ML20237L369
| ML20237L369 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/25/1986 |
| From: | Barnes I NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20237F760 | List:
|
| References | |
| NUDOCS 8708200193 | |
| Download: ML20237L369 (84) | |
Text
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1 UNITED STATES NUCLEAR REGULATORY COMMISSION IN THE MATTER OF:
DOCKET NO:
i INVESTIGATIVE INTERVIEW I
l 1
1 j
l LOCATION:
ARLINGTON, TEXAS PAGES:
1-75 j
1 DATE:
FRIDAY, JULY 25, 1986 l
ace-FEDERAL REPORTERS, INC.
offealFo x m 444 North CapitolStreet Washington, D.C. 20001 (202) 347-3W g e20g g g}8$
Attachment J 5
NADONWIDE C G
fw
1 SWORN STATEMENT of IAN BARNES July 25, 1986 NRC Region IV Headquarters Arlington, Texas L
10:40 a.m., C.D.T.
i l
TAKEN BY:
George Mulley REPORTED BY:
Trish Sims r
S t
h
__..m._.______
2-1 MORNING SESSION 2
July 25, 1986 3
j 4
Thereupon, 3
'S IAN BARNES, 6
took the. stand an'd, having been first duly. cautioned 7
and sworn, testified upon'his oath as follows:
8 9
EXAMINATI.ON 10 BY MR. MULLEY:
.i 11 0.
The time is 10:40 a.m.
on July the 2 5 th,.
12 1986.
We're at the Region IV headqua'rters NRC in i
13 Arlington, Texas.
l 14 Present is Mr. Ian Barness a Region IV.
l'5 employee, myself George Mulley, assistant director 16 from investigation office of Investigating Auditor 17 of NRC, Steve Goldberg who is a' technical advisor.
18 detailed to the office of Inspecting Auditor NRC, j
i 19 and the court reporter Trish Sims.
20 We're here'today to discuss with
- i t
21 Mr. Barnes his involvement with several inspections 22 done by Region IV Comanche Peak Nuclear Power' Plant.
L 23 and to obtain some information from Mr. Barnes 24 concerning Region IV's regulation of the Com e.n ch e 25 Peak proj ect.
TATE REPORTING SERVICE Houston, Texe:
(713) -222-71'77
.)
A
. 3' 1
Before we begin, can you give us a brief 2
resume of your background here at Region IV?
3 A.
I joined the NRC in Region IV on November 4
the 3rd, 1975.
I was hired as a contracter 5
inspector in the vendor inspection branch as it was 6
called in those days.
7 From the time period that I joined the NRC
[
8 up till July, 1980, I performed primarily 9
inspections per the Manual Chapter 2700 program of 10 various and assorted c o n t r a 'c t e r s, primarily in the 11 arenas of fabrication of piping subassemblies, 12 vessel manufacture, valve manufacture, pump 13 manufacture, various diverse mechanical components.
14 In July of 1980, I was made section chief 15 of what was called Component Section II.
Actually 16 it was the section I was inspectering.
17 In early
'81, I inherited the other 18 component section.
They integrated bcth sections 19 under my supervision.
At that time period, I had l
20 about eleven or twelve inspectors assigned to me as 21 section chief.
l 22 That kind of staffing remained until, I 23 believe, probably late
'83.
I'm not quite sure.
In 24 the time period that I was a section chief in the t.
25 vendor branch, the work load and various j
TATE REPORTING SERVICE Houston, Texas (713) 222-7177
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1 manufacturing facilities were starting to decline j
2 because of the absence of new orders.
3 We started to change the thrust
'f the o
4 program in terms of my personal responsibilities
't o 5
what we called reactive inspection.
The thrust of l
6 this was to look at notifications to the Commission 7
per 30.55(e) or Part 21 and to respond to j
8 allegations if they came up involving contractors 1
9 and to try and assess why did these things happen, 1
10 make sure that al.1 potentially affected utilities 1
11 had been appropriately informed.
j 12 So, we were reacting to a stimulus, a known
)
13 deficient conditions and we were-utilizing that 14 trying to assess from a quality assurance and 15 technical aspect what was the scenario and what were 16 the contributing factors.
I 17 In June of
'84, the vender program branch 18 was transferred to the office of Inspection and 19 Enforcement; and I did not want to move to 20 Washington for personal reas,ons.
21 I was offered a position in the region as a 22 r'e a ct o r l'n s p e c t o r, which I accepted.
My assignment 23 in the region since that time period, I went to Wolf 24 Creek on completion of the program inspection 25 efforts there.
I performed after that inspections TATE REPORTING SERVICE Houston, Texas (713) 222-7177
a
~'S 1
at River Bend and completion;of the construction-2 program there, primarily in the arena of the 3
construction appraisal' team, f oll'ow up and j ust some i
4' of the IE program. modules.
1 I
5 Additio'nally, I was assigned the primary 6
responsibility for inspecting the activity at Cooper J
7 Station relative to' recirculation piping 8
replacement.
9 In June,
'85, I was informed that I had 10 been assigned to the Region-IV Comanche. Peak group 11 which was currently being performed.
I was told I
12 that I would act as a group leader.
That is an i
13 unofficial position.
It is not defined anywhere.
14 One would have to ask management why they i
15 assigned me that function, but I believe it was l
16 primarily because they knew my performance in the l
17 vendor branch and reactor inspection and that I was i
18 used to dealing with nulti-disciplined personnel and 19 it was per.ceived that I had done a very credible 20 job.
21 I remained in that position at Comanche 22 Peak till, I guess it was, May when they announced 23 that they selected me as the Comanche Peak group i
24 chief.
It was not actually in process until L.
25 sometime in June.
That's where I am now.
i TATE REPORTING SERVICE l,
Houston, Texas.
(713).222-7177 l
l
l 6
1 0.
So, from June of '85 until currently, 2
you've had some or a lot of involvement with-3 Comanche Peak?
4 A.
I have been at Comanche Peak virtually 5
every week since sometime in July of
'85.
6 Q.
What I'd like to do, then, is to go over 7
several recent inspection reports that were donc at 8
Comanche Peak in which there's been some differences 9
between the inspector and what he felt s h o ul d be in 10 the inspection reports, how his inspection findings I
11 should be documented versus Region IV management's 12 opinion as to how his inspection findings should be i
13 documented and ask if you can recall some of these j
l 14 issues and ask if you have any i nv olv er.e n t or any 15 knowledge concerning how these issues were resolved.
16 I'd like to have Steve go through them one 17 at a timer and we can go from there, understanding 18 that 1
19 A.
If I may say something before Steve and 20 yourself start, I had no knowledge of what questions 21 for sure you would be asking me.
22 I want it on the record'that I'm speaking 23 purely from re coll ection.
I have had no opportunity 24 to do any kind of research to try and refresh my
(..
25 memory.
TATE REPORTING SERVICE Houston, Texas (713) 222.7177
7 l
I 1
J 1
Q.
That's understood.
l l
2 Q.
(By Mr. Goldberg)
That's understood.
The l
3 first inspection report that we're going to focus on 4
is 85-07-05.
The period of inspection that was done
]
5 by Mr. Phillips is during the period April 1st, l
i 5
1985, through June 21, 1985.
7 I'm going td go down the issues.
As I
)
I 8
understand in discussion -- we've had discussions 9
over the last few weeks.
10 The first one involves the reactor vessel; l
l 11 and, specifically, we're going to go into two 12 specific issues.
The first one is the instruction i
13 that was written for the installation design i
14 criteria.
I 15 There were some question about the 16 construction operation traveler and changes that 17 were made, if those changes were or were not 18 included in the installation spec, as well as i
19 questions about the the clearance between the 20 reactor vessel support bracket and the support shoes 21 were not within the ranges stated within the 22 instruction operation traveler and~the condition was 23 not reported as a non-conformance report.
24 Are you famili,ar with that issue?
L 25 A.
Not very.
Let me say this on that 1
TATE REPORTING S E RVICE Houston, Texas (713) 222-7177
l 8
1 particular report:
'I was asked by Tom Westerman to 2
review it and'make any technical comments.
I have.
3 I reviewed that report.
4 I. performed what I would call.a limited 5
review.
The reason I did that was I was not a 6
supervisor.
We're talking about a report that was 7
already ~in existence.
j 8
I was a retained Grade 15, and I did not 9
feel very comfortable about reviewing reports that 10 involved other Region IV management inspectors.
l 11 I performed a limited review.
Those
' 12 subjects that stood out clearly to me as being i
13 questionable, I' identified to Tom Westerman.
14 Q.
(By Mr. Mulley)
When did he ask you to 'to j
H l
15 this review?
16 A.
I don't really recall the day, George.
It i
17 was somewhere about the time that we were moving on 18 site.
A group of reports were actually physically handedtomebyf the former division 19 j
20 director here.
That was or e of them.
I don't 21 recall the exact time frame.
22 Q.
When you stay the report was already in 23 existence, you mean that the report had.been signed 24 out and finaled?
L.
25 A.
From memory, I don't think the report was TATE REPORTING SERVICE Houston, Texas
.(713) 222-7177
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1 signed when I saw it.
l 2
Q.
So, it was still in 'raf t form?
3 A.
- Again, Im not too sure.
4 Q.
(By Mr. G ol d be r g)
I'm going to go ahead 5
with the issues.
At this point you don't have 6
anything specific t'o tell us on that particular 7
report?
8 A.
All I'll say about that particular issue, I 9
do remember Tom discussing it with me, I looked at 10 it f'r om a purely' technical prospective,-knowing that 11 the reactor vessel installation is a rather limited 12 activity.
In that particular plant, there are two 13 vessels.
I personally didn't see any need to write
{
14 a formal procedure assuming that all of the NSSS
)
15 guidance had been incorporated in that instruction.
I 16 Q.
Okay.
Let's go to the next one.
It 17 relates to the reactor vessel.
It says there is no 18 evidence that TUGCO had audited either Unit II 19 reactor vessel installation specification, placement 20 procedures, actual hardware placement, or as-built 21 records.
22 The a question here is the scope of the 23 audit program.
What about that one, Mr. Barnes?
24 A.
I don't know of any regulatory requirement 25 that would specifically require a utility to audit a TATE REPORTING SERVICE Houston, Texas (713) 222-7177
1 f
10 1
1 cisc eet activity like that.
2 Q.
Had you had any exposure to the audit plan l
i 3
of TUGCO?
Did you have any opportunity to review 4
their audit plan?
l 5
A.
No, I did not.
t 6
Q.
At this time, do you feel their audit plan 1
i 7
is in compliance?
l 1
'8 A.
If I haven't reviewed the audit plan, I 9
obviously have no opinion.
j i
10 Q.
We understood that you had some input 'into
)
11 the audits themselves?
j i
12 A.
We're talking about a much later time 13 frame.
14 Q.
That's why I'm asking today.
That was the l
15 question, today, as of today.
]
16 A.
You're asking a question?
17 Q.
As of today.
j 18 A.
My involvement regards audits was a later 19 report to,do with a Brown & Root audit of their site 20 activities, Brown & Root audits.
21 Q.
Not TUGCO audits?
22 A.
No.
23 Q.
The next issue involves ASME Section 3,
24 1974 edition, spool piece 3-0-1, drawing number
(.
25 BRP-CS-2-RB-76.
TATF REPORTING SERVICE Houston, Texas (713) 222-7177
11 i
1 This spool piece had neither been marked 2
with the material specifications ingrained nor heat j
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number nor heat code of the material.
The' inspector 4
made the finding i ti June of '85; but in August, the'
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1
'5 applicant found the identification number on the l
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6 spool piece.
The inspector rechecked the spoci 7
piece and found the number.
8 Now, I believe tha't issue was a section of l
9 the inspection report where there's an issue on l
10 spool pieces.
Why don't I let you comment on that.
11 Do you remember that issue at all?
12 A.
I remember it, yes.
I remember informing j
l 13 Mr. Westerman that I thought the inspector was in 14 error.
15 The reason I gave Mr. Westerman that 16 information was based on a large part on my prior 17 inspections of nuclear pipe fabricators which I 18 inspected all of them when I was member of the 19 vendor branch and also my prior working in the 20 industry with the Babcock and Wilcox Company.
21 My knowledge of the code, there was no 22 requirement at that point in time to maintain those 23 specific numbers on a piping assembly.
As I recall, 24 there was a mark number identified on the spool in 25 question.
TATE REPORTING SERVICE Houston, Texas (713) 222-7177
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1 Well,.if one knows anything about the way 2
. piping fabricators and architect engineers do
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3 business, that mark number in itself provides total 4
traceability.
j 5
The mark number is assigned by the l
l l
6 purchacer to t'he fabricator.
There's a code data l
7 report that reflects that mark number.
'There's an 8
inspection sketch that shows the identity of each 9
and every piece.
That subassembly -- prior to 10 shipment, that documentation has been reviewed and I
11 approved by an independent third party.,
i.e.,
the i
12
' authorized nuclear inspector.
l j
13 My reading of the ASME code does not l
l 14 indicate that one hac to, ad nauseum, maintain heat 15 numbers stamped on the item, and that is why I told 16 Mr. Westerman that'I believe the inspector in j
17 question was in error.
18 Q.
According to the earlier draft I just 19 want to revfew this one more time -- it says here in 20 respect to material requiring a C TR, which is 21 certified material test report, "NA-3766 requires' 22 marking with the applicable spec and graded material-23 and heat number or heat code.
When material is 24 divided, identification mark is required to be t
ks 25 transferred to all pieces."
TATE REPORTING SERVICE Houston,-Texas (713) 22.2-7177
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1 A.
I would respond to that by saying you are 2
quoting from a'n ASME code arena that pertains to 3
material manufacturers and material suppliers.
4 We're not talking about material.
We're talking 5
about a piping sub-assembly where the rules that i
6 apply would be the rules of NCA 4000.
l I
7 Q.
So, in your opinion, the traceability c o ul d l
8 be maintained in the plant by simply knowing the 9
spool?
I guess what was left on the spool piece 10 was a marking.
l 11 A.
A mark number.
12 Q.
A mark.
13 A.
In my opinion, traceability was l
14 maintained -- not could be maintained, was.
l i
15 Q.
In other words, if that spool piece is 16 changed out and needs to be reordered, it can be 17 done and the pedigree would be found?
18 A.
There would be no problem.
19 C.
Okay.
Go to the next issue.
This is a 20 long one.
I'm going to read it to you.
I think it 21 requires to be read to you.
Your name keeps coming 22 up as an important source of information on this 23 one.
24 Its called Loop 3 reactor core and (s
l 25 collate.
I'm going to read you the whole thing.
I l
TATE REPORTING SERVICE Houston, Texas (713) 222-7177 i
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1 think it's helpf ul to do that.
It would help in 2
maybe recalling what you did.
)
3
" Requirements for this item are stated that 4
in the ASME Section 3, 1974 edition.through summer l
5 of 1974 addendum --
I I
6 (Discussion off the record.)
7 Q.
This is for the record, exactly.-
I'll give 8
it to you if you want to reread it.
I think it's 9
hard to track when you answer without knowing what 10 the issue is.
l 11 "This piping s uba s s em bly consists of 12 27.5 inch cast pipe with a 22-degree elbow on the 13 reactor end, a 10 inch 45-degree nozzle, a 3 inch 14 nozzle, and three 2 and a half inch thermowell 15 installation bosses.
The following records were 16 reviewed for the subassembly."
17 I'm going to drop down to No.
3.
"The code 18 NPP-1 says that no hydrostatic test has been l
l 19 performed.
In discussions with Westinghouse and I
20 Brown & Root personnel, the statement was made that I
21 it is normal practice to defer the partial hydrotest 22 until whole system is hydrotested.
B&R requirements 23 CP-QAB-12.1 and CP-QAP-12.2 describe requirements 24 for the test."
25 I'm going to drop all the way down.
-I'm TATE REPORTING SERVICE
- Houston, T. exas (713) 222-7177
1'5 :
1 not going to read.everything.
"The above' items are 2
unresolved pending clarification of the code 3
requirements by_ headquarters."
4 That's.the key point.
5 MR. MULLEY:
Why-don't.you let 6
him look at it.
7 (Discussion off the record.)
8 A.
You want me to respond to that?
9 Q.
(By Mr. G ol d be r g )
Yes.
~
10 A.
With regard to what you've just asked me, I 11 again considered the inspector was in error, that he i
12 did not understand the ASME. code.
13 I felt there was no need t6.go to NRC 14 headquarters.
I was conversant with the subj ect.
I 15 believe I understood the code.
It's been 16 subsequently verified that my understanding of the 17 ASME code was correct.
18 I have pulled out'some documents out of the L
19
'74 edition.
I didn't have the time to go research 20 it again, but I can assure you the code in 1974 and 21 the code in 1983 are identical in terms of basic 22 requirements.
The text has dramatically changed 23 over-the years, but they're identical.
24 The inspector I believe -- and this is 25 surmisal I believe that the inspector got TATE' REPORTING SERVICE
, Houston, Texas (713) 222-7177.-
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1 16 l
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somewhat confused about the terminology in the code j
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talking about'the testing of components prior to 3
installation and that since there was no hydrotest j
4 done a piping subassembly, he felt there was some i
5 potential violation of Section 3 of the ASME code.
6 What I believe that he failed to grasp is a 7
pipe subassembly is not a component as defined by 1
8 Section 3 of the ASME code.
A piping system is a l
9 component.
It is a rather unique arena.
This is l
10 the only one I can r e a'dily or the only one I can 11 think of -- never mind readily -- when, in fact, you
{
12 do not have a component, per se, until it is 13 until there's a piping system.
14 In other words, you cannot test the thing 15 as a component until it's built.
The reacon I had 16 this position is this:
From the '74 code, I'm going 17 to hand you some documents.
18 The first document I'm going to ask you to 19 read Section NA-1210, and I think you'll see there 20 that the example of a component includes piping i
21 systems.
22 MR. MULLEY:
I'll read for the 23 record the first sentence of the document.
24 This is from NA-1210, Components, "The 25 components of a nuclear power plant in cl u d e TATE REPORTING SERVICE Houston, Texas
.(713) 222-7177 l
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1 items such as vessels, piping systems, 2
pumps, valves and storage tanks."
3 What I would like to do is mark this 4
document, which page four from NA-ll40, as 5
Exhibit 1.
l 6
(Exhibit No. I was marked for i
7 identification and is attached hereto.)
8 A.
The second document I'm going to hand you 9
is the same code section, NA-1232, entitled " Piping 10 Subassemblies," which defines a subassembly as a l
11 section of a piping system.
12 MR. MULLEY:
For the record, I 1
13
(,~
,ill read Section NA-1232, Piping j
w 14 S uba s s em blie s, " Piping subassemblies are I
l 15 defined as sections of a piping system 16 consisting of fittings and pipes or tubes 1
17 which are fabricated as subassemblies in a l
18 shop or in the field before they are 19 installed in a nuclear power system."
20 I'm going to mark this document as 21 Exhibit 2.
22 (Exhibit No. 2 was marked for 23 identification and ir attached hereto.)
24 A.
The third document I'm going to hand you, I 25 want you to look at two references on the page.
The TATE REPORTING SERVICE
_-__..__ Houston, Texas (713)'222-7177
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first one is Section NB-6111.1, Subparagraph (a).
2 The second reference on that page is Section ND-6114 3
pertaining to time of hydrostatic tests of the 4
parts, piping s uba s s em bl i e s.
l 5
My interpretation of that document shows l
6 that ASME code requires that all pressure bound 7
components be hydrostatically tested.
t 8
Secondly, it states that components serve 9
as tests for piping subassemblies, which to me 10 clearly' indicates recognition by the ASME code that 11 a piping system is the component and the subassembly l
12 is just a section of the component.
\\
j 13 MR. MULLEY:
I'll read for the 14 record Section NB-6111.1, Hydrostatic l
15 Testing, "All components and appurtenances 16 constructed under the rules of this 17 subsection shall be hyrdrostatically tested 18 in the presence of the inspector."
19 In the sectioning NB-6114, "The 20 component or appurtenance' hydrostatic test 21 when conducted in accordance with the 22 requirements of NB-6221(a) shall be 1
23 acceptable as a test'for parts and piping 24 subassemblies."
25 This document I will mark as
\\
TATE REPORTING SERVICE
- Hoy,ston, Texas (713) 222-7177 t_________.
=
i 19 l
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Exhibit 3.
2 (Exhibit No. 3 was marked for 3
identification and is attached hereto.)
i 4
A.
The fourth documents I'm going to' hand I
5 you -- by the way, I should have said earlier what 6
"NB" represents.-
The acronym "NB " denotes a Class I 7
component of Section 3.
It's the most critical 8
component.
I'll go on.
,9 The fourth, document I hand you, there's two
{
10 areas that I would wish people to look at.
Section i
11 NB-6221(a) requires com pl e t e d components to be 12 s ubj e cte d to hydrostatic test at a pressure not less 13 than 1.25 times the system design pressure prior to 14 installation in the system.
15 This is what I believe the' inspector in 16 question was led and said they didn't test, failing 17 to recognize there wasn't a component to test rtior 18 to installation.
19 The second and rather important reference 20 is NB-6221(c) permits the sy s t em hydrostatic tests 21 to be substituted for a component hydrostatic test
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22 c '? provided that certain things can be done, meaning 23 if you do that, you've got to be able to do a repair 24 weld on the system if it proves necessary.
You've
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25 got to be able to do post-weld heat trestment of TATE REPORTING SERVICE
,,, Houston, Texas (713) 222.7177
20 _
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that repair, or whatever, if deemed necessary.
2 You've got.to 'be. a bl e to1non-constructively examine' j
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a'nd also got to. test after 'any repairs.
]
4 MR. MULLEY:
Okay.
For the 5
recordLI will' read Section NB-6221(a)..
L 6
I'.11 read the' highlighted portion, j
7
" Completed _ components shall be subj ect to.a j
8 hydrostatic test at a pressure not l' e s s 9
than 1.25 times t,he system design pressure 10 prior to installation in the sy s t em.'"
11 I'll read (c), "The system hydrostatic 12 test of NB-6221(b) may be substituted:for a
('
13 component hydrostatic test of NB-6221(a),
14 provided."
Underneath is listed the.
I 15 various requirements to have to be complied 16 with.
.I'll mark'this document as 17 Exhibit 4.
18 (Exhibit No.-4 was marked for 19 identification and is attached hereto.)
[
20 A.
I'd like to make one otber comment.
dne of l
21 the things I recall that disturbed me a little bit 22
.at the time was the text was written in a fashion f
l 23 that you could not ascertain why this hydrostatic 24 test was not done, other than to say, " Hey, it's 1
25 r eq uired. "
y TATE REPORTING SERVICE Houston, Texas (713) 222-7177 c
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1 In my judgment, an inspection report should 1
^
2 have referenced the inspector's knowledge of the 3
-procurement document.
The procurement specification 4
itself waived this hydrostatic test requirement on 5
the subassemblies.
That didn't come out.
I 6
I felt that it was inappropriate and should i
I 7
have been referenced that we're not talking about l
l 8
some possible omission of a contractual requirement I
l 9
or code requirement.
It was a cl e a r, up front, "We 1
10 do not require you to test the s ubas sem blie s. "
11 That should have been in there.
1 12 Q.
(By Mr. Goldberg)
I understood, though, 13 notwithstandingLyour point, the issue did go to NRC 14 hea dq ua rt er s.
15 Can you explain what happened then?
16 A.
As best as I can.
I personally did not 17 speak to the inspector in question with regards to 18 Mr. Westerman.
19 At some point after I had given this advice 20 to Mr. Westerman and it became apparent that the 21 inspector was dissatisfied, there was a meeting in 22 this office with the l'nspector,
~
Present 23 were Mr. Eric Johnson,,I believe Mr. Hale, and 24 Mr. Westerman and myself.
25 The inspector did not seem to want to grasp TATE REPORTING SERVICE Houston, Texas
.(713) 222-7177
22 1
what I was trying to tell him.
I forget the exact 2
words that weie said.
I believe that meeting may 3
have been documented in some fashion, but I don't 4
think I ever saw any records of that.
5 During that meeting, I recommended to the 6
group that if anyone had any reason to question my-l 7
knowledge or were not assured of the accuracy of my 8
statements, the appropriate party in my judgment to 9
communicate with wa,a Robert J.
Bosnick, branch chief.
10 of mechanical engineering, branch NRR.
11 The reason I recommended Mr. Bosnick was 12 that I was well conversant that he was NRC's i.
13 representative on the main committee of Section'3l'of 14 the ASME code, and I felt he was the most qualified, l
15 knowledgeable person to'give as an individual.
16 No one can speak for the ASME code, per 17 se.
He was an experienced person.
He could give an 18 independent evaluation.
, agreed to I
19 contact Mr. Bosnick.
'~
20 To my knowledge, he never contacted h.im.
21 Later on -- I don't know how many weeks -- I and 22 Tom -- T forget who initiated it -- "Would it help
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23 you ifg were on site to talk to to.
24 Mr. Bosn~ick?'
l-25 I contact Mr. Bosnick.
I told him what the em y TATE REPORTING SERVICE i
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inspector's concerns were and asked would he speak
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2 to him.
He'sa'id yes.
was put on the 3
phone with Mr. Boznick.
I left the room.
I do not l
4 know the exact conversation, but I-believe I was 1
I 5
told that Mr. Boznick had indicated to the inspector l
6 that there was no code requirement to test a piping i
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subassembly.
1 l
8 So, since I wasn't present, that's what I
]
9 was told I believe from(
That's about 10 all I can tell you a' bout Mr. Boznick.
3 1
11 Q.
One last question.
Going back to the write
)
l 12 up that was in the original draft report, there's a i
(,,
13 statement lmade here.
I j ustlwant to make sure I
]
1 14 understand your point here.
15 It says, 'It's not evident that the system 16 test substitution was permitted f or pipe subassembly 17 since NA-1200 make a distinction in the definition 18 between component and piping subas semblies. "
1 19 I guess I need to get your comment on that 20 statement.
)
21 A.
I'll have to read it first because I think I
22
'I already answered that question.
23 Q.
You might have, but just for the record I 24 would like you to repeat it.
s,.
25 A.
For the record, NA-1200 clearly makes a I
i t'
TATE REPORTING SERVICE Houston,. Texas (713) 222-7177 1__._
24 1
distinction; and that is why I took the posture that 2
there.was no need under code requirements to perform 3
a hydrostatic test on a piping subassembly.
Yes, I 4
agree, there is a distinction between them; and that 1
5 distinction is the pivotal key to understanding the l
6 subj ect.
I 7
Q.
That's all I wanted to do.
8 Q.
(By Mr. Mulley)
To the best of your 9
knowledge, did Mr. Westerman show the documents that
]
l 10 we've marked as Exhibits 1 through-4 to 1
11 Mr. Phillips?
I I
12 A.
I was not present in any discussions with I
1 I
13 Mr. Phillips.
S'o, I cannot comment on that.
I do 14 not know what Mr. Westerman showed to Mr. Phillips.
15 Q.
Okay.
16 A.
I don't know if he showed him any 17 documents.
18 Q.
(By Mr. Goldberg) okay.
The last issue on 19 that report that we're looking at involves the 20 concrete mixer blades, and I'll just quickly l
21 summarize it and see if you have any knowledge or 22 want to add to it.
"A violation was written as a 23 result of applicant's failure to provide record 24 evidence that the concrete mixing blades had been 25 inspected quarterly since 1977; and what turned out TATE REPORTING SERVICE Houston, Texas (713) 222-7177 i
7 0
2 5._
m
~
-1 to be violation'was maintained, but there was no i
2 letter asking'the'l'icensee for-corrective action."
i
'3 Do you have -anyf comment you ' want to make on 4
that one?
1
'5 A.
I'would not have any professional 6
disagreement with that approach in that the blades' I
I
.7 were established to'show'no wear, that. there was 8
concrete testing throughout'the life of the batch 9
plant.
There waseno' problems.
If.we're talking 10 about historically, then, I have no professional 11 reservations about what Mr. Westerman recommended in 12 instituting.
1 13 Q.
Going to the next inspection report w h'i c a 14 involves records and the weld' rod issue.-
It's j
1 15 85-14-16.
Let me j ust get my folder.
16 It may be that your ' maj or involvement in 17 this was the last issue.
That's why_I'm going to go
)
18 through it fairly quick.
Maybe you have other 19 things you want to add.
I r
20 The first issue involves the requirement i
21 for record storage in 45.29 in-the PSAR an QA 3
22 manual.
23 Do'you have any comment on that one?
24 A.
I only had m.oderate involvement in that A.
25 particular subj ect in that I relied quite heavily on TATE REPORTING SERVICE Houston, Texas.
(713) 222-7177 i -.--
l 26
~
i i
1 Mr. Hale's input on that.
He was my QA/QC leader.
I l
2 He' was the deputy QA/QC leader of TRT.
f 3
I was aware of wha't SSER 11 stated.'
- Again, 4
I had moderate involvement.
I did believe in I
I 5
reading the report, I thought that the way it was j
6 structured, in my judgment at least, was not 7
consistent with the guidance given by Manual l
8 Chapter 0610.
l i
{
9 I did not think it was appropriate, what I i
l l
10 considered an iteration of basically the same
]
11 information; and I felt it was creating an 12 impression or could create an impression in an
(
13 uninvolved and' unbiased reader that the scenario l
{
14 seemed to be far worse than reality indicated.
15 Q.
From what I understand, Mr. Hale was your 16 key person.
17 A.
I relied heavily on Mr. Hale's judgment, 18 yes.
19 Q.
These issues I'm just going to quickly 20 tick them off -- are issues on S5one
& Webster's 21 records in terms of its storage and shipment off 22 site, CB&I records, the condition at the storage 23 facility, the auditing of CB &I's records and the 24 commingling of final records and in process I
a 25 records.
Those are a n um be r of issues.
TATE REPORTING SERVICE Houston,' Texas (713) 222-7177
27 4
1 If you want to give me anything on any of 2
those, y o u ' r e 'w el come to.
3 A.
I'would' prefer that you ask me some g
4 specific questions.
5 Q.
I will do that.
I'll give you the first 1
6 one.
I'll go. step by step here.
TUG CO failed to 7
have or use procedures to control' shipment of.
8 original records to Stone & Webster in New York.
9 A.
I believe that that scenario was adequately 10 reflected in the issue report relative to the notice 11 of violation showing that scenario.
I 12 Q.
Original desig'n records shipped in 13 cardboard boxes without making'a back-up copy.
4 14 A.
As I recall -- first of all, I believe the j
15 citation addresses the core issue of this practice.
16 I did not personally consider it prudent to ship 17 sole source design documents off site.
I don't 1
18 think it prudent at all.
I 19 In fact, I was somewhat appalled that an 20 organization would do that.
I believe the citation j
21 addressed the basic core issue of what was the 22 problem.
23 As regards cardboard boxes, I don't know 24 whether records were shipped off site in cardboard
(-
I 25 boxes.
I do recall they had conversations with QA TATE REPORTING SERVICE
. Houston,' Texas
-(713) 222-7177'
-m
.m_..am_
2-
28 1
branch about this; and the best of my recollection, 2
we were told there was no cl ea r regulatory 3
requirement.
4 Q.
When say address the core issue, the core 5
issue in your mind was the procedural issue as 6
opposed to the 45.29 issue?
Is that what you're 7
saying?
8 A.
I believe that's what I'm saying, yes.
9 Q.
Okay.
Next issue is failure to control and 10 account for QA design records transferred from the 11 site to Stone & Webster.
12 A'.
I think that is an iteration of the prior l
13 issue and I think was adequately addressed by the l
14 citation that was issued.
15 Q.
The prior issue was the shipment in 16 cardboard boxes.
17 A.
I'm sorry.
Two issues before.
We're 18 really talking about shipment of the sole source 19 design records to Stone & Webster.
I believe that 20 we have already touched on that s ubj ect in another l
l 21 form.
22 Q.
(By Mr. Mulley)
With the notice of 23 violation?
24 A.
And the fact that we're tal king about a
(.
25 variant of the same theme.
TATE REPORTING SERVICE Houston, Texas (713) 222-7177 I_____ _ ____
i 29 1
Q.
In other words, you feel that we're not 2
we -- the inspector took one incident which we cited 3
them with notice of violation and took that same 4
incident and broke it up into component parts and 5
th'en recited them?
6 Do I have that correct?
7 A.
I believe you have it basically correct,'
i 8
George, the concern I had'was were we really I
9 concisely, factually reporting things; or were we 10 just making variations on the same subj ect?
I do 11 not think if you do that latter posture that it's 12 consistent with the guidance I have been given by
(
13 senior. manage' ment of this region.
14 I do not think it is consistent with IE 15 manual chapter guidance.
I d o r. ' t think that's the 16 way we do business.
17 Q.
(By Mr. Goldberg)
If we get to 18 practicality of the situation, the first issue in my 19 mind talks about procedures and failure,to follow 20 procedures and have adequate procedures, and the 21 next two issues involve practices.
22 Is it conceivable that TUGCO could 23 establish the procedure but still continue to ship 24 out in cardboard boxes and not do the accountability
(
25 correctly?
There are three things that are TATE REPORTING SERVICE
,_ Houston, Texas (713) 222-7177
3 ~0 l
1 involved:
Establishing an adequate procedure, the 2
actual shipment, the preservation of the records 3
that are in shipment, and a c c'o u n t a bil i ty of the s
4 records.
4 Do you cover all three bases with the way 6
the citation was written?
7 A.
In my judgment, yes.
l 8
Q.
I would expect there would be corrective.
9 action to address all of the ramifications of that 10 particular scenario.
11 Q.
Notwithstanding the fact you don't mention 12 the other two issues in the citation?
(
13 A.
I think we did.
14 Q.
Unfortunately I don't have the final 15 document.
So, I don't know.
16 You're assuming that they did mention both l
l 17 of the other issues in the citation?
18 A.
I believe the way the citation was 19 structured addressed the issues.
I learned somewhat l
20.
to my chagrine when we got a response to that 21 citation that all along that had been a procedure 22
'and they hadn't been complying with their own 23 procedure.
24 I did not feel very happy about that s
25 particular facit of the response because it reflects TATE REPORTING SERVICE Houston, Texas (713) 222-7177
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31 1
somewhat adversely on us and our inspection
}
2 performance.
l 3
Q.
Okay.
Go on to the next set of issues 4
which involves CG&I.
Site records of Chicago 5
Bridge & Iron were shipped to Houston in cardboard 6
boxes, originals subj ect to little protection 7
without retaining back-up copy at site.
8.
A.
Well, first of all, I'd like to say, it is 9
like a rerun of the Stone & Webster scenario.
The i
10 second point I'd like to make, we were informed by 11 the utility -- Mr. Phillips was present -- we were i
l 12 informed ~by the site QC manager, Mr. Hale said that 13 TUGC0 had never taken possession at that time of 14 tho'se records and the reason the records were being 15 shipped off site was f'or duplication prior to turn 16 over to the owner.
17 That sounded like it was probably f a ct ual 18 and that I would expect that to be a normal event, 19 to duplicate records CB &I would expect to retain 20 records for their own purposes and provide copies to 21 the owner of the original records and copies for 22 themselves.
23 That was never reflected in the inspection 24 report.
(-
25 Q.
It gets back to who has control of the TATE REPORTING SERVICE Houston 3. Texas (713) 222-7177
32 1
records.
You're saying they're CB&I's records at 2
this point?
)
3 A.
I have no reason to disbelieve other than 4
that or believe other than that.
It was nev.er l
l l
5 demonstrated to my satisfaction that TUGC0 had ever
{
6 taken possession of those records.
7 Q.
There's words in Criterion I of Appendix B l
8 involving the retention of responsibility on the 9
part of the utility.
10 In this area, do you think that the utility 11 retained -- has any grounds to retain responsibility 12 under Criterion I?
13 A.,
I would be highly surprised-if any utility 14 in this country acted in that accord.
If you hire a 15 major contractor to do a specific work activity, and 16 you give him virtual total responsibility to 17 accomplish that task, I do not think the utility is 18 required by anything to be officially in charge of j
13 that contractor's records.
When the task is 20 completed, they have to turn over contractually 21 required records.
22 It's my understanding in this particular 23, case that for whatever. reason they had not 24 officially turned them over and were in the process.
(
25 O.
I understand that the records were TATE REPORTING SERVICE Houston, Texas (713) 222-7177
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33 1
associated with the containment liner.
l 2
A.
Correct.
3 Q.
And the consequence of loss of these 4
records would be rather significant?
5 A.
I would imagine the utility would have one
(
6 heck of a problem to establish the containment of-l 1
7 those liners if those records were lost.
8 Q.
You think that the issue of retention of 9
responsibility can be looked at a lfttle more l
10 carefully in this area?
11 A.
I think what we're tal king about is 12 prudency as opposed to regulation, prudency.
If 13 that plant prior to fuel load does not have an l
14 operating license from the NRC, we're talking about 15 prudency of management.
16 We're not talking about anything also.
It 17 w c ul d be the utility's responsibility to come up 18-with a position or to regenerate records if records 19 were lost.
I think it's purely a matter of 20 determination of prudency.
21 Q.
(By Mr. Mulley)
CB&I in their involvement 22 out at Comanche Peak -- I don't know if you know the 23 answer to this or not did they operate under just 24 one contract or did they have various contracts or 25 various systems out there?
TATE REPORTING SERVICE Houston, Texas (713) 222-7177
7 34 i
I 1
A.
I co ul dn ' t speak unequivocally on that, 2
George.
To my knowledge, CB&I was under one 3
contract pure'ly for the containment liner; but I may i
j 4
be wrong in that.
I've never had reason to l
l 5
ascertain did they have other contracts.
6 Q.
The records under question'right now are 7
only records dealing with the containment liner?
8 A.
Uh-huh.
l 1
9 Q.
Okay.
So, for example, the George i
10 Washington Bridge records, I don't know if CB&I was 11 involved.
12 A.
I'm afraid I can't answer that.
My l
13 involvement with Comanche Peak started in June, 14 1985.
I have no prior involvement.
I 15 Q.
(By Mr. G ol dbe r g )
Okay.
Let me go on to 16 the next issue.
We got your point.
It's fairly 17 clear.
TUGCO failed to inventory CB &I records sent 18 to Houston and, therefore, cannot determine records 19 that must be returned.
20 A.
I think we are talking about the chicken l
21 and egg syndrome.
If TUG CO was correct in what the 22 information they gave us, that they had not taken 23 possession of the records, they co ul d n ' t very well 24 be in a position to be performing an inventory.
(-
25 A.
I'm going to go to the next group of issues TATE REPORTING SERVICE Houston, Texas (713) 222-7177
.1 3' S
~
1 involving the condition of the storage f acility.
2 Thers is one issue involving failure to
~
~
3 preclude' rain from entering the QA records va ul t 4
over several years time.
.I guess it has to do with j
5 water leakage somewhere in the roof area in the
]
6
. ventilation duct and also related to slope of the 7
floor and the ability for it to drain properly.
8 A.
I considered a violation relative to rain 9
entering the vault a highly subj ective j udgment.
My 10 reading of 45.29 showed me that the facilities have 11 got to be constructed to protect contents from 12 possi'ble deterioration by,a combination of extreme 13 variations in temperature and humidity conditions.
{
1 14 The issue regarding the facility in 15 question had to do with air conditioning.
I find it l
i 16 rather stretching the point to say that any records 17 had ever been subj ected to an extreme combination of 1
I 18 extreme variation of temperature and humidity.
19 I felt the inspector was somew'at out in h
20 left field.
21 Q.
. What about the matter of the roof not being 22 repaired for a significant amount of time?
23 A.
I personally didn't get into that.
All I 24 can remember is here that the utility had made i
l
\\~ '
25 various efforts over a period of time to fix this TATE REPORTING SERVICE Houston, Texas (713) 222-7177
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36 1
roof; but I,
personally, didn't get into the 2
specifics on that or sloping floors.
i 3
Q.
Next one is failure to preclud'e food from l
4 the copy parts of the QA records vault area.
5 A.
If I had been the inspector in question on l
6 that particular subj ect certainly one shouldn't l
l 7
have food c r um bs or whatever in a records area I
8 would have informed the utility management to please l
l 9
correct the scenario.
10 I do not think a violation is appropriate 11 for that particular scenario.
12 0.
The last record oriented issue is failure 13 to provide temporary or permanent storage facilities 14 for records, co-mingled with in process records and 15 the paper flow group.
16 As I un'derstand it, records were taken from 17 one part of the facility where there was storage, 18 mechanical and electrical calculations, and brought 19 back into the paper flow group.
20 A.
That particular subj ect, I relied totally 21 on Mr. Hale's j udgment and the fact that the NRC had 22 in a publicly issued document, SSER 11, basically 23 addressed this scenario.
24 It was Mr. Hale's continued assertion or
(~
25 belief that there were no longer a record.
A l
l l
TATE REPORTING SERVICE Houston, Texas (713) 222-7177 1
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37 l
1 document was re-issued to be be incorporated into j
1 2
another entity.
It wat no longer a record, i
\\
l 3
I relied totally on his position; and in
{
j 4
terms of Mr. Westerman's actions, I would consider 5
he exercised good j udgment in that case.
If one has 6
NRC people internally in disagreement, it is not the I
i 7
time for writing violations.
It is time to be 8
getting information and further advice from 9
headquarters, if warranted.
10 Q.
You said public public forum, are you j
11 referring to SSER7 12 A.
'Yes.
13 Q.
As I understand -- we talked to Mr. Hale 14 yesterday -- circumstances involving that issue and 15 the answer to that allegation was different than the 16 one involving this issue.
That was involving 17 records I'm sorry -- documents.
18 We had a discussion on what was a record 19 and what was a document, documents that had not made 20 it to the records file, they were still in process.
21 Where the issue was documents that became records 22 that came back into the process position.
So, they 23 were different.
24 So, when you say public forum, why do you 25 make that point when the issues were different?
TATE REPORTING SERVICE Houston, Texas (713) 222-7177
38
0 l
1 A.
It was my recollection of SSER 11 that the 2
subject was to'uched on.
-Perhaps my recollection is
)
3 f a ul ty'.
I would have to go back'abd-reread SSER j
j 4
11.
5 Q.
The.next issue involves weld rods.
I guess-1 6
there's a memo or something.
~I don't think.I have 7
it, but it.has to do with a' weld rod not identified l
8 at the main distribution or distribution station.
9 Could you comment on that?
10 A.
I believe you are in possession of.a memo I 11 wrote which Mr. Westerman brought this to me, this 12 particular subj ect.
Again, I don't have a copy of l
13 that document I wrote; but as I recall in my review
{
l 14 of that inspection r e p'o r t, I was reading the i
15 construction appendix and I noted that there was;an
)
16 unresolved item relative -- I s ho ul d say a previous I
17 unresolved item which addressed applicant's action 18 previous inspection findings which was being closed 19 and a subject of weld rod control.
20 In essence, Mr. Phillips said he was' 21 closing it because of the exhaustive review of this l
1 22 subj e ct by-TRT and also based on a current 23 inspection in this arena which'had found or had no 24 findings, no violations or deviations.
25 As I continued to read the report, I TATE REPORTING SERVICE Houston, Texas.
(713) 222-7177-
i 39 e
1 finally came'to the arena that, I'
1 l
2 believe, had written,that addressed the subject of
\\
3 weld material control.
4 To my.chagrine, I'found there was a 5
violation indicated, which I couldn't understand 1
l 6
what was going on in the same appendix of the 7
report.
I went next door to see Mr. Phillips.
l 9
My recollection of the-conversation,.I, told t
l 9
him or I asked him how could he be closing out an 10 unresolved item on weld' rod contzol'saying there was O
11 no findings and in his own appendix later on in the l
12
, report was an indicated violation.
13 I said that was unacceptable and that
(
14 either the unresolved item remained open if the
)
15 inspector truly believed there was a violation or 16 the unresolved item would remained closed and-there 17 would not be a violation.-
/
18 Reading the text that i
had i
19 written did raise some questions in my mind in that 20 he stated that they had-not lost traceability.
l 21 I had not made a final determination.1 I
r g
22 said, "Plese discuss this withs-and reach' I
23 an acceptable resolution of this matter."
24 Mr. Phillips informed me some days later L
w 25 that he had discussed this matter with TATE REPORTING SERVICE Eoustoh, Texas (713) 222-7177
40 i
i i
1 and they had decided to drop the violation.
I told 2
Mr. Phillips a' t that time that labels, vendor J
3 labels, on cannisters sho ul dn ' t be coming off and j
4 that'I definitely wanted the subj e ct followed up 5
- anyway, i
6 So, I believe I wrote the actual words.were I
7 put in the report' about the referral to Brown & Root 8
welding engineering to look into the matter.
I then-
)
9 checked at the time the report was going out, or l
1 10 shortly thereafter, to confirm that he had, in fact, 11 contacted Brown & Root's welding engineering.
12 Mr. Phillips answered in'the affirmative.
i
(.
13 Q.
Why was this not continued'as a violation?
14 The technical issue was a violation identi'fied as 15 loose and missing labels on cannisters of Satvick-16 electrodes.
Was that condition corrected?
17 A.
I haven't personally checked it.
l 18 Q.
That seems to be the nub of the whole 19 thing, was the condition at ahe plant.
20 A.
Not the condition in the plant.
You're 21 talking about a condition that was at a weld rod I
22 issue station.-
23 Q.
Facility or whatever.
What I'm questioning 24 is what was the condition at the time and was it, in k-25 fact, a situation where there's still an issue
\\
TATE REPORTING SERVICE Houston, Texas ~
(713_)- 222-7177
41 1
here.
2 A.
I-cdnnot tell you that.
I responded to 3
that.
I believe I acted appropriately.
.I mean, one 4
can lo'ok at things in a broader picture, true, about 5'
how a weld rod is issued.
6 I could maintain to you that it was 7
virtually impossible for them ever to have 8
effectively lost traceability.
9 The ASME code certainly requires control 10 identity o'f weld material to the point of j
f 11 consumption, but weld issue stations at Comanche I
12 Peak do not issue cannisters of electrodes to 13 welders.
14 It's my understanding of the procedure 15 and it's been quite awhile since I read it 16 welders are all issued portable rod ovens.
They 17 come to an issue station with the appropriate 18 traveler type paperwork given to them by their 19 supervisor.
I I
20 The man that records the identity of the l
21 consummables is actually the issue clerk.
The 22 welder has nothing to do with that.
They do not 23 issue cannisters of electrodes.
They follow normal 24 industrial practice of issuing rods sufficient to
('
25 weld up to a maximum of four hours, and that is a TATE REPORTING SERVICE Houston, Texas (713) 222-7177
'42 1
return criteria.
2 The moment an issue clerk opens a cannister
'3 of electrodes, the balance goes into a rod' oven with 4
the identity of the electrodes.
5 I _would f urther. say that the only J
6 electrodes in that issue station are approved 7
electrodes that have been released by Brown'& Root 8
welding engineering based on the vendor testing or-9 their own testing.
There is no unapproved.
1 10 It's a requirement 'of Section 2 (c) of the q
i 11 ASME code of welding material that the coding on a 12 stick electrode at'least show electrode type.
(l 13 So, I think from memory, was 1!
talking about some E-309 electrodes, rather rarely 15 used electrodes.
Be that as it may, the electrode 16 would always be identifiable as an E-309 electrode.
i 17 The only thing that probably was not.on the 1
18 coding stenciled on was the lot number.
It's not a 19 manditory requirement.
Some companies actually put i
20 the lot num be r right on_the coding.
21 I don't know for sure whether this company 22 does it or doesn't.
We are talking about a-code 23 requirement, maintenance of identity up to the point 24 of consumption.
That is the one potential area.
(,-
25 I'll say again, if one has a carton of-TATE REPORTING SERVICE Houston, Texas (713) 222-7177
43' 1
cannisters of electrodes-and that carton is clearly 2
identified as'to lot number,. type of electrode, the 3
fact that a particular cannister ib'that' carton has 4
a-label that is starting to come. loose, the
~
5 probabilities of losing traceabf.lity are very low.
6 Q.
Rather than gatting into the issue or' 7
debating the point of-traceability -- this is an 8
issue that's very debatable -- let me go back to a 9
sentence.
10 It says here, "I told'Shannon at that time 11 I did not want the subj ect dropped and that the l
12 labels should not be coming loose from electrode
(]
13 cannisters.
I recommended the matter be referred to 14 Brown & Root-welding engineering for follow-up."
15
- The thing that strikes me here is that if i
16 we had issued a violation bef ore we're ' expecting l
17 corrective action -- I don't understand the word 18 follow up.
19 A.
First of all, I did not make or make the 20 decision that a violation should not be issued.
It 21 was my understanding from Mr. Phillips that 22 conversations between himself and jmade 23 that determination.
24 I did have a question about the validity of L.
25 the violation.
Our role'here is not simply j ust to TATE REPORTING SERVICE Houstoh' Texas-(713) 222-7177
44 I
1 issue violations.
Our inspection role also is-
)
1 2
structured at ~getting inspected organizations to 3
demonstrate compliance to regulatory requirements 4
'and commitments.
1 5
I believe I a cted ' appropriately.-
H 6
Q.
Okay.
7 A.
We're not hiding anything.
I put it in the l
8 report, the referral.~
I'm not making some kind of 9
pri'vate phone calliand saying take. care of this 10 matter.
I'm putting it in the report for the.public 11 record.
12 Q.
The issue gets back to if corrective action i
f 13 was required previously by the utility.
The 1
14 question is:
Did they fulfill completion of that i
15 corrective action?
That's the only question I 16 have.
17 A.
I believe that as a senior resident 18 inspector of construction, that's his 19 responsibility.
That's his appendix.
That is his 20 report.
I believe, yes, we should f ollow up to 21 verify corrective action has been taken; but that is 22 his lead responsibility.
23 I mean, I think he should have established 24 whether they had done anything with-. Sam vick to 25 change the. adhesive or do something since we're TATE REPORTING. SERVICE Houston, Texas (713)1222-7177
45 1
1 talking-about a Sam Vick' label that was peeling.
~
2 We're.not talking about a label put.on by Brown G-3 Root.
We're talking about-the actual manufacturer.
j I
4 Q.
Okay.
I'm. going to go onto the.next T
1 5'
inspection report.
6
'Q.-
(By Mr. Mulley)
'Let me j ust ask one l
7 question before you go to'the next inspection:
l l
8 report.
9 Did you discuss. the' conclusions that'we.had 10 just talked about with Shannon Phillips?
11 A.
What conclusions specifically are you 12 referencing, ceorge?
(
13 Q.
Your opinions concerning your review of I
14 this inspection report that we just outlined, the 15 vari'ous topics we j ust went through.
l 16 A.
No.
I did not, and'I will give you a 1
17 reason why I did not.
I had.a title as group 1
18 leader.
I was a retained. Grade 15; but in reality, 19 I was not a supervisor.
I was a peer.in terms of 20 formal paperwork.
21 I did not feel it appropriate that I should 22 start critiquing with the individual.his report.
23 Any concerns I had, I passed onto 24 Mr. Westerman who did the necessary coordination.
L.
25 Q.
Good.
TATE ~ REPORTING-SERVICE
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1 l
1 Q.
(By Mr. Goldberg)
Next set of issues 2
involve inspection report-85/16-13, and this was an
)
3 inspection which occurred during the period of 4
November 1st through 30th of 1985.
5 I will put these inwo three sections.
One 6
is actions on 50.55(e); second, bulletins; and third
'7 section is Bisco seals.
8 The first one involves, I guess, a series
{
9 of inspections that were done by Mr. Phillips 10 assisted by consultants McCleskey ' and Young on the 11 issue of action on 50.55(e).
12 I'm going to group them together.
If you
(
13 want to, I can put them separately or together.
14 They seem to come together in a group.
15 A.
Be my guest.
16 Q.
TUGCO failed to develop or implement a 17 procedure to show a reference of subj ective evidence 18 that deficiencies were corrected.
TUGCO failed to 19 revise implementing procedures before corporate NEO 20 procedures, resulting in conflict with five other 21 procedures.
22 TUGC6 failed to maintain 50.55(e) files 23 which were QA r e c o r. d s that were retrievable and 24 that these records were not produced for almost a (s
25 month.
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TATE REPORTING SERVICE H,ouston, Texas
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1 Finally, TUG CO failed to report to NRC the 4
2 corre.ctive act' ion actually taken and changes to 3
commitment regarding corrective action reported to 4
NRC.
~
t 5
'I understand these issues involve a series a
6 of hardware items that~were needed to be checked out l
7 throughout the plant and it was difficult in getting 8
out to the plant to check.the hardware items.
9 A.
I think for me to respond effectively, that 10 you're going.to have to provide me a little more 11 specificity about the issues than j u s.t general
-l 12 characterizations.
(
13 Q.
I'll be glad to do so.
There were several 14 variations of these inspection reports.
I'm going 15 to try to get the best one that we can ta1k from i
16 because they do change quite a bit.
17 Here's one I'll give you.
Procedures do 1
l 18 not address 50.55(e) file content or provide a 19 method for completion / sign-off of, corrective l
20 deficiency.
Five procedures were reviewed during i
21 the October, 1985, inspection period; and this item 22 in this version was unresolved because TUGCO' 23 management informed the NRC Comanche Peak group i
24 leader that a new procedure had been developed and L
25 would be implemented.
TATE REPORTING SERVICE Houston, Texas (713) 222-7177
l 48 1
TUGCO management thought the procedure h
2 would take care of procedural weakness.
This item 3
was left ' unresolved pending the review of this l
i 4
issue.
5 Does that ring a bell?
l I
6 A.
A little.
This area Mr. Westerman acted' 7
' fairly individua31y.
He kept me' informed of where 1
8 he was at, what his p'ositions were and his thought 9
process.
I didn't have any particular reservations 10 about Mr. Westerman's position.
11 Q.
Let me give you another issue.
50.55(e) 12 deficiency files do,not contain sufficient 13 information of documentation.
The NRC inspector 14 reviewed 20 construction filet-which showed 15 licensee's action complete.
16 TUGCO,QC supervisor stated that reports had 17 been made to NRC and had nothing to do with ensuring 18 that corrective action was implemented; however 19 these files do not contain sufficient documents or 20 reference documentation that would show that the 21 deficiencies had been corrected or sufficient 22 information to show how the evaluation had allowed 23 TUGCO to conclude the deficiency was not 24 reportable.
's 25 What about that?
TATE REPORTING SERVICE
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A.
Again, we're talking about prudency rather 2
than regulatory requirements.
I don't know of any 3
regulatory requirement that required an organization 4
to maintain those files.
They have complied that 5
I'm aware of.
I 6
Q.
Again, did you rely on Mr. Westerman on 7
this issue as wel17 i
8 A.
Essentially, yes.
9 Q.
I'll go on to the next issue, a series of 10 IE bulletins, IE Bull'etins 79-14 and 79-28.
Let me 11 go through them in a group.
12 TUGCO never responded to all aspects of IE 13 Bulletin 79-14.
TUGCO's IEB' files for 1982 and 1985 14 do not contain sufficient records or reference to 15 records which allow IEB action, corrective action.
16 TUGCO had replaced NAMCO switches per IE Bulletin I
l 17 79-28, but two of the fourteen that were field 18 inspected were not properly identified.
19 A.
Regarding 79-i4, I felt $t was somewhat a 20 moot issue in that the utility had hired Stone &
21 Webster to essentially verify all of the analysis 22 that had been performed with respect to 79-14; and 23 that was and is an ongoing endeavor.
24 3o, I think it's a somewhat academic issue
(
25 in reality.
Itds a mattar of knowledge and the NRC TATE REPORTING SERVICE Houstoh, Texas 1713) 222-7177
50 1
stated in public meetings what they are doing in 1
2 this particular arena.
3 79-28, all I can say'to you is I believe I 4
was present at a time that I thi'nk there was an 5
issue about records or something, records were 6
requested of a QC supervisor.
Lots of those things l
~
7 in the records were produced in very short order.
8 I believe there was no problem as regards 9
to one of these things at all.
The one was in a 10-safety-related system.
They'did finally produce 11 records showing what was there was what was 12 correctly indicated s h o ul d be.
(
13 I believe the other one was in a non-safety 14 related system as best I can recall.
15 Q..
There's one issue I wanted to touch on.
16 It's related to the 79-14.
I guess the inspector 17 found an internal letter, CPA No.84-163, dated 18 October 22, 1982, that the engineering manager 19 stated that " reporting of non-con,formence areas.cf 20 the IE bulletin which we must take exception and we 21 will not identify nonconforming conditions to NRC."
22 Is that an appropriate memo to be in the i
23 utility's file?
l 24 A,
If I was a utility executive, I would nct
(..-
l 25 have a memo like that in my file.
I don't know that t
i
. - -.. ~ ~.. - -
TATE REPORTING SERVICE Houston, Texas (713) 222-7177
ns 1
that's a very prudent statement.
2 Q~.
Would that give an inspector an indication 3
that they may not be complying?
i 4
A.
No, not necessarily.
They would have an i
5--
obligation to report under 50.55(e) if they had a 6
problem that met ths criteria of 50.55(e).
7 Q.
Going to the last issue, that's the Bisco 8
matter.
I guess you might have more knowledge since 9
this is sort of vendor related issued.
10 MR. MULLEY:
I just have one m'o r e 11 question on the records retrievable.
12 Q.
(By Mr. Mulley)
From what I understand, 13 although the inspector co ul dn ' t get a record over a 14 period of a coupit of months, appar,ently either Tom 15 or somebody was able to go to an individual like you 16 and get the record within a couple of hours.
17 Do we know whether the individual that he 18 went to was able to retrieve the record from the 19 system or was this a record that he may have had on 20 his own?
21 For example, draft reports, we have certain 22 inspectors in the region that maintain draft reports 23 in their desk drawer although these draft reports-l 24 should be filed away in a system.
l
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25 Do we have any knowledge that de report TATE REPORTING SERVICE Houston, Texas (713) 222-7177
i
.o 52 I
l 1
that.we.were actually given came from the' system aor L
2 came from, you know, a report that he maintained'on'
~
'3 the site on.his own?
4 A.
I think your question, George, is quite 5
philosophical.
The probability of an individual 6
having or knowing where to go for'some private 7
records when he has no knowledge in' advance what the 8
NRC is' going to ask for.is so slim.that I can reject 9
it out of hand.
10 Q.
You feel there's enoughLassurance based on 11 what's going on that if this man got.th.e records, he 12 had to get it out of the system?
13 A.
The gentleman's name is Thomas Brant.
I
\\
14 have no reason whatsoever t$ believe that he wasn't 15 able to go anywhere other than the:TUGCO record 16 system.
17 Q.
What is his title?
18 A.
He's a quality engineering supervisor.
I 19 think he's been there about six years or so.
He.
I a
20 happens to be very conversant with the way that 21 TUGCO structures its records.
22 I think that is why he is able to rapidly 23 identify:in part.
24 Q.
What happens if Thomas Brant decides to get 25 a job up in Connecticut?
Would we still be able to:
q TATE REPORTING SERVICE Houston, Texas
.(713) 222-7177;
53 1
get records?
2 A.
I obviously couldn't answer that question.
3 That -wduld be their ultimate dilemma if t h.ey 4
couldn't produce records that we requested 5
legitimately in any inspection process.
They're 6
going to have a major problem.
7 Q.
(By Mr. G ol d be r g )
To follow up, do-you 1
8 view the retrievability issue as more of a prudency 9
issue?
10 A.
To answer you as candidly as possible, i
11 Mr. Phillips is not the only individual that has had 12 trouble from time to time retrieving copies of 13 records.
i 14 All of my people from time to time have had 15 some problem or other.
The records have always been 16 retrieved.
I don't know what the full scope is.
I 17 don't know whether part of the < problem.is our lack 18 of understanding of how their records are 19 structured, whether they're relying pretty much on a 20 word-of-mouth system.
Maybc we asked for a record 21 in the wrong way because of our ignorance.
22 I think there's probably a lot of 23 contributory factors.
I'm not about to sit here and 24 say TUGCO has the finest records retrieval system 25 I've ever seem because that would be a blatant TATE REPORTING SERVICE Houston, Texas
-(713) 222-7177
54' 1
falsehood.
2 They'have at time to time difficulty 3
retrieving records.
In essence, they'have retrieved 4
the record when asked for..
Sometimes it took in my 5
judgment overly long to retrieve.
I have never 6
personally seen it take a month for anything I was 7
actively personally involved trying to retrieve the 8
record.
No, it's much faster than that.
9 Only arena I have been involved with 10 difficulty retrieving records was the electric 11 penetration assembly inspection when I was preparing 12 the reports with the possibility of escalated 13 information action; but in that case, some of those l
1 l
14 records I don't think existed and we properly l
15 reflected that in the report?
l 16 A.
(By Mr. Goldberg)
The last issue in this 17 inspection report covers Bisco seals.
I think I can 18 read you generally what it is.
l 19 The certification of Bisco Al penetration 20 seals is under review as a result of the 21 q ue s tiona bl e testing.
It was first found by 22 Mr. Young who was a consultant and I believe that 23 has been put on the unresolved status until all the 24 facts have been determined.
It's still unresolved.
('
25 It goes back to the testing that was done in the TATE REPORTING SERVICE Houston, Texas (713) 222-7177
SS 1
l 70's by the company and these, as I understand, 2
involved a three-hour test for safe-guarding certain 3
pieces of eq ui pm e n t.
l 4
Do you want to comment on this one?
I 5
A.
I don't really think so.
I wasn't actively 6
involved.
I saw a vendor problem.
I knew that we 7
should be referring it to the vendor branch.
The 8
primary concern was with the vendor.
9 Q.
The last inspection has to do with the 10 current inspection report that has not been 11 finalized.
12 One issue that we're focusing, we l
13 understood that there was a finding that 14 Mr. Ell e r s h aw had picked up on involving a welding 15 1.ssue.
It's some clips that were put on in which 16 there was some problem; and in t'e exit inter'iew, c
v 17 Mr. Counsil mentioned something like, "That's a 18 violation."
19 Are you familiar with thia one?
20 A.
I recall the exit meeting; and I recall the 21 subj ect, yes.
22 Q.
Do you have a comment to give us on that?
23 A.
In the course of the inspections, one of 24 our consultants went out to either witness this
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25 third-party evaluation or was doing an independent i
TATE REPORTING SERVICE Bourton, Texas (713) 222-7177
56 1
inspection relative to the activity of those 2
people.
i 3l While he was out there, in what whatever 1
4 particular arena, he noted some really cruddy --
5 perhaps I should be a little more precise.
He 6
' noticed some welds attaching brackets to an actuator 7
barrel on some, I believe, it was auxillary field 8
boiler system valves and the man was a mechanical l
9 inspector and very experienced in welding.
He could 10 see no fusion associated with these welds.because I
l 11 who had ever done the welding had went and placed
)
12 these brackets on top of where there was some 13 casting letters, 14 There were raised letters on the surface, l
15 and they had went and located these brackets right 16 on top in the crena uhere these raised letters 17 were.
It was impossible to make a totally sound l
18 weld because of that stupidity, and he came back an 19 informed us of what he had seen.
i 20 We in our follow-up of that came to 21 learn -- I really don't recall exactly how we came 22 to learn.
We came to learn that partiiular subj ect 23 had been addressed in a 50.55(e) report to Region IV 24 in the past and the 5 0. 5 5 ( e) report informed us 25 they're going to remove those brackets and they're i
TATE REPORTING SERVICC Houston, Texas (713) 222-7177
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57' 1
going to replace them with new brackets correctly 2
welded.
3 As a result of learning this, I went.and 4
located the file relative to
- c. ". a t 50.55(e). report.:
5 The document they used to determine deportability, I I
l 6
believe,'is called a significant. deficiency analysis
- {
t 7
report, SDAR.
i 8
In this file was a couple of versions or 9
there was -- there was an SDAR and then a couple of 10 versions of NCRs and tnen there wa's this 50.55te)
{
)
11 submittal.
12 I saw a' document I forgot if it was NCR i
(
13 or SDAR -- but after they had informed the l
l 14 Commission that they were going to remove these 15 things, they changed their mind.
16 Apparently, they revised the -- I think it f
l 17 was the NCR and said use "as-is" and the basis given 18 for this new disposition was, hey, the vendor is i
19 Fisher Controls, and ASME certificate holder, that 20 taey had used their ASME.QA program,.the welding had i
21 been.done by qualified welders usin g ' q ualified I
22
'w el ding procedu r es, specifications, qualified filler l
l 23 materials, et cetera.
l 24 Now, I'm looking at a document in full
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25 knowledge that there are welds attaching these i
TATE REPORTING SERVICE Houston, Texas
( 71.3 ) 222-7177'
58 1
brackets that have got non-fusion and rejectable 2
casings by any standard you want to apply.
3 I was not very happy with'this document.
A 4
question came into my mind that 'there was at least a 5
potential for wrongdoing, a potential.
We learned 6
right in the same time frame that TUGCO had taken a 7
statistical sample of NCR with use "as is",
that 8
type of category disposition, 300 of them; and we 9
learned that one of these valves -- by the way, I 10 think it was something like 62 valves were reflected 11 by this problem.
12 We only saw it on the one, but we learned l
13 by checking ~ it was 62 of these valves'.
We decided 14 that we would lay back in the weeds and see what 15 they did about the NCR disposition.
We wanted to 16 see if they themselves would relook at this thing l
l 17 and say "This is totally non-acceptable."
18 We wanted to get the thing addressed as 19 rapidly as possible.
We made, hopefully, a 20 pragmatic decision and we would go ahead with the l
21 deviation made to us in 50.55(e) and we would hold 22 back on the violation to determine our actions after l
23 we'd seen what they were doing.
24 Once we had the thing up front, we didn't l
25 have any problem.
The subj ect is disappearing, I
~
TATE REPORTING SERVICE Houston, Texas (713) 222-7177 i
59' l
i 1
believe.
We were in full ccgnizance.
1 i
.1 2
Unfortunately, Mr Counsil kind of i
1 3
preempted.us.
First time it's eve'r happened to me.
{
i 4
I've never heard an executive in any organization j
(
s.
t 5
turn to a regulatory board and say, "That sho ul d be i
i
' i I
6 a violation."
l 7
It kind of stunned us a little' bit, but hem l
8 preempted us.
We went ahead and pulled out the l
9 violation and I believe we have a report in process.
I
/
u 10 right now that has both the deviation and the i
/ M1 l
11 violation, but I'm still reserving j udgment on L
12 action until I've seen what they've done on this' l
f, s 13 particular disposition.
, f, 7
14 MR. MULLEY:
I have one more 15 question.
16 A.
Excuse me a moment.
I don't want to 17 interrupt, but this subj ect was fully discusgod in 18 the regional management, who knew exactly whAre we.
J 19 were coming from.
It was not something we we.re
')
20 keeping as a little sleuth endeavor.
1 1
21 Q.
(By Mr. Mulley)
There's another area In 22 the draft inspection report that apparently has to 23 do with a v'olation is concerning Brown
&. Root iudit
. I 24 program?
k-25 A.
Uh-huh.
'4 "th i
TATE REPORTING SERVICE
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Houston, Texas (713) 222j7177
60 o
-1 JOR. MU L L E Y :
I don't want to get
,/
2
'g into thatkNe.cause that's draft inspection.
3 I don't want'to get into the issue y
4 4ther than.to ask there's a again ask,
)
i l
5 7,;
'chey.
Maybelit',3 too general for you to
+
6
, answer.
It's,a draft report; but
,/
7 apparently initially when these findings s.
8 were written up.they were, written up as a
'9 OIolation when'the' inspector was told to 10 make them unregol.ved.
You got involved and lli apparently you replaced Mr. Westerman as i
122 Phillips' immediate supervisor?
13 A.
I may have been in an acting capacity at l$-
that time, George; but, yes,.
15i Q.
You told Phillips_these things should be q
1G' violations, and you; think they should be violations f.
17 instead of unreso1*/ad i'tems.
Did that, in fact, t
'18 happen?
i i
19 A.
Let me think about;that before I respond to t
20 that.
I don't believe th'at that actually happened 21 that way.
22 A.
We had,a scenario where he had established i
r 23 in 197943rawn.4 Root had clearly not live up to its
- }4 ASME code.
We,would quite a bit of discussion about k
25 that.
TATE REPORTING SERVICE Houstoh, Texas (713) 222-7177
l 61 1
I believe I was the one that, thinking 2
about. this issue and.the merits, said to Shannon, 3
"It would be'much more meaningful from 'an assessment 4
point of view to look at the' performance of this "rogram up-to-date."
5 audit p
6 I didn't want to have a citation issued 7
saying Brown & Root didn't live up to their 8
responsibilities in 1979; and it could have been a l
9 valid citation and in terms of, yeah,,they didn't do 10 it and then have a utility write back saying, "Yes, 11 you're right; but h,ere's all the wonderful things we i
12 did.
Just look at this program from 1981 o nw a r"d, "
([
13 something like this; and it would kind of make a i
14 useless citation; however, I don't know how well 15 Brown '& Root had been auditing in the
'80.
So, I 16 did request Shannon.
l 17 Q.
Let me just ask a general question not 18 connected'to any inspection reports.
Have you ever l-19 noticed a tendency on the part of,, Region IV to try 20 and resolve issues with TUGCO on an informal basis 21 where,'you know, Region IV gets together with TUGCO 22 Management, discu'sses the issues, gets a commitment i
23 from TUGCO, and corrects.the problems without going 24 the violation route?
(.
25 A.
I can obviously only speak.in the time TATE REPORTING SERVICE Houston, Texas (713) 222-7177
62 f
frame June and July,
'85, to date.
I can tell you, 2
though, unequivocally, in the time frame I have been 3
there, no, I have never seen Region IV personnel j
4 trying to get informal resolutions of findings,
~
5 never.
6 That would be personally unacceptable to me
)
i 7
as an individual.
I pride myself in trying to be a
)
8 professional, I am proud of my personal inspection 9
history to this organization.
I think anyone that 1
10 knows anything about me would find it unbelievable 11 that I would accept that kind of scenario.
l 12 Q.
(By Mr. Mulley)
So, based on your i
13 experience at Com'anche Peak if a situation is found 14 to be a violation of some requirement, then it is 1
15 written as such.
l 16 A.
That is correct.
I have one qualified
'l 17 statement to that.
I do not believe it is in the 18 NRC's or public's interest to take one isolated 19 piece of information where technically one could 20 make some kind of citation and act that way.
I 21 think one should look at things thoroughly, look at 22 the implications and assess the situation and 23 determine how to structure the citation.
24 What should be the scope of the citation?
\\...
25 That might mean that I w o ul d the request inspector TATE REPORTING SERVICE Houston, Texas
{713) 222-7177
'63 l
l 1
to do further work before we follow t'he citation 2
r.o u t e.
It does not mean that I would ever condone 3
sweeping anything under the rug or doing something 1
4 informal.
That's not the way I think or act.
5 Q.
Have you seen any indication on the part of 6
Mr. Westerman with his review of the reports to l
7 indicate that he is trying to, you know, downgrade 8
violations, make them unresolved items, trying to, 9
you know, get rid of issues?
l 10 A.
No.
I believe-to the best of his ability 11 he was trying to get factual reports that did not i
12 contain subjective opinions.
You've got to be 13 factual.
I do not think it's in the agency's r
\\.
3 14 interest to write any kind of citation which is l
15 s ubj e ctive. de bate, no matter by whom.
16 You do not achieve anyth'ing.
We have to be 17 o bj ective and factual at all times.
That's my 18 position.
It will always be my position.
I believe 19 that's fairness, due process, everything you want to 20 say.
21 Q.
So, in your opinion, if there's an issue 22 that is deb.atable or that we can perceive with a 23 licensee to come back and successfully rebut the 24 violation, do you feel it is encumbant on the NRC to
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25 get their act together before we issue the violation TATE REPORTING SERVICE Houston, Texas (713) 222-7177
i 64 I
)
1 versus issuing the violation and having the licensee 1
2 respond why they did wh.at th'ey d.id?
^
3 For example, let me just throw out the 4
in process records or records being co-mingled.
5 A.
Uh-huh.
6 Q.
Where apparently an argument could be made 7
that they're not records but documents that are in 8
process.
We have had debates in.the NRC whether or 9
not these are records of documents.
10 Do you feel that it's a good practice for 11 NRC to issue the violation and have the licensee 12 come back and make that argument to us that these 7
la are, in fact, in process documents and not records?
(.
14 A.
I'll respond as an individual, which is all 15 I can do'.
I do not speak for NRC.
Only the 16 commissioners can do that.
17 I would say to issue a violation being full 18 aware that there was debatable aspects would be 19 inexcusable and in violation of my understanding of 20 the enforcement policy of this agency.
21 I would expect Jane Axlerod and her staff 22 to jump on us with both feet.
We do not write 23 opinions as citations.
I think it would be totally 2,4 and utterly inexcusable.
25 Q.
So, something like this, y o.u feel it would TATE REPORTING SERVICE
.Housbon', Texas (713) 222-7177
65 1
be acceptable to write an item as unresolved until 2
we came across a consensus within ourselves as to 3
whether or not 4
A.
What is an unresolved item?
The official S
terminology today which, by the way, has altered 6
historically is an issue where the NRC needs more 7
information to determine whether a violation or 4
8 deviation exists historically which isn't clearly 9
shown by the manual chapter.
I don't know if it i
10 ever was.
l 11 Most inspectors look at an unresolved item l
l 1
l l
12 as a subj ect where they believe a violation or j
1 i
13 deviation exists, but because of circumstances -- be k
)
(
14 it the records are not at the site or they're at 15 some other location --
- t. hey can't make the final 16 determination to prove that there's a violation or 17 deviation.
There's really not that much difference.
18 I believe an unresolved item is the I
19 prescribed vehicle where there are issues that you information drom others before 20 might need input or l
21 you make a determination.
22 Q.
One question having to do with Shannon 23 Phillips.
You have not been present when 24 Mr. Westerman has discussed inspection findings with l
k 25 Shannon and witness Mr. Phillips and/or Mr. Phillips TATE REPORTING SERVICE Houston, Texas (713) 222-7177
,l
66 1
and Mr. Westerman, you know, debate these issues?
l 2
Were you present during these discussions?
3 A.
I will say it w o ul d be cohrect for me to 4
say in general I was not present..
I would not 5
preclude that there might have been'some b
6 conversation about a particular issue at some. point; 7
but in general, I was not present.-
i 8
Q.
Okay.
That's all I have now.
If you would 9
like to add something before we close out the 10 record --
11 Q.
(By Mr. Goldberg)
I have one last issue.
12 This might have been before your time of your 13 involvement at Comanche Peak as to what modules were 14 or were not covered over a period of time, i
15 particularly QA modules such as the inspection of 16 the QA at TUG CO, for example.
I 4
17 Did you want to comment on that at all in i
18 terms of, you know -- first of all, we were told 19 that you're filling out 766 information for your l
20 people.
As I understand, this is what we were 21 told.
J 22 We're trying to look at 766's.to determine 23 if certain modules were completed, how they were.
i 24 completed, and whether they were B modules or C 25 modules, that kind of thing?
TATE REPORTING SERVICE l
Houston, Texas (713).222-7177 hm N
e 53 1
A.
Obviously I wasn't at Comanche' Peak prior 2
to June of 1985.
So, obviously I cannot speak with
's that the 766 3
any s p,e cif i c a t i o n.
All I can say i
4 vehicle is a somewhat flawed vehicle.
5 I don't think there's been correct 6
understanding by inspectors and I can give you a 7
story about my current difficulties in completing
)
8 these forms but I would not personally make any 9
judgment about what was done or what wasn't done i
10 without really analyzing where was the inspection 1
11 program on a given point in time.
I 12 The IE 25-12 program has not exactly been l
r-13 cast in concrete for many,.many years.
It has been l
1-
{
14 a dynamic program and thing in constant change.
l 15 Well, logic tells you that if you keep making 16 changes in programs this will o bv io u sly impact on 17 what has been done in the past.
c 18 I don't have any specific j udgment, but I 19 w o ul dn ' t make a judgment until I had looked at l
20 programs at a point in time, what was required and 21 all that scenario.
l 22 Q.
Getting to today's time frame, when you l
l 23 fill o u't a 766 when something is completed, is it 24 based upon the inspector's coverage of the 23 inspection requirements of that module or based on
)
)
TATE REPORTING SERVICE Houston, Texas (713) 222-7177
l gg l
1 some other criteria?
2 A.
Let me try and explain my involvement 3
currently with 766.
Through.the January report, 4
1986, we were issuing -- I'll call it an integrated
~
{
5 inspection report in that there were appendices 6
addressing operations inspection, construction 7
' inspection, Comanch Peak response team inspections; 8
and I learned that the system really wasn't designed 9
to handle all of these diversities in a 766.
10 It was never dreamed of at the time the l
11 program developed that that kind of approach would 12 go on; but, in essence, the operati'ons and 13 construction inspections, the senior resident j
14 completes that information including status, 15 presents it to me.
It's a j udgments call.
{
15 That's his responsibility to determine how l
17 far along he perceives they are on a given 18 inspection module.
I
\\
19 I handle the Comanche Peak response team l
20 totally differently in that the Comanche Peak 21 response team inspection to my knowledge la a unique 22 endeavor from an NEC point of view.
23 To my k ncwl edge, the NRC has never devoted 24 resources of the magnitude they do at Comanche Peak k-25 to do this ongoing massive surveillance and l
l TATE REPORTING SERVICE l
Houston, Texas (713) 222-7177 l
.gy i
1 reinspecting program.
2 There's nothing in our guidance that even 3
addresses something, nor would you' expect Eo ~ have 1
4 guidance.
We're talking about something unique.
We 5
are looking at a program prepared by a utility-6 because of ongoing questions, including the SLB j
7 questions, to assess how well the plant is built, I
8 does it comply with the Committee's code and l
9 standards is it safety si gnifi'ca nt.
10 In a nutshell, we're looking at something 11 that's. unique.
I found no way readily of addressing 12 that in a 766.
I al s o found that a 766 was kind of 13 us.eless less to me if you place any credence at all f(
14 in the significance of hours of inspection.
l 15 I co ul dn ' t use it accurabely.
Actually, in j
16 the absence of any guidance, I decided I would use a 17 particular inspection modu'le with a number 92705; 18 and that, in essence, is a n um be r that all it means 19 is regionally requested inspection.
l 20 It's a reactive inspection.
We are 21 certainly doing reactive inspection now.
1 22 Unfortunately, the hours we have invested every 23 month is usually in excess of 2,000 man-hours of 24 effort by consultants and the permanent NRC staff.
k' 25 The form only allows me to charge 999 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.801195e-4 months <br /> TATE REPORTING SERVICE Houston, Texas (713) 222-7177
70
~
l 1
maximum.
So the system is forcing me to log in a 2
fraction of what we're actually doing.
So what is i
3 the value.of that.
Make your own determination.
I 4
tried to enter the same number multiple times so I l
5 can get the hours.
I got it thrown back at me.
You i
6 can only enter it once.
1 7
We've done so much work, so much l
8 inspection, an order of magnitude certainly much 9
greater than the order.of magnitude to relative to 10 IE inspection modules.
l 11 We've done physically so much more work 12 than traditionally NRC would ever do at a site.
I l
13 wonder how can I use the work and take credit and 1
14 how can I reflect this inspection report in our 15 regular program.
l 16 I'm going to look at can I legitimately 17 just add hours into given inspection modules, not i
18 changing the status of them necessarily; but I want 19 our official records to reflect this efforts.
20 I still hive not reached a final 21 determination on how I'm going to do it.
22 Q.
(By Mr. Mulley)
On the 766, just one 23 comment, if you put down an inspection module, is it 24 reasonable for a reviewer to go back to that
(
j 25 inspection report and see the inspection activities l
TATE REPORTING SERVICE Houston, Texas (713) 222-7177
71-I 1
on that module documented in the reports?
2 A.
Is it reasonable to expect that?
3 O'.
It is reasonable to hope'?'
4 A.
I obviously cannot speak for actual 5
performance of all reviews in this region-or in this 6
agency.
I think that a supervisor certainly should 7
look at 766 via or versus the reports; but I could 8
think of several scenarios where the two'could get 9
separated or the 766 got generated later, i
10 I personally think the situation where I've 11 been involved in the last year where, since I was 12 the guy that put this p,ackage together,-that 13 sometimes I'm somewhat late putting that thil.3
-~
14 together.
I was the 766 preparer.
15 It is reasonable to hope that someone would 16 check a 766 against the report.
It is also not 17 unreasonable to expect that from time to time -- and-18 I wouldn't speculate on frequency -- that perhaps it i
19 doesn't get done.
20 Q.
So, if I were goihg tothy to make an 1
21 assessment of the status of various inspection
)
22 modules and. procedures, 766 wouldn't be a 23 trustworthy place to go?
I would have to go beyond 24 that to get an accurate I
25 A.
I think the 766 is probably the only real l
TATE REPORTING SERVICE l
Houston, Texas (713) 222-7177 1
1
yg i
i f
1 vehicle one would have.
See, George, you have to i
2 put in other factors into the equation.
We do not 3
separate inspection programs with io'cked in assigned 4
people over.a historical, time span.
You get 5
different individuals for whatever reason.
There's'
{
6 all kinds of reasons one could get assigned to pick 7
up on a-given module.
You gets errors created in I
8 that sometimes.
9 I think some inspectors have said, "You
{
l 10 have given me the module.
Was there any work ever 1
11 done on the thing before?"
They started from ground 12 zero again.
13 So, you get all these strange anomalies 14 that cloud the issue; but in terms of what other 15 vehicle is there, the only other vehicle is called l
l 16 personal communicate.on.
17 Inspectors it wouldn't be reasonable to i
18 have the time to start doing historical reviews of l
19 reports, collective reports of periods of years.
20 We really, I think, place a great onus of 21 responsibilities on the senior resident to know 22 where the inspection program is at.
He's t.he only i
23 person that can over a period of time go through the 24 whole thing and learn, " Hey, this hasn't been
(#
25 addressed" or "This is still shown at some TATC REPORTING SERVICE
^
Houston, Texas (713) 222-7177
73 1
percentage."'
l 2
Probably the only viable mechanism we have 3
to date is to rely heavily on the senior-resident.
4 Since the senior resident program was created, I 5
think, in 1979 or so and I was assigned to the plant 6
that broke ground in, say, early
'75, I'm afraid I
'7 can't say much more than that.
8 Q.
If you have anything that you would like to 9
add before we close out the record, you may.
10 A.
Yeah, I think I would like to say a few I
i 11 wordo.
I find it regrettable that there's a need 12 for you gen'tlemen to be here.
13 I find that personally regrettable and 14 sad.
I wish that if an individual or individuals 15 had had real concerns or have real-concerns, that 16 they had followed the prescribed oute.
There has 17 b.een a gen cy policy -- I forget the exact. year -- for l
1 13 several years about different professional opinions; l
19 and I know that Chairman Hollis Dean is a proponent c
20 of of this.
21 I can remember from my vendor days of a i
22 centleman who had a differing professional opinion.
l 23 He followed the prescribed route.
His concerns were l
24 reviewed by an independent panel of his peers.
25 It came out of the IE and NRR, and they TATE REPORTING SERVICE Houston, Texas
'(713) 222-7177
.s L
- 74 1
1 disagreed with his particular concerns; b'ut it was 2
handled while'they told him why they had reached the 3
con cl u s ion they did; and that was hhe end of the
)
4 matter.
5 I just find it totally regrettable that 6
this scenario had to come to pass.
I don't 7
understand why it came to pass, to be honest with 8
you.
9 With regards to Mr. Westerman, I will have 1
10 to say -- I believe my personal judgment is that he 11 tried at all times to communicate and to do the job l
12 as a prudent manager s h o ul d.
It doesn't mean that 13 he was perfect.
I'm not perfect.
We're all flawed l
14 in some respect or'other.
j 15 I would personally never accept any 16 contention that Mr. Westerman was trying to suppress i
17 a citation in any way.
That's my personal belief.
18 If I felt he was trying to suppress 19 information, be it a citation or whatever, I can l
20 assure you I would have taken violent exception to j
21 him and gone the prescribed route personally.
22 I just will never accept any. contention 23 that he acted improperly in any way.
I believe he l
24 tried to live up totally to his responsibilities as
\\'
25 an NRC supervisor.
I think his interests was that TATE REPORTING SERVICE Houston, Texas (713) 222-7177
^
75
'l the reports be totally factual, that we can stand.
2 totally behind them.
3 I certainlyLdid-'not-want personally to b'e 4
associated with any report that's going to be_
N 5
submitted to the ASLB to become part of the hearing i
6 process if I co ul dn ' t stand behind1the report.
I 7
did not think that would be right.
8
~The stand of ethics have is'such that no 9
matter whether-there was and ASLB or not, I will.not 10 accept writing s ubj ectiv e citations as a correct 11 practice, nor do I believe the IE guidance would 12 allow us toldo ~ that.
13 That's about all I-have to say.
14 (Statement concluded at 1
15 12:50 a.m.
C.D.T.)
l 16 l
17 18 19 20 j
21 1
22 23 24 t
kJ 25 TATE REPORTING SERVICE Houston, Texas (713) 222-7177
76 1
STATE OF TEXAS 2
COUNTY OF HARRIS 3
4 I,
Trisha Sims, a certified shorthand reporter and notary public, in Harris County for tho 5
State of Tuxas, certify that the facts stated in the caption hereto are true; that the witness named 6
herein personally appeared before me and, after being by me first carefully cautioned and sworn to 7
tell the truth, was examined by counsel for the respective parties hereto; that the testimony of 8
said witness was taken down in shorthand by me, later reduced to. typewriting under my direction as a 9
true and correct record of the testimony.
~
10 I further certify that I am neither attorney or counsel for, nor related to or employed 11 by, any of the parties to the action in which this statement is taken and, further, that I am not a 12 relative or employee of any counsel em pl oy e d by the parties hereto, or financially interested in the 13 action.
c i
14 G.IV EN UNDER MY HAND AND SEAL OF OFFICE on this the 26th day of' July, 1986.
15 16 M
C/
Notary Public in and for 17 Harris County, T E XA S 18 Certification Number:
2035 19 Date of Expiration of Current certification:
12/31/86.
20 21 22 23 24
'(_ -
25 TATE REPORTING SERVICE Houston., Texas (713) 222-7177
w N*I'74" U h,
Af" =
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{
N A.l ! 40-N A. : 220 SECTION III, DIVISION 1 - SUBSECTION NA NA Il40 EFFECTIVE DATES OF CODE the nuclear power plant to be constructed in ac.
EDITIONS, ADDENDA, AND cordance with this Section.
CASES.
NA-1200 GENERAL REQUIRE 31ENTS (a) Code Edi: ions become mandatory on July I of FOR AND DEFINITIONS OF the publication year printed on the cover. Addenda ITESIS AND INSTALLATION may be t sed on and after the date ofissue and become maindatory six months after the date c issue.
r NA 1210 COMPONENTS (b) Code Cases may be used begmning with the date of approval by the ASME Council and, being Thgf a nuclear power plant include permissive, do not become mandatory. Only Code items sucn as, vesse pumps, valves, Cases that are specifically identified as being 'ap-and storage tanks.
nent shall bear the m -
plicable to Section 111 may be used for construction in required Code N type Symboli and Manufacturer's accordance with this Section.
Data Reports shall be prepared for them (NA 3370 i
fc) The Code Edition. including Addenda, which3 j
mandatory on the contract date for a mmn-a ll and NA 8400). The Installer of such components or determine the mandatory rules for the, mar >qfact.utt any associated appurtenances shall complete Data l
a Report Form N 5 which serves to indicate that each
)
mstallation of; that cptnptnent.,, including its component or appurtenance assembled into the and matenals, parts, and appurtenances. Earlier editions nuclear power plant and the installation meet the j
shall not be used except to meet the requirements.of requirementsof thisSection.
i Section XI for alteration. modification. renewal.
=
replacement. or spare components, parts. or ap-purtenances.
i NA 1220 MATERIALS the mandatory rules for manufacture and installat on of core support structures and component supports Materials are manufactured to an SA, SB, or SFA J
including their materials. Earlier editions shall not be -
i used.
Specification 5 or any other material specification permitted by this Section. Such matenal shall be (c) Tbc contract date for an entire nuclear power systr does not govern the Code Edition. Addenda, manufactured and certified in accordance with the
~
ases applicable to the components, core support requirements of this Section. Materials produced and structures, and component supports.
under an ASTM designation may be accepted as l
(f) Code Editions, Addenda,and Cases which have complying with the corresponding ASME spec-not become mandatory on the contract date for a ification provided the ASME specification is des.
i nated as being identical with the ASTM spec-component may be used by mutual consent of the I
Owner 1 or his agent and Manufacturer 8 or Installer 3 ification for the grade, class, or type produced and on or after the dates permitted by (a) through (d) provided that the material is confirmed as complying above. It is permitted to use specific provisicns within with the ASTM specification by a Certified Materials Test Report or Cernfication from the Material an Edition or Addenda provided that all related l
requirements are met.
Manufacturer. Welding material produced under an
(
(g) Caution is advised when using Addenda or AWS designation may be accepted as complying with the corresponding ASME specification provided the Cases that are less restrictive than former re-latter specification is indicated to be identical with the quirements without having assurance that they are AWS specification and provided the welding material acceptable to the enforcemen authorities having jurisdiction at the nuclear plant site.
is confirmed as complying with the AWS specification (h) The Owner or his agent shall obtain a Cer-by a Certified Matenal Test Report or Certification from the Materials Manufacturer.
tificate of Authorization (NA 3230 and NA 8240) prior to th-fieldinstallation (NA 1250)of any item of
- The terts N type symbol rneans any one of the symbols shown in Figure NA.82201
,See NA.3210 for definiuon cf Owner.
SSA or 18 Spedicauons hsted under 'he headmg Bars. Rods.
8See NA.3310 for delmiuon of Manufacturer, Shapes. Argmgs : nay be used as matenal for any of the product 3See NA.3410 for definsuon of Installer.
forms even thout a not all product forms are listed in the SA or SB Specificacon.
4 e
i
t M
M J
y&
l l
OF SECTION !!!
N A 1230-N A.1273 each component support or group of component supports for each component shall be furnished by the i
5-requiredin NA 8000.
Manufacturer. Da.ta Reports and Stamping sh.dl be as l
NA 1231 Parts Parts have work performed on them requiring the NA 1260 APPURTENANCES AND presence of or verification by an Inspectort and are PENETRATION ASSEMBLIES furnished to a component Manufacturer by other Manufamrers, or by the same component Man-NA 1261 Appurtenances ufacturer under a different Certificate of Au-theorization (NA-8113) than that applying to the An appurtenance is an item similar to a part (NA-component. By definition, a part is attached to or 1230) which is attached to a completed and stamped beco nes a part of a component before completion component. The design conditions for appurtenances and stamping of the component. The Design Spec.
shall be included in either the component Design ifications (N A 3250) and Stress Report (NA-3350) for Specification (NA-3250) or in a separate Design l
componeno shall apply to the parts of such com-Specification. A Stress Report (NA 3352) for each ponents. Data reports and stamping shall be as appurtent.nce or group ofidentical appurtenances for requiredin NA 8000.
each component shall be furnished by the ap-i purtenance Manufacturer if not included in the 1
l NA 1232 F1 ping Subassemblies
, component Stress Report. The Owner, directly or through his agent, shall be responsible for the overall sa correlation of the component and appurtenance
,.! k). g
[
Stress Reports (NA-3260). Data reports and stamping shall be as required by NA-8000.
- g. The Design Specifications (NA-3250) and NA 1262 Penetration Assemblies stress Report (NA 3350) for the piping system shall apply to the piping subassemblies of that system. Data Penetration assemblies are defined as electrical or reports and s tamping shall be as required in N A-8000.
mechanical parts or appurtenances required to permit piping, mechanical devices, or electrical connections, NA-1240 CORE SUPPORT STRUCTURES to pass through the pressure retaining beundary of a component.
l Core Support Structures are those structures or parts of structures which are desi ned to provide.
NA-1270 MISCELLANEOUS ITEMS 6
direct support or restraint of the core (fuel assemblies) j within the reactor vessel. Core Support Structures NA-1271 Control Rod Drive Housings require Des:6n Specifications (NA 3250) and Stress Report (NA 3350). Data Reports and Stamping shall Control rod drive housings a:tached to a reactor be as required in NA-8000.
vessel shall be considered in the Design Specifications as a vessel part or appurtenance or as a separate
.fA1250 COMPONENT SUPPORTS _
vessel. The rules of Subsection NB shall apply to those portions of the housings formin6 a pressure retaining Component supports are those metal supports boundary.
which are designed to trummit loads from the
,~
l pressure-retaining barrier'of the component to tne NA 1272 Hester Elements i
load-canying building structure. The design con.
ditions for component supports shall be included in That portion of heater elements forming a pressure either the component Design Specifications (NA.
retaining boundary of a nuclear power system shall be 3250) or in a separate Design Specification A Stress considered in the Design Specification either as a part l
Repo+t or Load Capacity Data Sheet (NA 3352) for or an appurtenance.
cach component support or group of component supports for each component shall be furnished by the NA 1273 Fluid Conditioner Devices Manufacturer of the component or the component That portion of a fluid conditioner device such as a l
support. Data Reports and stamping shall be as filter, demineralized, trap, or strainer which forms the requiredin NA 8000. _,_,,,_
5
,,g m. _
i
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. w a-.
aM
}rn sM, Ch / c:&r k.{ y 1
t ARTICLE NB-6000 TESTING NB4100 GENERAL REQUIREMENTS (2) When componen:s, appurtenances, or sys-NB4110 TESTING OF COMPONENTb, tems, wM am not na@y M am to W W 6 APPURTENANCES,AND
' ' *E * "* #*"
g tolerated and, whenever possible, the parts of the components, appurtenances, or systems have been NB4111 Conoponents and Appurtenances Previously hydrostatically tested to the pressure requiredin NB 6220.
l NB4111.1 HydrostaticTesting (b) A pneumatic test at'a pressure not te exceed 25 (a) @ J gqqgnungsum p" " -
psi may be applied, preliminary to either a hydrostatic l
N or a pneumatic test, as a meant of locating major l
l jn the presence of the b-leaks. If used, the preliminary pneumat.c test shall be spector. Nuts, bolts nuds, and gaskets are exempt carried out in accordance with the requirements of from hydrostatic testing.
NB-6300.
(b) The hydrostatic test of each line valve and pump with inlet connections over 4 in. ncmmal pipe NB4112.1 Precautions to be Employed in Pneu-size shall be witnessed by the Inspector and a data matic Testing. Compressed 5as is hazardous when used as a testing medium. It is therefore re-
)
hy os e tes o h e valve and pump commended that spedl precautiot s for protection of with iras piping connections of 4 in. nominal pipe size Personnel be taken when a gas underpressureis used and smaller shall be performed by the Manufacturer as test medium.
l and so noted on the data report form (NA-8400);
however, this hydrostatic test need not be witnessed NB4113 Testing of Systems t
by the Inspector. The Inspector's review of the NB-6113.1 Hydrostatic Testing. Prior to initial Manufacturer's test records will be his authority to operation, the installed nuclear energy system shall be sign the report and takes precedence over NA 5280.
hydrostatically tested except as permitted in NB-NB-6111.2 Pneumatic Testing. When a hydrostatic 6113.2 in the presence of the Inspector. The test shall test is not practical (NB4112), a pneumatic test, in be conducted in accordance with the requirements of NB-6200.
l accordance with NB-6300, may be substituted.
NB-6113.2 Pneumatic Testing. When a hydrostatic NB4112 When Pneumstic Testing may be test (NB-6112)is n6t practical, a pneumatic test, in Used accordance with NB-6300, may be substituted.
(a) Pneumatic tests may be used in lieu of the NB4114 Time of Hydrostatic Tests of Parts, hydrostatic test required by NB-6111.1 and NB4113 Piping Subassemblies, and Materials except as permitted in (b) below, only when the gay { g gggg g g.g g.f following conditions exist:
(1) When components, appurtenances or sys-q,gj;g,nts' g ggOfNB 627ttsystmutemcoeptable as stesth tems are so designed or supported that they cannot be m
g y
safely filled with' water;t u
wr we wmponent or appurtenance hydrostatic iThese tenu may be made with the item bems testcJ paruany riued test when conducted in accordance with the re-with wuer. it desired.
quirements of NB-6221 may be used in lieu of any 205 e.--
4
l
,M/
t thf j
f NB4000-TESTING NB4212-NB4223
('c) For the vessel hydrostatic test before in-abhiuens,The syste desien pressure shall be es-stallation,it is r: commended that the test be made et a tablished in accordance with the rules of NB-7411.
temperature not lower than RTypt + 60 F (see NB-(b) All pressure retaining components of the 2331).
completed system t, hat are within the boundary protected by the overpressure piotection devices NB4213 Check of Test Equipment Before which satisfy the requirements of NB 7000 shall be
{
Applying Pressure subjected to a system hydrostatic test at a pressure not ne test equipment shall be exammed before less than 1.25 times the system design pressure. The Pressure is APP ed to ensure thatitis tight and that all system design pressure. for the protected boundary li shall be established m accordance with the rules of I
low pressure filling lines and other appurtenances that 2
NB-7411*
should not be subjected to the test pressures have been t
g disconnected or isolated by valves or other suitable means.
c mPonent can & repaired Qwehg,
)
if requ! ired as a result of the system hydrostaue tes
(
NB4215 F.nmin= don for Leakage After Applicadon of Pressure accordance with the rules of NB-2500:
4 Following the application of the hydrostatic test (2) The component repair can be postweld heat pressure for a minimum of 10 min. (NB4224),
treated, if required and nondestructively examined in exammation for leakage shall be made of alljoints, accordance with rules of NB-2500, and NB-5100 as l
connections, and of all regions of high stress such as applicable, subsequent to the system hydrostatic test; regions around openings rad thickness transition (3) The component is subjected to minimum section;. Except in the case of pumps and valves, required system hydrostatic test following the com-which shall be examined while at test pressure, this pletion of repair and examination.
examination shall be made at a pressure equal to the greater of the design pressure or % of the test pressure, and it shall be witnessed by the Inspector.
NB4222 Maximum Permissible Hydrostatic Leakage of temporary gaskets and seals, mstalled for Tm h e the purpose of conducting the hydrostatic test and which will be replaced later, may be permitted unless (a) The stress limits specified in NB-3226 shall be the leakage exceeds the capacity to maintain system used in determining the permissible hydrostatic test test pressure for the required amount of time. Other pressure. In multichamber components, pressure may leaks, such as from permanent seals, seats, and be simultaneously applied to the appropriate adjacent gasketed joints in components, may be permited chamber to meet these stress limits. He number of when specifically allowed by the Design Spec-test sequences for which the above provisions may be ifications. Leakage from temporary seals or leakage considered applicable shall not exceed ten.
permitted by the Design Specification shall be (b) When hydrostatically testing a system, the test directed away from the surface of the component to pressure shall not exceed the maximum test pressure j
avoid masking leaks from otherjoints.
of any component in the system.
l ll NB4220 HYDROSTATIC TEST PRESSURE NB4223 Hydr' static Test Pressure for Pumps o
REQUIREMENTS and Valves, and for Components and Appurtenances Containing Brazed j
NB4221 Minimum Required Hydrostatle Test Joints i
Pressure l
Prior to installation, pumps and vajves and other (a) Except as may be otherwise required by components and appurtenances containing brazed material specifications (NB4114). samensusemash joints shall be hydrostatically tested at a pressure 1.5 i
gnd appurtenances except those containing times the system design pressure as determined by the orazed joints._pu.mpt and valves alallbe ceteng rule of 14B4221(b). except that in the case of valves l
^^
a.
p designed in accordance with NB-3531. t w rules of i
NB-3531.2 shall apply.
l 207 7
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