's what your testimony is, isn't it?-
6 A
(WITNESS THORSELL)
It's the only criteria he had.
7 JUDGE GROSSMAN:
Excuse me, Mr. Thorsell.
8 You lost me somewhere.
9 I don't believe you explained why the cable jacket 10 is thicker on a single-conductor cable than on a 11 multiple-conductor cable.
~ ~ ~J 12 Your explanation amounted to why a cable j acket is 13
. thicker than insulation, but not why the cable jacket on 14 a single-conductor cable is thicker than the cable 15 jacket on a multiple-conductor cable.
16 A
(WITNESS TBORSELL)
Okay.
I'm sorry if I -- if I wasn' t 17 clear on tha t, Judge Grossman.
18 The thickness of the j acket and the thickness of 19 the insulation are totally independent of one another.
20 The thickness of the insulation is determined by 21 the voltage ra ting of the cable.
In other words, if I 22 have a cable that I need to apply higher voltages to, I 23 will need thicker insulation in order to apply that at a h
24 higher voltage.
Sonntaq R epor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14436
.~
i
. J l
The thickness of the cable jacket is based on 2
primarily the size of the cable and the material that 3
the jacket is made of.
4 In the case of a multi-conductor cable -- first of 5
all, bear in mind that the jacket is there to provide 6
physical protection of the insulation, if you will.
7 In a multi-conductor cable, that physical 8
protection is provided by an overall j acket, and --
9 JUDGE GROSSMAN:
Yes, I understand that.
You 10 don' t have to --
l 11 A
(WITN ESS THORS ELL)
Okay.
12 And in addition to the protection afforded by that 13 overall jacket, there is a' jacket on each one of the 14 individual conductors, al so'.
15 JUDGE GROSSMAN:
Okay.
16 A
(WITNESS KOSTAL)
Okay.
17 If I go to a single-conductor cable, where it's all 18 by itself, it has no extra overall j acket, the jacket on 19 that single-conductor cable is the only protection for 20-the insulation; and that has to be thicker than the 21 jacket that appears on each of the individual conductors 22 in a multi-conductor cable.
23 JUDGE GROSSMAN:
Okay.
Tha t's fine.
,. 3
/
N
(
).
24 A
(WITN ESS TH ORSELL)
And it's the thickness of the x_/
Sonntag Reporting Se rvice, Ltd.
Geneva, Illinoi's x 60134 (312) 232-026R
14437 1
insulation and the jacket that limit the bending radius 2
of the cable.
3 (Indica ting. )
4 BY MR. GUILD:
5 Q
In this case, the observed condition observed by the CSR 6
inspector was with respect to a conductor?
7 A
(WITNESS THORSELL)
Right.
8 Q
The conductor had no jacket; the conductor had 9
insulation?
10 A
(WITNESS THORSELL)
No, the conductor had a j acket.
11 Q
It didn't have a jacket that was to protect the j
~
12 insulator -- protect the conductor during the course of 13, cable pulling -- it didn't have a < jacket as thick as the 14 jacket on the overall cable?
15 A
(WI TNESS THORS ELL)
Correct.
16 Q
All right, sir.
17 So you took into account the fact that the -- of 18 the actual diameter of the conductor when you made your 19 evalua tion of the discrepancy ?
20 A
(WI TN ESS THORS ELL)
Yes, si r.
21 Q
When the CSR inspector used a reference diameter for the 22 size of the individual conductor with reference to a 23 single-conductor cable, it would have had a thicker 24 jacket?
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14438 1
A (WITNESS THORSELL)
Yes, si r.
2 Q
Therefo're, you took the advantage of a less stringent 3
requirement for minimum bend radius or minimum training 4
radius, since you considered only the actual diameter of 5
the conductor?
P 6
A (WITNESS THORSELL)
I took advantage of knowledge of 7
what the actual diameter of the conductor was.
8 0
Well, who specified the acceptance criteria for the CSR 9
inspector to utilize, apparently in error ?
10 That was to presume that the conductor was, in T
11 fact, a single-conductor cable where there would have V _,)
been a greater diameter jacket.
12
~
13 A
(WITN ESS THORS ELL)
W ell, the acceptance criteria was s
~
14 specified by the BCAP engineers.
15 The acceptance criteria appears on the Sargent &
16 Lundy design documents.
It's common practice for both 17 the CSR engineers -- or both the CSR inspectors as well 18 as Comstock inspectors, when a multi-conductor cable has
~
19 the overall jacket stripped away, to utilize the 20 tabulated allowable training radius for a 21 single-conductor cable of the same size.
22 Since that's a conservative approach and since it 23 eliminates the need for putting a lot of extra
(
)
24 information on the drawings, that rarely ge ts used.
q,-
Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14439 i
x-
-l 1
That's been an accepted practice.
2 Q
All right, sir.
3 What was the diameter of tho -- for a 01506 cable, 4
pres uming it was a single-conductor cable ?
5 A
(WITNESS THORSELL)
I'm sorry.
I don't remember that 6
n umbe r.
7 Q
The reference standard, in.effect, that the CSR 8
inspector used to measure -- to determine the training 9
radius acceptance criteria?
10 A
(WITN ESS THORS ELL)
I do not know.
/
i 11 Q
We do know it was greater than the value that you 12 measured -- or that you employed, on the basis of the 13-manuf acturer's submission, for the conductor diameter?
14 A
(WITNESS THORS EL L')
Yes, si r.
15 0
All right, sir.
16 Now, your conclusion is -- excuse me.
If I can get 17 back to it.
18 JUDG E GROSSMAN:
Excuse me.
19 I believe the inspector wrote up the specification 20 here as requiring a 3.2-inch training radius?
21 A
(WITNESS THORS ELL)
Right.
22 JUDG E GROSSMAN:
I thought that was the 23 question.
7-I
)
24 A
(WITNESS THORSELL)
The question was what the diameter Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 l
(312) 232-0262
14440 i
1 of the cable was, the diameter of a single conductor 2
500-MCM 600-volt cable, which is the --
3 BY MR. GUILD:
4 Q
The reference diameter?
5 A
(WITNESS TUORS ELL)
-- which is the cable that is 6
designated by the type code 01506.
7 MR. GUILD:
Mr. Chairman, the reference 8
diameter that the CSR inspector used, that apparently 9
has a fixed relationship on which is derived the minimum 10 training radius of 3.2 inches.
(
)
11 JUDGE GROSSMAN:
Now, by the way, just to x,/
12 make sure that the record is clear and that my 13.
understanding of it is-' clear, you are saying now that 14 there was no j acket -- there was the insulation jacket, 15 but no other jacket on these three conductors, and that 16 the radius that the CSR' inspector referred to was one 17 that was required for a conductor that had not only 18 insulation, but a j acket on it; not -an outer j acke t, but 19 an inner jacket.
20 Is that correct, now ?
21 A
(WI TNESS TUORS ELL)
Right.
That's -- the conductor will 22 always have -- in the case of this type of cable, the 23 conductor will always have a -- an inner jacket, if you
,r.
l
)
24 want to call it that, or a j acket around each of the 1R.j Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
r 14441 1
individual conductors as well as the insulation.
2 (Indica ting. )
3 JUDGE GROSSMAN:
Right.
4 But in this case, was the jacket still on?
5 A
(WITNESS THORS ELL)
Oh, s ur e, ye.
The jacket is never 6
taken off.
7 The only -- the only time that the -- that a 8
jacket, cable jacket, is ever removed is when you take 9
off an overall outer jacket at the point that the cable 10 terminates.
11 (Indica ting. )
v 12 Okay.
The other minor clarification for that is 13 that -- let me go to the example.
14 This portion -- I'm referring to the penciled 15 portion -- this portion of the j acket is removed at the 16 termination just to make a nice connection.
17 (Indica ting. )
~18 But this -- this jacket on the individual conductor 19 is never removed f rom the -- from the --
20 JUDGE COLE:
That's what you referred to as 21 the inner j acket?
'22 A
(WITNESS THORS ELL)
Yes.
23 J UDG E G ROSSMAN :
So there is an inner jacket 24 on both a multiple-conductor cable and a Sonntaq Repor tinq Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
- f~ v
- 1 0
- (, /
I single-conductor. ca ble ?
2 A' -
(WITNESS THORSELL)
For a single-conductor cable, 3
this -- this jacket -- this inner jacket is the only 4.
jacket.
There's j ust one j acket.
5
- Perhaps -- would you like.me to --
f' 6'
JUDG E GROSSMAN:
.There's no other jacket for-7 the -cable as a whole?
- 8 A
(WITNESS THORSELL)
Correct, there'.only one j acket.
~
9 Would you like me to draw a cross section of the 10 cable?
-> s
/
' ' ll MR. ' GUILD:
Mr. Chairman, I think you'd 11 2 better, because there's a misstatement in your-13 description of the condition that was found, -at least,as
~
~
14 I. heard Mr. Thorsell's first explanation.
15 Perhaps we could ask him to illustrate..the two
~
[
16 condition s.
17-
.J UD3 E G ROSSMAN :
Oh, yes,-there was a I
misst'tement, because -I stated that the inner jacket was 18 a
i
[
.19 '
not there, and, of course, he's stating that it is l
'20 there.
l 21.
Is that what you understood to be the misstatement?
l 22 MR. GUILD:
.One par t, Judge.
- [~T-J 2 3 '-
I'm afraid there's also a different thickness in
)
24 the jacket if it's a single conductor, as opposed to if l (G l
- i. -
Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
.=.
-..~
14443 1
it's one conductor of a three-conductor power cable, as 2
I understand Mr. Thorsell's statement.
3 A
(WITN ESS THORS ELL)
Tha t's true.
4 Okay.
Any conductor, whether it's part of a
-5' multi-conductor cable or is just a single-conductor 6
cable of this type, will have a core that is the copper 7
conductor.
This is stranded copper.
8 Around that core there will be an insulation.
In 9
this case, it's an ethylene-propylene rubber ins ula tion, 10 and around the insulation is a protective jacket.
11 In this case, the jacket is made of Hypalon, which 12 is an industry term that refers to -- I believe it's 13 chlorosulfonated polyethylene.
14 In the case of a multi-conduct 6r cable, 15 single-conductor cables are combined, and there is an 16 overall protective j acket.
This overall j acket is made 17 of the same material as this jacket.
It's a Hypalon 18 jacket in this case.
19 (In dica ting. )
20 BY MR. GUILD:
21 Q
Now, you are comparing "this" and "this. "
22 Both jackets --
23 A
(WITNESS THORSELL)
In the case of the cable that is the 24 subject of the discrepancy.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134
(
(312) 232-0262
~.
14444 l
1 Other cables may use dif ferent materials f or 2
insulation or j acketing.
3 Q
To be clea r, the first -- this is a depiction of one of 4
those three conductors.
5 It has a Hypalon jacket, as does the cable as a 6
whole?
7 A
(WITNESS TH ORS ELL)
Yes, sir.
8 Q
All righ t.
l 9
A (WITNESS TBORSELL)
Now, the thickness of the jacket on 10 an individual conductor of a multi-conductor cable is 11 not necessarily the same as the thickness of the jacket 12 of a single-conductor cable, even though the cable is 13 the same siz e, the voltage rating is the same, the 14 materials are the same, the insulation thickness i's the 15 same.
16 Thus, the minimum bending radius or training radius 17 for this conductor may not be the same as this 18 individual cable.
19 (In dica ting. )
20 It will -- it will never be, or this j acket will 21 not be thinner -
"this jacket," again, refers to the 22 single-conductor cable j acket -- will not be thinner 23 than the jacket on an individual conductor of a 24 multi-conductor cable of the same size.
Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134 j
(312) 232-0262
s 14445 7--;q
- (
)
=x_/
l-JUDGE GROSSMAN:
You are saying it won't be.
2 thinner?.
- 3 A
(WITNESS THORSELL)
Right.
4 JUDG E GROSSMAN:
I thought you were also 5
saying it. is thicker.
6-A (WITNESS TBORSELL)
In general, it's thicker.
7 In order to do my evaluation, what I ~did was get 8
the actual diameter, outside diameter, of this cable and 9
then go to the manuf acturer and determine whether --
10 what the. allowable bending radius-for that cable was.
[
(Indica ting.)
' V}
11:
12 Okay.
This -- the-information regarding the 13 bending radius of this individual conductor is not -data 14 that I normally' acqui-re f rom the manuf acturer, which' is 15 why there's a letter attached to the -- to - the 16 --
evaluation where that ' data was provided separately from 17-the data that exists in my design documents.
18 J UDG E CALLIH AN :
I-have a question, please.
19 JUDGE GROSSMAN:
Go ahead.
20' J UDG E CALLIH AN :
I 'have a question.
21l Mr. Thorsell, just in passing and --
22 A
(WITNESS THORSELL)
Yes, sir.
23 JUDGE CALLIH AN:
-- probably irr elevant, does
~)
(
24 the spacing of the three conductors in the cable under Sonntaq Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
?
14446 c
- ls f.
J L
1-discussion' demand more insulation'in the three-conductor
,2
, arrangement than the ~ thickness of the insulation in a
-3 single-conductor cable ?.
4 A
- (WITNESS THORSELL)
No, sir.
.5.
JUDGE CALLIH AN:
Thank you.
6 J UDG E G ROSSMAN : -
Oh, yes.
'7 MR. GUILD:
Mr. Chairman,.if.I could ask, 8
following the pract' ice: to date, that that sketch be 9
' reproduced in. an exhibit-size document. 148. is my next Applicant's number.
[~'\\
.11' MR.-STEPTOE:-
That's fine, Judge Grossman.
1
- Q)
-12 Applicant'sl148 will be' reproduced.
13' HBY -MR. GUILD : -
14_
Q Now, sir, Mr. Thorsell, again, if you turn to your r
15 evaluation of this discrepant condition, what is the
-16 relationship between cable diameter and minimum training
.17 radius that was applied by the CSR inspector in his l18 inspection of this observation?
{
19 A
(WITNESS THORS ELL)
I can't speak for what the -- what j.
20 the inspector did, but I believe that he would not -have
.21 taken into account diameter at all.
22 Q
Well, I take it that's a given, since he was given'a 23 specified ' reference cable --
l g_s
'. (t
(
24.
A.
(WITNESS THORSELL)
Correct.
[
Sonntag Reporting Service, Ltd.
i Geneva, Illinois 60134 l
(312) 232-0262
14447 1
0
-- diameter, which, by Sargent & Lundy specification, 2
was associated with a specific minimum training --
3 minimum training radius requirement?
4 A
(WITNESS MIORSELL)
He was given a specific minimum 5
training radius for the cable construction that he was 6
looking at.
7 Q
All righ t, sir.
8 And what was the relationship between the cable 9
diameter for that reference cable and the minimum 10 training radius specification that Sargent & Aundy 11 pr o'vided ?
\\
12 A
(WITNESS HIORSELL)
Oh, I' d have to calculate that out.
13 I don't know.
~14 Q
Can you do that, sir?
15 A
(WITNESS THORS ELL)
I don' t have all the data.
16 Q
What data do you require?
17 A
(WITN ESS THORS ELL)
I need to know the specified minimum 18 training radius as well as the OD, outside diameter, of 19 the cable.
20 Q
All right, sir.
21 Well, we have some of that data.
We have the 22 minimum training radius r equirement of 3.2 inches tha t's 23 specified in a description of the observation.
24 A
(WITN ESS THORS ELL)
Yes ; but I do not have the diameter Sonntaq Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262 g
14448
. y k
1
. of the cable that corresponds to the 3.2-inch minimum
-2 training radius.
3 Q
All right, sir.
4
. How can you obtain.that data?
~
S' A
(WITNESS THORSELL)
I would have to review Drawing 6.
7 MR. GUILD:'
Mr. Chairman, I would ask that 8-tha t -inf orma tion' be supplied.
9
_ Obviously, not now;. but if that is.a piece of data 10 that can be retrieved from that document, I ask that it.
11 be supplied by Applicant.
12' JUDGE GROSSMAN:
Any objection to that, Mr.
13.
Steptoe?
14 MR. STEPTOE:
No, Judge Grossman.
15 JUDGE GROSSMAN:
While we're on this, why 16' does there appear to be a -conflict between the 17 specifications' referred to by the CSR -inspector and the 18-specifications that the manuf acturer apparently _ had of
,i 19 four?
20 MR. GUILD:
The next question, Judge.
21 A
(WITNESS THORS ELL)
Oh, okay.
i' 22-JUDG E GROSSMAN:
It seems to me that using 23 the four times outside diameter -- and I assume the N
%). 24 outside diameter referred to by the manuf acturer is the i
Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262 4
~-
14449 1
conductor, including jacket outside diameter -- that the 2
specification ought to be somewhere in the neighborhood 3
of 4-1/4 inches or 4.2 inches rather than 3.2.
4 A
(WITNESS THORSELL)
I -- I can explain that, if you 5
would like.
6 J UDG E G ROSSMAN :
Sure.
7 A
(WI TN ESS THORS ELL)
Okay.
8 Commonly, with cable, the information that is 9
provided by the cable manuf acturer is referred to as 10 minimum bending radius, and the minimum bending radius 11 is generally expressed as a multiplier of the outside 12 diameter of the cable, such as four times the outside 13 diameter, five times the outside diameter, six times the outside diameter of' the cable.
14 15 That minimum bending radius is applicable under all 16 conditions to which the cable may be subj ected.
f 17 In other words, if I am pulling a cable through a 18 conduit during installation, I am not allowed to violate 19 that minimum bending radius as I pull it around the bend 20 of a conduit.
21 Now, under those conditions, I am subj ecting the 22 insula ting material to forces that result from pulling 23 the cable.
In other words, in addition to pulling the 24 cable, bending the cable, there is what's referred to as Sonntaq R epor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
'14450 g4
.(
):
y 1 ;-
side wall pressure on the insulation.
2 That pinching, if you will, of the insulation can 3
cause. a breakdown or deterioration of the dielectric
.4 strength of the insulation and thereby affect the 5
performance of the cable.
6 In this letter, where he -- the cable manuf acturer 7
is referring to "four times outside diameter," he's.
8 referring to a minimum bending radius.
l 9
Now, when it goes on to say that we give -- we've 10 given some' relief on -this to three or two-and-a-half
[V
'{ - 11 times the outside diameter, in general what they are 12 referring to is conditions where-you are 'not subjecting 13 the cable to additional outside force's.
It's commonl,y
.14 referred to as a minimum training radius.
15~
In other words, if I'm just bending the cable, I can bend 'it to a smaller radius than if I am bending the i
16 17 cable and applying. pressure resulting from pulling the 18-cable through conduit, for example. -
l -.
19 (Indica ting. )
20 So in this particular case, we're referring to a
- 21 training of the cable at the cable termination, we're 22-not subjecting the cable to other forces of pulling; and the cable manuf acturer in that. instance allows 2.5 times
' O )
23
(
24 the outside diameter of the cable, provided that -- and Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14451 1
his extra requirement is that that doesn't result in any 2
wrinkling of the jacket or distortion of the shape of 3
the cable that would indicate that there is some extra 4
force being applied to the insulation.
5 (Indi ca ting. )
6-JUDG E GROSSMAN:
So the short of your answer 7
is his four times outside diameter recommendation, with 8
regard to the manuf acturer's recommendation, was with 9
regard to pull radius and that here it was a training 10 radius?
11 Even though the observer f rom the company knew that 12 you were discussing training radius, he just didn't 13 mention that here?
14 A
(WITN ESS THORS ELL)
Correct.
15 Now, this letter -- this cable was not only 16 observed by me.
It was also observed by a 17 representative of the Okonite Company, a representative 18 from their engineering staf f.
19 JUDG E GROSSMAN:
Right.
Mr. Bartolucci?
20 A
(WITNESS THORS ELL)
Correct; and he observed this along 21 with several other cables.
22 In the case of I'll say at least one of the cables 23 that he observed, there was wrinkling of the -- of the 24 outer jacket or distortion of the cable.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14452 l
1 So in this letter, which is providing a criteria 2
that we can apply for acceptance, he's making the 3
distinction that in those cases where there is no 4
wrinkling, this criteria can be used.
If there is 5
wrinkling, you can' t -- you can't use this criteria.
6 (Indi ca ting. )
7 MR. GUILD:
Mr. Chairman, may I proceed ?
8 JUDG E GROSSMAN:
Certainly.
9 MR. GUILD:
I would request that Applicant 10 provide, first, an identification of the instances in 11 which Mr. Bartolucci or the Okonite representative --
4 12 strike that -- instances in which wrinkling or 13 distortion of the cable were identified in the CSR 14 sample items, Mr. Chairman.
^
15 In addition, there appears, for completeness, to be 16 a letter that prompted the Okonite response with 17 attachments.
18 So that we can understand what exactly the Okonite 19 response is referring to, I would also ask that 20 Applicant provide a copy of the letter with attachments 21 that was apparently sent by J.
J. B oj a n, B-O-J-A-N, May 22 13,
'85.
23 J UDG E G ROSSMAN :
Any problem with that, Mr.
24 Steptoe?
i Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262 L
14453 1
MR. STEPTOE:
I don' t think so, no.
2 No, Judge, no problem.
3 BY MR. GUILD:
4 0
All right, sir.
5 Now, your evaluation of this discrepancy -- your 6
evaluation is that this discrepant condition was not 7
design significant; correct?
8 A
(WITNESS THORSELL)
Correct.
9 Q
And that evaluation is based on the letter f rom the 10 manufacturer, the Okonite Company; correct?
11 A
(WITNESS THORSELL)
Yes, sir.
12 Q
All right.
Let's turn to that letter from the Okonite 13 Company,. the last pa ragraph:
14 "We canno t, in the absence of data or experience, 15 render a j udgment as to whether the observations on the 16 bending radii.made in the Analysis Program are design 17 significant."
18 A
(WITNESS THORS ELL)
Correct.
19 0
Well, did you provide the Okonite Company with the data 20 on the basis of which they made a subsequent rendition 21 of an opinion as to the design significance of the 22 bending radii discrepancies?
23 A
(WITNESS THORSELL)
What the Okonite Company --
24 Q
If you would just answer that question directly, sir, Sonntaq Repor ting Service, Ltd.
Geneva, Illin ois 60134 (312) 232-0262
==
14454 r
j1~
k, /1
'1:
a'nd. then please feel free to explain.
2:
.A (WITNESS DIORSELL)
- No,' si r..
-- 3 0
All right, sir.
~4-
.A (WITNESS - HIORSELL)
The statement in here does not refer 5-to data that we would provide the Okonite Company.
6-It refers to data that the Okonite Company would -
-7 assemble on 'their own regarding bending radius less than-
'8
' 2.5 times the outside diameter of the cable.
i 9
Q.
Th'ey don' t. s ay tha t, do ' th ey ?
10 That's not what the letter says.
You have the 'same letter' before you as I do.
It simply says that they
().11 12-lack the data or experience to render a judgment about 13 the bending radii observations that were made~ in BCAP
'14 for design' significance.
15-It makes no caveat that that 'is with reference to 16 any particular relationship between the diameter' of the
~17 cable and the observed condition.
18 A
(WITNESS MIORSELL)
As I stated earlier, there was-more 19 than:one bending radius problem or' violation observed by 20-
'the Okonite Company.
21 I believe that Mr. Bojan's letter asks for an 22 assessment in general of the sum total of the F
23 information that was provided to the Okonite Company of p {[
4 s-24 design. significance, t
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262 w.
14455 l
1 In general, the Okonite Company declined to make 2
that assessment, based on a lack of testing and 3
performance data available, for violations of bending 4
radius that were less than 2.5 times the outside 5
diameter.
6 Q
Excuse me, sir.
Just --
7 A
The preceding paragraph --
8 Q
Excuse me, sir.
Let me interrupt for clarity.
9 When you say "less than," do you mean radii less 10 than or less severe violations?
11 A
(WITNESS THORS ELL)
Radii less than 2.5 times the
~~
12 di ame ter.
13 0
I apologize for interrupting.
Please continue with your 14 answer.
15 A
(WITN ESS TH ORSELL)
The previous paragraph states the 16 conditions which the Okonite Company finds acceptable.
17 All right.
Those conditions are the conditions 18 that' exist for the cable that's the subject of this 19 observation.
20 My conclusion of no design significance is based on 21 the f act that the cable manuf acturer said that this is 22 an acceptable condition.
23 Q
I see.
24 J UDG E G ROSSMAN :
Excuse me, Mr. Th or sell.
Sonntaq Reporting Se rvi ce, Ltd.
Geneva, Illinois 60134 (312) 232-0262
a 14456 N~J s
~1 Are <you. rea' ding tha t last paragraph as 'the J2 fmanuf acture'r saying that a bending radius 'of 2.5 times a
3-the outside diameter is acceptable? -
11 A-
- (WITN ESS ' THORSELL)
No,-sir.
5_
The way I read this 'is that the Okonite. company'.is 6
declining to make an assessment of design significance 7-on violations of bend radius and also stating that if 8
you meet their bend radius recommendations, it will:not 9
affect the ability of the cable to perform its function 10 over-its. expected life.
- f,~ ;
11 If I go to the preceding paragraph, they ~ say
,,g 12 that -- under the conditions where there is no wrinkling
~
13 or apparent physical distortion in cables that they 14 observed installed in the plant, Mr. Bartolucci says.
15 that -- and there's not a violation of 2.5 times the 16 OD -- that that is acceptable.
17 JUDGE GROSSMAN.
Mr. Thorsell, le t's j ust 18 stay with that last paragraph first.
I believe you lef t 19' out the word " published" when you restated that.
20 Now, they are standing by.their four times OD 21 recommenda tion in that last paragraph,. aren' t they, and-22 saying.that things that -- radii that meet that four 23.
times OD are acceptable; isn't that correct?
5 24 A
(WITNESS THORSELL)
Correct.
j Sonntag Reporting Se rvice, Ltd.
Geneva, Illinois 60134 s{[
(312) 232-0262
1 14457 1
JUDGE GROSSMAN:
And now in the penultimate 2
paragraph, the one preceding that, they are commenting 3
on the particular cases that they reviewed, that Mr.
4 Bartolucci review ed --
5 A
(WITN ESS THORS ELL)
Yes, si r.
I 6
JUDG E GROSSMAN:
-- in which the bending 7
radii were 2.5 times OD or larger; isn't that so?
8 A
(WITNESS THORSELL)
It is a common practice with the 9
Okonite Company that they will not uniformly change 10 their criteria, whether it be a bending radius criteria 11 or a cable pulling tension criteria.
12 How ev e r, they --
13 J UDG E G ROSSMAN :
Mr. Thorsell, bef ore you go 14 further, I take it your answer was yes and you are 15 giving the explanation now ?
16 A
(WITUESS THORSELL)
I believe so, if I had the question 17 right.
18 Would you like to restate the question and then 19 I'll answer it directly --
20 J UDG E G ROSSMAN :
Yes.
21 A
(WITN ESS THORS ELL)
-- and then explain it?
22 J UDG E G ROSSMAN :
Well, the question was:
23 They were accepting only the specific cases 24 reviewed by Mr. Bartolucci in which the bending radii i
Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14458 j
1 were 2.5 or greater times the outside diameter; is that 2
so?
3 A
Correct, correct, correct.
4 JUDGE GROSSMAN:
Okay.
5 A
(WITNESS THORSELL)
But the general process is that they 6
have published criteria.
If you meet the published 7
criteria, it's acceptable.
8 If you do not meet the published criteria, if you 9
have a violation of that published criteria, and go back 10 to the Okonite Company on a case-by-case basis, you find-
,m
(
'g 11 that their actual criteria is substantially lower.
C/
12 There's a substantial margin in their published 13-criteria.
How ev e r, they will not give leave to utilize
. 14 that margin by anybody other than themselves, 15 essenti ally.
16 They require that you go back on a case-by-case 17 basis and, in the particular circumstance where you have
~
18 violated their criteria, 20 vid them inf ormation.
If 19 they have enough informat son m'- ed cn1 th e 20 correspondence, they may give you approval.
21 In this particular case, they wanted to make sure 22 that they had all of the data they needed, so they sent 23 out their cable engineer to actually assess the cables i
x
(
)
24 in the field to provide approval of that.
Sonntaq Repor ting Service, Ltd.
G eneva, Illinois 60134 (312) 232-0262
14459 1
(In dica ting. )
2 JUDG E GROSSMAN:
Thank you.
3 Mr. G uild.
4 BY MR. GUILD:
5 0
All right, sir.
6 Okonite starts out by saying in the second 7
para gr a ph, "The Okonite Company has no data, nor are we 8
aware of any data, or service experience where cables 9
have been shown to be unaf fected by being installed with 10 bending radii as small as listed in Appendix A of Mr.
11 B oj an's letter. "
12 Now, I take it Appendix A of Mr. Boj an's letter 13 listed the observed minimum bending radii discrepancies 14 in the CSR inspections?
15 A
(WITN ESS THORS ELL)
Yes, sir.
16 Q
All righ t, sir.
17 Well, I take it, also, you accept that they use the 18 word "unaf fected" and tha t's not an error, is it?
19 "Unaf fected" means they simply are -- that's a 20 correct typographical treatment of what the company 21 intended to communica te, as f ar as you know?
That's a 22 negative there, " unaffected"?
23 A
(WITN ESS TH ORSELL)
Maybe I can make this a little 24 sim pli e.r.
Sonntag Reporting Service, Ltd.
Geneva, Illin oi s 60134 (312) 232-0262
14460 1
Q No.
How about just answering that question?
2 That was not an error using -that word " unaffected,"
3 was it?
4 A
(WITNESS THORSELL)
No, sir.
5 Q
All right.
6
~Now, did -- af ter the time -- did you receive 7
another letter from Okonite that makes a calculation 8
with respect to. the observed minimum radii?
9 A
(WITNESS THGRS ELL)
No, sir.
10 0
This is it; this letter is it?
j
)
11 A
(WITNESS THORSELL)
This is it.
~
12 Q
All right, sir.
13 Is there any suggestion that Okonite has since 14' performed the calculations or since acquired the data or 15 experience that they didn' t have at the time of their 16 June 5,
'85, letter?
17 A
(WITNESS THORSELL)
No, sir.
18 Q
I don't see it.
Am I missing some pages here?
19 Did you, Mr. Thorsell, or Sargent & Lundy acquire 20' the data, evaluate the experience and make the 21 calculations that the Okonite Company did not make with 22 respect to these cable discrepancies?
23 A
(WITNESS THORSELL)
No, sir.
7
/
x
(
)
24 Could I clarify this for you?
Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
~-
14461 1
The statement in the Okonite letter that refers to 2
no data or service experience to be able to, I'll say, 3
accept bending radii as small as contained in Mr.
-4 Bojan's letter refers to bending radii that were less 5
than 2.5 times the outside diameter of the cable.
6 The particular observation that we are dealing with 7
here is one in which the cable manufacturer provided us 8
with a letter establishing a criterion that allowed us 9
to accept this bending radius violation.
10 There were other bending radius violations for 11 which the manuf acturer did not provide us acceptance, if s
12 you will, 13 In those instances, what was done was the cable was 14 tested and subjected to the same acceptance criteria as 15 a new cable for a 500-volt DC insulation resistance 16 test, and that test was used to determine whether there 17 was any degradation of the cable or whether the cable 18 would still meet its design requirements.
19 In each case, those tests indicated that there was 20 about a 50-percent margin over the manuf acturer's 21 requirements for performance of the insulation, and 22 those cables were deemed to be acceptable.
23 0
All right, sir.
24 MR. GUILD:
Mr. Chairman, could I ask that Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14462 1
Applicant make available whatever data Mr. Thorsell 2
relies upon for that last response, please.
3 MR. STEPTOE:
Sure.
Of course, we have no 4
problem doing that.
5 BY MR. GUILD:
6 Q
Are there any Okonite letters?
7 A
(WITN ESS THORS ELL)
No, si r.
8 Q
So there's no letter that said, "We won't accept these 9
case s" ?
10 There's just the letter that says, "We will accept 11 this case," as you characterize this Okonite letter ?
12 A
(WITNESS THORSELL)
There were a handf ul -- I don' t 13 remember the exact number -- of bending radius 14 violations identified by BCAP inspectors.
15 To assess those bending radius violations, th e 16 cable manuf acturer was contacted.
The cable 17 manuf acturer came out and examined those and, based on a 18 visual examination only, was able to accept some and 19 unable to adopt a position on others.
20 The ones for which the cable manuf acturer was 21 unable to adopt a position on, those cuoles were 22 subj ected to tests to determine whether the bending 23 radius viola tion had, indeed, affected the cable.
24 The result of the test indicated that it had not.
Sonntag Repor ting Se rv i ce, Ltd.
Geneva, Illinois 60134 (312) 232-0262
r 1
14463 1
Q All right, sir.
2 Well, you are telling me a little more than I asked 3
for and less than I asked for.
4 A
(WITNESS THORSELL)
I'm trying to make it simpler for 5
yo u --
6 Q
I'm sorry.
7 A
(WITNESS THORS ELL)
I'm sorry.
8 0
If you would respond to the question, that would be 9
h elpf ul.
10 What I wanted to know precisely was:
(
11 Is there a letter from the manuf acturer declining 12 to accept any of the cable discrepancies found in BCAP?
13 I still didn't get an answer to that question.
14 A
(WITN ESS THORS ELL)
This is.the only letter.
15 Q
All righ t, sir.
16 There is no other letter?
17 A
There is no other letter.
18 Q
Is there any other documentation reflecting the refusal 19 by the manuf acturer to vouch for, to pass off on, to buy 20 off, other BCAP discrepancies?
21 A
(WI TN ESS THORS ELL)
No, si r.
22 Q
Did you document it in any way ?
23 A
(WITN ESS THORS ELL)
Document what?
24 Q
The f act that the manuf acturer went out and said, "I'm Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14464 1
looking at this discrepancy, and I cannot take a 2
position on it.
I will not vouch for that.
I will not 3
buy off that discrepancy," words to that effect?
4 A
(WITNESS THORSELL)
No.
I believe.those words appear in 5
this letter.
6 Q
This is it; this is the only documentation?
7 A
(WI TNESS THORS ELL)
This is it, this is it.
8 Q
If I look at another observation, it will not say the 9
manufacturer's rep looked at this condition in the field 10 and declined to vouch for the lack of design 11 significance of this discrepancy?
12 A
(WITNESS THORSELL)
No, sir.
13 Q
Did you tabulate those instances?
Did you write them 14 down anywhere?
15 A
(WITN ESS THORS ELL)
No, si r, no, sir.
16 Q
How many are there?
17 A
(WITNESS THORS ELL)
A handf ul.
18 0
- Well, I' ve go t five fingers, 19 Are there more than five?
20 A
(WITNESS THORSELL)
I don' t know whether the number is 21 four or five or six.
22 Q
Does anybody know, sir?
23 A
(WI TN ESS THORS ELL)
I'd have to go back to the data.
24 The number is less than.10.
Sonntag Reporting Se rv i ce, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14465
- 7%
i
't N_/
1-Q
' All. righ t.
'2 What is'the data-source you are going-to have to go-3
.back to ?.
It's not the observation form?
4 A
The observation --
5 0
The observation will show itself whether or not the 6
manuf acturer-_ vouched.for the significance or 1ack 1
7 thereof of the condition?
8 A-(WITNESS THORSELL)
No, sir.
9 Q
So.how are you. going to find out, sir?
10 A
(WITNESS THORSELL)
Is your question which ones the
/
\\
11 manufacturer did not vouch for --
)
12
-Q Yes.
13 A
-- or which ones violating the bending radius.that I did 14 a test on? Q The question is_ which BCAP cable discrepancies the 16 manufacturer observed in the field!and declined to vouch 17 for.
18 A
(WITNESS TBORSELL)
I believe those would be contained 19 in Attachment a to Mr. Bojan's letter.
20 Q
All right, sir.
I'll await that with interest.
.21 Is it indicated which ones on that attachment were i
22 observed and the manuf acturer declined to vouch for,
-23 sir?
- D\\
(
24 A
(WITNESS THORSELL)
No, sir.
\\_ /-
Sonntaq Repor tina Se rvice, Ltd.
j Geneva, Illinois 60134 (312) 232-0262
W 14466 fy i
1 q,)
1
-Q lit's among a class 'of discrepancies listed on that 2
attachment?
3-A (WITNESS. THORS ELL)
Yes, sir.
4 Q-How are we going to identify which ones?
5
.A
- (WI TN ESS THORS ELL)
It would be the bending ' radius 6
violations that are -- or would be the observations for 7
which the bending radius was less. than 2.5 times the OD.
8
-Q You state that based on.your personal knowledge?
9 A
(WITNESS THORS ELL) - Yes, sir.
10 JUDG E GROSSMAN:
Excuse me.
[ h ll The implication I get from that is that V.
12 notwithstanding that Mr. Bartolucci only approved 13 certain -instances-that he observed, you took that as a 14 blanket authorization to approve every single one of 15 those instances in which the' bending radius was 2.5 or 16' greater times the outside diameter?
17' A
(WITNESS THORSELL)
No, si r.
18_
JUDG E GROSSMAN:
W ell, in which instances did L
19 you not approve that?
4 20 A
(WITNESS THORSELL)
This letter approving a 2.5 times 21 outside diameter minimum bending radius violation was 22 only used -for those cables which had greater than 2.5 23 times the outside diameter bending radius and were h
L(
j 24 observed by Mr. Bartolucci.
s Sonntag Repor ting Service, Ltd.
G enev a, Illinois 60134 (312) 232-0262
\\
14467
]
1 Indeed, I believe that this is the only observation 2
for which this letter was used.
3 (In di ca ting. )
4 JUDG E GROSSMAN:
Well, now, where is the list 5
of the ones that Mr. Bartolucci did not observe?
6 There is no list of the bending radii violations --
7 that is, less than the manuf acturer's recommendation, 8
but 2.5 or greater times the outside diameter -- which 9
Mr. Bartolucci did not observe?
10 A
(WITNESS THORSELL)
Those violations don't exist.
Th ere i
11 are no such discrepancies.
12 JUDG E GROSSMAN:
He observed all of the 13 in stan ce s, you are telling me, in which the bending 14 radii were 2.5 or greater times the outside diameter?
15 Is that what you are saying?
16 A
(WITN ESS TH ORSELL)
No.
17 He observed those bending radius violations --
18 let's see.
I'm trying to phrase this precisely.
19 There may have been bending radius violations which 20 exceeded 2.5 times the outside diameter but also 21 exceeded other bending radius criteria which were 22 available to us to perform an evaluation.
Okay.
23 There's only a narrow band of bend radius 24 violations which Mr. Bartolucci observed for which -- I Sonntaq Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14468 1
believe this is the only -- this is only observa tion 2
for which his observation -- hia rip provided us 3
the acceptance of that particular diset t.pancy.
4 J UDG E G ROSSMAN :
Okay.
5 This is the only instance, then, that you relied on 6
Mr. Bartolucci --
7 A
(WI TN ESS THORS ELL)
Correct.
8 J UDG E G ROSSMAN :
-- on his observance?
9 A
- (W I TNESS THORS ELL)
Correct.
10 He also looked at others with smaller bending 11 radiuses, for which he could not provide an opinion 12 without test data.
13 JUDGE GROSSMAN:
Okay.
14 A
(WITNESS TH ORSELL)
We did the test data --
15 JUDGE GROSSMAN:
Okay.
Now --
16 A
(WITNESS THORSELL)
-- and evalua ted the test da ta.
17 JUDGE GROSSMAN:
But you also mentioned other 18 bending radii violations in which the radii were 2.5 or 19 greater times the outside diameter and which you 20 approved, appa ren tly.
21 Is that so?
22 A
(WITNESS HIORS ELL)
I'm not sure that there were others 23 in that category.
I'd have to review the observations 24 to find out.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262 l
14469 1
But if there were others that were greater than 2.5 2
and we approved, our approval would have been based on a 3
published acceptance criteria.
Jn other words -- let me 4
give you a hypothetical case.
5 The hypothetical case would be an installation 6
cimilar to the one documented in this observation, where 7
the inspector had identified a violation of the 8
12.9-inch criteria, and we accepted it based on bending 9
radius criteria for an individual conductor, for 10 e xampl e.
11 J UDG E G ROSSMAN :
Well, that doesn' t seem to 12 be related to this kind of violation that we're talking 13 a bo ut.
14 A
(WITNESS HIORSELL)
Right.
15 JUDGE GRCCSMAN:
So you are saying that there 16 just did not exist instances, such as the one that Mr.
17 Dartolucci observed, which had bending radii of 2.5 or 18 greater times the outside diameter, which you approved 19 on the basis of his approving in this particular 20 instance ?
21 A
(WITNESS THORSELL)
Correct.
22 J UDG E G ROSSMAN :
Okay.
23 And now you are telling us that --
h 24 A
(WITNESS M10RSELL)
To tMe best of my knowledge, this Sonntag Repor ting Se rvice, Ltd.
G enev a, Illinois 60134 (312) 232-0262
14470 1
is the only case in which Mr. Bartolucci or the Okonite 2
Company's-letter was used.
3 (Indica ting. )
4 J UDG E GROSSMAN:
Okay.
5 And now you are saying that your testing, voltage 6
testing, was, in all cases in which there -was a less 7
than 2.5 --
8 A
(WITNESS THORSELL)
Correct -- or there was wrinkling of 9
the jacket or distortion of the cable.
10 (Indi ca ting. )
11 Ther e's a -- ther e's a three-part test.
12 J UDG E G ROSSMAN :
Okay, fine.
33 In some of those cases, the diameter was between 14 2.5 and whatever the publisher's recommendation was --
15 the published recommend was?
16 A
(WITNESS THORSELL)
Right.
17 MR. GUILD:
Mr. Chairman, I'd ask that 18 Intervenors' Exhibit 162 be received in evidence.
19 JUDG E GROSSMAN:
Any objection ?
20 MR. STEPTOE:
No obj ection, Judge Grossman.
21 JUDGE GROSSMAN:
Mr. Ber ry ?
22 MR. DERRY:
No obj ection f rom the Staf f, Mr.
23 Chairman.
24 J UDG E G ROSSMAN :
Received.
Sonntag Repor ting Se rvice, Ltd.
G eneva, Illinois 60134 (312) 232-0262
14471 1
(The document was thereupon received into 2
evidence as Intervenors' Exhibit No.
3 162.)
4 J UDG E G ROSSMAN :
I think it's time to 5
adjourn, Mr. G uild.
6 MR. GUILD:
Yes, sir.
7 JUDGE GROSSMAN:
So why don' t we --
8 MR. STEPTOE:
We'll pick up the admission of 9
these exhibits at a subsequent time --
10 J UDG E G ROSSMAN :
That's fine.
}
11 MR. STEPTOE:
-- af ter we set them 12 reproduced.
13 JUDG E GROSSMAN:
All right.
14 We'll adjourn now until Wednesday of next week at 15 9:00 o' clock.
16 (WHEREUPON, the hearing of the 17 above-entitled matter was continued to 18 October 15, 1986, at the hour of 9:00 19 o' cloc k A.
M.)
20 21 22 23 h
24 Sonntag Repor ting Service, Ltd.
Geneva, Illinoia 60134 (312) 232-0262
t NO PAGE NUMBER CERTIFICATE OF OFFICIAL REPORTER 9
This :is to certify that the attached proceedings before the UNITED ST TES NUCLEAR REGULATORY COMMISSION in the matter of:
- NAME OF PROCEEDING:
Braidwood Station Units 1 6 2 DOCKET NO.:
50-456/457-OL PLACE:
Chicago, Illinois DATE:
Friday, October 10, 1986 were held as herein appears, and that this is the originai transcript thdreof for the file of the United States Nuclear Regulatory Commission.
(sigt)
-l.
(TYPED) Gary L. Sonntag Official Reporter Reporter's Affiliation O
m